THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


ROCKY FLATS
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Hebron, Kentucky on April 


19, 2007. 

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C O N T E N T S
 

April 19, 2007 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


WORKING GROUP UPDATE 12 


SC&A REPORT 17 


NEUTRON ISSUES 33 


THORIUM 152 

DATA COMPLETENESS 202 


’69 – ’70 252 


COWORKER MODELS 258 


WOUND ISSUE 268 


PROOF OF PRINCIPLE 270 


COURT REPORTER’S CERTIFICATE 280 

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TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


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


an unintentional or purposeful interruption of a 


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


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


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


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


"uh-uh" represents a negative response. 


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


without reference available. 


-- “^”/(inaudible)/(unintelligible) signifies 


speaker failure, usually failure to use a microphone. 

 

 

 

4

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


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

GIBSON, Michael H. 


President 


Paper, Allied-Industrial, Chemical, and Energy Union 


Local 5-4200 


Miamisburg, Ohio 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


MUNN, Wanda I. 


Senior Nuclear Engineer (Retired) 


Richland, Washington 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 

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IDENTIFIED PARTICIPANTS
 

ALBERG, JEANETTE, SEN. ALLARD 


BARKER, KAY, ANWAG 


BARRIE, TERRIE, ANWAG 


BOLLER, CAROLYN, CONG. UDALL 


BRACKETT, LIZ, ORAU 


BROEHM, JASON, CDC WASHINGTON 


BUCHANAN, RON, SC&A 


CHANG, CHIA-CHIA, NIOSH 


ELLIOTT, LARRY, NIOSH 


FALK, ROGER, ORAU 


FITZGERALD, JOE, SC&A 


HILLER, DAVID, SEN. SALAZAR 


HOFF, JENNIFER, ORAU 


HOLEN, BILL, CONG. PERLMUTTER 


HOMOKI-TITUS, LIZ, HHS 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAUT 


LABONE, TOM, ORAU 


LANGSTED, JIM, ORAU 


LITTLE, CRAIG, ORAU 


LOPEZ, TERESA, ORAU 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MCFEE, MATT, ORAU 


MINKS, ERIN, SEN. SALAZAR 


NETON, JIM, NIOSH 


PHELEN, CHRIS, CONG. LAMBORN 


RAFKY, MICHAEL, HHS 


SEWELL, JESSICA, CONG. DEGETTE 


SHARFI, MUTTY, ORAU 


SMITH, MATTHEW, ORAU 


ULSH, BRANT, NIOSH 

 

 

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P R O C E E D I N G S


 (9:30 a.m.) 

(Court Reporter’s Note: The following transcript 


contains intermittent drops of speech due to 


telephonic transmission problems. This is indicated 


by the “^” symbol.) 


WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO
 

DR. WADE: This is Lew Wade and I have the 


privilege of serving as the designated named 


federal official for the Advisory Board. And 


this is a meeting of a work group of the 


Advisory Board. This work group is looking at 


issues related to the Rocky Flats site profile 


and the Rocky Flats SEC petition. The work 


group is chaired by Mark Griffon, members 


Gibson, Presley, Munn. Griffon, Presley and 


Munn are here in the room. 


Mike Gibson, are you with us on the 


telephone? 


MR. GIBSON (by Telephone): Yeah, Lew, I’m 


here. 


 DR. WADE: Ray, you’re ready to begin? 


Let me begin by asking if there are 

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any other Board members who are not members of 


this work group who are participating in this 


call? Any other Board members participating 


in this call? 


 (no response) 


 DR. WADE: That’s important because we don’t 


have a quorum of the Board which we cannot 


have and conduct this meeting. 


What I’d like to do is go through 


introductions, and I’ll do that by just going 


around the table here. Then I’ll ask for 


other members on the telephone of the NIOSH 


and ORAU team. I’ll ask for other SC&A 


participants. I’ll ask for other workers, 


worker reps, members of Congress or their 


staffs, other federal officials who are on the 


call by virtue of their employment, and then 


anyone else who would like to be identified. 


For the members of the Board and the 


NIOSH/ORAU team and SC&A I would ask you also 


to identify whether or not you have conflicts 


relative to the Rocky Flats site. 


So I’ll begin. This is Lew Wade. I 


serve the Advisory Board. I also work for 


NIOSH. 

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MR. ELLIOTT: Larry Elliott, NIOSH, I have 


no conflicts. 


DR. NETON: Jim Neton, NIOSH, no conflicts. 


 MR. PRESLEY: Robert Presley, Board member, 


no conflict. 

 MR. SHARFI: Mutty Sharfi, ORAU team, no 

conflicts. 

 DR. LITTLE: Craig Little, ORAU team, no 

conflicts. 

DR. ULSH: Brant Ulsh with NIOSH, no 


conflicts. 


 MS. JESSEN: Karin Jessen with ORAU team, no 


personal conflicts. 


 MS. HOFF: Jennifer Hoff with the ORAU team, 


no personal conflicts. 


MR. BUCHANAN: Ron Buchanan, SC&A, no 


conflicts. 


MS. HOWELL: Emily Howell, HHS. 


MR. GRIFFON: And Mark Griffon with the 


Board, no conflicts. 


MR. FITZGERALD: Joe Fitzgerald with SC&A, 


no conflicts. 


MS. MUNN: Wanda Munn, Board member, no 


conflicts. 


 DR. WADE: Those are the people in the room 

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at the moment. Let me go out now and ask for 


other members of the NIOSH/ORAU team to 


identify themselves and to identify if they 


have any conflicts on this site. 


MR. RAFKY (by Telephone): Michael Rafky, 


HHS, no conflicts. 


MR. FALK (by Telephone): This is Roger 


Falk. I’m with ORAU, and, yes, I have 


conflicts. 


MS. BRACKETT (by Telephone): Liz Brackett 


with the ORAU team, no conflicts. 


MR. SMITH (by Telephone): Matthew Smith 


with the ORAU team, no conflicts. 


MR. LANGSTED (by Telephone): Jim Langsted 


^, I have conflicts. 


MR. McFEE (by Telephone): Matt McFee with 


the ORAU team. I have no conflicts. 


MS. LOPEZ (by Telephone): Teresa Lopez with 


the ORAU team. I have no conflicts. 


 DR. WADE: Other members of the NIOSH/ORAU 


team? 


MR. LaBONE (by Telephone): This is Tom 


LaBone. I have no conflicts. 


 DR. WADE: Other members of the NIOSH/ORAU 


team? 

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 (no response) 


 DR. WADE: Members of the SC&A team? 


DR. MAURO (by Telephone): John ^ with SC&A, 


I have no ^. 


 DR. WADE: John, you cut out on us. Could 


you please repeat? 


DR. MAURO: John Mauro with SC&A, no 


conflicts. 


DR. MAKHIJANI (by Telephone): This is Arjun 


Makhijani, no conflicts. 


 DR. WADE: Any other members of the SC&A 


team? 


 (no response) 


 DR. WADE: Other federal employees who are 


on the call by virtue of their employment? 


MR. BROEHM (by Telephone): Jason Broehm, 


CDC. 


 DR. WADE: Other federal employees? 


MS. CHANG (by Telephone): Chia-Chia Chang, 


NIOSH. 


 DR. WADE: Other federal employees? 


 (no response) 


 DR. WADE: Workers, worker reps, members of 


Congress or their staffs? 


MS. BOLLER (by Telephone): Carolyn Boller 

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with Congressman Udall’s office. 


MR. HILLER (by Telephone): David Hiller 


from Senator Salazar’s office. 


MS. MINKS (by Telephone): Erin Minks from 

Senator Salazar’s office. 

MR. HOLEN (by Telephone): Bill Holen from 

Congressman Perlmutter’s office. 


MS. SEWELL (by Telephone): Jessica Sewell 


with Congresswoman DeGette’s office. 


MR. PHELEN (by Telephone): Chris Phelen 


with Congressman Lamborn’s office. 


MS. ALBERG (by Telephone): Jeanette Alberg 


with Senator Allard’s office. 


MS. BARRIE (by Telephone): Terrie Barrie 


with ANWAG. 


MS. BARKER (by Telephone): Kay Barker with 


ANWAG. 


 DR. WADE: Other workers, worker reps, 


members of Congress or their staffs? 


(no response) 


 DR. WADE: Is there anyone else on the call 


who would like to be identified for the 


record? 


 (no response) 


 DR. WADE: Anyone else who would like to be 

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identified for the record? 


 (no response) 


 DR. WADE: Okay, let me just do a little bit 


of a discussion of phone etiquette. Again, 


we’re getting better at this. Please, if you 


are going to speak, speak into a handset and 


not a speaker phone. If you’re not speaking, 


and you have the ability to mute the 


instrument then please do that. Be mindful of 


background noises, babies crying, dogs 


barking. If you put the phone on hold, and 


you know that there’s background music played 


when you do that, don’t do that. Again, it’s 


important that we observe those simple rules 


so these meetings that are terribly important 


can be as inclusive as can be of people who 


want to participate and hear the 


deliberations. 


Mark, it’s all yours. 


WORKING GROUP UPDATE
 

MR. GRIFFON: I did put out a short agenda. 


I hope everyone received that. And basically 


as an introduction I think our main goal here, 


and we’re coming down to the wire, is to be in 


a place where we can have a vote in the May 

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meeting, the May Advisory Board meeting. And 


at this point we have, we have received SC&A’s 


report although there’s going to be a 


supplement to that report. 


But I think I’d like SC&A to kind of 


go over their report, just the executive 


summary. I think there’s five primary points 


in the executive summary, just to give us a 


perspective on sort of what’s left out there, 


what the main conclusions of SC&A’s report 


are. 


And I think as Joe probably is going 


to say, a lot of the primary points lead into 


the subsequent agenda items that I have down 


here. So maybe we won’t get into the full 


discussion of those, but this is kind of an 


overview of where we’re going. 


I think today the most detailed 


discussion is probably going to be around the 


neutron questions and obviously that’s been 


the, or maybe not so obviously, but since the 


last work group meeting I think there’s been a 


lot of activity around the questions on the 


neutron dose data, the NDRP report. And just 


as an introduction here, I mean, I think 

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everybody was working diligently on these 


action items. 


And part of the reason this comes up 


now as a big issue is because we received some 


actions, some outstanding actions from NIOSH, 


SC&A received those. And as they did analysis 


on some of those, you know, it raised 


questions and it raised questions about the 


NDRP report itself. So we had some 


spreadsheets that were sort of provided as 


actions, outstanding action items that we had 


for the neutron questions and that led into 


some further discussion on the NDRP report 


itself. 


And for those that don’t know, in 


between the last work group meeting I think we 


had two technical calls, was it? Right? 


MR. FITZGERALD: Two calls. 


 MR. GRIFFON: We had two technical calls 


between SC&A and NIOSH. I was on both those 


calls on and off actually, but I was on part 


of both those calls. And a lot of that had to 


do with, we had Roger Falk on the phone 


basically asking about the NDRP report itself, 


how the NDRP research was conducted, some 

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background on that just to get a sense of what 


in this database we were looking at. 


Also since the last meeting, and this 


all came out of that last action, too, I had 


asked, since there were questions on the 


spreadsheet I asked Brant can we just have the 


NDRP database posted itself. The action items 


before that were actually based on claimant 


data, NDRP data but claimant data only. And I 


said can you just provide the entire NDRP 


database on the O drive so we can have a look 


at all the data instead of just claimant data. 


And Brant did post that. 


So then when we started looking at 


that full database that raised some questions. 


And we thought we don’t want to delay this. 


We want to keep things moving. Let’s see if 


we can get Roger on the phone and ask some 


questions about what these different data 


columns mean, how they came to the conclusions 


they did in that report. And so Brant was 


nice enough to set up these two technical 


calls, and we had that happen in between the 


work groups. 


And also just last point of 

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introduction and then we’ll get into the 


meeting, both these calls we did have full 


minutes taken. They’re pretty in-depth 


minutes of the calls, and they will be 


available as attachments to SC&A’s supplement 


report on this neutron question. I don’t know 


if they -– 


Lew, have they been, they haven‘t been 


reviewed yet or circulated at this point. So 


for those on the phone you haven’t seen these, 


but there are detailed minutes of these calls, 


not transcripts, but detailed minutes. So we 


want to make sure that everyone knows exactly 


what was discussed on these calls. Really, we 


did these in a non-work group setting just to 


keep, to expedite, to keep this moving on 


course for the May meeting. And that was the 


driver behind that. 


Anyway, I think I’ll go into the items 


and let Joe Fitzgerald from SC&A give us an 


overview on their report, and then we’ll go 


into the in-depth questions, the neutron-


thorium, data completeness, et cetera, on the 


agenda, if that’s okay. 


Questions? 

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 (no response) 


MR. GRIFFON: Joe? 


SC&A REPORT


 MR. FITZGERALD: Good morning, this is Joe 


Fitzgerald. I am the SC&A lead for Rocky 


Flats. You now have the draft report that 


we’ve been working on for some time, and Mark 


mentioned, I guess, five issues which we 


summarize in the executive summary to that 


draft report. That certainly isn’t 


necessarily the scope of the issues that we 


addressed in the report as you will see by 


reading the executive summary and going 


through it. 


We have done quite a considerable 


amount of effort to try to resolve and 


converge on a number of these concerns. And 


certainly issues like high fired plutonium 


oxide. We’re concerned about measuring that, 


the concern about the reliability and the 


integrity of the data itself. These are all 


issues that we treat in quite a bit of detail 


and have spent a considerable amount of time 


with NIOSH in this working group to reach 


resolution. 

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So what we’re focused on at this 


particular meeting, and what we’ve been 


focused on for the past several weeks and will 


be focused on until the meeting, is addressing 


the issues which we feel, frankly, are either 


not resolved yet, meaning that even through 


all these efforts, we still have some 


remaining concerns, or we feel there is 


legitimate concern about the adequacy of the 


data or its completeness. So we’re certainly 


beyond issuing this draft also addressing with 


this work group and NIOSH these remaining 


issues. 


And the five issues, and these are 


outlined I think in the draft that you have. 


Certainly, Mark mentions the neutron question. 


This has been a longstanding question that 


we’ve been concerned about since the middle of 


last year because of the uncertainties 


incumbent on, and this is not just Rocky 


Flats, this is really across the Department of 


Energy complex in the 1950s. 


Certainly, the technology was 


evolving, and the ability to, in fact, measure 


neutrons was evolving as well. So our concern 

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with the so-called early years, the 1950s into 


the early ‘60s, was the ability to estimate 


those neutron doses where, in fact, you might 


have gaps in the data or the technology had 


not caught up yet. 


And for Rocky Flats the concern that 


we were focused on was the so-called back 


extrapolation which is a fancy way of saying 


if you don’t really have all of the neutron 


exposure data for, say, the 1950s in this 


case, specifically 1952 to ’58, the approach 


that’s evinced in the NIOSH model -- this is 


in their coworker model -- was to back 


extrapolate to apply the values, in this case 


the neutron/photon ratio values of 1959 


backwards to those years and to apply them. 


And we certainly had questions about 


their concerns and wanted to see that data, 


the individual information for the workers 


involved and to understand the basis for that 


approach. And that basis, of course, as Mark 


mentioned, is rooted in the NDRP, the Neutron 


Dose Reconstruction Database, which Rocky 


applied. 


And we did get this data finally in 

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March and have spent, I think, considerable 


effort to understand how that’s used and to 


understand whether there would be any issues 


in terms of using that for this specific 


purpose, understanding that that time was used 


certainly to come up with a better means of 


measuring neutrons. We’re looking at it in 


the context of how effectively and adequately 


it could be used for the purpose of dose 


reconstruction. And we’ll get into that in 


greater detail since that’s certainly a 


foundation concern for us at this point.
 

MR. GRIFFON: I’m not sure, just one 


clarification. We’ll get into details later, 


but I think that back extrapolation from ’59 


was actually in the NDRP project, not in 


NIOSH’s coworker model. 


DR. ULSH: Well, it was in the NDRP. That 


was the original source, but it was adopted.
 

MR. FITZGERALD: And certainly in looking at 


the NDRP, as we indicated in the draft report, 


we’re also looking forward into the 1960s as 


well just trying to understand how that 


circumstance may change and whether there 


would be any similar concerns getting into the 

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early ‘60s, understanding this wasn’t a 


stepped function, that certainly the situation 


evolved over time at Rocky Flats. So we’ll 


get into that in more detail. 


Certainly, the other issues that are 


identified in the report are probably ones 


that are familiar with certainly others on 


this phone call. We looked at the 


completeness of the database. I think we made 


a lot of headway, frankly, in terms of 


establishing what, in fact, was complete but 


where there may have been gaps in a couple of 


instances for in particular 1969 and ’70. 


The work group asked SC&A to focus on 


the observed prevalence of zeros that were 


assigned to a number of workers at the site, 


and we did so, and I think with NIOSH 


established that there was, in fact, a badging 


policy where some of these badges were not 


read and zeros were assigned. I don’t think 


there’s any, frankly, disagreement there. 


NIOSH has, and we can certainly touch on this 


later after we get through neutrons, but has 


offered a revision of this coworker model, 


OTIB-58 which is the external coworker model 

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which has removed in a sense those zeros as a 


way of addressing, at least in a preliminary 


way, addressing this question of assigning 


zeros in the absence of badges being turned 


in. So certainly, that’s been progress. 


Now the other issue that we’re looking 


at that’s identified in the report is non-


plutonium workers, in this case specific to 


Building 441, where --


DR. MAKHIJANI (by Telephone): Four-fourfour. 


MR. FITZGERALD: I’m sorry, 444, Arjun, 


where we believe that there are still some 


concerns as to whether there is a valid 


coworker model which would address those 


specific workers at that facility. And we can 


touch on that in a bit as well. 


The remaining two issues are ones 


where I think we did spend a considerable 


amount of time trying to establish whether the 


analyses and the model provided in the NIOSH 


report were, in fact, bounding of the doses 


that might be presented. One was the case of 


thorium use at Rocky Flats, and there I don’t 


think there’s any disagreement that there may 

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be sufficient data to, in fact, use it to 


bound historic thorium doses. 


I think the issue that remains is 


whether the model approach that NIOSH has 


adapted which is provided in NUREG-1400, 


whether that has been demonstrated to be 


necessarily bounding. And I think we feel 


there’s some concerns left there that bear 


further resolution with NIOSH. And we do 


think that there is, in fact, some data, 


available data, that could be applied, but we 


have not seen evidence that the current model 


is necessarily bounding. 


The final issue is one that also we’ve 


addressed from the standpoint of being able to 


demonstrate whether, in fact, the approach is 


conservative which is in OTIB-38 which is the 


internal coworker model. We still have 


concerns about whether anything but a 95th
 

percentile or higher, which is a statistical 


approach where conservative fit for 


distribution is applied, would be sufficient 


to address the uncertainty that is incumbent 


in that database. And so we’re concerned 


there whether, in fact, in practice the more 

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conservative approach would be applied in 


those cases. 


And we’re also aware that, of course, 


for Rocky Flats the number of unmonitored 


workers for which a coworker approach for 


internal dose will be applied is relatively 


small. But nonetheless we feel it’s important 


to go ahead and raise that issue. 


Given the spectrum of information and 


issues that we did include in the report I 


think just the fact that we’re at this point 


where we have these specific questions left I 


think is still a considerable amount of 


progress, but we feel that these aren’t quite 


resolved, and we need to address them before 


we can actually have closure on the 


evaluation. 


So with that do you want to --


MR. GRIFFON: No, I think, I mean, that’s a 


good overview. I don’t think we want to go 


into any of those points in depth right here. 


If we could hold questions until we get to the 


specific items, I think that would be a better 


process. 


MS. MUNN: Mark, I have one question. This 

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is Wanda. Joe, do I understand that there is 


going to be a supplement to this report before 


May, but that that supplement will not, will 


it or will not, address any of these issues to 


the extent that they can be considered 


resolved? 


MR. FITZGERALD: Well, I think the 


supplement is just that, that if we can reach 


closure on any of these other issues, we 


certainly would want to acknowledge that in 


the supplement. I think the supplement will 


be a snapshot by next week of where we stand 


on the remaining issues, these remaining five 


issues. Now clearly, I think the thrust, 


major thrust, of the supplement is going to be 


the neutron issue just because that probably 


had the most to be addressed in the way of 


actual data analysis. 


But certainly, for example, the 


issuance of OTIB-58 with the recognition of 


the ’69-’70 issue is certainly one 


possibility, and we would want to certainly 


look at that and acknowledge whether that 


satisfies that particular issue. That would 


be an example that we would put that in the 

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supplement as well. So the supplement I think 


will be sort of the, if you may, the final 


written word in addition to the draft report 


as to what we were able to achieve in the last 


four or five weeks. 


MS. MUNN: And hopefully here today. 


MR. FITZGERALD: And hopefully here today. 


In fact, that’s the timing of the supplement 


which is to reflect everything up to and 


including today and have it available by next 


week to enhance the meeting. 


 DR. WADE: Can you be more specific, Joe, 


about when actually, I’m just trying to make 


sure that the Privacy Act --


MR. GRIFFON: I know. The timing is 


critical. 


 DR. WADE: Especially right now. 


MR. FITZGERALD: I guess in terms of 


pinpointing a day, Arjun, are we able to plus 


or minus a day or two? 


DR. MAKHIJANI (by Telephone): Well, what 


we’ve done almost all of the digging on the 


neutron question in terms of the data. As you 


know, Joe, some of the writing is done, but it 


hasn’t been checked or QA’d or anything, and 

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there’s a lot there. I think, oh, goodness, 


Thursday of next week? Wednesday --


MR. FITZGERALD: The concern is the Privacy 


Act review on the --


DR. MAKHIJANI (by Telephone): Yes, what I’m 


thinking, what I’m thinking is if we can 


prepare a report that has no names in it or a 


summary at least that has no names in it, but 


that can be maybe with your permission and 


with Emily and Liz agreeing, circulate it. 


And then whatever pieces that may have 


names in it or individuals mentioned other 


than, you know, we’ve had these conversations, 


of course, with Roger that are expert 


conversations that are essentially public 


conversations, what he’s going to say today 


or, you know, what he said on those calls as 


experts which I understand are allowed. 


Except for those, I think we can keep 


names out of the report. Maybe just publish 


the report, send the rest of it for Privacy 


Act review like the spreadsheets. And I 


don’t, that might be a way to proceed that 


might put things in the hands of the Board and 


the petitioner rapidly. 

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MS. HOWELL: Arjun, this is Emily. 


Obviously, as usual, if you have something put 


together the Board members and members of the 


OCAS and ORAU teams can see that, but we 


cannot make anything public on the OCAS web 


page or available to the Congressional 


staffers, who I’m sure are very interested in 


this, until a full privacy review has had time 


to take place. Can anybody give me a rough 


estimate of how large you anticipate this 


document being? 


DR. MAKHIJANI (by Telephone): I had a 


question about that. Privacy Act review is 


necessary even if it has no names in it? Or 


no individual, no names and no -- I just want 


some clarity because this is something that we 


revisit quite a bit, and that’s not my 


understanding of my instructions from our 


project manager at SC&A. Is that if there’s 


no individual data and no individual names and 


no workers that --


MS. HOWELL: Arjun, we can discuss that 


offline perhaps. I think that it doesn’t 


necessarily sound like this supplement will 


have no Privacy Act information in it. I 

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mean, like I said, it can go to the Board 


members who obviously need the most time to 


spend with it prior to the meeting, but --


MR. FITZGERALD: I guess from the standpoint 


of back engineering this, and we’ll talk this 


through in offline work with the work group, 


but it sounds like we should aim to enable 


NIOSH to post this for the Congressional 


delegations and petitioners by a week from 


this Friday I would think as at the minimal, 


which would mean that back engineering from 


that we would need to get it to General 


Counsel by --


MS. MUNN: Tomorrow. 


MS. HOWELL: Well, how, do you have any, can 


you estimate a page number for me? I need to 


know how much. 


MR. FITZGERALD: I think that certainly it’s 


going to be about 25, 30 --

DR. MAKHIJANI (by Telephone): Fifty pages. 

MR. FITZGERALD: Fifty pages. 

MS. HOWELL: That’ll be fine. If you could 

give us 48 hours from the time that, 48 hours 


not including a weekend, 48 hours on week 


days. 

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MR. FITZGERALD: Okay, it does look like 


we’re talking middle of next week at the very 


outside. So we’ll have to talk about that and 


make it happen. I mean I certainly with a 


meeting coming up there’s no ground to make it 


later than that. So I think we’re talking 


about no later than Wednesday to get it --


MS. HOWELL: Close of business Wednesday. 


MR. FITZGERALD: -- to get it to General 


Counsel to enable it to go out on Friday. 


DR. ULSH: Can I make a request? When you 


send it to General Counsel, also send it to 


me. 


MR. FITZGERALD: We’ve been trying to do 


that. 


DR. MAKHIJANI (by Telephone): But some 


pieces of paper you already have that are the 


two -- I don’t know if you have them, Emily --


but certainly NIOSH, OCAS and the working 


group has them because Brant and I sent them 


out, two pieces of the minutes of the 


conference calls with Roger. And also, I 


understand three spreadsheets, Joe? 


MR. FITZGERALD: Yeah, listen, we don’t have 


to solve all this. 

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DR. MAKHIJANI (by Telephone): Okay. 


MR. FITZGERALD: But certainly, as we did 


with the main draft of the report, we will 


make available as many pieces of that report 


in advance to General Counsel and to Brant as 


possible. And that way you’ll have a head 


start on this. By the time you get the 


finished product on Wednesday next week, you 


would have seen maybe half of it hopefully. 


 DR. WADE: It’s a plan. 


MR. GRIFFON: Yes. 

MR. ELLIOTT: Could I ask a question for 

clarification? Joe, in your delivery of the 

executive summary what I did not hear were 


specific words that go to whether one of these 


five issues or all five of these issues are 


SEC related or are they a mix of site profile 


issues and SEC issues? Can you clarify that 


for me? 


MR. FITZGERALD: Yes, these would have what 


we believe would be SEC implications from the 


standpoint in some cases of, not so much 


whether the approach seems to have sufficient 


data, which is normally one test of something 


with SEC significance, but it comes down to 

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demonstrating that, in fact, an upper bound 


can be established with the data. 


And that’s a little bit of a variant 


in that we think the approach seems to be 


adequate. We do believe that in general 


there’s enough data, but we have not crossed 


the T to actually see a demonstration. Or if 


there was a demonstration, and this gets to 


the NUREG-1400, we feel the results were 


equivocal, meaning that there were some sense 


that some of the calculations were not 


bounding. 


So we wanted to be very complete in 


terms of the issues where even though we felt 


the approach was adequate, we felt that in 


general there was enough data, we were still 


concerned that we never got to the point of 


seeing an upper bound demonstrated which would 


be, I think, the final step in that. 


And there’s two or three instances in 


that where we felt that was the case. And I 


think we’ve kind of indicated that in that 


language in the report that certainly that was 


the context of providing that. 


MR. ELLIOTT: Thank you. 

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 DR. WADE: For the record the judgment 


relative to the Board’s vote will be the 


Board’s judgment as to whether these are 


issues, and then it will go on to the NIOSH 


Director and the Secretary. Those are where 


the judgments really need to be made. 


NEUTRON ISSUES
 

MR. GRIFFON: Okay, and I think we also 


prioritized these items as we often do, 


frontloaded the, at least what I think have 


higher SEC implications on the front of this 


agenda, so with that in mind I think we should 


go right into the neutron question. Again, 


I’m not sure if I can describe in enough 


detail, I didn’t write enough detailed notes 


out here, but we had, as Joe indicated, we had 


some outstanding neutron questions that were 


action items for several months, probably six 


or seven months out. And NIOSH had been 


working on these issues, and I think it was 


probably what, three weeks ago, four weeks 


ago? 


MR. FITZGERALD: About four weeks ago. 


MR. GRIFFON: Four weeks ago when the data 


was provided on some of this. One thing I’m 

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remembering is an Excel spreadsheet which 


examined the question on the N/P ratios that’s 


some paired data that Ron had requested to do 


some of his follow up, and that was provided. 


And that led to some further questions of, on 


the N/P ratios themselves but also then we 


realized that the data provided was on 


claimant data. 


So we asked, and Brant provided the 


NDRP database on the O drive, and we actually, 


it raised more questions on the actual NDRP 


database. And I guess that’s what led to 


these two technical calls. So just with that 


backdrop I think I’d ask Joe to sort of frame, 


there’s a lot of, for those of us who were on 


the technical calls, there’s a lot of details 


and twists and turns in understanding the NDRP 


project. Just when I think I have a handle on 


it I found out something new that I didn’t 


necessarily know what was going on. 


So the background was very useful for 


us to understand, but for the sake of this 


work group though I think it would be useful 


if, Joe, you can sort of frame preliminary 


conclusions and sort of a brief description of 

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your basis for those. Of if you want to do it 


or if Arjun’s going to do it, but rather than 


get into, we got into very specific 


discussions on everything from quality control 


of the NDRP Project to some very specific 


issues within the NDRP Project, I’d rather at 


least give us sort of the big picture right 


now. And then as we need to go into some of 


the details we can, but I think that’d be a 


way to start this off. 


MR. FITZGERALD: Yeah, and Arjun Makhijani 


and Ron Buchanan, Ron’s here and Arjun’s on 


the phone, I think have been the two 


principals in revealing the NDRP database, 


looking at this particular issue. And I’d 


like to defer to, I guess, Arjun. 


If you can just give that overview, 


Arjun, as opposed, at first, as opposed to 


maybe getting into maybe the nitty gritty at 


this point, but certainly just to put things 


in perspective. 


DR. MAKHIJANI (by Telephone): Sure. 


Basically, in looking at the NDRP, we’re 


looking at -- and Roger, you can jump in and, 


you know, put a nuance on the facts if I’m not 

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getting them exactly right. We’re looking at 


the workers who are considered at risk of 


plutonium exposure in the ’52 to ’70 period. 


And because not everyone was monitored 


or those who were monitored had some gaps in 


the different periods, those gaps were filled 


by certain methods that were developed in the 


NDRP and then an estimate of neutron dose was 


made for each individual worker which is in 


their dose file. And when there’s a claim, 


then that’s the thing that is used. 


In understanding the NDRP we’ve split 


it up into three broad periods: ’52 to ’58, 


’59 to ’66, and ’67 to ‘70. There are some 


kind of sub-periods within those, but ’52 to 


’58 is when there wasn’t very much monitoring. 


Up to ’56, Los Alamos was doing it. They had 


these glass track badges. They issued 20 per 


badge cycle, and all of them were issued in 


one building, Building 91. And Building 71 


where there was also plutonium work was not 


monitored at the time. So everybody has kind 


of a calculated dose in Building 71 in the ’52 


to ’58 period. 


‘Fifty-seven and ’58 Los Alamos was no 

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longer doing the issuance of the badges and 


the reading. There was a private contractor 


and those badges were not mostly recovered for 


re-reading. Part of what the NDRP did was to 


re-read, recover as many of the original 


dosimetry records’ badges and re-read them. 


And up to ’66 at least the original readings 


were generally found to be systematic 


underestimates. And then those underestimates 


were sought to be corrected in the NDRP. 


And unfortunately, for ’52 to ’58 


there’s not very much data so the vast 


majority of workers who were at risk of 


plutonium exposure have assigned doses, and 


they are not assigned basically from the data 


of the time because the data of the time are 


very sparse. They’re back extrapolated from 


neutron/photon ratios from 1959. And so there 


are a number of problems with that. 


First of all there’s an assumption 


that you can multiply a gamma dose by a 


neutron to photon ratio from a ^ back 


extrapolate that. There are two assumptions 


in that. One is that neutron dose is 


proportional to gamma dose, relating to a 

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building. And the second assumption is that 


essentially the working conditions in relation 


to both the neutrons and photons were about 


the same for workers in buildings even though 


you’re back extrapolating. 


And when we looked at it, we found 


that in the period when you looked at the 


doses -- and also we were told by NIOSH that 


the highest, the workers at highest risk of 


exposure or judged to be at highest risk of 


exposure were badged in the ’52 to ’58 period. 


So we did a check of various of these 


conclude ^ NIOSH, and we couldn’t verify many 


of them. For instance, the assigned doses 


which are the calculated doses, not the 


measured doses, were often bigger than the 


measured doses which were supposed to be of 


workers most at risk in some years. And in 


some years it was not the case. So in ’53 the 


top ten exposed workers to neutrons were all, 


all had measured doses so the NIOSH assertion 


is clearly correct for that year. 


But in ’55 and ’56 the top ten, and 


more than ten actually, workers were in 


Building 71 where there were no measurements, 

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and also they were all assigned doses of 


calculated doses which were calculated as best 


estimates with some claimant favorable 


factors. So it’s not at all clear that the 


most exposed people were badged. So there’s 


no way to actually validate what is being done 


with these assigned doses and back 


extrapolation. 


Also, it appears that when you do 


scatter plots of either the original doses or 


re-read doses, it doesn’t appear that in the 


measured doses there is a very good 


correlation between gamma and neutron doses in 


the period. We haven’t yet finished the 


statistical work. This is just a kind of 


visual inspection. 


So there are actually a number of 


issues with respect to that. ^ that arose is, 


can the calculated doses be validated in some 


way to be bounding or to relate to the working 


conditions by, say, area measurements of 


neutron dose or similar data from the period. 


And we were informed by Roger that the 


NDRP tried to find such data to validate the 


calculations for the ’52 to ’58 period but 

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could not. And we also have not been able to 


find it. So we have a lot of concerns about 


this. There’s also finally some indications 


that job types to affect neutron/photon 


ratios, ^ some locations where gamma doses are 


high and neutrons are low and vice versa, you 


can have neutron doses but zero gamma dose. 


And there is not really a serious 


analysis of job types and neutron to photon 


ratios. Although in a pilot study that was 


analyzed in a master’s thesis, so the only 


real reference on neutron to photon ratios in 


the NDRP, such an analysis was recommended. 


So for the ’52 to ’58 period it seems 


difficult to characterize the calculated NDRP 


doses as bounding doses based on the available 


information. 


MR. GRIFFON: Arjun, do you want to go 


through each time period and then we’ll take 


questions or do you want to stop at this 


point? 


DR. MAKHIJANI (by Telephone): Whatever your 


preference is. 


And finally then also, you know, the 


NDRP report does say that the notional doses, 

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these doses that are calculated, they’re 


calculated in two ways, but the doses that are 


calculated from neutron to photon ratios are, 


quote, somewhat speculative. And we discussed 


this with Roger on one of the calls, the call 


actually day before yesterday, and you have 


his statement in there, and I might just read 


it so I’m not mischaracterizing it in any way. 


He said that “I agree that notional 


doses are basically estimates and they are a 


best shot at calculating the dose. They are 


more speculative the farther back we 


extrapolate. So the 1952 to ’58 period would 


be the more speculative part. As you get more 


and more film in the 1960s, the second method 


of using the average neutron dose as the 


estimator of the notional dose becomes more 


important. Then notional dose becomes less 


and less speculative. 


And we would agree with that, and so 


the ’52 to ’58 period really has, relatively 


speaking at least, the most speculative 


components in it and also not well 


characterized by the data. I could go on to 


the other periods if you like, Mark. 

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MR. GRIFFON: Just briefly, describe the 


other periods and then let’s go back. I think 


’52 through ’58 will be a long discussion, but 


I think just the sense that the issues change 


in the different time periods. 


DR. MAKHIJANI (by Telephone): Yeah, they do 


change. 


MR. BUCHANAN: Could I make a clarification 


before we go on? Arjun stated that you could 


have neutron dose and no gamma dose, and I 


want to clarify that. That means that the 


gamma dose could be low, below the detectable 


limit, and in the database that we looked at, 


here is zero. That was changed to one so you 


wouldn’t have to divide by zero, and then your 


neutron dose would be some value. And so what 


to clarify that the gamma would be below the 


detectable limit and the neutron would be 


above. 


DR. MAKHIJANI (by Telephone): Thank you, 


Ron, yes. Zero means below the LOD. 


MR. GRIFFON: Okay, go ahead on to the next 


time period, Arjun. 


DR. MAKHIJANI (by Telephone): The next time 


period is useful to consider also in two sub­
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periods: ’59 to ’64 and ’65-’66. And it’s 


clear in looking at the data that more and 


more people were badged. And starting from 


’59 there were people who were badged, well, 


in this period there were people who were 


badged basically by the end of the period in 


all the plutonium buildings. 


^ and by the end of the period it’s 


very clear to see that the workers at highest 


risk were the ones who were being badged so 


you can see this very clearly in 1966 if I 


remember right. ^ look at whether the 


assigned doses are higher or the measured 


doses are higher. The measured doses are 


consistently higher. 


That’s not the case in the early 


period. Also, in the early period not all the 


badges were recovered for re-reading, and so 


you have a kind of peculiar problem wherein 


this period you had considerable systematic 


underestimates of dose in the original 


readings. I’ll give you an idea. These are 


not QA’d so they may change, but the re-read 


dose could be several times or an order of 


magnitude bigger than the original dose. 

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Roger, am I characterizing that 


correctly? 


MR. FALK (by Telephone): Arjun, based on 


the conflict of the interest rules, I’m not 


able to really participate in this --


MR. ELLIOTT: No, you can answer the 


question. He’s asking you a direct question, 


and you can answer it. 


DR. MAKHIJANI (by Telephone): Yeah, just 


asking for your recollections so I’m not 


mischaracterizing it for the working group 


here. The re-read doses in the ’59 to ’66 


period were often many times greater than the 


original readings. 


MR. FALK (by Telephone): Yes. 


DR. MAKHIJANI (by Telephone): Up to an 


order of, maybe an order of magnitude bigger? 


MR. FALK (by Telephone): That is a 


possibility. 


DR. MAKHIJANI (by Telephone): So in this 


period when we looked at the data, we found 


that quite a lot of more systematic 


underestimates, say, than in the Los Alamos 


period where there were also underestimates, 


or in the later 1960s period where they had 

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gone back and tried to read the badges more 


carefully. 


One of the problems here is that not 


all of the badges were recovered. And so 


there was a portion of the original readings 


that could not be re-read. And the NDRP 


decided that they could not correct a badge 


reading that they could not find. So they 


simply added the original badge reading which 


is very likely to be a systematic 


underestimate to the re-read dose. 


So now you have a final neutron dose 


that has three components: an assigned dose 


which is calculated to fill the gaps when 


there was no monitoring, a re-read dose from 


the badges that were recovered and re-read, 


and then a component from the badges that were 


not recovered and not re-read which is as best 


as we know known to be in substantial error 


and statistically speaking very, very likely 


to be in substantial error and an 


underestimate. 


So now we’ve got a final dose estimate 


that is very difficult to characterize as a 


bounding dose in those cases where the badges 

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of the workers were not all recovered. Now 


that particular problem varies from year to 


year. In some years almost all the badges 


seem to have been recovered. In other years 


there were maybe 15 percent of the original 


reading could not be re-read because for some 


reason the badges were not available. And so 


there are significant numbers of workers whose 


badges could not be recovered. 


Also, not everyone was monitored, and 


we did check in this period whether the most 


at risk were monitored, and we found that up 


to 1964 many of the workers who had completely 


assigned doses from neutron to photon ratios, 


a hundred percent, were among those who had 


the highest doses. So we could not verify 


that the highest risk workers were actually 


being monitored in this period, and in fact, 


there’s evidence to the contrary. 


That’s not the case for ’65 and ’66 if 


I remember correctly. And all of this 


analysis is in process, and I’m giving you the 


best status based on what we’ve done so far. 


We also tried to check whether the NDRP 


notional dose is a best estimate compared to 

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the measured dose. 


So we took one randomly selected 


worker from Building 71 and one from Building 


91 for each year from ’59 to ’64, and we 


pretended that they didn’t have a neutron 


measurement even though they did, and 


calculated it by the NDRP method and then 


compared it to the measured dose. And for 


Building 71 it was less than the measured dose 


in all cases. In two cases it was in the 90 


percent. But in four out of six cases it was 


substantially less than the measured dose. 


And Building 91 --


MR. GRIFFON: Arjun, one second, is this 


Table 2 that you --


DR. MAKHIJANI (by Telephone): No, it’s in 


the --


MR. GRIFFON: In Ron’s spreadsheets though, 


didn’t --


DR. MAKHIJANI (by Telephone): In Ron’s 


spreadsheets I don’t know. 


Ron, will you say which spreadsheet it 


is from because I’m not looking from your 


spreadsheet. 


MR. BUCHANAN: I think it’s four, but that’ 

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not --


DR. MAKHIJANI (by Telephone): Yeah, it 


hasn’t been published yet because this hasn’t 


been QA’d yet. This thing needs a check, and 


so I’m giving you the numbers that we have so 


far that could be changed, but I’m giving you 


the best judgment. 


MR. GRIFFON: Just to step back from that 


for a second, Arjun, because there was some 


shaking heads on this one so I just want to 


clarify. I think you took one individual from 


each year from each building, 71 and 91, 


right? 


DR. MAKHIJANI (by Telephone): That’s right, 


so there are ten individuals. 


MR. GRIFFON: And where they had a period of 


measured dose, they summed the measured dose, 


and then they basically said, okay, let’s 


pretend that this person wasn’t monitored. 


And according to Table 11.1, is it? 


DR. MAKHIJANI (by Telephone): Yes. 


MR. GRIFFON: You would use the photon dose 


to use that factor to calculate a notional 


dose and said, okay, how does a notional dose 


compare for that time period to the actual 

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measured dose for that individual and see if 


it was, in fact, a bounding approach, right? 


Is that --


DR. MAKHIJANI (by Telephone): Right, and/or 


a best estimate approach. In a best estimate 


approach it should be comparable because the 


bounding can then be calculated by applying a 


variant. 


The question that is being asked here 


in this analysis, is there some factor that 


could be creating systematic underestimates of 


neutron dose in the NDRP notional dose 


assignments as they are calculated from 


neutron to photon ratios? And the answer 


indicated in this analysis, and we chose 


workers who had at least six months of neutron 


monitoring, who had six months and 12 months 


of neutron monitoring, for this. 


And we found that in 10 of 12 cases 


that the answer was less than the measured 


dose. The notional dose was less than the 


measured dose -- four, five, six, seven cases 


it was considerably less than the measured 


dose. That is more than ten percent less than 


the measured dose. The lowest value was 22 

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percent of the measured dose. So this test of 


the adequacy of the neutron notional dose to 


be comparable to the measured dose was not 


successful. 


The other problem that we found was in 


the validation of the re-reading which becomes 


more important in this period. It was found 


that the people who were re-reading the badges 


were tending to under read the actual dose and 


correction factors were developed for each 


individual reader because it tended to vary by 


reader and their experience. 


And the correction factors were 


essentially developed assuming that one 


reader, who was Roger Falk, had, as he 


described, was the gold standard, that he had 


the perfect reading. Now his reading was 


never independently that statistically very 


difficult, as independent of the quality of 


his reading. Everybody’s going to have some 


error, and those errors were not 


characterized. 


And so all of the re-reading was 


calibrated against one person’s, a one person 


reading. Now there was some validation 

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exercise which was done against badges that 


Roger, himself, has had calibrated. 


MR. HOLEN (by Telephone): This is Bill 


Holen with Congressman Perlmutter’s office. ^ 


any comparative analysis of the difference 


between the contractor’s badge reading and 


those that were done by the government in the 


early ‘50s? 


DR. MAKHIJANI (by Telephone): Well, the 


NDRP, itself, was that comparative analysis. 


The government’s readings, especially up to 


1966 were found to be systematic 


underestimations. And the NDRP, and that was 


found to be so at the time as you’ll see from 


the minutes of the 17th April conference call 


is one or 12th April. 


One of the reasons that a review of 


neutron doses was undertaken in 1967 was that 


-- by Roger -- was that the earlier dose 


readings were found to be not of adequate 


quality, and so they decided to read the ones 


of those considered at highest risk more 


carefully so that they would cut down on the 


errors. And they did succeed in that. 


They didn’t eliminate all the errors, 

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but the percentage error markedly decreased in 


1967 to ’70. And so that goal was mostly but 


not fully accomplished. So the government’s 


readings were not sound from the time so 


that’s why the badges were re-read. 


MR. HOLEN (by Telephone): Thank you. 


MR. GRIFFON: Arjun, can you give us a brief 


description of that last time period then? 


Are you --


DR. MAKHIJANI (by Telephone): Yeah, the 


last time period we actually haven’t finished 


all of our looking at all the data so there’s 


quite a bit of work remaining to do. And part 


of the reason that there is so much work 


remaining to do is that we did not understand 


until the last few days that there had been 


significant changes in the neutron dosimetry 


program in 1967 in that fewer badges were 


read, but they were read more carefully. And 


so we have to take a look at that period. 


We did verify that they were read more 


carefully. Almost all the badges were 


recovered in ’67, but in ’69 and ’70 the 


badges were not archived, or at least some of 


the badges were not archived, and so not 

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available for re-reading. And so there’s 


quite a few gaps in terms of the re-reading. 


At least in 1970 only 48 percent of the 


original dose was re-read. And in 1969 82 


percent was re-read. 


Now the significance of those gaps may 


be less in this period because of the quality, 


improved quality, of the readings since the 


indicated errors in the cumulative dose are 


lower. And also in this period, I think from 


the mid-‘60s -- and we haven’t been able to 


pin down the date yet -- but from the mid-‘60s 


most of the gaps are not filled by the neutron 


to photon ratio method, but they’re filled 


from looking at the worker’s own nearby dose 


in the badged periods which is a more reliable 


method of filling gap and more normal 


certainly corresponding to other practices of 


filling gaps in a worker’s dose. 


MS. MUNN: Arjun, this is Wanda. I 


apologize for not having been able to be on 


that phone call on the 19th . Perhaps this 


would be more -- I mean on the 17th -- I might 


be more clear. But I’m a little confused 


about a couple of things that are being said, 

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and I’d appreciate some help clarifying it for 


me. 


For one thing the question was asked, 


and I’d like to define terms a little bit 


here. The question was asked about the 


differences between badge readings from the 


contractor as opposed to by the government. 


Now to me the government incorporates all 


kinds of agencies and I guess I’d like to be 


very clear about what we’re talking about when 


we say government readings as opposed to 


contractor readings. 


And the other question that I have for 


you, which I think is a simple one, you talk 


about variances of as much as an order of 


magnitude difference. When we talk about an 


order of magnitude difference, are we talking 


about the difference between 20 millirem and 


200 millirem or are we talking about the 


difference between 200 millirem and 2,000 


millirem? 


DR. MAKHIJANI (by Telephone): Well, let me 


take the second question first because it is 


simpler. The cases would vary by worker and 


by reading. So sometimes you’d be in the 40 

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to 400 millirem or 40 to 100 millirem, and 


sometimes you would be from a couple of 


hundred millirem into two millirem. 


The doses do go up into the several 


rem range. The doses are in the thousands of 


millirem for the most exposed workers. So the 


re-readings do materially change the doses for 


many workers. For the most exposed workers 


certainly they put them into significant dose 


levels. 


MS. MUNN: And since I have not seen the 


tables with which you’ve been working, the 


spreadsheets that I guess Ron put together, 


how many actual individuals, how many doses 


are we talking about per year? You spoke in 


terms of having looked at various years, but 


I’m trying to identify how many actual 


individuals were incorporated in those two, so 


far you’ve talked about two separate time 


periods. 


DR. MAKHIJANI (by Telephone): Three 


actually. 


MS. MUNN: Well, yeah, but primarily you 


talked about pretty much the ‘50s and pretty 


much the ‘60s. 

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DR. MAKHIJANI (by Telephone): Right. 


MR. BUCHANAN: Hey, Arjun, do you want me to 


address that? 


DR. MAKHIJANI (by Telephone): Sure, please. 


MR. BUCHANAN: In the ’59 to ’64 era, we’re 


talking one to 2,000 annual doses. And in the 


’65 to ’69 era we’re looking at just about 


2,000 doses per year, workers. And if you 


looked at how much the original dose that was 


not re-read compares to the, if you was to 


adjust it, say, you went in and adjusted it 


like you did the other re-reads, some years it 


would not have much effect on the overall dose 


and some years it would increase it by 50 or 


100 percent. 


It would increase it some years, 


double it, if you went in and made the same 


adjustment to the non-re-read as you did to 


the re-read. So that gives you an order of 


magnitude of how many workers would be 


affected, a thousand to two thousand workers 


each year and the order of magnitude is from 


zero percent to about increasing it by 100 


percent. 


MS. MUNN: Do you have a rationale for why 

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there would be that much variance from one 


year to the next? 


MR. BUCHANAN: It would depend on how many 


of them were found and re-read, and if those 


constituted the high dose workers or the low 


dose workers. If most of the high dose 


workers’ badges were recovered and re-read, 


then you would have very little impact on the 


overall dose. 


MS. MUNN: So you’re talking about only 


reworks here in this particular discussion 


right now? 


MR. BUCHANAN: We’re comparing those that 


were re-read and those that could not be reread and how the ones that couldn’t be re-read 


would influence your overall dose assignments. 


MS. MUNN: Right, got it. Thank you. 


DR. MAKHIJANI (by Telephone): So in regard 


to the first question, you know, as I 


understand it all the dose readings were done 


by contractors, or essentially all, and part I 


was answering was comparing the original 


readings done by the government’s contractors 


basically was running Rocky Flats in the ‘50s 


and ‘60s compared to the re-reading of the 

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same badges done in the neutron dose --


MS. MUNN: NDRP, okay. 


DR. MAKHIJANI (by Telephone): -­

reconstruction project which was also done by 


a contractor, which was done by ORAU actually. 


MR. GRIFFON: I think for me looking at this 


data, and I was on these technical calls so I 


have a little advantage having looked at some 


of this data, but I’m still, you know, there 


are some details that are, we’re all sort of 


sorting out. But I noticed, and Roger said 


this on one of the calls -- I forget if it was 


the 17th or last week -- but the year’s not 


perfectly defined but ’64, ’65, somewhere in 


that time period, they started phasing in and 


more of the highly exposed workers were 


monitored in full. 


And just looking at some of the data 


from the NDRP database, it does support that 


argument. But you can see instead of, I just 


did some plots on my own that look at the 


percentage of notional, which is basically an 


estimated dose. And when you have 100 percent 


notional, it was basically all, as Arjun’s 


pointed out, assigned dose versus the final 

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neutron dose. And as you get out to like ’65, 


it’s clear that, like in ’55 I have up on the 


screen the top 40 or so final neutron doses as 


far as magnitude, the top 40 are all 100 


percent notional dose, so they had no, either 


they didn’t find the film badges or they had 


no film badges, all 100 percent notional. 


When you go out to ’65, it’s reversed. 


It’s all the higher end final doses actually 


have their own film data. And Roger indicated 


that this is kind of phased in. They took the 


highest risk workers, which makes sense, they 


took the highest risk workers and badged them, 


but it wasn’t all done in one year. 


It was kind of phased in over a couple 


of years from ’64 so that their time is 


unclear. But the data does support that. And 


I would say in those cases you’re on more 


solid grounds with regard to being able to 


bound that dose because you have the actual 


film data from the high-end people, for the 


highest exposed. That was an important take 


away for me and the data sort of shows what 


Roger said was happening in the field, and 


they support each other. 

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But maybe, Arjun, is it a good point 


to maybe then go back to the first timeframe 


and --


DR. MAKHIJANI (by Telephone): Sure. 


MR. GRIFFON: -- I’m sure there are several 


questions, so let’s maybe turn it over to 


Brant and have some discussion. 


DR. ULSH: Good morning everybody. Mark, I 


do have a lot to say about this. I don’t know 


in terms of logistics when you want to take a 


break, but what I’m going to do is since 


certainly the people on the call and the 


people who were not involved directly in the 


conference calls may not have as good a 


picture of the NDRP as those of us who were, 


I’m going to start with an overview of NDRP, 


and that’s going to take a little while. 


MR. GRIFFON: I’m getting a nod from our 


court reporter that we should have a break. 


So let’s take a ten-minute break and then 


reconvene. 


 DR. WADE: We’re going to take a ten-minute 


break. We’ll mute the phone, and we’ll turn 


it back on in approximately ten minutes. 


(Whereupon a break was taken from 10:47 a.m. 

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until 11:00 a.m.) 


MR. GRIFFON: Okay, for everyone on the 


phone we’re ready to start up again, and I 


think Brant’s going to give us a little 


background on NDRP and get into some questions 


for Arjun I’m sure. 


 DR. WADE: Can we just verify for the 


record, Mike, are you still with us? 


MR. GIBSON (by Telephone): Yeah, I’m still 


here, Lew. 


 DR. WADE: Thank you. 


MR. GRIFFON: And everyone on the phone just 


let us know if you’re not picking up Brant 


well or any of us. We’ll make sure we adjust. 


DR. ULSH: All right, thanks, Mark. 


As I mentioned before the break I 


think it’s worthwhile to take a step back here 


for those of you out there on the phone and 


for the people around the table here who were 


not directly involved in the conference calls 


that we had over the past couple of weeks and 


the process that we’ve been involved with for 


months now. 


I’d like to start with just a little 


bit of background on how SC&A and NIOSH have 

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approached these neutron questions. And 


please don’t read anything into what I’m about 


to say. I just think it’s important to 


understand how we’ve been interacting and what 


data has been provided and when and what that 


all might mean. 


We provided the neutron dose 


reconstruction protocol. It was months ago. 


I don’t know the exact date, a long time ago 


though, and we also provided de-identified 


data months ago. So that stuff has been 


available to the working group and to SC&A for 


some months. 


We had a process initiated where we’ve 


had several exchanges of questions and 


responses primarily with Ron Buchanan of SC&A 


and some folks on the ORAU side and that has 


been a very productive process I think. I 


hope, at least, that everyone involved with it 


would agree with that. And there’ve been 


numerous iterations, and questions would be 


presented; we’d answer them and then follow up 


questions would be presented. 


We’ve also had numerous conference 


calls over the past several months. At least, 

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well, two within the past week I think, and at 


least two before that, and that’s just going 


from my memory. It is true that we provided 


matched neutron gamma readings on the 14th of 


March to SC&A. And those were de-identified I 


believe. Yeah, I believe so, yeah. 


Once SC&A had some time to spend with 


that it became clear that they still wanted to 


see the NDRP database, and I discussed that 


with Mark. And as Mark mentioned, we provided 


the complete NDRP database on the 23rd of 


March. So there’s been an ongoing 


interaction. I mean, it hasn’t all just 


happened in the past couple of weeks. It’s 


not like these action items have been, there’s 


not been a lot of items hanging out. There 


have been a couple that have been provided 


within the last few weeks. 


Now for some background on the NDRP 


itself. This is a very big, a very complex 


study that was done so I think it’s worthwhile 


to point out a couple of things. And some of 


this is going to be some tough hoeing, so I 


hope that you can just bear with me. 


The NDRP was undertaken by the 

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Department of Energy because it was recognized 


that there were some problems with the neutron 


dosimetry as it was done at the time. And 


we’re talking about the early ‘90s. And the 


impetus, at least as I understand it, was an 


epidemiological study that was done by Dr. 


Ruttenber from the Colorado Department of 


Health. And at that time it was recognized 


with input from former workers, I’m thinking 


of you know, the NDRP staff, that the weakest 


link in the dosimetry as it stood in the early 


‘90s was the neutron dosimetry. 


And so as Arjun mentioned, there was a 


study by a researcher at Colorado State, kind 


of an original study, and then a pilot study 


quickly followed just to demonstrate that, 


yes, this was a worthwhile thing to do. And 


then the NDRP was launched following on those. 


Now the NDRP itself, and when I say 


NDRP, I’m talking about Neutron Dose 


Reconstruction Project, was conducted by ORAU. 


The scientists involved were former workers. 


Roger Falk was a primary scientist. Joe 


Aldrich was the project director. It did have 


oversight by not only by DOE individuals, Bob 

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Bistline and Bruce Wallen, but it also was 


overseen by an advisory board similar to the 


way our program is overseen by an advisory 


board. And the advisory board for the NDRP 


included a number of very knowledgeable, preeminent scientists in the field. 


Now in terms of the history of neutron 


monitoring at Rocky, you’ve heard some of this 


from Arjun’s description, but I’m going to 


cover it in maybe a little more detail. From 


1952, that was the start of operations, 


through 1956, workers who were judged at the 


time by the health physicists to be at highest 


risk of neutron exposure were issued neutron 


track plates. And those were supplied by Los 


Alamos. A total of 757 neutron track plates 


were retrieved from Los Alamos for the NDRP. 


So that covers the ’52 to ’56 time period. 


Now you might be a little confused 


because I said -- and I very carefully worded 


what I said -- the health physicists at the 


time judged that the people who were issued 


plates were the ones at highest risk. In 


retrospect it became obvious that not all of 


the people at significant risk of neutron 

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exposure were monitored. 


So I think it’s fair to say that their 


judgment at the time, while it was based on 


understandable reasons which we can’t really 


discuss at the moment, it was in error. 


There were people in Building 71 who were 


getting significant neutron exposures and who 


were not issued plates. It is a fact that 


those people in Building 71 were not monitored 


from ’52 to ’56. 


The people who were monitored were in 


primarily Building 91. That is where 


plutonium was received from offsite and where 


final assembly was performed I believe. And 


during that time like I said, Building 76, we 


have to be careful when we say that they were 


not monitored. People in Building 76 were 


monitored for beta and gamma. They were not 


monitored for neutron. So it’s not really 


accurate to say that they were not monitored. 


Now from 1957 to ’70, through 1970, 


workers were monitored with NTA film. And 


this is where I think a little perspective is 


in order about the magnitude of the NDRP. The 


NDRP retrieved almost 90,000 films for the 

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NDRP. And of those 87,000, a little over 


87,000, were matched to workers. 


So that’s the population of films that 


was looked at. So I think that’s a little bit 


of perspective on the magnitude. We’re not 


talking 20 films or 100 films. We’re talking 


almost 90,000 films involved. 


Now for in terms of the NDRP 


methodology and hang with me on this. This is 


a very complicated topic, that I’m still 


grappling with, too. The NDRP re-evaluated 


over 76,000 matched neutron-gamma pairs. Now 


let me tell you what I mean by that. A 


matched pair consists of a gamma measurement 


and a corresponding neutron measurement. So 


that is a matched pair, and there were 76,000 


approximately of that. 


And now the NDRP re-evaluated all the 


films that were available, and here’s an 


important fact. They didn’t just go back and 


re-read the films. They went back and re-read 


the films in most cases several times because 


from a statistical standpoint that will give 


you a better estimate. If I take a film and I 


read it once, well, that’s a number, but if I 

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read it four or five times, then I have a much 


more statistically robust estimate from that 


film. 


So you multiply that 90,000 by I don’t 


know. I would just be guessing what the 


average number of re-reads is. Let’s say 


three, you get an even larger scale project. 


So this was not a trivial project. It was 


very rigorous in terms of the QA that was 


applied. 


Arjun mentioned, and I’ll get to it at 


some point here, there were individual 


specific calibration factors. So each 


individual person who was re-reading films had 


a calibration factor that was specific to that 


person, and that was to eliminate errors from 


differences between readers. Looking around 


the table I might read a film differently than 


Wanda would read a film. And the NDRP didn’t 


want that to have an impact on the estimate of 


the dose. 


So they were, and the individual 


specific calibration factor’s applied to each 


reader. And it’s a little, I think the 


description that was given before was a little 

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bit incomplete. They were compared against 


the senior scientist readings, Roger Falk, but 


they were also compared to two sets of 


calibration films with known doses, and 


Roger’s readings were also compared to 


calibration films with known doses. 


So Roger was simply the normalizer. 


It wasn’t as if these, if there was a 


disagreement, Roger was right and the reader 


was wrong. They were both compared to these 


calibration films. 


And there were two sets. One set was 


exposed to a bare, unmoderated plutonium 


fluoride source. That’s the source of the 


plutonium at Rocky Flats. That’s the source 


term there. So it’s the same type of 


plutonium. That was one set of films, and 


there were, I think, maybe four different 


doses that were evaluated. 


And then a second configuration was 


used. That was completely moderated plutonium 


fluoride source. So you had plutonium 


fluoride source encased in seven centimeters 


of polyethylene, completely moderated to 


spectrum, and a second set of calibration 

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films was used. And these are the films that 


the readers’ calibration factors were 


calculated against. 


MR. GRIFFON: These were Rocky Flats 


calibration films or --


DR. ULSH: Yes, they were. 


MR. GRIFFON: -- were they developed outside 


of --


DR. ULSH: I’m trying to recall, Mark. 


These were films that Roger Falk did in the 


1960s. I don’t know the exact year. I’m not 


sure if this was the Los Alamos source. I 


think it was. Yes, I think it was the Los 


Alamos --


MR. GRIFFON: So Roger Falk set up the films 


and exposed them and made these calibrations? 


DR. ULSH: Yes, exactly. I think 1960­

something. I don’t know the exact year. 


Now prior to the, now this really 


astounded me, prior to reading any films on 


any given day, readers were required to read 


films and pass an initial qualification test 


every day that they were reading, every day. 


And a separate Quality Control Program was 


implemented where they had to re-read at least 

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ten percent of the films that were read the 


previous day by each reader just to make sure 


that they were being consistent. The point 


that I’m making is not the details here, but 


the point that I’m making is there were 


rigorous QA protocols in place at the time. 


Now, we’ve talked a lot about notional 


doses, and I know this might be a bit 


confusing. If you think about the total dose 


that would be calculated for an individual, if 


you can think in terms of an equation. Total 


dose equals the measured dose as re-evaluated 


by NDRP plus the notional dose. And I’m going 


to talk about each of those terms in a minute. 


Now what is a notional dose? Well, 


notional doses are neutron doses that were 


assigned to workers who may have been exposed 


to neutrons in a plutonium building at Rocky 


Flats, but for one reason or another they were 


not monitored. I’m sorry. There is no 


monitoring data for that person. Now that 


could have happened because the person was not 


monitored. It could have happened because he 


was monitored, but the doses couldn’t be reevaluated from the film. And it could also be 

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the case that the worker was not likely to 


have been exposed during that period of time. 


Now everything I’m saying comes from 


the NDRP protocol. This is not a late 


breaking development. All of this information 


is available in the NDRP. So a notional dose 


covers periods for when there is no neutron 


monitoring data for whatever reason for a 


particular individual. And you add that to 


the time when there was monitoring, and you 


come up with a total re-evaluated neutron 


dose. 


So let’s talk a little bit more about 


that notional dose term. Well, you start with 


the recorded gamma doses. And this is an 


important point. It is not true to say that 


every person who was in a plutonium building 


at Rocky Flats was included in the NDRP. The 


policy in place at the time was that if a 


worker was judged to have an exposure 


potential greater than ten percent of the 


limit, then they were required to be 


monitored. If it was less than that, they 


were not required to be monitored. 


So there were people who were judged 

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not to have significant exposure potential who 


were not monitored for gamma. Those people 


aren’t in the NDRP. The trigger for getting 


into the NDRP was that you were gamma 


monitored, and that is a surrogate for having 


significant exposure potential. 


So let’s start with the gamma. We’ve 


got a person, let’s say he’s monitored for 


gamma, but he’s not monitored for neutrons. 


The whole focus of the NDRP, well, that’s too 


strong a statement. One of the big focuses of 


the NDRP was to come up with a method to 


calculate notional neutron dose that, well, 


the best method. And simulation studies were 


performed to come up with the best method of 


calculating notional dose. 


Now these studies as part of the NDRP 


compared the predicted neutron dose, the 


predictions from various alternative methods ­

- and these are all described in the NDRP --


and they compared them to actual measured 


doses for matched pairs. 


So you’ve heard a little bit about 


SC&A trying to do some of these comparisons. 


There was a rigorous effort in the NDRP itself 

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to do exactly these kind of comparisons and 


find out which methods yielded predictions 


with the smallest error. So that was, the 


details are in the NDRP. I don’t want to get 


too far down in the weeds any further than I 


already am. 


Now let me tell you about notional 


dose, the method that was finally determined 


to be the superior method to do it. It was a 


weighted combination. Now this is where it 


might get a little difficult. It’s a weighted 


combination of estimates that are determined 


from two methods. 


The first method is based on a 


worker’s average neutron dose per day, and 


that is attained from actual neutron 


measurements. The second method is an 


estimate based on a common neutron to gamma 


ratio for a particular building and for a 


particular year. 


So let’s say I was a person in the 


NDRP, and let’s say I was monitored; I was 


measured for neutrons for four months out of 


the year. I don’t know. I can’t do math now. 


Let’s make it six months out of the year. For 

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the other six months I was not monitored. My 


total neutron dose is going to be my measured 


neutron dose plus my notional. 


And my notional is going to be a 


weighted average of the dose that is 


calculated for that gap period when I was not 


monitored by my average neutron dose per day 


or the common neutron to photon ratio. So 


some of the concerns that you’ve heard 


expressed here deal with using neutron to 


photon ratios to calculate notional doses, 


that’s the part of the dose that we’re talking 


about. And if you want additional details, I 


would always refer you to the NDRP protocol. 


Now note that when a worker had only 


small gaps, in other words he was monitored 


most of the time, then his neutron dose 


estimate would be heavily weighted towards his 


actual measured neutron doses. And 


conversely, if a worker was only monitored a 


little bit of the time, his estimate would be 


heavily weighted towards the notional 


methodology. 


So I mentioned that one of the big 


concerns that has been expressed or questions 

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that have been raised concern neutron to 


photon ratios. Well, how were these ratios 


calculated? Well, you started with a 


population of matched neutron and gamma doses. 


And I told you there were about 76,000 of 


those I believe. And the ratio was determined 


by dividing the sum of all the neutron doses 


for a particular building, for a particular 


year by the sum of the gamma doses for a 


particular building, for a particular year. 


Now that method was evaluated as well 


to determine which gave acceptable results, 


stable results, and results that matched what 


was observed. And one of the big conclusions 


from those studies were the estimates that are 


based on neutron to gamma ratios are generally 


more accurate than the common neutron to gamma 


ratio was used rather than individual derived 


neutron to gamma ratios. Those were extremely 


variable over the course of the year. And I’m 


going to talk about why that makes perfect 


sense that they were variable. 


So rigorous statistical studies were 


performed to determine which method of 


estimating the neutron to gamma ratios gave 

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stable and accurate results. And in the years 


where there were no matched neutron to gamma 


pairs, they were extrapolated from neighboring 


years. And I think this is also a source of 


concern. You heard Mark maybe or Arjun or 


somebody mention they had questions about 


extrapolating back from the ratio observed in 


’59 back to earlier years. 


And that is certainly true since there 


were very, there were relatively few neutron 


measurements in the early ‘50s. There wasn’t 


enough data to generate year and building-


specific neutron to photon ratios for the 


‘50s. And so what was done was the ratio that 


was observed in 1959, when we did have 


significant data available, that was back 


extrapolated to 1952. 


So it’s always, you always have to be 


cautious when you’re making those kinds of 


extrapolations. That was one of the things 


that was hammered into me in school was you 


don’t extrapolate beyond the range of your 


data without having very good reasons to do 


so. 


And so we considered this question, 

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the validity of extrapolating back from ’59, 


and there were a couple of questions that we 


evaluated. And this dealt with what factors 


could occur that would make 1959, the ratio in 


1959, different from earlier years. What are 


the possibilities, and do they compromise our 


ability to make this extrapolation, or really 


the NDRP’s ability to do that. 


Well, if there was a significant 


change in the source term you would expect 


that extrapolation might be questionable. In 


other words if you had plutonium fluoride in 


1959, but earlier than that you had some other 


form of plutonium which generated a different 


neutron to photon ratio, well, obviously you 


wouldn’t want to back extrapolate. 


However, the only change that occurred 


in the source term was an increase in the 


batch size. They started out with a batch 


size of 200 rems. They increased to 1,200 


rems. I believe that occurred in 1957. Well, 


now obviously that increase in batch size 


would increase the amount of neutron radiation 


coming off. It would increase the amount of 


gamma radiation coming off, but it would not 

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be expected to change the ratio, and that’s 


what we’re talking about, the ratio. 


So we didn’t, and the form of the 


plutonium, plutonium fluoride, was constant 


across that time period. So we in our 


evaluation, we did not see that there was a 


factor related to the source term that would 


compromise that extrapolation. Well, there 


are a couple of other things that might crop 


up. 


One is what if there were changes in 


the configurations of the buildings or in the 


neutron shielding that was involved that 


occurred prior to 1959. I mean, let’s say you 


installed a bunch of shielding in 1958 that 


changes the neutron to photon ratio. 


Obviously, then you wouldn’t want to 


extrapolate back from ’59. That didn’t occur. 


If you look at the building histories 


that’s available on the HAER. I think that 


stands for historical -- well, that’s as much 


of the acronym as I can come up with, but that 


is certainly available on the internet if you 


do an HAER search. There were no major 


building configuration changes until the ‘60s. 

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They added significant neutron shielding in 


the ‘60s but not before ’59. So we don’t see 


any changes in terms of those kinds of factors 


which would compromise the ability to back 


extrapolate. 


And that leaves you with one other 


factor that might affect the ability to back 


extrapolate, and that is if there were changes 


in the way workers did their jobs you might 


question the ability to back extrapolate. But 


the philosophy that was in place at the time 


in the ‘50s and well into the ‘60s was that a 


particular group of workers would be assigned 


to a batch of plutonium, and they would follow 


it through the process from start to finish. 


And that did not change over the course of our 


extrapolation. That was well into the ’60s. 


Now in the ‘60s the philosophy did 


change. You had workers who did specific 


tasks and the batches passed them by, you 


might want to think of maybe in an assembly 


line fashion. But that didn’t happen until in 


the ‘60s. And we don’t know of any other 


factors that changed the way workers did their 


jobs. 

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So we did consider all of these 


questions when we evaluated the advisability 


of back extrapolating from ’59. And we just 


did not see anything that would compromise 


that extrapolation, to be honest, over the 


discussions over the past couple of weeks, I 


haven’t heard of anything. I haven’t heard a 


technical argument that says that that 


extrapolation would be invalid. 


Now it is true, and I know, Mark, this 


is one of your big concerns, about notional 


doses, the highest doses in early years being 


notional rather than measured. And as I 


mentioned, the health physicists at the time 


made a judgment that people in Building 91 


were at highest risk of exposure, and that’s 


why they got the plates. 


As I said, in retrospect that was 


probably not in this individual, in this 


particular instance a good judgment because 


what you see is that the notional doses are 


higher in the earlier years. That is 


certainly true. And you could say, well, 


that, obviously, I think it’s fair to say that 


the health physicists at the time didn’t have 

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an accurate judgment about who should be 


monitored if you’re trying to monitor the 


highest people. 


But the relevant question is can we 


bound, or really the question is can we bound 


or come up with a more accurate methodology 


for calculating neutron doses. And the fact 


that the doses are notional, highest doses are 


notional does not in and of itself in any way 


compromise our ability to estimate those 


doses. 


Now, I’m almost done. I had a feeling 


that the speculative language would become a 


sound bite, and I appreciate Arjun reading 


what Roger said about that. I think taken out 


of the scientific contexts, members of the 


public or others could be forgiven for reading 


more into that comment than is really 


appropriate. When you say speculative, I 


mean, scientists, health physicists, 


abbreviation protection people, always prefer 


directly measured doses over calculated doses 


even in a situation like this where the 


calculated doses were done very rigorously. 


So, of course, it would be preferable 

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if the workers monitored in the ‘50s had been 


directly monitored for neutrons. And there is 


some degree of assumptions involved in 


calculating via notional dose methodology. 


And, of course, you have to evaluate those 


assumptions. I think they’ve been very 


thoroughly evaluated. 


So with that I think I’ll finally be 


quiet and you ask, discuss questions or... 


MR. GRIFFON: Joe or Arjun, I give it to 


you. 


MR. FITZGERALD: I think Arjun’s chafing. 


DR. MAKHIJANI (by Telephone): I’d just like 


to make one clarification about a point 


regarding a notional, what goes into the final 


dose. Brant said that the final dose has a 


two component equation. One is the re-read 


dose, and the other is a notional dose and ^ 


two components. 


And I agree with all that, but there’s 


a third component which I mentioned. Doesn’t 


apply to all workers but is important for many 


workers, and it depends on the period and the 


year how many workers this applies to. But 


since not all the badges were recovered, the ^ 

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re-read portion of the original dose. 


So the original dose actually was 


split up into two pieces, the piece that could 


be re-read because the badge was available and 


in condition to be re-read and could be 


matched up with a specific worker, and the 


part that was not re-read. Now the part that 


was not re-read was simply added into the 


final dose without change. 


And one of the essential 


methodological problems that we see is we know 


that the non-re-read portion ^ likely to be in 


significant error as an underestimate for the 


whole period but particularly for certain 


periods it would be a large underestimate most 


likely. So that piece of the total neutron 


dose is a problem for those workers who have 


that in their final dose. 


DR. ULSH: Arjun, we agree with you that 


that particular piece of the total dose, in 


other words the piece of the original dose 


that was not able to be re-read could pose a 


problem, and that takes you up through the 


NDRP. Now the particular individual enters 


the NIOSH dose reconstruction process. And 

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we’re very well aware of that problem so I 


think Mutty’s going to have a few words to 


tell you how we address it in terms of a dose 


reconstruction. 


 MR. SHARFI: When we actually assessed the 


NDRP data, we didn’t re-break it back up to 


any originally non-adjusted doses and the NDRP 


dose and the notional dose. The original 


doses then are the ones that have not been reread are then readjusted for possible track 


errors. 


And those are covered in the site 


profile and in a lot of cases are adjustment 


factors of up to a factor of two can be 


assigned to those original non-re-read doses 


to account for possible misreadings. And 


that’s all covered in the site profile. So 


the original dose is actually pulled back out 


of the NDRP dose and re-analyzed for possible, 


and adjustment factors are given for that 


possible issue. And that is covered in the 


site profile and how to handle that and is 


addressed in the dose reconstruction. 


DR. MAKHIJANI (by Telephone): The errors as 


we observed them for certain years as I 

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mentioned go up to an order of magnitude or 


more even in the cumulative dose and they are 


considerably bigger for individual workers. 


And a correction by a factor of two certainly 


would not in most or all years, except maybe 


’67 to ’70, could be described as bounding in 


any way, at least as I’ve read the data. 


DR. ULSH: Well, Arjun, I’m sorry, but I 


don’t have your analysis in my hands or maybe 


I do and I just haven’t had time to digest it 


yet. I’m not quite sure. 


DR. MAKHIJANI (by Telephone): No, you 


don’t, Brant, because as I said, we’re still 


in the throes of producing this and as you 


understand, you don’t like to publish --


DR. ULSH: Oh, sure. 


DR. MAKHIJANI (by Telephone): -- draft 


documents. 


DR. ULSH: I would say that -- this is 


dangerous without seeing your actual data, but 


in my experience, limited experience, you tend 


to see a lot more variability in terms of the 


neutron to photon ratios when you’re very 


close to the limit of detection. And I’m 


looking at Mutty to give him an opportunity to 

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correct me. So I think you might see more of 


that kind of an issue at very low doses. But 

I would have to see the data that you’re 

basing this on to say for sure. 

DR. MAKHIJANI (by Telephone): Brant, I 

think you did not understand me. I’m not 

talking about neutron to photon ratio 

calculated portions of the notional dose. I’m 

just talking about the errors that were 

present and discovered, assuming that the rereading, re-read dose was completely correct, 


and just accepting that, you try to estimate 


by how much the original reading was in error. 


And that error varied from one year to the 


next. 


For instance, Los Alamos ^ seemed to 


do a fairly good job, in some of the time at 


least, and those errors are not very large in 


the ’59 to ’64 period. In the ’66 period, the 


errors ^ some of the years, and I think as was 


discovered in the NDRP the individual reader 


errors were dependent on experience and at the 


time they were not corrected. So you tended 


to have a fluctuation in the errors of the 


original readings. 

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And what we’re talking about is what 


can you do to correct the original readings, 


and as Roger mentioned and as is documented in 


the minutes, either of the one of the two 


calls in the last week, is that the ^ decided 


that they really couldn’t do anything to 


correct the errors of the badges that they 


could not find. That’s why they left them 


alone. 


DR. ULSH: Yes, I think it’s safe to say, 


Arjun, that that was done in the NDRP in an 


overabundance of caution because you have to 


realize that what they were trying to do here 


was recalculate, readjust a dose of record. 


So they were very conservative about messing 


with the original dose. I mean, if they had 


significant, if they had enough data to do it, 


they did it. 


But in terms of what we do here, I 


mean, we might, you’ve given me some numbers. 


You said that it can be, I don’t know, 100 


percent or 50 percent. I think Ron put some 


numbers out there. So I mean, we might, I 


would encourage you to look at what we’ve done 


in the TBD if you haven’t already and send 

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over what you guys have done, and we’ll take a 


look at that. 


But I think at the end of the day if 


it’s just an argument about numbers, should it 


be a factor of two or a factor of ten or a 


factor of whatever, that’s not necessarily an 


SEC issue. That is simply a TBD issue. What 


number should be applied? I can’t go any 


farther than that without seeing your data. 


MR. BUCHANAN: Could I ask for 


clarification? I believe in the TBD the 


factor of up to two is applied because of the 


NTA film’s lack of response below the 700 keV 


threshold was the main reason for putting 


those in and building specific. 


 MR. SHARFI: That’s a separate adjustment 


factor on top of that. There is an adjustment 


for the low energy less than 700 keV. 


MR. BUCHANAN: Right, and that’s around a 


factor of two. 


MR. SHARFI: In addition to there’s a --


it’s in Section 6.7.3.4 which talks about the 


correction for neutron film reading 


deficiencies. And there is a separate issue 


for the low energy neutron energy range that 

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also gets applied on top of these original rereads. So, yes, TA could do adjustments up to 


a factor of four to eight, depending on if 


they’re falling into both categories 


certainly. I was describing just the 


deficiency part of it. 


MR. GRIFFON: My feeling is this is news. I 


mean, I didn’t know that there was this 


adjustment factor so I think we should, for 


that one issue I think it would be useful for 


SC&A to reflect on that in the TBD, and --


DR. ULSH: And send us your analysis so we 


can reflect on that. 


MR. GRIFFON: Right, right, right, but 


that’s --


 MR. SHARFI: So a factor of ten ^ order of 


magnitude between recalculated and the 


original, unless you’re talking about like go 


down in the ^ where you’re talking about right 


near the LOD where I could see large --


When you get to the larger doses I 


don’t know if I’ve seen factors of ten where 


the original dose was like 500 millirem, and I 


usually see five rem in re-read. But I could 


see that when the original dose was ten 

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millirem and now you see 100, you’re getting 


down to the error of the dosimetry itself. 


MR. BUCHANAN: Just for the records can you 


summarize briefly when the, what years and 


when the dose reconstructor would apply a --


 MR. SHARFI: Anytime there was original, 


non-adjusted NDRP dose, then these factors 


then would be applied onto the original 


portion of the NDRP dose. 


MR. BUCHANAN: For what years? 


MR. GRIFFON: For all years. 


 MR. SHARFI: For all years. 


MR. BUCHANAN: ‘Fifty-two through ’69? 


 MR. SHARFI: ‘Sixty-nine, ’70, yeah. 


MR. BUCHANAN: But the neutron threshold was 


apparently corrected in the later years. 


 MR. SHARFI: Correct, that’s for certain 


years. I have to go back to look up on that 


issue when those apply. 


DR. ULSH: Because that’s a separate 


correction. 


 MR. SHARFI: Yeah, that’s a separate 


correction. There are two separate 


corrections. 


DR. MAKHIJANI (by Telephone): Let me throw 

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some numbers into this mix that are from real 


readings. So you have an original reading of, 


in 1965, of 517 millirem, and a re-read value 


of 3,267 millirem with a variance of 204. 


Then one right below it there’s one of 515 


with ^. You know, one is about a factor of 


six and one is a factor of five for that same 


original reading both of which are over the 


LOD. You’ve got a hundred and odd millirem 


that turns into 1,000 millirem. You’ve got 


274 that translates into 1,249. You’ve got 43 


that become 58, so those are some examples of 


order of magnitude type of changes in nontrivial doses. And there’s not just a 


question of what ^ apply and picking something 


that would cover because ^ methodology. 


MR. GRIFFON: Arjun, are you on a speaker 


phone? 


DR. MAKHIJANI (by Telephone): No, I have 


headphones. 


MR. GRIFFON: Okay, because we’re losing 


you. We had a better connection before and 


now you’re crackling. 


MS. MUNN: You’re very staticky, and you’re 


also very soft. We can’t get the volume up 

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any higher. 


DR. MAKHIJANI (by Telephone): I’m sorry. 


Maybe I will dial back in so I don’t have 


headphones. I thought this would be easier 


because I can mute this, and I couldn’t mute 


my other phone. 


 DR. WADE: Why don’t you try dialing back in 


with a handset. 


DR. MAKHIJANI (by Telephone): Okay, I’ll 


just hang up and dial again. I’m sorry. 


MR. GRIFFON: My sense is just that I wasn’t 


aware. 


I don’t know if, Ron, if you were 


aware of it. I mean, I think we need to, we 


should look at that and the question of 


whether the factor’s appropriate or not. I 


think you have to look at the factor first to 


determine that. So I think you need to look 


at that closer. But that’s for the non-reread. There’s other issues that we need to --


DR. ULSH: Right, the non-re-read dose I 


think is a fairly small problem in terms of 


the number of people that it affects, the 


number of films. 


MR. GRIFFON: Right, although there’s a 

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couple of years when it gets pretty 


significant, but, yeah, overall that’s, so 


that’s related to that one issue. 


 MR. SHARFI: When he talks about a factor of 


four or five and I’m just talking about 


discrepancy, there is the other issue of the 


low energy photon I believe was corrected in 


the re-read that if you applied both of them, 


you might be looking in more of a factor total 


that will compensate --


DR. MAKHIJANI (by Telephone): Hello, I’m 


back I think. 


MR. GRIFFON: That’s much better. 


MS. MUNN: That’s so much better. 


DR. MAKHIJANI (by Telephone): I’m sorry 


about that. I thought I was making it better, 


but I made it worse. 


Anyway, I was ^ a magnitude ^ is a 


factor of five and seven changes in the mid­

‘60s in the re-read dose from a base that’s 


non-trivial, that ^ rem. But the point I 


wanted to make is it’s just not a question of 


calculating the ratios and picking a number if 


there’s some scientific basis on which we can 


pick that number because these things vary 

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from one year to the next. 


And I think that is a problem because 


I think the main source of this error, at 


least if the NDRP record I understand 


correctly, was individual reading errors and 


the experience of the individual reader. And 


at this time we have essentially no 


information about who was reading these badges 


originally, and what their errors might have 


been in the badges that are missing. 


DR. ULSH: I just don’t think we’re able to 


say much more, Arjun, without getting your 


data and taking a look at it. 


DR. MAKHIJANI (by Telephone): Yeah, I mean, 


I was reading directly from the O drive data. 


MR. GRIFFON: I think, Mutty, you might want 


to repeat because Arjun didn’t hear the one 


statement about the --


 MR. SHARFI: The re-read I think also 


accounts for the low energy neutron that 


wasn’t a capture, so when you’re comparing the 


factors, I think you have to take both 


factors. I believe the low energy neutron’s a 


factor of 2.5, and I guess that sort of 


combined together you could see, we could end 

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up multiplying a factor of five to the 


original neutron dose. 


DR. MAKHIJANI (by Telephone): But then you 


should see a consistent ^ for the low energy 


neutron adjustment, but you don’t see that. 


MS. MUNN: A consistent what? You broke up. 


DR. MAKHIJANI (by Telephone): If there’s a 


piece of the adjustment factor that relates to 


the low energy neutron adjustment, then you 


should see a consistent factor of, say, two 


that is there at least in all the re-read 


doses, but you don’t see that. You’ll see reread doses that have smaller corrections. 


 MR. SHARFI: Correct, because you have to 


consider that we take a factor 2.5 because 


that’s the most conservative underestimate 


based off the percentages of neutrons you’d 


expect under 800 keV. In some cases you would 


expect a much lower correction factor if you 


went building by building and type of material 


specific which the NDRP project probably went 


into a more detailed scenario of where that 


person was working in the case like a 


plutonium ingot versus molten salt or 


something like that. That means you’re going 

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to see different low energy neutron 


composition. 


What we did is we took the worst case 


scenario and then applied the, which would 


have been the 2.5. In most cases we’re 


attempting to put you at that upper bound 


instead of trying to find possibly a lower 


correction factor. 


DR. MAKHIJANI (by Telephone): I think we 


would need Roger’s help here. I do ^ NDRP did 


a job type analysis in the re-evaluation. 


Roger? 


MR. FALK (by Telephone): That is right. 


 MR. SHARFI: It’s by building. 


MR. GRIFFON: By building, right? Yeah, 


you’re --


 MR. SHARFI: Seventy-one out of ^ versus 707 


had different lines. So based off the 


building --


MR. GRIFFON: Right, it’s building not job 


type. You’re right. You’re right, Arjun. 


But I think at this point I don’t know that we 


can take this much farther without just asking 


SC&A to address the factors that you discussed 


in 6.7.3.4 and see where you come out on that. 

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I mean --


DR. ULSH: And we’ve got to see what SC&A’s 


going to produce, quickly. 


MR. GRIFFON: Right, it’s got to be quick. 


DR. ULSH: It’s a very technical issue, and 


we’re going to need some time to respond to 


it. 


MR. GRIFFON: I know, but I think they have 


to look at the numbers and how they’re 


applied. I mean, doing a real-time out loud 


here, I’m not sure we’re going to get much 


further. 


DR. MAKHIJANI (by Telephone): And if I 


might ask Ron to give me a buzz on my cell 


phone at lunch we can make some progress 


because I need to talk about numbers with him. 


Sorry to say this on the record. 


MR. GRIFFON: So then -- go ahead. 


DR. ULSH: We talked about two issues. We 


talked about what to do about badges that were 


not re-read, and then I’ve given you a 


response on neutron to photon ratio. Do you 


want to talk about that some more? 


MR. GRIFFON: Yeah, Arjun, the question of 


neutron to photon back extrapolation of the 

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ratio? 


DR. MAKHIJANI (by Telephone): Yes. There 


are a lot different issues with that. First 


of all the underlying assumption is that you 


can calculate an average building ratio and 


apply it to an individual. And the second 


underlying assumption is that neutron doses 


are proportional to photon ratios; that’s why 


you use a constant factor. 


If you look at the evaluation of 


different methods of neutron to photon ratio 


calculation that could be done with the same 


data which is there in the Stanfield thesis 


which was done using the pilot ^ provided to 


Stanfield by Rocky Flats, you find that 


depending on how you calculate the neutron to 


photon ratio, you can get an order of 


magnitude difference in the ratio. 


And there’s no really clean way of 


aggregating this data. I’m not talking about 


differences in individual paired ^ badge 


readings. I’m talking about aggregated data. 


So for instance, if you look at the scatter 


plots of neutron to photon ratios, either 


annually aggregated or in matched pairs, 

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you’ll find there’s very little correlation. 


In the pilot study that was done by 


Rocky Flats and where Roger was involved ^ 


stratify, if you stratify the data by gamma 


dose and say less than 50 people who had less 


than ^ what would the neutron/photon ratio be. 


And more than 50 millirem but less than 100, 


more than 100, you get very different results. 


If you look at scatter plots, you find 


that neutron doses are concentrated in a 


rather low band of gamma doses, but then there 


are also people with very low neutron doses 


who have quite high gamma doses, and then 


you’ve mixed all of those things up. And it 


appears to me that building N/P ratios are 


useful for calculating population doses but 


not individual doses. I think the underlying 


methodology is open to question even for the 


years in which it was applied. 


And I think the terminology was not, 


scientists don’t use the word speculative very 


easily. They use the word uncertainty when 


they can realistically, actually put a number 


on it, and that defines a kind of scientific 


representation of what you can say about a 

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particular number. In a scientific context 


when you say speculation, there’s a ^ which 


you’re throwing up your hands. 


And if you read the NDRP report, it 


does say that the piece of the notional dose 


that is calculated based on the neutron to 


photon ratio is the more variable part. And 


the back extrapolation is considered as the 


more speculative part the farther back you go. 


I think that’s, in my opinion, when I 


look at the sum total of everything, I’m not 


saying it isn’t the best shot or a very well 


thought through scientific approach, but you 


have, you’re dealing with thin gruel, and you 


can’t get more calories out of than are there. 


MR. SMITH (by Telephone): This is Matthew 


Smith on the phone with the ORAU project. 


Just to add to that, the final that was on 


that conclusion regarding the uncertainty of 


notional dose in the NDRP report, it states, 


“To reflect this uncertainty methodological 


choices have been made at every stage of the 


analysis that will tend to overstate ^ the 


claimed variability of the estimates.” 


And it’s important to note that we do 

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take that uncertainty that’s reported by the 


NDRP data, and we work it through our 


calculations and into the IREP input that we 


use to calculate POC. And that’s all I have 


to say. 


DR. ULSH: I don’t think it’s going to be 


worthwhile to get into a debate of what the 


meaning of speculative is. I mean, you read 


what Roger said he meant by that, and that 


stands. 


DR. MAKHIJANI (by Telephone): And when we ^ 


so that’s why we’ve tried to do these 


quantitative exercises, as I say, you know, we 


will publish this as soon as we possibly can, 


but I’m sharing with you, you know, these unQA’d numbers. And we did try to verify 


whether the calculated doses from N/P ratios 


are comparable to the measured dose, and in 


eight out of 12 cases we found that they were 


considerably short. In some cases they were 


22, 39, 49 percent. 


I mean, those are the lowest numbers, 


and that is well short of the measured dose. 


Now this isn’t a statistically significant 


analysis, but they were randomly chosen 

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workers with significant monitoring data. So 


we’re not able to verify that the actual 


application of N/P ratios calculated on a 


building basis actually works. 


DR. ULSH: Well, I appreciate your sharing 


your preliminary results with us, Arjun. I 


mean, obviously, I can’t comment on in detail 


because I haven’t seen what you’ve done. But 


I can say though that the NDRP itself did 


exactly this kind of analysis with a 


statistically significant population, and they 


picked the method of calculating N/P ratios 


that agreed, had the smallest error when you 


compared to actual measured neutron doses. 


Beyond that I can’t really say much without 


seeing your analysis. 


DR. MAKHIJANI (by Telephone): I’ll also not 


say what is in process in terms of our 


statistical evaluation. But during one of the 


calls I did raise a question about the whole 


statistical model that was adopted by the 


NDRP. Now I sent off my reading of that to 


our statistician, Harry Chmelynski. 


DR. ULSH: I think you said he sent off his 


reading of this model to the statistician. 

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MS. MUNN: Some statistician. 


 DR. WADE: Arjun, we’ve lost you. 


DR. MAKHIJANI (by Telephone): I’m very 


sorry. I have a landline and a handset, and I 


don’t know what I’m doing wrong here. 


 DR. WADE: Well, you’re probably doing 


nothing wrong so just --


DR. MAKHIJANI (by Telephone): I’ll try to 


speak as loudly as I can. I’m sitting in a 


room by myself with a closed door. Is that 


better? 


MS. MUNN: Your volume is fine. 


 DR. WADE: There is interference 


periodically. I don’t think it’s you so 


please persevere with us. 


MR. BROEHM (by Telephone): And this is 


Jason. I’m hearing Arjun just fine on my end. 


DR. MAKHIJANI (by Telephone): Yeah, I 


believe that the interference is not coming 


from my phone. 


 DR. WADE: I think you’re right. 


MS. MUNN: Probably here. 


 DR. WADE: Go ahead. 


DR. MAKHIJANI (by Telephone): As I said I 


have a question about the statistical model 

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both in relation to the way the errors, 


expected values of the errors in the true 


value of the dose and the measured value of 


the dose and in the model for how the variance 


was calculated for the notional doses with 


using these N/P ratios, that piece of the 


notional dose. Now I have some experience in 


statistics, but I’m not an expert and so I 


have sent it off to our statistician, Harry, 


and he has not yet had a chance to get back to 


me about that. 


MR. BUCHANAN: I would like to make one 


question or clarification. The verification, 


Brant, when you said that they did do some 


comparison, that was the master’s thesis, and 


he did 71 and then a group that was in the 


late ‘60s and compared 50 workers or 


something. But that was the qualifying I’d 


like to put on it, right? Is that correct? 


DR. ULSH: I’m not sure that I agree 


entirely, and I might need to be corrected. 


The way you described Stanfield’s thesis is, I 


think, accurate. But I’m talking about 


Appendix 4 of the NDRP where Dr. Chapman’s 


analyses are presented. And I’m talking about 

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the simulation studies where they compared 


various different methods for predicting the 


neutron. They took matched pairs. You had a 


gamma; you had a neutron. And they compared 


several different ways of predicting a neutron 


dose and compared it to the actual measured 


neutron dose and picked the one that had the 


smallest relative error. So I’m not talking 


about Stanfield’s thesis on that. 


MR. BUCHANAN: That was for later years 


though, right? 


DR. ULSH: Oh, I don’t really remember the 


details, Ron. I’m not sure. 


MR. GRIFFON: Can I just, I think Matt Smith 


was on the phone and the point you made, Matt, 


I think was when you’re doing the dose 


reconstructions, you do add that 95th
 

percentile or you consider it? I’m not sure I 


understood exactly how that’s used in IREP --


DR. ULSH: Matt, are you still out there? 


MR. SMITH (by Telephone): Yeah, I’ll pick 


up the handset. When you look at those NDRP 


sheets, you’ll see that there’s an error value 


associated with the total dose. That kind of 


error is carried forward ^ and then it 

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eventually ends up in IREP as well. 


DR. MAKHIJANI (by Telephone): But you use a 


full distribution, not the 95 percentile 


value. 


MR. SMITH (by Telephone): That’s correct. 


For someone who has NDRP data. It’s being 


applied as a distribution. 


DR. MAKHIJANI (by Telephone): So actually 


when you apply it as a distribution, don’t you 


wind up with some negative dose values because 


you used, you’re using a normal distribution 


with a plus or minus that carries you into the 


negative dose range? 


MR. SMITH (by Telephone): That would be a 


question regarding how IREP operates under the 


hood, and that is not my area of expertise. 


DR. NETON: It’s quite possible. 


DR. ULSH: Well, I don’t think that we, 


Arjun, we never really go in and explicitly 


calculate individually the neutron dose by 


year. We put the neutron dose by year into 


IREP with the distribution along with all of 


the other doses in the IREP input spreadsheet, 


and it runs through the calculation. And then 


we pick the 99th percentile credibility limit. 

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DR. MAKHIJANI (by Telephone): Yeah, I 


realize that. I know that that’s how it’s 


done. I’m just mentioning this as this is a 


direct consequence of the statistical model 


that was selected because when you do it that 


way it is going to take you into negative dose 


ranges in some cases. 


DR. NETON: I’m not sure, Arjun, whether 


IREP would truncate that as zero. It may 


well. 


DR. MAKHIJANI (by Telephone): I don’t know. 


DR. NETON: I know it does with the risk 


models. It won’t allow the risk to go below 


zero, but I’m not sure about what it does with 


the dose calculations. But nonetheless, I 


mean, if the distribution’s a distribution, I 


mean, it’s the range of expected values. And 


I don’t see anything wrong necessarily with a 


negative dose. 


DR. MAKHIJANI (by Telephone): Some of the 


range of negative expected values are 


physically impossible. 


DR. NETON: Not when you can do measurements 


and you subtract background, no. I mean, if 


you put a number of measurements and average 

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them, if you take out the negatives, you’re 


biasing your values. 


DR. MAKHIJANI (by Telephone): This is not 


about measurements. This is about a model 


that is leading you into considerable negative 


dose territory, not --


DR. NETON: But I think in reality it is 


possible to measure a negative dose because of 


statistical distribution. So that’s 


consistent with reality. 


DR. ULSH: Yeah, it would not be 


considerable. It would be way out at the 

tail. 

 MR. SHARFI: You’d have to be way out at the 

tail to get to the negative values. I mean, 


you’re talking three, four standard deviations 


out, 99th percentile, 99.9 percentile. 


DR. ULSH: But anyway, I don’t know if it’s 


MR. GRIFFON: No, I think we’re getting 


beyond our discussion here. But the only 


thing I was going to -- in your dose 


reconstructions though, you would enter this 


dose as a normal distribution? 


 MR. SHARFI: Correct. 

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MR. GRIFFON: Yeah, okay, so you don’t 


modify that in any way. 


 MR. SHARFI: Correct. 


MR. GRIFFON: Arjun, do you have anything 


more on --


DR. MAKHIJANI (by Telephone): No, you know, 


I’d be happy to answer questions. I mean, 


I’ve given sort of as much of a review of our 


analysis as I could in some detail, but I’d be 


happy to answer questions and invite Ron to 


talk more about the data. I mean, I don’t 


know. We just have to complete our work and 


share it with all of you as soon as possible. 


MR. GRIFFON: The only thing I think you 


might want to speak to is the back 


extrapolating the N/P ratio from ’59. Brant 


gave some arguments about how the process and 


source term would not have affected that. I 


think you’ve said some different things on 


some of the technical calls so I just wanted 


to, I think you should share that for the 


record. 


DR. MAKHIJANI (by Telephone): Yeah, let me 


find my draft here. 


DR. ULSH: While he’s looking, Mark, we 

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should probably talk about the validation 


question that just occurred to me. We haven’t 


talked about that. 


MR. GRIFFON: Right. 


DR. MAKHIJANI (by Telephone): Do you want 


to go ahead while I find my stuff here. 


MR. GRIFFON: I guess there was a question 


that came up on the technical calls that we 


had about, and Arjun raised it in his 


description of the work we’ve done, that prior 


to ’59, and I think Roger sort of supported 


this, that while the NDRP Project made 


extensive efforts to kind of try to validate 


the neutron/photon ratio based on field-type 


data, and Roger basically concluded that it 


wasn’t available. 


DR. ULSH: Yeah, this question has been 


raised by SC&A in the conference calls and 


maybe in the draft report. I’ve seen it 


somewhere. And that question has to do with 


what they call validating or benchmarking the 


data. And I’m going to rely on Ron and Arjun 


to correct me if I’ve got a misinterpretation 


of what you mean by that. 


I saw it in the context of using field 

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measurements, neutron and gamma surveys in 


particular areas to compare to the NDRP. Is 


that kind of what you’re thinking about, those 


kinds of comparisons? 


MR. BUCHANAN: That’s what we’d like, but we 


found out that wasn’t available. 


DR. MAKHIJANI (by Telephone): Well, there 


are two types of validation, you know, like 


what we’re doing in the ‘60s is we have data 


from exposed workers that have neutron and 


photon measured data in the various buildings. 


And so we can actually do the kind of the 


comparison that we talked about is assume we 


don’t have a neutron dose and estimate it 


using the method and compare it, the kind of 


validation that was done by the NDRP and by 


Stanfield and so on. 


For ’52 to ’58 the only available 


method is to compare it to Building 91, 


measured neutron doses, because there’s very 


little data, almost no data from Building 71. 


There’s a little bit but almost none. 


And since the job types were different 


and since the maximum exposed workers in many 


cases were in Building 71 best as we can tell, 

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there’s no, in terms of estimated dose, 


there’s no actual measurements ^ against which 


you can validate your model. So that leaves 


you with area neutron measurements and those 


also do not exist. 


And since the building ratio is an 


average ratio, yes, you have some workers 


following a badge, but not all workers are 


doing the same thing. And the Stanfield 


thesis which looked at this question, even for 


’59 to ’66 in that pilot study, found that 


there is a difference by job type. So that 


back extrapolating from a limited set of ’59 


data which is, which has some questions even 


for 1959. 


So it’s not as if we’re taking a 1959 


dataset that is complete and that we know has 


a certain amount of integrity in terms of job 


coverage and back extrapolating that. We’re 


not, we don’t have by job analysis in 1959. 


We have a limited amount of data. Most of the 


doses in 1959 that are high were calculated 


notional doses for workers who were not 


monitored, and we’re taking the limited data 


available for paired data in that year and 

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back extrapolating it into a different time. 


For workers whose exact jobs and how 


they followed, how much time they spent, for 


instance, in the early years, you would have 


workers with less experience. As they became 


more experienced, they would do different jobs 


differently, more efficiently. The amount of 


experience that they would get in different 


jobs would vary. So even if the process is 


the same, it’s not at all guaranteed that when 


you’ve got a start up plant, that you’re not 


going to have many workers who have 


difficulties or following through the batch or 


the processes may take longer. 


So none of these things can actually 


be validated by any piece of measurement that 


we have, and that makes back extrapolation 


very iffy even leaving aside all the 


methodological questions like assuming a 


constant proportionality for a period of seven 


years between neutron and photon exposure for 


all workers. 


DR. ULSH: Well, let me talk about 1959 


first because you said that there wasn’t much 


data there. 

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DR. MAKHIJANI (by Telephone): I said it was 


limited. 


DR. ULSH: Okay, sorry. It was limited. 


In 1969 in Building 71 --


MR. GRIFFON: ‘Fifty-nine you mean? 


DR. ULSH: ‘Fifty-nine. I’m sorry. Thank 


you. Nineteen Fifty-nine in Building 71 I see 


310 people counted for gamma and 160 counted 


for neutron. And in 91, I’m sorry, Building 


91 in 1959 I see 216 people counted for gamma 


and 88 counted for neutron. So that is what 


it is. I’m not going to offer a qualitative 


judgment on this. That’s just, those are the 


numbers. 


Now, yet we did talk about, I mean, I 


talked about the job philosophy in terms of 


people following the batches through the 


process, all the way through the process and 


that did not change. Now could there be some 


changes because workers learned their job? 


Yeah, that’s not quantifiable. I mean, that’s 


true not only for the ‘50s, that’s true for 


any time when a worker starts. 


Those are the kinds of factors that I 


don’t think you can really get a quantitative 

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estimate on. We don’t do it anywhere else in 


the program. That’s why we use the 99th
 

percentile credibility limit to cover 


situations, those types of factors that are 


not quantifiable. 


So, yeah, Arjun, I agree with you. I 


mean, you can’t, there’s no way to evaluate 


that, but that’s not limited to this 


particular situation. That’s true everywhere. 


DR. MAKHIJANI (by Telephone): No, I 


disagree with that. I think it’s not just any 


time period we’re talking about. We’re 


talking about the first time period when Rocky 


Flats went into operation so that you had 


workers who were doing industrial 


manufacturing processes for nuclear weapons on 


an assembly line basis for the first time 


ever. This had not been done anywhere so yet 


you’re taking processes that were custom 


processes at Los Alamos and Hanford and 


translating them into mass manufacturing 


processes. 


And so you have workers who are 


necessarily doing something that was unique, 


where you don’t have an experienced 

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population. And then ^ a relatively 


experienced population because as I understand 


it there are no ^ very high from 1959 and back 


extrapolating that. Now it is not 


quantifiable, and that’s exactly part of the 


problem here. 


I do not believe that the appeal to 


the 99th percentile in IREP has anything to do 


with it. That’s simply part of the law. This 


has something to do, once the dose is 


calculated, this has something to do with how 


the dose is calculated. It has nothing to do 


with the 99th percentile. 


DR. ULSH: Well, it’s also not clear to me 


how the -- well, first of all, how long does 


it take to learn a job. I mean, okay, you can 


maybe make an argument for ’52, maybe ’53, but 


the next thing is how does getting more 


experience change the neutron to photon ratio? 


I just don’t see that. 


DR. MAKHIJANI (by Telephone): The number of 


workers was going up, and I have looked at 


many of the job cards as part of our 


evaluation of the gamma and beta dose 


completeness. And as Roger had said, there 

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were people applying to work there. The 


workforce was growing, and very often people 


would start in non-uranium work or janitorial 


work, and they would be promoted. And this 


happened within a period of months very often, 


and a promotion was very often into the 


plutonium area. So this was happening 


throughout the ‘50s. So it’s, I don’t have an 


analysis of this problem, and if NIOSH has an 


analysis of the problem, you know, we should 


have it. 


DR. ULSH: No, I --


DR. MAKHIJANI (by Telephone): It’s a 


difficulty with, it’s one of the difficulties 


with back extrapolation. The other ^ don’t 


have a job type analysis. Not everybody was 


following the batch in the same way. They 


were different, and the Stanfield thesis when 


it looked at these nine different methods, 


came up with nine different answers for 


neutron to photon ratios. 


And minimizing variance in a 


particular model doesn’t guarantee you that 


you’re going to calculate a bounding dose. 


That just says that the error is smallest for 

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the method you’ve chosen. It says absolutely 


nothing about the adequacy of the method for 


producing a bounding dose. 


DR. ULSH: We’re not required to produce a 


bounding dose. 


DR. MAURO (by Telephone): Brant, this is 


John Mauro. Can you folks hear me okay? 


DR. ULSH: Yes, sir. 


DR. MAURO (by Telephone): I’ve just got a 


factual question. In those 100 and so paired 


neutron to photon ratios collected for the two 


buildings in 1959, let’s say we have one 


building, and you have a set of, you mentioned 


on the order of about 100 or so, individual 


measurements. And if when you take those 


individual measurements, you get a range of 


neutron to photon ratios from a low to a high. 


Then for that building when you go 


ahead and back extrapolate, do you use the 


full distribution of the neutron to photon 


ratio to apply to the gamma dose, let’s say 


for the 1952 person, or do you use the upper 


95th percentile or in other words, 


mechanistically, when you are going to apply a 


neutron to photon ratio using the 1959 

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experience to an earlier time period, do you 


work with the full distribution, the median, 


the upper 95th percentile of those individual 


paired values? 


DR. ULSH: John, I’m going to take a shot at 


answering your question and rely on other 


people to correct me if I’m wrong. But I 


believe that the NDRP provides distributions 


of the neutron to photon ratio. Now, am I, 

anyone want to correct me? 

DR. MAKHIJANI (by Telephone): As I read it 

a constant number is used and is not 


calculated in the way that John suggested. 


Roger, correct me if I’m wrong, but 


the way I believe NDRP wound up calculating it 


was summing all the neutron doses and summing 


all the gamma doses and taking a single ratio. 


Roger? 


MR. FALK (by Telephone): Yes, that is the 


way that the ratios were determined. 


DR. ULSH: Okay, I stand corrected. Thank 


you. 


DR. MAURO (by Telephone): No, that’s very 


useful because then, now I understand. So in 


effect the ratio that was selected is sort of 

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an aggregate. Now, in the way I look at a 


problem like this is in the aggregate, that 


number might work. 


What I mean by that is let’s say we 


have a person that worked in 1952 through 


1956, and there’s reason to believe he worked 


in a lot of different functions which means 


that his experience in each change out of his 


gamma dose is going to reflect the cross-


section of neutron to photon ratios that, and 


not any one extreme. 


We’ve had this theme before. So the 


way I look at it is if, in fact, you have an 


aggregate ratio, and then you’re going to 


apply it to an individual, and I understand 


Arjun’s concern in going from an aggregate 


number which is really a population number to 


now I want to apply it to an individual. 


Now I would agree entirely with Arjun 


that if you were going to try to apply that 


aggregate ratio to a single change out for one 


person in let’s say one month in 1952, there 


would be a real problem with that. But if 


you’re going to apply that aggregate ratio to 


a person’s, let’s say to several hundred 

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change outs that he may have experienced over 


the course of many years, and there’s reason 


to believe that he had very varied experience 


by way of the nature of his exposures in those 


early years, then all of a sudden ^ the ring a 


little more true. 


But if it’s plausible that the person 


in the early years that you’re trying to 


reconstruct ^ may have worked at a single 


location in a particular job where he 


consistently was exposed to let’s say more of 


the higher end of the neutron to photon ratio 


as observed in your 1959 data, then I would 


say that then we’ve got a problem. 


So we’re back to a question that we 


have encountered before. There are times when 


using an aggregate ratio will serve us well. 


If the person that you’re assigning it to we 


have a good reason to believe he’s experienced 


a cross-section of the exposures. But if we 


don’t know that, and it’s possible that that 


individual over the time period for those 


early years worked in one location or one job 


function where it’s not inconceivable that he 


could have experienced the high end ratio, 

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then I think we’ve got a problem. 


So that’s how in listening to the 


conversation here, that’s where I come out as 


what we need to discuss and what needs to be 


addressed. Do you folks, I don’t know, I 


guess I’d like to hear a little perspective on 


that way of looking at things. Am I looking 


at it correctly? 


DR. NETON: John, this is Jim. I think I 


sense a slight shift here in the logic behind 


the arguments. You know, at one point I was 


getting the sense that SC&A was arguing that 


the data are not sufficiently robust to do 


anything. That’s kind of the sense I’ve been 


getting this morning. 


But your suggestion that, you know, 


it’s a matter of picking the right dataset to 


use to reconstruct the doses sort of shifts 


the emphasis to imply that the data may be 


sufficient to do dose reconstructions just 


that maybe we’re not going about it the right 


way. 


DR. MAURO (by Telephone): I don’t want to 


cut short the other aspect. In other words 


I’m not saying, now there may be more issues, 

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there are multiple layers of issues. 


DR. NETON: Right, but I’ll tell you, I’m 


not sure this discussion, the previous 


discussion needs to be finished and agreed 


upon before we go to whether it’s the 95th or 


the 50th percentile. We’ve been down that path 


many times. 


DR. MAURO (by Telephone): I just wanted to 


get that clear in my mind. Now what I’m 


hearing is notwithstanding that issue, and I’m 


agreeing with you, Jim. What I’m hearing then 


is that’s not really where the issue lies 


because that is a tractable problem if it’s 


just a matter of judging whether we should 


operate off the 95th percent. Now what I guess 


I’m not fully understanding is that there are 


other issues that are ^ go beyond the matter 


of whether we should be picking off the 95th
 

percentile off a full distribution of paired 


numbers. There are other aspects to what has 


transpired that undermine that. And I guess 


for my own benefit if I feel I suspect other 


people have experienced it also, there are 


other aspects or nuances to this extrapolation 


problem that ^ ^ just raised. 

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DR. MAKHIJANI (by Telephone): John, we 


don’t even have a 95th percentile for neutron 


to photon ratios in the way things were done. 


So, yeah, there are a lot of prior questions. 


DR. NETON: Well, it could be calculated, 


Arjun. 


 MR. SHARFI: The NDRP is --


DR. MAKHIJANI (by Telephone): We’re just 


addressing what was done in the NDRP project 


and how ^ was set up, and what the critique of 


that is and the centrality of this. Now, they 


chose this one method out of, I don’t know, 


nine different methods that are mentioned here 


that I’m looking at. Let me see how many 


there are. I can tell you how many there 


were. One, two, three, four, five, six, seven 


^, nine different methods that were tried to 


calculate the same number with nine quite 


different results. 


And so there are a lot of prior 


questions, and there is a problem in that I 


didn’t say ^. It seemed to me that N/P ratios 


that are aggregated by building would give you 


a good idea of what was the typical average 


dose in that building. But under 42-CFR-83, 

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that’s not the question you’re trying to 


answer. 


MR. GRIFFON: Mutty had something to say 


here. 


 MR. SHARFI: Arjun, the NDRP study did 


provide a 95th percentile notional dose. 


DR. MAKHIJANI (by Telephone): Yes, they did 


provide ^ percentile on the notional dose. 


 MR. SHARFI: On the upper end of the --


DR. MAKHIJANI (by Telephone): Right, but 


based on a ^ the N/P ratio was calculated as a 


single number based on a particular 


aggregation of neutron and photon doses. 


DR. ULSH: Building specific, I mean --


DR. MAKHIJANI (by Telephone): No, no, I’m 


not saying, I’m just trying to be clear about 


what was done. That’s all. 


DR. MAURO (by Telephone): For clarity 


purposes just so I think to understand where 


we are, what I’m hearing is in 1959 for two 


different buildings we have 100 or on that 


order individual paired measurements that we 


believe are robust. They’re reliable ratios. 


In other words those 100 or so measurements 


for a given building are, those individual 

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measurements are something that are robust 


numbers for that year. 


Now the idea being now, and the 


question I guess I want to put on the table 


is, given that we have those numbers for that 


building, those 100 numbers for 1959, I guess 


I’d like to hear a little bit more about, and 


maybe this has been covered, but what is it 


about that that creates a situation that we 


may still not necessarily be able to 


reconstruct the neutron to photon ratios that 


might, that one individual might have 


experienced in a given year. 


In other words what I’m hearing is 


that there might be a problem being able to do 


that. That is, taking that full distribution 


of 100 paired numbers and say here’s the range 


of neutron to photon ratios, and now somehow 


I’m going to use that data to somehow figure 


out a claimant favorable, but still plausible, 


upper bound on what the neutron to photon 


ratio may have been for a given worker in, 


let’s say, 1952. 


Could ^ or Brant, what are the 


challenges associated with that because the 

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layers of problems the way ^ I’ve been 


listening ^ complex that I’d like to hear just 


a simple like what would it be about that 


situation that would make it very difficult to 


reconstruct the neutron exposure that that 


particular person experienced, let’s say, in 


1952. 


DR. ULSH: Well, I mentioned earlier the 


questions that we considered when we were 


evaluating whether or not this extrapolation 


was a good thing to do. I’m not sure if 


that’s what you’re talking about or not. 


Those --


DR. MAURO (by Telephone): I’m asking a very 


simple question that goes right to the, I’ve 


got 100 paired measurements in 1959 for people 


that worked in this building, given building, 


and which give me my neutron to photon ratio 


distribution for those 100 or so workers. Now 


all of a sudden I have another worker that 


worked in 1952 and all I’m really hearing is 


that, well, let’s see, can we use that data 


somehow to figure out what the neutron dose 


was to the person that worked in 1952 in that 


building. 

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And what I’m really hearing is a 


disagreement or there’s some concern. In one 


case someone says, yeah, I think we can do it. 


And the other person’s saying, well, there are 


a lot of things that are still uncertain here 


that I’m not sure whether you can do it. 


And I guess I’m really bringing it 


down to if I were about ^ understand where the 


problem lies in being able to go from the 1959 


distribution of neutron to photon ratios back 


to the 1952 given that I do have ^ exposure 


for that fellow in 1952. 


DR. NETON: The only argument I’ve heard so 


far against that is Arjun’s supposition or 


assertion that workers would gain more 


experience over time; and therefore, their 


time at any different station might be 


different between ’59 and the earlier years 


although I might argue that the time would be 


slow and be ramped up equally among each of 


the stations. 


DR. MAKHIJANI (by Telephone): Well, that’s 


not the only argument. I mean, I have a whole 


list of bullet points. 


And John, you have an incomplete draft 

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in your e-mail to look at. 


DR. MAURO (by Telephone): I understand. I 


mean, I think that I am listening as everyone 


else is around the table, and I’m starting to 


understand what the -- I guess I’d like to 


understand more given that starting point, but 


I ^ really fundamental and you’d understand. 


I’d like to get a better appreciation of the 


other dynamics at work here. 


Jim had just mentioned one, and you 


had mentioned one, Arjun, the fact that 


there’s experience changes. What I heard is 


that there were some, I’d like to hear a 


little bit more of what are the other 


challenges to be enabled to do that that are 


before us, that when we engage in this ongoing 


dialogue that will continue certainly after 


this meeting, what will that be about? What 


are these other challenges? 


DR. MAKHIJANI (by Telephone): Let me try to 


give you an idea of, repeat some of the things 


that I’ve said. I talked about the validation 


of these doses and some way to find whether 


the calculated doses are claimant favorable, 


much less bounding or not. If for a period in 

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which you have measurements of real workers, 


say, with particular job types, or even an 


average, say, following a badge through, if 


you define it as one composite job, when you 


have neutron and photon measurements, you can 


take the workers with paired measurements, and 


you can also calculate doses using the 


notional dose approach for those workers. And 


you can validate whether your model is good or 


not. For from ’52 to ’58 we have no 


measurements for Building 71, and so it’s not 


possible to validate it that ^ measurements. 


And so it is not possible to validate it that 


way. 


There’s a question about the whole 


neutron to photon ratio approach that is 


raised in the NDRP itself is that this 


approach has been chosen ^ out of one of many 


different approaches that were examined, none 


of which, some of which have advantages over 


this one and disadvantages over this one. 


This was selected to minimize the variance or 


uncertainty in the results in a particular 


statistical model --


DR. NETON: And I think we’re not talking 

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about the NDRP model now. We’re talking about 


why we couldn’t use these 80 or 100 data 


points to back extrapolate. 


DR. MAKHIJANI (by Telephone): I’m just 


giving John the picture of why I think --


well, there’s the underlying problem with the 


model itself which is compounded by the back 


extrapolation. That’s basically what I’m 


trying to explain. 


DR. NETON: But John has suggested if you 


threw away the model and you’ve got 80 to 100 


data points, now what can you do? I mean, we 


don’t need to talk, rehash, what’s wrong with 


the NDRP model at this point is what John’s 


saying. 


DR. MAKHIJANI (by Telephone): You don’t 


have any way to validate what you’re going to, 


whether the doses you’re going to calculate 


are bounding doses under the rule as I read 


it. 


DR. MAURO (by Telephone): This is very 


helpful to me, I’ll tell you why, because what 


I’m hearing is that ^ have 100 measurements in 


1959. And let’s say someone would say, well, 


let’s just take the highest ratio ^ that turns 

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out to be or something at the 95th percentile, 


and ^ that would place a plausible upper bound 


on what some earlier worker might get. 


What I’m hearing, Arjun, and I’m not 


disagreeing with you; don’t get me wrong. I 


just want to understand what you’re saying is, 


well, that’s not good enough. You’ve got to 


do, in other words, we don’t know if that 


distribution that was captured in 1959 has, in 


fact, any resemblance to the exposure 


distribution that a given worker may have 


experienced in an earlier year. In other 


words you need a little bit more way of 


validating that distribution that somehow it 


has applicability to the earlier years. Did I 


say that correctly? 


DR. MAKHIJANI (by Telephone): John, we’re 


in the process of critiquing something that 


hasn’t even been created. The issue on the 


table that we’re evaluating is NIOSH’s SEC 


evaluation report in which it says it can 


calculate doses in thus and such a way; and 


therefore, it’s not a problem. And that 


method is the NDRP method, and that for ’52 to 


’58 involves a particular approach. And as I 

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understand what we’re doing is we’re writing a 


review of that. 


DR. MAURO (by Telephone): Okay, I guess 


what I just raised is, you’re right, Arjun. I 


posed, I guess, a more, the question was 


related to is there a way to ^ you have lots 


of concerns about the method that was 


selected. I guess I’m trying to get to the 


point where, notwithstanding the method that 


was built, the bridge that was built, 


recognizing that we may have lots of 


disagreement regarding that particular 


methodology, I guess I’m ^ --


DR. NETON: This I don’t think is very 


dissimilar from where we ended up with 


external doses at Y-12 in the SEC evaluation. 


DR. MAURO (by Telephone): I think you’re 


right. 


DR. NETON: We had a lot of disagreement 


internally among us about the maximum 


likelihood estimation methods, but at the end 


of the day we all looked at the data and 


agreed that based on the data that we did 


have, some method of bounding the doses could 


be, was plausible. So I don’t see that too 

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much different here. I don’t know. 


MR. FITZGERALD: Except I don’t think we’ve 


reached closure on sort of the first issue is 


that whether or not there’s a problem with the 


’52 to ’58. I think that’s what we --


DR. NETON: Exactly. 


DR. ULSH: We do have, I don’t think 


anyone’s disagreeing that we do have -– 


(Whereupon, telephonic transmission 


interrupted the proceedings.) 


MR. GRIFFON: I mean, it might be almost 


time for a break. Let us all reflect on 


because we’re getting deep into the weeds. I 


think we need to take a break, step back and 


see where we’re at. 


 DR. WADE: If you can hear us, we’re going 


to take a break. 


MR. GRIFFON: We’re going to take a lunch 


break. So we’ll reconvene at 1:30 if that’s 


okay. 


(Whereupon a lunch break was taken from 


12:30 p.m. until 1:45 p.m.) 


 DR. WADE: Mike, are you with us? 


MR. GIBSON (by Telephone): Yeah, I’m here. 


 DR. WADE: Are there any other Board members 

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on the line other than Mike? 


 (no response) 


 DR. WADE: Any other Board members other 


than Mike? 


 (no response) 


 DR. WADE: David, why don’t you ask your 


question of the work group Chair? 


MR. HILLER (by Telephone): Thanks, this is 


David Hiller of Senator Salazar’s Office. 


While we were waiting to reconvene I had asked 


Lew kind of what the burden of proof is. I’m 


not sure that’s the right term in this 


context, but that’s my legal history creeping 


up on me. 


I’m trying to figure out if in this 


context the burden is on the government or 


NIOSH or the appropriate agency to demonstrate 


the validity of its methodology and accuracy 


of its dose reconstructions, or if the burden 


is really on the petitioners here and kind of 


in the context of today’s discussion in a 


sense the burden is on SC&A to demonstrate 


that the methodology is unreliable and 


produces inaccurate results. 


MR. GRIFFON: Lew, did you want to --

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 DR. WADE: Well, I’ve answered it. 


MR. GRIFFON: -- take a crack first? I 


didn’t hear your answer to I’ll listen to 


Lew’s and then I’ll ponder that. 


 DR. WADE: I’ll give you a briefer version 


than what I did before. I really approached 


the answer by looking at the sequence of 


things. First, the petitioners in their 


petition present their arguments why they 


think this class should be added to the 


special exposure cohort. 


And this special exposure cohort rule 


goes to issues of the ability to cap dose or 


bound dose with sufficient accuracy. There 


are all kinds of concepts we could talk about 


with that, so the argument is presented by the 


petitioners. NIOSH responds with a petition 


evaluation report. NIOSH gives its logic as 


to why they agree with the petitioners or why 


they don’t agree with the petitioners. 


And those two data points then make 


their way to the Board, and the Board has to 


consider both arguments and decide upon its 


recommendation as guided by the statute. The 


Board will often as it has in this case asked 

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for further deliberations to take place and 


assign it to a work group and dig through 


issues and sift through issues to try and come 


to a clear understanding. 


The one thing, David, that I will 


point out to you that SC&A really is a 


participant but not an active participant in 


this. SC&A is a contractor that does what the 


Board or the working group asks it to do. 


SC&A is not presenting final arguments. SC&A 


is just informing the process by their 


scientific deliberations. 


So again, the Board will look at the 


petition, will look at NIOSH’s evaluation 


report. It will look at what the work group 


brings to it. It will deliberate and debate 


and then make a recommendation. 


MR. GRIFFON: And I think just to add, I 


don’t disagree with that. As the work group 


has gone along, I think it’s important to 


point out that we always turn to NIOSH for, to 


do sort of the follow up investigations. So 


the Board isn’t really going to the site and 


investigating these issues independently that 


way. 

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But we’re getting data back from NIOSH 


to support their arguments or, and then we’re, 


we consider that data that’s put on the table 


that way. So in that sense I think, you know, 


the burden there is for NIOSH to demonstrate 


that, I think the burden falls to NIOSH there 


to demonstrate that they can, in fact, do the 


dose reconstructions. 


But it also is we have to, I think 


we’ve started to consider sort of the weight 


of the evidence in our deliberations. The 


Board has to lean to some extent, look at sort 


of the weight of the evidence issues because 


sometimes there’s not a bright line on some 


things. But sometimes we can come to a place 


where we are pretty or very confident that we 


can get a plausible upper bound. So that’s 


the terms Lew was referring to. 


MS. MUNN: And if the science is sound. 


MR. GRIFFON: Yeah, and then the science is 


sound. So does that sort of answer your 


question? 


MR. HILLER (by Telephone): Yeah, I guess 


one of the things it suggests is when I think 


I detected from this morning’s conversation 

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which is it’s very tough when you are trying 


to look back at old issues, and you don’t have 


the data you’d like to have from that time 


period to give you independent validation. 


MR. GRIFFON: Right, right, and that’s why 


we have these deliberations about were there 


process changes? How did you determine this? 


And without those independent measurements 


necessarily are there other ways to sort of 


corroborate that method. So, you’re right. 


Anything else to add, Lew, or --


 DR. WADE: Well, just to look to our 


process. The one thing I think we all try and 


do is make the process open, let everyone 


participate and really expend a great deal of 


effort of trying to get to the core of issues. 


And again, the Board and its work group really 


deliberates and works hard towards getting to 


the core of the issues and tries really to see 


that the concerns of the petitioners are heard 


and investigated. And that’s why sometimes 


the process takes so long. 


MR. GRIFFON: Okay. 


MR. HILLER (by Telephone): Thank you. 


MR. GRIFFON: Thank you. 

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MR. HILLER (by Telephone): And I’ll point 


out that no one is going to accuse you of 


rushing through this. 


 DR. WADE: We’ll take that as an endorsement 


of our practice. 


MR. GRIFFON: I think we want to, well, we 


definitely want to close out the neutron 


issue, but I’m not sure exactly where we left 


off. We had, I mean, my sense of the end of 


the discussion before lunch was that we have 


this question of the back extrapolation, but 


then we were starting to get into some 


dialogue of how to correct it. 


But I’m not sure that there’s any, I 


mean, I’m not sure that I’ve heard clearly 


that there’s a problem with it. So I was 


getting a little confused that some people 


were throwing out proposals for how we might 


bound it, but I think the current proposal on 


the table is that this approach is what we’re 


using, and it works. There’s no reason to 


look at another model. 


So maybe starting there, Brant, I’ll 


let you --


DR. ULSH: Mark, I think that’s certainly 

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our position at this point in time. We’ve 


heard SC&A’s concerns that Arjun expressed. 


We really can’t come to any conclusion about 


those concerns until we see the analysis. As 


soon as it comes over we certainly will give 


it due consideration. 


There was some discussion as I recall 


about -- and this is probably where it got 


confusing -- was trying to determine whether 


even if we have these disagreements about the 


back extrapolation, is it a tractable issue or 


is it an SEC issue. I think that was some of 


the discussion that was going on. And Jim, I 


think, was talking about source term. 


DR. NETON: Well, yeah, I was just trying to 


point out that we do need to look at the SC&A 


analysis and see if there’s any issues with 


the NDRP model that would affect our ability 


to do dose reconstructions. But, in fact, at 


the end of the day we believe these can be 


reconstructed. There’s a source term involved 


here that’s pretty well defined. 


We know they started with around 200 


grams of plutonium in the early ‘50s and 


worked their way up to something like 1,200 

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grams. And physics is physics. I mean, you 


can model the neutron/photon ratio or 


calculate it very precisely actually coming 


off of a source term such as that. 


And whether one chooses the moderated 


or in a worst case an unmoderated source term, 


you can come up with a ratio from that 


activity. And in our estimation that would be 


a worst case analysis of ^ neutron/photon 


ratio. In fact, that could be used to in some 


sense be used to look at the ratios that were 


derived in the NDRP study to, in effect, maybe 


not a validation in the traditional sense, but 


at least a sanity check against some of those 


numbers. 


And we’re prepared to do any, we’re 


prepared to look at the data and look at the 


plans. And then also if we do have to change 


our position, which I’m not saying we would at 


this point, but there are other techniques 


that are available to us. 


MR. GRIFFON: Timing obviously is of the 


essence here, but we also have to consider 


this question, don’t we, of the aggregate 


nature of the N/P ratios being applied to 

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individuals in the prior time period? 


DR. NETON: Yeah, I think that’s right. We 


need to look at this whole set up, and I’m not 


MR. GRIFFON: I’m not saying you can do it 


real-time here, but I’m just --


DR. NETON: I’m not convinced in my mind. 


I’m not close enough to it to know exactly how 


they, what the aggregate ratios, how they were 


applied. In some sense I don’t know whether, 


did they take exactly that or I’ve heard a 


couple excerpts where they were extremely 


conservative approaches, where they believe 


that they’re almost like bounding 


calculations. So we can just take a closer 


look at the NDRP analysis itself to see where 


they ended up. They do provide 95th percentile 


dose estimates. We need to look at that and 


see how those were derived, what factors were 


included. So there’s a, we need to do a 


little more homework on this. 


DR. ULSH: Yeah, and these issues were just 


discussed within the past week, so I mean, we 


do need to --


MR. GRIFFON: Right, right, right. And 

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we’ve all been, I mean, to everybody’s credit 


we’ve been working real hard in the last two 


weeks to come to closure, but we’ve got to get 


this right. 


But I guess the other observation that 


I had with these N/P ratios -- and this gets 


back to some of the discussions about the 


production and whether it was modified or 


anything -- and I don’t even have the exact 


years, but I, we were discussing a little at 


the break. I think it was ’63, ‘4 and ‘5 


where they have, they sort of used a ten, a 


ratio of ten for the N/P ratios. And it has 


an asterisk saying it’s kind of an upper 


bound. It was just administratively said. It 


wasn’t necessarily the average value, the 


calculated value. 


But I was just trying to understand 


because when Jim was talking about, well, we 


could use just a pure source term approach and 


calculate it, it seems to me that those years 


were when the americium was coming in, and 


you’d actually have lower neutron to photon 


ratios. And why were the tens coming up in 


that time period and the ratios lower in the 

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early -- I’m not necessarily asking for an 


answer. I’m just trying to figure that out 


myself. 


DR. ULSH: I think I have an answer. 


MR. GRIFFON: All right. 


DR. ULSH: I’m recalling from our conference 


call two days ago that those tens with 


asterisk that you’re talking about were for 


Building 91 in the years that you said, three, 


four, five. 


MR. BUCHANAN: ‘Sixty-two, three and four. 


DR. ULSH: ‘Sixty-two, three and four, okay. 


But the americium line is not in Building 91. 


MR. GRIFFON: Oh, okay. 


DR. ULSH: So I’m thinking that those two 


are unrelated. Now I can’t tell you why the 


tens, but I don’t think it has anything to do 


with the americium. 


MR. GRIFFON: So it was just for 91. I 


didn’t realize that. So where do we stand 


overall on this? We’re going to have, you’re 


going to look closer, SC&A’s going to, are you 


going to wait for some materials from SC&A? 


This doesn’t have to be privacy reviewed to be 


exchanged. 

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MR. FITZGERALD: I think, I don’t know. 


Arjun’s given me a very, very tight timeframe. 


When would be the reasonable time to provide 


something to Brant? 


DR. MAKHIJANI (by Telephone): Well, you 


know, Joe, it just depends on how much of an 


internal check you want. We’re in the process 


of preparing this. As you know, last night 


when Ron and I talked, some of the numbers I 


came up with weren’t the same as some of his. 


And so I don’t think we should be providing 


NIOSH and the working group with numbers that 


we don’t have, you know, we have to make sure 


that the data is properly sorted and that we 


were internally talking about the same sets of 


data. So I can’t really see that we’re going 


to be able to digest all of this and address 


all the periods until Wednesday. Now if you 


want to chop that up and say let’s serve up 


the ’52 to ’58 first, and then postpone the 


other stuff. I mean, that presumably we could 


focus on the ’52 to ’58 and send it off by 


Monday or something. 


MR. GRIFFON: Would that save time? 


DR. MAKHIJANI (by Telephone): But if you 

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prefer that, because then you get a piecemeal 


report. 


MR. GRIFFON: I think we might want to do 


that, Arjun. And we might even have to be in 


a position of either another technical call or 


another work group call because I don’t want 


to travel in the next week. But we might want 


to, yeah, if you can do the ’52 to ’58 by 


Monday, then maybe have a call on that on 


Wednesday or something. 


DR. MAKHIJANI (by Telephone): I’ll try to 


have it out by Monday close of business. And 


I guess, Ron, this will mean -- Ron, are you 


there? 


MR. BUCHANAN: Yeah, I’m here. 


DR. MAKHIJANI (by Telephone): Will we be 


able to talk about data between now and Sunday 


and for you to be able to review what I’ve 


done, what I write up, because I’m really 


relying on you, you know, you’re familiarity 


with the data much more than mine. 


MR. BUCHANAN: Yeah, okay, well, I think we 


can have, I can review your write up for ’52 


through ’58 tomorrow, try to have you 


something by close of business tomorrow that 

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you can --


DR. MAKHIJANI (by Telephone): Yeah, well, 


we need to go over a lot of the data, too. So 


anyway we can talk about that offline. 


So we’ll deliver the ’52 to ’58 before 


the close of business on Monday. 


MR. GRIFFON: And then we’ll, Brant and Joe, 


I’ll coordinate it for you. We have a 


technical call. I think we can keep it to 


technical calls at this point, and we’ll 


certainly notify all work group members and 


everything. But if we need a work group, one 


final work group call before the May meeting, 


I mean, we’re running out of space here. 


 DR. WADE: It’s your call. 


MR. GRIFFON: But I mean if we were to look 


at this ’52 to ’58, and we have some technical 


sort of exchange that needs to go on, I think 


we could do that in the next couple days after 


that. And then I’ll certainly notify Lew and 


get the word out if we’re going to have a full 


work group call it’d probably be the next --


MS. MUNN: The Monday before the meeting. 


MR. GRIFFON: The Monday before the meeting 


might be the day we might want a work group 

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call. 


MS. MUNN: Might be a wise idea. 


MR. GRIFFON: I know. I know. But we’re 


running out of days so we really do want to 


push for --


 DR. WADE: Really the only difference 


between the technical and the work group call 


is we have the court reporter. 


MR. GRIFFON: Exactly, and maybe a few less 


people involved. And then the other time 


periods we’ll just assume you’re going get out 


your full report by Wednesday, right? Or 


whatever. 


MR. FITZGERALD: Yeah. 


MR. GRIFFON: All right, everybody’s on a 


tight timeframe. I know it’s, and just for 


the record, I mean I think I don’t think we’re 


at this point where the neutron stuff and, you 


know, I don’t think we anticipated this much 


in-depth work at this point, but sort of here 


we are. I think we had this neutron issue on 


the table for awhile, and I think we might 


have underestimated the depth that we were 


going to have to go into a few of them, but 


we’ll just have to do our best from this point 

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forward. 


DR. MAKHIJANI (by Telephone): Mark, may I 


also say one thing regarding a comparison that 


was made before lunch just so at least, you 


know, I think there are quite a few 


differences between Y-12 and this dataset and 


actual situation and the job descriptions and 


so on. So if there’s an impression that it 


might be sort of simple to say we did it at Y12 and so we can do it here, from what I know 


of the data that are available, I think it’s a 


much more complicated question here. 


DR. NETON: Arjun, this is Jim. I think I 


made that comparison. I wasn’t trying to say 


your comment on the simplicity of it, I was 


trying to comment on the process. 


DR. MAKHIJANI (by Telephone): Yeah, right, 


no, no, I’m just kind of worried about, I know 


last night by the time I talked to Joe I was 


so tired that I could not talk about what I 


had written. So I don’t want to get to that 


point and be working in that mode. 


MR. GRIFFON: All right, I think we’re 


leaving neutrons unless there’s anything else. 


Obviously, we’ll be talking in the near future 

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about these issues. 


THORIUM
 

Then the next agenda item I think, as 


I’m opening my computer, was thorium. Let me 


just attempt to give a little introduction to 


the thorium question then. The way I remember 


this, the way I remember it from the last work 


group meeting is that the work group and SC&A 


have sort of, have accepted NIOSH’s definition 


of the source terms, the various source terms. 


So we pursued this for awhile. We had 


some questions of other source terms of 


potential significance. And we basically feel 


that NIOSH has turned over every rock they can 


find, and we have a good handle on the source 


term of thorium. Where SC&A has some 


disagreement is the method. The method on the 


table I think is the NUREG-1400 approach. 


And I think that SC&A in their report 


that was recently provided had some concerns 


that that does not bound some of the potential 


exposures. And now my understanding also was 


that there was this other sort of set of, or 


other data available, and we had discussed 


this a little bit at the meetings, and we have 

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some references. 


And I may have this wrong, but Adley 


comes to mind as one of the reports. I don’t 


know if that was uranium or thorium or, anyway 


there were some other references that were 


recently found by NIOSH or SC&A or both 


parties that had, that looked at sort of 


several different processes and work places 


that involved either thorium or uranium 


exposures. 


And they looked at sort of the general 


airborne concentrations from various processes 


and things like that. And we had said, and I 


think NIOSH offered, that they would consider 


this data and see if, in fact, it was, could 


be used as a bounding or to validate their 


approach ^ approach. And I guess that’s the 


question is, you know, if the NUREG-1400 


approach, there’s some question whether it 


bounds the exposures. 


If there is other data there that we 


all agree is in a form that can be used to 


bound the exposures, then I think it comes 


down to a sort of a dialogue between the two 


parties of sorting out the method that’s going 

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to be used going forward. And it may not be 


an SEC issue. But if, you know, I have to 


hear a little bit more about what this other 


data, you know, how appropriate it is for 


application at Rocky Flats and the operations 


you have. 


And I think SC&A may have more 


questions than I do, but that’s sort of where 


I stand with the thorium question. So the 


source term we agree with. The methodology 


there’s questions about whether it bounds, but 


at least speaking for myself, I believe you 


have other data there that if you chose to use 


that, it’d probably be used to bound those 


exposures. So, I’ll turn it to Joe first, 


then Brant. 


MR. FITZGERALD: Yeah, I think that’s a 


pretty good summary. I think this ^ category 


I had mentioned earlier where we think again 


there’s enough data available, but the concern 


is the method and whether or not it would be 


bounding in terms of the potential exposures. 


In this case I think there was some 


equivocalness introduced in some calculations 


that NIOSH provided in December where we felt 

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that it showed the opposite, but maybe there’d 


be instances where it would not necessarily 


bound it. And I think that’s our concern on 


1400. And I’ll let Arjun jump in. It is 


really from there. It’s not that we don’t 


think it would be feasible to do a bounding 


approach, we just don’t think NUREG-1400 has 


been shown in this particular instance to do 


that in all cases. 


Is that a fair approximation, Arjun? 


DR. MAKHIJANI (by Telephone): Yeah, yeah, I 


think it is. Just to be specific, in the 


December paper, leading up to the December 


paper, Jim Neton had suggested that there be a 


comparison with centerless grinding and so on 


to see whether NUREG-1400 was bounding. And 


as I read NIOSH’s paper and the numbers 


presented in that paper, the intakes from the 


process numbers, the measurements from other 


plants were much higher than the NUREG 


numbers. And so the validation exercise for 


NUREG as a bounding dose failed, but NIOSH 


continues to say NUREG is bounding which I did 


not understand. 


And then we had a separate validation 

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exercise using time weighted data in the next 


paper whose date I don’t remember. And as 


we’ve pointed out in several different 


studies, and specifically made an analysis in 


Mallinckrodt in the context of an SEC, that 


you couldn’t use time weighted averages for 


bounding individual doses because time 


weighted averages are just that; they’re 


averages. 


And when they involved two and three 


measurements you’ve got very big 


uncertainties, and then you have to try to 


calculate a bounding dose or a 95 percentile 


to see whether your dose is actually bounding. 


And in that exercise also NUREG-1400 did not 


hold up. And that is in our, the calculations 


are in our report if I remember right. 


And so on both tries where a numerical 


test was applied to NUREG-1400 it actually 


failed so in my opinion it’s not an equivocal 


question. I think the demonstration of the 


bounding nature of NUREG-1400 failed. 


DR. ULSH: I have similar recollections to 


Mark, but my recollections go a little bit 


further. We did talk about at the March 7th
 
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working group meeting that there were these 


other data sources available. Adley was one. 


A book by Albert on the industrial hygiene of 


thorium, those were both provided by NIOSH. 


And John spoke very highly of them 


although SC&A needed more time to review. We 


also spoke about there was continuing 


disagreement between SC&A and NIOSH on the 


applicability of NUREG-1400 to a bounding 


analysis. So far we are in agreement in our 


recollection. 


DR. MAKHIJANI (by Telephone): Right. 


DR. ULSH: But I recall clearly that we had 


agreed to disagree and that this was 


categorized as a TBD issue and not an SEC 


issue. I’ve got to tell you I’m a little 


exasperated that we’re talking about this in 


the context of an SEC issue. 


DR. MAKHIJANI (by Telephone): I guess I 


have a procedural question in terms of how I 


understand things. Does NIOSH have to, just 


in terms of the criteria that we are expected 


to follow that the Board laid down, and what 


happens when the criteria are seen to fail, 


now the Board has said you have to give some 

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kind of a proof of principle, and the first 


step in that is you have to specify a method. 


And when the specification of a method 


failed, then we’ve said there likely are data, 


but they belong to other sites, and there’s 


some kind of demonstration that’s needed to 


show that they can be properly applied. And 


in that context we all agreed that if that 


were done, it likely would not be an SEC 


issue. 


But as I understand it, NIOSH is 


insisting that NUREG-1400 is bounding, and in 


my analysis and the analysis that we did in 


our report, both of those assertions of 


validation actually failed. And so we’ve got 


a factual, technical situation where we’re 


making opposite assertions about the same set 


of numbers in which the Board’s criteria are 


not being fulfilled. 


And if I’m wrong, I’ll just stop 


talking about it and it’s certainly not my 


province to say how the Board’s criteria 


should be applied. We’re just doing the best 


we can in understanding what the Board’s 


criteria are. 

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159

 DR. WADE: Let’s let Mark --


MR. GRIFFON: I think, Arjun, I think, and 


my recollection also, and I haven’t looked at 


the minutes, but my recollection was that we, 


as in general we did sort of say, you know, 


with this Albert reference and this other 


reference, it was my sense that we had enough 


there to be able to bound. Now quite frankly 


I don’t, and I still haven’t looked in detail 


at the analysis that you just talked about, 


Arjun, that you’re saying that the NUREG-1400 


doesn’t bound those two circumstances. 


And whether what we said in the last 


meeting, irrespective of that, I guess, I 


would like to go into the next meeting saying 


that I don’t think we want to go in as the 


Board having SC&A say we don’t think that 


NIOSH’s approach is bounding. So what I was 


hoping is that if we can hear from NIOSH that 


these other two references have this data, and 


we’re not necessarily committing to this 


method, but we would deliberate further with 


SC&A on the NUREG-1400 versus this method. 


But if we choose to, we have this data here 


that could be used as well. 

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And let SC&A say, okay, if you went 


that direction, we’re in agreement. And then 


sort out the details afterwards, and that 


would be more of a TBD issue. It gets a 


little bit in this gray area of this proof of 


process, and I think you have to show that 


it’s feasible to reconstruct dose with 


sufficient accuracy. 


And then the question of, in my mind I 


guess, is when we’re looking at feasible, we 


have to at least know enough about do you have 


the data there, and do you know how you’re 


going to, how you can apply it. Whether we 


need to see you commit to one method or 


another, you know, even if there’s still 


disagreement. 


And this is my opinion. I’m not sure 


I’m on very solid ground here, but even if 


there’s a disagreement of methods, if at least 


one of them everybody agrees is bounding, then 


we can have further arguments on which one is 


correct as a TBD issue. I don’t know how 


other people feel on that. 


DR. ULSH: Well, let me respond to that, 


Mark. Certainly, we would agree to discuss 

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161 

NUREG-1400 and these other data sources 


further. Certainly we would. But that would 


occur in the context of the TBD issue, TBD 


discussion. That was the consensus that was 


reached at the March 7th meeting. 


MS. MUNN: Yes, it is. 


DR. ULSH: We agree that this data looks 


promising, the Adley and the Albert, sure it 


does. Now in terms of NUREG-1400 --


MR. GRIFFON: But you’re not in a good 


enough position right now to at least describe 


the Adley data, and how promising it looks, 


and how it would or would not be applicable to 


Rocky Flats? 


DR. ULSH: Well, I do have to say that our 


primary position has been and remains the 


NUREG-1400 is bounding. We also think that 


Adley looks promising. Now, of course, we are 


in disagreement with SC&A about NUREG-1400, 


and since those issues have twice now been put 


on the record, SC&A’s objection to that, I 


feel I do have to respond. However, I 


refrained last time because we had this 


consensus that it would be a TBD issue, and I 


did not want to disturb the consensus that we 

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had reached. 


In retrospect I guess that was a 


mistake because SC&A has backed away from that 


consensus, and I would like to know, I mean, 


we knew that we were in disagreement about 


NUREG-1400 on March 7th . That’s not a 


surprise. We knew that. But consensus was 


reached at that meeting that this was not an 


SEC issue. It was a TBD issue. So what new 


has come up between then and now to make SC&A 


walk away from that consensus? 


DR. MAKHIJANI (by Telephone): Well, I think 


that this is not a very accurate or full, at 


least a full characterization. My 


understanding -- well, first of all at the 


last working group meeting we had not had a 


chance to analyze the weighted, time weighted 


average validation exercise that you had done. 


When it was actually put to the test of the 


numbers, it did not meet them so that 


necessarily happened after the meeting because 


we got the paper just before the meeting. So 


that work could not have been completed at the 


time of the meeting. 


Secondly, my puzzlement on this 

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question is not relating to whether doses can 


be calculated, and therefore, whether it’s a 


TBD issue. And I think that’s the context in 


which I remember an agreement last time. My 


puzzlement is when you’ve got something before 


you that fails the criteria of the Board 


affirmatively that NIOSH could retain the 


option of using that as a bounding dose method 


and insist that it is a bounding dose method, 


and say, well, the disagreement disappears 


because this other thing is there, but we may 


never use it, and we may use a failed method. 


That’s what is puzzling me. 


DR. ULSH: I’ll first talk about what was 


actually agreed to on March 7th, and then I’ll 


get into your objections about NUREG-1400 


since it’s an SEC issue. 


DR. MAKHIJANI (by Telephone): Well, I don’t 


know. I cannot look at the minutes. I don’t 


have them in front of me. 


DR. ULSH: I can help you out with that 


because I have them. 


DR. MAKHIJANI (by Telephone): Well, can we 


talk about the substance of the technical 


matter? 

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164 

DR. ULSH: We certainly can, but first we 


have to talk about what was agreed to. These 


are from the draft minutes. Ray is finishing 


the official version. 


MR. GRIFFON: What page? 


DR. ULSH: Well, on the draft it’s 142. I 


don’t know what page it will be on on the 


final. 


COURT REPORTER: The pages will stay the 


same. 


DR. ULSH: The pages will stay the same, so 


it’s page 142. 


Mark Griffon says -- and this is in 


the context of the thorium discussion -- “But 


I think at least for those two things, like 


you said, the source term and the exposure 


model, and I think at least we’re probably at 


the point where we can say that we may not 


agree with them all right now, but we think it 


can be. There are ways to model and bound the 


doses and when you know the source term. Is 


that a fair synopsis?” 


And Dr. Makhijani says, “Yes, I think 


that’s fair.” And then Mark says, “And then I 


think the upshot of that is I think that it’s 

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165 

removed from our SEC sort of deliberations, at 


least that aspect of it. We want to still 


bring it to ground, but it’s not on that 


urgent profile.” 


Page 150, Larry Elliott says, “Well, 


you know, SC&A’s going to finalize their 


report, and I would hope that in that 


finalization of this point alone they would 


refer to the consensus that I think I hear 


today and designate the issue as being site 


profile related. And then we can take it up 


in that form. If you’re explicit enough in 


what your concern is about NUREG, then we can 


react to it from this report in a site profile 


discussion form.” 


Dr. Makhijani says, “Yeah, we will do 


that.” 


MR. GRIFFON: But hold on. Let me just add 


on the bottom of page 142, after I stuck my 


neck out a little bit so to speak, Arjun did 


come back and in the last sentence there says, 


“The one Becquerel piece that comes out of the 


NUREG-1400 remains unconvincing. 


DR. ULSH: Yes, that’s on the thorium 


strikes. 

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MR. GRIFFON: Oh, the thorium strikes, yeah. 


DR. ULSH: Right. 


DR. MAKHIJANI (by Telephone): The context 


of this discussion, I believe, is the idea 


that NIOSH would not use NUREG-1400 if there 


were a disagreement about whether it was 


bounding or not. I don’t disagree that you 


can calculate these doses. The data appear to 


be there. You haven’t done it yet because 


you’re sticking with NUREG-1400. 


And subsequently when I looked at this 


issue, and when we talked about it internally 


with Joe and John and as a team, it seems to 


me that if -- and we did the calculations 


after the March 7th meeting, and they are in 


the report -- that the claim that NUREG 1400 


met the test of bounding dose by that time 


weighted average calculation actually, in the 


calculations that we did, it did not meet the 


test. 


And then when you’re writing a report, 


you have the Board’s criteria in front of you 


that you have to actually have some proof of 


principle. You have something in front of you 


that’s actively failed the test every time it 

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167 

has been put to the test, then unless you 


reject that method, I do not see how it can’t 


remain an SEC issue. And if that method is 


rejected, then it no longer is an SEC issue, 


and I believe that’s what our report said. 


DR. ULSH: Okay, so I still didn’t, at the 


March 7th meeting we knew that we were in 


disagreement about NUREG-1400. That is not 


something that was discovered afterwards. 


DR. MAKHIJANI (by Telephone): But we had 


not checked your validation exercise, and I 


believe there was a discussion about that as 


well. 


DR. ULSH: If you didn’t agree with it on 


March 7th, and you don’t agree with it now, but 


we agreed to have a consensus that it was a 


TBD issue, nothing has changed. 


Now in terms of the substance because 


you’ve gone into your objections to NUREG-1400 


several times, and like I’ve said, I’ve 


refrained from responding. Now I will 


respond. 


The validations that were performed, 


first of all, we disagreed strongly with even 


the need to do a validation exercise of a 

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168 

standard that is widely accepted by the 


regulatory community; however, we recognize 


that it is to no one’s benefit to go before 


the Board in disagreement. So we agreed to do 


these validation exercises. 


It was suggested by you, Arjun, that 


we look at Simond’s Saw and Steel, and that we 


also look at Rocky Flats’ application. That 


is exactly what we did. At Simond’s Saw and 


Steel we took the highest of 20 monitored 


workers. 


Let me back up a little bit. You 


suggested Simond’s and Rocky, and we took a 


look at that, considered your suggestion and 


it actually turned out to be a very good 


suggestion because it had the advantage of 


having a well-defined source term, a well-


defined processing time, and air monitoring to 


go with it. So those were very good criteria 


and that allows you to do a good comparison. 


So we did that comparison on your 


suggestion. At Simond’s Saw and Steel there 


were 20 monitored workers. We took the 


highest of the 20. Yes, it was a time 


weighted average. I think that you’re 

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misinterpreting the applicability of time 


weighted averages, and perhaps Jim can jump in 


on that. We took the highest, and we found 


that even with the highest worker, NUREG-1400 


was bounding. 


Then we looked at the ingot operation 


at Rocky Flats which is described in the 


Callabra report. This is all in our February 


28th report. And in that case as well you had 


a well-defined source term. You had a well-


defined processing time, and you had some air 


monitoring. That’s the best we’re going to 


get at Rocky Flats, but that’s what you 


suggested. That’s what we did. And in that 


case it turned out to be bounding. 


Now you’ve mentioned the previous 


method of looking at uranium operations. As 


we pointed out in our report, that methodology 


incorporates a time factor, so we had to 


estimate how much processing time. And that’s 


why we thought your suggestion to actually 


look at thorium processing operations with 


well-defined parameters in terms of source 


term and processing time was a good one 


because you didn’t have to estimate that time 

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factor. That is the explanation for the 


difference that you see on the uranium 


comparison. 


So even when we took your suggestion 


and did the validations you suggested, and 


they turned out to be bounding, now all of a 


sudden it’s not any good any more. Jim, will 


talk about, I think, time weighted averages. 


MR. GRIFFON: Let me hear, because I heard 


from Joe actually in the December report --


MR. FITZGERALD: I think it was February. 


MR. GRIFFON: Okay, February. I’m hearing 


an indication that in their own analysis that 


the NUREG-1400 wasn’t bounding, but I’m not 


gathering that you said that. 


DR. MAKHIJANI (by Telephone): That’s 


correct. If the table --


MR. GRIFFON: I want to understand that. 


DR. MAKHIJANI (by Telephone): Sorry, Joe. 


MR. FITZGERALD: Go ahead, Arjun. 


DR. MAKHIJANI (by Telephone): It’s on page 


167 of our report where NIOSH’s table from the 


December report, I believe --


DR. ULSH: From the December report. 


DR. MAKHIJANI (by Telephone): Yes, it’s 

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from the December 21st report is reproduced. 


It’s an attachment, the whole thing is in 


Attachment 20 of our report. So if you look 


at that, the time factor is actually taken 


into account. The number of hours per year 


which are assumed for machining and grinding 


are ten hours per year, and the Becquerel 


intake is assumed based on only ten hours per 


year. So there isn’t, like we’re not 


comparing like 250 days per year in some place 


with a few hours per year at Rocky Flats. 


We’re comparing ten hours per year with ten 


hours per year. And the intakes and doses 


that were calculated were in both cases bigger 


than what -- and in one case considerably 


bigger than what was calculated by NUREG-1400. 


That was in the December 21st report. That’s 


why I believe the need arose for a second 


round. Now, we didn’t agree then. I still 


cannot understand how you can do a calculation 


like this with a limited number of hours and 


then say that there is a time factor that 


hasn’t been taken into account when it’s right 


here in the table that it has already been 


factored into the result. And the result was 

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much bigger. 


I can’t, what was the NUREG-1400 


Becquerel intake? It was a fraction of a 


Becquerel if I remember. And the grinding, 


the centerless grinding suggested by Jim Neton 


as a validation exercise, not by me, came out 


to be a considerably bigger, at least an order 


maybe two orders of magnitude bigger, than the 


prior estimate. And I do not believe, I do 


not understand actually how this can be 


characterized as a validation that NUREG-1400 


is bounding. 


DR. ULSH: All right, let me clarify. You 


referred to a page in your report that 


referenced our December report. 


DR. MAKHIJANI (by Telephone): Yes. 


DR. ULSH: The December report contained the 


methodology that Jim suggested, you’re correct 


on that, about looking at uranium numbers and 


converting based on equal mass basis to 


thorium. And involved in that process, that 


incorporated the estimate of ten hours which 


you mentioned. The source of that estimate 


was Bryce Rich because we proposed it earlier 


to give a bounding estimate of the thorium 

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machining at Rocky Flats. 


DR. MAKHIJANI (by Telephone): Yeah, it was 


the same time as you used in NUREG-1400. So 


it’s a factor that just cancels out. 


DR. ULSH: I would have to go back and look 


at that. I don’t think I --


DR. MAKHIJANI (by Telephone): If you use a 


larger or smaller time in NUREG-1400 and the 


same time in this new calculation, you’ll get 


exactly the same ratio. You won’t get a 


bounding dose. 


DR. ULSH: Arjun, NUREG-1400 does not have a 


time term in it. 


DR. MAKHIJANI (by Telephone): No, I know, 


but you used a time term with NUREG-1400 to 


calculate the intake, and you’re using the 


same time here. So if you get this being 100 


times the previous one, the time factor 


doesn’t enter into it. 


DR. NETON: No, Arjun, you could pick any 


time factor and change that analysis. 


DR. MAKHIJANI (by Telephone): Yes, and the 


ratio will be the same. 


DR. NETON: No, it won’t. 


DR. ULSH: No, it won’t. 

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DR. MAKHIJANI (by Telephone): If you use 


the same time in both calculations --


DR. ULSH: Arjun, time does not come into 


the NUREG-1400 calculation. It comes into 


what you’re comparing it against, and that is 


an air concentration times the time in that 


air concentration gives you an estimated 


intake along with all the other factors in 


terms of inhalation rate. Now Jim --


DR. MAKHIJANI (by Telephone): That’s right, 


you do have to have a time to calculate the 


intake. 


DR. ULSH: Yes, and let me finish. Jim 


suggested this method. This was one of the 


brainstorming sessions at the end of one of 


our previous working group meetings. Once we 


got into it, and we realized that the results 


are completely dependent on the time that you 


choose, then we realized that that was a 


weakness of that approach. 


And in concert with that we had a 


conference call with SC&A, with you and I 


can’t remember who else, and you suggested 


that we look at actual thorium operations. 


And you even suggested by name Simond’s Saw 

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and Steel and Rocky Flats. And we did that. 


And in both cases NUREG-1400 yielded higher 


estimates than what was actually observed. 


DR. MAKHIJANI (by Telephone): I believe 


that our analysis of that which has been 


reviewed internally is before you in our 


report so I don’t know that it is useful to go 


through why we arrived at a different 


conclusion from you about those data because 


how many workers were there at Simond’s Saw 


that you were looking at time weighted 


averages? 


DR. ULSH: There were 20 people. 


DR. MAKHIJANI (by Telephone): I believe --

DR. ULSH: Twenty workers. 

DR. MAKHIJANI (by Telephone): -- sorry? 

DR. ULSH: There were 20 workers at Simond’s 


Saw and Steel. Twenty monitored workers. 


DR. MAKHIJANI (by Telephone): And there 


were air concentration data if I remember. 


Then we’re not talking their monitoring data. 


DR. ULSH: They were B-Z air data I believe. 


DR. MAKHIJANI (by Telephone): Right, well, 


I stated that we looked at the time weighted 


average and the methodology to calculate 

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bounding doses, and this is time weighted 


average for a particular job which would 


correspond to some job presumably at Rocky 


Flats. And we’ve stated the time weighted 


averages when you do sporadic work do not 


correspond to a bounding dose. That is the 


analysis that we’ve presented. Now, we’ve got 


a disagreement about that, and I don’t know, I 


mean --


DR. NETON: I think, Arjun, this is Jim. On 


the time weighted averages I think you’re 


misrepresenting the case. We agreed early on 


at Simond’s Saw that Simond’s Saw and Steel 


time weighted averages were not applicable to 


Bethlehem Steel because we could not determine 


that the work practices were similar. That 


was the only reason. 


We did not say time weighted averages 


weren’t useful for calculating intakes. And 


so what we have here is a job-specific time 


weighted average which is indeed applicable 


for this analysis. I mean, it’s the best 


analysis you could have. 


MR. GRIFFON: In other words, you’re saying 


the job’s comparable to what would be at 

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Rocky? 


DR. NETON: ^ comparability job. It’s a 


comparability, it’s to demonstrate that the 


NUREG-1400 calculation would be bounding in 


that application at Simond’s Saw and Steel. 


It has no validity to compare it to Rocky. 


DR. MAKHIJANI (by Telephone): Yeah, no, I 


agree with Jim on that. The question of 


whether time weighted averages should be used 


to calculate bounding dose in the context of 


an SEC was discussed in detail in one of our 


reports on Mallinckrodt, and all that has been 


done here is to really do a short form of 


exactly that same analysis and much more 


briefly --


DR. NETON: No. 


DR. MAKHIJANI (by Telephone): -- and refer 


you to that. 


Now if, Joe, I believe that you and 


John and maybe Mark need to take over this 


because what’s in the report is very clear. 


We’ve said this before in the context of 


Mallinckrodt. We’ve said it again in the 


context of Rocky Flats, and I don’t believe 


that there’s any difference in the technical 

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position. Now if there’s a policy decision, 


that is not in my province. 


DR. NETON: Arjun, this is not the same 


issue. We are not calculating bounding doses 


here for dose reconstruction purposes. We’re 


trying to demonstrate that the NUREG-1400 


concept accurately portrays what the intakes 


would have been for a job. 


DR. MAKHIJANI (by Telephone): That’s not 


what has been represented. What has been 


represented is NUREG-1400 provides a bounding 


estimate of the intakes for thorium using a 


source term. 


DR. NETON: It does for that job. For that 


particular job, NUREG-1400 bounded that 


person’s exposure. 


DR. MAKHIJANI (by Telephone): I don’t 


believe you can compare that to a time 


weighted average because time weighted average 


doesn’t provide you with a bounding intake. 


DR. ULSH: All right, time weighted average 


does not bound an instantaneous intake. That 


is true. 


DR. MAKHIJANI (by Telephone): You’ve got 


two or three samples in a work station. 

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DR. NETON: Oh, now you’re challenging the 


validity of the time weighted average --


DR. MAKHIJANI (by Telephone): No, I’m not 


challenging the validity of it as a time 


weighted average, I’m challenging the validity 


of it to represent the intakes for that work 


station as a bounding dose. That’s two 


completely different things. If you have 


1,000 workers doing the same job, that would 


likely be the average. But then you would 


have significant uncertainty still because 


you’ve got very few measurements at each 


station. 


DR. NETON: This is the best estimate of the 


intake for that worker at that time. 


DR. MAKHIJANI (by Telephone): But maybe 

it’s not good enough. 

DR. NETON: Why? 

DR. MAKHIJANI (by Telephone): For the 

reason that I’ve told you. There are a couple 


of measurements at each work station for each 


job, and when you have got a piece of that job 


that may even last only 15 minutes, if you’ve 


got two measurements that are highly variable 


one from the other, the uncertainty of the 

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intake for that particular 15 minutes is going 


to be huge. 


And then from one day to the next, 


from one hour to the next, and certainly over 


a cumulative of a few hours and a year, you 


could have two workers getting very, very 


different doses. And that is the objection to 


applying a time weighted average in this 


context for producing a bounding dose 


comparison. I don’t think it’s that 


complicated. 


DR. ULSH: I don’t either. 


DR. NETON: I don’t think so either. 


DR. ULSH: Arjun, it’s true that a time 


weighted average will not allow you to 


calculate, to bound an instantaneous dose that 


a worker might experience. But in terms of 


the intake that could result from a job that 


is more than instantaneous, and in this case 


at Simond’s Saw and Steel we’re talking about 


I think it was eight hours. The only way to 


get an accurate estimate of intake is from a 


time weighted average. 


DR. MAKHIJANI (by Telephone): Are we 


talking a best estimate of intake or a 

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bounding estimate of intake? What does NUREG 


produce? 


DR. ULSH: NUREG-1400 produces a bounding 


estimate, and we showed that --


DR. MAKHIJANI (by Telephone): Well then, 


you have to try to calculate a bounding 


estimate from Simond’s Saw to compare it to. 


DR. NETON: No, no, no, no, no, you’re 


wrong, Arjun. 


DR. MAKHIJANI (by Telephone): Well, this is 


my understanding, and this is how the report 


is written. And so that’s why I’m saying this 


is beyond my purview at this stage. If we’re 


not comparing a bounding dose to a bounding 


dose, then I don’t think it’s an apples-toapples comparison. And then somebody else has 


to define what kind of comparison we have to 


make because that’s ^ calculation I know how 


to do. 


DR. NETON: All right. 


MR. GRIFFON: Hold on. Let Jim --


Go ahead, Jim. 


DR. NETON: All I was going to say is our 


position was that NUREG-1400 provided a 


bounding dose, and we took an estimate of the 

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worker’s intake which was based on breathing 


zone air samples and probably a G-A sample 


locally, and we demonstrated that it bounded 


his exposure. 


DR. ULSH: For the highest of 20 workers. 


DR. NETON: For the highest of 20 workers. 


I’m not sure why you wouldn’t accept that as 


demonstrating that this approach would bound 


that worker’s dose. 


DR. MAKHIJANI (by Telephone): I have stated 


the reason, and for the record, in my opinion 


and my reading of the document, the sample 


that was represented as a breathing zone 


sample for Rocky Flats was not representative 


of a breathing zone sample in the document. I 


do not believe that it is. 


DR. ULSH: We’re not talking Rocky Flats. 


We’re talking Simond’s Saw and Steel. 


DR. MAKHIJANI (by Telephone): I’m just 


saying that for the record because the term 


breathing zone came up. I’ve said what I 


believe. I don’t believe that a time weighted 


average can give you a bounding dose, and you 


have to calculate a bounding dose to compare 


it to another dose that’s claimed to be a 

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bounding dose. 


And I just think that’s not a 


mathematical matter anymore, it’s how we 


understand the terms. And I think it’s maybe 


for the Board to define the terms, not for me 


certainly. As Dr. Wade has said, we do the 


calculations and the process as directed, but 


this is the best of our understanding. 


 DR. LITTLE: Arjun, this is Craig Little. 


You keep talking about time weighted averages, 


and it seems to me that their breathing zone 


sample is exactly that. It’s a time weighted 


average. A person wearing a breathing zone 


sampler wears it for the period of time that 


he’s in the atmosphere that he’s breathing, 


and it integrates over the period of time that 


you have it. And you calculate his input per 


hour based on how many hours he wore the 


breathing zone sampler and what the intake was 


over that period. That is a weighted average. 


DR. MAKHIJANI (by Telephone): Yeah, Dr. 


Little, I do understand that. What I am 


putting forward is that when you have a couple 


of measurements, for instance, when you have a 


very high concentration in a certain work 

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operation, you have to have some confidence 


that you know what that concentration is. 


When you have two or three measurements of 


that that are very different from each other, 


you’re going to have a very high uncertainty. 


And therefore, when you try to 


calculate a bounding dose for that person as 


to what they might inhale if they only worked 


a few hours a year, you’re not going to get a 


bounding dose estimate by using the time 


weighted average. I’m not arguing about what 


a time weighted average is and whether it’s a 


legitimate number to calculate. 


DR. ULSH: I think it’s safe to say that we 


have a technical disagreement that’s not going 


to be resolved today about this time weighted 


average. So I only have one question for, I 


guess for Joe. 


MR. FITZGERALD: Yeah. 


DR. ULSH: About what is the SC&A final 


report going to say about thorium in terms of 


whether or not it is an SEC issue? And then I 


have the same question for the working group. 


Because we’re not going to settle the 


technical --

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185 

MR. FITZGERALD: First off I think certainly 


we’ll take responsibility for what was said on 


the March 7th meeting. Clearly, we needed to 


have this exchange that was truncated when 


apparently we felt we had consensus when we 


did not have consensus. So I think that’s 


pretty clear just from this exchange that at 


that particular work group meeting on this 


issue we did not, in fact, reach closure even 


though I think at that time, maybe it was late 


in the day, we thought we were done. 


So for the benefit of the work group, 


your benefit, too, I think we certainly owe, 


not at this session perhaps, but some 


resolution so that, you know, this is a 


technical issue. And I agree, it’s a 


technical issue unlike maybe some of the other 


more subjective questions that we’re 


addressing. This is a technical issue. I 


would hope that we would put the Board in the 


position in two weeks that they would have a 


resolved technical answer to this issue. 


And I would commit that we will 


certainly work with you to do that. I mean, 


let the chips fall where they may on the 

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discussion of time weighted average, whatever. 


We didn’t have this discussion. I feel 


responsible that maybe we covered too much 


ground and didn’t get as much of this out as 


we should have at that time because I think 


there is clearly some missed communication, 


misunderstanding, maybe some disagreements on 


the facts that I think and hope we can resolve 


over the next week or so. 


But I think we ought to go back and 


finish that conversation we started on March 


7th, and just put the Board in the position if, 


in fact, this is, as we put it earlier, a TBD 


issue after all. I would just as soon not see 


this as a standing question to be presented on 


May 2nd . 


MS. MUNN: It was a surprise to me to see it 


in this report because my understanding was 


that we were going to approach it as a TBD 


issue, and from this individual perspective it 


was off the table for our SEC discussions. So 


to have it appear as it has in this current 


report was a surprise for me. I was taken 


aback. As soon as I saw thorium, I --


MR. FITZGERALD: Yeah, I think we probably 

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187 

talked about some of the reasons why there was 


some sense of not leaving this question there. 


But nonetheless I think it’s one that we have 


to resolve and not put you and the rest of the 


Board in the position of having any 


ambiguities about this technical question. We 


certainly have other ambiguities. 


MS. MUNN: That’s true. 


MR. FITZGERALD: We don’t want to have any 


more than that. So I would propose that we 


address it that way. And again, I certainly 


apologize for the confusion over the 


statements made. I think we did truncate that 


conversation quicker than we should have, and 


we should have had the benefit of some of this 


discussion on the time weighted average and 


what have you. It did not take place --


MR. GRIFFON: Yeah, I can’t remember. And 


part of it might have been that we had your 


report but SC&A hadn’t really had a chance to 


assess it, and we kind of assumed. And I 


probably got ahead of myself, too. But I’ll 


finish this discussion where I started which 


is that if, you know, my feeling is that if --


and it sounds like everyone agrees that the 

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data’s out there that could be used to bound 


whether you agree with NUREG-1400 or not --


and there’s some question on the application 


or the comparison of this data. 


But if we’re in a good position to say 


that we think we have data for these type op ­

- that are applicable to these type operations 


at Rocky that could be used to bound, I think 


we can leave the methodology dispute. We can 


just say we’ve got the data. 


DR. NETON: Well, I think we did a 


calculation the first time around. I mean, it 


didn’t agree with NUREG-1400, but that 


certainly in my mind was a bounding 


calculation. I don’t know what else --


 DR. WADE: And the good news from a 


procedural point of view is that this work 


group deals not only with the SEC question, 


but also with the site profile question so 


this work group will have to deal with that. 


MR. GRIFFON: And all I’m asking is that 


even if Arjun and SC&A are in disagreement of 


the way you did that bounding analysis with 


the other data, I don’t think he disagrees 


that there’s data there to be used, and it 

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could be a, you know --


DR. NETON: Well, that’s my point though. 


The first analysis had some arbitrary time 


factor which we thought was unusually large. 


MR. GRIFFON: Well, I’m not saying that’s 


the analysis we would use, but --


DR. NETON: But if one agrees that that time 


factor’s appropriate, then there’s an 


analysis, and I don’t see what the issue is. 


MR. GRIFFON: Then there’s an analysis. 


DR. NETON: I’m not saying that’s the 


analysis we would use, but --


MR. GRIFFON: The only reason it comes up 


this way is because the final, I guess, the, 


it’s sort of like where we were at with the 


neutron. The proposal on the table was NUREG1400. So that’s what Arjun was arguing 


against. But I think if we all agree that the 


data’s there, and as Jim just stated, you can 


choose to use that, but you have that out 


there. Then I think it goes to a 


methodological review. 


And I mean I won’t, SC&A is going 


present what they’re going to present. I 


would say from my perspective I think at that 

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point, as a voting member of the Board if I 


was in a position where I could feel like 


there’s solid data there. I have some 


questions about NUREG-1400 still because of 


some things that the contractor’s raised, but 


I feel pretty solid that there’s this safety 


net in the back that could certainly be used 


to bound. And I’d be comfortable with saying 


it’s a non-SEC. That’s sort of where I stand. 


DR. MAURO (by Telephone): John Mauro. I 


have another, maybe a little bit more to add 


that might be helpful. When we discussed the 


fact that something is a TBD issue, it’s 


always been my understanding that we leave the 


door open. That means both SC&A and NIOSH 


agree that we, at this current time we may not 


entirely agree on the methodology by which 


best to reconstruct this dose, but we both 


agree that it can be reconstructed. 


Now that usually means that the door 


is still open, that the day will come that 


we’re going to revisit this issue again as 


part of the site profile review. And I think 


the reason for the dilemma that we have here 


is it sounds as if that door’s been closed. 

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Namely, that no, we’re going to go with 1400, 


and this is our procedure, and it’s not a TBD 


issue either. 


DR. ULSH: No, no, no. 


DR. MAURO (by Telephone): And I think 


that’s really where the dilemma lies 


unfortunately. It’s just really a matter of 


are we right now in the position to agree 


that, yes, the door is still open. We will 


certainly be, at some time in the future, 


discuss this. And if we can do that, then I 


think we can put it behind us as an SEC issue. 


MS. MUNN: Yes. 


MR. GRIFFON: NIOSH is saying yes, that the 


door’s still open and it’s a TBD issue. 


DR. ULSH: Absolutely. We still have 


confidence in NUREG-1400 but we recognize that 


you don’t. We recognize that there are other 


data. I think this is probably a heated 


discussion for another day. 


DR. MAURO (by Telephone): Good, because I 


think that we’ve been arguing when we didn’t 


have to. As long as the door is open related 


to the TBD, I think that we’re all in the same 


place. 

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MR. GRIFFON: I think part of it, and 


Brant’s right. I hate to go back to transfer 


some ^ for future meetings. I’ve held back a 


few past times in the Rocky Flats meetings to 


be honest, but I mean, we did say, and part of 


it is this, you know, I think we all feel the 


pressure to narrow this list. 


And I certainly said that it was a 


non-SEC issue, probably did not have SC&A’s 


full analysis. At that point I’m not sure if 


we had it or not. But anyway, I think we’re 


all saying now the door’s still open for the 


TBD process. 


 DR. WADE: And it’s this work group that 


looks at it. 


MR. GRIFFON: Right. 


All right, are we done with the 


agenda? No, we’re not. I feel like we should 


be done. I’m kind of --


MS. MUNN: How will this appear in the final 


report? How’s this going, is this going to 


change? It should change if we’re going to 


present this --


MR. FITZGERALD: Well, I think in the 


addendum I’d like to take a crack at it in 

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terms of capturing what we’re talking about 


here. Putting in perspective that this is not 


a debate on NUREG yes or no, but an agreement 


that even though there continues to be some 


technical differences on NUREG-1400 that there 


are alternate means available, and certainly 


they’ll be explored on the basis, a TBD basis. 


Just kind of lay that out for the record. 


We’ll also indicate that consensus was 


reached in March 7th, but clearly there was a 


misunderstanding; and therefore, we’re at this 


point. Just something that will put things in 


perspective and make sure it’s very clear. 


DR. MAURO (by Telephone): I’d like to add a 


little bit. I think to a degree this was 


triggered by one of the criteria that we 


operate within, within the SEC guidance that 


the working group put together. One of the 


items is an example of proof of principle. 


And I think that’s what really triggered this. 


In effect, what we’re really saying is 


we certainly can construct at this time 


several examples of the proof of principle 


which covers a range of different approaches 


that theoretically could be used. One of 

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which we would all agree upon or at some time 


in the future we believe that we -- how do I 


say this? The fact that we don’t actually 


have, right now, in the evaluation report, an 


example of the proof of principle that we all 


agree upon, yup, that’s the way to do it. 


I think that’s what the problem is 


with the conversation we’re having. And as a 


result, SC&A is put in the difficult position 


of saying, you know, you didn’t meet that one 


criterion by providing a proof of principle 


because that hasn’t been done yet. So I’m 


trying to find a way to say that, well, the 


conversation that we just had implies that, 


well, we probably could, if we wanted to right 


now, develop other methods that would also be 


other ways in which we could reconstruct or be 


a little bit more conservative that SC&A 


believes would be more consistent with what we 


believe is the right way to do it. 


So in a way the problem we’re going to 


have, Joe, is writing our language in such a 


way in our report that it’s able to concur, 


yes, in principle, that criteria in principle 


has been met because we believe that such a 

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model can be applied. But we’ve got the 


strange situation we’re in because we’re on 


the horns of a dilemma. We want to say it’s 


behind us, but we sort of have in front of us 


this criteria of proof of principle. I’m not 


quite sure what to do about that. 


And maybe, Mark, do you have some 


thoughts on that? 


MR. GRIFFON: No, that’s why I said, I think 


we’re sort of in this middle ground, and I’m 


trying to, you know, I think part of the 


reason the Board went down this whole path of 


proof of principle was that we needed to hear 


more than we have a lot of data. And so, and 


then we sort of went through this hypothetical 


phase when we said, oh, that’s getting us in 


trouble for a number of reasons so we wanted 


proof of principle. 


But I think in this case, I think 


we’ve had enough discussion around the other 


data that is available. It’s more of the 


application of it that there still remains 


some disputes over it. So it’s not just a 


matter of, so I think in a sense, you know, we 


haven’t completely had a proof of principle 

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because NIOSH is still sticking with the 


original model. But –-


(Whereupon, telephonic background noise 


interrupted the proceedings.) 


MR. GRIFFON: You okay, John? 


 DR. WADE: Somebody’s going to have to look 


at their phone situation. There’s a race car 


sound. We’re hearing all kinds of noises. 


MS. MUNN: I thought it was a Harley. 


 DR. WADE: So please mute your phone. If 


you can’t control background noises, hang up. 


MR. GRIFFON: But we have the, you know, we 


have this, I guess my position is that NIOSH 


has gone further than just saying that we have 


other data out there. They’ve looked at it. 


We’ve seen what kind of data it is, and now 


there’s just a dispute about application. So 


I think we have a sense that there is data 


there that could be used to bound. If you 


take the position that you don’t want to agree 


with NUREG-1400, there is this other data that 


could certainly be used or that’s my sense 


anyway right now. 


MR. FITZGERALD: I think what John though is 


pointing out, this is a dilemma I referred to 

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earlier where we get into proof of principle 


which is how to gauge the application of that 


additional data without actually going through 


a demonstration. And I think that’s a general 


challenge when you get into proof of 


principle. 


 DR. WADE: I think the only answer is common 


sense. I mean, the reality is when the Board 


votes on an SEC petition not all the dose 


reconstructions will be done, and that’s a 


reality. So you’re going to have look at 


reasonableness of what is undone and make some 


judgment. I applaud the Board’s desire to see 


as much as it can, but in point of fact not 


everything will be done. 


MR. GRIFFON: And what I was trying to say 


here is that we have more than just NIOSH 


coming in and saying we’ve got lots of data 


for that. They’ve actually examined it 


further than that and broken it down further 


than that. So we have more than just data 


there that, you know, well, we have this data 


there. We could use it if we want. They’ve 


examined it to some extent. So there’s been 


analysis on it. 

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MR. FITZGERALD: I think certainly we want 


to go ahead and attempt to frame it up in that 


context and just see what we can do. 


DR. ULSH: Yeah, more than one way to prove 


a principle I guess. 


MS. MUNN: But the first week of May, the 


only issue with respect to thorium, that’s 


going to be before us, is whether or not our 


lack of information and lack of ability forces 


an SEC cover on the thorium issue. And that’s 


not the case. That’s simply not the case. 


The data is there. The dose can be 


reconstructed. The thorium issue is not an 

SEC issue. 

MR. GRIFFON: The last question I have on 

thorium, and this should close it out I hope, 


is -- and I talked to Brant about this. The 


question of how do you determine who gets 


assigned thorium dose. And I think you’ve got 


a good handle on that. I did ask him earlier 


if he could say something for the record so we 


have a good sense of that. But then otherwise 


I think it’s --


DR. ULSH: Right. Mark, you’ve got to 


consider or recall that there were a couple 

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different types of thorium operations at Rocky 


Flats. The first was the ingot operation that 


occurred in I believe 1960. I’d have to look 


and make sure. There is a notation in one of 


the health physics log books that covers that 


operation that lists, I believe it’s nine 


individuals by name, and for some of them by 


badge number. So we know pretty well who was 


involved in that operation. So that’s the 


thorium ingot operation. 


Now, for the thorium strikes I’ll just 


give you a couple of sentences of context 


here. The thorium strikes were in terms of 


physical extent of the operations, were a lot 


like a chemistry experiment in that it was a 


very small physical operation. In other words 


the thorium strike was performed inside a 


reaction vessel which was in turn inside a 


high integrity glove box. 


So there were only a couple of people 


that were directly involved with the hands on 


part of the thorium strikes. And those two 


individuals wrote a detailed report on the 


chemistry and the process. I’m not going to 


say their names on the record just because I’m 

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not sure if I can, in an overabundance of 


caution. 


One of the people we have interviewed, 


and he told us directly the details of that 


operation. So those are the two people that 


you would expect to be at highest risk in, to 


the extent that there was any for internal 


exposure in a thorium strike. There were also 


some additional people who were monitoring 


health physics coverage because that type of 


operation has a very high external exposure 


hazard. So it did receive a lot of attention. 


But it’s primarily going to be those two 


people directly involved in that. 


And then finally, you have the final 


operation which was the, receiving the 


finished parts, thorium metal parts, from Y12. There, there’s really no external 


exposure potential. Now let me go a little 


further on that. The finished parts were used 


in models, and I don’t really want to go a 


whole lot farther than that. Originally, and 


I regret saying this to this day, I said I 


can’t tell you that if there was a high spot, 


they didn’t go grind it off. 

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Well, at that time that was true. I 


couldn’t say that. But since then, and I 


think this is in our report, our latest 


report, we have interviewed the research 


machinists who, if they had done any grinding 


or machining of those parts, these are the 


guys that would have done it. And I can’t 


remember exactly how many individuals that we 


talked to, but more than one for sure. And 


they said we just don’t recall doing that. I 


mean, we didn’t machine these parts. 


So therefore, I don’t think there’s an 


internal exposure hazard for that particular 


operation. It’s not so much of an issue. But 


the other two, the thorium strikes and the 


ingot operation got a pretty good handle on 


who was involved. So I think that is how I 


would answer Mark’s question. Unfortunately, 


for those of you on the phone, Mark has left 


the room briefly. 


 DR. WADE: Why don’t we take a five-minute 


stretch break. Mark is not with us. Five 


minutes we’ll be back. We’re going to, we 


won’t break the contact line. We will mute 


the phone for five minutes. Just a quick 

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break, thank you. 


(Whereupon a break was taken from 3:00 p.m. 


until 3:13 p.m.) 


 DR. WADE: Mike and the three in the room? 


Okay. 


MR. GRIFFON: I think, since I left a little 


early, I think we closed out thorium, correct? 


DR. ULSH: I’ll go for that. 


MR. GRIFFON: Closed out again. I know, 


second meeting in a row. 


DR. ULSH: I just repeated our earlier 


discussion on the record. 


MR. GRIFFON: I apologize. I wanted to 


catch, Jim Neton was leaving and I had to ask 


him something. 


DATA COMPLETENESS
 

So now we have data completeness, and 


I’ll just turn it over to Joe and ask you to 


give us an update on this. This is one of the 


five, right? We’re going back to your 


original four. 


MR. FITZGERALD: Really given the span of 


issues that we addressed in data completeness, 


and it was quite extensive, I think that was 


quite a bit of progress to get it down to just 

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the question revolving around, I believe it’s 


441. 	Am I correct, Arjun? 


DR. MAKHIJANI (by Telephone): No, 4-4-4. 


MR. FITZGERALD: Four-four-four, I’ll get it 


right, non-plutonium workers and the questions 


of a bounding analysis. And again, I think we 


tend to in these other issues talk about proof 


of principle or try to demonstrate if the 


approach is bounding more than whether the 


concept is, itself, valid. And I think this 


is one of those cases. 


Arjun, do you want to add? 


DR. MAKHIJANI (by Telephone): Yeah, I mean, 


we looked at the data that Brant gave and all 


the other data that they put up, that NIOSH 


put up on the O drive, and Brant is right that 


there was a lot of data on Building 44. Now 


we didn’t see any job types identified in that 


data. 


Brant, do you have any job types 


identified with Building 44 data? 


DR. ULSH: Well, Arjun, I think to get that 


type of information you would have to link the 


individuals’ hard copy file and look at their 


cards. 

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DR. MAKHIJANI (by Telephone): So we 


couldn’t discern right away how that data 


would be used for bounding dose. There 


certainly does seem to be extensive data for 


the period about which we were concerned in 


terms of data completeness for that building. 


So presumably something could be put together, 


but there is a proof of principle issue that’s 


why it is still mentioned. 


I can’t remember now exactly the words 


in our report, but I think that is the 


context. Let me just go there. That is the 


context in which it is brought up for 


Building... I think all it says is NIOSH 


would either show that foundry workers are the 


workers maybe at risk of high shallow dose 


were routinely badged or sufficient data are 


available. There are certainly quite a lot of 


data, but we haven’t been able to parse it. 


That’s why it’s still here. 


And there’s a not a dissimilar issue 


for Building 81 where there are actually not 


data, but where the risk of exposure, 


potential for exposure, appears to be lower, 


but similarly, proof of principle is not 

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there. 


MR. GRIFFON: Are there other data 


completeness questions, Joe, or should we take 


them one at a time here and let Brant --


MR. FITZGERALD: Well, the ’69, ’70, I 


think, we probably should address separately. 


I mean, it’s a separate issue, but it’s data 


completeness as well. 


MR. GRIFFON: And I still haven’t probably 


haven’t read every detail of the report. 


There’s the question of the pre-’69, I don’t 


know if we ever, I mean, I think we’ve kind of 


attempted to get our hands around this, but 


the question of there were some workers in 


your analysis that didn’t have data from, say, 


’64 to ’69. They had no records, and it was 


the period when we thought that everybody was 


going to be monitored. But then apparently, 


that wasn’t necessarily the policy going 


forward. 


And then I had asked as a follow up 


can we examine some of these cases to see, in 


fact, if they had blanks in their record and 


zeros in the database. And I think you did 


look at that, right? And you didn’t find --

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MR. FITZGERALD: No. 


MR. GRIFFON: -- anymore years with that 


kind of problem. 


MR. FITZGERALD: No, no, it’s a span that 


we’re talking about 


DR. MAKHIJANI (by Telephone): Yeah, that’s 


right, Mark. I mean, I don’t think that we 


did any sort of extensive or statistical 


analysis. But we did, I certainly looked at a 


couple of them. I don’t know, other members 


of our team looked at more, and we did not, I 


did not find that the gaps had been replaced 


by zeros as there were in ‘69. 


MR. GRIFFON: I guess we have this odd 


problem in ’69 and ’70 which NIOSH has taken 


an action to correct or at least to mitigate. 


And we have no evidence that that has occurred 


in any of the other years or not as far as you 


can find. 


MR. FITZGERALD: Not as far as the sampling 


that we’ve done nor has NIOSH done. I mean, I 


think it’s clear right now it’s just the 


situation for those two years although we 


still have not established a firm endpoint, 


but nonetheless, it looks like it’s combined 

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in ’69 and ’70. 


DR. ULSH: We’ve got a couple of different 


issues, I think, that we might be mixing up --


MR. GRIFFON: Start off with Building 44, 


the early year issues, I guess. 


DR. ULSH: There was the question -- I’m 


trying to think of how it went at the last 


working group meeting. SC&A has raised the 


question, I think this -- Ron, you can correct 


me if I’m wrong, but I think originally the 


motivation for the question was that workers 


in the uranium foundry would be expected to 


have a significant shallow dose potential. 


And so you all were concerned about whether or 


not OTIB-58 would bound those workers. I 


think that’s where it originally came from. 


Am I right about that? 


DR. MAKHIJANI (by Telephone): Right, yeah, 


that’s correct, Brant. That is correct. 


DR. ULSH: At the last working group 


meeting, as Arjun mentioned, I handed out some 


data that showed that the Building 44 workers 


were indeed monitored. There was an example 


that I handed out. And we’re talking about in 


the ‘50s now. And I think that the concern 

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was that since SC&A had found gaps or periods 


without monitoring in the ‘50s for Plant B 


workers, they were concerned about whether or 


not the foundry workers would be monitored. 


And I pointed out that the foundry 


was, in fact, not in Plant B. It was in 


Building 44, and then so the question became, 


well, okay, fine, but were they monitored. 


And I handed out that example, and then it was 


requested at the last work group meeting, it 


was an action item for us to supply the 


monitoring data for other years in the ‘50s. 


MS. MUNN: A few foundry worker dose sheets. 


DR. ULSH: Now one thing that’s going to be 


difficult, and Arjun has alluded to it, and 


that is that what we have on the data that I 


supplied is the dosimetry results for people 


who worked in Building 44. And I’ve 


purposefully refrained from calling them 


foundry workers because that is really an 


artificial construct. 


Building 44 is where the DU foundry 


was. That is certainly true. But it’s not a 


defined job title of foundry worker. That’s 


not a job title. Like for instance in 

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209 

Building 76 you have process operators. Well, 


there isn’t a corresponding foundry worker job 


title. So there is some degree of difficulty 


in determining from the Building 44 results 


who was doing foundry-type operations. 


And that’s not the only thing that 


occurred in Building 44. I mean, certainly 


some of those operations were of the type that 


would lead you to high shallow dose potential. 


And I think one that was mentioned in 


Putzier’s memoir and also SC&A has mentioned 


it I think from that source was the breakout 


molds from DU. And the contact dose rates 


could be very high on those. So I think 


that’s kind of the background of where it all, 


where the issue came from. 


When I provided, after the working 


group meeting, the last working group meeting, 


when I provided the depleted uranium -- I’m 


sorry, the Building 44 dosimetry results, I 


think that spanned most of the ‘50s although 


I’d have to go back and look because that was 


a concern that was expressed about those 


years. 


Now in terms of peeling out the 

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foundry workers, well, like I said, I mean, 


that’s an artificial construct anyway. You 


could kind of make a guess by looking at the 


dosimetry results who had the highest ones. 


Then you could identify who was foundry and 


who wasn’t. 


MR. GRIFFON: Assuming the foundry workers 


were monitored, right? I mean, that assumes 


that they were at least in the cohort. 


DR. ULSH: Yes, exactly. And we have to, I 


mean, we have found individuals whom we know 


because they’re people just through personal 


knowledge, I mean, not me but other people on 


the ORAU team know those people and know what 


they did. And so for those individuals we 


could peel them out, and they were monitored, 


but it’s a big site. 


There’s a lot of people there. There 


is some degree of assumption here. And I 


think you have to go with common sense. I 


mean, why would they monitor Building 44 


workers and not monitor the people with the 


highest exposure. And you might ask that 


question --


I know, Mark, you’re giving me the 

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look. 


MR. GRIFFON: I didn’t give any look. I 


just wanted to use your words back at you. 


Seventy-one sound familiar? 


DR. ULSH: But there is some evidence that 


at least some of those people were monitored. 


If you look at the Building 44 dosimetry 


results, some of them are substantial. So it 


would certainly make sense, and I can tell you 


that the badging policy in place at the time 


was -- you know, we’ve heard this before -- if 


they had a significant exposure potential 


defined as greater than ten percent of the 


regulatory limit at the time, they were to be 


monitored. And that relies a bit on the 


judgment of the radiation protection staff in 


place at the time. That is certainly true. 


So what we have established is maybe 


not a definitive piece of paper that says we 


monitored foundry workers, and I’ve told you 


why we wouldn’t expect to find that, but what 


we have established is that there were a 


significant number of people in Building 44 


who were monitored. Some of them received 


very, well, some of them received some 

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appreciable external doses, and certainly you 


can see the types of ratios of shallow-to-deep 


that you would expect from these foundry-type 


operations. So as Mark mentioned earlier 


about a weight of evidence approach, I put on 


the table that the weight of evidence 


certainly suggests that they were monitored. 


We have monitoring for all the years in the 


‘50s I think. I have to look, but, so to that 


extent I think we’re left with trying to 


differentiate out the people who may not have 


been involved in foundry operations in 


Building 44, and I would go to the dosimetry 


results. People who have low dosimetry 


results would be good candidates for that. 


DR. MAKHIJANI (by Telephone): Low dosimetry 


results? 


DR. ULSH: The people who, Arjun, I would 


suggest to you that if I were trying to 


separate out people who did hands on work with 


the DU metal who might be expected to receive 


appreciable shallow doses, I would use the 


dosimeter results as the source. I mean, if 


you find people who have a high shallow-todeep ratio, those would be good candidates. 

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And if you find people who have zeros, they’re 


probably not good candidates. 


DR. MAKHIJANI (by Telephone): So, okay, I 


didn’t understand what you said. 


DR. ULSH: So, I don’t know. That’s where I 


am with this. Now that’s for the ‘50s. Is 


that --


MR. GRIFFON: Just to refresh my memory, Joe 


or Arjun, the individuals that we looked at 


with the gaps or the questionable periods in 


the ‘50s, were they identified in Building 44 


or are we, another question came up out of 


that review? 


DR. ULSH: Plant B. They were in Plant B. 


DR. MAKHIJANI (by Telephone): They were 


primarily in Plant B. There were a few 


scattered in other places. I do not believe 


that we actually found anyone with a history 


in Building 44 that was part of those gaps. 


I’m doing this from memory, but I think that 


Brant is right about that. 


DR. ULSH: I think that’s the way I remember 


it, too. 


DR. MAKHIJANI (by Telephone): There were 


other places than Plant B, but I don’t believe 

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that any of them were in Plant A. Now, well, 


I had a question, but I don’t know where you 


were headed. 


MR. GRIFFON: Did we conclude -- yeah, just 


let me finish my thought here. Did we 


conclude that the gaps in those workers seemed 


appropriate given their job type in the plant? 


I mean, that’s a question that I had just 


aside from this Building 44 question. 


DR. ULSH: Yes, that’s what we concluded. I 


can’t speak for SC&A. 


MR. GRIFFON: Right. Well, I’m asking if 


SC&A was in agreement with that. 


DR. MAKHIJANI (by Telephone): We found, we 


agreed that we did not find any gaps at that 


time in the -- and Ron, correct me if I’m 


wrong. We did not find any gaps among the 


plutonium buildings in terms of the way we 


define the gaps, that is, one full year of no 


monitoring data available. And so the --


MR. GRIFFON: But to my question --


DR. MAKHIJANI (by Telephone): -- yeah, it 


was confined, it was in the non-plutonium 


areas generally. And within the non-plutonium 


areas it was mostly in Plant B. 

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MR. GRIFFON: But where do you come down on 


that is the question. 


DR. MAKHIJANI (by Telephone): Yeah, we 


looked, I agree with Brant that, I looked at 


the O drive. I don’t know, Ron, did you, 


there are data I believe in most or all years 


for Building 44, and that had been the center 


of our concern in terms of if it were the non-


plutonium buildings, you know, and the size of 


our sample was overall statistically 


significant. But then we were then taking out 


a small piece of it for the ‘50s, and so --


MR. GRIFFON: But I’m still asking about 


these ones we reviewed. None of the ones we 


reviewed were in 44, were they? 


DR. MAKHIJANI (by Telephone): No, no. 


MR. GRIFFON: So I’m still asking about the 


ones that you reviewed that were non-plutonium 


in the ‘50s. There were gaps. Brant gave an 


explanation as to why. I mean, basically I 


think because of the ten percent and the job 


title information or --


DR. ULSH: That is true, Mark; however, 


Arjun mentioned the gaps that were primarily 


seen, not exclusively, but primarily in Plant 

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B. That’s Building 881. And we talked last 


time, and we will again this time, how those 


workers were not monitored externally until 


the fourth quarter of I believe 1960. And 


this is an issue that I’m sure we’re going to 


get into about how we cover those people. 


DR. MAKHIJANI (by Telephone): Yes, that’s a 


separate, that was a separate question. 


MR. GRIFFON: Okay, so let’s stick with 44, 


but I just wanted to understand --


DR. ULSH: Yeah, but in terms of the 52 


cases that we looked at for the data 


completeness evaluation, it was our conclusion 


-- now this is only NIOSH -- that the gaps 


that you see in the periods with no monitoring 


are explainable primarily by two factors. 


One, in several instances the people weren’t 


onsite, or in some instances, so you wouldn’t 


expect there to be monitoring results. 


And two -- and I’m not sure which was 


the more common. I think maybe this one was 


the more common -- the jobs that they were 


doing as discerned from their job history 


cards. For instance, if they were a janitor 


and you know --

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 DR. LITTLE: Administrative secretary. 


DR. ULSH: -- yeah, those would be 


consistent with them not being monitored. And 


you’re right, Mark, this is another thing that 


you mentioned in your original question I 


think. Originally we had assumed that 


everyone was monitored after ’64. And that 


turns, that’s not the case throughout the 


history. It appears that there was at least a 


small number of Rocky Flats workers who had 


low exposure potential were not monitored. 


So that’s kind of what we found. I 


don’t want to go further than that and speak 


for SC&A. 


MR. GRIFFON: Just sticking with the ‘50s 


still, do we, SC&A, does SC&A agree that 


there’s gaps? Do you accept the explanation 


given by NIOSH for those gaps I guess is the ­

-


DR. MAKHIJANI (by Telephone): You know, we 


didn’t find any different explanation. The 


question that arose from the existence of 


those gaps since there were gaps for full 


years wasn’t about what the policies were at 


the time or the judgments of the health 

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physicists which, as we saw this morning, 


weren’t 100 percent correct. 


The question that arose from the fact 


that there were these gaps was does the, can 


the coworker model be demonstrated to cover 


those gaps in a bounding way or is there 


another set of data that can do the same job 


and can that be demonstrated. So as I 


mentioned, this wasn’t a question about 


monitoring practices. It was simply left at 


the proof of principle level just following 


the Board’s criteria of what is required to 


review as we review NIOSH’s work on SEC. 


MR. GRIFFON: And just to stay with that 


thread, are we convinced that the coworker 


model bounds those years? 


DR. MAKHIJANI (by Telephone): Well, you 


know, we have not, as I said, that’s why I 


looked, when I looked at Building 44, I saw 


lots of data there. We did verify that so 


that is correct. I believe that Brant is 


right. I think there are data, my memory is 


the same as his, there are data for every year 


and quite copious, but no job types. 


And since there’s a particular types 

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of jobs that had the high exposure potential, 


you know, the only question remaining 


reviewing that data since the last meeting was 


how are we going to identify those people and 


make sure there’s an approach to covering them 


and/or make sure that they were all monitored 


since their job types are not mentioned. 


I mean we’ve felt all along that, you 


know, people made the best judgments that they 


could at the time, but they’re not infallible 


and that some data are preferable before you 


affirm an idea that somebody was doing things 


right all the time. And I think as it’s 


turned out with neutron doses this morning 


finally, we have an idea that maybe an initial 


judgment was not quite right when it tried to 


be verified by numbers. And so it’s the same 


concern here is that can you show it. 


DR. ULSH: Well, I think that’s true, and 


let me be more specific here. In this 


situation the thing that originally I think 


maybe caught SC&A’s attention was the memoirs 


of Ed Putzier. And if you look at his 


memoirs, he identified that this was 


recognized as an issue back in the ‘50s. And 

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they had housekeeping issues; they had pretty 


high contact dose rates. 


And I would certainly agree that we’re 


talking about, when we’re talking about the 


radiation protection staff, I agree with 


Arjun’s characterization. They were doing as 


good a job as they could. I think I would go 


a little further and say in general they did a 


pretty good job, but they’re not infallible, 


and we saw that this morning, and that is 


true. 


However, I don’t think you can 


necessarily equate that to the situation in 


Building 444 because it’s clear from Putzier’s 


memoir that it was recognized early on that 


there was significant exposure potential here. 


Now again, I have to go back to it. This is 


just the weight of the evidence, and you 


certainly see that in the dosimetry results 


there are people who would fit the profile you 


would expect if they’re doing the type of work 


that we’re concerned about here. You know, 


high shallow-to-deep ratios. 


So at least some of them I would say 


are there. I mean, I would say that the 

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weight of evidence suggests that they were 


monitored. I mean, if the hazard was 


recognized as Putzier’s memoir indicates that 


it was, and you have dosimetry results for 


workers who were in Building 44 who may not be 


able to say that Worker X was a foundry 


worker, and let’s go look and see if he was 


monitored. But the weight of the evidence 


certainly points in that direction. 


It’s just a question of for the 


working group and the Board, do you feel the 


weight of the evidence is strong enough. 


DR. MAKHIJANI (by Telephone): Brant, could 


I ask, did you actually, is there a table or 


something of the ones with high shallow-todeep ratios? I mean, you seem to have 


examined it from that point of view. 


DR. ULSH: No, Arjun, I’m speaking more 


anecdotally from when I was looking through 


the dosimetry results. I haven’t done a 


formal analysis or anything. 


MR. BUCHANAN: What years of operation 


looked at that or what years of operation that 


the uranium foundry workers ^. 


DR. ULSH: Ron, let me go on from Putzier’s 

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memoirs. I think he referred to the ‘50s. 


I’m not sure if he was more specific in that. 


And to be honest with you, Ron, I don’t know 


if that would extend up into the ‘60s and, I 


mean, I don’t know. You’d have to look at the 


building history, but --


DR. MAKHIJANI (by Telephone): Well, 


Putzier’s concerns about it, you know, until 


the time he wrote, but his main concerns were 


about the early years. I don’t believe that 


he actually wrote down an interval of years 


for which he was mostly concerned. I think he 


said early years. 


MR. GRIFFON: This data in the worksheets, 


is it part of your TIB-58 spreadsheets now? 


Is it, would it be included in that annual 


data or is this kind of new data that you’ve 


uncovered in response to this question? 


DR. ULSH: No. 


MR. GRIFFON: No, it’s been out there. 


MS. MUNN: It’s individual dose data, right? 


MR. GRIFFON: Yeah, is it? 


DR. ULSH: The worksheets that I provided 


are individual dose data, Wanda. And, yes, 


they would be reflected in OTIB-58. Keep in 

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mind that OTIB-58 prior to 1970-something has 


a penetrating dose and a non-penetrating dose. 


And, yes, we certainly expect them to be in 


HIS-20. 


 DR. LITTLE: As a lump sum? 


DR. ULSH: As a lump sum. 


 DR. LITTLE: Prior to ’76. 


DR. ULSH: Thank you, that’s what I was 


reaching for. 


So, yes, Mark, they are in there. 


MS. MUNN: So the weight of that evidence 


would lead us to the conclusion that we do not 


have an SEC issue here. 


(Whereupon, hotel staff interrupted the 


proceedings via telephone.) 


MR. GRIFFON: So Wanda’s conclusion is --


MS. MUNN: That the weight of the evidence 


would lead us to believe that dose 


reconstructions are in fact possible from the 


data that’s there, and this, therefore, is not 


an SEC issue. 


MR. GRIFFON: Yeah, I think the final, is 


there any, there’s no way to, I forget these 


^. I was just looking for these worksheets on 


my drive. I know I have them somewhere. Are 

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there exposure IDs or any way to link these to 


individuals? You said --


DR. ULSH: I’m trying to remember, Mark. I 


know that they were given by name, but we 


might have main number in there. I’m not 


sure. 


 DR. LITTLE: Are you talking about the 


worksheets? 


DR. ULSH: I’m talking about the worksheets 


that we put, we mailed out to the working 


group for ‘50s, Building 44. 


 DR. LITTLE: I think they have names. They 


have mang numbers, too. I’m 99 percent sure 


that’s true. 


MR. GRIFFON: Because you say even if we, 


I’m just wondering if I cross-checked some of 


these names with their cards -- they may not 


be called a foundry worker anyway. Is that 


what you’re telling me? 


MS. MUNN: They aren’t. 


MR. GRIFFON: There’s no such job title so 


it’s not, it’s going to be --


 DR. LITTLE: They’re probably a chemical 


operator or a assistant operator or something 


of that nature. 

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DR. ULSH: You’ve got to remember, Mark, 


that the dosimetry results that I provided to 


you are not limited to the claimants, and we 


have the job history cards for claimants. 


MR. GRIFFON: So there may not even be any 


matches. 


DR. ULSH: Yeah, you just have to, needle in 


a haystack. 


 MR. FITZGERALD: Would those be considered 


for, you know, just as on external dose, it’s 


attributed to those working radiation areas ^ 


I would think that would be ^ that category, 


right? 


DR. ULSH: Yeah, I mean, if we had an 


unmonitored person who did foundry-type 


operations, I would say -- Mutty’s not going 


to jump across the table and reach me -- but I 


think that we would certainly give 95th
 

percentile to people like that. 


 DR. WADE: Mike, are you still with us? 


MR. GIBSON (by Telephone): Yes. 


MR. FITZGERALD: Arjun, are you still with 


us? 


DR. MAKHIJANI (by Telephone): Yup. 


MR. FITZGERALD: Any reaction on that before 

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we get to --


DR. MAKHIJANI (by Telephone): Well, no, I 


think, you know, a decision about whether 


something’s SEC at this kind of stage and 


whether the Board’s criteria is being 


fulfilled clearly belongs to the working 


group. The comment that we made is there that 


certainly the data, there are plenty of data. 


They’re not identified by work type, you know. 


I take Brant at his word that there 


are some data with high shallow-to-deep doses, 


and I think that then certainly the rest is 


for the working group to say how much of a 


proof of principle they want. 


MR. GRIFFON: And I think if we’re 


reasonably convinced, and I think Wanda is, 


that the most exposed were monitored, you know 


are in this population, I might amuse myself 


if I had time to check some of these cards. 


But I think it’s going to be kind of fruitless 


because I think it’s probably, you’re not 


going to find a foundry operator or whatever 


foundry worker. 


So as long as, and I have no reason to 


believe they wouldn’t have had some operators 

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in that population, I think they probably have 


gotten the bounding job types covered. So I 


guess that’s the question is if we’ve got the 


gaps and they apply. And I also, looking at 


the procedures, I have no reason to believe 


that they wouldn’t assign a 95th in this 


scenario for the external coworker model 


because that’s different than the internal 


coworker model. 


And Mutty’s nodding his head, let the 


record show. And I think that’s the general 


rule is that if it’s in a radiation operating 


area, then you --


 MR. FITZGERALD: That would make a 


difference from my standpoint. One can’t 


close that loop on this so-called proof of 


principle. It’s almost the, what’s the 


overall available cautions or conservatism. 


So I think that will make a big difference. 


MR. GRIFFON: So I think from that 


standpoint it’s, I think we’re satisfied with 


that, at least I am personally. 


MR. FITZGERALD: What’s next? 


MR. GRIFFON: I mean when we, let’s see. I 


just want to go back to that Building 81 

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question that you mentioned. Is that part of 


this discussion or is it another item? I 


think bring it up now I guess. 


MR. FITZGERALD: Well, the 81 issue devolved 


from discussions on the other issues of the 


last couple of work group meetings. I guess I 


don’t have a bin for it. We certainly cite it 


in the completeness analysis of it, didn’t 


provide a bottom line conclusion as to whether 


it was an issue or implication there. 


Arjun, do you remember how that came 


up in terms of part of this discussion and it 


just kind of fell out of it. 


DR. MAKHIJANI (by Telephone): Well, 


Building 81 is distinguished in two ways from 


what we’ve just been talking about in that in 


Building 44 there are data. They’ve been 


identified, and there are data throughout the 


period, their names attached to them if I 


remember correctly and so on. 


In Building 81 the ’52 to ’59 period 


does have lots of workers who were not 


monitored. They were working mainly with 


uranium. There were some other areas besides 


Plant B where there are significant gaps in 

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the sense of not being monitored for whatever 


reason. And we didn’t see that the exposure 


potential had been quantitatively 


characterized so as to be sure that it was 


covered by the coworker model. 


And so that is the issue. It’s a 


different kind of proof of principle issue is 


that there is a coworker model, but there’s no 


demonstration that it applies to this group of 


workers who were production workers who were 


not monitored and whether it covers them 


adequately or not. 


So, I mean, that’s where we left it. 


We haven’t seen anything more specific than 


that. And I think we do have agreement that 


in those areas there were workers who were not 


monitored because they were felt to be not at 


high exposure potential. 


DR. ULSH: Do you want me to go ahead? 


MR. GRIFFON: Uh-huh. 


DR. ULSH: You are correct, Roger -- Roger, 


Arjun -- we do have agreement that there were, 


there was a time period when the workers, the 


uranium workers in Building 81 were not 


monitored. That time period is prior to the 

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fourth quarter of 1960, I believe. 


DR. MAKHIJANI (by Telephone): That’s 


correct. 


DR. ULSH: Okay, thanks. And that was 


discussed by the ORAU team, that was pointed 


out in a conference call that we had with 


SC&A. And that came up in that that you 


mentioned that you had found a lot of 


unmonitored periods or gaps in the Plant B 


workers in the ‘50s. And so that’s when we 


said, yeah, that’s because they weren’t 


monitored until the fourth quarter of 1960. 


DR. MAKHIJANI (by Telephone): Right. 


DR. ULSH: Now I don’t think it’s, I don’t 


think I would characterize that we have not 


performed an analysis to show that they were 


bounding. I would say that we have presented 


an analysis and maybe SC&A is not convinced by 


that, but we certainly have presented an 


analysis. 


I’m looking at our response to SC&A’s 


draft report on this chapter, Chapter 8, the 


“Data Completeness Evaluation,” and we 


presented an analysis that shows that once 


they were, okay, first of all the reason that 

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they were not monitored --


DR. MAKHIJANI (by Telephone): Can you give 


me the date of the paper you’re talking about? 


There are a lot of papers here. Is that 


2/26/07? 


DR. ULSH: Sounds right. I don’t have a 


date on my copy here but it sounds about 


right. And I’m on page five if that’s the 


right report. 


So the reason they were not monitored 


is because they were judged by the health 


physicists at the time to be at less than ten 


percent of the exposure potential. So what we 


see is that when they were monitored in 1960, 


and we also have results for 1961, that 


certainly turned out to be the case. They 


were at less than ten percent of the exposure 


potential. 


But now we’re into a situation where 


we have to back extrapolate again because we 


have some monitoring data here, and it 


certainly shows that in the years when they 


were monitored, 1960 and ’61, number one, they 


were at less than ten percent of the exposure 


potential, but number two, and more 

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importantly and more relevant for what we’re 


talking about here, the coworker dose that we 


would apply was bounding in those years. 


Now, we’re back to this back 


extrapolation. What do you do about the 


period when these workers were not monitored? 


Well, again, you have to be cautious when we 


do this, when we back extrapolate. And we 


have to consider whether or not there were 


changes in the source term that would have 


compromised our conclusion. 


Now, I do want to be clear that we’re 


not back extrapolating data. What we’re doing 


is back extrapolating the presumption that our 


coworker model is shown to be overestimating 


or bounding in ’60 and ‘61, and that 


assumption we are going back and saying that 


applies also to this earlier period when these 


workers were not monitored. 


And we presented an analysis that 


showed that when they were, it was 


overestimated by pretty large factors. 


Factors of, and we’re talking only about the 


positive doses that were measured, factors of 


13, factors of 24, factors of, well, there’s a 

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three; there’s a four. So we’re not talking 


by a little bit, by ten percent. We’re 


talking about the coworker model overestimated 


by a significant, and would be bounding by a 


significant margin. 


And so what we considered were, were 


there source term changes that would you would 


expect to make this assumption suspect. Well, 


yes, as a matter of fact, there were source 


term changes. If you look at the amount of 


uranium that was processed at Rocky Flats 


beginning in the ‘50s and going up into the 


‘60s -- I can’t give you exact amounts because 


that is classified. 


I can tell you the trend though. And 


the trend was that they started low in the 


’50s, low inventory, low through-put of 


uranium, and that increased steadily 


throughout the ‘50s up into the early ‘60s, up 


into the middle ‘60s where it kind of 


plateaued right there in the ‘60s. And then 


in 19 --


Maybe you can help me out, Bob, 1965 


was it? 


Nineteen Sixty-five those operations 

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were transferred to Y-12. So it goes away in 


1965 at Rocky. So what we see here is that, 


yes, there were source term changes. 


If you look at a graph, and you see a 


steadily increasing line, but that gives us 


confidence that at least on this source term 


question, if we use this assumption, or I mean 


this phenomenon that we’ve seen in the ‘60s, 


well, it doesn’t make sense if you consider 


that factor that they would have been at 


higher exposure potential based on the source 


term because the source term was higher in the 


‘60s than in the ‘50s. 


Now, if that had been the reverse 


situation, if they had been higher in the ‘50s 


and gone down, well, you would say, well, when 


they were monitored, they were at lower 


exposure potential. But not based on the 


source term for what we see at Rocky Flats. 


This is all presented in our response here 


that I’ve referenced. 


We also don’t see any changes in the 


building configuration similar to the 


discussion this morning in terms of 


improvements in shielding or anything like 

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that that would have depressed the doses that 


you see in the ‘60s compared to the ‘50s. So 


based on that we just didn’t see anything that 


would call into question this fact, well, what 


we observed that our coworker dose was, in 


fact, bounding and not by a little, by a lot. 


So in order for this not to be 


acceptable, in order for someone to say that, 


well, the coworker dose isn’t bounding for 


these workers back in the ‘50s, you would have 


to say, number one, their doses were going up 


when the source term was going down and not by 


just a little bit but by factors of three, 13, 


24, a lot. It just doesn’t sound plausible to 


us. 


DR. MAKHIJANI (by Telephone): All right, 


thank you for reminding me. I remember this, 


and I believe there is a discussion of this 


some paper of ours, probably also in the 


report that we’ve given you. 


I have the table that you’re referring 


to in terms of the coworker comparison in 


front of me, and I think this back 


extrapolation issue in terms of the source 


term has been an issue of some discussion. 

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Certainly, we’re not arguing about whether the 


source term was going up in the ‘50s because 


that’s a matter of record for you looking at 


the classified data. 


The thing that we’ve said is that the 


source term quantity matters only in one 


context on a priori basis in terms of exposure 


potential is that if you’ve got workers who 


are going from full time to part time because 


the source term is going down, then you’ve got 


a lower exposure potential. So long as you’ve 


got some workers who are doing full-time work, 


the source term is irrelevant because then 


you’re simply multiplying the number of 


workers who are exposed and it doesn’t matter 


for individual dose whether the source term is 


going up or down at that point. 


What matters are the industrial 


hygiene conditions, the ventilation 


conditions, the area dust doses. And there 


are certainly plenty of examples where you 


have got relatively small source terms, for 


instance, typical with AWEs where you have 


gotten much, much larger intakes than with 


much larger operations because the industrial 

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hygiene conditions are much worse. So I think 


this point should be clear that unless there’s 


part-time work, the source term is not 


relevant. 


It’s the industrial hygiene conditions 


that are relevant, and that’s why the back 


extrapolation issues are kind raised here. Is 


there some data to validate this back 


extrapolation from the time, like dust data 


and so on. And I believe this question is 


raised in our report if I remember correctly. 


DR. ULSH: Well, let me talk to that. When 


you’re talking about dust, external dose from 


airborne material that, I mean, I assume that 


you’re talking about airborne material that 


settles out on surfaces, not on people’s skin. 


 (no response) 


DR. ULSH: And hearing no objection I’ll go 


with that. So what you have to, let’s try to 


put together a scenario where our assumptions 


would not work. What you would have to assume 


-- now remember, starting in the ‘50s, at some 


point, ’52, I don’t know the exact year that 


the uranium operation started. 


But operations are just getting 

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started so industrial hygiene operations at 


worst, what you’re worried about is an 


accumulation of airborne material on equipment 


and surfaces. And that’s going to take some 


time to accumulate. And if you’re doing good 


hygiene, good industrial hygiene, cleaning up 


after every shift or every week or whatever, 


then really that accumulation factor is not 


going to be too much of an issue, and --


MR. GRIFFON: I think that’s the general 


point though. I think, I mean, every site 


I’ve been at, work practices and hygiene 


improve with time, and I’m not sure. I think 


the source term is sort of irrelevant because 


your workforce could go up with the source 


term increasing, and you know, personal 


exposures may not be affected by that. I 


guess the, we’re at the same sort of question 


of do we have some hypothesis or do we have 


evidence that supports, you know. 


DR. ULSH: Well, what I’m saying, Mark, is 


that it would certainly be an issue if the 


trend were going the other way. If you had 


higher inventories in the ‘50s going down into 


the ‘60s, then we might be concerned. No, I’m 

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not saying that it’s sufficient to say that 


the source term was increasing up into the 


‘60s. I’m just saying that’s one piece in the 


weight of the evidence. 


Now in terms of the industrial hygiene 


and this question of dust that accumulates and 


what not, you have to take into account here 


that the primary source of external dose is 


going to be the hands on work with the uranium 


metal. I’m not saying that the dust, the dose 


from the dust that accumulates is 


insignificant, but it’s certainly less than 


the operations that involve the hands-on metal 


work. So that’s not going to be an issue in 


terms of changing hygiene conditions in the 


‘50s or ‘60s or whatever. 


I just, what you have to say here is 


that the, at the same time that the source 


term was increasing into the ‘60s, the hygiene 


conditions were so different in the ‘50s that 


they led to such an increase in external dose 


from this accumulated material on surfaces 


that it would counteract not only the source 


term, if you even think that that’s an issue, 


but it would have to overcompensate the fact 

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that we’re overestimating by factors of, by 


large margins. 


And I just don’t think that that’s 


plausible. I mean by factors of 13, factors 


of three, factors of four, and you have to 


also realize that these factors are 


underestimate because we only considered 


workers with positive doses in this analysis. 


It doesn’t count anybody with zeros. So, yes, 


could you have had a little bit of higher 


exposure from dust on the surfaces in the 


‘50s? Sure you could, but is it going to be 


so much that it would make our coworker 


analysis --


MR. GRIFFON: The dust on surfaces makes it 


DR. MAKHIJANI (by Telephone): Is it a dust 


MR. GRIFFON: Arjun, hold on. 


The dust on surfaces makes a good sort 


of sell in this situation, to sell your model. 


But I think it’s more than just the dust 


differences over time. I think, I question 


whether work practices from ’52 through ’60, I 


doubt they were stagnant. I think they 

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learned a lot about uranium handling in that 


period from ’52 up through ’60. 


And maybe shielding, I mean, you’re 


saying we have no evidence that shielding 


didn’t significantly change. You know, you 


see some of these papers, and they just say, 


you get suggestions over time that we’ve 


learned that, we modified the work practice 


here so that the workers aren’t handling this 


directly. They’re using this approach 


instead, or whatever because we found high 


hand exposures. I mean, they were constantly 


doing that in the early years. 


So I guess that’s my question, not so 


much to harp on one particular item or 


another, it’s just that trend. And even if 


the production values were going the other 


way, I think the production source term is, 


I’m not sure it’s completely relevant because 


I think if you’re scaling down production, 


you’re scaling out workers. And some 


individuals may just be doing, their 


particular personal experience may not be 


changing at all. You’re just modifying the 


workforce in the area maybe. I don’t know. 

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Maybe. So I can hypothesize that way as well. 


DR. ULSH: If that’s not a factor of concern 


to you, the source term, then ignore 


addressing ^. 


MR. GRIFFON: I’m just saying. I’m just 


saying. 


DR. ULSH: I understand. I want to address 


the questions that you consider compelling. 


And if that’s not one of them, that’s okay. 


That’s fine. 


But in terms of industrial hygiene, I 


again have to go back to the fact that, yes, 


it is certainly possible that industrial 


hygiene practices improved from the ‘50s to 


the ‘60s. Is that maybe enough to counteract 


the fact, number one, you have to realize that 


the health physicists at the time were judging 


that these people were at low exposure 


potential. Now might there have been one, 


two, a couple, some that exceeded that? Sure, 


there might have been. I can’t say that there 


weren’t, but we just don’t see people 


exceeding the 95th percentile of the coworker 


doses that we’re assigning when they were 


monitored. I mean, we’re overestimating by a 

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factor, by large factors. And the question I 


MR. GRIFFON: And I don’t remember that 


analysis to be honest with you. I mean, I 


looked at it initially, but I don’t even find 


it. 


DR. ULSH: The question that I think you 


would have to wrestle with is the possible 


effects from possible changes in industrial 


hygiene practices, would they be enough to 


make our coworker model not bounding? That’s 


the question you have to wrestle with. 


And also I know that people have 


varying confidence in the judgment of the 


health physicists at the time. We know that 


they were not infallible. We do know that, 


but they judged at the time that these people 


were less than ten percent of the exposure 


limit, and when they were monitored that is 


certainly borne out. Might they have missed a 


couple? Yeah, they might have. But would 


that have put them over 95 percent of the 


people that were monitored? 


MS. MUNN: One has to use common sense in 


approaching these things and use the personal 

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knowledge that we have of the individuals and 


their motivations. And certainly the health 


physicists of the time were extremely 


concerned over the health and welfare of the 


workers. We know that. 


MR. GRIFFON: Oh, sure, but I believe they 


probably had priorities, too --


MS. MUNN: Oh, undoubtedly. 


MR. GRIFFON: -- and this type of facility I 


don’t know if uranium was necessarily a big 


problem. In the early years I don’t think 


people were so real hepped up over external 


exposures to uranium, and probably rightly so, 


I mean, so I’m not sure they were thinking 


let’s worry about who might exceed ten, you 


know, that’s my question. 


MS. MUNN: That’s probably true, but we do 


have some data to look at. 


MR. GRIFFON: Yeah, so not for these people 


we don’t. So that’s the question. I think we 


just have to grapple with those figures you 


gave. There might be differences. Are they 


really going to throw it off by a factor of 


three to ten or whatever the examples you 


gave. 

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MR. FITZGERALD: It seems like we have two 


or three variables at work side by side, so I 


don’t know if there’s a way to know how they 


offset, I think your point’s well taken, a 


source term. But then the question of whether 


practices improved, it seems to me --


DR. ULSH: They might have. 


MR. FITZGERALD: They might have. 


DR. ULSH: It seems plausible to me that 


they did. 


MR. FITZGERALD: I think whether or not the 


measured doses compare favorably with ^. 


DR. ULSH: It would be nice to lay 


monitoring data for these people in the ‘50s 


before you. That doesn’t exist. I’ve put the 


weight of the evidence that is available on 


the table, and I think it’s up to you guys now 


to decide what you think of that. I mean, I 


don’t have a lot more to add to it. 


MR. GRIFFON: Arjun, do you have anything 


else? 


DR. MAKHIJANI (by Telephone): No, I think 


Brant is right about that. I think that he’s 


properly characterized the numbers. The 1960 


data are as they are. And as I said, the 

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point, at least as we have discussed 


internally, and as somebody that’s written a 


lot of the stuff that’s been discussed today, 


the principle I’ve tried to follow is to look 


at the Board’s criteria and our operating 


procedures on what we’re supposed to evaluate 


and present that evaluation to you. 


So I think, you know, at that point I 


agree with Brant. The numbers are, we have no 


dispute about, the numbers, no argument. It 


is true that the 95th percentile is severalfold the doses that were measured in the 


fourth quarter of 1960. And if that is being 


compared to the coworker model, the coworker 


model at that time was as characterized at the 


95th percentile. So then it’s the Board’s 


judgment call about back extrapolation because 


these other factors we don’t know. 


MR. GRIFFON: I think the only other piece 


we have to consider in this is how, if we have 


these different groups or this one group, I 


guess, that was not included in the 


monitoring, one question is would a 95th bound 


and I’m leaning toward a yes as that answer. 


The second question, I guess, is for 

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those years, ’52 through ’59 --


DR. ULSH: Third quarter of 1960. 


MR. GRIFFON: ‘Sixty, okay. How does this 


population of workers not being included in 


the full dataset affect the coworker model 


itself. Because you use not only the 95th, but 


you’re going to use the 50th sometimes for some 


workers. 


DR. ULSH: Well, that’s an interesting 


question, Mark. 


MR. GRIFFON: Sort of a secondary one, but ­

-


DR. ULSH: I want to think about how to 


answer that. I can tell you that they were 


judged to be a low exposure potential. When 


they were monitored, that judgment was 


supported. When they weren’t monitored, you 


can make your own conclusion. In general, as 


a general principle, if I exclude a group of 


workers who were at low exposure potential, 


you accept that they were, that would be 


claimant favorable. That would shift my 


distribution to the right. 


MR. GRIFFON: No, no, I agree with that, but 


in looking at the 44 data or if I recall what 

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you said about the 44 data, like I said I 


couldn’t find it in real-time here on my 


computer. But going back to 44 for a second, 


for those you indicated that maybe it was by 


your personal knowledge of the names or 


whatever. 


You said some of them were management, 


and some of them were operators, some of them 


were, so it makes me wonder was this judgment 


of ten percent of the RPG based on like 


building or was it on job or, you know. And 


managers were included in this population that 


was monitored in the early years. It makes me 


wonder if, in fact, --


DR. ULSH: I think I recall -- yeah, I 


understand your question. I think I recall 


our discussion at the last working group 


meeting about this because the question came 


up. What was the unit of decision. Was it an 


individual-based question or was it a 


building-based question? I think the answer 


that we heard, I’ll have to defer to people 


who were actually there, but I think the 


answer that we heard was it was by work group, 


by org code. 

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Now that conversation occurred in the 


context of Building 44. I don’t have any 


reason to think it would be different in other 


places. Is anyone out there on the ORAU team 


that can speak to that? 


 (no response) 


DR. ULSH: No one’s going to take the bait, 


huh? 


 DR. LITTLE: Is anybody out there from ORAU? 


DR. ULSH: I can get back to you with an 


answer on that, Mark. 


 DR. LITTLE: Well, I think to some extent I 


can speak to that because the, certainly we 


did find one indication of people who were in 


the uranium foundry, and it was in a personnel 


strength report. It was from 1962 or ‘3 it 


seems to me. And those, a strength report is 


essentially a compilation of how many people 


worked in various org codes in various 


buildings. 


And that’s where we identified, we 


verified that these people that we found for 


the later ‘60s were actually in the foundry. 


What we, and those are all classified by org 


code and by building code as are most of the 

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data worksheets are not, but the so-called 


supervisor reports or the health physics 


exposure reports are all classified by org 


code, building and org code. 


MR. GRIFFON: Org code can include a strata 


of job titles, I guess, right? 


 DR. LITTLE: Absolutely. And the 


unfortunate thing about org code is it was not 


a constant. It changed a lot. 


MR. GRIFFON: Because the other thing though 


that now that I’m sitting here thinking about 


it, I know I looked through some of the data 


and noticed the percentages of non-detects in 


the early data. And I think part of it is 


related to I think there was a time period 


when it was a weekly or biweekly --


DR. ULSH: In 44? 


MR. GRIFFON: Yeah. 


-- turnover cycle so you’d have a 


higher percentage there, but it struck me that 


there was a lot of zeros, and if they were 


supposed to be over ten percent of the RPG, 


you know, so part of that might have been 


attributed to the short film cycle. But I was 


curious if --

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DR. MAKHIJANI (by Telephone): There wasn’t 


a foundry in ’81, was there? You’re referring 


to 44. 


DR. LITTLE: I was referring to 44, sorry. 


DR. MAKHIJANI (by Telephone): Okay, sorry, 


it just had a little disconnect there. 


MR. GRIFFON: Okay, I think we have enough 


there. I think it’s likely that, Arjun, do 


you have anything more on the --


DR. MAKHIJANI (by Telephone): No, no, Mark, 


I think that all the facts are before you, and 


NIOSH and --


Joe, I don’t see any disagreement in 


how the facts have been characterized. 


MR. FITZGERALD: No, I think on these proof 


of principles we do the best we can on both 


sides to provide the information and --


MR. GRIFFON: Then we used the weight of the 


MR. FITZGERALD: -- uncertainties. I do 


think they do come down to the weight of the 


evidence because there’s no way to, the 


technical information that would ice it is not 


necessarily available so it is what it is. 


MS. MUNN: And it’s adequate. 

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MR. GRIFFON: Since I’m sure some people 


have flights to get to including myself --


DR. MAKHIJANI (by Telephone): Could I sign 


off if I might? 


MR. GRIFFON: No. I guess so, Arjun. 


DR. MAKHIJANI (by Telephone): If there are 


no more questions, I’d like to sign off. 


MR. GRIFFON: If you’ve got to leave us, 


you’ve got to leave. Yeah, go ahead. 


DR. MAKHIJANI (by Telephone): No, well, 


I’ll wait if there are --


MR. GRIFFON: We’re coming up to coworker 


models or ’69, ’70. 


MR. FITZGERALD: We didn’t quite --


DR. MAKHIJANI (by Telephone): Oh, ’69, ’70, 


okay. 


MR. FITZGERALD: We really need to at least 


close that out. 


DR. MAKHIJANI (by Telephone): Yeah, sorry, 


okay. 


MR. GRIFFON: Go ahead, Joe. 


’69 – ‘70
 

MR. FITZGERALD: Well, we started backing 


into it I guess to some extent. And actually 


I’m not reporting there was a disagreement 

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actually. There was a lot of agreement on the 


fact that the zeros that were introduced by 


the badging policy ought to be dropped out. 


That was something that was stated at the, I 


think, the last work group meeting, and I 


think we concurred with that. 


And since then I believe last Friday 


there was a revised OTIB-58 that was 


circulated. I think, Brant, you sent it to 


us, and I’ve read the language. I don’t think 


all of us have had a chance to let it soak in 


because it was just Friday, but in a sense I 


think that pretty much goes in the direction 


of resolving the issue at least from that 


standpoint. 


Now there’s only one other question. 


I’m afraid to say sort of a proof of principle 


statement, but does OTIB-58 given -- this gets 


to some of the questions -- we take those out 


essentially as data points. Can one actually 


apply, and I think, not to prejudice the 


answer, can you actually apply OTIB-58 and 


apply the data for those workers and is there 


any artifact to the distribution itself? 


Again, I think it’s similar to what 

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you were asking for because you’re just 


withdrawing these people. I think the numbers 


are such that it wouldn’t make much of a 


difference. 


MR. GRIFFON: Or how does it shift to 95th is 


really what you’re asking? 


MR. FITZGERALD: That’s one question but yet 


it’s sort of a, the biggest issue I think we 


have resolved which we all agree that these 


data points should not remain. They should be 


removed. And I think that’s what you’ve done 


with the OTIB. And I think that takes care of 


the big issue, but that certainly leaves this 


other implication similar to what you raised. 


Does it affect anything on the coworker 


application? 


DR. ULSH: Well, to answer your question and 


to make your review simple in terms of this 


particular issue, ’69 and ’70, you could look 


at Table 7.1 and there’s just a, the only 


thing that changed in that table was 1969 and 


’70. It’s pretty easy to see. I can tell you 


qualitatively what the effect of removing the 


zeros was. The 95th percentile didn’t move 


much as you would expect. The 50th percentile 

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moved more as you would expect. I don’t have, 


unfortunately, the previous version to say it 


changed by this much, but --


MR. BUCHANAN: It changed by, I can --


DR. ULSH: Okay. 


MR. BUCHANAN: The biggest change was in 


neutrons for 50 percent. It changed it by a 


factor of about four times, increased the dose 


about four times. In ’69 and ’70 it increased 


it about double. And for the 95th percentile 


it increased it by about 30 percent in ’69 and 


about 20 percent in ’70. So the biggest 


increase was in ’69. Apparently there was 


more zeros in ’69 than ’70. 


DR. ULSH: And that would make sense. 


MR. BUCHANAN: Then on the gamma dose it 


didn’t change the gamma dose as much as it did 


the neutron dose in the 95th and 50th
 

percentile, but it changed it some. 


MR. GRIFFON: Mutty looks like he has a 


question. 


 MR. SHARFI: You’re talking about the actual 


doses, not the final coworker? 


MR. BUCHANAN: In the Table 7.2. It’s 


according to the new one compared to the old 

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one. In ’69 it changed the 50th percentile 


from 58 millirem to 270 millirem. 


DR. ULSH: I can verify the 270. I got 


that. 


MR. GRIFFON: What did it do to the --


MR. BUCHANAN: The old one’s 58. 


MR. GRIFFON: What did it do to the 95th? 


MR. BUCHANAN: Ninety-fifth it changed from 


1,483 millirems to 2,015 millirems. That’s 


about a 30 percent change. And in ’70 it 


changed from .190 rem to .328 rem, about 


double for the 50th percentile. So there was a 


significant change in ’69 and some change in 


’70 for the neutrons. The photons changed by 


a smaller amount. 


DR. ULSH: So that’s the effect. 


MR. FITZGERALD: I think from the preamble 


to what you sent us in the OTIB, you are 


considering a PER for the --


DR. ULSH: Well, we’re not only considering, 


we’re going to do it. 


MR. FITZGERALD: For the past cases. 


DR. ULSH: And that is an error that’s in 


the publication record for this. It says no 


PERs required, and that is not correct. 

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MR. FITZGERALD: I think that’s very 


responsive to the issue, and I don’t think we 


have any further comment on that. 


MR. GRIFFON: And this question of going, 


whether the issue precedes or is that through 


the 1970 period? NIOSH has looked at that? 


SC&A has looked at that? 


MR. FITZGERALD: We sampled, and again, we 


did look very comprehensively to see if we 


could find any other instances that would be a 


similar phenomena or a situation, and we 


couldn’t find one that was the same so we did 


sample that. 


DR. MAKHIJANI (by Telephone): Yeah, Joe, on 


the contrary, we did find that when there were 


gaps, they were represented as gaps. 


MR. FITZGERALD: I’m sorry, okay, right. It 


wasn’t the same as this situation where --


DR. MAKHIJANI (by Telephone): No, whatever 


we found was actually in the affirmative. 


DR. ULSH: Thank you, Arjun. 


MR. GRIFFON: Anything more on data 


completeness? 


DR. ULSH: Arjun? 


DR. MAKHIJANI (by Telephone): No, no, my 

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main concern and our main concern with ’69 has 


been the integration of bad data with good 


data. And Larry did say that last time it 


would be removed, and it was done. I think 


that settled that. 


COWORKER MODELS
 

MR. GRIFFON: Moving on to coworker models. 


Let’s see, I think let’s do the TIB-38 first, 


the internal coworker model. Go ahead, Joe. 


MR. FITZGERALD: Yeah, on that one I think 


it’s not an exaggeration to say that my 


colleague, Joyce Lipsztein, spent quite a bit 


of time on this issue, and we did have a 


number of opportunities with NIOSH to try to 


allay some of the concerns over the 


uncertainties. And let’s see if I can 


paraphrase uncertainties with the MDA and 


certainly some of the issues relative to HIS20 and some of the gaps that certainly were 


identified in our completeness review of 


internal. 


And we got to a point, and it was a 


fairly good point, where there was some 


acknowledgement that the 95th percentile was 


certainly available and could be applied to 

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address some of these uncertainties. And 


relative to the report we wanted to clarify 


that since in practice the 50th is applied for 


intake values in terms of a clarification of 


how and when the 95th would, in fact, be used 


given the standing uncertainties with the MDA 


and the internal coworker data. 


I thought, and again this comes from 


some review that Joyce has done along the way, 


stands as a concern. We had left it as one 


where certainly the 95th would be satisfactory. 


However, there wasn’t a good way to, since 


there was a concern over whether or not, well, 


it was a concern that the 50th, a full 


distribution, would not be sufficiently 


conservative in all instances so would not 


necessarily be bounding. 


So therefore, in adopting the 95th, it 


wasn’t clear when that would be applied and 


how. So in a way what we wanted to do here is 


-- and this may be in the vein of proof of 


principle -- given the uncertainties, given 


the issues that have been raised along the 


way, how would NIOSH apply the 95th given the 


fact that the 50th is routinely applied on the 

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internal side, and can that be reconciled with 


the fact that you have these uncertainties? 


So in a way we did get to the point 


where I think we all agreed the 95th was 


available and would do the job given the 


uncertainties. However, in practice the 50th
 

is used. So we’re left with this sort of lack 


of reconciliation on the practice versus the 


availability of the 95th to satisfy some of 


these issues and uncertainties. 


So I think we tried to lay that out, 


that we buy into the concept. We thought 


certainly the approach was fine. We agree 


certainly the 95th or higher would be 


satisfactory in the way of a conservative 


approach. However, we’re still left 


mechanistically with when that would be 


applied, and if the 50th is applied in 


practice, how could that be reconciled with 


the uncertainties that have been expressed? 


That’s I guess a not too helpful way of 


putting it, but that’s where we were left at 


the end. 


DR. ULSH: I’ve discussed this with Jim 


Neton, and there’s a part of this that’s an 

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overarching issue, but there may also be a 


part of this that is Rocky Flats specific in 


terms of some of the questions that, well, I 


know that Mark has about this HIS-20 database 


and the CEDR, you know, the various databases 


that were used for the internal coworker 


models. I can tell you that it is generating 


some discussions. Jim is taking the point on 


this in considering this issue, the 95th
 

percentile, and if we decided to agree to 


that, when and how it would be applied as you 


said, Joe. 


I can tell you that, for what it’s 


worth and probably not much, the philosophy in 


terms of external coworker models is we apply 


the 95th when there is a person who was 


unmonitored but was routinely exposed. We 


apply the 50th when a person was unmonitored 


and might be only intermittently exposed. And 


we typically apply ambient for people who 


never went into the production area. 


I don’t want to say that that’s 


exactly what we would do in terms of internal 


because I don’t know. This is something that 


Jim is still wrestling with. I can tell you 

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that we’ve committed to get back to Mark and 


the rest of the working group with our 


position on that. And I think you’ve 


characterized it accurately that ^ there from 


^. And I hear what you’re saying that if that 


was applied that you’d be okay with that. 


In terms of the details of the 


application of it and all that, we’re just 


going to have to get back to you on that. 


MR. FITZGERALD: Given the considerable 


effort on both sides to resolve that, I think 


that was sort of the mechanistic part we never 


really hammered out which it was okay, it’s 


available, but like on the external side how 


and when would you actually ^. And I think 


that’s fine. As long as we can be assured 


that there’s a way to apply it, there’s some 


guidance or criteria that would be enough. 


DR. ULSH: We’ll get back to you. 


MR. GRIFFON: And I think it is, I discussed 


this a little with Brant and Jim, and I think 


it is a unique circumstance with the HIS-20 


CER data because I had to use this approach at 


several sites, but they’re going to, I think 


we’ll leave it up to you to come back to us 

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with a reply on that. 


DR. ULSH: And we’ll do that quickly. 


MR. GRIFFON: Yeah, that’s ^. 


MS. MUNN: So that’s ^ conference call. 


MR. GRIFFON: Yes. 


And it says coworker models so I think 


we need to do 58. I think certainly it’s in 


the ^ I think mainly, but I’ll just as a sense 


of completeness here, Joe, maybe touch on 


that. 


MR. FITZGERALD: I almost hesitate to wade 


into ^. Ron has spent a good part of a year 


in OTIB-58 land, and really I think the issues 


we’ve already discussed have surfaced the ones 


that have the SEC implications. If you want 


to just spend a minute just kind of 


overviewing where we ended up. Not so much 


the --


MR. GRIFFON: I think we sort of touched on 


them in there. We touched all the other items 


today. We kind of touched on them. 


MR. FITZGERALD: Is there anything that we 


did not touch on, Ron? 


MR. BUCHANAN: There’s a couple 


clarifications on the ^. We’ve had two recent 

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additions of revisions to OTIB-58, one on the 


tail of another. And so we’re still trying to 


get it all together. In ’70 to ’76 in the 


next to the last revision, you added Table 6.2 


which before you were going to use the .42 


derived from lighter TLD data. 


And then you found the worksheets or 


something like that which gave individual 


neutron/photon data separate for ’70 to ’76. 


Now my question is are you going to use 


individual workers’ data then for individual 


dose reconstruction or are you going to use, 


apply to Table 6.2 to all the workers that you 


do dose reconstruction on? 


MR. GRIFFON: Because that situation you 


have the lump-sum doses, right? The 


aggregated neutron/photon doses during that 


period? 


 MR. SHARFI: No, we have reported pen doses. 


Those ratios to separate the pen dose out? 


MR. BUCHANAN: Right, are you going to use 


this table or are you going to use the 


individual TLD datasheets for each individual 


worker to separate out their penetrating 


neutron and photon dose? 

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 MR. SHARFI: I’m not sure when you refer to 


individual datasheets. 


MR. BUCHANAN: Okay, this information here, 


this new table came from some new datasheets 


that you gave us, right? 


 MR. SHARFI: They were the quarterly, or in 


this case, monthly? Yeah, they were monthly 


data by building, and it was a printed out 


supervisory report. And what we did was enter 


every valid neutron and photon pair. If there 


was a zero in one of them, we didn’t enter it. 


So we entered all 30,000 or whatever it turned 


out to be for the year, well, for several 


years. But we did not put in identifiers for 


individual people. They are individual 


readings, but --


MR. BUCHANAN: Right, no, what I’ve seen, 


the database you sent, I think you posted, was 


it had individual readings for each worker. 


DR. ULSH: Yeah, it wasn’t the neutron TLD 


worksheets. It was the supervisor reports. 


MR. BUCHANAN: Okay. 


DR. ULSH: I understand what you’re saying. 


^ data there. 


MR. BUCHANAN: You had individual workers 

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and their neutron and their gamma, photon 


readings separately. And so this was going to 


be, so that data was used on a, you determined 


the total neutron dose and the total photon 


dose, and determined that --


 DR. LITTLE: On that data we calculated 


individual pairs. 


MR. BUCHANAN: Individual pairs, okay. 


 DR. LITTLE: So rather than taking the ratio 


of the means or the ratio of the sums, we took 


the ratios. 


MR. BUCHANAN: And then averaged the ratios? 


 DR. LITTLE: Correct. 


MR. BUCHANAN: To get this Table 6.2? 


 DR. LITTLE: Correct. Well, I wasn’t 


involved in Table 6.2, but that’s the raw data 


I can tell you. 


MR. BUCHANAN: And so you averaged the 


individual ratios to get an overall ratio each 


year? 


 DR. LITTLE: Yes. 


MR. BUCHANAN: But not according to 


building. So when you do dose reconstruction, 


if a person has a composite dose in ’70 to 


’76, you will use, say 1971, you’ll use a 1.61 

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to separate out their dose regardless of what 


building they was in or anything. Now, why 


was there, I noticed that several years, ’72 


and, ’73 and ’70, you had not enough data. 


You had to use other, the year before or the 


year after. 


 DR. LITTLE: I can’t speak to Table 6.2. 


MR. FITZGERALD: Yeah, Ron, the issue is 


just whether there’s anything that because of 


the fact that there’s new tables that might 


influence the bottom line. I --


MR. BUCHANAN: Yeah, I realize this isn’t 


the place to discuss, but what I’m trying to 


determine is, is there any missing data here 


that would determine any SEC --


MR. FITZGERALD: That would have the 


implication --


MR. BUCHANAN: Right, and that’s what I was 


trying to clarify, exactly how it was going to 


be, how it was attained, and how it was going 


to be used. 


MR. FITZGERALD: And sometimes we might not 


have the right personnel, people who worked on 


this particular item. 


MR. GRIFFON: I might just need to follow up 

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on that one, right? We’re going to have a 


neutron call anyway. I think that’s a 


neutron-related question, but just a follow up 


on that Table 6.2 related to de-convolution, I 


guess, is the question. 


MR. BUCHANAN: How it will be applied and 


how it will be ^. And I don’t see an SEC 


issue here, but I just wanted to clarify how 


it was done to make sure we don’t have 


anything like we had doing ’59 back to ’52. 


MR. FITZGERALD: So Table 6.2 and you said 


you had one more? 


MR. BUCHANAN: Well, the other one is, I 


would characterize it as a site profile issue 


as far as Table 7.2. 


MR. FITZGERALD: Six-two is the one --


MR. GRIFFON: We don’t need to talk about 


that now. 


MR. FITZGERALD: We’ll have that on the 


neutron call. 


WOUND ISSUE
 

MR. GRIFFON: One other thing I just added 


as we were doing our conversation, and the 


individual’s who might likely respond to this 


is gone, but if you recall in the March 7th
 
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meeting I brought up again my wound question. 


DR. MAKHIJANI (by Telephone): Mark, could I 

sign off now? 

MR. GRIFFON: Yeah, yeah. 

DR. MAKHIJANI (by Telephone): There’s some 

people waiting for me. 

MR. GRIFFON: This time you really can, 


Arjun. 


DR. MAKHIJANI (by Telephone): Thank you, 


bye. 


MR. GRIFFON: I didn’t think of it until Jim 


was gone. 


MS. MUNN: It’s on my list. 


DR. ULSH: I know we’ve talked about it. I 


know I gave Jim a point on that. 


 MR. SHARFI: He had a thought process that 


he wanted --


MR. GRIFFON: Can you get something in 


writing to us maybe, a memo from Jim or 


something about this? 


 MR. SHARFI: ^ why we do what we do. 


 DR. WADE: And what’s this? 


DR. ULSH: What I can say, Mark, is that we 


have done some analysis, and Jim has been 


involved. We’ve had, there’s been some 

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discussions about it. The bottom line, I 


think -- I have to speak very generally, from 


Jim, was that we had some pretty good reasons 


why we thought what we were doing is bounding 


especially with, when you consider compared to 


like Super-S. I can’t go any deeper than 


that. I’ll have to rely on Jim for that. 


MR. GRIFFON: I’ve done some IMBA runs 


myself, and I can come up with scenarios that 


where the model’s not bounding, but are they 


likely scenarios? I’d have to say they’re 


probably not. Not only a huge wound intake, 


but also the likelihood that someone was 


wounded with a plutonium exposure and not 


monitored for a year. 


The records seem to indicate that if 


they were in those plutonium areas, they 


likely fell into that monitoring program. So 


I would concede that I would like to see you 


guys at least run, give us some kind of 


analysis back on that just to close it out. 


PROOF OF PRINCIPLE
 

The last item I had is proof of 


principle, and the only reason I had this on 


the agenda was you did provide some cases. I 

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think that’s where, you know, we’ve brought up 


proof of principle several times today, but I 


think there were some specific cases that were 


posted for us, Joe, and I don’t know if you 


specifically reviewed any of those or had an 


opportunity or we kind of put those on the 


side with the other issues? 


MR. FITZGERALD: Well, I think there’s been 


a, we looked at a few. I haven’t look at them 


specifically, but I guess Arjun’s already 


missing on the --


MR. GRIFFON: Yeah. 


MR. FITZGERALD: Did you look at some of the 


proof of principle, the actual cases 


themselves? 


MR. BUCHANAN: Yes, uh-huh. I had some of 


the hypothetical cases, you know, I looked at 


three external --


MR. FITZGERALD: These would be the more 


recent ones. 


DR. ULSH: Yeah, we had an initial set that 


we put together around the time we presented 


the ER back in April of last year. But a lot 


of water’s gone under the bridge since then. 


MR. GRIFFON: Then you gave us some new --

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DR. ULSH: Yeah, do you recall at the last 


working group meeting we decided that we 


needed to provide real cases that -- let me 


see, we had external coworker, preferably 


including ’69 and ’70. We had internal 


coworker, and we had Super-S. Those are the 


three specific categories of cases that were 


requested for proof of principle cases. I 


provided to the working group and Mark and 


SC&A -- let me think now. Was it some 


external case --


MR. GRIFFON: Case number, actual case 


number. 


DR. ULSH: Yeah, and then it was a 


hypothetical case that covered internal 


coworker and Super-S. Following onto that I 


provided a list of all of the cases that we’ve 


done that included external coworker and 


internal coworker. That’s where we, I don’t 


know if you reviewed those, Ron. 


MR. BUCHANAN: No, I got left out of the 


loop. 


MR. FITZGERALD: I think that was, yeah, 


that came in. I think Joyce may have looked 


at the internal, but I think the external one 

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certainly came in the same time that this 


neutron --


MR. GRIFFON: It sounds like we’ve, but I 


think we sort of know the internal issue, and 


we’ve got that on the table. As far as the 


external, let’s at least look at that case for 


the, I think we’re already planning for a 


Monday conference call meeting. I would 


argue, we can do it on the phone, but on 


Monday --


MR. FITZGERALD: It may be Tuesday because 


the Monday, I think the notion was to get the 


’52-’58 out. 


MR. GRIFFON: No, no, I’m not talking next 


Monday, I’m talking the Monday after, Monday 


the --


 DR. WADE: The 30th of April. 


MR. GRIFFON: For a work group call, Monday 


 DR. WADE: What time, Mark? 


 DR. WADE: Eleven? 


MS. MUNN: Eleven. 


 DR. WADE: Respect to Wanda? 


MS. MUNN: Or suffer the wrath. 


MR. GRIFFON: This could be good. I could 

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avoid an implant preparation at my dentist. 


What time did you say, Wanda? 


MS. MUNN: Eleven. 


MR. GRIFFON: Yeah, I could be a little numb 


by then. That might be good. Yeah, eleven 


o’clock’s good for a conference call. 


 DR. WADE: This is going to be a work group 


call. 


MS. HOWELL: Is this on the 30th? 


MR. GRIFFON: Yes. Now next week we might 


have a couple technical calls, but at least 


one technical call. 


MR. FITZGERALD: This is a work group call, 


right, right. 


MR. BUCHANAN: Joe, will you send? I 


haven’t received that. 


MR. FITZGERALD: Yeah, well, we’ll, again, 


we’ve been diverted, but yes, absolutely. 


MR. GRIFFON: And in addition to the, so you 


have the wound thing on an action item, too. 


And SC&A will look at those other couple 


cases. 


MR. FITZGERALD: Right, I think though, 


again, the external, since the internal ^. 


MR. GRIFFON: Yeah, we kind of discussed the 

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external and internal in the broad sense. I 


don’t know that we’re going to see much more 


out of the cases, but we should look at them 


and --


MR. FITZGERALD: Probably the other thing, 


too, is, well, okay, we can talk about this 


offline, but the Super-S certainly ^. 


MR. GRIFFON: Right, I think we had another 


hypothetical before in the Super-S, and it may 


not, but there were some changes, I think --


DR. ULSH: I think the situation there is 


that we don’t yet have the Rocky Super-S 


cases. 


 DR. WADE: They’re in adjudication. 


 MR. SHARFI: That’s why we ended up doing a 


MR. GRIFFON: Adjudicated. 


MR. FITZGERALD: Well, I think we did one 


before, but that’s okay, we can do --


MR. GRIFFON: If you can provide us case 


numbers for Super-S that are non-adjudicated, 


I mean, we can do the same thing we did with 


the others. 


 MR. SHARFI: ^ 


DR. ULSH: No, that was then. This is now. 

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I’ll have to check on that. 


MR. GRIFFON: The understanding is if we can 


get case numbers that are non-adjudicated we 


can review them but we won’t discuss them 


specifically on the record. 


MR. FITZGERALD: But that would be a change 


from the one that we did before that which was 


another hypothetical Super-S. 


MR. GRIFFON: So if you have a real case for 


Super-S. 


DR. ULSH: I’ll double check. I know that 


there’s an answer back in my office. I just 


can’t --


MR. GRIFFON: But otherwise the action’s in 


SC&A’s court. 


MR. FITZGERALD: Yeah, yeah, we can 


certainly do that. 


MR. GRIFFON: All right, and then the final 


process leading to the May meeting. I think 


we have meetings from now until the May 


meeting. 


 DR. WADE: Well, we certainly have a work 


group call at eleven a.m. on the 30th . We’re 


looking at possible technical calls. 


MR. GRIFFON: Yeah, and next Monday we’re 

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getting a report from SC&A to NIOSH, a draft 


section. 


 DR. WADE: The neutron 1952 to 1958. 


MR. GRIFFON: And then I would offer that 


maybe Wednesday or so, Brant, if we can get a 


technical call. 


MR. FITZGERALD: ^. 


DR. ULSH: Meeting on Wednesday. 


MR. FITZGERALD: I was thinking Tuesday. 


MS. MUNN: Sounds like you’ve got Tuesday. 


 DR. WADE: And Wednesday we’re looking by 


close of business, the SC&A addendum, and then 


with Privacy Act review hopefully it will be 


available to the world by close of business 


Friday. 


MR. GRIFFON: That takes care of everybody’s 


next couple of weeks. We’re getting there 


though I think. 


 DR. WADE: Deserves it, all the work you’ve 


put into this one. 


MR. GRIFFON: And made good headway. Any 


final comments before we close? 


 DR. WADE: Only thank you. 


MR. GRIFFON: Arjun? We know he’s gone. 


 MR. PRESLEY: Are we going to meet before 

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the meeting? 


 DR. WADE: Wednesday we have a subcommittee 


meeting. 


MR. GRIFFON: We have a subcommittee 


meeting, yeah, a subcommittee meeting. So I 


think the answer is no. I mean, I’m hoping 


that anything we have to finalize is on the 


30th . I don’t think a lot’s going to change in 


two days. 


 DR. WADE: We won’t be taking up Rocky Flats 


until Thursday so theoretically you have 


Wednesday. 


MR. GRIFFON: We could have a late 


afternoon, yeah. 


 DR. WADE: Well, if we have also the public 


comment period Wednesday from five to 


whenever. 


MS. MUNN: So we can skip dinner. 


 MR. PRESLEY: Yeah, I can see you skipping 

dinner. 

MR. GRIFFON: Lew, before we close, I don’t 

know if we asked, if anyone’s still on the 


line if we have any final comments from 


anybody on the line? Petitioners or 


Congressional staff? 

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 (no response) 


MR. GRIFFON: Everybody lost track of us, 


huh? 


Well we appreciate it. If you stayed 


on, we appreciate it, and I think we’ll close 


out now. 


 DR. WADE: Thank you all very much. 


(Whereupon, the working group meeting 


concluded at 4:40 p.m.) 

______________________________ 

280 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of April 19, 


2007; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


26th day of April, 2007. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102