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 

 

The verbatim transcript of the Meeting of the 

Advisory Board on Radiation and Worker Health 

Working Group held at The Westin Hotel, Cincinnati, 

Ohio, on Oct. 6, 2005. 
2

C O N T E N T S

Oct. 6, 2005 

WELCOME AND OPENING COMMENTS 6 

DR. LEW WADE, EXECUTIVE SECRETARY 

BETHLEHEM STEEL SITE PROFILE 

TBD REVIEW 11 

TASK 3 PROCEDURES REVIEW 115 

Y-12 SITE PROFILE REVIEW 211 

COURT REPORTER’S CERTIFICATE 231 

 
3

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. 

In the following transcript (off microphone) 

refers to microphone malfunction or speaker's neglect 

to depress "on" button. 
4

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

(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

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 
5

OTHERS PRESENT: 

ALLEN, DAVE, NIOSH 

**ANIGSTEIN, BOB, SC&A 

BEHLING, HANS, SC&A 

BEHLING, KATHY, SC&A 

**DEMERS, KATHY, SC&A 

ELLIOTT, LARRY, NIOSH 

FITZGERALD, JOE, SC&A 

GLOVER, SAM, NIOSH 

HINNEFELD, STU, NIOSH 

HOMOKI-TITUS, LIZ, HHS/OGC 

**LIVINGSTON, REV. 

MAKHIJANI, ARJUN, SC&A 

**MAURO, JOHN, SC&A 

**MELO, DUNSTANA, SC&A 

NETON, JIM, NIOSH 

**PANTILLO, DANNY, CONGRESSMAN HIGGINS 

**SCHROEDER, JANE, CONGRESSWOMAN SLAUGHTER 

SHIELDS, LASHAWN, NIOSH 

TOOHEY, RICHARD, ORAU 

WALKER, ED, BETHLEHEM STEEL 

**telephonically 
6

 P R O C E E D I N G S

 10:07 a.m. 

1 MR. GRIFFON: Good morning everyone. My name is 

2 Mark Griffon with the Advisory Board on Radiation 

3 and Worker Health. I'm chairing this working 

4 group session. And I think we have Lew Wade on 

5 the phone from, and Lew, I think you wanted to 

6 make some opening remarks and welcome everyone. 

7 I'll let you start the meeting off that way, I 

8 think. 

WELCOME AND OPENING COMMENTS

DR. LEW WADE, EXECUTIVE SECRETARY

9 DR. WADE: Thank you, just I'd like to welcome 

10 everyone and thank you for your attendance. This 

11 is a working group of the Advisory Board. At the 

12 last Board meeting, this working group was 

13 formed. It consists of Mark acting as chair, 

14 Mike, Wanda and Robert, Richard Espinosa 

15 designated as alternate. 

16 The working group was put together to bring focus 

17 and to expedite some of the many ongoing review 

18 activities that the Board has under its purview. 

19 The thought was that this working group could do 

20 somewhat detailed work leading up to a 

21 subcommittee meeting and a full board meeting 

22 that will take place in the middle of October. 

23 The particular issues that my recollection would 
7

1 be that we'll need to be focused on are the 

2 Bethlehem Steel site profile review, TBD review. 

3 We have ongoing issues relative to the Task 3 

4 review by SC&A. That is the review of the 

5 procedures. I think there needs to be some work 

6 done on that. 

7 We have site profiles for the Savannah River site 

8 and Y-12. Also, that it could use some 

9 discussion. But in my discussions with John 

10 Mauro of SC&A, I know that they are finalizing 

11 their Rocky Flats review. There's an issue 

12 that's come up on this, what I define as high 

13 five plutonium issue, and I think it could be 

14 worthwhile to get that issue on the table. 

15 The Board in its wisdom suggests that we hold 

16 this working group as a public meeting, and I 

17 think that's wise. I mean, the more open we do 

18 our business the better. The public is invited. 

19 There is no public comment period that has been 

20 scheduled for the meeting, but the Board did ask, 

21 and NIOSH concurred, that we would afford an 

22 opportunity to Ed Walker who really is the focal 

23 point for those interested in the Bethlehem 

24 activity, to give Ed an opportunity not only to 

25 attend the meeting, but to participate, you know, 
8

1 within reason within the discussion as the 

2 working group takes up issues at Bethlehem. 

3 So those are the introductory comments I would 

4 have. I mean, you're under the able direction of 

5 Mark, and I look forward to a most productive 

6 meeting, again, leading up to our subcommittee 

7 and board meeting. Thank you, Mark. 

8 MR. GRIFFON: Thanks, Lew. 

9 The only thing I will say, Ed Walker is here. I 

10 see Ed, and we will be taking up Bethlehem Steel 

11 as the first item. And I think we, you know, we 

12 want to extend the offer that if you have 

13 comments during that discussion, then feel free 

14 to come to the mike and we'll recognize you. You 

15 made the trip all this way again, so we do 

16 appreciate you being here. 

17 And the other thing I think we should ask is I 

18 think there are other people on the phone line. 

19 I'm not sure if that's true, but has anyone else 

20 dialed in that we should acknowledge is at the 

21 meeting? 

22 DR. MAKHIJANI: Kathy wanted to dial in but did 

23 not know the number. 

24 MR. FITZGERALD: Well, I just called her. The 

25 number in the Federal Register apparently wasn't 
9

1 working. So I went ahead and checked, and I gave 

2 them the number and the code, so it should be 

3 fine. 

4 MR. GRIFFON: So as people come on -- 

5 MS. SCHROEDER: Are you asking for people to 

6 identify themselves? 

7 MR. GRIFFON: Yeah, please. 

8 MS. SCHROEDER: I'm Jane Schroeder with 

9 Congresswoman Slaughter’s Office. 

10 REV. LIVINGSTON: I'm Reverend Livingston. 

11 UNIDENTIFIED: (Inaudible). 

12 MR. GRIFFON: Wait, wait, we're going to have to 

13 start that again because we couldn't get those 

14 recorded those names. 

15 MS. SCHROEDER: Okay, I'll try again. My name is 

16 Jane Schroeder. It's S-C-H-R-O-E-D-E-R. I'm 

with Congresswoman Slaughter’s Office, the 28th 17 

18 district. 

19 REV. LIVINGSTON: I'm Reverend Jerome Livingston 

20 with the (inaudible) group -- 

21 MR. GRIFFON: Reverend who? I'm sorry. Excuse 

22 me, Reverend who? 

23 REV. LIVINGSTON: Livingston. 

24 MR. GRIFFON: Livingston? 

25 REV. LIVINGSTON: Correct. 
10

1 MR. GRIFFON: For the Bethlehem Steel group, 

2 correct? 

3 REV. LIVINGSTON: Correct. 

4 MR. GRIFFON: Okay, thank you. 

5 MS. MELO: I’m Dunstana Melo. I'm with SC&A. 

6 DR. MAURO: John Mauro, SC&A. 

7 DR. ANIGSTEIN: Robert Anigstein, SC&A. 

8 MS. DeMERS: Kathy DeMers, SC&A. 

9 MR. PANTILLO: Danny Pantillo, the office of 

10 Congressman Brian Higgins. 

11 MR. GRIFFON: Can you repeat that? I'm sorry. 

12 MR. PANTILLO: Sure, it's Danny Pantillo. It's 

13 P-A-N-T-I-L-L-O with the office of Congressman 

14 Brian Higgins. 

15 MR. GRIFFON: Thank you. 

16 Anyone else? 

17 DR. WADE: This is Lew Wade again with NIOSH. 

18 Again, this is a working group meeting, not a 

19 board meeting. I don't think we're in any danger 

20 of having a quorum with the Board present, but 

21 Mark, I’ll ask you to just sort of watch for 

22 that. 

23 MR. GRIFFON: Right, that's part of the reason I 

24 wanted to do the roll call on the phone there. 

25 And I think as Lew stated, I think we're going to 
11

1 start the with the Bethlehem Steel site profile 

2 TBD review. And my desire is to do the 

3 procedures review secondly and then, as we can 

4 get to them, either the Savannah River or Y-12 

5 site profile, in the afternoon. And I'm not sure 

6 how far we'll get along. The procedures review 

7 might be time consuming. 

8 But to start -- 

9 DR. WADE: This is Lew Wade. I would ask that 

10 when we do get to either Savannah River or Y-12, 

11 we do Y-12 first only because we have an SEC 

12 petition pending. 

13 MR. GRIFFON: Okay, that's fine. 

BETHLEHEM STEEL SITE PROFILE

14 TBD REVIEW

15 And to start with Bethlehem Steel I think what 

16 makes more sense is probably to have SC&A do a 

17 quick overview of their recent report, the 

18 supplemental review draft, rev. two, and then 

19 maybe have, give NIOSH a chance to respond, and 

20 then have -- open up for discussion after that. 

21 So, Joe or Arjun or -- Arjun, I guess, is going 

22 to present on this. 

23 DR. MAURO: This is John Mauro. I just wanted to 

24 say that first of all I apologize for not being 

25 able to make the meeting. I hope everyone can 
12

1 hear me okay. Arjun, myself and Bob Anigstein 

2 were the coauthors of the recent review. I was 

3 hoping I'd be able to give a little overview, but 

4 Arjun, if you could please, it's probably most 

5 efficient for you to give the overview regarding 

6 the latest revision of Bethlehem Steel. So I'd 

7 like to -- 

8 DR. MAKHIJANI: Yeah, thank you, John. Yeah, 

9 originally John actually prepared the initial 

10 draft of the slides and was going to make the 

11 presentation, but since he's not here, I'm sort 

12 of pinch-hitting for him. 

13 Let me just preface this by saying that our 

14 report was submitted about a week ago, and then 

15 the day before yesterday, and one of the 

16 principle things in the report was that there 

17 were a number of illegible data points in some 

18 very important data sheets from Bethlehem Steel. 

19 And NIOSH sent us new, NIOSH got the originals of 

20 those data sheets and sent us a spreadsheet. 

21 We would like to see the originals of that if 

22 they are available, but we do take NIOSH's word, 

23 we took NIOSH's word at it that those were 

24 properly represented and that, of course, has 

25 changed the picture somewhat. How much and in 
13

1 what way we haven't had quite time to look. 

2 We've done a little bit of preliminary looking at 

3 the data. 

4 And so I just wanted to preface that by saying 

5 that there is a new element. I will try to 

6 address the element somewhat, but of course, we 

7 haven't had really time to have a considered 

8 analysis of this new information. I just want to 

9 stress that in the beginning. 

10 Last I was here I presented. We had a number of 

11 issues that we made in our first review, and I 

12 think a number of the issues that we raised have 

13 been resolved. I just want to go over at least 

14 we're in concurrence with NIOSH. We've looked at 

15 the NIOSH analysis technically, and we think that 

16 those issues have been addressed or resolved or 

17 where we have found that our original concerns 

18 were not -- we raised some concerns in regard -- 

19 let me just go through them. 

20 We agree, NIOSH has said that they’re going to 

21 use the Simonds data set at least for part of the 

22 time, and we agree with that. NIOSH is making a 

23 consistent use of the 95 percentiles, and we 

24 agree with this approach. In the first review 

25 SC&A had quite strongly raised a concern as to 
14

1 whether the things that were marked as breathing 

2 zone samples in the old data sheets that were 

3 taken 50 years ago or more were actually 

4 breathing zone samples comparable to modern 

5 standards. 

6 And we've looked at NIOSH's analysis that was 

7 commissioned, and we're in agreement with NIOSH 

8 that the samples were properly taken, and they 

9 appear to be represented. There were a few data 

10 points in the Bethlehem Steel data that didn't 

11 seem quite in line, but the laboratory analysis 

12 and the representation of the data, we don't have 

13 an issue with that anymore. That was a pretty 

14 major point in the last review. 

15 We also have said that the Simonds' data set 

16 would be appropriate for estimating resuspension 

17 which was another significant point. And SC&A 

18 commissioned an analysis of industrial setting 

19 dust loadings as to what could be breathed in 

20 routinely in order to see whether there was some 

21 kind of upper limits to routine intakes of dust 

22 that could be determined. 

23 There were two analyses that were commissioned. 

24 They're both in the report that we sent the 

25 board. And partly by happenstance, the limit was 
15

1 in milligrams per cubic meter, 30 milligrams per 

2 cubic meter. But because here we're dealing with 

3 natural uranium, by happenstance it translates 

4 into about 600 times the maximum allowable 

5 concentration. Of course, enriched uranium would 

6 be more. If it were depleted uranium, it would 

7 be less. 

8 But for natural uranium it turns out to be 

9 roughly the same number as the 95 percentile of 

10 the Simonds' data set. And so that made us sort 

11 of very comfortable that the 95 percentile of the 

12 Simonds' data set is a very claimant favorable 

13 and robust number for routine intakes in that 

14 kind of setting and so you would not be 

15 underestimating routine intakes by applying 

16 Simonds' data to Bethlehem Steel. 

17 We had some caveats about cobbles and incidents 

18 in transient loadings, and I'll mention that a 

19 little bit later. As I mentioned, we've taken a 

20 look at the new Bethlehem Steel data. One of 

21 our, we had said in our report that Bethlehem 

22 Steel data are inadequate for estimating doses 

23 for 1951 and 1952. Now one of our problems with 

24 the Bethlehem Steel data set was that in the 

25 early data from April 1951 there were many 
16

1 illegible points. That was also the data set 

2 that contained the highest air concentrations 

3 that were sort of legible or barely legible. 

4 And we had other issues that I want to mention, 

5 but that was one of the main ones. And two days 

6 ago we got a complete set of data. So now we 

7 have essentially all of the data that were taken 

8 at Bethlehem Steel in that period including those 

9 13 points. They did contain quite a lot of high 

10 air concentrations. 

11 There are some issues with -- so what I'm going 

12 to say about this data is very preliminary and 

13 John and Bob and I have discussed this. And we 

14 all agreed that we really need to look at this in 

15 more detail since we have a much richer data set. 

16 One of the issues was that there was only one 

17 breathing sample for, zone sample, for the early 

18 period in the data set that we analyzed in the 

19 report that we sent the board. Now there are six 

20 which, and so the number of breathing zone 

21 samples now is not that different from Simonds -- 

22 I haven't added up all the numbers, but it, the 

23 data set doesn't look, in terms of number of 

24 points, that different. 

25 However, we still had some issues in the 
17

1 interpretation of this data set in that both for 

2 the early period and for the later period -- let 

3 me just show you. Harry Chmelynski did some 

4 statistical analysis of the data set. I should 

5 put up this slide so you can look at it. 

6 Can we put up this slide? 

7 Anyway, our SC&A statistician analyzed the data 

8 set, and we found that there are two -- the 

October 6th 9 folder, the PowerPoint, and it's 

10 slide number four. 

11 Well, I'll just describe it. Let me just go on. 

12 It's clear that in the early period when they 

13 were doing the lead bath experimentation, when 

14 they were heating up the uranium in a lead bath, 

15 that it was much more dusty than in the later 

16 period. This observation was also made by the 

17 AEC, Mr. Eisenbud, I believe in 1951, that the 

18 lead bath rolling process generated -- there you 

19 go. You have it there. It's above, slide number 

20 four. 

21 -- generated much more dust and was comparable -- 

22 yeah, that one -- and it was comparable to the 

23 Simonds' no ventilation dust loads. And the red 

line is the data up to October 27th 24 , 1951, and 

the blue line is data from October 17th 25 , 1951, to 
18

1 the end of the period for which we have data, 

2 somewhere toward the end of 1952. 

3 And you can see that the line that goes up to 

4 zero, the Z score of zero, the average is 

5 somewhat, the median is somewhat different, but 

6 they're both below one times MAC, but the 95 

7 percentiles are very different. In one case more 

8 that a hundred times MAC. In the other case 

9 it's, I think, about seven times MAC or close to 

10 ten, just under ten. 

11 The processes were different, generating 

12 different amounts of dust, and one of the 

13 observations that we have now on this data set 

14 that it does appear that the early period in 

15 Bethlehem Steel should be looked at in a 

16 different way. Well, our main message to the 

17 board about Bethlehem Steel data that's different 

18 from the report that we filed is that this is, 

19 because of the missing data points that have been 

20 filled in, this is a sort of different data set 

21 that needs a look. 

22 One of the main reservations that we have about 

23 this data set is that the breathing zone samples, 

24 both for the early period and the later period, 

25 the averages are less than the general air 
19

1 samples. And that makes us kind of a little bit 

2 uncomfortable as to how they are to be 

3 interpreted as breathing zone samples. Even 

4 though we agree that the labels are probably 

5 accurate, there's no report on this whole 

6 sampling as to what was the purpose of it that's 

7 comparable to Simonds. Just for reference the 

8 Simonds' breathing zone were ten times the 

9 general air, so it's the reverse direction by 

10 about a factor of 15 to 30 depending on the 

11 period. 

12 So the next set of observations was really about 

13 the Simonds' data set, and we did conclude that 

14 it was an internally consistent data set that 

15 could be used in a claimant favorable way. We 

16 had three categories of workers about which we 

17 presented conclusions in our report. One was 

18 that since everybody at Bethlehem Steel in that 

19 period can apply, the people who were not in 

20 routine working contact with uranium, for them 

21 the Simonds' data is clearly very claimant 

22 favorable. For workers who were not involved in 

23 high transient loading incidents, for them also 

24 this is claimant favorable, especially as it is 

25 robust from the point of view of routine 
20

1 exposures from dust loading analysis. 

2 In the worker meeting of July 1, 2004, and in 

3 subsequent interviews that SC&A did with workers, 

4 it became very clear that some issues, especially 

5 the cobbles which happen more frequently at 

6 Bethlehem Steel than at Simonds where workers had 

7 to cut up these long uranium rods probably 

8 generating fumes, and fumes could generate high 

9 transient loadings for some workers, not for all 

10 workers. You know, you wouldn't expect this to 

11 be, say, typical of somebody who's working 

12 outside or in a different area or in a crane or 

13 something like that. 

14 But for a worker who was cutting up these uranium 

15 rods during a cobble when the uranium gets out of 

16 line and gets tangled up like spaghetti and has 

17 to be cut into small pieces, we think that has to 

18 be taken into account in some way. We weren't 

19 sure whether it was going to add anything to 553, 

20 whether increasing that above 553 would be 

21 warranted or not. But it's certainly something 

22 that should be taken into account. 

23 So generally we agree that the use of the 

24 Simonds' data set is pretty robust and transient 

25 incidents have to be taken into account. We have 
21

1 not calculated any quantitative significance of 

2 those, but recommended worker interviews. 

3 We had a pretty big discussion over the last many 

4 months about oronasal breathing, and we agree 

5 with NIOSH's analysis that in the specific 

6 context of Bethlehem Steel, it's a small relative 

7 difference, and it's not a large uncertainty 

8 given the kind of uncertainties we're talking 

9 about. But it's not a negligible factor, and for 

10 other areas where the other uncertainties, other 

11 facilities where the other uncertainties are 

12 lower, it could be an issue. We haven't, so it 

13 could be a general issue, but it doesn't appear 

14 to be a big issue at Bethlehem Steel. 

15 Now we still do not -- here's a sort of a point 

16 which is still outstanding -- we don't agree with 

17 the use of TIB-0009 for, Technical Information 

18 Bulletin nine, for intakes as it doesn't take 

19 into account live particle intakes. And the 

20 numbers that were calculated in the revised site 

21 profile are sort of fortuitously similar. 

22 Bob Anigstein came up with a different model that 

23 assumes a hundred milligram ingestion every day 

24 but progressively mixed in with greater 

25 quantities of steel as time goes on after the 
22

1 rolling and resulted in a considerably bigger 

2 intake, about threefold bigger than the 5.21 

3 calculated from TIB-0009. It probably won't make 

4 a big difference to most of the doses, but the 

5 technical method is out there. 

6 We also did some analysis of the resuspension, 

7 and Bob Anigstein came up with a model that's 

8 described in there. One of the main things that 

9 we found was that because in between rollings 

10 there was no activity at Simonds that the dust 

11 wouldn't be stirred up in that, and that factor 

12 needed to be taken into account. Again, Bob 

13 developed this different model and came up with a 

14 higher intake. Certainly, this is also 

15 something, you know, all of these things are up 

16 for discussion. We've presented this as a 

17 alternative scientific approach that could be 

18 adopted. 

19 We found that the point that we had raised in our 

20 last review, that there were some workers like 

21 inspectors who were touching these uranium rods 

22 with bare hands and may have had extended 

23 contact, that their skin doses and near surface 

24 doses should be calculated for these types of 

25 workers. And we didn't find that issue was 
23

1 addressed in the TBD. 

2 I think that's it. Thank you. 

3 MR. GRIFFON: Thanks Arjun. 

4 I think NIOSH is ready to respond. I'm not sure 

5 who's going to respond, but what I might ask for 

6 the sake of the people on the phone if we can 

7 remember to identify ourself when we talk. This 

8 is Mark Griffon by the way, violating my own 

9 rule. 

10 DR. NETON: This is Jim Neton. We've had this 

11 document for just a week now, and we've taken a 

12 fairly preliminary look it, but we do have some 

13 initial take on some of these issues. And I 

14 don't know whether it's best to go through what 

15 our opinion is on each of these findings at this 

16 point or just to start -- open the table for some 

17 discussion on what we believe to be some of the 

18 more critical points. I'll just go through, I 

19 guess, and then we can open up for general 

20 discussion, but let me just get this thing going. 

21 I sort of have just a snapshot summary of what 

22 Arjun just went through. And I think probably 

23 the most significant issue that we take exception 

24 to is bullet number one or finding number one 

25 which I've sort of paraphrased here. It says 
24

1 that we can't use any of the two hundred data 

2 points from Simonds Saw and Steel 1951 and '52 to 

3 predict the air concentration datas in those time 

4 periods. That's essentially what, that's exactly 

5 what they've said. They're inadequate to be used 

6 for any, they're not informative in any way of 

7 what happened at Simonds Saw and Steel '51 and 

8 '52. 

9 UNIDENTIFIED SPEAKER: So you're saying Simonds -

10 - 

11 MR. GRIFFON: Simonds Saw, you mean -- 

12 DR. NETON: I'm sorry, the Bethlehem Steel. I'm 

13 sorry. So, you know, we believe that when you 

14 have a couple hundred data points something can 

15 be used to do a bounding analyses, especially in 

16 light of the fact that it's acknowledged by SC&A 

17 that these processes were substantially 

18 different. If you recall, the Simonds Saw and 

19 Steel data represented roughly, it was about 40 

20 data points, I think, which were taken under very 

21 similar circumstances by the same organization. 

22 The Health and Safety Laboratory covered both 

23 jobs. 

24 But the Simonds' data, if you recall, essentially 

25 was roasted uranium. I mean, this was fired in a 
25

1 furnace with no salt bath, no lead bath, and 

2 generated these extremely large concentrations 

3 where we had up to a thousand MAC air. But the 

4 picture at Bethlehem Steel is substantially 

5 different. 

6 I mean, you have a combination of lead bath 

7 operations through October, and after October 

8 1951, they adopted the salt bath as the method of 

9 preference for heating. So there is some very 

10 good technical reasons why these air sample 

11 concentrations went down over time. But SC&A has 

12 essentially, doesn't believe that they're 

13 informative as to why these concentrations should 

14 be lower. 

15 Secondly, so from throwing out the air sample 

16 data then SC&A has resorted to saying well, the 

17 only informative information is either the 

18 Simonds Saw and Steel data or this sort of 

19 ancillary analysis they've done that said are 

20 bounding 30 milligram per cubic meter, choking 

21 atmosphere. And that's the best one can do to 

22 estimate exposures in '51 and '52. 

23 One of the problems we have with that, and this 

24 is all open for discussion, is that we'd be 

25 interested to hear the mechanism that is there to 
26

1 sustain air concentrations of that magnitude. So 

2 sustained 30 milligrams per cubic meter for ten 

3 hours a day requires some sort of a process 

4 that's going to generate that type of airborne, 

5 and we're hard pressed to come up with that 

6 mechanism. If you recall, the air samples were 

7 taken, and this is one of their criticisms, 

8 they're short duration air samples. Well, in 

9 essence, what they are is short duration because 

10 the process was short duration. 

On August 26th and 27th 11 , that first rolling, they 

12 rolled 72 billets. On average a billet takes 

13 about three minutes to go through the production 

14 mill. Remember, at Bethlehem Steel there was an 

15 18 stand rolling mill. They only used stands 13 

16 through 18 because these were finished rollings. 

17 These were like one-and-a-half inch or so 

18 diameter rods. It took about three minutes to go 

19 through so in my mind if you have 70 billets 

20 about three minutes a piece, there's 210 minutes 

21 of a process that will generate a large airborne 

22 that we've got captured in these air samples. 

23 That's about what? Three hours. A little over 

24 three hours, maybe four hours tops out of 20 

25 hours, yet SC&A's analysis suggests that this was 
27

1 going to be 30 milligrams per cubic meter for 

2 their additional 17 hours of rolling. It just 

3 does not seem plausible to us that that's the, a 

4 value that should be used for bounding at this 

5 facility. We have much more to say on these 

6 issues, but we'll start there. 

7 The profile does not address short-term episodic 

8 air concentrations. This is related to the 

9 cobble situation where you do have looping and 

10 bending of the rods as they go through. Most of 

11 the analysis is based on the fact that there was 

12 an interview with a worker who indicated that the 

13 rods were cut with a torch. Although that may be 

14 true, we're having trouble understanding how that 

15 could happen. 

16 Cutting uranium with a torch is, doesn't seem to 

17 be a good idea to us. It's a pyrophoric metal, 

18 particularly in the light that they've speculated 

19 that the concentrations in air could be as high 

20 as 300 milligrams per cubic meter. If you've got 

21 open torch cutting with 300 milligrams uranium in 

22 air, a small particulate size, it would suggest 

23 that this would be a fairly combustible 

24 atmosphere for uranium. So, you know, it may be 

25 that it happened, but we have done some searches. 
28

1 We have no evidence that uranium, we could not 

2 find any evidence of uranium torch cutting that 

3 actually occurred, and, you know, I'd like to ask 

4 SC&A if they could substantiate that a little 

5 better. It just does not seem to be reasonable 

6 to us. It may be that steel rods were cut with a 

7 torch and such, but, and in fact, we've looked at 

8 a number of samples. 

9 And where there were cobbles in an instance, 

10 there's an indication that the process was 

11 stopped, the rod, it was opened and the rod was 

12 removed. There was one instance where they had a 

13 cobble. They actually took it out of the 

14 process, put it back in the salt bath, reheated 

15 it, and reran it. 

16 So the whole issue of cobbles and creating 

17 potentially six thousand MAC air, I think needs 

18 to be addressed a little better. I mean, it is 

19 based on an interview of a worker, but at this 

20 point, we have no substantiating evidence that 

21 that actually happened. 

22 The other issues become more minor as we go down. 

23 Oronasal breathing, SC&A has acknowledged that it 

24 has a relatively small effect. I think they took 

25 issue with our use of the word negligible, which 
29

1 I think would be a six percent. We calculated at 

2 most it would be a six percent increase in the 

3 MAC. We accept that criticism. I mean, it is, 

4 it's not a significant issue, I think, given the 

5 uncertainties of the air sample data here. 

6 The injection and resuspension models, I mean 

7 these were purported to be new models. Really, 

8 they are essentially the same as what we've had 

9 just with different starting points in my mind. 

10 The one thing I have, we have a problem with is 

11 the resuspension model, I believe, started with 

12 the resuspension being equal to the air 

13 concentration during rolling. 

14 If you have to accept the fact, it's kind of 

15 hidden in there, but you're reading through and 

16 all of a sudden, whoa, let's assume that the 

17 resuspended air was equivalent, was all due, that 

18 the rolling operation was all due to 

19 resuspension, and that just does not make sense 

20 to us to start with that high of a concentration. 

21 In fact, they're left with a chronic resuspension 

22 of about, I think it's 13 or 14 MAC air every day 

23 for four years which seems to be implausible to 

24 us for a facility of this nature. 

25 Ingestion model, I think we're still struggling 
30

1 with SC&A's guidance that 100 milligrams per day 

2 is an acceptable amount for ingestion to start 

3 with. This is not going to make a very huge 

4 difference in the end result. Our model, in 

5 fact, was pretty much the same where you just 

6 didn't, there's a diminution in the amount per 

7 day. It's just what's your starting point. 

8 External exposure model, I think this is an 

9 issue, and we've had similar discussions in the 

10 past where we developed a model that exposes a 

11 person for, you know, I think the model currently 

12 says that one foot for six hours and one meter 

13 for four hours or something to that effect, 

14 trying to sort of get a time-weighted average of 

15 what the exposures may have been. That does not 

16 preclude the fact that a person could have been 

17 handling the metal at any given time. 

18 We're not saying that didn't happen. So we think 

19 the model is probably, is claimant favorable. We 

20 just need to go in and demonstrate that, you 

21 know, handling on occasion is not going to 

22 increase those values substantially. You know, 

23 there are issues here. Much of the time the 

24 uranium was being handled there's crowbars and 

25 gloves as workers have indicated. It's hot, it's 
31

1 1100 degrees Fahrenheit while it's being rolled. 

2 It takes awhile to cool down. 

3 So the amount of manual handling, and one has to 

4 remember also, these are one-and-a-half inch 

5 diameter rods. We were assuming that these were 

6 planer exposure geometries of about 230 millirem 

7 per hour beta on surface which is representative 

8 of an infinite plane source of uranium which 

9 these were not. So, you know, we can go back and 

10 look at that, but I think we've got some bounding 

11 estimates that are fairly claimant favorable. 

12 I think that's enough to get the ball rolling, so 

13 I'll stop here and I guess we'll open up for 

14 discussion. 

15 DR. MAURO: This is John Mauro. I would like to 

16 just comment on a couple of points you made to 

17 sort of kick this off if that's okay. 

18 DR. NETON: Sure. 

19 DR. MAURO: Regarding –- and again this is to get 

20 the ball rolling. Regarding the data we do not 

21 have any intention of saying that the data are 

22 useless if that's what, you know. If we did, we 

23 should not have. I think that there are data, 

24 now that we've gotten the additional data, 

25 there's no doubt, it was very much a part of our 
32

1 considerations in our evaluation. So I, if we 

2 left that impression that the data is useless, we 

3 should not have. That's the first point I wanted 

4 to make, the data certainly is very much part of 

5 our analysis. 

6 DR. NETON: John, I'd just like, the finding 

7 actually says the Bethlehem Steel dust data 

8 indicate they are inadequate for use in dose 

9 reconstruction. I'm not sure how else I would 

10 characterize that. 

11 DR. MAURO: Well, yeah, you're right, and I guess 

12 where we're coming down is that there may be a 

13 better way to say that. Perhaps there's a better 

14 way to say that is taking everything into 

15 consideration. And there are a number of items 

16 that we've been talking about. We came down, and 

17 it wasn't an easy decision to make, we came down 

18 on the side that it seems like bounding -- There 

19 were concerns about making sure or trying to have 

20 a one-size-fits-all for all workers. There's a 

21 degree of confidence in that we don't 

22 underestimate the exposures in any worker. 

23 Everything considered where it comes down with 

24 Simonds Saw, Simonds Saw in the house so to 

25 speak. But I would not want to leave an 
33

1 impression that we felt, and in that, that we're 

2 trying to make sure that no individual is 

3 (inaudible) would underestimate. There's not a 

4 doubt that the levels of exposure were lower and 

5 certainly coming down. Now that we have new data 

6 it's clear that we actually see a trend, but that 

7 observation regarding the (unintelligible) of the 

8 data, one of our concerns, of course, was the 

9 issue of the cobble. 

10 That was another part of the equation. How do 

11 you deal with that issue? You don't know who 

12 might have experienced these transient exposures. 

13 How do you deal with that? And as an individual 

14 we find through a dose reconstruction we're not 

15 quite sure whether or not there's a data set 

16 which will (unintelligible) certainly is now 

17 approved. 

18 Whether or not we've got a degree of confidence 

19 that we've captured the individual that may have 

20 had some unusual exposure, because as you know, a 

21 lot of our discussion with the workers reveal 

22 that there were some practices that were made 

23 reference to only one of which, or perhaps the 

24 most important one of which in our eyes up until 

25 this point, was cobbling. 
34

1 Now, you make a very good point, and I think this 

2 is an important point of discussion is that it 

3 really is not plausible for that scenario in 

4 someone using an acetylene torch-type of 

5 apparatus for cutting the cobble. This is, at 

6 least the potential for this unusually high 

7 spike, of course, is that it diminished. So I 

8 want to say that. Quite frankly, we did not 

9 discuss that. In our lineup we took it basically 

10 on face value that well, we know this cobble had 

11 to be cut up. We have some information 

12 apparently that that might have been the way in 

13 which it was done. If it turns out that's not 

14 the way it was done, then certainly this needs to 

15 be revisited. 

16 And finally, the issue of resuspension. Now, you 

17 (unintelligible) that the three things that as 

18 you were going through the material I sort of 

19 jotted down. The, with reading your approach in 

20 doing the resuspension, you have your line, your 

21 status and your scenario. And the way I 

22 understood the scenario was it made use of a 

23 couple things, made use of dust blowing the 

24 reserve at Bethlehem Steel at a time when things 

25 were quiet. There was no activity going on and 
35

1 that characterization of the -- 

2 DR. ANIGSTEIN: Excuse me, John. You meant at 

3 Simonds there was -- 

4 DR. MAURO: I apologize. I meant at Simonds. 

5 No, that was our first. You know, I'm a little 

6 uncomfortable with using air sampling data 

7 between (unintelligible) so to speak, but where 

8 there's no physical activity. So that was a 

9 concern. And the other one I noticed in the 

10 write up that you would use as a way of sort of 

11 evaluating the resuspension issue or resuspension 

12 factor (inaudible) per meter. In a working 

13 environment like this where there might be the 

14 potential for kicking up dust as well as working, 

15 et cetera, et cetera, the potential item that 

16 sticks in my mind is a (unintelligible) factor of 

17 10 to a hundred (unintelligible). So those two 

18 areas left us with what I would say 

19 uncomfortable. 

20 So Bob Anigstein, came up with the strategy 

21 whereby, which I would be the first to admit is 

22 probably high on the other extreme. And you want 

23 to go with Simonds' general area. Now when you 

24 go with Simonds' breathing zone on this, and Bob, 

25 certainly you can elaborate on this, but we 
36

1 approached Bob and Dr. (inaudible). One 

2 (unintelligible) is that the general air samples 

3 collected at Simonds, if you assume that that 

4 dust load which is substantially higher than the 

5 breathing zone samples. 

6 Let's assume just to put an upper bound on it 

7 that -- 

8 DR. ANIGSTEIN: Excuse me, Doctor. 

9 DR. MAURO: Yes, go ahead. 

10 DR. ANIGSTEIN: The sample of air needs to be a 

11 factor of ten lower. 

12 DR. MAURO: It needs to be under study. 

13 DR. ANIGSTEIN: The general air samples are a 

14 factor of ten lower than the breathing general 

15 air samples. 

16 DR. MAURO: Yes, I'm sorry, of course. 

17 And so we went with that. Now in retrospect and 

18 in thinking about this, when we came up with our 

19 example approach, and Bob, you may want to come 

20 in on this. 

21 DR. ANIGSTEIN: Okay. 

22 DR. MAURO: We picked the 95 percentile value for 

23 general air samples at Simonds as our starting 

24 point, then of course, (unintelligible) down from 

25 there. I think in retrospect we probably should 
37

1 have worked with the average. And I'm sort of 

2 (unintelligible) some of the realizations that 

3 when you think about it, resuspension's a long4 term setting and the exposed people would 

5 experience -- would probably be more appropriate 

6 given every worker considerations that if you 

7 look for a way to bound the resuspension issue at 

8 Bethlehem Steel -- 

9 Perhaps a better way we should have done is go 

10 with the Simonds' general area samples, but not 

use the 95th 11 percentile as a starting point, but 

12 use the mean. That might have been no bounding, 

95th 13 percentile to my mind now that we're talking 

14 true and a little bit more could be considered to 

15 be pushing the upper bound to the point where 

16 it's over the top. 

17 This is my reaction to, I guess, some of the 

18 major points. Bob, I don't know what's your, do 

19 you have a sense of what I just described? Or 

20 are, you know, what do you think? 

21 DR. ANIGSTEIN: The reason, if you took history, 

the reason for doing the 95th 22 percentile was 

simply to be consistent with use of the 95th 23 

24 percentile of all the samples for worker 

25 exposures. So it seems to me like to be 
38

1 consistent, we should continue the 95 percentile 

2 approach that had been used. If you go with -- I 

3 don't have, however, I don't have a strong stance 

4 on either way. 

5 If you go with the average of the general air 

6 samples, you come down by a factor of six. So 

7 the whatever the dose from the resuspension would 

8 be a factor of six lower. The reason we're using 

9 the general air samples, Jim made the observation 

10 that these would not be all due to resuspension. 

11 Of course not, but we're looking in the absence 

12 of known data, of knowledge of what the 

13 resuspension really was at Bethlehem. It's not 

14 going to be any worse than the average, than the 

15 general air samples at Simonds. 

16 So we're looking for a limiting approach not for 

17 the best estimate. That's the basic rationale 

18 for it, and then the rest of it is pretty 

19 straightforward, just a, the dust again, it's a 

20 limiting approach to say that on the day of the 

21 roll, we don't know when the facility was 

22 cleaned, if ever. We don't know when all the 

23 steel dust was removed, so we're making the 

24 limiting assumption that just before the uranium 

25 rolling there was no dust. 
39

1 So that on the day of the uranium rolling, all 

2 the dust was uranium on, let's say they roll on a 

3 Sunday. On Monday, an equal amount of steel dust 

4 is mixed in over the period of the day. And on 

5 Tuesday, another equal amount, so you'd have one6 half, one-third, one-fourth, and so forth on 

7 succeeding days, of uranium. And that the 

8 airborne concentration of all dust is equal to 

9 the general air sample due to resuspension, equal 

10 to the general air sample at Simonds during the 

11 rolling only the uranium (unintelligible) goes 

12 down day by day. That's the model. 

13 MR. GRIFFON: Can I -- this is Mark Griffon. I 

14 just wanted to, after that response I'm curious 

15 that Bob just said that using the average versus 

the 95th 16 brings the dose down by a factor of six. 

17 How does that compare with what was originally 

18 presented in the TBD? I'm trying to resolve 

19 these numbers in my head here. 

20 DR. NETON: That's a good question. Dave Allen 

21 might have -- he's trying to find out right now. 

22 MR. GRIFFON: The other thing let me just say for 

23 a second, I mean, I think that this might be an 

24 oversimplification, but I think that we got more 

25 common ground than initially we might have 
40

1 thought. I think the first bullet, I think, 

2 deserves more lengthy discussion here. But the 

3 other things, I think, like the ingestion 

4 question, the resuspension question, I think 

5 we're getting, at least, you know, even when I 

6 hear numbers that are a factor of three apart for 

7 the ingestion, that to me is, well, you know, 

8 that's not too bad, you know. 

9 So I think maybe we could spend a little more 

10 time on that first one. I have some questions in 

11 my mind about the one point that was raised that 

12 the breathing zone samples being less than the 

13 general area samples at Bethlehem as compared to 

14 the Simonds. It seemed like a flip-flop. I 

15 wondered if you had a response to that. 

16 DR. NETON: We have some opinions on that, too. 

17 Do you want to move on then and let -- Dave, have 

18 you found the values for resuspension? 

19 MR. ALLEN: Well, it's a ballpark. The number we 

20 used -- 

21 DR. NETON: Microphone, Dave. 

22 MR. ALLEN: I'm sorry. Dave Allen, and I think, 

23 I'm looking real quick. I'm trying to remember 

24 what we did and look at the TBDs, so I could be 

25 wrong here, but at one point in here we have for 
41

1 the month it would be equivalent to, what we have 

2 in here for the month it would be equivalent to 

3 inhaling 11.2 MAC in one day. So I'm just saying 

4 11.2 MAC days per month, whereas -- 

5 DR. MAURO: Divide that by (unintelligible). 

6 Right now our average comes to 1.9 in MACs per 

7 day. In other words, I'm going to the 

8 (unintelligible) units here. In other words, you 

9 only need to use off rolling days. Our 

10 resuspension approach, using the average 

11 assignment for the general air we come in with 

12 1.9 in MAC as the concentration in the air on the 

13 off rolling days. What does your number come to? 

14 Your number's in MAC days? 

15 MR. ALLEN: Right, my question was are you 

16 assigning them resuspension inhalations for 29 

17 days a month? 

18 DR. NETON: John, I think you've 12.77 MAC 

19 according to -- 

20 DR. MAURO: Yes, we've got that. That's using 

with the 95th 21 percentile. 

22 DR. NETON: Right. 

23 DR. MAURO: I just want to say quite frankly I 

24 think that was over the top. In retrospect I 

25 would sooner say the strategy that Bob has 
42

1 adopted is certainly a bounding strategy given 

2 that we lack, at least from this perspective, 

3 given that we're a little bit uncomfortable with 

4 the sensitive item of resuspension factors in the 

5 approach involving (inaudible). So we took the 

6 position that -- 

7 MR. GRIFFON: John, John, we're having trouble 

8 recording you here, so maybe if you -- 

9 DR. MAURO: I'm sorry. Is that a little better? 

10 Can you hear me okay now? 

11 MR. GRIFFON: That's better; that's much better. 

12 DR. MAURO: Okay, I'm up close to the speaker 

13 here. 

14 What I'm saying is, yes, you're right, Jim. In 

15 our report we came up with 12.77 MAC per workday 

16 for resuspension. I think that -- 

17 DR. ANIGSTEIN: We made no assumption about how 

18 many days a month a worker was working, but we 

19 don't know what the work schedule was except on 

20 uranium rolling days. That number should be 

21 applied to the days on which they worked. 

22 MR. GRIFFON: This is Bob Anigstein, right? 

23 DR. ANIGSTEIN: Right. 

24 MR. GRIFFON: Make sure you identify yourself, 

25 please. 
43

1 DR. ANIGSTEIN: Okay, sorry. 

2 DR. MAURO: And then to complete that, if you use 

3 the average for defining general air's data as a 

4 surrogate for an upper end of what might have 

5 been the dust loading for resuspension at 

6 Bethlehem Steel, you come up with a concentration 

7 of 1.982 MAC on those days. And I guess it would 

8 be useful to say now how does that compare to 

9 your value that you just described in terms of 

10 MAC days? Are you going to have to convert that 

11 into a concentration on a given working day? 

12 DR. ANIGSTEIN: If I can, I have a comment to 

13 that. So (unintelligible) MAC if you assume 22 

14 days a month, say 22 work days a month. 

15 DR. NETON: Forty-four MAC days. 

16 DR. ANIGSTEIN: So that would be about 40-odd MAC 

17 days as opposed to 21.7 MAC which is in your 

18 Section 3.53 of the TBD. So now we're using a 

19 factor of two. 

20 MR. ALLEN: I think it's -- just to correct you 

21 even though I don't want to here, it's -- this is 

22 Dave Allen again. I think it's 11.2. 

23 DR. ANIGSTEIN: No, I disagree. The exponential 

24 model with -- I was reading the second sentence 

25 of this section. The exponential model will 
44

1 ultimately produce an intake equivalent to a 

2 failing 21.7 MAC for one day. So the impact for 

3 one month, for the impact period, 30 days. Okay, 

4 I stand corrected. So then we'll multiply it by 

5 a factor of four. Assuming 22 days, I don't how 

6 many days you assumed. 

7 MR. GRIFFON: So we're talking 40 MAC days versus 

8 11.2 MAC days. 

9 DR. NETON: I'm certainly much more comfortable 

10 getting down into the lower MAC range. I mean, 

11 to me 13 MAC exceeded most of the air samples 

12 that were collected at Bethlehem Steel in 1951 

13 and '52 during rolling operations. So to assign 

14 that for those two years just seemed to me to be 

15 an implausibly high value which just made no 

16 sense to us at all. 

17 And I think, you know, I don't intend, I don't 

18 think it's the intent that we're going to work 

19 all these details out at this working group 

20 meeting, but I think it's good that we -- 

21 MR. GRIFFON: No, no, but I think this brings us 

22 a lot closer, this discussion here, I think, 

23 brings us a lot closer. 

24 DR. MAURO: I think, Jim, I think we're getting 

25 closer at this point. I think we're on an 
45

1 agreement (inaudible). I think you can see where 

2 we concur. (unintelligible) Now certainly there 

3 may still be some point of discussion on this, 

4 the differences, but I think we're coming into an 

5 area where the differences are not large. I 

6 agree with Mark that I think really the place 

7 where our time is best spent perhaps today given 

8 our agenda is perhaps to address that first 

9 issue. 

10 MR. GRIFFON: Right, and I think maybe we should 

11 delve into that right now. 

12 DR. NETON: Now first I forgot to apologize for 

13 sending those data a couple days ago, but in the 

14 spirit of going with exactly the truth of what we 

15 have, you know, we did make the decision to send 

16 those data points out to clarify the remaining 

17 samples. And I do have the originals with me. 

18 SC&A is free to look at them throughout the day 

19 and verify that we, indeed, have interpreted the 

20 values properly. 

21 They're much more easily readable, although I'll 

22 admit even in some cases on these copies, they're 

23 faint. These are those blue onion-skin-type 

24 pieces of paper. It's no surprise that the scans 

25 were not good quality. 
46

1 MR. GRIFFON: Jim, can I ask you before we get 

2 into this specific, your first bullet. Ed, I 

3 think Ed had some comments so we'll let Ed Walker 

4 say a few words. 

5 MR. WALKER: I just wanted to touch on some of 

6 these points that you had before we get far 

7 beyond them in my view as a worker. 

8 Unfortunately, I was there, and some of the 

9 things that I hear, and I've been hearing, and 

10 some of my issues in far more in what I'm going 

11 to be talking about today. I would just like to 

12 address these issues that kind of you are talking 

13 to in my opinion. 

14 Now the first is the breathing zone issue. 

15 Obviously, I'm not a scientist, and I'm not a 

16 health physicist, but I can only tell you from 

17 experience and what I felt and what I saw down at 

18 Bethlehem Steel. And going over the breathing 

19 zone samples, what struck me the most was is the 

20 location where the ten breathing zone samples, if 

21 it so be that we rolled uranium for four years, 

22 and there was only four breathing zone samples 

23 taken, and they were all taken at the shear, now 

24 how these samples can be accurate when I believe 

25 some of your findings, there may have been one or 
47

1 two that wasn't, but what I found most of them 

2 were taken, the information that I got was taken 

3 by shear. 

4 And in your findings you say that the highest 

5 concentration was at the rolling as it went 

6 through the rollers. Well, the shearer was 

7 something like 400, probably around 400 feet away 

8 from where the rollers were at Bethlehem Steel 

9 because between the rollers and between the 

10 shears was the cooling bed which we know for a 

11 fact was over 300 feet long. At the end of this 

12 cooling bed stood a control panel of metal, sheet 

13 metal, where the fella that controlled all these 

14 rods, and you probably seen the illustration that 

15 I made. He sat there and he ran those rods 

16 through getting ready to shear. 

17 As they cooled he moved them ahead and moved 

18 them. They were constantly moving on this 

19 rolling bed. So when he got them through, they 

20 were, to start off that they were cool. They 

21 weren't 1100 degrees no more. And he was from 

22 where the worst points of contamination according 

23 to you people was, was up by the rollers when it 

24 went through the roller. That's where you'd get 

25 the most radiation. And that's documented. 
48

1 I can come up with these documents, not 

2 instantly, but I've read them all, and I've gone 

3 through it. So my question is if you're taking 

4 air samples, and you aren't even close to the 

5 areas where the worst contamination was, which 

6 would include the cooling bed and the salt bath 

7 and the rollers, the three operations that should 

8 have had the highest concentration were, they 

9 were taken protected. 

10 DR. GLOVER: Mr. Walker, I don't know what data 

11 you may have -- is this on? I'm sorry, my name's 

12 Sam Glover. For the shears we had nine breathing 

13 zone samples taken as part of the shears. 

14 MR. WALKER: Okay, that's about what I came up 

15 with. 

16 DR. GLOVER: And so that's, but there are salt 

17 bath data. There is -- 

18 MR. WALKER: Breathing zone samples? 

19 DR. GLOVER: Yes, sir. 

20 MR. WALKER: I had requested the information, and 

21 what I got, and it came from Oak Ridge. I didn't 

22 see that there so that's what I'm basing my stuff 

23 on, just what I can tell you from what I saw. 

24 DR. NETON: We did send you yesterday the, or day 

25 before yesterday. We tried to send the completed 
49

analysis sheet for the April 26th and 27th 1 

2 rolling. I don't know if you received it. We 

3 sent it to the e-mail address that we've been 

4 communicating. 

5 MR. WALKER: No, I didn't, but -- 

6 DR. GLOVER: I apologize. 

7 MR. WALKER: -- it's kind of short notice. I've 

8 been at this thing for three years, and a day or 

9 two before the meeting doesn't hack it for me 

10 because I struggle going through all these things 

11 so, I don't work at it every day and, you know, I 

12 need a little bit of time to look into this. 

13 MR. GRIFFON: Just one second, Ed. Can I ask 

14 Sam, how many in those other areas, breathing 

15 zones and the salt bath area are in the -- 

16 DR. GLOVER: There are, we have, just flipping 

17 through the data, I have actually put it into 

18 another sheet, but I don't have it with me. 

19 There are two. On the very first day there's two 

20 where they transfer from the lead bath to stand 

21 number one. Actually, there's four of that. 

22 You'll notice in this, and I think part of the 

23 difference at Bethlehem Steel versus Simonds, I 

24 haven't been there, but the size of it and the 

25 accessibility of the rolls, it doesn't lend 
50

1 itself to standing up near it and getting 

2 intimately in contact with this. And you could, 

3 and as far as there is definitely a difference -- 

4 MR. WALKER: Let me tell you, okay? 

5 DR. GLOVER: Let me just -- 

6 MR. WALKER: Standing right next to it, okay? 

7 Let me tell you. These guys, and it's documented 

8 in the reports of government people that went 

9 through, it is documented that people stood there 

10 and held hand-held thermometers to see between 

11 the rollers. And if you look at the pictures 

12 that I sent, and there's four inches of dust on 

13 the floor between these rollers, and there's a 

14 couple little holes. You can see it in the 

15 picture which I found after three years of 

16 research. And those three little holes are a 

17 foot square. You would be standing in dust, and 

18 they had to be fed in to the first roller with 

19 sledge hammers. 

20 In most cases the first rod that went in had to 

21 be fed manually hitting the rods with sledge 

22 hammers on the first one. Maybe Simonds carried 

23 them around in a circle, but at Bethlehem Steel 

24 they put them in with a sledge, and in between 

25 the rollers, they had to station men with 
51

1 crowbars to open up the wedges to receive these 

2 rods. 

3 Now I'm going to very briefly, and I don't want 

4 to take up too much of your time to tell you. 

5 There were six stands, and the reason they went 

6 to Bethlehem Steel, it's called a continuous 

7 mill, because there was no other continuous mill. 

8 A continuous mill, they had the ability by 

9 running through six stands continually, they 

10 could take it from a billet down to a rod. 

11 And when we talk of just finish rolling at 

12 Bethlehem Steel, the information that I have in 

13 the reports that Simonds Saw got billets from 

14 Mallinckrodt and so did Bethlehem Steel. Simonds 

15 Saw didn't rough roll them only and send them to 

16 Bethlehem Steel. Bethlehem Steel took the same 

17 ones, as far as the information that I have, and 

18 they rolled them down in a continuous operation. 

19 They didn't have to carry them around which they 

20 did at Simonds. 

21 It went through, there was two mills. One was 

22 roughing, one was finishing at Simonds. They run 

23 it through the roughing mill once. They run it 

24 through and put it through the same mill the 

25 second time. There was two roughing rollings. 
52

1 They took them over. They, I believe, they 

2 straightened them as much as they could. They 

3 brought them back, and then they went through the 

4 finishing process to get that billet down to a 

5 finished rod which they done. Bethlehem Steel, 

6 you put the rod in at one end, and it comes out 

7 as a finished rod. 

8 So I'll probably get into that later, and I don't 

9 want to get too far into this. There's another 

10 issue about that that I'll be getting into. 

11 As far as the cobbles, there were no cobbles at 

12 Simonds Saw. You can count on that because they 

13 didn't have a continuous mill. And a cobble 

14 simply means when this rod is going through the 

15 roller, if it doesn't hit that next roller going 

16 approximately -- it varied. There's different 

17 speeds, a hundred feet per minute, two hundred 

18 feet, three hundred feet. When it hit that next 

19 stand, it shot up in the air. It shot on the 

20 floor. It went down those holes in the drain. 

21 No one knew where it went. All the information 

22 that I heard that they cut them out. I can't 

23 swear to it because I never actually personally 

24 cut one out. 

25 But I want to tell you they wrapped around 
53

1 sometimes like a vine, and it would take them -- 

2 there's one document that says it took seven 

3 hours to clear that stand. You talk about a ten4 hour work period. It took seven hours before 

5 they could get the plant started again so they 

6 done the rolling apparently on Sunday. So where 

7 is the ten hours? That's 20 hours right there, 

8 and that's just one instance that we know. 

9 As I go through the documentation and find the 

10 cobbles that happened on almost every rolling, 

11 and another problem with that cobble is if that 

12 uranium rod wasn't heated to the exact 

13 temperature when it hit that roller, and if there 

14 was a cold spot in that rod, that cold spot would 

15 stop it from going in that roller because it was 

16 harder, obviously, not soft enough to take. And 

17 that would cause a cobble and shut down the 

18 plant. 

19 When they had a cobble, they had to shut the 

20 whole line down, but that didn't mean that there 

21 wasn't uranium laying on the cooling bed. That 

22 doesn't mean they weren't shearing it, the stuff 

23 that was being cooled. So that was continuous. 

24 So I wanted to touch on that on the cobbles. 

25 There's no way that this information that I'm 
54

1 hearing is what happened at Bethlehem Steel. And 

2 as far as Simonds Saw being smaller, it's much 

3 easier to clean out this room than it is this 

4 whole hotel. As far as the resuspension on it, 

5 I've talked to site workers. I've talked to 

6 probably 50 to 75 people that actually worked 

7 there. Some were credible; some of them weren't. 

8 And I took what I felt and from what they told 

9 me. When they were telling me what went on, I 

10 could pretty much tell if they were there when 

11 the uranium was being rolled. It was very 

12 obvious you could tell because if they weren't 

13 there when uranium was being rolled, their 

14 information was different. 

15 And the resuspension, there was doors in the side 

16 of this place that would open, and they would 

17 periodically they would open them. And they were 

18 big doors that were almost the whole side of that 

19 building. So you talk about resuspension. If 

20 that uranium dust went up there on the weekend 

21 and laid up there, and that door was opened on a 

22 Monday where they were rolling regular steel, 

23 there probably wouldn't be any more steel going 

24 up there, any more dust going up from the steel. 

25 So you're not mixing up one-and-a-half, and it 
55

1 didn't mix itself like a woman makes a cake. 

2 This stuff, as it fell down, it hit the heat and 

3 it blew it back up again. If you were setting 

4 there, and there was three inches of dust from 

5 the uranium rolling on that weekend being blown 

6 up there, and a crane went across, where do we 

7 get the steel in that uranium. That would fall 

8 right down on the workers. It would hit the 

9 heat. It would go back up. 

10 Sure, it may mix with some, but this computing 

11 just how much it would mix every day is 

12 ridiculous. Some of that stuff could stay up 

13 there a week and never be knocked down, nothing 

14 on top of it. The uranium was laying there until 

15 something happened to make it come down. 

16 In that photograph, that picture that I drew, I 

17 took to a fella that worked, that worked on top 

18 of that catwalk on the mill. And he said that 

19 that thing was right on. That picture was right 

20 on. He says except there's so much stuff that 

21 you left out of that picture that would 

22 contribute to colling (ph.) uranium during the 

23 rest of the week. And that is all electric 

24 lines. He says you ain't even close in that 

25 picture. And I says I know it, but if I showed 
56

1 all that, I couldn't show this basement area and 

2 just what it was like. 

3 I had to leave that stuff out, the gears and 

4 stuff it took to run that rolling process, all 

5 that was underneath, even the rollers. There was 

6 motors as big as cars underneath there where that 

7 uranium could go down in and get into those 

8 motors. And you're not cleaning it out on the 

9 weekend. And if those electricians and that went 

10 and worked the rest of the week, they were 

11 involved in that uranium so it wasn't a ten-hour 

12 shift. 

13 Honestly, not everybody delved in it. There was 

14 only certain people, but I can't tell you which 

15 ones were there. A lot of these claimants call 

16 me. They all worked at (unintelligible), and 

17 they heard that's what was being done. So that's 

18 as far as the resuspension. 

19 The ingestion I'm not going to say too much 

20 about, but I ate my sandwiches, and I would like 

21 to take a cup of anything you have here, being 

22 that I was there. And I'm not lying about this. 

23 I'd like to take a cup and just put any kind of 

24 dust in it and ask you to drink it. When you 

25 talk how much it was, and it didn't amount to 
57

1 much, I'm telling you at times there was almost 

2 an eighth of an inch of dust in the plant. If 

3 something went over it, when you take your cup 

4 like this, and you'd go like that to get it to 

5 flow off the top and you'd drink it. Was it 

6 uranium? I don't know. Was it steel? I don't 

7 know, but we were there when the uranium was 

8 there. 

9 And a sandwich is very similar. You'd take your 

10 sandwich -- and Dave, you know this from 

11 (inaudible) -- you'd take your sandwich and tip 

12 it over and it would fall off like pepper. So 

13 what about this ingestion? I think you really 

14 should talk to some of these people and set down. 

15 From day one nobody's come up and talked to these 

16 people until July of '04. And talk to some of 

17 these people that will swear, give you any kind 

18 of sworn statement you want on the conditions at 

19 Bethlehem Steel as far as the resuspension and 

20 this inhalation and stuff. 

21 I got one claimant that's got cancer quite bad, 

22 and when he retired, his wife told me, she says 

23 it took him two weeks before he could spit up 

24 without having black stuff in his throat, two 

25 weeks to clear his throat just when he coughed 
58

1 before he could spit up clear stuff. That's the 

2 kind of stuff we were dealing with, and that's 

3 the kind of stuff that I want you people to know 

4 in a clear conscience say that we weren't exposed 

5 to whatever was there. 

6 That's all I have to say on this. I think it 

7 covers the resuspension. If you have any 

8 questions, you know, I'll try and answer them. 

9 DR. NETON: I just have a quick question for Mr. 

10 Walker. 

11 You indicated you had information that suggested 

12 that billets were rolled like five-inch diameter 

13 billets at Bethlehem Steel? We'd be interested 

14 in seeing that. Are you saying that they were 

15 rolled in stands other than 13 through 18 at 

16 Bethlehem Steel? 

17 MR. WALKER: A six stand, and I questioned the 

18 rollers, the guys that actually run the rollers, 

19 and I says could you take down a billet from 

20 three to five inches and run it down to an inch21 and-a-half? And he says easily. And he says the 

22 reason they only needed six stands because that's 

23 all it would take to get that down. 

24 DR. NETON: All right, that's different than the 

25 information I have. I'd be very interested in 
59

1 seeing that because the finishing roll -- 

2 MR. WALKER: That'll give you sworn affidavits 

3 that they can do that with that. 

4 DR. NETON: Oh, I thought you had documentation 

5 from other areas. I mean, you have affidavits 

6 that said that they rolled five-inch diameter -- 

7 MR. WALKER: Well, I don't know if they were five 

8 inch, three to five. Now I don't know what they 

9 got. There were squares, and there were rounds 

10 from the information that I have. 

11 DR. NETON: I understand, but of all the 

12 documentation that we have from Bethlehem Steel, 

13 there is no evidence that I've seen that suggests 

14 that anything other than finished rolling was 

15 done. In fact, that was the contract with the 

16 government, but I'd be very interested to -- 

17 MR. WALKER: I can get that. I'll mark it down, 

18 and I'll get it to you, Jim. 

19 Any other questions? 

20 MR. GRIFFON: Not for now. Thanks, Ed. 

21 I think we need to speak to this 

22 representativeness of the data question and that 

23 gets in the number one so... 

24 DR. NETON: I think one of the conclusions that 

25 was, aside from the fact that the legibility 
60

1 issue was raised, I think the other fact that 

2 SC&A relied on was that the breathing zone air 

3 sample data were lower than the general area data 

4 which surprised them. And in fact, we looked at 

5 that analysis, and there was a Wilcox Rank Sum 

6 analysis done on that data which we understand. 

7 But what they've done in looking at the data, 

8 have done linear interpolations on lognormal data 

9 which, if you actually do a lognormal plot of 

10 this data and fit a curve to it, you end up with 

11 almost exactly the opposite conclusions. In 

12 fact, the mean value of the B-Z data are almost 

13 the same as the -- the geometric mean value of 

14 the B-Z data are almost the same as the geometric 

15 mean of the -- I'm sorry, Dave Allen is more 

16 familiar with this. 

17 MR. ALLEN: The, instead of linear interpolation 

18 if you do the lognormal type of distribution plot 

19 that we've done on everything else and that SC&A 

20 says would be appropriate for this data, the G21 A’s for that same time period, the geometric mean 

22 comes out to be about 13- and-a-half DPM per 

23 cubic meter which is about a tenth of what the 

24 average is. The average is very high on the G25 A’s because of one outlier. And that one outlier 
61

1 was also one of the two points used for the 

linear interpolation to get the high 95th 2 

3 percentile. 

4 So if you use all of that in a typical lognormal 

5 plot, you end up with a geometric mean of about 

13-and-a-half DPM per cubic meter and a 95th 6 

7 percentile of about, I've got 468 DPM per cubic 

8 meter for about 6.7 MAC. So between the G-A’s 

and the B-Z’s, the 95th 9 comes out to be fairly 

10 similar but the geometric mean is about, well, 

11 the general area is about a fifth that of the B12 Z’s. 

13 DR. ANIGSTEIN: This is Bob Anigstein. I'd like 

14 to speak to that. The only, actually, the data 

15 that we just got for the first day of rolling, 

April 26th, 27th 16 , 1951. The one time that you had 

17 comparable data was the October -- let me be sure 

it's right here. Sorry, the January 26th 18 , 1952 

19 rolling is the greater set of B-Z's data non-zero 

20 were significant numbers. There were nine values 

21 on that day, on those two days, oh, it was one 

22 day, with three data sheets. I believe it was 

23 one day. And then at the same time so we have, 

24 you had about 20 -- I'm flipping on my 

25 spreadsheet now, so bear with me for a second. 
62

1 We've had 12, we had 92 data points and 12 G-A 

2 data points so it was a comparable number. The 

3 arithmetic mean of the non-zero value or the B-Z 

4 is 116 DPM per cubic meter. The arithmetic mean 

5 for the G-A is 147, but the G-A is higher, but 

6 thus, you can't compare because for most days 

7 there were no B-Z, so you can't compare all the 

8 B-Zs to all the G-As. It's comparing apples and 

oranges. In the 95th 9 percentile done by the 

10 methodology, the non-parametric methodology, 

11 while simply taking the (unintelligible) and 

seeing where the 95th 12 is, not in some lognormal 

13 distribution for which there is really no valid 

14 basis. You end up with the one for that day is 

15 G-A ends up being 1055 DPM a cubic meter. And 

16 the B-Z ends up being 368. 

17 MR. ALLEN: Yeah, I realize. The numbers I 

18 quoted are from the exact same data you're 

19 talking about. I have nine B-Zs, and I have 12 

20 G-As from that one day. But taking the 

21 arithmetic, taking the just straight average 

22 means if you have one outlier, you blow that 

23 whole average out the door, and that's exactly 

24 what happened in this. So you're basing your 

25 entire argument here on one air sample instead of 
63

1 taking a distribution of all twelve. 

2 DR. MAKHIJANI: Are you talking about the same -- 

3 this is Arjun. Are you talking about the 1952 

4 data set or are you talking about -- 

5 DR. ANIGSTEIN: January of 1952. 

6 (Unintelligible). I'll give you that point. We 

7 still find that we had assignments where we had 

8 all the samples were indicated. They were either 

9 G-A or B-Z, and the B-Z (inaudible), which is the 

10 whole idea of taking the B-Z. So we took a 

11 question whether there was enough B-Z data and 

12 something similar. I did a quick look at the 

April 26th, 27th 13 , 1951, and a similar conclusion 

14 that might make a difference, but a similar 

15 conclusion. The G-A is higher than the B-Z. 

16 And we just question, that one big reason of 

17 questioning the Bethlehem data. And if the data, 

18 we don't question that the data was, the samples 

19 were taken correctly and properly analyzed by 

20 AEC. We did find a few data points, there were 

21 five data points which were miscalculated by AEC, 

22 but you know, that's five out of 199. Because 

23 the numbers they gave for the DPM and for the 

24 CPM, and the flow rate are not consistent with 

25 the DPM, again, that's a very minor point. We 
64

1 concede that these were good samples, but the 

2 question is they were samples of what, and are 

3 they really samples of the workers' exposure? 

4 DR. MAKHIJANI: I just want to return to the 

5 point I made during my presentation is I think 

6 the way this data, this is a complex set of data 

7 now, especially as the new points have been 

8 added. But almost the highest points in the 

9 early data set, in April 1951, are all general 

10 air samples. The highest, I think the highest 

11 four, are all general air samples. And they are 

12 much, much higher. 

13 So if you take a, without doing any statistical 

14 analysis, if you just take a look at the data, it 

15 seems very odd that none of the high, the highest 

16 data point in general air is 29,000 and odd DPM 

17 per cubic meter. And the highest breathing zone 

18 is like 2,000 or 5,000. It's many, many times 

19 off, and there are many, there are several data 

20 points in general air that are more than 10,000 

21 DPM per cubic meter. 

22 And that doesn't, I mean, it raises a question 

23 about how you use this data, and how you 

24 interpret it, specially as you got another set of 

25 data that was taken with the explicit purpose of 
65

1 estimating worker exposures and the time 

2 averaging was done and so on. And there you can 

3 see that the breathing zone samples are 

4 significantly higher. They're an order of 

5 magnitude higher than the general air, and that 

6 makes sense because if you're working, if you're 

7 taking a sample at the work location, you should 

8 expect a higher concentration unless you've got 

9 some resuspension problem. I don't want to go 

10 back there. I think -- 

11 MR. GRIFFON: Let NIOSH respond. 

12 DR. NETON: I think, and what I see they didn't 

13 really look at very closely was the difference in 

14 the processes that there were occurring there. 

15 If one looks at the, that the whole purported 

16 purpose, and we have is the documentation, of the 

17 Bethlehem Steel process, as Mr. Walker correctly 

18 indicated, was to use a rolling mill, a finishing 

19 mill, or a continuous rolling mill so that they 

20 could quickly process this without having to go 

21 around and keep refeeding it. And that's exactly 

22 correct. 

23 But one of the other main objectives of this 

24 process was to evaluate the health protection 

25 afforded by the use of salt baths, lead versus 
66

1 salt as a heating mechanism. There were also 

2 some production benefits for using a bath. You 

3 got a better, more uniform temperature and such, 

4 but it was also well established that the coating 

5 provided by either the lead or the salt clearly 

6 minimized or reduced the air concentrations in 

7 the plant. And that's exactly what's happened at 

8 Bethlehem Steel. 

9 So what you see in the early rollings, and I 

10 think the first -- Sam, correct me if I'm wrong, 

11 the first four rollings that we had data for? 

12 The first three rollings were a combination of 

13 lead and salt bath rollings. I mean, you can see 

14 in the documentation. These are lead bath; these 

15 are salt bath. And if you plot the lead versus 

16 the salt, this is what you get. Clearly, 

17 clearly, two different air concentration sets of 

18 data. 

19 Now what we've done is combine those into one set 

20 which ends up giving you more, gives you a higher 

21 value. It's going to be assigned across all the 

22 years, you know, rather than break them apart. 

23 We're certainly willing to discuss the merit of 

24 breaking these into two different sets because 

25 clearly, the salt bath, the lower curve there, 
67

1 the red triangles, is substantially lower. In 

2 fact, there's very low concentrations when the 

3 salt baths are being rolled. So you need to look 

4 at that. 

5 To give you a little better perspective on this, 

6 this is a graph -- 

7 MR. GRIFFON: Jim, Mark Griffon. You don't have 

8 an overlay with Simonds on that same graph, do 

9 you? 

10 DR. NETON: Yeah, I do as a matter of fact. 

11 MR. GRIFFON: I'm just curious how that -- 

12 DR. NETON: That's with the Simonds, so their -- 

13 MR. GRIFFON: And Simonds is no salt baths at 

14 all, no lead or salt baths, right? 

15 DR. NETON: That's correct. That's what I would 

16 call the roasted uranium technique, and the 

17 Simonds are the squares. 

18 Now those, and Eisenbud was correct. He said 

19 that the lead salt bath was similar to what they 

20 saw at Simonds with no ventilation, I mean, 

21 within the realm of reasonableness, these curves 

22 are way up here. The salt bath treatment clearly 

23 added a protective effect. Now what also 

24 happened here was that since these things were 

25 encrusted and not roasted uranium -- I'll use 
68

1 that term -- it appears to us at least at the 

2 stand, the distribution of the air concentrations 

3 by stand was somewhat different. 

4 You got, I think the highest concentration -- 

5 Sam, help me out here -- at Simonds was typically 

6 at stand one. I mean, there was only one stand, 

7 but the first pass through the furnace. Taking 

8 it out of the furnace was a 70,000, 1,000 MAC 

9 sample. But when you put that through the first 

10 pass, you had this no protective coating so the 

11 concentrations were fairly high on that first 

12 pass through. At Bethlehem -- I think I have 

13 some data by stand. These are just the data, 

14 there's the data by stand, and actually, that -- 

15 DR. GLOVER: Then show it by date, by salt versus 

16 lead. 

17 DR. NETON: This is the one that shows by salt 

18 versus lead. You can see that that sort of shows 

19 you what we saw in the other graph, that the lead 

20 bath is higher than the salt bath. 

21 MR. GRIFFON: These are breathing zone samples or 

22 all samples? 

23 DR. NETON: These are all samples. 

24 The other thing is I don't know, I think we seem 

25 to be going down a path that the only usable data 
69

1 we're ever going to be able to come to a 

2 conclusion on is breathing zone air sample data. 

3 And I'm not convinced that that's necessarily the 

4 case here. I mean, we need to go back and look 

5 at what the G-A samples were trying to do. 

6 These were not what you would call G-A samples 

7 where you went and sampled the cafeteria or some 

8 non-working environment. These were actually 

9 positioned at the rollers themselves. Now, they 

10 weren't a B-Z taken over a guy's shoulder like 

11 they did in those days, but they had samples, you 

12 know, during vertical rolls, horizontal rolls and 

13 that sort of thing. I'm certain we don't have 

14 exactly where they were, but they were in the 

15 vicinity of those rollings, not far away, and if 

16 the same positioning occurred at Simonds, they're 

17 very close. 

18 MR. GRIFFON: Do you have any indication of what 

19 the difference would be between general area 

20 versus some that are labeled production samples 

21 or processing samples? 

22 DR. NETON: The process sample was -- 

23 MR. GRIFFON: My impression was those were the 

24 ones right in the process of interest or 

25 whatever. 
70

1 DR. NETON: Right, in fact, we have process 

2 samples which was included in our distributions 

3 although my recollection of the process samples 

4 were not all that much higher than the general 

5 areas samples. There's actually a similar 

6 spread, the process and general area. So the 

7 process samples were taken in areas where it was 

8 not normally considered that a worker would be 

9 positioned. 

10 MR. GRIFFON: Yeah. 

11 DR. NETON: Yeah, so they were not in the way. 

12 But I think these G-A samples were positioned at 

13 the stands, and if you look at the G-A samples 

14 that were taken at Simonds, I mean, there are 

15 some better descriptions of the positioning in 

16 relation to the stands. And these were not, you 

17 know, far removed from those stands. 

18 MR. GRIFFON: I guess I'm not hearing that, you 

19 know, you can't use the general area air samples. 

20 What I'm hearing is it seems like there's a 

21 peculiarity between Bethlehem versus Simonds 

22 where at Bethlehem you had the B-Zs running lower 

23 avoiding all the lognormal versus linear. 

24 DR NETON: Right, right. 

25 MR. GRIFFON: The geometric mean versus average, 
71

1 I mean, they tended to be lower as opposed to 

2 Simonds which the ratio flipped, and it seems a 

3 little peculiar especially if you're saying, 

4 you're saying that that early coating, I mean, 

5 you might even want to look at stand-by-stand 

6 ratios if you're saying the coating was 

7 protective on the first cycle through. 

8 MR. ALLEN: That's the point, Mark, is the idea 

9 that the B-Zs were lower than the G-As was 

10 represented that way in the SC&A review, but that 

11 same data set it's just not true. It's only an 

12 artifact if you take an average because of one 

13 outlier that's high. If you actually take a 

14 geometric mean of all data points, the G-As are 

15 about a factor of five lower than the B-Zs. 

16 MR. GRIFFON: And is that consistent with Simonds 

17 then? What was the -- it's in the ballpark? 

18 DR. MAKHIJANI: It would be for the -- I didn't 

19 do the original analysis. I haven't looked at 

20 the data, but just taking Dave at his word and 

21 that is the case, that would apply to January 

26th, 27th 22 . I think if you look at the April 1951 

23 data, you would have a very clear issue where the 

24 general air samples are much bigger. 

25 And Mark, I agree with you. You know, we're not 
72

1 saying that you can't use the general air samples 

2 because obviously in the Simonds distribution 

3 you've got both a breathing zone and general air 

4 samples that are part of the distribution. And 

5 because if you only use the breathing zone 

6 sample, you wind up in a different place. 

7 So it's not a, it's a question of, it would be 

8 really useful to have some description of what 

9 was the purpose of this whole program comparable 

10 to what we have very clearly for Simonds because 

11 I find it quite hard to interpret the data in 

12 retrospect given the complexities and how long 

13 ago it is and the questions that we have. 

14 MR. GRIFFON: Go ahead, Sam. 

15 DR. GLOVER: Real briefly, I did want to make the 

16 point that in the text of the revisions, I did 

17 try to show what the stands, how the samples 

18 compared so we took the MAC that we were 

19 assigning, that the tower and show at the stand, 

20 this is what it was at Simonds Saw so that you 

21 actually could see how they compared and also 

22 Bethlehem Steel so you could actually look at 

23 that evaluation. And so I wasn't trying to hide 

24 that or to, you know, really try to bring that 

25 out, that this is the worst location and this is 
73

1 how that data compares. 

2 DR. NETON: I think one thing to remember is 

3 these samples were taken by the same program that 

4 took the samples at Simonds Saw and Steel for 

5 them, too, and several years later. And so 

6 presumably their thoughts and methodology 

7 developed to even be better not to be worse, and 

8 you know, we don't have a -- 

9 MR. GRIFFON: We don't have a written methodology 

10 for that, right? 

11 DR. NETON: Well, we have some later 

12 documentation put together by Al Breslin that 

13 indicated the purpose of a G-A, a P, and a 

14 breathing zone air sample and that sort of thing, 

15 and you know, we don't have -- there was 

16 certainly not a time-motion study done here like 

17 there was at Simonds. I think that's what Arjun 

18 is referring to. It certainly would be better, 

19 but to sort of assume that they covered the least 

20 exposed locations with these air samples just 

21 does not seem to me to be a reasonable 

22 conclusion. 

23 DR. MAKHIJANI: There's no implication about that 

24 they did a good job or bad job. In fact, we've 

25 agreed that the people who were doing the 
74

1 sampling and the lab work seemed fine and the 

2 designations seem okay. It's just that if you go 

3 to Simonds and the purpose of the sampling is to 

4 estimate time-rated exposures, and you've got a 

5 track record that they did that, then you can be 

6 confident that what you calculate from that has 

7 some relationship to exposures. 

8 When you've got a set of data where you don't 

9 know -- if the purpose of the expedition to 

10 Bethlehem Steel was simply to examine the 

11 difference between the processes and not to 

12 attend to the exposures of the workers and that's 

13 why a time-motion study wasn't done, then it 

14 becomes harder to think how you might apply these 

15 data to worker exposures. 

16 It's not that the data are bad. It's a question 

17 of having the documentation to interpret it, 

18 specially as we've got these anomalies. And I've 

19 an open mind about it, I want to assure you. 

20 It's just that I don't know how we're going to 

21 interpret this data. Maybe it's worthy of 

22 further study, or I don't exactly know how where 

23 we go from here. 

24 DR. NETON: Right, and I think maybe in light of 

25 these new data points that are there and SC&A is 
75

1 still, you know, has not had a chance to look at 

2 them, and there may be some different conclusions 

3 drawn. I don't know. I don't want to speculate, 

4 but until that happens, I guess, we -- my main 

5 and our main objection to the conclusion was that 

6 you have to go directly from there to 550 MAC 

7 air. And that's really where we have our biggest 

8 source of anxiety is that is it reasonable then 

9 to say that that is the only bounding value one 

10 can use in light of the data. 

11 Now we have more points. I understand that, and 

12 as I mentioned earlier that one has to provide 

13 some mechanism that can sustain the generation of 

14 that type of airborne activity given that these 

15 billets were rolled in three-to-five or whatever 

16 minutes per shot, and we know how many billets 

17 were rolled per rolling. That doesn't give you a 

18 mechanism to generate 30 milligram per cubic 

19 meter air for ten, twenty hours. 

20 MR. GRIFFON: I got the impression, maybe not so 

21 much in the documentation but from Arjun's brief 

22 presentation this morning, that that thought 

23 experiment with the 30 milligrams per cubic meter 

sort of supported the 95th 24 , not that it was a 

25 sustainable amount but that it sort of supported 
76

1 your -- 

2 DR. NETON: No, I think what that does is support 

the fact that at the 95th 3 -- it couldn't be 

4 higher than that, let's put it that way. Was it 

5 that high? I don't think it was that high at 

6 Simonds even on a kind of sustainable basis. 

We're saying the 95th 7 is what is was, and we've 

8 agreed to use that. But then to say that at 

9 Bethlehem Steel where we have a couple hundred 

10 samples, it's also reasonable to conclude that 30 

11 milligrams per cubic meter was there doesn't seem 

12 reasonable to us given that these were bath, you 

13 know, the report itself lists all of our reasons 

14 why we believe that these values are lower. And 

15 SC&A actually agrees that there is a substantial 

16 case to be made that these values were lower. 

17 DR. MAKHIJANI: I think, you know, that there is 

18 agreement on many of the points and that we 

19 actually explicitly said in quoting the draft 

20 revision of the site profile that in most 

21 respects it does appear that Simonds Saw was more 

22 dusty than Bethlehem Steel from the data and the 

23 evidence and the nature of the processes. We did 

24 raise a couple of points where the contrary 

25 conclusion, you know, that point in the opposite 
77

1 conclusion. 

2 But you know, we did not ignore Bethlehem Steel 

3 data or thought that they were useless. In fact, 

4 we explicitly said that one, we arrived at a -- 

5 maybe we ought to start at a point of agreement 

6 that we arrived at a conclusion that for two sets 

7 of workers that this number of 553 was very 

8 claimant favorable. And one of the factors that 

9 we used in arriving at the conclusion was that 

10 553 is really higher than every measured sample 

11 even including the new data points which we 

12 didn't have at that time at Bethlehem Steel. 

13 So it's not a question of having ignored the data 

14 or not looked at it. It's a question of when 

15 you, how we have read the regulation is -- and 

16 this is a point of debate obviously -- is that 

17 when you've said you're going to resolve every 

18 uncertainty to the benefit of the claimants, how 

19 do you interpret that in a situation like this 

20 where you're using a surrogate facility? And 

21 obviously, you know, there's room for 

22 interpretation, and we should look at that. 

23 MR. GRIFFON: I'm not sure the regulation says 

24 exactly that, but I'll let Jim respond to that. 

25 Ed, I know you have a comment. 
78

1 DR. MAKHIJANI: I have the quotation here from 

2 the regulation here. 

3 DR. NETON: I think it speaks to the fact if we 

4 have too uncertainty, we will give the benefit of 

5 the doubt to the claimant. But we believe that 

the uncertainty using the 95th 6 percentile and all 

7 the other claimant-favorable assumptions that 

8 have been built into these models, which is a 

9 sustained continuous air concentration at the 

95th 10 percentile, accomplishes that. I mean, I 

11 don't think there's any requirement for us to 

12 pick the highest air concentration that was ever 

13 observed in a uranium processing facility in 

14 light of the fact that we have 200 data points 

15 which is what the report says. 

16 MR. GRIFFON: Let me, something that was on my 

17 mind on this thing from the beginning is just 

18 what you alluded to, Jim, up here, is that it 

19 seems to me that when they went to the salt baths 

20 there was quite a drop off. And yet, you chose 

21 to, I think you chose to roll all the Bethlehem 

22 Steel data into one, lumping the lead bath and 

23 the salt bath data together. 

24 What was the rationale there? Is there enough 

25 data to separate that out? It seems from an 
79

1 exposure standpoint it might make sense that 

2 those people in the '52 rollings, maybe they were 

3 all the same people anyway, but they would have 

4 probably got much lower exposures than the 

5 earlier rollings. 

6 DR. NETON: Right. I guess the issue is how 

7 closely do you parse the data and when you have a 

8 couple hundred samples that seems to be fairly 

9 good when you start parsing that. We really 

10 didn't make that conscious decision to say we're 

11 going to parse it out at that point. I think we 

12 tried to use as much data as possible recognizing 

13 that the lead bath technology is higher. But 

14 when you roll that up into the whole 

distribution, you end up with a higher 95th 15 

16 percentile than if you segregated it. It's sort 

17 of six of one, half dozen of the other. There is 

18 some merit, I think, in going back and looking at 

19 that, and we'd be interested to explore that. 

20 Certainly, the people in '52 would receive higher 

21 --. 

22 MR. GRIFFON: Especially now that you have some 

23 of those illegible points. 

24 DR. NETON: I'm not sure it would actually, in a 

25 cumulative sense it would not probably make that 
80

1 much difference. 

2 MR. ALLEN: I think it might go down just a 

3 little. 

4 DR. NETON: It might go down a little. I don't 

5 know. 

6 MR. ALLEN: You've got a longer time frame that 

7 they did the salt. 

8 DR. NETON: But then to get into the issue of 

9 what's fair to a worker who maybe worked there in 

10 '52 versus '53, you know, then you have to look 

11 at that. 

12 DR. MAURO: Jim, this is John Mauro. Can you 

13 guys hear me okay? 

14 DR. NETON: Yeah. 

15 DR. MAURO: Hello. Jim? 

16 MR. GRIFFON: Go ahead, John. 

17 DR. MAURO: I'm sorry. I wasn't sure you heard 

18 me. I'd like to also, part of this, one of the 

19 reasons we came down where we came down is also a 

20 lot of feedback about it appears that there were 

21 a lot of activities, practices, scenarios going 

22 on at Bethlehem Steel as described by Mr. Walker 

23 that leaves us with a sense that perhaps the 

24 samples we were taking or that were taken did not 

25 capture some of those activities, perhaps many of 
81

1 those activities. 

2 And that also had a bearing on where we came 

3 down. And that's why the 550 or the 33 milligram 

4 on the back of the 30 milligram number gave us a 

5 degree of comfort. That is, if there were such 

6 practices, and if they were widespread, and if 

7 there was uncertainty as to who participated in 

8 those practices, we felt that we came down in a 

9 place where those people were covered. So that 

10 plays also. 

11 And I, quite frankly, I'd like to hear a little 

12 bit more about the degree to which there may have 

13 been practices that could have generated 

14 substantially elevated levels of dust that we 

15 really did not capture in the scenarios and in 

16 the data that we've embraced as our model for 

17 these facilities. 

18 DR. NETON: Right, I hear what you're saying, 

19 John, and I -- oh, Mark has something to say. 

20 MR. GRIFFON: Go ahead, Jim, respond to this. I 

21 just had a little birdie in my ear. They're 

22 asking for a break. 

23 DR. NETON: We're aware that there were other 

24 activities, but in our minds the rolling of the 

25 uranium seems to have generated the highest 
82

1 concentrations, you know, in both Simonds and 

2 Bethlehem Steel. We've taken a look at the 

3 centerless grinding activities which was, by the 

4 way, a water, a wet operation. We did not 

5 believe that that produced concentrations higher 

6 than what we're looking at here. So any of the 

7 other activities that have been mentioned, it's 

8 just hard for us to envision that they go higher 

9 than the values that we've seen at some of these 

10 stations where rollings were conducted. But we'd 

11 certainly be interested in entertaining, you 

12 know. It's one thing to say it happened. It's 

13 another thing to say is it really higher than 

14 what we're assigning here. And right now I don't 

15 think we believe that. 

16 MR. GRIFFON: Let's, if it's okay with everybody, 

17 let's take a comfort break. Take like ten 

18 minutes, and I think maybe we can try to schedule 

19 lunch around 12:30. I mean, this will just be a 

20 quick break, comfort break, for our reporter and 

21 myself, and then, you know, we'll think about 

22 lunchtime being at 12:30 if that’s okay. Thanks. 

23 (Thereupon, a break was 

24 taken from 11:45 a.m. to 

25 12:05 p.m. after which 
83

1 the following 

2 transpired:) 

3 MR. GRIFFON: John Mauro, are you on the phone? 

4 DR. MAURO: Yes, I am. 

5 MR. GRIFFON: John, we're having a hard time, 

6 Ray's having a hard time hearing you for the 

7 transcript, and I don't know if you can maybe go 

8 on a hard line instead of the speaker phone. 

9 DR. MAURO: Is that better? It was on the squawk 

10 box. Can you hear me any better now? 

11 MR. GRIFFON: That seems to be much better, yeah. 

12 DR. MAURO: I was on the squawk box, you know, 

13 it's a little easier, but I certainly will talk 

14 directly into the, you know -- 

15 MR. GRIFFON: That will be helpful, appreciate 

16 that. 

17 Just trying to reconvene, and I think we should 

18 probably close out on the Bethlehem Steel 

19 discussion pretty soon. I think the one item, at 

20 least my sense is that the one item that is most 

21 outstanding or most difference here between SC&A 

22 and NIOSH is the first bullet item of Jim Neton's 

23 presentation which speaks to the air sampling of 

24 Simonds Saw versus Bethlehem Steel, the 

25 representativeness of it and several other 
84

1 issues. 

2 My thought is that since some of that illegible 

3 data was only recently collected and put into a 

4 spreadsheet format, SC&A has not been able to do 

5 any assessment on that. I think we probably need 

6 to defer that issue to, and I'm suggesting maybe 

7 to, hopefully finalize this at the next 

8 subcommittee meeting which will be the meeting in 

9 Oak Ridge or Knoxville, I guess, really, the next 

10 full board meeting or the subcommittee before the 

11 full board meeting later this month, yeah, 

October 17th 12 , yeah. 

13 So in the meantime though several items have been 

14 brought up, at least from what I've heard. It 

15 seems like we've come to maybe better agreement 

16 on certain items. And to the extent that some of 

17 these things were offered during the discussion, 

18 I think that SC&A and NIOSH should both come 

19 prepared to show those differences. The one 

20 example that comes to mind is the resuspension 

21 calculations. If you're going to modify anything 

22 from your existing report, SC&A, you should 

23 probably come with that to the next subcommittee 

24 meeting to explain that. 

25 Is there anything to add to this before we close 
85

1 out? I do want to ask, Ed Walker asked to say a 

2 few more words, but before Ed, I'd just ask is 

3 there any other discussion before we want to 

4 close out? 

5 DR. WADE: Mark, this is Lew. The only thing I 

6 think I actually, the only thing I would hold out 

7 is if either of the parties find it critical in 

8 their need to talk to the other party between now 

9 and the subcommittee meeting, I think we should 

10 encourage them, although I think again, we should 

11 do that, notify all of the work group members so 

12 that they could participate, but I wouldn't want 

13 to rule out the possibility of an interaction if 

14 either side wants to take steps towards the 

15 purpose of bringing this to closure. 

16 MR. GRIFFON: Yeah, I certainly agree with that, 

17 yes. 

18 Arjun. 

19 DR. MAKHIJANI: Thank you, Dr. Wade, for 

20 clarifying that, and I would propose that the way 

21 Jim and I did for the Mallinckrodt report, and 

22 what we have done for this report that we simply 

23 make all the e-mails part of any official report, 

24 and Ed would be copied on everything, I presume, 

25 so he would be able to participate and know 
86

1 what's going on. 

2 But my question, Mark, for you was is there a 

3 specific expectation of a resolution to that 

4 first bullet point about the use of the Bethlehem 

5 Steel data and how do you, where do you see that 

6 headed, in your judgment? It's not a long time, 

but we’re now in October 17th 7 . Do you expect to 

8 hear from us before the working group meeting 

9 with a revised report or a memorandum on that 

10 question? I guess I'm not clear on what the 

11 process is. 

12 MR. GRIFFON: I guess my sense is that, you know, 

13 one of the issues that you outlined in that 

14 section was the illegible data. So now is that 

15 still an unresolved issue? I think they've 

16 addressed, right, they've addressed that, and 

17 then, but you haven't had time to look at that 

18 data. So given the analysis you did in that 

19 first section, how would this new data, you know. 

20 Maybe you want to re-look at that analysis and 

21 see if it changes any conclusions. That's what I 

22 would say. And in the meantime I also agree with 

23 Lew that dialogue between, you know, with NIOSH 

24 might help to come to some conclusions there. 

25 Ken, did you have any -- 
87

1 MR. PRESLEY: Mark, is there any way though that 

before we go to the 17th 2 meeting that we can have 

3 some type of a closure on this from SC&A and 

4 NIOSH on this one point? 

5 DR. WADE: I think that's terribly important. To 

6 speak to your issue, Arjun, and to Mr. Presley's 

7 point, there are two ways this could work. Let's 

8 take just the one point. One is that, you know, 

9 based upon deliberation and consideration by both 

10 sides that you come to a meeting of the minds. 

11 There's a possibility that you don't come to a 

12 meeting of the minds. 

13 I think in the first case it would be just as 

14 important to know that, understand that. If you 

15 don't come to a meeting of the minds, I think 

16 it's essential that the board can look at clearly 

17 articulated points. Obviously the board would 

18 have to make its recommendation. So I would hope 

19 that before the board meeting that we could hear 

20 from both SC&A and NIOSH on this point. Either 

21 we've agreed or we haven't agreed and here's our 

22 position on it. 

23 MR. PRESLEY: That's what I would like to see. 

24 DR. MAURO: Lew and other members of the working 

25 group, this is John Mauro. What comes to mind 
88

1 that would be of particular importance in terms 

2 of coming to as much we can to closure has to do 

3 with the issue of unusual practices, cutting of 

4 the cobbles, other words, activities, scenarios, 

5 practices that may have taken place. A richer 

6 understanding of that because a lot of our 

7 concerns related to where, why, where we came 

8 down is this discomfort we have that the actual 

9 data that we do have did not capture some of 

10 these practices. 

11 And of particular importance that Jim brought up 

12 that we had not looked at was the possible 

13 implausibility that these cobbles were not cut 

14 with a torch of some type because that would then 

15 reduce the likelihood of substantially high 

16 levels of fumes which are very small particle 

17 size and could be fairly high in concentrations. 

18 One of their areas that I think a dialogue over 

19 the next two days might be especially productive 

20 is to come a little closer together on our 

21 understanding regarding that particular matter. 

22 MS. DeMERS: This is Kathy DeMers. Can I ask Ed 

23 a question? 

24 MR. GRIFFON: Yeah, go ahead, Kathy. 

25 MS. DeMERS: Ed, we know that you guys weren't 
89

1 aware you were rolling uranium. Was cutting of 

2 cobbles common for when it occurred with steel? 

3 MR. GRIFFON: We're getting a mike for Ed right 

4 now. 

5 MS. DeMERS: Did you guys hear me? 

6 MR. WALKER: Yes, I've got -- is it on? 

7 Kathy, would you repeat the question, please? 

8 MS. DeMERS: We know that you guys were not aware 

9 that you were working with uranium, okay? 

10 MR. WALKER: Correct. 

11 MS. DeMERS: Now when you had a problem with 

12 steel, what did you do to get them out of the 

13 rollers? 

14 MR. WALKER: We burned them out. That was the 

15 only possible way you could get a steel cobble 

16 out of, steel out of the cobble, is to burn them 

17 out. 

18 MR. GRIFFON: As opposed to this torch cutting 

19 that they -- 

20 MR. WALKER: Well, burning out would be torch 

21 cutting. That would be the same. 

22 MR. GRIFFON: Okay, that's what I thought. So 

23 it's the same thing. 

24 MR. WALKER: And I never heard any of the experts 

25 ever say that they done anything. I will check. 
90

1 I'll go back and bring up this issue to them and 

2 check and see. But as far as I know they had to 

3 be burned out. There was no other way to get 

4 them out. You couldn't pull them out. They had 

5 to be burned out. It's possible they could have 

6 been cut with what we call today a chop saw, but 

7 I don't think so. 

8 MS. DeMERS: Well, Ed, as far as you guys were 

9 concerned, uranium was steel. 

10 MR. WALKER: Right. 

11 MS. DeMERS: Okay. 

12 MR. WALKER: Is that all? 

13 MS. DeMERS: Yes. 

14 MR. GRIFFON: Arjun is -- 

15 DR. MAKHIJANI: Yeah, I have a request of Ed. 

16 You know we're going to correspond, SC&A will 

17 correspond with NIOSH about this forthwith. I 

18 think starting tomorrow. You're going to be 

19 copied on everything. This is a point that was 

20 brought up by workers and people who really know. 

21 I've never worked in a steel or uranium rolling 

22 mill, right? I think it's extremely important 

23 for the most knowledgeable people in your 

24 community to participate in this so we can have 

25 the best judgment possible. 
91

1 Because as Jim has said, uranium, and we all know 

2 that uranium is pyrophoric. It catches fire very 

3 easily under these kind of conditions. And this 

4 is a kind of very important point for the 

5 integrity of the process, and we don't have 

6 documentation. If you have any documentation 

7 from the period, statements of workers, at least 

8 I would very much like to have the benefit of 

9 looking at them. And urgently, because as you 

10 can see, we're asked to come up with an opinion 

11 very rapidly. So I would request that. 

12 MR. WALKER: To the site experts that actually 

13 worked down there, there's quite a few of them. 

14 And I only talk to the ones that I feel, and 

15 that's all I have done. If I feel they're not 

16 telling me the truth or I catch them in something 

17 that isn't right such as the fella that worked in 

18 the straightener. I talked to him, and I got an 

19 interview. And I believe Kathy has that or I'll 

20 send it to her where he loaded into the 

21 straightener with his bare hands. 

22 He had a partner and today his hands are crippled 

23 and he's got severe headaches and his front lobal 

24 (sic) brain cell. He's about 76 years old, but 

25 he actually picked up the steel by hand off of 
92

1 the, after the shear, and carried it and put it 

2 into the straightener. And as he put it in, he 

3 commented how when he put it in and these rollers 

4 were rolling to pull this into the straightener, 

5 how it would flash and light up the whole plant 

6 and blind him 'cause obviously he had no 

7 protection. And truthfully, I says is that your 

8 arthritis in your hand. He said no, I don't know 

9 what it is. The doctor's don't know. And his 

10 hands look like they've been run over by a 

11 bulldozer. 

12 And I says, Richard, I says what went on back by 

13 the cooling rack and what went back on back by 

14 the salt bath? And he says, Ed, I don't know. I 

15 went to work there. My job is at the 

16 straightener. I done my job for eight, sixteen 

17 hours a day, he said, and that was it. I didn't 

18 walk around and look to see what was going on. 

19 So I have no information other than what happened 

20 at that straightener at that time that I worked 

21 on. 

22 So that's how I'm getting my information. I 

23 worked there as a bricklayer. At times I was 

24 there, and there was times I wasn't there. There 

25 was a lot of the people that I talked to worked 
93

1 there much longer obviously in the plant as 

2 rollers that worked on it all the time. And 

3 that's where I get my information from. And I 

4 tell them if you don't know, tell me 'cause I 

5 cannot go down and talk to these people and find 

6 out that some of the information you gave me is 

7 false. I says I'm not going to be questioned on 

8 it. If you don't know, I'd much rather you tell 

9 me right now, Ed, and this is just like what 

10 Richard done. So that's how I get my information 

11 and I'll look as long as I can. 

12 MR. GRIFFON: Thanks, Ed. Let me -- I'll give 

13 you the mike in a second, too. I know you had 

14 some other thoughts to share. 

15 Let me just ask in terms of schedule, I'm hearing 

16 Bob and Lew Wade, and it would be nice to have 

17 some kind of more conclusive process before the 

18 next board meeting. On the other hand I'm 

looking and saying, you know, it's the 6th 19 now, 

and we've got till the 17th 20 . All I would say is 

21 that maybe if there are any amendments to the 

22 SC&A report or any, it'd be nice to have them at 

that Friday before, which is the 14th 23 . Yeah, at 

24 least in draft form, something that we can 

consider before we get there on the 17th 25 . 
94

1 DR. MAURO: Yeah, Mark, this is John Mauro. 

2 Given that the main body of our report is only 27 

3 pages, everything we've been talking about right 

4 now, there might be some effect on some of the 

5 appendices, but I'm going to go out on a limb a 

6 little bit, and I believe between now and let's 

7 say a week from tomorrow, you know, we're going 

8 to be busy putting our slide presentations 

together for the meeting on the 17th 9 . 

10 But I think it's plausible for us to issue 

11 another revision because I think it will affect 

12 only some of the main body of the 27 pages that 

13 makes up our main report. So I'll go out on a 

14 limb a little bit, and we're going to do our best 

15 to give you a revised report that will reflect 

16 not only this conversation, but also the dialogue 

17 that we engage NIOSH in over the coming weeks. 

18 It'll be ambitious, but I think it's important 

19 that we try to do that. 

20 DR. MAKHIJANI: Can I have a conversation with 

21 our project manager in public, please? 

22 DR. MAURO: Certainly, go ahead, Arjun. 

23 DR. MAKHIJANI: John, I think the approach 

24 suggested to kind of present a memorandum of 

25 revisions rather than a revised report will avoid 
95

1 the logistics of typesetting and revising, and we 

2 can work to present any new or revised 

3 conclusions maybe in a table with text or 

4 something like that and then give a revised 

5 report after the board for the record rather than 

6 provide, I think the logistics of a revised 

7 report may take a couple of days that would be 

8 more useful in actually doing the work. 

9 DR. MAURO: Okay, Arjun, fine, but I think it's 

10 critical that we come to closure as much, as best 

11 we can on many of these issues as we can. If 

12 they take the form of a memorandum or such like, 

13 that's fine. Maybe that's the best way to go, 

14 just let's get the final report out after the 

15 meeting. Quite frankly, the Monday morning 

meeting on the 17th 16 , more may emerge so perhaps 

17 that is a wise choice, so let's wait and see a 

18 little bit. 

19 MR. GRIFFON: Okay, we're in agreement here, 

20 John. Wanda has some comments. 

21 MS. MUNN: John, this is Wanda. Thank you very 

22 much for making the effort to try to get some 

23 additional data settled between now and the 

24 upcoming meeting. The fact that you have only 

25 six findings and that most of them probably 
96

1 balance on a single technical point gives me hope 

2 that perhaps you can do that. 

3 One of the other things that has not been 

4 discussed here in depth, and I don't know whether 

5 it was your intention to take this up again after 

6 lunch or not, but there's no question in my mind, 

7 I keep hearing the issue of oronasal breathing. 

8 And that's just about been beaten to death in one 

9 form or another here, but I see no solution or 

10 agreement between NIOSH and SC&A on that point as 

11 yet. 

12 It seems to me that we're going to have to face 

13 this and face it preferably with Bethlehem Steel 

14 with the understanding that it may vary somewhat 

15 at the other sites, but it would certainly be of 

16 great comfort to several members of the board if 

17 we could put that to some degree of rest. 

18 MR. GRIFFON: I thought I heard agreement. 

19 That's the one I had okay next to, but maybe Jim. 

20 DR. MAURO: Arjun, if you want to respond on it, 

21 either way. 

22 MR. GRIFFON: Jim Neton first then -- 

23 DR. NETON: Well, you guys can go first if you'd 

24 like, but I thought there was substantial 

25 agreement there that for this particular site 
97

1 profile, oronasal breathing would not make a 

2 substantial difference. The issue was whether it 

3 was negligible or not, and we agree it wasn't. 

4 Possibly not negligible. There was, I think, a 

5 six percent adjustment that may or may not be 

6 required, and we have not really addressed that 

7 issue yet. But I don't think that's a show 

8 stopper to any extent. 

9 DR. MAURO: I'm going to be very frank. I think 

10 it's a non-issue on Bethlehem Steel in the 

11 margin. I think, however, a more fundamental 

12 issue regarding whether or not it should be a 

13 matter of policy to take into consideration the 

14 fact that some workers -- now we're not talking 

15 Bethlehem Steel anymore, just in general -- are 

16 mouth breathers and certainly we have some data 

17 that says there could be 15 to 20 percent of the 

18 population. This becomes almost a -- and I 

19 mentioned this at one of our meetings awhile ago. 

20 So yes, the issue is still on the table from a 

21 generic point of view. I think it's off the 

22 table for all intents and purposes of Bethlehem 

23 Steel. 

24 MS. MUNN: I understand that, but my concern was 

25 the larger policy issue because if we have to go 
98

1 through the kind of exercise we've been through 

2 on the last two sites at every one that we come 

3 to, it would certainly be far more beneficial and 

4 far more expeditious if we could come to some 

5 general agreement about how we're going to 

6 address that issue. It would resolve problems 

7 for all of us I think. 

8 DR. NETON: I agree, Wanda, and I think if we get 

9 into it, that same comment occurs in the, I think 

10 it's either the Y-12 or the Savannah River review 

11 or both. So it's an issue that we're going to 

12 have to deal with. It's coming up in the next 

13 set of reviews. We'd like to put this issue to 

14 bed as well. 

15 DR. MAKHIJANI: May I make a suggestion that 

16 since it is a generic issue as John has said, 

17 then maybe it ought to be addressed in that 

18 context rather than it coming up. And maybe 

19 there's a range of uncertainties within which 

20 it's important to take it into account. And you 

21 know, when the other uncertainties are big, then 

22 it becomes a non-issue or a small issue that can 

23 be regarded as not important. And so some 

24 general guidance maybe can be developed inside 

25 NIOSH since they did do an analysis that we 
99

1 agreed with on the question. So we don't think 

2 there's a kind of a technical difference anymore. 

3 It's a question of how do you go from here to a 

4 general guidance which is a policy issue -- 

5 MR. GRIFFON: And how is it applied 

6 programmatically, yeah. 

7 DR. NETON: This becomes a -- I think we tried to 

8 address this to a certain extent at the last 

9 board meeting with the Bethlehem Steel comment. 

10 And the fact is the difference in breathing 

11 depositions among people is greater than the 

12 difference in the oronasal breathing deposition 

13 parameters. And in some sense one has to argue 

14 then if we correct for oronasal breathing, then 

15 do we correct for differential breathing rates 

16 among different sized people, different sexes, 

17 you know, all those sort of issues come into play 

18 at that point. And then one creates a quagmire 

19 of corrections that may never, we may never end, 

20 but these are the issues, the policy issues, that 

21 need to be addressed, and it's a fairly broad 

22 issue. 

23 DR. MAURO: Yes, in fact, Jim, I think you hit 

24 the nail on the head. We managed to sort of 

25 avoid this issue with Bethlehem Steel because we 
100

1 had a way to avoid it. It's not important here. 

2 I think though that the line of attack on this 

3 issue of the type that you just described, mainly 

4 reference man and the definition of reference man 

5 and the inherent variability in all of the 

6 parameters that make up the respiratory tract 

7 model. Your, as I understand it is well, this is 

8 just one more of those parameters. 

9 And I think that coming at this issue from that 

10 perspective and whether or not we should look at 

11 the oronasal breathing as something different and 

12 separate from all the other parameters that make 

13 up the genetics of retention, deposition and 

14 clearance for the respiratory tract model, that 

15 really becomes the question. 

16 I agree with you that if this is just one more of 

17 many parameters that represent a definition of 

18 reference man, then we, you know, why are we 

19 taking on it? However, there's reason to believe 

20 that ICRP provides for this type of treatment or 

21 to separately look at oral breathing. You know, 

22 that may be, then it becomes a matter of 

23 interpretation, whether we should be trying to 

24 apply this as a claimant favorable approach. 

25 By the way, I don't know if Kathy Behling is 
101

1 there today? 

2 DR. NETON: Yes. 

3 DR. MAURO: Kathy, is oronasal breathing on the 

4 Task 3 internal dosimetry generic issues? 

5 DR. BEHLING: No. It is at the Savannah River 

6 site as Jim had already mentioned. 

7 DR. MAURO: I didn't know if you heard the 

8 question. 

9 DR. NETON: Yes. It's not -- Hans is going to go 

10 to the microphone, John. 

11 DR. BEHLING: John, it's not in the Task 3 

12 report, but it is on the table for discussion if 

13 we get to the Savannah River site today. 

14 DR. MAURO: Okay. Now the reason I raise the 

15 question is I agree with Arjun that this is a 

16 generic issue, and it could be addressed offline 

17 or on a case-by-case basis. It would be much 

18 more satisfying as Wanda indicated if we could 

19 address it generically and put it to bed once and 

20 for all. I just thought it might be one of the 

21 ones we'd be looking at on Task 3, but apparently 

22 not. 

23 MR. GRIFFON: I think we're all in agreement on 

24 that, John. 

25 Larry Elliott has a comment. 
102

1 MR. ELLIOTT: This is Larry Elliott and speaking 

2 from a program policy perspective here today. 

3 That's what you're talking about. 

4 Jim Neton has clearly put on the record our 

5 thinking and our position, our rationale on this 

6 issue, and it is a generic issue in our mind. We 

7 stand on that, and that's the policy that's being 

8 applied right now; what you heard from Jim two, 

9 three meetings ago, I believe, on this issue. 

10 That's where we stand. If we need to, you know, 

11 refresh your memories of that, we can do that 

12 maybe at the next meeting or do whatever and walk 

13 through that. But that's essentially where we 

14 stand, and that's what the policy is. That's 

15 what's being applied. 

16 MR. GRIFFON: Yeah, we might need a refresher on 

17 that. 

18 DR. NETON: Yeah, I think we could prepare to do 

19 that maybe at the next meeting or whenever people 

20 want. But someone made the comment about ICRP 

21 not addressing it. I just want to clarify. ICRP 

22 actually chose to ignore oronasal breathing in 

23 their models because of the exact reason that I 

24 just mentioned. The difference between, among 

25 people is greater than the difference in oronasal 
103

1 breathing differences. 

2 Also, it gets into the issue of do we default and 

3 make a correction universally on one side or do 

4 we incorporate this into the distribution at 

5 which point I'd argue that the GSD of three on 

6 internal dose calculations already includes that. 

7 But I won't say anymore on that. We can pick 

8 that up at another time. 

9 MR. GRIFFON: Yeah, and I think we've all agreed 

10 that this is a general issue, and we need to 

11 address it. But for Bethlehem Steel I think it's 

12 kind of, there's agreement here on this issue. 

13 So I think I wanted to try to close out Bethlehem 

14 Steel discussion now. If there's anything else -

15 - I know Ed has some things. 

16 I'm sorry to make you wait so long. 

17 Ed has some final things he wants to share with 

18 us. 

19 MR. WALKER: That's all right, Mark, I'm retired. 

20 Well, when I started out, I was under the 

21 impression and I was told that if we have any 

22 information, we should present it to NIOSH, and 

23 they'll give it consideration. There's been many 

24 issues that I have that I've tried to get 

25 through, and I have not been able to get through. 
104

1 There's many issues, and a lot of it just 

2 requires a simple answer. If a group of three or 

3 four would have come up and sat down and says, 

4 Ed, this is where it's at. But when I don't get 

5 any answer... 

6 (Telephone line interference occurred.) 

7 What was that? So I'm concerned about that, and 

8 one of the things is this weighing the range 

9 letter that I've had for quite awhile, and we've 

10 discussed, I think, before. But it kind of upset 

11 me as I said. I feel my job for working with 

12 this group is to find information and present it 

13 to the people so they get a fair treatment on it. 

14 And there seemed to be a black hole in '49 to 

15 '51. The range letter was sent to the assistant 

16 manager, Mr. Anderson, of the Environmental 

17 Control. 

18 I don't know if you're all familiar with this, 

19 but the Bethlehem Steel Quality, Environmental 

20 Quality Control. Now it says many things, but 

21 one of the things that kind of caught my eye was 

22 beginning in approximately 1949 it was determined 

23 that then current production rolling of uranium 

24 billets to rods left much to be desired in the 

25 present reduction in the mill pass schedules. 
105

1 And this regular production was not being 

2 performed at Bethlehem Steel but through a 

3 contract with them. It was determined that a 

4 suitable blooming mill -- they determined this. 

5 Eddie Walker didn't determine this, and this is 

6 what they say in '76 -- and a suitable continuous 

7 mill -- which is a ten inch mill, which we all 

8 know -- existed for the necessary development and 

9 work to indentify (sic) required pass schedules. 

10 Okay, it mentions that mill. There's a lot of 

11 mills at Bethlehem Steel. There's a 12 inch 

12 mill, 13 inch mill, strip mill, you name it. But 

13 they specifically said the blooming mill. The 

14 blooming mill reduces the size of billets, or in 

15 most cases, ingots which is the first step of a 

16 billet, okay? So they said the blooming mill was 

17 there. So why would they say it if they didn't, 

18 why did they say the ten inch mill. Why didn't 

19 they just say the ten inch mill if they didn't 

20 mean it? Okay. 

21 To the best of our ability we have established 

22 that Bethlehem Steel was given a contract for the 

23 necessary development for pass schedules. For 

24 the development of pass schedules, given a 

25 contract -- well, I read that. And work 
106

1 accomplishing in the period -- in the period -- 

2 between '49 and '51 -- to '51. It doesn't say 

3 including '51 which we know they done 

4 experimental rollings. But this is their wording 

5 that it was experimental work that was being done 

6 between '49 to '51. It says a lot of other 

7 things but unimportant. 

8 It goes on to say the extent to which air samples 

9 or surface sample contamination readings were 

10 taken is not known -- is not known, okay? It 

11 goes on to say these records long since have been 

12 destroyed. We do not believe there are any 

13 remaining records of the archives at Bethlehem 

14 Steel Lackawanna plant. It is quite probable 

15 that in 1949 to 1951 time periods of the 

16 technical information developed was a classified 

17 nature and for this reason was returned to the 

18 AEC. 

19 Okay, classified nature and the technical 

20 development. They did not walk into that plant 

21 in 1951 and say tomorrow you're going to roll 

22 uranium rods. They had to set up. They had to 

23 experiment with it. One of the gentlemen said 

24 they done it in another plant. I've never seen 

25 anything about that. But it does state there -- 
107

1 I didn't say it -- that there was mills used in 

2 one area. Here it does say, it mentions mills 

3 being used. 

4 So as I look at it as a worker, there was more 

5 than one mill being used. I take this 

6 information. I confront it. It's thrown out. 

7 Well, that doesn't mean nothing. That's a letter 

8 of somebody that lost their memory. Could be, 

9 but they used parts of it in their dose 

10 reconstruction. 

11 This is what upsets me. I found a document that 

12 said what happened. It didn't say rollings 

13 happened. It said developmental experiments were 

14 being done at Bethlehem Steel. How much 

15 contamination did they get with the salt baths, 

16 the lead bath that they were dealing with then 

17 and probably more lead baths and uranium. When 

18 they had to figure out running it through the 

19 pass schedules, the heat temperatures and that 

20 because it had to be heated evenly, how much 

21 experimental work that they say was done, was 

22 done at Bethlehem Steel from '49 to '51 that 

23 we're not given any credit for? Because Jim will 

24 say that we are allowing you for a rolling once a 

25 month. 
108

1 That doesn't mean much. We don't know what they 

2 done. We don't know what their exposure was. 

3 We've taken exposure samples from Simonds Saw to 

4 say what we done later on, but we don't know what 

5 happened at Bethlehem Steel at that time. We 

6 don't know what exposure they had and how often 

7 they had it. So if you get a document, and I 

8 present it to NIOSH, and they completely 

9 disregard it, I don't think it's fair to us. 

10 I want to go with the lost uranium a little bit. 

11 I won't take up much longer. I know you're all 

12 hungry including myself, so I would just like to 

13 talk about the lost uranium which the document 

14 says four to six pounds of uranium was lost in 

15 the rolling process at Bethlehem Steel on every 

16 billet rolled. People will say well, they take 

17 care of that when they say they picked it up and 

18 they cleaned up the site. 

19 No. Because if they picked it up and they 

20 weighed it, it would be accountable. This is 

21 unaccountable, was lost at the site. I have 

22 people, when this uranium come off the rollers, 

23 and a lot of it that was washed was put into what 

24 they call a scaling pit. I have a man that 

25 worked in the scaling pit. He told me when they 
109

1 loaded these scaling pits, they cleaned them out 

2 once a month so that uranium wasn't cleaned out 

3 every day. 

4 They cleaned them out once a month, sometimes 

5 twice a month. They put it in a railroad car. 

6 And what the man told me was I noticed, he says, 

7 there was no air hoses on the railroad car and 

8 this scaling was dumped that come out, not, it 

9 was mixed with steel, granted that. But it was 

10 dumped on and it was with no air hoses means it 

11 could not go off the plant site because you can't 

12 take a railroad car of any sort without brakes 

13 and air hoses had the brakes. So it was dumped 

14 on the site but there's no residual. 

15 And that's what he told me. I didn't pump this 

16 into him. He says the first thing I noticed 

17 there was no air hoses on that car. So when you 

18 talk about residual contamination, there's a good 

19 source of it. And we don't know how often that 

20 was done, but at least for two years we know for 

21 sure. 

22 That's about all I got to say, but I hope that I 

23 can stay in touch, and I really appreciate giving 

24 me this opportunity to talk. But there are quite 

25 a few other issues that when I send in, I would 
110

1 like somebody to respond. And as I said, a lot 

2 of these questions may be answered very simple 

3 and easy. And I can understand. I'm not a hard 

4 person to understand or reason with. So thank 

5 you again, and hopefully I'll see you in 

6 Tennessee. Thanks again. 

7 MR. GRIFFON: Thanks. 

8 Larry's going to give us a response. 

9 MR. ELLIOTT: I appreciate Mr. Walker's comments, 

10 and I must take exception though, Mr. Walker, 

11 that if you look on our website, we have 

12 responded to inquiries you sent to us, the 

13 information you shared with us. There are 

14 documents there that show what you sent and our 

15 reaction to your input, and we're going to stand 

16 by that. If there are points that you want to 

17 discuss further that you think you haven't got 

18 full reaction to, we should talk about that. We 

19 should continue the dialogue. I don't want to 

20 shut the dialogue down, but I just want to make 

21 sure that people understand for the record that 

22 we have been responsive and we have been working 

23 together on this. It's not that we have been 

24 ignoring the input that you've been giving us. 

25 MR. GRIFFON: Thank you. 
111

1 Any further thoughts on Bethlehem? Otherwise, I 

2 think we'll break for lunch. Ed has -- 

3 MR. WALKER: And again, I'll make this real short 

4 because I'm getting hungrier, too. But what 

5 really upsets me is our technical-based document 

6 came out in 2003, '03. It wasn't until 16 months 

7 after that date that we've been denied, that our 

8 claimants have been denied, that anyone talked to 

9 anybody from Bethlehem Steel site experts. And 

10 it was my understanding that the dose 

11 reconstruction is taken from the technical-based 

12 document which is taken from the site profile. 

13 Our site profile was done 16 months after our 

14 technical-based document. And when I questioned, 

15 a couple months after that I questioned, I says 

16 where is our site document? Where did you get 

17 the information? I was told Simonds Saw. And I 

18 says could you send me Simonds Saw site profile 

19 being that you used their documentation to assess 

20 our contamination site. And he says it is not 

21 done. 

22 So this is what upsets me about what went on. I 

23 can't see how anybody can do an assessment and 

24 not go there or not talk to anybody who was 

25 there. If there was car accident out in 
112

1 California, I could not set in Eden, New York, 

2 and say the two cars hit at 50 miles an hour. 

3 This guy was at fault. I would have to go and 

4 talk. And this was not done. Clearly, I want to 

5 know that this was not done till 15 months after 

6 our claimants had been denied, and I think that's 

7 a gross injustice to Bethlehem Steel. 

8 MR. ELLIOTT: Larry Elliott, and I appreciate 

9 your frustration, and it is a complex and a very 

10 difficult program to understand. It's a 

11 difficult program to manage as you might suspect. 

12 In trying to handle a large caseload of claims, 

13 yes, we made some decisions early on as to when 

14 to draw the line and say we had enough data to 

15 provide a reasonable estimate of dose to 

16 determine the compensability of a case. 

17 We did that in the early days, as you say, with 

18 Bethlehem Steel. We had experts at the table 

19 that understood the data and understood what it 

20 was like to work in a steel mill. Had we been to 

21 the steel mill at Bethlehem's site? No, sir, 

22 I've told you we hadn't. We didn't. We did get 

23 input through our interview process. We did take 

24 action later on, as you know, maybe too late, but 

25 we were doing a variety of things, as you know, 
113

1 to get a meeting set up where we come in and said 

2 here's what we're working with. What do you 

3 think of it? What can we do to make it better? 

4 We did do that, and you gave us input, and we 

5 addressed that input. This is a process. You're 

6 part of that process, and we're very proud of the 

7 work you're doing in that process. And I just, 

8 you know, I wish we could do better for you. 

9 We're trying our level best, but the, you know, I 

10 think it's remarkable that for Bethlehem Steel, 

11 we have paid out over 45 percent of the cases 

12 there through dose reconstruction. 

13 We think it is a very sound scientific product 

14 that we're using to do that. We've given the 

15 benefit of the doubt as appropriate to the 

16 claimants. And if there are ways that we can 

17 improve upon that, that's why I'm standing here. 

18 That's why I want to be here. 

19 MR. GRIFFON: Okay, last comment, Dick Toohey, 

20 wants to make a comment and then we're going to -

21 - 

22 DR. TOOHEY: Dick Toohey, ORAU. I just want to 

23 clarify for the record this issue on TBDs and 

24 site profiles. TBD is a technical basis document 

25 and it's just one document category we use in our 
114

1 document control system. For an atomic weapon 

2 employer site there is only one document, the 

3 technical basis document. That is the site 

4 profile. That's it. 

5 So there's only one document and rev zero of the 

6 Bethlehem Steel TBD which came out in 2003, as 

7 you say, that was it. It has been revised since 

8 then as more data became available. For a DOE 

9 site, which in general were larger and more 

10 complex, the site profile consists of a set of 

11 TBDs, each looking at a different aspect of 

12 exposure. But usually an AWE only did one thing 

13 so we can cover it in one document. 

14 Secondly, in terms of using the Simonds Saw and 

15 Steel data, we thought that was the most complete 

16 set of air sampling data at a site that had 

17 rolled uranium. Obviously, we had nowhere near 

18 that much data from Bethlehem Steel. So we 

19 thought given the lack of whatever large, 

20 reasonable, adequate amount of data from 

21 Bethlehem Steel, the best way to develop an 

22 exposure model for these workers would be to use 

23 actual air monitoring data from Simonds Saw and 

24 Steel, and that's what we did. 

25 And we looked at and analyzed that data, and we 
115

1 saw no need to complete the Simonds Saw and Steel 

2 TBD before using that data. And the reason we 

3 went to Bethlehem Steel first, our order of doing 

4 site profiles was basically by the number of 

5 claimants from the site. And as you know, 

6 Bethlehem Steel was by and large had the largest 

7 number of claimants of any of the atomic weapon 

8 employer sites so that's where we started. 

9 MR. GRIFFON: Thanks for that clarification. 

10 I, myself, have been a little loose with the 

11 language of a site profile versus TBD, so we 

12 might have created some of that confusion 

13 ourselves. 

14 With that I think we'll close out on Bethlehem 

15 Steel and have lunch. So 1:45, we've got a busy 

16 schedule, so we'll start up at 1:45. Thanks. 

17 (Thereupon, a lunch break 

18 was taken and the meeting 

19 reconvened at 2:00 p.m. 

20 after which the following 

21 transpired:) 

22 TASK 3 PROCEDURES REVIEW

23 MR. GRIFFON: Let's reconvene. I think we're 

24 going to take up the procedures review, the Task 

25 3 Procedures Review. And probably it looks like 
116

1 the focus is going to be on the external dose 

2 issues because that appears to be what SC&A has 

3 completed the matrix elements and NIOSH has just 

4 now provided some draft responses for us. So we 

5 at least have, I think that's where we'll have 

6 the most fruitful discussions or dialogue. 

7 And I did want to raise one thing though that was 

8 a little point of confusion coming in here for me 

9 was that I actually thought this was the priority 

10 of this work group and apparently this got de11 prioritized as the time went between the last 

12 Advisory Board meeting and this work group 

13 meeting. And I'm not sure who did that so I 

14 just, you know, if, I mean, this may have been 

15 done in conjunction with Lew talking with our 

16 chair, but I don't know that the Advisory Board 

17 was in the loop. 

18 And that's one concern I have going forward. 

19 There's nothing we can do about it now, but you 

20 know, I think this is a pretty important 

21 priority, and if it was to be lowered in the 

22 scheme of priorities, and I know everybody was 

23 loaded down with work between these last two 

24 meetings, but if it was going to be lowered, 

25 maybe someone should have let the Advisory Board 
117

1 know about it. 

2 DR. WADE: This is Lew, Mark. It wasn't lowered 

3 by any conscious effort. I mean, I, it was my 

4 understanding coming out of the Advisory Board 

5 that we were to look at a number of issues. We 

6 did not receive SC&A's matrix on internal dose 

7 until, I guess it was yesterday. And you know, I 

8 think that was just the press of business on 

9 their part. So I don't think it was a conscious 

10 on anybody's part to de-prioritize this. 

11 MR. GRIFFON: Well, I think we've spent a lot of 

12 time at the last meeting saying can SC&A complete 

13 the matrix by this work group meeting? And can 

14 NIOSH give responses back by then? There was 

15 some hemming and hawing, but everybody agreed to 

16 the date, and then we come in and we're not 

17 there. So I, just, you know, and I don't, look, 

18 we just have to proceed with what we've got, but 

19 I think in the future if there's going to be, you 

20 know, there's limited resources, everybody's got 

21 limited time. 

22 If there's some issue that arises, I think 

23 somebody has to bring the board into the circle, 

24 and you know, we'll work through it. And maybe 

25 we would have come to the same conclusion, but 
118

1 you know, at least bring us in the loop I think. 

2 That's my opinion anyway. I'm not sure I speak 

3 for the entire board here. But given that I 

4 think we need to start on the matrix, and my 

5 sense is, if this is a good way to do this, I 

6 think this is where we need, a nice informal 

7 discussion going finding by finding down the 

8 matrix. 

9 Some of these I think we'll pass by fairly 

10 quickly, given NIOSH's response. Some of them 

11 are going to be a little more technical in 

12 nature, and we'll have to have a discussion 

13 explanation by SC&A and an explanation of the 

14 response. So I think the best way might be just 

15 to start at the beginning of your matrix and work 

16 down and have SC&A start the --. 

17 MS. BEHLING: This is Kathy Behling of SC&A, and 

18 if I could just make a few brief opening comments 

19 about Task 3 because it has been quite some time 

20 since we published this report and actually, it 

21 was well over a year that we started working on 

22 this project. And so therefore, just to re23 familiarize everyone with what the Task 3 project 

24 was all about, and what we did. 

25 First of all, the participants were Hans Behling 
119

1 and myself, Joyce Lipsztein, Arjun Makhijani, 

2 Kathy DeMers and Steve Ostrow. And we, as I 

3 said, started this over a year ago, and we were 

4 initially given 33 procedures that were selected, 

5 I guess, by the board and NIOSH that represented 

6 the primary procedures used at the time for the 

7 dose reconstruction process. I want to note that 

8 since then, obviously, there have been a lot of 

9 additional TBDs so this isn't complete at this 

10 point in time by any means. 

11 When we evaluated this, we looked at this and 

12 evaluated from assessing seven objectives that 

13 focused on timeliness, efficiency, completeness, 

14 consistency, claimant favorability and the 

15 procedures and the methodologicability to account 

16 for uncertainty. And then lastly to try to 

17 balance this adequate science against efficiency 

18 and to determine if the procedures did that. 

19 So in light of that you will see in our matrix 

20 that was developed from the findings of the Task 

21 3 report that there are a lot of issues that are 

22 not technical in nature. I guess the matrix that 

23 we will be using today to, does try to follow the 

24 Task 3 report pretty much page by page. 

25 And the other point I wanted to make is when we 
120

1 started this project, this is really one of the 

2 first tasks of the, Task 3 was one of the first 

3 tasks we did, the procedure reviews. And it 

4 preceded us actually looking at the dose 

5 reconstruction audits. And so I guess Hans has 

6 mentioned this before, but at the time it was 

7 almost as if we went into the showroom and looked 

8 at the car and kicked the tires and looked at 

9 specifications. 

10 And since then we've obviously had the 

11 opportunity to do some, a lot of dose 

12 reconstruction reviews; and therefore, we have 

13 actually taken these procedures for their test 

14 drive. And so as we go through this matrix there 

15 may be things that at the time seemed more 

16 significant than they possibly are now and maybe 

17 the other way around also. But I just wanted to 

18 point that out and remind everyone of the 

19 process. 

20 I was going to suggest that we would discuss only 

21 those items that possibly we had some differences 

22 of opinion on, but it appears that you prefer to 

23 go through them one by one, and we're prepared to 

24 do that. 

25 MR. GRIFFON: I think, I mean, just to step 
121

1 through them so people can follow along, and the 

2 ones that there's no difference of opinion, let's 

3 dispose of them quickly, you know. 

4 MS. BEHLING: And one last item, this is the 

5 first that we've, in fact, as we were sitting 

6 here is the first that I saw NIOSH's response. 

7 So as we discuss these topics, we haven't even 

8 had a chance to read through these. 

9 DR. BEHLING: Yes, and just -- this is Hans 

10 Behling, just to put things into perspective, 

11 it's part of the expanded review process. And as 

12 of today we have not had any direct dialogue with 

13 NIOSH over the Task 3 report in spite of the fact 

14 that the report was issued back in January of 

15 this year. So this is really the first time 

16 we've had the opportunity to discuss the 

17 technical merits of some of the issues that we've 

18 raised. And it's basically we're starting at 

19 ground zero with this discussion of an expanded 

20 review. And it's possible that we may have to go 

21 beyond today, but it's also possible that we may 

22 be able to resolve these things in an informal 

23 fashion hereafter. 

24 I guess we'll do it in sequence. We will start 

25 out, for those who have the matrix in front of 
122

1 you, the first procedure, and it's really the 

2 dominant procedure that defines really the 

3 foundation for all dose reconstruction for 

4 external dosimetry and that is the OCAS 

5 implementation guide 0-0-1. 

6 And as Kathy already mentioned, there are some 

7 issues that go outside the scope of technical 

8 issues as we'd mentioned or as Kathy mentioned, 

9 we had with the board's approval defined seven 

10 different criteria that we wanted to assess these 

11 procedures, and some of them were really 

12 addressing the issue of process efficiency, and 

13 do these procedures meet that objective. 

14 We've heard all kinds of comments made by people 

15 over the last couple years at various board 

16 hearings that what's taking you so long. And we 

17 considered that an important issue. We need to 

18 resolve these dose reconstructions as quickly as 

19 possible for the obvious reasons. And so many of 

20 these issues will be somewhat subjective in 

21 nature, and there may not be a necessary 

22 resolution. It's just a comment, a criticism 

23 that we make without the expectation that we 

24 anticipate a revision in these procedures. It's 

25 just a comment, and I want everyone to understand 
123

1 that. 

2 So the first comment that we have, or issues that 

3 we identified here is the format, the structure 

4 of the document. And quite honestly, I looked at 

5 this and as a potential person who might be asked 

6 to do a dose reconstruction, and I found some of 

7 the information provided as somewhat fragmented, 

8 difficult to follow, and perhaps excessive in 

9 terms of what information would be really needed. 

10 So the first comment that you see here are 

11 deficiencies with procedural layout, the 

12 fragmented structure of the procedure, and in 

13 some instances what we consider, or I consider, 

14 excessive information that served really no 

15 purpose. 

16 And I don't want to go unnecessarily into detail, 

17 but for instance, when we talk about as an 

18 example the issue of occupational medical 

19 exposure. There are a certain number of pages 

20 dedicated in the implementation guide that almost 

21 reads like a primer on Health Physics 101 on x22 ray and so forth that really in the end should 

23 have been something that every person who's part 

24 of the dose reconstruction process has already 

25 had, fully understands, and certainly serves no 
124

1 purpose because we're not going to sit there and 

2 reconstruct an organ dose based on our 

3 understanding of milliamps and milliseconds and 

4 distances and chest wall thickness and those 

5 kinds of things. 

6 And in the end we will use always the default 

7 parameter values used in the derivation of organ 

8 doses as defined in the various documents whether 

9 it's the implementation guide, the TBDs or in 

10 TIB-0006. So again, this is just an example 

11 where I felt you have to go through an awful lot 

12 of information to get to the point where you 

13 understand what is really being offered to you as 

14 a way of procedural guidance. And so that's 

15 issue one, and as I said, it falls into the 

16 category of a subjective criticism that may or 

17 may not require any resolution at all. 

18 MR. HINNEFELD: Okay, from our standpoint, just I 

19 want to make one comment here that will maybe 

20 help us out later on. We have a generic response 

21 here that says that we don't disagree with the 

22 comment at all, but that any particular revision 

23 we would consider a relatively low priority 

24 revision to rearrange this structure. And so 

25 this first response is a sort of a generic 
125

1 response that you'll see several times down the 

2 page when we encounter a comment that we think 

3 that's in that category. Now if we've misapplied 

4 that one, you know, we don't understand that the 

5 nature of the comment or the finding at some 

6 point, we want to make sure that I point that out 

7 today because this response will occur several 

8 times down the matrix. 

9 DR. BEHLING: For instance if, for those who may 

10 have read the actual Task 3 report, when I said 

11 fragmented, for instance, to go through the issue 

12 of photons, you have to go through a whole series 

13 of steps that says first we discuss dose recorded 

14 dose. And we have to talk about dose recorded 

15 dose for photons, electrons and neutrons. And 

16 then we go from missed dose. This photon, and 

17 this was clearly identified as an improvement in 

18 PROC-006 where you aggregated them, and it was 

19 nicely done there. 

20 MR. GRIFFON: Can I make a suggestion? Where we 

21 have general agreement, unless you're disputing 

22 that, maybe we can give a very quick description 

23 of the finding so that we can get to the meatier 

24 ones. 

25 DR. BEHLING: Okay, and I think I accept your 
126

1 comments and at this point I don't think we need 

2 to discuss issue number one. Let's go to the 

3 second one and that is guidance for deriving film 

4 and TLD dosimeter uncertainty neutron dose from 

5 source term and occupational medical doses and x6 ray machine levels. 

7 Skip the second one, but talk about uncertainty 

8 because at this point as Kathy pointed out 

9 already, when we reviewed these procedures, we 

10 had no real understanding of how some of the 

11 issues that we identified would translate into 

12 the actual dose reconstruction process. 

13 And at this point in time I will say this. We've 

14 had now 60 audits of dose reconstruction reports, 

15 and some of these things have turned out to be 

16 exactly what I would have predicted. With regard 

17 to uncertainty with film dosimetry, the 

18 implementation guide gives you a lot of formulas 

19 and they give you methods by which you can 

20 calculate it if you understand what the 

21 densitometer values were and so forth. And in 

22 some cases early on when films were essentially 

23 issued to people 52 times a year on a weekly 

24 basis, the recommendation to do uncertainty would 

25 have resulted in an expenditure of time that was 
127

1 phenomenal. 

2 And clearly, now that I've had a chance to look 

3 at 60 audits, not one person has ever made an 

4 attempt to do this, and it's clearly 

5 understandable. And so my recommendation is, 

6 while it's very nice to explain what the nature 

7 of uncertainty is, but clearly no one is really 

8 capable of doing it in a practicable way. And so 

9 my recommendation here is while the uncertainty 

10 was described adequately on a technical level, it 

11 really lacks the ability to be used in a 

12 functional way. 

13 And my recommendation is to assign at 30, 40 

14 percent value that people can use when they come 

15 up with a dose, a recorded dose, and saying well, 

16 what do I put in under parameter two? And in 

17 most instances, as I said, the people have, 

18 either they've ignored it entirely and avoided 

19 the need for an uncertainty which is obviously 

20 deficiency and certainly not claimant favorable, 

21 or they've gone to the opposite direction by 

22 using the maximized approach by saying we'll 

23 multiply all recorded doses by a factor of two 

24 and that covers my need to deal with uncertainty. 

25 Now again, that might have been even appropriate 
128

1 for the instances where a maximized dose is the 

2 objective of the dose reconstruction, but when 

3 the day comes where we have to deal with best 

4 estimate, there you are, in fact, at this point 

5 no longer in a position to make use of maximized 

6 approach of multiplying the recorded dose by two, 

7 where you're now faced with having to assign an 

8 uncertainty. And I would recommend we resolve 

9 this issue by perhaps identifying a reasonable 

10 percent value as an uncertainty value for film or 

11 TLD and exempt the dose reconstructor from having 

12 to go through this tedious process. 

13 MR. GRIFFON: It's a little more extensive than 

14 what's here. 

15 MR. HINNEFELD: Right, now our response really, 

16 response to the parts other than the uncertainty 

17 part of the comment, and I think I just neglected 

18 to include our uncertainty response in it. If 

19 you look at finding number IG-004, we said that 

20 we feel like the IG, the implementation guide's 

21 uncertainty description should support what is 

22 being done, as you say, in the dose 

23 reconstructions you look at. Let's have a 

24 discussion that supports that uncertainty if it's 

25 not been prepared yet. We're suggesting we'll 
129

1 revise the IG, take out this uncertainty language 

2 and insert a basis for what is being done in dose 

3 reconstruction. 

4 DR. BEHLING: And I also wanted to say it's a 

5 discussion that we could probably spend the 

6 balance of this afternoon on just by itself. The 

7 uncertainty as I found out was really not a 

8 complete uncertainty that did not address, for 

9 instance, a radiological uncertainty or 

10 environmental uncertainty. It seems that it was 

11 mostly based, or the formula that were given were 

12 essentially dealing with the laboratory 

13 uncertainties. 

14 MR. HINNEFELD: Right, you're jumping ahead. 

15 That comes up later. 

16 MS. BEHLING: The other thing that we also 

17 recognize is the workbooks, the workbooks that 

18 are being developed, the best estimate-type 

19 workbooks, do take into account the uncertainty 

20 on the dosimetry, the attempt to do that with 

21 Monte Carlo and crystal ball runs. However, 

22 based on this particular document, that's where 

23 the comment of uncertainty comes in. 

24 MR. GRIFFON: I think the other thing I see 

25 repeated and for OCAS-IG-001, and also that I 
130

1 think we should keep in mind is that it's a 

2 general guidance document, right? 

3 MR. HINNEFELD: Yes. 

4 MR. GRIFFON: So there is, I see that reflected 

5 in your response several times that, yeah. 

6 MR. HINNEFELD: There's language in that document 

7 that would lead you to conclude that, so a dose 

8 reconstructor is supposed to be looking at this 

9 when he does dose reconstructions. But that's 

10 really not the intent. The intent is this is 

11 general guidance for performing dose 

12 reconstructions, and so, we're not really trying 

13 to write a step-by-step procedure in IG-001. 

14 DR. NETON: Right, I can address that a little 

15 better. I was largely responsible for working 

16 with the person who drafted this document early 

17 on. And that's exactly the intent was to lay out 

18 the framework for general concepts and what 

19 issues need to be addressed. And then the 

20 subsequent procedures that are based on them 

21 would flow from them and be more general and use 

22 the efficiency process and that sort of thing. 

23 But at some point I thought we felt the need to 

24 at least address these higher tier issues some 

25 place. And it's an implementation guide, very 
131

1 similar to what you see in either DOE or NRC 

2 facilities where the implementation guides 

3 themselves, they're not really useful to a person 

4 in the field trying to do a job. It's a policy, 

5 not a policy, but it's a technical basis almost. 

6 MS. BEHLING: And I believe actually when we 

7 started to review this, I think we agree with 

8 that we understand that was the intent. However, 

9 when we started doing the dose reconstructions, I 

10 don't think there's a dose reconstruction that 

11 we've looked at that they don't reference the 

12 implementation guide. They seem to use the 

13 implementation guide quite a bit. 

14 MR. GRIFFON: So what do we say about the second 

15 finding? Is there agreement there with NIOSH's 

16 response? 

17 MR. HINNEFELD: In our response remember, we also 

18 have the uncertainty edit that should be part of 

19 this response. 

20 MR. GRIFFON: In part number four. 

21 MR. HINNEFELD: In part number four, that also 

22 relates to the -- 

23 MS. BEHLING: I said this is the first time we've 

24 had a chance to read the responses. 

25 DR. BEHLING: Are we prepared to go to the third 
132

1 item? 

2 MS. BEHLING: They want to know if we're in 

3 agreement. 

4 MR. GRIFFON: Is there agreement on number two? 

5 DR. BEHLING: Yes. 

6 MR. GRIFFON: Okay, then go to the third item. 

7 DR. BEHLING: Again, this is a relatively easy 

8 one to resolve. The issue here is one of the 

9 implementation guide provides inadequate guidance 

10 for classifying a case as potentially less than 

11 or greater than 50 percent POC and should 

12 identify the role of the Task 2 personnel. 

13 When I first looked at, and I looked at, 

14 obviously, the regulations and they clearly 

15 spelled out that there'll be different tiers of 

16 dose reconstruction based on efficiency, the need 

17 for efficiency and so forth. And that the 

18 question I had in reading the implementation 

19 guide, it doesn't really offer you the 

20 opportunity to say how will we differentiate a 

21 maximized dose that is likely to be less than 50 

22 percent from one where best estimates apply and 

23 the implementation guide didn't address it. 

24 Obviously, the procedure number six clearly 

25 identifies that in a series of appendices. So 
133

1 again, this is an issue that I identified because 

2 the implementation guide was the very first 

3 document I reviewed. And had I had the benefit 

4 of seeing everything up front, I probably would 

5 have deleted that as an issue. So it's a 

6 question of learning things as you go along, and 

7 I don't think this really requires any -- 

8 MR. GRIFFON: There's agreement there, okay. 

9 Number four. 

10 DR. BEHLING: Number four, again, we're going 

11 back to TLD uncertainty, and I just took a couple 

12 issues here. For instance, in the TLD 

13 uncertainty it defines an equation for mu sub n 

14 and mu sub e, or something that should be 

15 obtained from your local DOE, DOELAP-accredited 

16 health physicist. And I found that, first of 

17 all, two problems with that. It's not something 

18 that you should call somebody who was involved in 

19 DOELAP accreditation to get the answer to. 

20 And second, if you're talking about DOELAP 

21 accreditation for a TLD that was done in the 

22 early 1990s, how is that applied to a TLD system 

23 that was used in the '70s, and it's questionable. 

24 So that's really where the issue is here. One of 

25 discrepancy in terms of time and the availability 
134

1 of data that should be made available in the 

2 procedures so that people wouldn't have to 

3 necessarily consult somebody within a DOE complex 

4 in arriving at variables that are necessary for 

5 defining uncertainty. So it goes to the same 

6 issue we addressed earlier. 

7 MR. GRIFFON: In your response, NIOSH's response, 

8 it seems like this is more than simply a matter 

9 of modifying language. 

10 MR. HINNEFELD: Well now, in this case I believe 

11 it is. I mean, there's, the discussion that is 

12 in the implementation guide, you know, the 

13 offending passages, don't really provide 

14 direction on how to accomplish anything. And so 

15 from our standpoint, you know, we have a pretty 

16 standard approach to uncertainty on these 

17 measurements, and that's used typically in each 

18 of the site profiles or in one way or another 

19 will describe what the uncertainty approach 

20 should be on measured doses, and we have a basis 

21 for that. 

22 And so the IG should write that basis not this 

23 various other conversation about potential ways 

24 to do uncertainty. And so to my way of thinking 

25 this is really a language change, but the IG 
135

1 should describe the basis for what we're doing in 

2 uncertainty rather than these other passages 

3 about uncertainty that don't, that really don't 

4 tell us what to do for what we're doing. 

5 MR. GRIFFON: Do you agree with that response? 

6 DR. BEHLING: Yes. 

7 MS. BEHLING: Number five of the implementation 

8 guide indicates that what we're just suggesting 

9 here that the LOD values, I believe the 

10 implementation guide had suggested a ten 

11 milligram in the early, well, '56 through '60 as 

12 an LOD value. And based on other technical basis 

13 documents and other references that we looked at, 

14 it just appeared to us that that was a low value. 

15 And I guess in retrospect, as I said, when we 

16 started doing the dose reconstruction reports we 

17 realized that they often do use the TIB 008 and 

18 the TIB 0010 which does recommend the 40 

19 millirem. But it just seemed that there was a 

20 little bit of a discrepancy with the 

21 implementation guide in the fact that these early 

22 years were just such lower LOD values such as ten 

23 millirem as opposed to 40 as a minimum. 

24 DR. BEHLING: And just for clarification, Table 

25 2.1 of the implementation guide provides LOD 
136

1 values for '56 through 1960 that went from 30 

2 millirem to ten millirem. And I have a difficult 

3 time being part of, or having been part of the 

4 dosimetry program at various locations that as 

5 early as 1960 you would find an LOD value for a 

6 film at ten millirem. And again, it's 

7 inconsistent with TBD values that identify site8 specific values. And for that time period 

9 usually you end up with 40 millirem as the 

10 standard LOD value that is used throughout the 

11 complex. So it's just a statement here. 

12 As I said most people when they go to LOD values 

13 from this dose, whether it's LOD over two or just 

14 N times LOD, they usually cite site-specific 

15 information which makes this particular statement 

16 in the implementation guide a question we should 

17 -- 

18 MR. HINNEFELD: Right, I think from both finding 

19 number five and finding number 6, I believe 

20 their, the intent of the passages in the IG are 

21 to provide illustrative, you know, an 

22 illustration of a concept as opposed to a 

23 recommended value for LOD. So it's the, you 

24 know, in one part it illustrates this is the 

25 effect of a lower limit of detection or a less 
137

1 frequent badge exchange on the missed dose 

2 number. And so I think these are both sort of 

3 examples or illustrations, but without the intent 

4 that the actual LOD values are recommended values 

5 to be used. 

6 MR. GRIFFON: And I think to me it does sort of 

7 read that way. I mean, it's a Rocky Flats, you 

8 know. It actually says in one paragraph before 

9 the table, at least for the one on page 31, so 

10 you know. 

11 MS. MUNN: This is one that I'd like it if you 

12 really emphasized, illustrate, in your response 

13 there, Stu. I think as I read it if the word 

14 illustrate jumps out at me then it's very clear 

15 to me, and I think even to any casual reader it 

16 would be clear that you're not, even though you 

17 say later, not recommending. A little emphasis 

18 on illustrate would be appreciated. 

19 MR. HINNEFELD: Okay, in the language of the IG? 

20 MS. MUNN: Yeah. 

21 DR. BEHLING: The next one is just a statement 

22 that -- 

23 MR. GRIFFON: You agree with that five, right? 

24 DR. BEHLING: Right, right. 

25 The next is just a statement that refers to LOD 
138

1 values given in the implementation guide as being 

2 one and the same whether it's for photons and for 

3 deep dose photons as well as for the shallow dose 

4 which may be low energy photons or betas. And 

5 then I guess for anyone who's familiar with the 

6 dosimetry system that's not necessarily the case. 

7 We usually assume that the degree of sensitivity 

8 for shallow dose is not quite up to that level of 

9 the deep dose and that's really a comment. But I 

10 think you address, your response is acceptable as 

11 it stands. 

12 MR. GRIFFON: Okay. 

13 DR. BEHLING: The next one is finding number 

14 seven and it deals with the NTA film dosimeters, 

15 the limitations as defined by their response. 

16 And again, the implementation guide like so many 

17 of the other TBDs identify 500 keV as a threshold 

18 for being able to detect neutrons and producing a 

19 track that is observable under a light 

20 microscope. 

21 And I looked at the early documents including 

22 information that's contained in some of the 

23 classic textbooks like Hine and Brownell, and 

24 they identify something that is considerably 

25 higher, 800 maybe to 1,000 keV which would be a 
139

1 threshold that would expand the area of 

2 uncertainty for various neutron spectra 

3 associated with reactor sites. And so that's the 

4 reason I brought it up here. And it's also an 

5 issue that needs to be somehow other explained. 

6 Even if we accept a certain threshold, that 

7 doesn't mean that once you cross that threshold 

8 that your ability to observe an exposure is the 

9 same. There's a steep dose response gradient 

10 between 500, even if it is, in fact, something 

11 that on occasion you may be able to observe a 

12 track that is a result of a 500 keV neutron. 

13 The likelihood of seeing that in the terms of 

14 dose response and put it on equal footing for 

15 tracks that may be generated by neutrons between 

16 one and two MeV is considerably different. And 

17 that's really not always clearly stated. In 

18 fact, the casual observer would read that if you 

19 exceed 500 then everything is on an equal level. 

20 It is not. And I think in so many of the TBDs, 

21 including in the Savannah River site, you do show 

22 the steep dose response gradient that's above the 

23 threshold level and that let's you know that 

24 you're really operating in the dark. 

25 And of course, the whole issue also centers 
140

1 around the use of NTA film. At least for many of 

2 the facilities, NTA film has been viewed with 

3 skeptical, with a skeptical perception of how 

4 accurate is it, and therefore, completely ignored 

5 in favor of neutron-photon ratios. And so again, 

6 the question comes in why even bother for those 

7 facilities where NTA film has been used but 

8 acknowledged as unreliable, and therefore, the 

9 surrogate methodology involving neutron-photon 

10 ratio was adopted. 

11 And I have no comments beside that other than in 

12 so many of the TBDs the issue is resolved by 

13 saying we're not even going to use it. We're 

14 going to use something that is more, obviously 

15 more practical. 

16 MR. HINNEFELD: I don't disagree with anything 

17 you said. 

18 MR. GRIFFON: So the only clarification I want is 

19 on your response it says interpretation of the 

20 NTA film dosimetry results probably require site21 specific evaluation. I mean, is that, what is 

22 happening? It's all individual site-specific? 

23 MR. HINNEFELD: Well, the TBDs will generally 

24 describe like Hans was saying, some of the TBDs 

25 say NTA film was used before this date because of 
141

1 the nature of the spectrum they were exposed to. 

2 We're not even going to worry about it because we 

3 don't think it was effective at all, and so we're 

4 just going to use neutron to photon ratios for 

5 that period of time, so -- 

6 MR. GRIFFON: Maybe the guide should give that 

7 clarification, too, that -- 

8 MR. HINNEFELD: I think we could make an edit to 

9 IG-001 to make it more clear that we don't 

10 necessarily think 500 is a magic threshold and 

11 once you hit 500 everything's hunky dory. I 

12 mean, we could say that. I would make that kind 

13 of a low priority edit because we're behaving, by 

14 writing site-specific TBDs that address it for 

15 that site the way that we think we should behave 

16 anyway, I think, is what I believe I'm hearing. 

17 And so I would make that edit IG-001 relatively 

18 low priority because we seem to be, you know, 

19 it's going -- 

20 MR. GRIFFON: Probably a low priority, but it 

21 would be nice if it was consistent with the 

22 practices down through the chain. Yes, I agree. 

23 You agree? 

24 DR. BEHLING: (no audible response) 

25 MR. GRIFFON: Okay, next. 
142

1 DR. BEHLING: The next one is number eight, and a 

2 summary of this issue here is methods for a 

3 reconstruction of neutron doses from survey data 

4 or source term data do not appear practical, 

5 achievable and defensible. In a sense what I'm 

6 really saying is that Appendix B has a huge 

7 citation of neutrons' fluence and their 

8 conversion, and quite honestly, we all know that 

9 when we go into a facility based on time and 

10 space, time and space, the dose rate from 

11 neutrons is highly variable. 

12 And the option of even calculating an exposure 

13 for a person who may have worked there for years 

14 without knowing where he was, when he was there, 

15 how long he was there from neutron fluence, while 

16 it has some theoretical merit in discussing, has 

17 no practical value in dose reconstruction. And I 

18 would venture to say at this point we will never 

19 see an instance where somebody's going to be or 

20 where neutron dose reconstruction will take place 

21 with regard to a neutron fluence assessment or 

22 going through the motions as defined in Appendix 

23 B. 

24 Now the exception to that might be a person who 

25 works in a calibration laboratory where he has a 
143

1 mono or a fixed source that produces neutrons of 

2 a certain energy spectrum, and we can at least, 

3 you know, under the most extreme conditions if 

4 the person wasn't monitored, reconstruct it using 

5 a bounding value. That would be the exception I 

6 would take. But for a person working in a 

7 reactor facility I would say the use of that 

8 whole process would be an ambitious process to 

9 say the very least. 

10 MR. HINNEFELD: I agree. I'm proposing we change 

11 the wording to more accurately describe what we 

12 do. 

13 MS. MUNN: I would point out -- this is Wanda -- 

14 that we very likely may have such an instance as 

15 Hans referred to with respect to laboratories and 

16 sources and a variety of folks. We have an SEC 

17 that probably is coming up, it will be almost 

18 precisely what you were talking about. 

19 DR. BEHLING: As I've said, I'm not exempting all 

20 conditions from the use of that methodology but 

21 at least for a large category of workers in and 

22 around reactors whether it's at Hanford or at 

23 Savannah River. I would say this is a very 

24 ambitious approach to doing dose reconstruction, 

25 and I don't believe for a moment people would 
144

1 actually choose to use that methodology. 

2 If everyone agrees, we can go to the next issue 

3 number nine, and I guess the center of that 

4 particular statement is that at most facilities 

5 neutron exposures were generally less than 20 

6 percent of photon exposures. Now we do know that 

7 that's not necessarily the case, but again, it is 

8 not likely that this particular statement will be 

9 used for a dose reconstruction. It was, 

10 therefore, a statement that is generically a 

11 statement that may or may not necessarily be 

12 true. 

13 But for real dose construction people would, in 

14 fact, go to the TBD that defines the particular 

15 facility and look at the various locations in 

16 defining what the neutron-to-photon dose ratios 

17 are as are clearly defined in all the TBDs along 

18 with the ICRP correction factors, et cetera. So 

19 again, it's just a statement that I'm not sure it 

20 serves a purpose here in giving people the 

21 illusion that neutrons are always less than 20 

22 percent of photon doses. 

23 MR. GRIFFON: And there's agreement. 

24 MS. MUNN: Can we just simply take out 20 

25 percent? 
145

1 DR. BEHLING: Yeah, yeah. 

2 Yeah, the next one is issue number 10, and it 

3 refers to Appendix B DCFs for bone surface and 

4 red marrow. And again, if I look at some of the 

5 earlier work, especially for low energy photons 

6 where the photoelectric interaction dominates, 

7 the fact is when you have, whether it's an AP 

8 geometry exposure, the instant photons when they 

9 go through the skin and adipose tissue and the 

10 muscle tissue and finally strike the bone, there 

11 is a much increased probability of an interaction 

12 by means of the photoelectric effect which raises 

13 at the interface the actual dose of the bone 

14 surface by a considerable margin, up to, at the 

15 point of transition between soft tissue and 

16 mineralized bone you will see a steep gradient in 

17 terms of the actual dose, which for certain types 

18 of bone cancers would apply here in terms of the 

19 DCF. 

20 In fact, I brought with me some of the actual -- 

21 and I cited Hine and Brownell for that. And I 

22 brought the original document as photocopied from 

23 Hine and Brownell with me. You will see 

24 instances where the actual bone surface dose far 

25 exceeds the entrance dose. And so that was not 
146

1 brought out if I look at the DCF in Appendix B 

2 for the low energy photons, the DCF does not 

3 reflect a much enhanced dose that involves the 

4 photoelectric interaction at lower energy 

5 photons. Again, this is something that you may 

6 want to look at or correct. 

7 MR. HINNEFELD: Yeah, this is one that I think we 

8 want to study and probably talk about some more 

9 after today because I'm not sure we're going to 

10 be able to reach a resolution today. ICRP 74 

11 does talk about electronic equilibrium in those 

12 bone surface dose part at least, not necessarily 

13 in the marrow dose part, but in the bone surface 

14 dose. And they describe, you know, the 

15 electronic equilibrium and all, the nature of the 

16 comment you brought up and in the document that 

17 is the basis for the DCFs that we used. 

18 So our belief is that ICRP probably was aware and 

19 incorporated it appropriately as they describe in 

20 their finding. But you know, we're just kind of 

21 sorting through that now, and I think we'll need 

22 to exchange some more messages about a final 

23 outcome here. You know, our comment here is 

24 that, you know, ICRP, we consider that pretty 

25 definitive. 
147

1 DR. BEHLING: I agree with you. I looked at 

2 ICRP, and they do acknowledge it but don't do 

3 anything about it. And saying no, we're not 

4 going to address that as an issue. 

5 MR. HINNEFELD: Well, in the bone surfaces they 

6 say that we're going to call it bone surface like 

7 average of the bone dose or something like that 

8 so it's covered. But they don't, they don't say 

9 anything about it in the bone marrow dose which 

10 is also, and the effect on the bone marrow is 

11 going to be a function of the size of the cavity 

12 that the bone marrow resides in. 

13 And so the key question then, essentially, what 

14 is the average size of the cavity that bone 

15 marrow resides in because all these doses are 

16 average anyway. So what's the average size and 

17 that would be the extent of the effect. So I 

18 think we'll take a little more time to look at 

19 it, and then we'll talk to you about -- 

20 DR. BEHLING: It's a requirement that may or may 

21 not be something that is significant here. I 

22 brought it up because the early work, and I'm 

23 very familiar with it, with the Spiers' work in 

24 '49. And then again it goes back to what Stu was 

25 just mentioning, electron equilibrium. 
148

1 And when you talk about a marrow cavity that's 

2 less than ten microns in diameter, the electrons 

3 generated in the bone matrix is what liberates 

4 its energy in the cavity itself. And therefore, 

5 for a very small cavity you essentially have an 

6 electron equilibrium value that is similar to 

7 that of mineralized bone as opposed to soft 

8 tissue. 

9 If the marrow cavity is very large, it reaches 

10 again an equilibrium that is one of soft tissue 

11 and you average out the dose over a hundred, two 

12 hundred micron cavity that, in effect, becomes an 

13 average dose to soft tissue as opposed to 

14 mineralized bone. It's a moot issue. It's a 

15 small issue. I'm not sure if you want to address 

16 it, but I've raised it as an issue because I 

17 happen to know Spiers' work. 

18 Item number 11, implementation guide does not 

19 account for additional laboratory uncertainty for 

20 film badge readings associated with exposures 

21 less than 200 millirem. And I think in looking 

22 at the National Research Council's report, they 

23 do address that as a separate issue in saying 

24 that the uncertainty is much higher for low 

25 energy photons. But on the basis of certain 
149

1 considerations that NIOSH gave to this issue 

2 decided that it was not something that they were 

3 going to address. And then I just raised it 

4 because again, I'm quite familiar with the 

5 National Research Council's report, '89 report, 

6 on film badge dosimetry and the uncertainties as 

7 discussed in that report. And I just raised it 

8 here as an issue, but they addressed it as an 

9 uncertainty and NIOSH decided not to. 

10 MR. HINNEFELD: Yeah, and this will be part of 

11 the rewrite of the uncertainty part. There are 

12 several uncertainty sections of IG-001 that are 

13 commented on and our general rewrite of our 

14 uncertainty language needs to address this as 

15 well. And there's a sentence in the response to 

16 IG-001, finding number 16, the last sentence 

17 there really I think is relevant to this comment 

18 rather than 16 when you're talking about the 

19 NAS's, NRC NAS's additional uncertainty at low 

20 energy. 

21 So it's actually the additional uncertainty 

22 because of it's a field badge versus a laboratory 

23 badge, and it is most prominent. And these 

24 effects are more prominent. The higher 

25 uncertainty is more prominent in lower doses. 
150

1 It's part of that whole, everything we have to 

2 address and rewrite the uncertainty part. 

3 DR. BEHLING: In fact, there were a couple minor 

4 errors associated with the discussion of 

5 uncertainty where they referred to environmental 

6 uncertainty, and they ended up deferring to 

7 environmental exposure as environmental 

8 uncertainty in the context of the NRC report. 

9 Environmental uncertainty involves issues such as 

10 heat, humidity and other physical and chemical 

11 potential issues that may affect the performance 

12 of a badge. And it does not involve the term 

13 environmental dose as we define it in the 

14 implementation guide. And so it was just a mix15 up of sorts. 

16 The next one is obviously a very important one, 

17 at least from my point of view, and I believe 

18 NIOSH is going to look at this. The issue 

19 centers around the dose conversion factors as 

20 defined in Appendix B or Attachment A in PROC-006 

21 which are identical. 

22 I looked at those and obviously there are some 

23 problems here with defining how to convert a 

24 reading from a film dosimeter or a TLD into an 

25 organ dose. The assumption based on the 
151

1 implementation guide is that we all start out 

2 with an air dose, which is not correct, in free 

3 air nevertheless. When, in fact, the readings 

4 that we're going to be starting out with are 

5 readings that involve either a film or TLD badge 

6 that's worn, meaning that it has also, is subject 

7 to attenuation by the human body and other 

8 factors that will obviously have some profound 

9 impacts in converting a dose, for instance, in a 

10 PA geometry, isotropic and rotational. And I 

11 assume, based on the comments that NIOSH 

12 submitted, that some amendments will be made. A 

13 reasonably quick and dirty one would be to resort 

14 to AP geometry as a dose conversion factor for 

15 all geometries independent of what you might 

16 think they should be. 

17 MR. HINNEFELD: Well, and we're actually haven't 

18 been able to convince ourselves that that is the 

19 most claimant favorable in all conditions. We've 

20 done that much work to recognize it. Our first 

21 thought was let's just use AP, you know, no 

22 matter what we use, AP geometry does correction 

23 factors. And we're not entirely sure that that 

24 is claimant favorable in all conditions. 

25 DR. BEHLING: Not always. 
152

1 MR. HINNEFELD: Right, so we've got some work 

2 underway, but it's very preliminary, and I'm 

3 really not prepared to talk about it at any 

4 length except to say that, yeah, this is 

5 certainly a valid comment, and we are pursuing 

6 edits to resolve it. 

7 DR. BEHLING: I think we can already address the 

8 issue 13 in conjunction with 12, so the two of 

9 them come together so we'll skip 13. 

10 Item number 14 is angular sensitivity not 

11 accounted for in correcting measured film or TLD. 

12 Again, I went back to some of my own studies 

13 early on in my career. I also looked at Hine and 

14 Brownell. And clearly, film dosimeters as well 

15 as TLD are normally calibrated in a laboratory 

16 under the most ideal conditions, meaning that you 

17 have an instant beam of radiation that is at 

18 right angles to the face of the badge, and that 

19 obviously gives you the maximum response in most 

20 instances. 

21 On the other hand reality dictates that when you 

22 look at a TLD that's worn by an individual in a 

23 radiologic environment, even if it's a single 

24 point source, he will rotate through his own 

25 axis, 360 degrees, over a period of a week, a 
153

1 month or however long the badge is worn, and you 

2 realize that the exposure is not one of ideal 

3 exposure conditions. Under those circumstances 

4 when you look at, for instance, low energy 

5 photons, especially those that are heavily 

6 impacted by the 1,000 milligram filter that 

7 overlies the sensitive portion of the TLD or 

8 film, that you would potentially underestimate. 

9 And some of the underestimates are fairly 

10 substantial, especially when you approach the 90 

11 degree or 180 degree. And so I raised it up, I 

12 raised that as an issue. I provided some data 

13 with that from Hine and Brownell that identifies 

14 the dose response in various angles which are 

15 substantially less than unity when compared to 

16 the 90 degree on-face exposure. 

17 I did look at Fix, by the way, who is a very, 

18 very knowledgeable person and did an awful lot of 

19 the work on behalf of the Hanford site as well as 

20 other facilities. And one of the things that did 

21 bother me a little bit about him -- and I do 

22 respect his knowledge. He's a very, very 

23 intelligent person without ever having met him 

24 but reading his documents. He's clearly an 

25 expert on dosimetry. But he does make a point 
154

1 that when you have a film badge that is 

2 irradiated at a 90 degree angle that the 

3 processor would instantly recognize that. 

4 Well, that's true if you're going to be giving 

5 somebody a film badge and says you will not move 

6 from 90 degree to this one source. The truth of 

7 the matter is when you have a film or a TLD in an 

8 environment that has either multiple sources or 

9 you just walk around, you're going to have only a 

10 portion of the exposure that will impact a 90 

11 degree, a 180 degree. Which means that this will 

12 not be recognized, and the very, very low values 

13 at those extreme angles are masked by exposures 

14 of angles other than those. 

15 So I take exception to his comments that you can 

16 ignore the response at these extreme angles 

17 because the processors would recognize it. Well, 

18 that's kind of ludicrous because no one's going 

19 to be exposed for a period of a week, a month, or 

20 even a quarter at exactly 90 degrees which would 

21 reveal the exact angle of exposure. 

22 And that's the only comment I have because we 

23 talked about the issue of angles sensitivity 

24 before, and I guess NIOSH questioned the value 

25 cited in Hine and Brownell as perhaps being 
155

1 extreme. And I would just caution you that Fix's 

2 assessment of the 180 and 90 degree angles are 

3 not legitimate in the real world where people are 

4 going to be exposed not just at 90 or 180, but at 

5 all angles. And the ability to discern whether 

6 or not a certain portion of the exposure was 

7 received at those extreme angles is lost and 

8 would not be known to the person who's processing 

9 these films. 

10 MR. HINNEFELD: Well, we're including this 

11 angular dependence of the badge in the product 

12 that we described in the last two. 

13 DR. NETON: I agree with you. I think the range 

14 of error that could be made was cited at some of 

15 those extreme angles in your own review report, 

16 so you're, the magnitude of the error was 

17 asserted at those extreme angles implying that 

18 the error could be that large because a person 

19 was indeed exposed at those extreme angles. So 

20 we're just trying to respond in kind. 

21 DR. BEHLING: Yeah, if you were to use an 

22 aggregate which would essentially be represented 

23 by a person who is on a rotational exposure 

24 geometry, it could prove to be that for at least 

25 very low energy photons which are most effective, 
156

1 and clearly, as Hine and Brownell data and Fix's 

2 data show, he used 70 and 150 keV or 120 keV 

3 photons, they can be up to 30, 40 percent. 

4 DR. NETON: That was our point. These extreme 

5 examples where you -- could be a factor of four 

6 or whatever. 

7 DR. BEHLING: Yes, yes, no, I agree. I mean, I 

8 wouldn't use, for instance, an interdependence as 

9 cited by Hine and Brownell of 0.12 at the extreme 

10 end or edge of the low sensitivity. Of course, 

11 that would not be appropriate. But something on 

12 the order of 30, 40 percent as an average value 

13 for all angles that would be essentially 

14 representative of rotational geometry is not 

15 unreasonable as an uncertainty component. 

16 MR. GRIFFON: Let me just ask, you said that, I 

17 mean, this, unlike some of the other ones, the 

18 earlier ones, that you said were not priority 

19 changes, this seems like it might be a higher 

20 priority. Is there any sense of how, what kind 

21 of timeline we're looking at or how many, could 

22 this affect cases that have already been, the 

23 geometry's completed for? 

24 MR. HINNEFELD: I really hesitate to give a time 

25 frame today because like I said, we have some 
157

1 very preliminary products, but to be honest with 

2 you, I haven't even read them all yet. But I'm 

3 not ready to decide -- 

4 MR. GRIFFON: But it's a higher priority. 

5 MR. HINNEFELD: Oh, yeah, when I'm talking about 

6 things I think I consider low priority edit, 

7 that's like things I'll get to when I have time, 

8 you know, if I get to them. There are probably 

9 even three classifications you could put in here. 

10 This is really an important one. You know, 

11 resolving this issue and getting a correct answer 

12 or correct number down is an important response 

13 here. You know, there are some others that may 

14 fall in a middling category like the uncertainty 

15 where, you know, we're already behaving 

16 appropriately in uncertainty. That's kind of a 

17 middling sort of thing. But this is an important 

18 one and I think will resolve. 

19 MR. GRIFFON: I was thinking the same thing. The 

20 uncertainty kind of fell in the middle, so this 

21 one was a higher one. Okay, just getting the 

22 sense of -- 

23 DR. NETON: I'd just like to point out that if we 

24 increase the uncertainty on the external doses, 

25 it's not likely to affect many decisions because 
158

1 the uncertainty in the external doses probably is 

2 the smallest component of the uncertainty in all 

3 of these calculations even if we doubled the 

4 uncertainty or more. So it really, it has most 

5 impact when we actually change the estimate of 

6 central tendency as opposed to increasing the 

7 uncertainty bands really is not going to change 

8 much at all in the decision-making process. 

9 MS. BEHLING: The other issue with this, with the 

10 DCFs being an important issue as you just 

11 mentioned, Mark, is the fact that as you said for 

12 most of these min-max cases we are using the AP 

13 geometry. But when we are looking at the best 

14 estimates, and we're looking at doing these using 

15 the workbooks, then a lot of DCF information does 

16 come into play. And so, as you said, it does 

17 have to be a higher priority. 

18 DR. BEHLING: If we can go on to item 15. It 

19 deals with backscatter, and again, I can't speak 

20 on behalf of everything but, or all the TBDs, but 

21 at least on behalf of the Savannah River site for 

22 one, it's identified that on-phantom calibration 

23 started in the mid-1980s and there's a correction 

24 factor. And I believe they used something like 

25 11 point something, three decimal points, 
159

1 whatever, and I looked at the issue of the 

2 backscatter. 

3 And it's clearly a very complex issue. It's 

4 energy dependent for sure. It's going to be a 

5 function of the scattering medium and the 

6 physical dimensions. And I provided some 

7 information that comes out of Hine and Brownell 

8 again in our report. It's on page 47, figure 

9 2.1-6. And you see that you can receive 

10 backscatter factor for a very large person and 

11 for certain types of energies that are up to 40 

12 percent. And again, the question is is the 11 

13 percent a conservative, claimant favorable 

14 adjustment factor for on-phantom calibration, and 

15 that's the only reason I raised it. 

16 MR. HINNEFELD: Well, the 11 percent was actually 

17 a combination of factors. There were a number of 

18 things that changed that year and not only the on 

19 calibration phantom. I think calibration energy 

20 changed, and so that was actually an evaluation 

21 that was done by Savannah River, I believe. In 

22 terms of maybe our doses, our recorded doses, 

23 should be adjusted by that much which we've 

24 adopted. But it was a combination of factors and 

25 not strictly, not only changing to on-phantom 
160

1 calibration. 

2 So I think -- now Jim, if I say something wrong 

3 here, help me out -- but I think before if a 

4 facility's using a free-in-air calibration, our 

5 approach would be that well, that, they're then 

6 calibrating with an exposure measure not a rem 

7 measure and so the dose conversion factor that 

8 should be used is the exposure to HP 10 dose 

9 conversion factor. I think that's generally how 

10 we would deal with on air calibration or in air 

11 calibration versus an on-phantom calibration. 

12 DR. NETON: Right, if the phantom were present, 

13 it would backscatter into the badge. You would 

14 have a higher result. 

15 DR. BEHLING: Yes. 

16 DR. NETON: And so it would be under, it would be 

17 conservative to not have that included in the 

18 phantom calibration than if it were worn on 

19 another person's badge. So it would be claimant 

20 favorable. 

21 DR. BEHLING: There is some limitations with 

22 regard to backscatter since most of the film and 

23 TLD actually had a filter on the backside as 

24 well. So your 180 degree backscatter photons, 

25 especially from low energy photons, would in 
161

1 essence probably not even penetrate the backside 

2 of your film, so it's just a side issue. 

3 I guess we can leave it at this. I just thought 

4 that the 11 percent adjustment factor for pre5 1985 for in the case of Savannah may not 

6 necessarily be the most claimant favorable, but 

7 if there are data that suggests it was done on 

8 the basis of empirical measurements, I will 

9 accept that. 

10 MR. HINNEFELD: I'm sort of speaking from memory 

11 on that, but I know there were a number of things 

12 that changed. It wasn't strictly an on, 

13 switching from free-in-air to on-phantom. That 

14 change occurred, but there were other things that 

15 changed that year as well. 

16 DR. NETON: Right, there was a fairly systematic 

17 review done by Savannah River. We could produce 

18 that, I think, if need be. 

19 DR. BEHLING: Item number 16, I think we've 

20 already discussed. That is the environmental 

21 uncertainty that is the result of physical and 

22 chemical factors such as heat, humidity, light, 

23 et cetera. It was not addressed in the 

24 implementation guide. On the other hand we've 

25 already discussed that in a couple of previous 
162

1 issues as a part of a missing discussion and 

2 involving uncertainty that includes radiological 

3 such as the angle sensitivity or environmental 

4 uncertainty that was not discussed in the 

5 implementation guide. 

6 Item number 17, I'm going to have to, I'm drawing 

7 a blank here. The issues as cited in the matrix, 

8 I'd have to probably go back to the actual 

9 report. It states guidance for selection of 

10 uncertainty distributions for total organ dose 

11 raises question of consistency and requires 

12 professional judgment. And I'm trying to figure 

13 out what the purpose of that was or what the 

14 basis was. 

15 MR. GRIFFON: I guess the NIOSH response is the 

16 key here, too. 

17 DR. BEHLING: Okay, let me take a look. I 

18 haven't looked at that yet either. 

19 DR. MAURO: Excuse me, Hans? 

20 DR. BEHLING: Yes, sir. 

21 DR. MAURO: Can you hear me? 

22 DR. BEHLING: Yes, I can. 

23 DR. MAURO: We're all, the people on the line are 

24 not, sorry, the connection went bad, and we can't 

25 really hear you although now that I'm talking to 
163

1 you I can kind of hear you. But what’s gone on 

2 the last five minutes, hardly were able to hear 

3 you and you're going in and out. My guess is 

4 we're experiencing the same thing we experienced 

5 the last time only that was the focus that time 

6 on Mallinckrodt. I don't know if there's 

7 anything you can do about what we’ve done like on 

8 Mallinckrodt. For some reason we were fine this 

9 morning, but right now we're having a very, very 

10 difficult time hearing anything. 

11 DR. WADE: Well, you're very clear right now, 

12 John, so... 

13 DR. MAURO: Lew, are you hearing them well? 

14 DR. WADE: No, I had the same problem the last 

15 five minutes. 

16 DR. MAURO: Okay, so just to let you know, I 

17 don't know if there's anything you can do about 

18 it over there at your end or something's changed, 

19 something's happening with the communication, but 

20 I got a call also from Kathy DeMers who also is 

21 having the same problem. She called me on my 

22 cell phone. If there's anything you can do about 

23 it great, otherwise we'll just try our best to 

24 listen in. 

25 DR. WADE: Right, yes, please proceed. 
164

1 DR. BEHLING: Yeah, I try very hard, in fact, I 

2 have a tendency to shout at times, and so 

3 hopefully by being very close to the mike this is 

4 not going to, you're not going to lose the signal 

5 here. 

6 DR. MAURO: Yeah, that's a lot better. If you 

7 could keep doing that, that would be great. 

8 DR. BEHLING: Okay, I'm going to have to tell 

9 Kathy that too because she has a tendency to shy 

10 away from the mike here. 

11 MS. MUNN: But we had something on the line that 

12 was really creating a problem there for awhile. 

13 I think they went away whoever they were. 

14 DR. MAURO: No, there's actually static. I mean, 

15 now that you're -- I'm sorry to interrupt again, 

16 but as long as you're close to the mike and 

17 speaking loudly, we can hear you over whatever 

18 that static is. It's almost like a continuous 

19 noise in the background like a wind. That's 

20 there, but when you, that showed up about five 

21 minutes ago, but as long as you speak, you know, 

22 directly into the microphone, we can hear you 

23 over that. 

24 DR. BEHLING: We're still on number 17 here, and 

25 I'm really for the first time looking at NIOSH's 
165

1 response, and again, the issue is consistency in 

2 defining uncertainty distributions for total 

3 organ doses. And their response is that OCAS 

4 will revise the uncertainty language in various 

5 sections of the implementation guide so that it 

6 reflects the basis for the uncertainty approaches 

7 utilized in the program. 

8 I have to tell you right now I'm struggling to 

9 figure out what the issues were that I raised; 

10 what caused me to raise them. 

11 MR. HINNEFELD: I think -- if I could. I think I 

12 can help you out, Hans. This is Stu. The IG 

13 language describes the compiled distribution of 

14 whatever quantity we're talking about could be 

15 fit with any of a variety of statistical 

16 packages, et cetera, et cetera. So it's kind of 

17 wide open. What do I do? 

18 DR. BEHLING: Stu reminded me, and it's really 

19 in, I believe, section four of the implementation 

20 guide where you deal with the different 

21 distributions that all come together and then the 

22 use of the Monte Carlo analysis that aggregates 

23 all these different distributions that are a part 

24 of the IREP input code I take it, where you sort 

25 of look at the distribution and sort of say, 
166

1 okay, what is the net effect of all these 

2 different distributions in terms of the 

3 uncertainties. So I do remember now what it was, 

4 and I guess their comments are appropriate here. 

5 It scared me actually when I read it and say are 

6 we going to have to do all this? I know my 

7 limitations. 

8 MS. BEHLING: I actually -- can you hear me? I 

9 actually believe that was the last finding 

10 associated with the implementation guide-001. 

11 And I did make the statement on here that PROC12 0006, ORAUT-PROC-0006, is very similar to it, in 

13 fact, follows the implementation guide in this 

14 exactly. And so our comments to PROC-0006 are 

15 reflected in the implementation guide findings. 

16 The only thing I do want to add with regard to 

17 PROC-0006, it appears that they make revisions to 

18 PROC-0006 where they're adding addendums that 

19 seem a little bit puzzling sometimes because I 

20 believe the last addendum that was added was what 

21 you referred to as Attachment E, and it's an 

22 addendum specific to Hanford. 

23 And at sometimes I know it's confusing to us, and 

24 I'm sure it must be confusing to the dose 

25 reconstructors to have site-specific information 
167

1 as an appendix or as an attachment to a generic2 type procedure. It's very useful data that's 

3 there, but sometimes I wonder how all of the dose 

4 reconstructors if they're even aware that it's 

5 there. 

6 MR. HINNEFELD: Well, I understand the concern. 

7 The project population is fairly static, you 

8 know, a few new people come on now and then. And 

9 the people that are here have been at it for 

10 awhile, and they know, they've figured it out by 

11 now. And when new people come on there's a 

12 fairly, you know, fairly extensive training 

13 session to point out the, and then they also work 

14 under someone's tutelage clearly during their 

15 first period. 

16 So I understand the comment, and it probably 

17 relates to a kind of a hierarchy and something is 

18 going to come up a little bit about if, if you 

19 have a TIB that says you can do an overestimating 

20 technique like this, and a procedure that says 

21 you can do an overestimating technique like that. 

22 They're not exactly the same. Is there one 

23 prevalent over the other? Are there two options? 

24 You know, some of those things. 

25 And it kind of relates to is there a hierarchy to 
168

1 these things comment. And I guess I'm not really 

2 willing to commit to saying we're going to write 

3 a hierarchy right now, but I certainly understand 

4 the comment. I think it's worth some 

5 consideration and evaluation. So just saying 

6 that now, but I think that's what you're saying 

7 on this Attachment E type of thing. 

8 MS. BEHLING: Yes. 

9 MR. HINNEFELD: That similar kind of item, right? 

10 DR. BEHLING: Kathy's comment was just a summary 

11 statement with regard to procedure number six 

12 which by the way is a very, very good procedure. 

13 And I have to say that there is a level of detail 

14 here that is very constructive to doing dose 

15 reconstruction. It's very, it amplifies a lot of 

16 things that are obviously not there in the 

17 implementation guide, and for good reasons 

18 because the implementation guide was basically a 

19 foundation for expressing all the other things 

20 that are part of the dose reconstruction process. 

21 So PROC-0006 is not necessarily a facsimile. 

22 It's an expansion of the implementation guide, 

23 and it's a very, very useful and well organized, 

24 structured document. But some of the issues such 

25 as a DCF are commonplace and so they do need to 
169

1 be looked at in concert with changes that may 

2 affect the implementation guide. 

3 MR. GRIFFON: Can I offer something maybe that 

4 will help us with efficiency here? I'm looking 

5 ahead OCAS-PR-003? 

6 DR. BEHLING: Yes. 

7 MR. GRIFFON: The next two pages cover that and 

8 the response seems to be for every one of them 

9 that you're going to rewrite, you're going to 

10 have a new procedure to replace this one. Is 

11 that correct? 

12 MR. HINNEFELD: Well, chances are we'll just 

13 cancel it. 

14 MR. GRIFFON: Just cancel it, okay. 

15 MR. HINNEFELD: This procedure was written in 

16 September of 2002, and it provides a pretty 

17 decent general description of how dose 

18 reconstruction is done. But it sort of attempts 

19 to assign responsibilities and without, there 

20 were no organizations at the time to assign 

21 responsibilities to. In the interim those 

22 organizations have been set up, better procedural 

23 guidance has been provided. So we don't really 

24 see a need for it. 

25 MR. GRIFFON: So the only thing I would say is 
170

1 maybe we don’t have to go through these item by 

2 item. But is there another procedure that it 

3 makes more sense for us to follow up on, or 

4 rather a different set of procedures that would -

5 - 

6 DR. BEHLING: My gut feeling is that -- 

7 MR. GRIFFON: -- this isn't really replaced by 

8 one procedure. 

9 MR. HINNEFELD: No, no, it's -- 

10 MS. BEHLING: But I believe one of our comments 

11 was the fact that we didn't quite understand why 

12 this procedure was necessary. So I think, in 

13 fact, we do recommend that we didn't understand 

14 the duplication between the other procedures and 

15 this. 

16 MR. GRIFFON: So maybe we can just move ahead. 

17 DR. BEHLING: Yes, yes. 

18 MR. GRIFFON: Two pages and start with -- 

19 MS. BEHLING: I was going to recommend that. 

20 DR. BEHLING: If I didn't state it in my review, 

21 it probably was at least implied that we can do 

22 away with the procedure. 

23 MR. HINNEFELD: You did state it in your review. 

24 MS. BEHLING: You did. 

25 DR. BEHLING: I guess we will then go to ORAUT-
171

1 OTIB-0010 which is a procedure that is aimed to 

2 maximize exposures for claims that are not likely 

3 to be compensable. 

4 MS. BEHLING: Yes, can I make a comment here 

5 also, Mark? Something we may want to consider. 

6 Many of the comments that we are going to have on 

7 TIB-0010 also apply to TIB-0008. And so again 

8 for efficiency we may be taking care of two 

9 guidance documents there. 

10 DR. BEHLING: And the difference between TIB-0008 

11 and 0010 is one is geared towards maximizing 

12 exposures defined by film and the other one is 

13 for TLDs, but they run at parallel path and they 

14 are both used for the purpose of deriving 

15 maximized doses from non-compensable cases. And 

16 I think here is where we clearly have the benefit 

17 of looking at particular dose reconstructions 

18 that had been done at this point in time. 

19 And as I said, we've done 60 and one of the most 

20 frequent issues that we've had to contend with in 

21 reviewing those particular dose reconstructions 

22 involved these two procedures. They have been 

23 consistently misinterpreted. And it took me 

24 probably several weeks to understand what the 

25 intent was here, too. And I will basically 
172

1 summarize. Well, maybe we should go through each 

2 one of them. 

3 The first one is the guidance lacking for how to 

4 treat missed dosimetry data in which the number 

5 of zero readings is fewer than 12 cycles. Again, 

6 if I look at the dose reconstruction reports that 

7 I've seen to date, they will frequently ignore 

8 hard copy data from the DOE that defines the 

9 frequency of dosimetry exchanges. They will 

10 actually default to the assumed number of 12 even 

11 though they may have only been monitored on a 

12 quarterly basis. And so the assumption is when 

13 you maximize doses, if you are claimant 

14 favorable, that's all that counts. 

15 And to a certain extent I agree with it, but it 

16 sometimes is hard to say why would you 

17 necessarily give a person 12 missed doses when in 

18 fact he was only monitored quarterly and possibly 

19 even had positive responses during at least one 

20 or all of the quarterly doses. 

21 But again, I've heard from Dr. Neton that for 

22 efficiency purposes we just, rather than even 

23 dwell on the issue, we will just give you the 

24 benefit of the doubt by using the maximum number 

25 of dosimeter cycles and give you the full measure 
173

1 of the missed dose regardless of whether it was a 

2 zero or a positive response or even if the person 

3 was monitored at a frequency that is fewer than 

4 the 12 assumed in the two TIBs. 

5 Again, this is a subjective issue. We've had 

6 discussions about overly generous assignments of 

7 doses for the simple reason that sometimes, you 

8 know, sure you avoid the arguments, and you 

9 couldn't possibly have gotten any more than we 

10 are going to assign you. On the other hand if a 

11 person ends up with a POC of 43 or 44 percent 

12 based on these overly excessive and generous 

13 assignments, he may feel that he came so close 

14 and he's not happy about it. You're dealing with 

15 a potential problem in a sense where the person 

16 feels that he came close but not close enough. 

17 On the other hand there's the issue where 

18 excessive generosity with dose assignments may 

19 lead to a future problem if the person develops 

20 another cancer, and we say now that that cancer 

21 has a higher probability of being compensated, 

22 we're going to have to take away all these doses 

23 that we assigned to you from your previous claim 

24 of cancer and restart from scratch, and now we're 

25 going to basically use a best estimate. 
174

1 And so there are trade-offs in terms of what 

2 benefits there are to being excessively claimant 

3 favorable especially when there's no need for it. 

4 If I see a DOE document that says he was only 

5 monitored quarterly, it's very generous to give 

6 him four missed doses. And if you want to be 

7 excessively generous use N times LOD instead of 

8 dividing it by two. But it's unnecessary to be 

9 that generous where you assign missed doses for 

10 cycles that he didn't even, wasn't even assigned 

11 a dosimeter for. 

12 So that's a general comment about both the use of 

13 TIB-0008 and 0010 is that they do have a 

14 prescriptive process in which the number of 

15 dosimeter cycles are essentially told to you in 

16 the, in a table format. And as I said, I think 

17 in the end if you have real data perhaps you 

18 should use the data instead of defaulting to a 

19 value that is just a generic value in a table. 

20 MS. BEHLING: And I think that's especially true 

21 when process efficiency is not being impacted. 

22 DR. BEHLING: Yes, I can clearly understand where 

23 if a person was monitored 52 times in a given 

24 year and the person has to go through and says 

well, in this week, the 23rd 25 week of that year, 
175

1 there was a positive dose so I'm going to take 

2 not 52 number of cycles but 51. You know, it's 

3 so much easier to say well, we'll just ignore the 

4 positive ones and give you 52 for every year. 

5 And I understand the logic behind it. At least 

6 one can say for efficiency purposes the blanket 

7 assumption that every dosimeter cycle has to be a 

8 missed dose, has a lot of merit, but it's not an 

9 efficient process, efficient. But it's not 

10 process efficient to ignore the obvious when, in 

11 fact, you have real data that says, no, he was 

12 not monitored 52 times, but he was only monitored 

13 maybe 12 times or even quarterly. That's the 

14 point. 

15 The next issue that we have here, and again, is a 

16 consistent error that we've observed here is the 

17 -- 

18 MR. GRIFFON: Let's just hear from NIOSH on that 

19 one because I see a response, but well, basically 

20 that's a maximizing approach, and that's... 

21 MR. HINNEFELD: Yeah, as a general rule we, a 

22 number of our dose reconstructions are 

23 overestimating, you know, there's an 

24 overestimating component to it, and we tend to 

25 try to avoid really high POC numbers with an 
176

1 overestimating approach just for the reason that 

2 Hans alluded to, but I don't know that we really 

3 want to say well, we're going to stop doing 

4 overestimating approaches. 

5 And I think it's kind of -- you know, I don't 

6 know what else to say about that. I think we 

7 want to retain that as (inaudible). Sometimes 

8 it's not hard to predict in every case what's 

9 efficient for this case and what isn't so we want 

10 to retain at least some flexibility to do, you 

11 know, to use an overestimating approach even if 

12 it means assuming more bad cycles than there were 

13 or seemed to be. 

14 DR. BEHLING: It's an issue also of consistency 

15 because I think we all know that there's a 

16 possibility that people among the claimants, and 

17 there are so many of them, may compare notes and 

18 saying why are you getting all this assigned 

19 doses and I'm not. And it's due to the fact that 

20 two people interpreted the procedures 

21 differently. One is more likely to be 

22 excessively claimant favorable than another 

23 person which leads to inconsistency and unfair 

24 treatment perception. 

25 MS. BEHLING: I also believe that PROC-0006 
177

1 indicates that if you're using overestimating 

2 assumptions and your POC goes over 30? 

3 DR. BEHLING: Yeah. 

4 MS. BEHLING: Thirty percent that you're supposed 

5 to re-evaluate that. It's something that we 

6 don't always draw attention to because again, 

7 we're looking at the efficiency process. And we 

8 understand why it's not being done, but it does 

9 reinforce this statement in this particular case. 

10 DR. BEHLING: And it would certainly help because 

11 a lot of these POCs of 40 some odd percent are 

12 driven by excessive use of generous assignments 

13 that in principle would be avoided if you did, in 

14 fact, apply the 30 percent rule that says, oh my 

15 god, you know, maybe we should be still claimant 

16 favorable but not necessarily that favorable 

17 where we end up with a 40-some-odd percent POC 

18 value. Based on PROC-0006 the assumption is that 

19 if you exceed 30 percent, you should actually 

20 introduce the best estimate methodology. 

21 And that may not be necessary because oftentimes 

22 you can achieve less than 30 percent using still 

23 claimant favorable values but adhering to the 

24 rules that are defined by DOE document that says 

25 why give the guy 12 missed doses when four will 
178

1 do, et cetera, et cetera. And so you can avoid 

2 the costly time issue of a best estimate by 

3 ratcheting down the claimant favorability aspect 

4 that oftentimes ends up with these 40 percent 

5 plus POC values that really shouldn't be there. 

6 MR. HINNEFELD: Well, how about if I take a look 

7 at the language in TIB-0010 and see if there's 

8 something we can insert there to do that. And I 

9 also need to talk with what does that do on the 

10 actual reconstruction side. You know, changing, 

11 taking away a technique that's currently in place 

12 would be perturbation on the dose reconstructors 

13 and dose reconstruction process. And so before I 

14 say well, okay, we'll go take that away, I'd just 

15 rather, kind of like to know what the impact is 

16 on the dose reconstruction process. Because I 

17 mean, fundamentally, our position still is that 

18 if the case is less than 50 percent of causation 

19 theoretically, although we won't go as high as 50 

20 percent, but if it's a less than 50 percent case, 

21 and you've got overestimating approaches in 

22 there, then it's done. It's by efficiency 

23 method. 

24 DR. BEHLING: Well, then PROC-0006 needs to be 

25 revised because that statement of 30 percent -- 
179

1 MR. HINNEFELD: And I will check on that, too. 

2 DR. BEHLING: -- is something that conflicts with 

3 that. 

4 The second item for TIB-0010 is the issue of LOD 

5 and again here we have just a repetitive number 

6 of errors among the dose reconstructions that we 

7 audited to date. When you use N times LOD, that 

is the 95th 8 percentile and at that point you do 

9 not have a parameter value, the default value 

10 generally being 1.52 as the geometric standard 

11 deviation. 

12 And there is a tremendous amount of confusion in 

13 both TIB-0008 and 0010 on that very issue. And 

14 so if you multiply the number of cycles by the 

full LOD value, you are at the 95th 15 percentile 

16 which exempts the need for uncertainty. And 

17 people just haven't gotten that idea. And it's 

18 just a simple rewrite of those two procedures. 

19 MS. BEHLING: It's written well in PROC-0006. 

20 MR. HINNEFELD: Okay. 

21 MS. BEHLING: They don't make that mistake when 

22 they use the instruction, desk reference 

23 instructions. 

24 DR. BEHLING: Again, the next item three for TIB25 0010 is basically what we discussed very early on 
180

1 as our first issue. I'll just read it. The 

2 document contains too much upfront background 

3 information and does not provide the dose 

4 reconstructor with guidance for maximizing 

5 external dose until page eight. 

6 And I think again, I'm speaking on behalf of both 

7 TIB-0008 and 0010. You go through an awful lot 

8 of information and digest information that serves 

9 really no purpose. It's really the final table 

10 that says for recorded dose, multiply times two. 

11 That's really the gist of it. Multiply times two 

12 and again, avoid the need for uncertainty. For 

13 missed dose use LOD times N. That's it. That's 

14 really what the whole procedure tells you to do. 

15 And it is something that you don't find out until 

16 you get to the bigger end on page eight, or the 

17 very last. 

18 And again, it's not an efficient way to write a 

19 procedure. I would have liked to have seen an up 

20 front table that says this document is intended 

21 to maximize doses. Here's how you do it for a 

22 recorded dose and missed dose. And if you want 

23 to hear why we're doing it this way keep reading, 

24 but give the reconstructor the chance to use the 

25 information up front rather than force him to go 
181

1 through eight pages of background information 

2 before he gets to the point where he has to 

3 really make use of some information for dose 

4 reconstruction. 

5 MS. BEHLING: We believe also, based on your 

6 discussion here, we also covered finding number 

7 four on TIB-0003 and four. 

8 MR. GRIFFON: Yes, yes. 

9 DR. BEHLING: The next one I think we've also 

10 pointed out. Well, when we talk about missed 

11 dose, we usually talk about, or at least the 

12 procedures whether it's the implementation guide 

13 or individual procedures, always talk about 

14 missed doses being a recorded zero dose. But the 

15 truth is there are oftentimes recorded doses as 

16 little as one millirem when, in fact, they 

17 coincide with a period where the associated LOD 

18 value is cited as 40 millirem which means that a 

19 person might look at this under some 

20 circumstances. Well, this is a positive dose. 

21 I'll give you one millirem. When in fact the guy 

22 would have been better off having had a zero 

23 dose. In which case he would have gotten 40 

24 millirem over two at 20, or in some cases, just 

25 40 millirem. And so there's a need to identify 
182

1 missed dose in two parameters. A missed dose is 

2 anything that is less than LOD over two or LOD 

3 depending on which methodology you use. 

4 Again, I think that the next one, item six is 

5 something we've already discussed. The standard 

6 correction factor of two eliminates the need for 

7 uncertainty and that was already discussed. 

8 Number seven, I'm not sure. Let me see what you 

9 responded to here. Item number seven says 

10 guidance provided in TIB-0010 differs from 

11 instructions in Section 5.0 of ORAUT-PROC-0006. 

12 MS. BEHLING: PROC-0006 does not recommend 

13 standard correction factors, so I think we are 

14 questioning the inconsistencies. 

15 MR. GRIFFON: Is there a discrepancy in -- 

16 DR. BEHLING: Well, no, I'm just reading now 

17 again for the first time NIOSH's response. And I 

18 guess they agree. You know, I have to read it 

19 here. But they basically state that there are 

20 some discrepancies that need to be corrected. 

21 MR. GRIFFON: Yeah, yeah, yours -- 

22 MR. HINNEFELD: I think we'll take a look at 

23 those. It kind of fits where earlier we said we 

24 need to look at the language and procedures set 

25 against this TIB, and also TIB-0008 probably, and 
183

1 see these various language inconsistent portions. 

2 MR. GRIFFON: So you may amend your response by 

3 saying both procedures are overestimates but 

4 should be looked at for consistency, right? 

5 MR. HINNEFELD: Yeah. 

6 MR. GRIFFON: Go ahead. 

7 MR. ALLEN: Well, basically these are two options 

8 for overestimating. There's no real reason why 

9 we have to have one, and only one method, for 

10 overestimating. Is that what you're trying to 

11 say in this comment? 

12 DR. BEHLING: I'm reading; I'm sorry. 

13 MR. GRIFFON: I guess if there's two options then 

14 the PROC and the TIB should indicate both options 

15 maybe. Is that -- 

16 DR. BEHLING: Yeah, that is an issue that is 

17 raised in, I think, the next one, too, is that 

18 sometimes I'm confused about the hierarchy of 

19 documents, which dominates. Obviously, there's 

20 always, at least in my mind, the final conclusion 

21 that a TBD dominates everything. In other words 

22 if you have a site-specific document that says 

23 this is how you do it, you ignore everything else 

24 assuming that the issue is properly treated in 

25 that document. 
184

1 But beyond that when I talk about or when I see 

2 generic procedures, and I will just briefly 

3 allude to one. I believe, for instance, in case 

4 of Savannah River, there are a couple TIBs there 

5 that deal with the missed tritium dose. And one 

6 will say oh, it's okay for a missed tritium. 

7 It's five microcuries per liter that translates 

8 to 375 millirem a year. And the other one says 

9 it's really based on a one microcurie per liter 

10 that we didn't bother recording. That's 71 

11 millirem a year. And it's up to the individual 

12 to make a decision which I really don't think 

13 should be the case. 

14 You either decide one or the other. And for 

15 consistency purposes you should at least identify 

16 a common, like if there are multiple procedures 

17 that treat the same subject, they should at least 

18 be consistent. Preferably they shouldn't be 

19 redundant in terms of procedural content anyway 

20 because, you know, people have enough documents 

21 to confer with in doing dose reconstruction. 

22 They don't need to have multiple documents that 

23 treat the same issue. And so the issue comes 

24 into play in terms of hierarchy. Where does the 

25 person go to say this procedure takes precedence 
185

1 over the other procedure in defining what the 

2 dose shall be? And it's not always clear in my 

3 mind. 

4 MS. BEHLING: And there are definitely 

5 inconsistencies depending on who the dose 

6 reconstructor is. 

7 MR. HINNEFELD: I think probably our response has 

8 to be let's go sort out the language. And I know 

9 it's relevant to 0008, 0010, TIBs 0008, 0010 and 

10 PROC-0006. And see if we can come to some common 

11 understanding and approach that's not a 

12 particular perturbation on the dose 

13 reconstruction process. 

14 DR. BEHLING: So I think we've covered item seven 

15 and eight. Number nine for TIB-0010 is a 

16 standard correction factor of ten. And I would 

17 say generally speaking that the standard 

18 correction factor of ten is one that covers an 

19 awful lot of uncertainty. The other -- the 

20 standing correction -- I have two, I'm sorry -- 

21 encompasses a tremendous amount of potential 

22 errors associated with the performance of a film 

23 badge or a TLD. But I wouldn't say it's 

24 necessarily excessively claimant favorable. 

25 I think it's reasonable to assume that a factor 
186

of two may define the 95th 1 percentile. Because 

2 when I look at that National Research Council 

3 report of '89, and you look at the recorded or 

best estimate value versus the 95th 4 percentile, 

5 it’s usually a factor of two apart. So if you 

want to consider the 95th 6 percentile as being 

7 excessively claimant favorable, okay, but it is 

8 one that is within bounding values of real 

9 dosimeter performance. 

10 And so that statement was really written in here 

11 to say that the factor of two is potentially a 

95th 12 percentile value that that may apply under 

13 some circumstances when even a maximized dose is 

14 not necessarily the approach, but could even 

15 apply to, under certain circumstances, to people 

16 who are best estimates may be usable. 

17 MR. HINNEFELD: Okay, I want to talk about this 

18 one just a bit. The National Research Council 

19 study that you refer to, if I remember from your 

20 report, was the dosimetry of -- was it atomic 

21 veterans? 

22 DR. BEHLING: Yes, yes, up to '62, and those are 

23 films that were used -- 

24 MR. HINNEFELD: So a particular troop of soldiers 

25 would be given film badges. They'd be marched 
187

1 through the same terrain. They'd essentially 

have the same exposure conditions. And the 50th 2 

3 percentile of their badges, it could easily be 

half or the 95th 4 percentile could easily be twice 

the 50th 5 percentile, so that relates to the 

6 variability of a single badge, you know, episode 

7 like that. 

8 So there's that much variability in badge. I 

9 think from our standpoint that the times two 

10 factor for the standard correction factor, you 

11 recall, is applied as the multiplier of two times 

12 every recorded value. So we think that since 

13 we're doing it times every recorded value, the 

14 likelihood that a specific individual would 

15 always be the low outlier on the distribution of 

16 badge and exposures, we think that the factor of 

17 two is relatively okay in the way it's being used 

18 since it's, to his entire recorded dose as 

19 opposed to a single incident where you might say 

20 well, yeah, it might be that much. But over the 

21 course of his career and every recorded dose, if 

22 you apply that factor of two, we think we're 

23 pretty good at saying that that's an 

24 overestimate. So that would be our -- 

25 DR. BEHLING: Yeah, I agree with the idea that a 
188

1 factor of two certainly brackets the potential 

2 exposure. 

3 MR. HINNEFELD: Okay. 

4 DR. BEHLING: But I guess the exception I took is 

5 the wording of it in saying that this is 

6 excessively, it's probably in some instances 

7 within the range of performance of the, 

8 especially early film dosimeters. 

9 MR. HINNEFELD: Okay, we'll take a look at the 

10 wording. 

11 DR. BEHLING: Yeah, I mean, nothing needs to be 

12 changed other than the reference to the fact that 

13 this is way outside the scope of reality. It's 

14 probably not. It's probably in many instances 

15 within the range of a dosimeter's performance, 

16 the error band that says, you know, a factor of 

two may define a 95th 17 percentile value. 

18 MR. GRIFFON: You can do this last one, and then 

19 I've been asked for a five minute comfort break 

20 after. 

21 DR. BEHLING: The next one is item number ten, 

22 the use of a default LOD value of 40 millirems 

23 should be considered a typical value as opposed 

24 to a highly conservative value. Again, I looked 

25 at the NRC report which defines that as a typical 
189

1 value as you know if you look at the, I guess 

2 it's one of the appendices to that report that 

3 says 40 millirem is really a typical value for an 

4 LOD. 

5 Again, I haven't looked at the raw data involved 

6 in the various facilities that made use of the 

7 dose film. But considering the fact that the 

8 military personnel in the Pacific or at Nevada 

9 Test Site, probably were given the same DuPont 

10 fiber 2-5-10 badges. What applies there is 

11 likely to be applicable to the energy employees. 

12 And so I consider 40 millirem perhaps as a 

13 typical value as opposed to the highly 

14 conservative value as an LOD. 

15 MS. BEHLING: Again, it's just a wording issue. 

16 DR. BEHLING: Just the wording. 

17 With that I assume, Mark, you would like to take 

18 a break. 

19 MR. GRIFFON: Yeah, why don't we take a, just a, 

20 and let's keep it to five minutes because I know 

21 a lot of people have planes. I know I have a 

22 plane to catch so let's keep it to five so we can 

23 get through the rest of these. We're making 

24 headway. 

25 (Thereupon, a break was 
190

1 taken from 3:30 to 3:37 

2 p.m. after which the 

3 following transpired:) 

4 MR. GRIFFON: Okay, reconvening now. Hope 

5 everyone's on the phone that needs to be on the 

6 phone. 

7 One thing I wanted to bring up just in between, 

8 we're going from OTIB-0010 to 0008. I had a 

9 question in my mind was do either one of these 

10 documents -- and I can't remember for the life of 

11 me -- but do either one of these describe the 

12 procedure used for unmonitored periods as opposed 

13 to missed dose? Is there anything about 

14 unmonitored dose? Any guidance on that? 

15 And I'm thinking of a situation where you might 

16 have many cycles of dose records with positive 

17 readings, you know, 100 millirem, 300 millirem, 

18 and then you have gaps in the data. Are they 

19 always treated as just, you know, LOD values or 

20 are they actually unmonitored and treated 

21 differently? Treated as an average of, you know, 

22 is there any guidance? Is that in here? Is that 

23 in other guidance? 

24 DR. BEHLING: Well, I can answer that. I think 

25 if you looked at implementation guides they give 
191

1 you various options. If for instance you have a 

2 person who has an exposure track record for a 

3 period of time and then there's a gap, and he 

4 resumes again with an exposure period, one can 

5 use interpolation between the two. And assuming 

6 that everything else being equal, one could 

7 certainly look at that gap and say, well, during 

8 this period and the period that follows we just 

9 simply linearly extrapolate during the period and 

10 assume that that's a reasonable approach. There 

11 are other approaches for dealing with unmonitored 

12 or missed periods such as using administrative 

13 dose limits as an approach. 

14 MR. GRIFFON: I agree. Different approaches were 

15 outlined in the implementation guide. But that's 

16 a broad guidance document. I was wondering if 

17 there's any more specific -- 

18 DR. BEHLING: No. 

19 MR. HINNEFELD: Not in 0008 or 0010. 

20 DR. TOOHEY: No, they're not in 0008 or 0010. 

21 They tend to be more in the site profiles. Or 

22 the other option we've got now since we've 

23 completed coworker data distributions for the 

24 major sites is assigning that distribution for 

25 unmonitored gaps. 
192

1 MS. BEHLING: But what we're actually seeing in 

2 the dose reconstructions, and I don't believe 

3 I've seen anything other than this, is they’re 

4 just treating those gaps as if they were zero, 

5 and they feel that that's being, that's an 

6 overestimate. That's based on what we've seen on 

7 the audits. 

8 DR. NETON: That shouldn't be the case. If it 

9 was unmonitored, truly unmonitored exposure 

10 should not be treated as the L-O, as missed dose 

11 unless there's some great justification for that. 

12 MR. HINNEFELD: If there's reason to believe that 

13 the person was not monitored and was correctly 

14 not monitored. In other words there was a job 

15 title change that would make them look as if they 

16 moved into a job where they probably wouldn't 

17 have been monitored. If it has been done that 

18 the monitored worker missed dose would be applied 

19 as a bounding estimate for that, doing that. 

20 MR. GRIFFON: I think there might have been other 

21 site-specific conditions, too, where blanks in 

22 the record, it was determined that those were 

23 actually red badges that were less than 

24 detectable. So I think that was a site-by-site 

25 issue. But it's not in the procedures. That's 
193

1 the main issue. So we can address it another 

2 time. 

3 DR. BEHLING: Neither 0008 or 0010 address the 

4 issue of unmonitored. 

5 MR. GRIFFON: I'll let you continue. Didn't mean 

6 to sidetrack you. 

7 DR. BEHLING: I think we're trying to expedite 

8 things so as to leave some time left for other 

9 discussion. So we're on TIB-0008, and again, 

10 we've already mentioned that TIB-0008 parallels 

11 0010. So much of what we said about TIB-0010 

12 applies to TIB-0008, and so I think we, if we 

13 agree we can skip TIB-0008 because it's 

14 essentially a parallel of TIB-0010. 

15 That brings us to TIB-0007 and the first item 

16 here, and I think if I recall this deals with the 

17 issue of removing or eliminating environmental 

18 doses associated with badges that were stored 

19 perhaps in the areas that should have been 

20 reported as occupational. In other words there's 

21 EALER issue involving elevated ambient levels of 

22 radiation. There was a time in practice where 

23 control badges were used to subtract doses from 

24 the monitored badges. 

25 And it turns out that perhaps the control badges 
194

1 were stored in places that were not just natural 

2 background radiation, but actually occupational 

3 one. And I think if I recall, that particular 

4 procedure says we're going to continue this. 

5 This was an incomplete procedure at the time we 

6 reviewed it. 

7 Am I correct, Stuart? 

8 MR. HINNEFELD: Right, it was originally 

9 published with consideration of the practices at 

10 a selected number of sites with the idea that 

11 other sites would be addressed as they were 

12 evaluated. And realistically our feeling now is 

13 that when we evaluate each site, we'll write the 

14 site profile for the site. Let's just put that 

15 information in the site profile rather than keep 

16 this particular TIB around. So we're really 

17 going to consider whether we need to hang onto 

18 this one at all. 

19 DR. BEHLING: Yeah. Again, the next issue here 

20 besides the EALER issue is one of the exposures 

21 defined usually in behalf of a deep dose. And of 

22 course we know that deep dose really may not be 

23 representative of a skin dose which is not only 

24 deep dose but perhaps a beta component or low 

25 energy photons. And so issue number three, OTIB-
195

1 0007, does not provide guidance for assessing 

2 shallow dose in cases involving skin cancer. 

3 Again, it is an issue we've raised beforehand, 

4 but it's confined to only those claims where skin 

5 cancer is the issue and environmental doses are, 

6 generally speaking, recorded as deep doses. And 

7 is there an issue here that needs to be looked 

8 at? 

9 MR. HINNEFELD: Well, I think it folds into the 

10 desire to move this into site profiles because 

11 there'll be some sites we might have argon-41 

12 potential exposures. Or you might have 

13 contaminated, you know, beta emitting 

14 contaminants and particular areas that are 

15 elevated to the point where it would be relevant. 

16 But that's kind of like a site-specific thing as 

17 opposed to a general approach. And so I think 

18 it's kind of a resolution to those kinds of 

19 issues fits with using the site-specific site 

20 profile or TBD information rather than a generic 

21 one and see if we can't move away from this in 

22 general. 

23 DR. BEHLING: And I also have a question because 

24 I didn't really see any empirical data that would 

25 give me some understanding of what the magnitude 
196

1 of exposure is that may have been subtracted from 

2 worn badges based on control badges being stored. 

3 Did you have a feel for whether this is really 

4 even a significant issue? I mean, were there 

5 some sites where the potential exposure that's 

6 been subtracted is a substantial part of a 

7 person's exposure? 

8 MR. HINNEFELD: There might be an occasion where 

9 badges were stored in badge racks not far removed 

10 from a radiological area, and the one that comes 

11 to mind I believe it might be Idaho, there was 

12 some discussion. I don't know off the top of my 

13 head the final answer to, I don't remember that 

14 was discussed, but there might actually be 

15 control badges stored in badge racks that really 

16 weren't particularly isolated. 

17 DR. NETON: Yeah, I think this all came up at the 

18 green runs at Hanford when there were some 

19 significant environmental, ambient environmental 

20 levels, you know, virtually plant wide at some 

21 point. And if you subtracted those values from 

22 the badge rack reading, my recollection is this 

23 could be in the realm of several hundred 

24 millirem. It's not significant, but it's 

25 certainly enough that would, you know, could put 
197

1 somebody over the limit, I mean over the 

2 compensability limit if we weren't careful. But 

3 it's really isolated to a very select number of 

4 sites, pretty much early on. 

5 DR. TOOHEY: Dick Toohey. I just really, it 

6 really is a site-specific issue. It was also an 

7 issue at Rocky Flats where it was alleged that 

8 badges were stored in high background areas. And 

9 as it turned out, they were. 

10 DR. NETON: I think we put that one to bed. 

11 DR. TOOHEY: Yeah, we did, but the point I'm 

12 trying to make is that's dealt with on a site13 specific basis in the site profiles. 

14 DR. BEHLING: Okay, so this procedure may, in 

15 fact, be scrapped? Is that what I'm hearing? 

16 MR. HINNEFELD: Right, we're going to have to 

17 take a look and make sure if we don't hamper 

18 ourselves by doing that, but that would be our 

19 preference is not to keep this general. This was 

20 a general procedure issued early on with let's 

21 get the capability to do some dose 

22 reconstructions before all the site research is 

23 complete. 

24 DR. BEHLING: Okay, so in that case I guess we're 

25 down to TIB-0006. I have to actually remind 
198

1 myself what TIB-0006 is about. Is that the 

2 medical? Okay, that's the medical. 

3 Again, the first item for -- yeah, this is Ron 

4 Kathren's medical occupational exposure generic 

5 document. I find it's at times used when in fact 

6 there's a TBD that has a separate section. And 

7 again, I would assume that when there is a TBD 

8 that has site-specific data that that should be 

9 used as opposed to the generic one. And yet I've 

10 routinely found people using the generic one 

11 when, in fact, there's a site-specific TBD that 

12 identifies exposure. So I guess I would 

13 recommend that the hierarchy of use of procedures 

14 favors the site-specific data as opposed to 

15 generic one. 

16 But anyway this is obviously the one that's more 

17 generically used and the criticism or at least 

18 the statements that are offered under issue one 

19 is that the document is poorly structured and 

20 provides unnecessary background information and 

21 so forth and so forth. And it's really one of, 

22 again, giving the reader an awful lot of 

23 information to digest before going to the final 

24 tables that says here's what you use for 

25 identifying organ specific doses by a period of 
199

1 time during which these x-ray machines were 

2 provided with additional filtration, et cetera. 

3 So the first thing is just nothing more than a 

4 comment about the structure and design of the 

5 particular TIB that is again one that involves an 

6 awful lot of background information that has 

7 little or no value for dose reconstruction. And 

8 as far as I'm concerned there's not much we can 

9 do at this point other than to accept the fact 

10 that if we had to do it over again perhaps we 

11 would restructure these procedures. 

12 I've looked at the procedures in general. I 

13 think it's a well done procedure that has a lot 

14 of research behind it. The organ doses are well 

15 defined for various periods of time using 

16 obviously the state-of-the-art ICRP documents 

17 when organs were not necessarily identified, et 

18 cetera. So I believe the document stands as it 

19 is without any need for change other than the 

20 format. 

21 MS. BEHLING: Just one additional issue on TIB22 0006 is as the TBDs are being developed, one of 

23 the things we are finding is as we're comparing 

24 TIB-0006 to the TBDs, we're often seeing quite a 

25 discrepancy in some of the doses that are 
200

1 reported. May be something to keep in mind as 

2 the TIBs make a comparison. Because if you use 

3 TIB-0006 as opposed to the site profile, that can 

4 often make a fairly significant difference. 

5 DR. BEHLING: Yeah, and sometimes it's not 

6 necessarily something that I fully understand. 

7 For instance, assumptions regarding 

8 photofluorographic procedures, I think in one the 

9 total number of frames are five and they 

10 correspond to dose, especially to the issues, to 

11 organs in the primary beam, something in the 

12 order of three rem. And there are other site13 specific tables, and I forget which one in 

14 particular, where the dose is fully a factor of 

15 ten less. 

16 And again the question is why the difference? If 

17 the procedure, generally speaking, should have 

18 been somewhat common and for the same period of 

19 time should have resulted in similar doses. And 

20 a factor of ten is hard to explain. So again, 

21 consistency is an issue here specifically for 

22 photofluorographic procedures which is really 

23 item two for TIB-0006. 

24 DR. MAURO: Say Hans? This is John Mauro. One 

25 of our -- and I know that it's not on your list, 
201

1 but it may be something that's worth bringing up 

2 at this point in time is when we were doing a 

3 site-specific review of a site profile, one of 

4 the site profiles. It might have been Idaho. In 

5 the process of reviewing the medical exposure 

6 procedure in looking at TIB-0006 and how it's 

7 implemented, one of the commenters had indicated 

8 that the uncertainty that I believe has been 

9 adopted in TIB-0006 for the standard x-rays, or 

10 chest x-rays, I believe is around 30 percent. 

11 And the point that was made is that's probably 

12 realistic for, I guess, the physics, that is, 

13 the, assuming that the practitioner who's 

14 actually taking the x-ray is very, very highly 

15 qualified, well trained and always does exactly 

16 according to the rules. This person, the 

17 reviewer, the fellow that helped us with this 

18 review, his experience, his hands-on experience, 

19 was that there's a tremendous amount of 

20 variability in the actual practice and how people 

21 go about taking x-rays and their proficiency. 

22 So this would be a new item, I guess. It's not 

23 here on the list. I don't know if it's 

24 appropriate or not at this time to bring it up, 

25 but it was his feeling from his own personal 
202

1 experience that the real uncertainty, the 

2 variability that might exist when a person is 

3 taking an x-ray because of the differences in the 

4 skills of the practitioner and also the physician 

5 and what he, his sort of druthers regarding the 

6 film that he's going to look at, for a given x7 ray the difference is considerably greater than 

8 the 30 percent, and that was a point made by one 

9 of the fellows who participated in our review who 

10 had a lot of experience with these things. 

11 DR. BEHLING: And I agree, John. When you look 

12 at the variability of the doses defined by the 

13 millisecond exposure duration, the KVP 7, the 

14 distance between the source and the individual, 

15 these are all variables that, and of course, the 

16 one of the most important critical ones is the 

17 issue of number of retakes which is, I'm not 

18 sure, fully addressed here in a 30 percent sigma 

19 value. 

20 I'm sure that there were early times when a film 

21 was done perhaps twice, even a third time, which 

22 is perhaps going to be one of the major 

23 contributions to the uncertainty of assigning a 

24 particular dose to an organ. So 30 percent is 

25 perhaps not unreasonable, but it's clearly not a 
203

1 bounding value. 

2 MR. GRIFFON: John, John Mauro, I was just 

3 wondering if there was any reference, any 

4 publications supporting that claim that these in 

5 practice uncertainties might be greater? 

6 DR. MAURO: I can get that information, and I 

7 don't know if it's in the published literature, 

8 but here in New Jersey we have a sort of 

9 licensing process. We keep records of all of the 

10 licensed practitioners and their performance. So 

11 I probably can get my hands on them, and this is 

12 current now, data, but I could look into this. 

13 This, the comment that was brought up wasn't 

14 brought up by me. It was brought up by a 

15 practitioner who that was his personal 

16 experience. 

17 Let me look into this and so before we put this 

18 on the list so to speak as an item perhaps I 

19 could put out, look at this a little further and 

20 give his comment a little pedigree so to speak 

21 and forward it on. I'll forward it on to Hans, 

22 and Hans if you could work it into the system as 

23 appropriate. 

24 DR. BEHLING: Yeah, for instance, I'm looking, 

25 sometimes when I look at the data, and I look at 
204

1 the original data as supplied by the DOE, I 

2 actually look at, for instance, the individual in 

3 question in terms of his gender and his body 

4 weight. And of course we know when we talk about 

5 a reference person, we're assuming a 70 kilogram 

6 individual with a chest wall thickness of a 

7 certain fixed dimension. And of course that 

8 defines what the KVP setting is, et cetera, et 

9 cetera. 

10 When in fact you look at a guy and you see his 

11 weight is 240 pounds, he's going to obviously 

12 receive a much higher entrance skin dose for sure 

13 because the KVP setting has to be jacked up 

14 considerably to accommodate that person's weight. 

15 So these are all variables that clearly will come 

16 into play. 

17 The question is will the doses be significant 

18 enough to deal with issues that we're concerned 

19 with and that is the compensability of the claim. 

20 If one were to say okay, the long dose goes from 

21 early in years from 42 millirem to 52 millirem, 

22 would that necessarily, that increment, make a 

23 big difference with the likelihood that there 

24 will be instances where a person's claim will be 

25 compensated based on changes or increases, modest 
205

1 increases, in medical exposures. Again, it's a 

2 judgment call here. 

3 MR. GRIFFON: Dick's been waiting to -- sorry. 

4 DR. TOOHEY: Yeah, I'm sorry, just a couple of 

5 general comments on that. 

6 We actually had some serious arguments between 

7 two medical physicists while 0006 was in there. 

8 I think there were some health physicists when it 

9 comes to arguing about the physics. But I did 

10 want to mention we are revising TIB-0006 to 

11 include C-spine and T-spine doses for fluoride 

12 workers which was a gap we had. And in general, 

13 I think if we had site-specific data that we can 

14 put in the medical TBD at the site, that should 

15 take precedence for dose reconstruction. 

16 TIB-0006 should have the tables of the dose 

17 coefficients we're going to use given the skin 

18 entrance dose exposures, and default parameters 

19 if we don't have site-specific information. So 

20 as we include the other things in there, I want 

21 to get revision of that to cover these other 

22 bases and make it clear what the purpose of that 

23 one is. Again, that was one written early on to 

24 get us going. 

25 MR. GRIFFON: Does that address all the items for 
206

1 TIB-0006, Hans, or -- 

2 DR. BEHLING: Yeah, pretty much. I guess if I do 

3 have a modest criticism is that in some instances 

4 we defined doses for a lot of years that are in 

5 units of microrem and I find that a little 

6 disturbing. I think it would be nice just to say 

7 less than one millirem rather than microR 

8 readings or microrem readings. It gives you the 

9 false impression that there's a level of accuracy 

10 that simply doesn't exist. 

11 You know, it's like dividing ten by three. You 

12 could end up with 3.33 and an infinite number of 

13 threes, when in fact, if the value of ten is not 

14 a good, a solid number, you know, you should stop 

15 at the value of three or maybe 3.3. And I think 

16 there has been a tendency on the part of certain 

17 procedures to give the illusion of a level of 

18 accuracy that simply isn't there. But you know, 

19 that's just a comment on my part. 

20 I think we're done at this point, Mark. 

21 MR. GRIFFON: How about, isn't there a TIB-0007? 

22 There's two. 

23 DR. BEHLING: Oh, I'm sorry. 

24 MS. BEHLING: Now the next one's OCAS-TIB-0006 as 

25 opposed to ORAUT-TIB-0006, and this has to do 
207

1 with Savannah River site external dosimetry 

2 records. 

3 DR. BEHLING: Okay, the comment on, the first 

4 comment for TIB-0007 is that guidance does not 

5 specify all occupations that may involve neutron 

6 exposures. 

7 MR. GRIFFON: No, no, no, you missed -- go back 

8 up to TIB-0006, OCAS-TIB-0006, instead of -- 

9 DR. BEHLING: Okay, oh, I'm sorry. I'm sorry. 

10 Okay, we're at OCAS-TIB-0006, and the first 

11 comment there is that guidance regarding the need 

12 to correct SRS dosimeters with aluminum filters 

13 between 1954-1981 is complex, confusing, and does 

14 not clearly indicate which dosimetry data 

15 requires refinement. 

16 As this comment summarizes, I found it very 

17 confusing in terms of the description for dealing 

18 with the aluminum filter, and what it represents 

19 in defining a correction factor. 

20 MR. GRIFFON: Actually, can I make a 

21 recommendation here since I'm looking at the 

22 time? The next two procedures are Savannah 

23 River-specific, and I'd propose that we're going 

24 to take that up at the subcommittee in Oak Ridge. 

25 Let's put the Savannah River site profile on 
208

1 there and start with these two procedures. We 

2 can start with a matrix review from here. Is 

3 that agreeable? 

4 MR. HINNEFELD: It's okay with me. 

5 MR. GRIFFON: Yeah, because I want to give, Jim 

6 asked, and rightly so, to maybe have a little 

7 time to discuss Y-12 at this meeting. 

8 One thing before we move on from here, what I 

9 wanted to ask is on the matrix now SC&A has 

10 expanded the matrix to include all the internal 

11 dose findings now in the CATI interview findings, 

12 I guess. Is there any chance that we will be 

13 able to discuss that at the subcommittee meeting 

in Oak Ridge on the 17th 14 ? Will that give you 

15 time to -- 

16 MR. HINNEFELD: There are five workdays. 

17 MR. GRIFFON: Some preliminary response. 

18 MR. HINNEFELD: There are five workdays in the 

19 meantime so -- 

20 MR. GRIFFON: So the answer is yes? 

21 MR. HINNEFELD: I would think, I think what we 

22 could hope for is to hope that there are some 

23 simple resolutions and go through case, you know, 

24 a number of these comments and see if we have 

25 relatively, oh yeah, you're right kind of 
209

1 resolutions or -- 

2 MR. GRIFFON: Well, the other thing is, the other 

3 thing I would ask is if you can focus on the ones 

4 that are at least Savannah River-specific because 

5 then we can get a site profile in the procedures 

6 that relate to Savannah River. 

7 MR. HINNEFELD: We can focus on the Savannah 

8 River ones. Yeah, we can focus on those. 

9 DR. NETON: Many of the Savannah River ones are 

10 related to the high five approach which is 

11 covered in the Savannah River site profile 

12 review. 

13 MR. GRIFFON: Right, so they are one and the 

14 same. 

15 DR. NETON: They're very one and the same 

16 actually. I believe, and also the organically 

17 bound tritium, and there were a few other issues 

18 like that. 

19 MR. GRIFFON: I think you're right. I think we 

20 deferred most of them to the -- 

21 DR. NETON: Matter of fact most of them were 

22 deferred to the resolution within the site 

23 profile review. 

24 MR. GRIFFON: Well, I guess I would ask to the 

25 extent you can fill in the matrix responses on 
210

1 the internal and the CATI, you know, we can move 

ahead on this at the subcommittee on the 17th 2 . 

3 UNIDENTIFIED SPEAKER: Mark, could you speak into 

4 the microphone? 

5 MR. GRIFFON: Sorry, sorry. I was just saying to 

6 the extent that NIOSH can fill out responses for 

7 the internal dose and the CATI interview sections 

8 of the matrix, that will allow us to pick this 

item up at the subcommittee meeting on the 17th 9 . 

10 So we'll just understand they'll do the best they 

11 can, and we'll proceed from there. 

12 MS. BEHLING: The only additional comment I would 

13 like to make about the matrix because we were 

14 also under lots of time constraints here, there 

15 are a few things I may want to add to the 

16 interview that was the very last one I did. I 

17 was anxious to get it out and there may be a few 

18 clarifications I want to put onto the CATI, the 

19 matrix for the CATI reports. 

20 MR. HINNEFELD: Could you send it as a, 

21 essentially the same file name, but rev one or 

22 whatever rev you want, so we'll do the same 

23 thing? 

24 MS. BEHLING: Yes. And they're just 

25 clarifications. 
211

1 MR. HINNEFELD: And it would be acceptable to, if 

2 she's going to send these to me, who else should 

3 she send them to? I mean, the working group, the 

4 entire board? 

5 MR. GRIFFON: The entire board I think. 

6 MS. BEHLING: Just a few clarifications that I 

7 wanted to add. 

8 MR. HINNEFELD: Sure. 

9 MR. GRIFFON: Any other clarifications on this, 

10 the matrix, and what we're going to have prepared 

11 for the next meeting? Okay. 

12 I think we're going to try to cut this off at 

13 like 4:30 because I think a bunch of people have 

14 flights or at least I do. 

15 Y-12 SITE PROFILE REVIEW

16 Jim, for the Y-12 site profile review I think it 

17 makes the most sense to have Jim maybe give a 

18 preliminary discussion of -- 

19 DR. NETON: I don't know if Joe is prepared to 

20 discuss this at all and I can react or whether 

21 it's just more time efficient for me to -- 

22 MR. FITZGERALD: I think in 30 minutes I would, 

23 rather than going through a recitation, we did 

24 present this back in July although that was 

25 awhile ago. And I think in the process of 
212

1 responding, you can, in the process of responding 

2 I think you can just outline the finding at the 

3 same time. That would be very efficient. 

4 DR. NETON: That's fine. 

5 You know, as with the Bethlehem Steel, I think 

6 there's a couple key issues here that we really 

7 need to come to grips with and then the other 

8 ones are -- not that they're not important, but 

9 they're not as much of a show stopper as a couple 

10 of the other issues. 

11 So that was a cue for me to -- 

12 MR. GRIFFON: I think so. 

13 MR. FITZGERALD: I was going to say if there was 

14 an hour we could have done a tag team, but I 

15 think with 30 minutes, I'll just defer to you. 

16 DR. NETON: Actually, all I have is a slide that 

17 loosely paraphrases the findings. I know the 

18 report was very extensive. Again, we received 

this report I think some time in September 9th 19 or 

20 so, and we did have a preview earlier as to what 

21 it might be. But you know, it's a couple hundred 

22 page document. It's pretty hard to react to 

23 given all we have going on, but -- and Joe can 

24 correct me if I'm off base here, but these are 

25 really in my mind the six major findings that 
213

1 summarizes what was in the executive summary. 

2 There are a number of vertical issues that go 

3 along with these, but they all fall along similar 

4 lines. I'll just go through them briefly and we 

5 can set the stage here maybe for discussion at 

6 the subcommittee meeting. 

7 Support services worker was defined. There's 

8 incomplete monitoring data for the support 

9 services workers. Those would be welders, pipe 

10 fitters, those type, the crafts-type folks. And 

11 the finding was that we did not have enough data 

12 for, to justify that these workers were not as 

13 exposed as the monitored workers, and I'll go 

14 through that a little bit later. 

15 The second one is lack of evidence that monitored 

16 workers were maximally exposed. That's sort of a 

17 similar theme in the sense that prior to 1961, 

18 anywhere from seven to 20-something percent of 

19 the workers were monitored for external, and I 

20 think the finding was that the profile didn't do 

21 a sufficient job of defining why we believe those 

22 workers were in the maximally exposed population. 

23 The third finding is a number of issues rolled 

24 into one related to external exposure. 

25 Primarily, this had to do with our coworker 
214

1 matrix and solubility types used and the 48 hour 

2 lag period when you take a sample on a Monday 

3 when a person hasn't been exposed since Friday 

4 and what that means in terms of interpretation of 

5 the dose. It's a fairly complex technical issue 

6 that we'd like to address. I'm not sure we're 

7 going to be able to go through that today. 

8 And then as we go down the issues become a little 

9 less problematic. Internal dose not addressed 

10 for all radionuclides. There is a few, a number 

11 of radionuclides other than uranium at the site 

12 that were in existence. For instance there's 

13 some discrepancy in our mind as to whether these 

14 nuclides move rightfully under the purview of X15 10, versus the National Lab, versus Y-12, that 

16 sort of thing. 

17 And then this neutron exposure issue not 

18 adequately addressed is of a similar vein to what 

19 we just talked about with the procedure review. 

20 That is, you know, can one indeed see neutrons of 

21 greater than, less than one rem, I mean, yeah, 

22 one rem. And there's actually a fairly complete 

23 companion report now at TIB that goes along with 

24 the site profile that addresses this issue, and 

25 has very much along the lines of the table we saw 
215

1 in the procedure review, some documentation to 

2 support the fact that 500 millirem was indeed 

3 seeable although there are correction factors 

4 that need to be applied as you go. 

5 MR. FITZGERALD: And Jim, on that one it has a 

6 sort of a companion issue where I think there was 

7 a claim that the neutrons were sufficiently hard 

8 higher energy at Y-12 so that that, in fact, 

9 wasn't as inappropriate as it might be elsewhere. 

10 And that got into the question of spectrums. 

11 DR. NETON: What were the spectra coming off of 

12 these devices. 

13 MR. FITZGERALD: Right, in the sense that there 

14 really wasn't really a broad sense of that. 

15 DR. MAURO: Excuse me, Jim. This is John Mauro. 

16 I'd like to add a clarification. It sounds like 

17 there with regard to the neutron issue, there are 

18 two aspects to it that I'm hearing. One is this 

19 business of whether you can see, using NTA film, 

20 exposures of less than one MeV, (unintelligible) 

21 500, (unintelligible) one MeV, and now I'm also 

22 hearing this issue is now regarding the energy of 

23 the neutron but also, I guess, the exposure 

24 itself if it’s less than one rem notwithstanding 

25 the energy, you might have a problem. Is that 
216

1 what I heard? 

2 DR. NETON: No, I think what we're saying is you 

3 can see, NTA film can indeed see neutrons less 

4 than one rem. 

5 DR. MAURO: Okay, but there was a one MeV issue 

6 also, right? 

7 DR. NETON: And I said one rem. I mean MeV. 

8 It's late in the day. My mind is fogged. I'm 

9 sorry. A rem and MeV. 

10 DR. MAURO: I'm okay now. 

11 DR. NETON: I'm sorry. 

12 I think the first two issues in our mind, and one 

13 needs to keep in mind that we also currently have 

14 an SEC petition under evaluation and these are 

15 very relevant to that petition. You know, the 

16 profile reviews and petition evaluations are very 

17 interconnected obviously. And the issue of 

18 support services workers is actually the subject 

19 of the SEC petition. 

20 We have gone through that, and I've done a review 

21 of the data available, of which are fairly 

22 extensive. I mean, I hate to keep spouting 

23 numbers, but you know, we do have monitoring 

24 data. Y-12 is one of the sites that has a fair 

25 extensive monitoring history. Believe it or not, 
217

1 there were over 900,000 air samples taken at the 

2 Y-12 facility between '51 and '76, about 50,000 

3 lung counts for uranium, 10,000 lung counts for 

4 thorium, 80,000 air samples for thorium, and I 

5 forget exactly the number of external 

6 measurements, but tens and tens of thousands. 

7 So we have a fair monitoring history. The 

8 question though is when you get down to this time 

9 period, and we have two to 23 percent of the 

10 workers monitored, the profile review asserts 

11 that we don't really know and can't prove to a 

12 reasonable person that the workers who were 

13 monitored were the ones most likely to be 

14 exposed. This is a very similar theme that we've 

15 seen in other reviews. 

16 We do know job category here, but the fact is if 

17 you go through and analyze by job category, it 

18 turns out that a fairly wide spectrum of workers 

19 were monitored. I mean, you will see, and my 

20 original thought was you would see chemical 

21 operators or something like that and then none of 

22 the service folks. And what happened is you see 

23 a fairly diverse spectrum of workers being 

24 monitored. 

25 SOL has gone and interviewed support personnel 
218

1 staff, the health physics staff, and they pointed 

2 to documents, procedures which we have which we 

3 will provide, that indicates that there was a 

4 very conscious effort on the part of Y-12 health 

5 physics staff at that time to monitor maximally 

6 exposed individuals, those who had the 

7 significant potential for exposure. 

8 If you couple that, and they've gone back and 

9 done an analysis of these support personnel that 

10 were indicated that maybe were not monitored 

11 properly. It turns out that during the time 

12 period when the monitoring was conducted, about 

13 11 percent in this early time frame prior to 

14 1961, of support service personnel were actually 

15 monitored, not a hundred percent, but it's right 

16 in the same ballpark of the -- 

17 MR. FITZGERALD: Were these the -- certainly Bob 

18 can speak better than I can, but are these the 

19 outside maintenance or outside support people as 

20 opposed to the inside? Because it took us awhile 

21 to figure that out that there were support staff 

22 on the line programs versus what they called 

23 outside support or outside maintenance and sort 

24 of two distinct groups. And we found actually 

25 monitoring information and dose values for the 
219

1 support personnel on the line but not for the so2 called outside maintenance staff. 

3 DR. NETON: Now are you talking about 

4 subcontract, like -- 

5 MR. FITZGERALD: No, no, they made a distinction 

6 between two groups of support service workers. 

7 Ones that were, in fact, assigned to a specific 

8 facility, a specific operation, and were 

9 providing dedicated support to that operation 

10 versus -- I'm not sure what the best term would 

11 be, maybe sort of a freelance, support folks that 

12 would work anywhere in the plant on a daily 

13 assignment almost. They would provide 

14 maintenance, even over at the X-10 facility. 

15 And those folks seemingly did not have the 

16 monitoring, regular monitoring, routine 

17 monitoring that the people that were assigned to 

18 the line programs did. If you were a 92-12 

19 maintenance person, you did get monitored just as 

20 if you were a chem operator, it was a regular 

21 monitoring. But if you were an outside 

22 maintenance person, you could probably well not 

23 be monitored, and in fact, we interviewed a 

24 number of them. Interviewed workers from both 

25 groups, and clearly the one group was distinct 
220

1 and different even though they were both 

2 maintenance people. 

3 DR. NETON: Well, I don't know the answer to that 

4 question. I mean there was really just out of 

5 the database that was polled, 317 workers with 

6 job titles including, you know, pipe fitter, 

7 plumber, steam fitter were identified which was 

8 about 11 percent of the population. 

9 MR. PRESLEY: Can I talk? Can I talk? 

10 All right, at Y-12 you had -- this is Bob 

11 Presley. At Y-12 you had what we call a prime 

12 construction contractor. Then you had Y-12's own 

13 individual construction people. The people that 

14 worked for Y-12 we had carpenters and pipe 

15 fitters and everything like that. Some of them, 

16 yes, were assigned to work full time up in the 

17 areas of 92-12 or alpha five, places like that 

18 because we had satellite shops. And those people 

19 should have had a badge and should have been 

20 monitored just like everybody else in the plant. 

21 You had a prime construction contractor at that 

22 time I believe was Rust Engineering. And those 

23 people were hired to do nothing but construction 

24 or tear down. They would go in, if we decided to 

25 build a new building, they would go in and build 
221

1 that building and turn it over to Y-12. And then 

2 we would start production in that building. You 

3 have to know whether those people are Y-12 

4 employees or whether they are Rust or M.K. 

5 Ferguson (ph) because it's very likely that what 

6 you've got is everything rolled into one. You've 

7 got so many, say 200 pipe fitters. 

8 Well, those pipe fitters, Y-12 didn't have 200 

9 pipe fitters. We just didn't do, you know, we 

10 didn't have that much pipe fitting because the 

11 pipe fitting on the new buildings was done before 

12 we ever took it over. So you've got two sets of 

13 people. You've got construction contractors and 

14 then you've actually got people that worked for 

15 Y-12. 

16 MR. FITZGERALD: Well, it sounds like we might 

17 actually have three based on the worker 

18 interviews that we -- 

19 MR. PRESLEY: And yes, there were. People that 

20 went to all three plant sites. 

21 MR. FITZGERALD: Yeah, I was going to say -- not 

22 to dwell on this, but this might be important 

23 certainly for the SEC reviews, the fact that 

24 there were the dedicated, in fact, we did have 

25 the interviews with 92-12 and alpha maintenance 
222

1 people. We also had interviews with a group that 

2 called themselves the outside maintenance staff, 

3 but not, not, they weren't construction staff. 

4 They were people that were covering the entire 

5 site with different assignments. They were Y-12 

6 employees, so -- 

7 MR. GRIFFON: Like a pool maintenance -- 

8 MR. FITZGERALD: Like pool maintenance, and those 

9 folks generally were not monitored. And that was 

10 of concern and that's something that would be 

11 useful to pin down. But literally, that was the 

12 answer we got back. And now the ones that were 

13 assigned to specific operations as Bob was 

14 pointing out clearly were, in fact, monitored. 

15 And we can go back to the early '60s and find 

16 data for those specific workers as being 

17 monitored. They were monitored just like the 

18 chem operators were so... 

19 DR. NETON: Right, you made a very important 

20 distinction though. Right now NIOSH is not doing 

21 dose reconstructions for building trades folks 

22 that were not related to the prime contractor. 

23 We recognize that those folks were not monitored 

24 and there was special exposure circumstances, and 

25 this is complex wide where we have held up those 
223

1 things. And in fact, we have a contract in place 

2 with the Center to Protect Workers' Rights to 

3 help us evaluate the potential exposure 

4 conditions for those, that special -- 

5 MR. FITZGERALD: What I'm saying though is that 

6 just, the clarification for that group that we're 

7 talking about may be whether or not they were -- 

8 DR. NETON: And I appreciate that because I'm not 

9 sure that that was really pointed out as a 

10 difference in the review. 

11 MR. FITZGERALD: Right, and what we say here is 

12 that we couldn't nail the personnel records and 

13 figure out, you know, who was actually who in 

14 some of these cases. 

15 DR. NETON: In fact, whoever these 372 workers 

16 are, we've compared them to the average of the 

17 monitored population, in fact, they are lower 

18 than the average population of the workers that 

19 were monitored during that period. So that's 

20 some of the data that we tried to flesh out. 

21 One more issue that we tried to address. I'm 

22 sorry, these were the five major findings, and 

23 then as we get down here there were some five, 

24 there were ten total findings. Now I'm 

25 refreshing my memory, but we won't dwell on these 
224

1 right now. Let's stick with -- 

2 MR. GRIFFON: We've got about ten minutes. 

3 DR. NETON: We've got about ten minutes here so 

4 in the interest of saving time I want to just 

5 switch over to this one slide that I have. 

6 MR. GRIFFON: Jim, while you're switching can I 

7 ask, is any of this data, the databases you 

8 referenced, are they on the O drive? Are they 

9 accessible to us to see this data, all this 

10 monitoring data, you talked about, nine thousand 

11 samples, et cetera? 

12 DR. NETON: I don't believe it's readily 

13 accessible. Dick Toohey is not here right now, 

14 but we can certainly try to get those out there 

15 and make them available. They may be, but I'm 

16 not sure if they are. Those tend to be more -- a 

17 lot of this data came out of CDR databases very 

18 much like Mallinckrodt data. We'd need to put it 

19 out there in special format and everything so we 

20 can work on that. 

21 MR. GRIFFON: If that can be done, that'd be 

22 great. 

23 DR. NETON: This slide is very confusing so I 

24 apologize for that. I didn't put it together, 

25 but it's instructive. If I just can step you 
225

1 through here, this speaks to the issue of were 

2 the maximally exposed people monitored or not at 

3 the facility. So what we have here is the cut 

4 point. 

5 After 1961 almost everybody was, external 

6 exposure was monitored. And so we have prior to 

7 '61, after '61 which is the green hash line 

8 there. The red dots on the top are the maximally 

9 exposed workers by quarter during all those 

10 monitoring periods. If you notice, prior to '61 

11 and after '61, the maximum exposed workers 

12 continue to be about the same. There is no trend 

13 there in the data set. However, after '61 when 

14 you start monitoring everyone, you notice a trend 

15 going down which is not what you would expect if 

16 only the lesser exposed individuals were 

17 monitored where you're not capturing the maximum 

18 exposures. 

19 So this is somewhat instructive to point out 

20 that, you know, we believe there's sort of a 

21 three-pronged approach here. You talk to the 

22 line. You talk to the health physics staff. You 

23 talk to line managers. They indicate the 

24 maximally exposed people were monitored. There's 

25 some documentation to support that fact, and then 
226

1 you look at the monitoring data itself, and it 

2 also bears that out. So we feel we have a pretty 

3 good handle on this fact. And you know, we need 

4 to move forward on this, and we can engage in 

5 some -- 

6 MR. FITZGERALD: But just to confirm what you're 

7 saying is that the interviews plus the empirical 

8 information is pretty much what this would have 

9 to rest on. There still isn't anything that 

10 would be documentation procedures or -- 

11 DR. NETON: There are, well, there are a couple 

12 later reports issued like in the late '50s that 

13 when they were switching over from, I think a 

14 weekly to a quarterly program, there's some very 

15 good discussion in these documents while working 

16 with line management and discussing who should be 

17 on based on past histories of what the monitoring 

18 program is showing and that sort of thing. 

19 You know, I'm not sure what more we can produce 

20 on this, but it certainly is all pointing toward 

21 a direction that these folks were the highest 

22 exposed individuals were monitored. This is a 

23 very significant issue though because it also 

24 carries over into the internal dose area where 

25 we've worked on a coworker analysis of the 
227

1 hundreds of thousands of urine samples that were 

2 taken and intend to use those to establish bounds 

3 for the internal dose of unmonitored workers. We 

are proposing to use the 50th 4 percentile, and we 

have been using the 50th 5 percentile to assign 

6 unmonitored workers since we believe that the 

7 monitored workers were the maximally exposed. 

8 Now the profile review is suggesting that no, you 

need to use the 95th 9 percentile to assign that to 

10 unmonitored workers. That puts you in -- if 

11 these workers really were the most exposed, the 

12 absurd situation of assigning higher doses to 

13 unmonitored workers the 95 percent of the 

14 monitored workers. And that's not very appealing 

15 to us, and I think we can discuss this when we 

have more time about why we believe the 50th 16 

17 percentile is more appropriate for these workers 

than assign the 95th 18 percentile to the 

19 unmonitored workforce. 

20 That's probably about as far as we can get into 

21 this given five minutes left, but I think it's 

22 important to keep these thoughts for the 

23 subcommittee meeting. We're going to work out 

24 these details, you know, flesh these out in more 

25 detail. And if we have time, we can engage in 
228

1 some discussion just with the Bethlehem Steel 

2 profile with SC&A, and maybe, you know, some 

3 facts out there that they can react to. 

4 MR. GRIFFON: Just one other question. Are there 

5 other new TIBs? You mentioned one new TIB that 

6 might have come after this review or was it 

7 considered during this review? I mean... 

8 DR. NETON: Most of them were considered during 

9 this review. I think there were a couple. 

10 There's one that was, that evaluated the external 

11 exposures in 1948 and '49 that documented what 

12 was done and the pocket ion chambers and that 

13 sort of thing. And there is another one coming 

14 out that is in press, and the subject of it 

15 escapes me at the moment, but I think it's the 

16 beta dosimetry. 

17 There's a three-part series that discusses gamma, 

18 historical gamma, historical neutron, and there's 

19 an historical beta document coming out. So those 

20 are all out there on, as they’re published on the 

21 O drive or X drive or whatever it is on your 

22 computer, and they're available for review. 

23 There's probably, I had them totaled up but 

24 there's probably eight or so documents that are 

25 supplemental to the TIB and most of them were 
229

1 considered as part of this review. That's 

2 probably all we're going to be able -- 

3 MR. GRIFFON: Yeah, that's about -- okay. 

4 MR. FITZGERALD: And I guess maybe a thought 

5 would be to pick this up that Monday before. 

6 MR. GRIFFON: Yeah, my hope is, again 

7 tentatively, I think we need to try to close out 

8 Bethlehem Steel at the subcommittee level, 

9 continue on our procedures review, and probably 

10 take up Y-12 before Savannah River. We have a 

11 full day of subcommittee so -- 

12 MR. FITZGERALD: Well, this will help. We'll 

13 have Joyce Lipsztein who did a lot of the 

14 internal section, in Knoxville, so that will be 

15 good timing for that. 

16 MR. PRESLEY: Before we stop, can I make a 

17 suggestion or a motion or something that the next 

18 time we have a committee meeting that we kind of 

19 meet where everybody's at a round table where we 

20 can meet as a roundtable discussion, and we 

21 don't, you know, it's nice to see everybody's 

22 face. 

23 And the other thing that we could -- public 

24 comment's fine, but the telephone call-ins and 

25 stuff like that's been awful today. You know, 
230

1 we've had trouble listening to everybody and 

2 hearing what they say. And I kind of have a 

3 problem with that. If you're here, fine, but if 

4 we have a committee meeting, we need to, they 

5 need to be here. 

6 MR. GRIFFON: Yeah, I'm not sure we can make a 

7 motion here. It might be something we should 

8 bring up at a regular board meeting, and you 

9 know, bring up the format of these work group 

10 meetings as well as the, you know, the telephone 

11 aspect because it does make it difficult 

12 especially when we're sorting through technical 

13 documents. 

14 Anything else? All right, I guess we'll see 

15 y'all in a few weeks, two weeks. Meeting 

16 adjourned. 

17 (Meeting adjourned at 4:30 p.m.) 

18 

19 

20 
231

C E R T I F I C A T E OF COURT REPORTER 

STATE OF GEORGIA 

COUNTY OF FULTON 

 I, Steven Ray Green, Certified Merit Court 

Reporter, do hereby certify that I reported and 

transcribed the above and foregoing from the 

day of Oct. 6, 2005; 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 

6th day of December, 2005. 

_____________________ 

STEVEN RAY GREEN, CCR 

CERTIFIED MERIT COURT REPORTER 

CERTIFICATE NUMBER: A-2102