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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Fernald Work Group

Friday, August 10, 2018

The Work Group convened via teleconference at 

11:00 a.m. Eastern Time, Bradley P. Clawson, 

Chairman, presiding.
2 

Members Present: 

Bradley P. Clawson, Chair

Philip Schofield, Member

Paul L. Ziemer, Member

Also Present: 

Ted Katz, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Ron Buchanan, SC&A 

Stu Hinnefeld, DCAS

Jenny Lin Naylor, Hhs

Mark Rolfes, DCAS

Mutty Sharfi, ORAU Team

John Stiver, SC&A
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Fernald Work Group 

Friday, August 10, 2018 1

Roll Call/Welcome 4

Reconstruction of Doses Associated with 

Raffinate-Area Exposures 6

Reconstruction of Recycled Uranium 

Constituent Exposures 20

Review Status of Fernald Site Profile 

Issues/Plans for August ABRWH Meeting 

Report 53

Adjourn 54
4 

Proceedings

(11:00 a.m.) 

Roll Call/Welcome

Mr. Katz: Welcome, everyone. This is Advisory 

Board on Radiation Worker Health. It's the Fernald 

Work Group and we continuation of our Site Profile 

Review today in preparation for the Board meeting a 

little later in the month.

For people of the public who want to follow along, the 

agenda for today's meeting and the materials for 

today's meeting is posted on the NIOSH website for 

this program under "Schedule of Meetings," today's 

date.

You can go there, pull up the agenda. The agenda's 

very simple, so there's not really much to gain from 

the agenda.

But there are also the background documents related 

to this discussion today on topics posted there. So, 

you can either pull them up and read them as we're 

discussing or afterwards, what have you.

And then, let me just also note for members of the 

public and others who are not accustomed to these 

meetings.

Please mute your phones except when -- I hear a dog 

barking now -- except when you're addressing the 

group. And, if you don't have a mute button, press 

star six to mute your phone. And then, you can press 

star six again to take yourself off of mute.

And, also, please, no one put this call on hold at any 

point. Just hang up and dial back in if you need to 

go for a piece. Because hold will disrupt everyone 

else's call as long as you're on hold. 

I think that takes care of those matters.
5

Roll call, so I have -- and we're speaking about a 

specific site, so please, as we do roll call, address 

conflict of interest, but it doesn't really apply to the 

Work Group Members because they all, by virtue of 

being on the Work Group, do not have conflicts of 

interest.

And, there is Brad Clawson who is the Chair of this 

Work Group and he's in attendance.

And Dr. Paul Ziemer and Phil Schofield, Members of 

the Work Group. So, they have no conflicts and 

they're all in attendance.

And, let's go on and find out who NIOSH ORAU team 

is with us.

(Roll Call)

Mr. Katz: Okay, that takes care of all the 

administrative matters, and Brad, it's your meeting.

Chair Clawson: Well, now that I got off mute, that 

may help.

Well, I'd like to welcome everybody and thank you 

everybody for coming today.

I think, though, it's been a while since we've had a 

Fernald Work Group. So, John Stiver, could you give 

us just kind of a couple minute sound bite of where -

- how we've come to where we're at right now and 

last remaining things that we have to go over?

Could you do that for me? Just sort of get --

Mr. Stiver: Yes, sure.

Chair Clawson: -- so everybody's getting back on the 

board of where we're at.

Mr. Stiver: Yes, the last meeting we had was back in 

March, it was March 15th of this year.

And, we were going over the Site Profile issues that 
6

were still open. And, the ones that are still remaining 

after that meeting are the findings related to 

constituents and recycled uranium just for the period 

1961 to 1972.

And also, the raffinates that are four in uranium and 

radium and how to handle those.

So, those are the two issues that we're going to be 

going over today.

Chair Clawson: Okay, thank you.

So, which one do we want to tackle first? Do we want 

to go into uranium?

Mr. Barton: Brad, this is Bob.

I think probably the quicker of these discussions is 

going to be raffinate issue.

Chair Clawson: Okay.

Mr. Barton: So, if it's amendable, what I can do is 

kind of just quickly tee that up a little bit and then 

isolate those events there through paper and then we 

can discuss it.

Chair Clawson: Okay, that sounds fine.

Reconstruction of Doses Associated with RaffinateArea Exposures

Mr. Barton: Okay. And, as John said, what we're 

talking about is raffinate material that is pouring 

uranium and radium.

To reconstruct raffinates, there were two methods 

essentially on the table when this issue really kind of 

came to fruition.

The two methods, one is to use uranium urinalysis 

and ratios to get the other constituents that are in 

with the raffinate.
7

And then, you have intakes of all of the radionuclides 

of interest.

Now, of course, the problem with that, if we're talking 

about uranium-poor raffinates, there's not a lot of 

uranium there.

So, what is the bioassay program really going to see? 

They're going to, you know, throw a really large ratio 

on top of that if we're talking about uranium-poor 

material.

So, that didn't seem like a very feasible option.

And the other method was to use radon breath 

analysis, which, of course, requires that there's 

radium present.

And, again, if we have uranium and radium-poor 

raffinate material and you don't have the actual 

radon there, if there's no radium, then that doesn't 

really see like a viable option.

So, we brought up this issue of the uranium radium 

poor raffinates. And, initially the response was, well, 

we really don't think that there's exposure potential 

there.

And, SC&A came back and said, well, you know, what 

we do have is we have all of these air sampling 

studies, also known as daily weighted exposures in 

Plant 23 during the period of interest. Is there 

something we could possibly, you know, do with that 

data to either assign the constituent exposures from 

uranium and radium poor materials? Or, otherwise 

prove that the exposure potential is either not there 

and/or bounded?

That's kind of where we left it off at the last meeting. 

And, we have NIOSH's recent memo or White Paper 

on it that came in July.

So, at this point, I guess I'd like to turn it over to 

NIOSH ORAU and if they'd like to go through what 
8

their response is and what their position is.

And then, I think we can probably have a fairly quick 

discussion about it.

Dr. Hinnefeld: Okay, this is Stu Hinnefeld. I'll go 

ahead and lead off and anybody who wants to correct 

me, go ahead and jump in and correct me from 

NIOSH or ORAU.

PARTICIPANT: Hello?

Dr. Hinnefeld: Can anybody hear me? Can 

everybody hear me okay?

(Simultaneous Speaking)

Mr. Katz: It sounds like someone's trying to break 

in. Is there someone on the line that maybe isn't 

needing to be on this Work Group call from the 

public?

Okay.

Dr. Hinnefeld: Okay, I'll --

Mr. Katz: Okay, go ahead, Stu.

Dr. Hinnefeld: I'll go ahead.

Well, we actually had two parts of our approach --

two parts of our paper here and, rather than go 

through the paper, I'll just sort of summarize.

The one thing we did was we went back, as Bob 

mentioned, there is a fair amount of air sampling 

data from the plants in these years that's called a 

daily weighted exposure information which is 

essentially air sampling analysis.

And, we looked at locations in the refinery that are -

- these locations in the refinery that we think would 

be probably the most likely location for raffinate 

exposure if there were raffinate exposures.
9

And we -- and that was the location in the refinery 

called the combined raffinate area. And there are 

DWE studies for that area for a number of years, in 

these early years.

It's also important to know at this time that according 

to the information we found in the SRDB, the refinery 

ran ores from like 1954 through 1958.

They had used up the ores and they started operating 

-- started using for feed materials, things that were 

called ore concentrates.

These are materials that have been treated at a 

uranium mill, chemically treated uranium mill. And 

so, essentially, the radium has been removed.

It could still have thorium-230 in it. And so, you 

would still have that additional constituent in addition 

to the uranium when you were processing ore 

concentrates.

The -- so, the refinery appeared to run ore 

concentrates from about '59 through '61 to '62 when 

the refinery shut down for a number of years and all 

the refinery -- uranium refinery work was then 

shipped to Weldon Springs.

In 1966, though, the Fernald refinery reopened, this 

would be in fiscal 1966. So, it would be in the last -

- the end part of calendar 1965.

They reopened the Fernald refinery. But, at this 

point, the feed materials to the refinery were 

reclaimed uranium scrap or scrap resite.

So, this is uranium, byproducts of uranium 

production that were then ran back through the 

refinery to reclaim the uranium that was still 

remaining in these uranium -- in these byproducts of 

production.

And, the key fact here is that, since this had 

previously been purified uranium, thorium-230 would 
10

be gone from that. It would have been refined out 

before it ever became this uranium that you could 

then reclaim and send back through to refine, 

become reclaimed or recycled. It wasn't -- well, I 

don't want to use recycled, it was reclaimed scrap.

So, there is also -- now, that's -- we have -- so we 

have a difference in the feed material between '59 

and 1962 and '66 through, I think we had data to 

around '69 or something like that.

So, the feed materials were different. But, when we 

looked at the daily weighted exposure data for this 

combined raffinate area for those two periods of 

time, the air concentrations were essentially the 

same to one significant figure.

So, that gave us some clue that now there didn't 

seem to be a lot of potential for this thorium-230 

raffinate or thorium-230 that would have been in 

there form the '59/'62 period. There didn't seem a 

lot of potential for that -- for exposure to that.

Because, when they were running material that didn't 

have thorium-230, the air concentrations were the 

same as they were from '59 to '62.

So, that gave us some clue that we think maybe 

we're not -- we're okay here and that there's no real 

DWE value to use for thorium-230 intake for dose 

reconstruction.

The second thing to remember when we're doing 

dose reconstruction during this period is that this 

material, this uranium ore concentrate was not only 

handled in the raffinate area, it was also handled at 

the feed to digestion area.

In other words, the -- you know, they - the material 

had to be digested in order to be purified. And so, it 

had to be dumped into the digesters.

And, the thorium-230 would be present there. And 
11

so, people involved in that operation would be 

exposed to the uranium with thorium-230 for lack of 

a better concentration, we'll assume it will be in 

equilibrium with the uranium because it wouldn't be 

any higher than that and we don't know that it 

wouldn't be any lower than that.

So, they would be exposed to the uranium and the 

thorium-230 at the feeding and the refining. Again, 

we're talking from the '59 to '62 period.

And so, since those people are getting exposed to 

that, we won't have any way for any particular 

employees' record of knowing whether they were 

exposed to their, you know, the feed and/or not. 

We'll just have to assume that everybody was 

exposed during that period unless there's a clear, 

clear reason to believe that they weren't exposed in 

the refinery and that would have to be pretty 

convincing evidence.

So, we'll just assume that pretty much everybody 

exposed during that period, '59 to '62, was exposed 

to the ore concentrates as they were fed to the 

refinery.

So, when we do a dose reconstruction based on the 

uranium bioassay for people during that period, we 

would add in the thorium-230 and the other 

constituents that are found in the cold metal 

raffinate, cold metal oxide tank in Silo 3.

So, all those radioactive contaminants would come 

along in the proportions in which they exist in Silo 3 

with the thorium-230 and the uranium and that 

would all be applied to uranium bioassay for that 

period of years.

So, we believe by using that technique, we have 

clearly -- we feel like we have a bounding method or 

certainly a claimant-favorable method for doing dose 

reconstructions during this period.
12

And, I'll be glad to answer any questions or interested 

in Bob's reaction and SC&A's reaction to that.

Mr. Barton: Well, I guess, first, are there any 

questions for Stu before I get started?

(No Audible Response)

Mr. Barton: Okay, hearing none, I think really that 

second part, Stu, is really the most powerful piece of 

evidence. And, I know not all the Board Members 

appear to be on Skype, but I am using the NIOSH 

spreadsheet where they sort of did these 

calculations. I'll try to describe it as best I can for 

the Board Members who can't see it.

And, the first think we're looking at, I guess this is 

really answering the question. If there was going to 

be an exposure potential to thorium-230, that was, 

again, separated out and it couldn't really be 

detected in a great way by the uranium urinalysis, or 

at least that could be in theory, you would see that 

in the daily weighted exposures, you'd see high alpha 

activity in this raffinate area where the uranium's not 

supposed to be.

So, what NIOSH did, and I think it's an excellent 

approach to really get our heads around this problem 

is to say, well, you know, what are the actual 

numbers if we were going to kind of simulate this 

thing?

What kind of thorium-230 dose could we get based 

on the air sampling data? And, let's go ahead and 

compare that to the methods that Stu just described 

about the sort of the front end process where there 

is still uranium present and they're also adding in a 

thorium component.

How do components of that actually compare?

So, that's really what they did here. And, what I'm 

looking at, for those of you who can't see, is the 
13

adjustment of the daily weighted exposures.

And, anything to those for those of you who can see, 

that's kind of highlighted in green, is sort of an SC&A 

addition to the spreadsheet.

So, what we're looking at is the air sampling data for 

that combined raffinate area was your exposures 

could have happened during the years of interest was 

almost universally -- it was universally point one 

times the maximum allowable concentration.

So, just to show that reference right here. You can 

see here the years of interest times the max and 

we're going to go down to the raffinate and it's all 

point one.

So, that's essentially what our starting point is to 

assess the air sampling data and see what potential 

do we have for thorium-230.

Now, of course, the assumption that it's all thorium230 isn't really realistic and I think for the reasons 

she stated in sort of the first point. But, let's play the 

game anyway.

And, hold on, I've got to get this out of the way.

Mr. Katz: While you're doing that, Bob, let me ask, I 

just heard the phone ring and a constant -- there's a 

constant noise in the background.

Someone, unless that's your phone, I don't think it 

is, Bob Barton, someone has an open line either a 

member of the public or it's one of the participants.

And, it's driving everyone nuts. So, can you please 

either have --

I think that was Zaida trying to work the problem, 

but either hang up or put your phone on mute, *6 to 

put your phone on mute if you want to stay on this 

call, otherwise, we'll have to cut your line.
14

Thank you.

Okay, sorry, Bob.

Mr. Barton: No problem at all.

Okay, so the number to remember here, when you 

do very basic health physics calculation, it's only 1.2 

meters cubed per hour and your breathing rate per 

day, a full ten-hour workday, times that value of 

point one times the max, you get an intake of 

approximately 26 picocurie per day and that's the 

number that we're going to keep in mind when we go 

to look at what happens when we go and use the 

urine data and a ratio approach.

So, 26 picocurie per day, and I highlighted it here 

because the point one times the MAC is actually the 

values given for the period and the location was in 

Plant 2/3 that we're really interested in. So, 26 

picocurie per day.

And, NIOSH did it, they said, okay, we're going to go 

with the lowest potential of uranium exposure that 

we can. And it's a uranium missed dose based on 

solubility Type F.

So, basically, this is -- this would be the lowest 

uranium intake that you really could calculate.

And, what they came up with is that when you do just 

the uranium intake, you get about 24 picocurie per 

day. And, when you add in the ratios, it gets up that 

-- so that uranium combined with the thorium-230, 

you're up around 52.

And then, if you only look what would be the nonuranium component which is essentially your alpha 

component which is mainly thorium-230, based again 

on that bare bones calculation, you end up with an 

intake rate of 27 point --

So, anyway, using the uranium urinalysis data and 

sort of the minimum intake rate assumptions, you 
15

get 27 picocurie per day which actually bounds what 

we get if we assumed it was all thorium-230 based 

on the air sampling data.

So that's, again, so it's bounded right there with the 

bare bones analysis.

Now, I just want to point out, that's Type F 

highlighted up here in yellow. If you use type M, it's 

up around a 100 picocurie which actually translates, 

as you see down in here in green to about a 111, 112 

picocurie per day for non-uranium alpha.

If you use Type S as the assumption for -- and, again, 

this is missed dose -- now you're up around 1,600, 

1,700 picocurie per day which, again, we're 

comparing to 26 picocurie per day predicted by the 

air sampling data.

And then, one more piece of evidence, I actually went 

and looked and saw what are the coworker 

assignments?

And, for Type F, the coworker assignments are more 

than double that. So, at the ratio, it directly related 

to -- the thorium intake is directly related to the ratio 

to uranium.

Again, your thorium intake is going to double. And, 

that's just the 50th percentile of Type F.

And, you can see these numbers get quite high 

compared to what the actual thorium intake estimate 

would be if we used the air sampling data available 

to us that's in the area where you would expect these 

uranium and radium for rapid exposures during the 

period of interest.

So, essentially, what this shows is that even though 

you wouldn't expect exposures to thorium-230 alone 

where uranium's not present to be bounded by the 

uranium urinalysis data, the assumptions made by 

NIOSH and the TBD, even with the most bare bones 
16

case of Type F solubility, and a missed dose, not even 

a coworker dose or anything like that, you're still 

bounding the intake based on the air sampling data.

So, what that tells me is there really isn't the 

potential to miss a significant exposure to thorium230 which is the main concerns of these uranium and 

radium-poor raffinates simply based on using the 

methodology of ratioing to the uranium when it's 

present in the front end of the process.

So, what basically NIOSH showed is that their 

method is going to bound anything that we can come 

up with using the actual air sampling data which is 

really exactly what we were looking for and sort of 

discussed at the last meeting as a way to put this to 

bed.

So, I was very glad to see that, but I think it's a very 

pragmatic way to go about the problem and I think it 

shows that, at least from where I sit, we can put this 

issue to bed.

Anyway, I showed a lot of numbers out there, 

probably hard to follow without a flowchart, but if I 

can answer any questions on that, I'd be happy to.

Member Ziemer: This is Ziemer.

I think the logic follows pretty well. I think, to me, 

it's a convincing argument. So, I'm -- I certainly 

support the recommendation to use this.

I do have one sort of question on some of the related 

documents that were provided in paper. Let's see, 

I'm looking right now at the one called Fernald DWE 

Missed Intake. It's a brief paper from NIOSH.

What I'm wondering, as I look at the paper, the first 

page is called page 1 of 2. And the second page is 

called page 2 of 3. And the third page is called page 

3 of 4.

But, I'm trying to figure out if something's missing 
17

here or is it? Do you see what I'm looking at?

Mr. Barton: I'm looking at the one that was directly 

off the website and the page numbering is correct on 

that one. I wonder if it could have been a mistake in 

the original transcript?

Member Ziemer: No, I'm looking at the ones that 

Ted distributed. Actually, both of the -- the one 

called Fernald DW Missed Intake and the one called 

Fernald Recycled Uranium Constituents, both have 

the pagination issue which I just want to confirm that 

we got everything that's supposed to be there.

Because they both start with page 1 of 2. They both 

follow as page 2 of 3. And then, they both have page 

3 of 4.

So, it makes -- it looks like something's missing but 

wording wise, it looks okay. Do you see where I'm 

looking down in the lower right hand corner of these 

things where the pagination is.

Mr. Barton: Yes, Dr. Ziemer, this is Bob. I'm not 

sure, the one I'm operating off of was on the website 

and it is -- it's numbered correctly there. I'm not --

Member Ziemer: Yes, okay. So --

Mr. Barton: It could be an error in transmittal or 

something.

Member Ziemer: Yes, as I read through it, the paper 

looks fine, so I'm just assuming those are just 

somehow the pagination ended up in a screwy way. 

But, the rest of the material follows, I think, the logic 

is there, the reasoning as well and I'm okay with it.

Mr. Katz: Phil, Brad?

Member Schofield: It seems like a logical way to go 

to me.

Mr. Katz: Did we lose Brad?
18

Member Schofield: May be on mute still.

Mr. Katz: Yes.

Chair Clawson: Yes, somebody muted me so I talked 

there for a while to myself, that's nothing new.

But, anyway --

(Laughter)

Chair Clawson: -- it sounds all right with me. I'm --

it's just I'll need to talk a little on it, but I'm just trying 

to get my head around all this.

But, anyway, so I guess I'll talk to the other Board 

Members about this and if we're good with this 

process, then this will close this issue, correct?

Mr. Katz: Right, right, I think so.

Member Ziemer: It's as pretty clear to me and Bob 

with this what we're asking here.

Mr. Katz: Okay.

And, Phil?

(Simultaneous Speaking)

Chair Clawson: Yes, it does --

Mr. Katz: What's that?

Chair Clawson: I was going to say, based on the data 

and everything, it looks like they have managed to 

bound it.

Mr. Katz: Okay.

Chair Clawson: So, I don't have a problem with that.

Mr. Katz: Okay, so, Bob?

Dr. Hinnefeld: Brad, can you hear me now?
19

Chair Clawson: Yes, I can now.

Dr. Hinnefeld: Okay, because a few minutes ago 

when Paul was speaking about the pagination issue, 

I was trying to speak and I had my mute off but no 

one could hear me.

I just wanted to explain the paging issue if anybody's 

interested in that.

Chair Clawson: I'm more worried just about the data 

than anything.

Dr. Hinnefeld: Yes.

Chair Clawson: But, yes, I believe Zaida went around 

and muted us all and --

Dr. Hinnefeld: Yes.

Chair Clawson: -- I've got a mute button on my 

headset that I use. So, I've been talking to myself, 

too.

But, if you want to just take a minute, I know Dr. 

Ziemer had that issue. So, if you want to take a 

minute.

Dr. Hinnefeld: Yes, it'll take a minute, it'll be very 

quick.

I sent to Ted a version when it was ready to distribute 

to the Work Group Members and I also sent it out to 

SC&A so that they would have the text and the 

content of the memo.

And, I had not paid much attention to the pagination 

or other of the accouterments that go with it.

And so, our web team, our web person, when she got 

this -- the copy to post, corrected all those things and 

corrected the pagination.

So, the version on the website, the paging is correct 

but it's exactly the same paper.
20

Member Ziemer: Okay, so, if we got it afterwards --

Dr. Hinnefeld: It has, again, a better cover sheet on 

it, a better title sheet on the web.

Member Ziemer: Yes.

Dr. Hinnefeld: So you have correct copy.

Member Ziemer: But, we've got everything we're 

supposed to get, right?

Dr. Hinnefeld: Yes, you did.

Member Ziemer: Yes, got it.

Chair Clawson: Okay, well, that takes care of that 

issue. So, let's go to the next one. Bob, are you 

going to do that one?

Reconstruction of Recycled Uranium Constituent 

Exposures

Mr. Barton: Sure, I mean, maybe in a similar way 

we just did the raffinate issue. I can quickly tee it up 

and then Stu or his team can talk about where their 

position stands and then we definitely have a few 

more questions on this issue than on the raffinate 

issue. So anything could happen.

So, anyway, recycled uranium, I'm sure it's, you 

know, it's been an issue for a long time if we recall 

way back in the 2011 to 2012 time frame.

For this period we're talking about which is prior to 

1973, the ratio that had been agreed upon at that 

time was a 100 parts per billion plutonium on a mass 

uranium basis. So, a 100 parts per billion.

And, that -- the whole issue was really put in 

abeyance until the TBD was revised and we could 

kind of see those numbers, you know, in the flesh, so 

to speak.

When the revised -- until TBD came out, though, we 
21

noticed that, for this time period, the 100 parts per 

billion had been reduced to 10 parts per billion.

So, over at SC&A, our natural reaction was, well, 

what's the reason that the agreed upon ratios have 

been reduced?

At that time, it was postulated that, well, we reexamined the underlying data which is in the very 

sensitive report, we refer to it was DOE 2000, but 

now, it's basically an entire report on recycled 

uranium that includes a lot of data for recycled 

uranium.

And so, we said, okay, well, when we went into that 

database, we couldn't figure out who you knew which 

samples were for the period we're looking at. So, 

from that period prior to 1973, or more specifically, 

1961 to 1972.

That's when NIOSH sort of gave us the information 

which is contained in the same report that says, well, 

you know what? DOE 2000 says that these lot ID 

numbers which are a string of alphanumeric numbers 

associated with each sample, there's actually a way 

to decode them or a certain portion of them to obtain 

the month and year in which, you know, that lot was 

on site and being processed and whatnot.

And so, we went in and we did --

(Pause)

Mr. Katz: Bob, did you just go on mute?

(No Response)

Mr. Katz: Bob, we can't hear you.

(No Response)

Chair Clawson: Hello?

Mr. Katz: Who's that?
22

Chair Clawson: That's me, Brad.

Mr. Katz: Oh, Brad? Okay. All right, I'm trying to -

-

Chair Clawson: Yes, I think --

Mr. Katz: We lost Bob somehow.

Dr. Hinnefeld: This is Stu.

If you'd like, I can try to pick up for Bob and describe 

what he did.

Chair Clawson: Well, we need to -- we need to make 

sure Bob is back on the line, though.

Dr. Hinnefeld: I think he will.

Chair Clawson: Because, we just --

Dr. Hinnefeld: I don't know if what happened to him 

happened to me because earlier, I was chatting and 

my mute button is a light on my phone. I push it to 

go -- it comes on and push it and it goes off.

So, I clearly was off mute and no one could hear me.

Chair Clawson: Yes, right.

Mr. Katz: Zaida hasn't --

(Simultaneous Speaking)

Mr. Katz: -- recently, so it's not Zaida in this case.

Dr. Hinnefeld: Well, his phone could have dropped 

him.

Chair Clawson: Yes, Bob are you out there?

(No Response)

Chair Clawson: Hey, John, you may want to text him 

and let him know he's talking to himself.
23

Mr. Stiver: I was just getting to do that. Hang on, 

sir.

Chair Clawson: Appreciate that.

Yes, because I was going through and every once in 

a while I'd hear mute is off, mute is off and mute is 

on. And, I thought, well, maybe, you know, they're 

just checking to make sure where the -- somebody 

had an open mic or something because mine is 

actually in the cord that I mute with. But I talk to 

myself, too, Stu. So, you're not the only one.

Dr. Hinnefeld: I still talk to myself even though 

there's a light on my phone that tells me when I'm 

on mute.

(Laughter)

Chair Clawson: I know very well.

Mr. Katz: Kind of lonely doing that.

Chair Clawson: Well, sometimes, you know, the 

responses back are a lot more cooperative.

(Laughter)

Mr. Katz: That's true, that's true.

Bob, are you with us yet?

Mr. Barton: Oh, can everyone hear me?

Mr. Katz: Now we can, yes.

Mr. Barton: Okay, so I just gave my spiel and 

apparently nobody heard it.

Chair Clawson: And, you know what, Bob? It was a 

magnificent one, but I had a question right at the 

beginning there.

(Laughter)
24

Mr. Barton: What was the rest of it? Was that the 

question?

Chair Clawson: Yes.

Mr. Barton: Okay, so, I'll try to do it again, maybe a 

little quicker than I did the last time.

But, recycled uranium, you know, as everybody in 

the Work Group knows, this has been an issue that's 

been kicked around for a very long time, even going 

all the way back to the 2011, 2012 time frame.

At that time, the Work Group and NIOSH and SC&A 

had agreed upon RU constituents. And, just for the 

sake of simplicity, we'll just talk about plutonium.

The agreed upon ratio was 100 parts per billion 

plutonium during the period of interest prior to 1973.

And so, it was put in abeyance again until the TBD 

was revised and we could see that number as actually 

in a document. And the TBD was revised and when 

we went through it, we thought, well, that 100 parts 

per billion was actually changed down to 10 parts per 

billion.

So, naturally, our question was, well, you know, 

what's going on? Why -- what was the rationale for 

lowering it by a factor of 10 from what we agreed 

upon before?

And, at that time, the response was that the data had 

gone under I think what was described as a 

qualitative reassessment and that would basically 

show that all of the data or 95 percent of it was 

essentially below one part per billion and that the 

remainder of the data was still lower than 10 parts 

per billion.

So, the 10 parts per billion would certainly bound that 

situation.

So, SC&A went in to sort of verify that analytically 
25

and we couldn't figure out how to associate the given 

samples in this recycled uranium database with an 

actual date when it was on site.

So we brought that back, you know, and asked 

NIOSH, how are you guys actually decoding this to 

get a date?

And, NIOSH pointed us to a section in the source 

report where the data comes from that allows you to 

use a certain sequence in the lot ID number, which 

the lot ID number is a series of alphanumeric 

separated by dashes.

And, if you look at one specific section of it, you can 

essentially decode what the month and year was for 

that lot sample.

So, when we did that and we analyzed the data, our 

results were coming back in line with this notion that, 

well, all of the data is less than one part per billion. 

And, if not, it's definitely less than 10.

So, we wrote that up in a memo to distribute it and 

that's actually on the website.

And so, NIOSH took another look at that database 

and came to the conclusion that, well, you know 

what? The whole decoding the dates from the lot ID 

doesn't look like it's actually a valid solution.

And, that absent that, we really have no way to tell 

which of these RU data points are prior to 1973 which 

is the period that we're talking about.

And so, Stu sent that out in the email with NIOSH's 

rationale behind that. And, last week, they provided 

a new response absent analysis of the data since it 

was deemed that that data is not usable on why they 

still feel that 10 parts per billion is a bounding value 

and appropriate.

So, if everyone heard that spiel, I'll try to hand it over 

to NIOSH again, Stu or whoever to present their new 
26

White Paper.

Dr. Hinnefeld: Okay, this is Stu and I'll -- first I'll 

explain how we came to the conclusion that we 

should look at these, it's called the lot sequence 

number, the number that we originally told the Work 

Group could be used to date the samples in the DOE

2000 report.

And, we reconsidered that. And, what I was doing 

was, I was essentially trying to recreate what Bob 

had done in his memo which I thought was quite well 

done.

And so, I'm looking at that, I said, well, my initial 

read of it was, oh, he's kind of got it locked here, this 

was just about right.

But then, when I started looking at the data and 

looking back at the lot marking numbers guidance 

which is also in the DOE 2000 report, it's somewhere 

around, oh, PDF page 670 or so out of 1,242 pages, 

that tells you how big that report is.

When I looked back at that, I saw that there are 

actually several options for assigning lot sequence 

codes given in that guidance document for how to 

assign lot sequence codes.

It can be, as we thought, it can be a monthly tally 

starting in January of '61 or '62.

It could a specified number of containers of -- and 

there was a qualifier. It can be a monthly count if 

there's only one lot produced per month or less than 

one lot produced per month. Or, I guess if there's

one lot produced per month.

It could also be a specified number of containers 

which would not necessarily correlate with the date.

And, it also can be a lot size that's specified by 

criticality concern.
27

So, there are several conditions right off the bat that 

say, well, maybe this isn't exactly a monthly tally.

Another section of that report says that this lot 

sequence code for materials generated off site is a 

particular number that's drawn off the material 

shipping form that sites had to fill out when they 

shipped materials between accountability codes. 

They sent this off, in this case, they sent it off to DOE.

And so, that didn't seem like that correlated -- would 

necessarily correlate with months, either. And, in the 

interim, ORAU has actually checked some shipping 

records that we have, I don't think we have a 

comprehensive set, we checked some shipping 

records of these forms where materials -- that the 

sites had to fill out when they transferred materials. 

And, there doesn't -- it doesn't seem to be a date or 

related to date.

And, in fact, today's instructions for filling out that 

form, at least for the NRC, says that you just number 

your forms in sequence.

So, the first time you as Holder A ship to Holder B, 

that is form number one. And, the second time you 

as A ship to B that would be form number two.

So, in the case of materials generated off site, the 

sequence number certainly couldn't be used to 

identify the date.

Now, you can identify materials that were generated 

off site by a different set of numbers in the materials 

in the lot code. It's the -- I believe it would be 

probably the production order number or either the 

production order number or the source code.

But, there's a three-digit, there is a section of the lot 

sequence number that is -- it's alpha, it's letters if 

the material is generated off site and it's numeric if 

it's generated on site.
28

So, what I did when I started looking at the data to 

see if I could -- what effect this information would 

have on the data in the database that actually has 

the Excel spreadsheet that Bob had worked on.

I first of all, sorted essentially by lot sequence 

number and got all the lot sequence numbers that 

would correspond to the early years up through 1972 

and just looked at those.

And, I got approximately the same number of data 

lines that Bob used in his analysis. So, I figured I'm 

on the right track.

And then, I look for materials that were generated off 

site. And, I exclude -- took those out of my analysis 

and just deleted those from the spreadsheet I was 

working on. And, that was quite a large number of 

the data, not all of them, but quite a large number of 

them.

And so, I was still let with, oh, I don't know, 

somewhere around a 100 or so data lines.

But, every one of these data lines had a notations

that it was UO3 generated from feed plant ash, that's 

not quite right. Almost all of those data lines, there 

were maybe two or three didn't have that notation.

And, they all were saying UO3 generated from feed 

plant ash. And, I said, well, that doesn't seem like 

there would be that many analyses in those from way 

early. And, in fact, the feed plant ash didn't show up 

until later according to the Ohio Field Office reports, 

that DOE 2000.

And so, it seems like these lots sequence codes really 

can't be used to date any of this data. So, I'm not 

sure how much of this -- if there's any data that I can 

find that I can use lot sequence codes would give us 

any information about the date.

So, that's where I started, you know, so that's what 
29

led me to the conclusion, that's what we sent out --

that Amy sent out the email about correcting some 

incorrect information we have provided.

And then, we went ahead and worked on our analysis 

as best we could recognizing that there's not a lot --

it doesn't seem to be a lot of analytical data that's in 

that big analytical spreadsheet that relates to the 

early years.

So, we looked elsewhere in the Ohio Field Office 

report and I ought to probably get my paper out here 

to see what we covered in our paper.

There are other things from the Ohio Field Office 

report, there is a table in the Ohio Field Office report 

that identifies when materials were received from off 

site.

And, this is in the, let's see, just give me a second 

here to catch my thought.

Yes, this is found in the table, Table E.2-4 of DOE 

2000, that's on page E2-A. There are tables that 

show when materials in different categories were 

sent from other facilities to Fernald.

And, that table -- and one of the categories of 

materials that are listed in that are feed plant ash and 

tower ash are the material categories.

And the earliest receipt for any of the three gaseous 

diffusion plants for 1973 for those materials.

There's quite a bit of other information either in the 

Ohio Field Office report or in other Fernald documents

that say the Ohio, you know, the feed plant ash 

clearly was the bad actor.

Overtly, it was the source of material from 1981 and 

later was 17 hoppers from Paducah that were 

identified as feed plant ash.

That material and the aftermath of that material is 
30

pretty well characterized and there are lot of 

samples, in fact, virtually all the sampling for 

transuranics took place as the result of the 

identification of that material and then the effect that 

that material had on the products going on to the 

plant.

So, there's other information in other Fernald 

documents about how Fernald was aware and on the 

lookout for contaminants in recycled materials.

There was a sort of shipping specification for 

movement of materials between DOE sites of --

sometimes it was quoted as 10 parts per billion, some 

places it's quoted as 1,500 GPM of transuranic alpha 

per gram of uranium.

So, I mean there was some knowledge of -- watch 

out for this stuff. We don't see -- I couldn't find any 

convincing evidence that material, particularly high 

in transuranics were received prior to 1973.

So, it just seemed to us that, well, lacking data to the 

contrary, it's seems like this 10 value which seemed 

to be sort of in place, maybe not firm -- a firm 

specification, but seemed to be in place for certain 

kinds of shipping, you know one to one site 

agreements seems to be about the best we can do.

Keeping in mind that we are in the SEC for the SEC 

period, '61 to '72. And so, we're going to reconstruct 

what we can. We know there was some transuranic 

so we just feel like the 10 parts per billion was a 

suitable number.

I know Bob has questions about this because I saw 

his slides about 15 minutes before the meeting 

started.

So, anybody else, before we start with Bob?

Member Ziemer: Well, it's not clear to me what the 

bottom line here is.
31

Dr. Hinnefeld: Well, part of the bottom line is that 

there's almost no information, analytical data before 

19 -- in this particular data from '61 to '72.

There is a 1985 report, this report -- that report was 

generated when the recycled material first, you 

know, in my experience, really came to light. That 

was in the early '80s and that was the Paducah feed 

plant ash, the 17 hoppers.

Member Ziemer: Mm-hmm, mm-hmm.

Dr. Hinnefeld: From that point on then, there was 

quite a lot of investigation into transuranic content.

And, there was a report published in 1985 that 

attempted to claimed to report this is what we know 

about the recycled materials that we have received 

from various places and the plutonium content.

And, there's not a lot of data in there, but the data 

that is in there, in each case, whenever there was 

data for recycled material, the plutonium content was 

left as 10 parts per billion.

So, our bottom line is that that number's out there, 

the 10 part per billion number is out there. That 

seems to be certainly there was some. Or, you know, 

people recognized there was some transuranic 

contaminant in the recycled uranium. But that seems 

to be a number that is supported.

And so, we feel like that is about the best we can do 

in this period when we're reconstructing, you know, 

like we say in our SEC rule, we'll reconstruct what we 

can reconstruct.

Member Ziemer: Yes. And you would consider that 

a bounding value in those cases, is that what you're 

saying?

Dr. Hinnefeld: I think it's an appropriate value. I'd 

say I'm less confident of bounding in the case of --
32

Member Ziemer: Oh okay.

Dr. Hinnefeld: -- transuranics than I was in the case 

of the raffinates.

Member Ziemer: Mm-hmm.

Dr. Hinnefeld: I'm pretty sure that was bounding.

Member Ziemer: Yes.

Dr. Hinnefeld: I think in this case, I think it's the 

appropriate value to use. But, again, we're in an SEC 

Class period here when we are reconstructing what 

we can reconstruct.

Member Ziemer: Right, right. Which is an occasional 

case, I guess, right?

Dr. Hinnefeld: I think that happens on occasion. I 

mean, we --

Member Ziemer: Yes.

Dr. Hinnefeld: -- can do what we can do. And, in 

our view is that, you know, there's not data that 

takes us anywhere higher than 10 parts per billion.

Member Ziemer: Right, that's what --

Dr. Hinnefeld: Until the ash shows up, one --

Member Ziemer: Yes, it's not bounding in essence 

but it's --

Dr. Hinnefeld: Right.

Member Ziemer: -- a value that you believe is 

justifiable to use in those cases where you can do a 

partial reconstruction?

Dr. Hinnefeld: Right, that's what we think.

Now, I will point out that the feed plant ash that was 

analyzed that we know was really high in plutonium 
33

came in, oh, somewhere around '80, around 1980. I 

think it was a little after 1980.

But, the -- that's the material that we know is bad.

Member Ziemer: Yes.

Dr. Hinnefeld: If there was feed plant ash received 

in 1973 that was not analyzed and so we're saying 

we're completely comfortable with keeping the same 

values that were generated based on the 1980 values 

back to 1973. Because feed plant ash that came in 

'73 wasn't analyzed so we don't really know.

Member Ziemer: Mm-hmm.

(Simultaneous Speaking)

Member Ziemer: There are --

Dr. Hinnefeld: -- our position. Our position --

Member Ziemer: Yes.

Dr. Hinnefeld: -- was essentially timed with the 

arrival of feed plant ash. And that's what --

Member Ziemer: Yes, got you.

Dr. Hinnefeld: -- materials really got higher.

Member Ziemer: Well, Bob Barton has got some 

additional questions on this. Then where are we, 

Bob, on SC&A's?

Mr. Barton: If we -- can everybody hear me, first of 

all? Because last time I was on mute.

Chair Clawson: Yes, Bob.

Mr. Barton: Okay, great. Okay, great.

I do have some questions, you know, we kind of had 

to throw this together pretty quickly just because of, 

you know, the difficult timing trying to get all these 
34

things together.

But, we did have some questions. Before we sort of 

completely discard the DOE 2000 database, I did 

have a couple questions on that.

Based on your email, Stu, and removing lots that 

came from offsite and they had the alpha designation 

that you could tell they were coming from different 

facilities and there's a way to actually decode that to 

see which facility they were coming from.

Just to get rid of that, I do see what you're saying in 

general.

I will note that in this database, about 25 percent of 

the data actually have a specific date listed with 

them, there's an actual date column.

Unfortunately, again, that only covers about a 

quarter of the data points. And, only one of those, 

one data point out of the entire lot had a specific date 

provided prior to 1973.

I would note that that single value, if you use the lot 

ID method, the dates match up exactly. And, of look 

at the period past 1972, so the later period 

essentially.

There's almost a 1,000 entries that specify a date. 

And, in each one of those, the lot ID method works, 

again. But, again, that was only when there was a 

specific date listed.

If they only had the lot ID and no date, we really have 

limited options how to verify or try to figure out when 

those things actually were at Fernald.

So, my first question was, for all the ones that don't 

have a specific date, we know that if it had a specific 

date, when we did the lot ID method works. If it 

doesn't have a specific date, we don't know as much.

Do we have any idea what those remaining samples 
35

that have a lot ID number that, if you decoded it 

using the date method, what would those numbers -

- do we have any idea what those numbers actually 

match up to?

I heard you say that, for the outside receipts, you 

were able to match shipping records. I'd say that, 

yes, that's what the lot ID was referring to. It wasn't 

a date, it was the number on the shipping record.

And, it sounds like from your previous discussion, 

there were some other options. I think I heard 

criticality or the number of lots in a sample or 

something like that.

Have we been able to take any of these data points 

for which we're not sure of the date, we don't trust 

that the lot ID is giving us the correct date, for all 

those remaining samples, do we have any idea, were 

we able to match them to any other documentation 

to show that, yes, this is clearly not representing the 

date of the sample, it represents A, B or C?

And, so I know you said that the team was able to 

match things up for off site receipts based on the 

shipping records. Was there any ability to match up 

the remaining data to say what those lot numbers 

actually represented?

Because I think that would be a good piece of 

evidence to say, yes, well, clearly, you know, we can 

match this sample to this, you know, this, you know, 

any number of the sort of characteristics that you had 

just described?

I guess that's my first question.

Dr. Hinnefeld: Well, I can --

Mr. Barton: So, if we don't think of it as a date, do 

we have any idea what they are?

Dr. Hinnefeld: I can -- I have an idea that is that I 

can show on some documentation that leads me to a 
36

particular conclusion.

But, you guys can decide how convincing this is.

And, this really relates to the data lines from the --

from the spreadsheet that has all the sample data on 

it.

It relates to the data lines that I was left with from 

the -- where the lot sequence number initially led me 

to believe that these were pre-1972 or pre-1973 

samples. But then, I later concluded were not.

It's a big long list of UO3 from feed plant ash. And, 

the production order number, which is another 

segment of the lot ID number, is in each case, is S as 

in Stuart, 125.

And so, when I looked at the procedure for assigning 

lot sequence, and this is the procedure from 1999 

and this is in DOE 2000 and I'm looking specifically 

at PDF page 681 of DOE 2000.

It describes how that production order number is 

assigned and, at this point in 1999, that number was 

being assigned by the Nuclear Materials Disposition 

Organization.

Now, that's relatively -- and now, this is relevant to 

this time period, so this is 1999. So, this was the 

environmental remediation period. Because 

production stopped in '87.

So, this is -- now they're remediating the site and so 

the Nuclear Materials Disposition group is assigned 

these numbers.

And, the paragraph of -- says, 2.12 says, when 

enriched and uranium materials of a regular percent 

U-235 content for which no production order is 

applicable are received or generated special 

designations are assigned as outlined in the following 

paragraphs.
37

The first one is, S, the letter S, followed by three 

digits indicate the onsite producing plant's best 

estimate of highest G-35 content processed over a 

particular campaign.

So, this S-125 material that is -- that originally I 

thought had the early dates based on lot sequence 

numbers, that material, I believe, was the material 

that was in the refinery, that had to be cleared out in 

order to be dispositioned as they remediated the 

plant.

Because, there was, when the recycled uranium, 

quote, with the high Pu content was, quote, 

discovered, those 17 hoppers had already been 

emptied and the material had been processed in 

various ways including had been dissolved and there 

was quite a lot of material, liquid UNH, in the refinery 

that they had produced from that that had Pu 

contents and somewhere around the 40 part per 

billion range.

And so, there was quite a puzzle about what to do 

with that. There was a short-lived attempt to try and 

turn it into green salt in Plant 4 that was the material 

in Plant 4 was not well enough contained to deal with 

it in the DOE's judgment so that stopped pretty 

quickly.

And so, they still had all this UO3 they had to rid of 

and I think it was dispositioned in order to be, you 

know, it was processed in some fashion in order to 

be disposed of as excess material.

And so, that's how that production order number, S125, was assigned.

So, I can't make that judgment for a whole lot of 

other things and what other lot sequence codes 

meant, but it seems like that, for whatever reason, 

the nuclear materials disposition, by the time they 

started cleaning out the refinery and generating 

material to get this high Pu content UO3 out of the 
38

way so they could disposition it, it seems like they 

maybe started sequencing over again. Because, 

those sequences start very low.

So, that's my speculation on those. But, I haven't 

gone through and identified other things that the lot 

sequence code might correlate to.

Mr. Barton: Okay, I think I understand that 

explanation.

I did have a couple other questions on the database, 

but I think it's probably going to be better just to 

move on, because I don't think we're ever going to 

get to a point where we're going to trust the actual 

data in DOE 2000 to be able to use it.

So, I think I'm just going to skip up to my next --

okay.

Now, this is really talking about the 10 parts per 

billion limit. And, it's trying to look at when was this 

actually in place at Fernald.

And, you had discussed some of this as it is in the 

report from the NIOSH memo.

It says, Cavendish 1977, that's a reference to 1977, 

also indicates that there was an established 

permissible limit of 1,500 dpm per gram uranium, for 

transuranic uranium products to be shipped.

Now, we went into that report and it appears to me, 

at least, that that was not a Fernald requirement, 

that was from Paducah and that was for the product 

material.

So, I'm not sure, again, it's not necessarily a Fernald 

guideline, but that's what Fernald had to get it down 

to be able to ship it back. And, again, we're talking 

about 1977 and so, this is, you know, five years after 

the end date of the period we're talking about.

And, I'd also point out that that one was actually just 
39

slightly higher than 10 parts per billion, but not 

much, you know, it's like 11, 12 something like that.

And, the other part of this is from that 1985 report 

on page 5 says, a second finding of the task force on 

recycled uranium was that most DOE facilities do not 

have specifications for acceptable levels of TRU and 

fission product impurities and recycled uranium.

Consequently, the recycled facilities were directed to 

develop such specifications. The specification 

adopted by FMPC, Fernald, was that the total alpha 

activities from TRU elements in recycled uranium 

shall not exceed point one percent of the alpha 

activity from uranium.

This equates roughly to 10 parts of plutonium per

billion parts of uranium on a mass basis if the 

plutonium was the only TRU element present.

This was adopted in late 1985. So, it seems like the 

10 part per billion wasn't really a stringently adopted 

limit at Fernald, again, until late in 1985.

So, this kind of raises the question, you know, what 

was being looked at during this period of interest? 

Can we back-extrapolate this policy both to the 1977 

Paducah limit for shipping product back to them and 

then this 1985, it looks like the 10 parts per billion 

plutonium wasn't really in effect until late 1985 at 

Fernald.

So, that's kind of a rhetorical question, I'm not really 

-- I don't know if you have a better answer for how 

we can establish that 10 parts per billion was the limit 

used prior to 1973?

Dr. Hinnefeld: Well, I'm not sure how much 

documentation I can find about this. I do know that 

I'm confident that Hanford's PUREX had 

specifications on its product that it, you know, the 

recycled uranium that shipped.
40

And, it was just sort of to make sure the process was 

running correctly, if for no other reason. But, it was 

-- I'm sure it was -- I'm pretty sure it was in the order 

of 10 parts per billion and that was sort of an agreed 

to number that they would meet.

But, I don't know if I can find any documentation of 

that.

So, that was, you know, that was a big receiver.

And, I don't know how old that or when they, you 

know, when these worries really started happening, 

you know.

The recycled uranium we talked about arriving in '61, 

that means that's when the stuff that had been 

through I think it was the Hanford, I think it was 

Hanford, it could have been Savannah River, started 

to be arriving at Fernald.

And, I'm pretty sure that, during those times, the 

PUREX process was, you know, was evaluated and 

seeing how good it was, it was kind of in those areas 

or kind of in that range.

They can certainly make 10 parts per billion and so 

we would make sure they do that.

But, there was not -- as that '85 report points out, 

there is no -- there was no universal GB standard for 

shipping this stuff around and we're trying to 

reconstruct information from pretty far in the back -

- in the past based on, you know, what little 

documentation we could find.

So, I don't, you know, like I was explaining to Paul, 

can I say firmly bounding like I did with raffinate? I 

don't know that I can.

I just think it's appropriate based on the way the 

process -- things were handled.

Recall that, you know, the feed plant ash was 
41

material that was actually accumulated at the 

gaseous diffusion plants quite a while as kind of a 

byproduct that had uranium content in it, some 

uranium values in it, so it wasn't thrown away.

But, it got to -- it had to get to the point where did 

we really want to use that uranium in order to go get 

it out of that stuff?

So, this was really, you know, an out of the ordinary 

experience. It was not the typical shipping around 

of, you know, well-processed stuff through PUREX, 

sending it right back because that went on for a long 

time or the well-processed stuff through Savannah 

River sending that back.

This -- it was special because it was so different, it 

was really one up step kind of equilibrium condition.

So, that kind of -- where I'm coming from, I don't --

I kind of despair finding definitive information that 

will make us feel really, you know, the same way we 

feel about this that we did about the first issue.

But, I just don't think there's a better number to 

choose here or a better place to go.

Mr. Barton: I understand, especially, you know, 

since that rationalized database seemed like it was 

going be an excellent place to start so I --

Dr. Hinnefeld: Oh, I know, when I found that out I 

was disappointed. I was all ready to address your, 

you know, bless your paper and pick like a rank order 

of 95th percentile.

Mr. Barton: Yes, I understand.

And, I think the discussion about whether it's 

appropriate versus bounding and putting it in the SEC 

context is important. I think that's important 

because, ultimately, what we have here is really a 

lack of data that we can actually use to make a 

distribution and to find out what the upper bound 
42

values might be.

And so, it really is, it's a judgment call as to do we go 

with a value that's sort of as close to the mark as we 

feel we can get? Or do we select something that's 

bounding in the interest of all this uncertainty 

surrounding those contaminant levels during this 

earlier period?

And, I'll just move on quickly, because I think it's 

better if we just kind of get into a discussion of 

whether the appropriate value is appropriate or 

whether a bounding value is a better choice.

So, here, this is, again, from the NIOSH memo and it 

goes right back to this and sort of supports the 

conclusion that the average plutonium contaminant 

level did not exceed 10 parts per billion.

And, again, this goes back to what I was just talking 

about, is the average concentration sufficiently 

bounding? And, the answer is, well, we really don't 

know.

NIOSH gives the appropriate value, but, as we said 

earlier, are less confident that it's actually a bounding 

value. So, that's really a question for the Work Group 

and everyone is, how do we feel about using sort of 

the data we have or average concentrations versus 

trying to put a bounding number on it?

This is also from one of the references, I believe this 

is also the 1985 report, okay, here we go.

And, it really -- it's really the bottom here during the 

past few weeks we have initiated plutonium analyses 

on a routine basis in our laboratories in order to 

characterize our present inventories.

And so, I guess my question there is, and there's 

probably, I imagine, not a great answer to this, but 

when it says present inventories, we're talking about 

1985 and I guess my immediate knee-jerk question 
43

was, well, are those representative -- what you had 

there in 1985, is that going to be representative of 

what was going on prior to 1973?

I'm not sure that that's a question that can be 

answered.

Dr. Hinnefeld: Well, I was there in 1985 and I was 

personally involved in that 1985 report. You've 

probably seen my name on it. And, there's -- you'll 

see my name on a lot of stuff from 1985 around this.

I'm pretty sure there was probably not much 

inventory sitting around from 1973 still in 1985. I 

think they didn't tend to, you know, to accumulate a 

lot of waste, which I don't think they accumulated a 

lot of inventory that they intended to use and kept it 

around that long.

So, I'm guessing, the current inventory was material 

that had been generated fairly frequently -- fairly 

recently.

I do know --

Mr. Barton: I know --

Dr. Hinnefeld: -- the specification. I'm very familiar 

with this one and it is, you know, 1,500 parts -- 1,500 

dpm per gram is a little higher than the 10 parts per 

billion plutonium.

But, remember there's some neptunium that comes 

along all the time, also.

So, the combined neptunium plus plutonium had to 

be less than 1,500 dpm or less than point one 

percent.

And, 1,500 dpm per gram, that's natural uranium as 

point one percent of natural uranium's alpha activity.

Mr. Barton: Yes, different ends on the calculation. I 

really was under the assumption that this specific 
44

activity is plutonium, you know, really quashed the 

contribution of neptunium in any other --

Dr. Hinnefeld: Yes.

Mr. Barton: -- but --

Dr. Hinnefeld: The plutonium is essentially obviously 

the dominant player but there always is some 

neptunium along and you had to consider both. And, 

the, yes, natural uranium is 1.5 million dpm per 

gram. So, 1,500 is point one percent of that.

Mr. Barton: All right.

So, the answer to that is really that the analysis done, 

at least in 1985 where it talks about that, was for 

present material.

Dr. Hinnefeld: Yes, I'm pretty confident there was 

nothing sitting around from 1973 still that he was 

referring to in terms of current inventories.

Mr. Barton: What we're looking at now is an excerpt 

from that 1985 report. And, all I really wanted to 

point out here is that, you know, we have some data 

here that was referred to in the NIOSH memo.

And, what I pointed out here is that there are several, 

especially in the early years, where, you know, it 

started out because there's no analytical data for 

plutonium, not even an average data.

So, again, I'm -- what I'm really trying to point out 

is, there's a lot of uncertainty and lack of information 

here as far as to try to actually characterize it and 

putting a number on it.

Which really brings me to my last point is, how we 

could think about how you deal with these sort of 

situations at other sites?

And, one immediately came to mind because it just 

crossed my desk recently, and this was a site where, 
45

during the earlier time frame, they had radionuclides 

that they had no bioassay data for, no way to really 

construct an intake.

But, what they found and used was that a NUREG 

document that, well, if you know how much was 

actually used or (telephonic interference) in a given 

year, you could multiply that by a simple factor and 

that would give you a reasonable approximation of 

what the intake.

Now, obviously, there's a whole lot of certainty is 

preceded with that.

And, in this particular instance, this is actually from 

Report-90 and it talks about what that factor is, they 

talk about where it came from. And, at the end, and 

they kind of bolded it here, factor of 10 was added to 

ensure conservative evaluations.

So, I know it's always dicey. There's a lot of nuances 

between sites. They're all sort of different.

But, the commonalities I see here is, we have 

radionuclides that we don't have monitoring data for, 

bioassay data. And, we're trying to figure out a way 

to come at the problem and, well, I guess the 

question is come at the problem either bound or 

make a reasonable assessment of what those intakes 

were.

And, at this site, they had the same problem. They 

had radionuclides with no bioassay data and they had 

a method that obviously had a lot of uncertainty to 

it.

And, they -- and NIOSH elected to throw sort of an 

arbitrary factor of 10 on it to ensure that the 

evaluation was conservative.

So, I guess that was my last point. You know, I think 

this -- believe this comes down to a judgment, what 

is appropriate?
46

Is it appropriate to try to really bound the numbers? 

In which I think SC&A certainly feels that the original 

values agreed upon back in 2012 of 100 parts per 

billion are bounded -- bounded those exposures.

And, let's not forget, that value changed essentially 

because we felt we had usable data that indicated 

that that number was really bounded sufficiently by 

10.

And, as it turns out, we can't use that data for the 

number of reasons explained today.

So, essentially what we have is less knowledge than 

we had back in 2012 yet we're at a lower number. 

And, you know, usually that door sort of swings in 

the other direction.

But, as you say, this is really a question of whether 

the appropriate number is acceptable to the Work 

Group or whether a bounding number is preferable, 

in which case, you know, a 100 or something 

certainly higher than 10 would likely bound it.

And so, there's a whole lot of uncertainty, again, 

about what the site limits were. What was the actual 

material handled there at the site during this time 

frame?

You know, we're trying to back-extrapolate the 

policies.

So, again, when you have all this uncertainty 

surround a value, and if you were going to try to 

bound it, that is, then it's certainly been done at other 

locations where sort of an arbitrary number like a 

factor of 10 is thrown on to ensure that it's 

conservative.

And, as it so happens, a factor of 10 on 10 parts per 

billion really gets us back to what the original agreed 

upon ratio was.

But, again, it's a professional judgment question 
47

about whether we want to be comfortable that we're 

bounding these exposures or if we're comfortable 

that the original 10 parts per billion is closer to the 

mark and appropriate, I guess, given the SEC 

considerations.

But, I would say, yes, these are partials, but the SEC 

was not for uranium, it's for thorium. So, it's kind of 

a different exposure source altogether.

So, anyway, I don't know if anybody has any 

questions for me. That's really all I meant to say on 

the subject.

John, I don't know if you have anything you want to 

add here. I know you were heavily involved with RU 

back in the -- back in those early discussions back in 

2011, 2012 when we had the original ratios.

I don't know if you have anything you wanted to add.

Mr. Stiver: Well, Bob, I'm kind of feeling at the time, 

we were actually part of the full SEC issues. And, we 

were really concerned with bounding at the time.

I believe that 100 parts per billion number really did 

come from a factor of 10 upon the -- what was kind 

of the, I guess, agreed upon product specification. It 

wasn't really put into kind of a formal basis, but we 

really kind of followed and, you know, because the 

PUREX process could produce material at that level.

But, because of all these uncertainties that you've 

outlined here, I believe that's where the factor of 10 

came from.

So, I guess, once again, the question for the Work 

Group is, you know, are we happy with just the best 

guess estimate or do we want to try to bound it?

In the past, when we have these kind of 

uncertainties, at least I've seen, and at least Bob 

demonstrated here with Report-90, the most recent 

example, yes, a factor of 10 was deemed 
48

appropriate.

So, I guess I'd put that out there to the Work Group 

and if they feel this is the best factor to go forward 

with.

Dr. Hinnefeld: This is Stu.

If I could just say one or two things.

Report-90, I hadn't looked up, I didn't know what it 

was. It's for exotic radionuclides produced at the Oak 

Ridge National Laboratory in the Isotopes Division. 

So, that would be essentially a laboratory probably 

with hot cells.

And, because --

Mr. Stiver: Yes.

Dr. Hinnefeld: -- NUREG-1400 is, you know, takes 

10 to the minus 6 times the quantity you're working 

with in essentially in a laboratory for that possible 

intake.

But, I think Bob's point more was like to if you have 

an estimate maybe at, you know, at an order of 

magnitude and putting conservatisms in to make 

sure you're bounding.

And, there is no Class recommendation here. I 

mean, they really made sure they had been bounding 

dose estimates.

Is that my feedback I'm hearing back on my phone? 

Because I'm hearing something kind of a little after 

me -

Mr. Katz: Yes.

Dr. Hinnefeld: -- that's kind of strange.

Mr. Katz: It is. It's not necessarily your feedback, 

it's a feedback from someone's not muting and it's 

coming through their phone or whatever and going 
49

into their mic. But, so --

Dr. Hinnefeld: Okay.

Mr. Katz: So, but it's been going on.

Dr. Hinnefeld: So, in that situation where that factor 

of 10 was added, they really were trying to bound the 

dose because it was not a SEC Class and they wanted 

to make sure they had a bounding dose then.

As to the point that the other Class was added for 

thorium, that's true. I think if -- but just because of 

that and because this particular constituent wasn't 

called out, I don't interpret that to mean that you 

need to have a bounding estimate for every other 

component.

You need to have a reasonable dose reconstruction 

for, you know, which is the standard for dose 

reconstruction has to be reasonable.

And, I believe this is a reasonable dose 

reconstruction is that to use the number that 

certainly seems to be the prevalent number until the 

unusual treatment, stuff that was not treated usually, 

this feed plant ash, was introduced into the system.

You know, PUREX can get far better than 10 parts per 

billion. I mean, they just made sure they were, you 

know, most -- almost all the stuff that came from 

PUREX was below that.

So, and I would agree that there's a lot of missing 

data before 1973, actually before 1980, there's just 

not a whole heck of a lot of data and we're trying to 

make the best sort of informed judgment we can here 

with, you know, where we can't -- where we don't 

have enough information to view analytical data.

I just feel pretty strongly that, look, if you -- we're in 

an SEC Class. We've said that, for partial 

reconstruction -- dose reconstruction as an SEC 

Class, we'll do what we can do and, to me, you know, 
50

10 parts per billion is the number to stand on because 

there's really no reason for any other number to 

stand on, or at least, some qualitative discussion type 

information that 10 is probably the right number.

Mr. Stiver: This is John.

Actually, I was the culprit, I had my phone unmuted 

while you were talking.

But, yes, I understand the reasoning here. I'm just 

trying -- I always feel like when there is a high degree 

of uncertainty and maybe a bounding approach is 

probably more appropriate.

But, I guess to ensure, you know, maybe there was 

some stuff that came through that was quite a bit 

higher. And, they just have no record of it now, 

there's no identifiable data.

So, we have to err on, you know, the side of 

claimant-favorability while still trying to maintain, 

you know, sufficient accuracy and so forth.

But, I still try to tend to lean towards a factor of 10 

because, I guess, we disagree on that. But, I 

certainly understand your logical sequence that you 

were going through there.

Dr. Hinnefeld: Yes, my only take on this is that 

anything, you know, this factor of 10, anything that's 

just speculative and arbitrary. Why a factor of 10, 

why not a factor of 5?

Mr. Stiver: Exactly, what do you decide how much 

uncertainty --

Dr. Hinnefeld: So, if anything beyond that is just 

speculative and we have at least some basis for 

saying 10 is probably an appropriate number.

Member Ziemer: Well, and the other thing is that I 

think the equal of having a bounding value is to what 

reality?
51

Mr. Katz: So, Paul, you're hard to hear. John Stiver, 

can you mute your phone again?

Go ahead, Paul.

Member Ziemer: It just seemed to me that 

introducing a bounding value at this point where you 

already have an SEC and you have a situation where 

you weren't able to bound things to start with, it's 

hard to believe that that's the way to go on 

something like this.

If you do go that way, how -- what do you do in cases 

where you're trying to partially reconstruct? You 

can't go wrong when you have an SEC.

Do you always have to use a bounding value? I don't 

think we have that in the past. We used the data 

that's available and --

Chair Clawson: Well, this is kind of an unusual one 

but Fernald always has been one.

I think, you know, looking at this and this is just my 

personal take on this whole thing, we're already in an 

SEC issue. We're trying to get the best value for 

those that do not fall under the SEC and so that we'll 

be able to use this information, we have a goal.

I don't think that we thought -- we also want to go to 

the most claimant-favorable that we can. But, I don't 

think that we're going to attempt to -- I'm kind of 

sitting here looking at this.

You know, we've done about everything that we can 

for it and we're going in there and we are trying to 

be the most claimant-favorable as we are.

I'm just -- I'm looking to the other Board Members of 

their suggestion to fast forward this.

I agree with what Stu said and I understand what 

John is saying. But, I don't think, in this situation, 

where we've already got an SEC that we need to 
52

make sure that we're bounded by this.

So, I guess I look for Dr. Ziemer, Phil, of you guys' 

feelings on this, too.

Member Schofield: This is Phil.

I think that, you know, 10 parts per billion seems like 

a reasonable number, especially since this is -- under 

the SEC. As you said, we're not really looking for a 

bounding number here.

Chair Clawson: Right, and actually, if you remember, 

when we started off into this, how many years ago, 

Mark, have been battling around with this, we didn't 

really have the SEC in at this time.

And, I think we've got to this position. And so I think 

we're just going to have to, myself, I'm seeing that 

we ought to just go with the 10 parts per billion and 

go on.

Paul, what do you feel?

Member Ziemer: Well, as I indicated, I think that we 

don't need to look for a bounding value on this part 

of it. I think that -- I'm inclined to support the -- you 

go with what looks best, the value that --

Chair Clawson: Okay. Paul, you're kind of cutting 

out there a little bit. So --

Member Ziemer: Yes.

Chair Clawson: -- I take it that you're kind of in 

agreement that we go ahead and go with NIOSH's 

recommendation?

Member Ziemer: Yes.

Chair Clawson: Phil, you're good with that, too?

Member Schofield: Yes, I am.

Chair Clawson: Okay, then that being said, I think -
53

-

(Simultaneous Speaking)

Review Status of Fernald Site Profile Issues/Plans 

for August ABRWH Meeting Report

Mr. Stiver: If I could just jump in for a second?

I think you guys are probably right on this. You 

know, given the situation we're in, if there is an SEC 

and that's the best number we've got. I guess SC&A 

is fine with that, too.

Chair Clawson: I appreciate that.

So, that being said, we'll go off NIOSH's 

recommendation.

But, I would like, before that, Ted, I would like to say 

one thing, I appreciate the work and everything that 

went into these. And, I am in agreement, but Stu, 

as usual, you brought some sound judgment into 

these things and made us look from a different point 

of view and I appreciate that.

I appreciate -- tell everybody I appreciate all the 

work they've done on this.

So, Ted?

Mr. Katz: Yes, two things, I just want to applaud the 

coming to a conclusion. I think that's great.

And, then, I think John and Bob were both of them 

have already gotten a head start on preparing a 

presentation for the Board meeting. I had asked 

them to do that and just leave gaps for the stuff 

that's unresolved, which it looks like they did.

So, we should be able to get a presentation out from 

Bob and John pretty quickly I think, is that right, Bob? 

John? So that we can be ready for the Board 

meeting?
54

Mr. Barton: We have placeholders in the 

presentation that's ready to go. It just needs to be 

updated from this meeting and then we can move 

forward with it.

Mr. Katz: Yes, so that's great, that's great. And, 

again, I just also applaud the Work Group, which has 

gone through an enormous amount of work and 

consideration on this site and I think it's a great day 

that you've gotten through all that work.

Thank you.

Chair Clawson: Okay, that being said, do we have 

anything more that we need to cover on these? I 

believe this is the only issues we had.

Mr. Katz: Yes. Well, I think just reflecting in the 

presentation at the tail end, that the Work Group is 

recommending the Site Profile review be considered 

complete and then, that'll take care of it.

Mr. Barton: Very good.

Adjourn

Mr. Katz: Yes. So I think we are done then, right?

Chair Clawson: Yes, that's correct. I just wanted to 

make sure that there wasn't any outlying issues that 

we still needed to take care of from either side from 

SC&A or NIOSH to be able to complete this.

So, not hearing any, this Fernald Site Profile will be 

complete.

Mr. Katz: Okay. Thank you, everybody.

(Whereupon, the above-entitled matter went off the 

record at 12:30 p.m.)