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U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL 

SAFETY AND HEALTH

+ + + + +

ADVISORY BOARD ON RADIATION

AND WORKER HEALTH

+ + + + +

TBD-6000/6001, APPENDIX BB WORK GROUP

+ + + + +

WEDNESDAY 

DECEMBER 16, 2009

+ + + + +

The Work Group convened in the 

Zurich Room of the Cincinnati Airport Marriott 

Hotel, Hebron, Kentucky, at 9:30 a.m., Paul L. 

Ziemer, Chairman, presiding.

MEMBERS PRESENT:

PAUL L. ZIEMER, Chairman

JOSIE BEACH, Member

MARK GRIFFON, Member*

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

NANCY ADAMS, NIOSH Contractor*

DAVE ALLEN, OCAS

BOB ANIGSTEIN, SC&A

PAT COGGINS, Petitioner

JOHN DUTKO, Petitioner

EMILY HOWELL, HHS

JOHN MAURO, SC&A

DANIEL McKEEL, Petitioner*

JAMES NETON, OCAS

JOHN RAMSPOTT, General Steel Site Expert*

WILLIAM THURBER, SC&A*

MARGARET WOJCIK, Bliss & Laughlin Steel*

*Participating via telephone
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C O N T E N T S

Call to Order and Roll Call........... 4

Introductory Remarks.................. 10

Update on TBD-6000 Findings Matrix.... 13

Appendix BB (GSI) Issues Matrix....... 118

GSI SEC Petition Evaluation Report.... 156

Initial Review of Bliss & Laughlin

Steel SEC Petition ER................. 262

McKeel Comments on GSI Issue 5........ 276

Initial TBD-6001 Review and

Appendix C Electro Metallurgical...... 284

Adjourn
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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:29 a.m.)

3 MR. KATZ: Good morning, everyone 

4 in the room and on the line. This is Ted 

5 Katz, the Designated Federal Official for the 

6 Advisory Board on Radiation and Worker Health. 

7 This is the TBD-6000/6001 Work Group, and 

8 we're going to begin right away with roll 

9 call, beginning with Board members in the 

10 room.

11 CHAIRMAN ZIEMER: Paul Ziemer, 

12 Chair of the Work Group.

13 MEMBER MUNN: Wanda Munn, member 

14 of the Work Group.

15 MEMBER POSTON: John Poston, 

16 member of the Work Group.

17 MEMBER BEACH: Josie Beach, member 

18 of the Work Group.

19 MR. KATZ: And Board members on 

20 the line.

21 MEMBER GRIFFON: Mark Griffon, 

22 member of the Work Group.
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1 MR. KATZ: Hi, Mark. Any other 

2 Board members participating, listening in? 

3 (No response.)

4 MR. KATZ: Okay, and then in the 

5 room, the NIOSH ORAU team. And please, the 

6 Board members, none of the Board members have 

7 conflicts, but everyone else please speak to 

8 conflict as well. NIOSH-ORAU team in the 

9 room.

10 DR. NETON: Jim Neton, OCAS. No 

11 conflicts with GSI.

12 MR. ALLEN: Dave Allen, NIOSH, no 

13 conflicts.

14 MR. KATZ: Thank you, and NIOSH15 ORAU team on the line? Are you expecting 

16 anyone, Dave, on the line?

17 MR. ALLEN: No.

18 MR. KATZ: No. Oh, okay. Then 

19 SC&A team in the room?

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

21 conflict.

22 DR. ANIGSTEIN: Bob Anigstein, 
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1 SC&A, no conflict.

2 MR. KATZ: And SC&A team on the 

3 line? Are you expecting any?

4 MR. THURBER: Bill Thurber, SC&A, 

5 no conflicts.

6 MR. KATZ: Welcome, Bill.

7 MR. THURBER: Thanks.

8 MR. KATZ: That's it? Okay. And 

9 then HHS officials or contractors or other 

10 government staff or contractors in the room?

11 MS. HOWELL: Emily Howell, HHS.

12 MR. KATZ: And on the line?

13 (No response.)

14 MR. KATZ: Anyone from HHS, from 

15 DOE, from DOL? 

16 (No response.)

17 MS. ADAMS: Ted, it's Nancy Adams. 

18 I got disconnected.

19 MR. KATZ: Hi, Nancy, welcome. 

20 Nancy Adams. Okay. Then we have members of 

21 the public or staff of Congressional offices 

22 on the line.
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1 CHAIRMAN ZIEMER: That wish to be 

2 identified.

3 MR. KATZ: Who wish to be 

4 identified.

5 DR. McKEEL: Yes. This is Dan 

6 McKeel. I'm the GSI SEC petitioner.

7 MR. KATZ: Welcome, Dan. 

8 MR. RAMSPOTT: John Ramspott, 

9 General Steel site expert. 

10 MR. KATZ: Hi, John, welcome.

11 MR. RAMSPOTT: Thank you.

12 CHAIRMAN ZIEMER: Is that it?

13 MR. KATZ: Okay. Then let me just 

14 remind everyone on the line to please mute 

15 your phones, except when you're addressing the 

16 Work Group. 

17 *6 if you don't have a mute button 

18 and then *6 again to take it off mute, and 

19 please disconnect if you need to leave the 

20 call for a while. Don't put the call on hold 

21 at any time.

22 CHAIRMAN ZIEMER: Okay. Thank 
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1 you. Let's officially call the meeting to 

2 order then. I want to check first with 

3 everyone to make sure you have a copy of the 

4 agenda. I think all the members in the room 

5 do. Let me check with Mark. Did you get your 

6 agenda by email, Mark?

7 MEMBER GRIFFON: Yes, I did.

8 CHAIRMAN ZIEMER: Thank you, very 

9 much. I want to check with the petitioner, 

10 Dr. McKeel.

11 DR. McKEEL: Yes, I do. Thank 

12 you.

13 CHAIRMAN ZIEMER: And, John 

14 Ramspott, I don't think I sent you one, but we 

15 can forward a copy probably here readily.

16 MR. RAMSPOTT: I'll be able to 

17 follow you, Paul. I'm fine.

18 CHAIRMAN ZIEMER: Yes, okay. And 

19 others, let me see who else is on the phone 

20 here. Nancy Adams, you probably don't have 

21 the agenda; is that correct?

22 MS. ADAMS: Correct.
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1 CHAIRMAN ZIEMER: What's she 

2 saying?

3 MR. KATZ: Yes, correct.

4 CHAIRMAN ZIEMER: Correct, okay. 

5 And I'm not sure if Bill Thurber -- did I send 

6 you a copy? I think I did. 

7 DR. MAURO: Bill?

8 MR. THURBER: Yes, I've got it.

9 CHAIRMAN ZIEMER: You've got it, 

10 okay. So I think we're okay to proceed then.

11 MS. WOJCIK: Excuse me?

12 CHAIRMAN ZIEMER: Yes.

13 MS. WOJCIK: Margaret Wojcik.

14 MR. KATZ: I'm sorry. It's hard 

15 to hear you. Can you repeat?

16 MS. WOJCIK: Yes. I'm Margaret 

17 Wojcik from Bliss & Laughlin Steel. Never 

18 received an agenda.

19 CHAIRMAN ZIEMER: We're going to 

20 try to get it to you shortly here.

21 MS. WOJCIK: Thank you.

22 CHAIRMAN ZIEMER: And 
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1 incidentally, Bliss & Laughlin will not come 

2 up until late in the meeting. It will 

3 probably be mid to late-afternoon, for 

4 informational purposes.

5 MS. WOJCIK: All right.

6 CHAIRMAN ZIEMER: Now let me just 

7 take a brief moment to give us an overview of 

8 the agenda. We are going to begin with the 

9 TBD-6000 findings matrix. There are a couple 

10 of items there that we need to address at this 

11 time.

12 Then we'll move to the Appendix BB 

13 issues matrix and try to clarify several items 

14 there, and then move into the GSI SEC Petition 

15 Evaluation Report and the SC&A review, and 

16 there we want to determine next steps on some 

17 of those items.

18 We have the initial SC&A replies. 

19 We have the NIOSH responses, and then we have 

20 additional SC&A replies to those responses. 

21 Also we have a number of petitioner concerns 

22 have been enumerated in the last few days, and 
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1 I want to make sure we have those on the 

2 record, and then we can identify a path 

3 forward on the Petition Evaluation.

4 Then we will look at Bliss & 

5 Laughlin, and there mainly we're going to 

6 determine if we're able to today, whether or 

7 not we need a more formal SC&A review to 

8 clarify the SEC issues. In that connection, 

9 we'll at least briefly look at the Evaluation 

10 Report.

11 Then we're going to also get an 

12 update on Electro-Metallurgical, which is also 

13 a newly-assigned petition for us, and that's 

14 been under SC&A review, and we'll at least get 

15 a status report of that. We don't have that 

16 review as yet.

17 So that's kind of an overview. 

18 I've indicated in your agenda we'll take a 

19 break at approximately noon, sort of depending 

20 on where we are at that point. We're going to 

21 adjourn at five o'clock. There's a lot of 

22 issues before us.
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1 We will not necessarily come to 

2 closure on all of these issues, but we are 

3 going to be, as it were, pecking away at them. 

4 We'll obviously have to meet again fairly 

5 early in the new year, so we'll get as much 

6 done as we're able to today and then proceed 

7 from that point.

8 So let's begin with the TBD-6000 

9 findings matrix, and we have from Dave Allen a 

10 White Paper that was distributed fairly 

11 recently, December 10th, December 10th, just 

12 roughly a week ago. So I'm going to ask Dave 

13 just to briefly review that paper.

14 We also have -- or at least I do, 

15 and I think this went to everyone -- we also 

16 have some comments from Dr. McKeel, and 

17 perhaps we can answer those questions as well 

18 and any questions that SC&A will wish to 

19 comment on that as well. 

20 So Dave, if you want to just give 

21 us a brief overview of the White Paper, that 

22 would be a good start.
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1 MR. ALLEN: Okay. A brief 

2 overview of that, what I called Issue 1 in 

3 there, Issue 1 of the TBD.

4 CHAIRMAN ZIEMER: Issue 1 of TBD5 6000.

6 MR. ALLEN: And the issue was that 

7 the TBD did not address the phenomenon of some 

8 of the thorium-234 and protactinium-234m 

9 uranium decay products concentrating near the 

10 surface of a uranium ingot once it's remelted 

11 and cast into an ingot.

12 Originally, we said that -- we 

13 agreed that the TBD would benefit from a 

14 discussion of that, and I believe SC&A's reply 

15 was yes, that's what we said, and I think it 

16 was the last Work Group meeting I tried to 

17 clarify, because I was under the impression 

18 that if other favorable assumptions in the TBD 

19 did cover that external dose, and I wanted to 

20 make sure we were on the same page.

21 After the last Board meeting or 

22 after the last Work Group meeting, it was 
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1 clear we weren't, that SC&A felt there was 

2 some additional dose to be gained there, 

3 whereas I thought that it was covered. So the 

4 agreement was that I put together this White 

5 Paper.

6 CHAIRMAN ZIEMER: Right.

7 MR. ALLEN: And the White Paper 

8 looked at the Fernald. We have a database of 

9 Fernald external doses for pretty much the 

10 entire time frame, 1953 to 2006. Fernald did 

11 a great deal of this recasting in two 

12 different plants there. There were hundreds 

13 or dozens of guys working on it at any one 

14 time, 24-7 around the clock for decades.

15 So any dose associated with this 

16 should show up in at least the higher guides 

17 in that population. So I compared the TBD18 6000 95th percentile because TBD-6000 has a 

19 distribution in it. I compared that to the 

20 maximum Fernald, both deep and shallow dose, 

21 and in that comparison, TBD-6000 does show 

22 that it's favorable. 
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1 Just a very small little table 

2 near the bottom there that shows the shallow 

3 dose, 95th percentile and TBD-6000 was 293 

4 rem, whereas the maximum shallow dose at 

5 Fernald was 52 rem. 

6 On the deep side, it was 29 rem 

7 for the 95th percentile of TBD-6000, compared 

8 to a maximum of 12 rem at Fernald. That's 

9 pretty much where the White Paper ended.

10 CHAIRMAN ZIEMER: Okay. John 

11 Mauro, did you have some comments on that for 

12 us?

13 DR. MAURO: Yes. As a matter of 

14 fact, Bill Thurber, I asked Bill to follow up 

15 on that. He's reviewed your work. Bill's on 

16 the line. Bill actually prepared a White 

17 Paper that came out to me, for my use today, 

18 not for distribution.

19 CHAIRMAN ZIEMER: We don't have it 

20 though?

21 DR. MAURO: You do not have it, 

22 and you may very well have it after we finish 
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1 this discussion. But just to let you know 

2 that we have done some homework, and I will 

3 just give you what I call the 30 second sound 

4 bite, but ask Bill to go into a little bit 

5 more detail on what we did and where we come 

6 out.

7 The bottom line is there's no 

8 doubt -- the bottom line goes like this. TBD9 6000 gives you a distribution for external 

10 exposure, okay, and the guidance it gives you, 

11 I believe, is that here's your distribution 

12 for external exposure. Use the full 

13 distribution, depending on the category of the 

14 worker you use for external exposure.

15 Now if you're at a facility that 

16 is handling where the -- I'm going to call it 

17 the Puzier effect, okay. So for the sake of 

18 making it easier, whenever you have an ingot 

19 that has been recently cast, there's a real 

20 potential for the thorium and protactinium to 

21 find its way to the outside surface. We know 

22 that. That does occur.
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1 As a result of that, the radiation 

2 field that's in the immediate vicinity, both 

3 beta and gamma, is quite a bit higher than, 

4 you know, than it's clean. In fact, the 

5 numbers are, for example, the dose rate, 

6 penetrating dose rate one foot from uranium, 

7 pure uranium, is 2 mR per hour. 

8 But when the Puzier effect is in 

9 place, it could be 10 to 20 times higher, 10 

10 to 15 times higher. So the Puzier effect is a 

11 real phenomenon. So that was our concern.

12 Now it turns out that -- I'm 

13 saying more than I really wanted to, as usual 

14 -- that the 95th percentile value in TBD-6000 

15 is very conservative. The dose you would --

16 if you were to use a 95th percentile value in 

17 TBD-6000 with the external exposed. You 

18 caught it. You picked it up.

19 Question, you know, and the way I 

20 look at the world, okay great. Does that mean 

21 when you're at a site and you're doing a dose 

22 reconstruction for a guy, who may have very 
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1 well worked with an ingot where the Puzier 

2 effect might be in place, are you going to 

3 assign the 95th percentile, as opposed to the 

4 geometric mean, because we have this special 

5 circumstance?

6 If the answer to that question is 

7 yes, this discussion's over. I guess that's -

8 - so, yes, you've made a very powerful point, 

9 that the 95th percentile of the distribution 

10 does capture, more than capture the Puzier 

11 effect. The real question is is that what 

12 you're going to do when you think the Puzier 

13 effect is at play?

14 MR. ALLEN: And the answer is 

15 right now TBD-6000 assigns a distribution.

16 DR. MAURO: Right. So therein 

17 lies the essence of our concern. Now Bill did 

18 a lot of work. I mean I took --

19 (Whereupon, the above-entitled 

20 matter went off the record at 9:45 a.m. and 

21 resumed at 9:46 a.m.)

22 CHAIRMAN ZIEMER: Okay, we're back 
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1 on.

2 MR. KATZ: Okay. We're back 

3 online.

4 CHAIRMAN ZIEMER: Okay Bill, so 

5 Bill Thurber, did you have some comments.

6 MR. THURBER: Yes, just a couple 

7 to amplify a little bit on what John said. 

8 First of all, as Dave had indicated, NIOSH has 

9 a very large database from Fernald, which they 

10 use. 

11 Just to check on that, we did a 

12 quick look at some data from ElectroMet and 

13 from Mallinckrodt, and while the numbers were 

14 a little different than the Fernald max, they 

15 are certainly in the same ballpark and support 

16 the position in the little table at the bottom 

17 of David's White Paper. So there is other 

18 data that supports that position.

19 The second thing is this. In TBD20 6000, they look at both the dose to the hands 

21 and arms and to the skin other than the hands 

22 and arms. The numbers that David presented 
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1 are those related to the skin other than the 

2 hands and arms. We also took a quick look, 

3 and, again we haven't finished this, but I 

4 think what I'm saying is going to be the way 

5 it's going to end up. 

6 We took a quick look at the hands 

7 and arms using a similar methodology, and used 

8 a film badge to organ correlation that was in 

9 one of the NIOSH documents to convert the film 

10 badge dose, if you will, to what the hands and 

11 arms were experiencing.

12 And the same -- one can draw the 

13 same conclusion, that the TBD-6000 numbers for 

14 the hands and arms are also conservative. The 

15 only underlying concern we have is that TBD16 6000 is really not prescriptive as to what you 

17 do, whether you take the median and the 

18 distribution, or whether you take the 95th 

19 percentile, or what metric do you use to --

20 for your analysis.

21 It is clear from David's White 

22 Paper and the studies that we have done that 
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1 the median does not capture it. The 95th 

2 percentile does. Probably the arithmetic mean 

3 does, but the median does not. So as far as 

4 we're concerned, the issue is that one needs 

5 to be prescriptive in the use of this in order 

6 to get a bounding dose, and I think that's 

7 about it.

8 DR. MAURO: There's one more --

9 Bill, you made a -- pointed something out to 

10 me that was interesting, in the distinction 

11 between TBD-6000 and the kind of things you do 

12 with that kind of facility, and TBD-6001 and 

13 the types of things, and where the Puzier 

14 effect may or may not emerge.

15 MR. THURBER: Yes. The case that 

16 was analyzed for TBD-6000 -- I'm sorry, the 

17 operator class that was analyzed for TBD-6000 

18 by David Allen and the work that we did, is a 

19 guy that's involved in scrap recovery, and 

20 presumably the scrap recovery process involves 

21 the remelting of scrap from wherever, 

22 converting it back into an ingot that can then 
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1 be subsequently refabricated by rolling or 

2 extrusion or whatever.

3 In TBD-6001 you have basically the 

4 same issue for the fabrication operations, 

5 where the derbies are taken and remelted in 

6 vacuum induction furnaces and recast into 

7 billets for subsequent fabrication. 

8 But the specific analysis that 

9 we're talking about here is relevant only to 

10 -- the specific numbers we're talking about 

11 here are relevant only to TBD-6000. The same 

12 methodology may be applicable to 6001. I 

13 don't know.

14 CHAIRMAN ZIEMER: Okay. Thanks 

15 for those additional comments. While we're 

16 discussing the White Paper and the SC&A 

17 comments, let me also raise a couple of 

18 questions that we received from the 

19 petitioner, and Dan McKeel, if you're on the -

20 - I think you're on the line, you'll be 

21 welcome to jump in here if you need to.

22 But Dan's first point was that the 
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1 information about what was used in the Puzier 

2 report is not clear. He asked what does 

3 Puzier indicate would be delivered by the 

4 contaminating recast uranium-234 and 

5 protactinium-234m crust contaminants of 

6 uranium ingots. Is Puzier the only literature 

7 that addresses thorium and protactinium 

8 accumulation in uranium ingots? I don't know 

9 if either of you has a response to that.

10 But was there a particular part of 

11 the Puzier report that --

12 MR. ALLEN: I think it was a 

13 paragraph in there or a couple of paragraphs.

14 DR. ANIGSTEIN: As a matter of 

15 fact, I thought we had given Dr. McKeel the 

16 references, specific page numbers at the last 

17 meeting.

18 MEMBER MUNN: Yes, you did.

19 CHAIRMAN ZIEMER: I thought we had 

20 two --

21 MEMBER MUNN: There were only 11 

22 pages of the report.
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1 DR. ANIGSTEIN: There were two 

2 pages actually.

3 CHAIRMAN ZIEMER: A couple pages. 

4 We'll try to track that down. Dan --

5 DR. McKEEL: That wasn't really 

6 the thrust of my question. The thrust of the 

7 question was that the pages were mentioned. 

8 But what's not mentioned in the 

9 White Paper or any of this discussion, when I 

10 look back over the March 11th Work Group 

11 meeting, when Dr. Neton said that this issue 

12 needed to be elaborated upon, I haven't seen 

13 the doses that actually get delivered by the 

14 Puzier effect.

15 That's what's not written into the 

16 documents that I can see, and it seems to me 

17 that if you're talking about the Puzier 

18 effect, you need to be actually giving the 

19 dose that this would deliver. So that was 

20 really my question, not what pages of the 

21 report apply.

22 CHAIRMAN ZIEMER: Okay. Hang on 
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1 just a second here. 

2 DR. ANIGSTEIN: This is Bob 

3 Anigstein. 

4 CHAIRMAN ZIEMER: Bob has the page 

5 here.

6 DR. ANIGSTEIN: In the report, in 

7 Puzier's report, which has these two different 

8 paginations, the typed page is 26 and then 

9 there's a handwritten page 42 on top of the 

10 same page. 

11 I'll just read from -- two 

12 sentences from the report. "We used to use, 

13 as a rule of thumb, clean uranium metal in 

14 equilibrium with at least its first two 

15 daughters would give off on the order of 200 

16 mrad per hour beta radiation at the surface of 

17 a piece of metal.

18 "This went up by at least an order 

19 of magnitude and probably more than that. We 

20 can say we saw readings as high as 2,000 to 

21 3,000 mrad per hour on castings of depleted 

22 uranium that were in the foundry area."
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1 Then he goes on to say -- so that 

2 becomes a factor of 10 to 15 higher. 

3 DR. McKEEL: Well, Bob, that's 

4 exactly my point, that those numbers, two to 

5 three thousand millirads per hour of depleted 

6 uranium, which really is a small part of what 

7 was used, you know, as far as uranium ingots 

8 at many AWE facilities, I think those numbers 

9 need to be in the White Paper and TBD-6000. 

10 That's really my point. I think that's fine 

11 to have that data, but you need to mention the 

12 numbers.

13 DR. MAURO: Dan, that's exactly 

14 the point that we were discussing a moment 

15 ago, namely one of our comments. One of --

16 this is John Mauro. 

17 MR. ALLEN: Yes.

18 DR. MAURO: One of SC&A's comments 

19 on TBD-6000 is it's silent regarding the 

20 Puzier effect, and that's, you know, there's a 

21 need to address if in fact you encounter a 

22 site or a case where there's reason to believe 
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1 a worker may have been handling a freshly2 reduced uranium ingot, it's important to take 

3 into consideration that the exposure rates 

4 that he might experience would be, could be, 

5 both beta and gamma, could be 10 to 15 times 

6 higher for some period of time.

7 As you know, it does decay away. 

8 I think it has a 29 day half life.

9 CHAIRMAN ZIEMER: Twenty-four.

10 DR. MAURO: Twenty-four day half 

11 life. So, yes, we agree with you, and I 

12 believe NIOSH would agree, yes, you know, 

13 there needs to be something to be said. What 

14 we were just discussing a moment ago is, you 

15 know, how is that to be addressed.

16 I think David Allen made a very 

17 good point, that says, listen, the 

18 distribution of external doses in TBD-6000, 

19 the upper 95th percentile, more than accounts 

20 for the existence of that." But then it 

21 becomes a practical matter. 

22 Okay. You've got a real case. 
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1 How are you going to do the dose if you think 

2 the person may have a Puzier effect? Are you 

3 going to stick with the 50th percentile, or 

4 are you going to use some high end of the 

5 distribution in TBD-6000.

6 So I think we're all in agreement, 

7 and it really is a matter of judgment to be 

8 made. When that situation arises, what do you 

9 do?

10 DR. McKEEL: My additional Point 3 

11 related to the fact that, you know, recasting 

12 depleted uranium scrap is one thing that went 

13 on at the AWE sites, but as was mentioned for 

14 TBD-6001, a much more common thing to do was 

15 to remelt derbies into ingots, or what is left 

16 out of TBD-6000 altogether is the process 

17 patented at Mallinckrodt and used at Weldon 

18 Spring, which was the direct casting of ingots 

19 in a bomb, which left a thick magnesium 

20 fluoride crust around ingots which had to be 

21 removed with a lathe. 

22 So those two complimentary 
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1 situations with thorium-234 and protactinium2 234 may also rise to the outer surface of the 

3 crust. That's not covered at all, and it 

4 seems to me that that should be. So I wanted 

5 to put that on the table as well, that the 

6 case cited in this discussion is really a 

7 very, very limited one of remelting scrap.

8 CHAIRMAN ZIEMER: Okay, thank you.

9 MR. THURBER: But I think -- this 

10 is Bill Thurber -- isn't it correct to say 

11 that if some of those factors are added to the 

12 discussion of, in TBD-6000, which everyone has 

13 agreed needs to be expanded upon, that the net 

14 result might be to increase the median and the 

15 95th percentile for this particular operation.

16 But then when you compare it with 

17 the real world numbers, you're still going --

18 the real world numbers are still going to show 

19 that you are very -- you're even more 

20 conservative. 

21 DR. McKEEL: Well my comment would 

22 be I don't think you're really showing the 
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1 real world numbers because what you don't have 

2 is data that you can clearly point to of 

3 workers that were working with, as you say, 

4 freshly-cast ingots. What you really have is 

5 a huge conglomerate of film badge readers 

6 reading from various sites, you know. 

7 ElectroMet, Mallinckrodt for now have been 

8 mentioned. But those are all diluted out. 

9 Let's say that the people who 

10 worked with recast scrap metal ingots and were 

11 exposed to thorium-234, what you need is data 

12 from people like that made directly from 

13 those, and know what their film badges read.

14 So to say that the entire mix of 

15 Fernald badges represents that particular 

16 group of people who may have much higher 

17 doses, I think, is just -- is flawed. It's 

18 like the healthy worker effect, you know. In 

19 epidemiologic studies, if you compare a highly 

20 at-risk population with all young workers, 

21 let's say, in an industry, obviously the 

22 health, you know, they're going to have a 
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1 skewed distribution.

2 So I don't think we're really -- I 

3 don't think there is any real good 

4 representative data from workers working with 

5 freshly-recast uranium that has thorium-234 at 

6 the surface. I think that's not an accurate 

7 portrayal of what you're actually working 

8 with. So that was another major thrust of my 

9 point number 2 that I made to the White Paper.

10 CHAIRMAN ZIEMER: My understanding 

11 is that NIOSH is not using the film badge data 

12 in this case for that purpose; correct? 

13 You're using, you're using this model for the 

14 --

15 MR. ALLEN: TBD-6000 has a model 

16 dose rate, and the intent of the short White 

17 Paper I wrote was to say that in the real 

18 world application our model is conservative, 

19 and SC&A has agreed that on the 95th 

20 percentile, it certainly seems to be 

21 conservative.

22 CHAIRMAN ZIEMER: Right, and 
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1 Puzier's values were not based on film badge 

2 reading; correct? They're based on actual 

3 measurements at the surface of uranium, not --

4 and that's what you're using. You're not 

5 using --

6 DR. McKEEL: The Fernald data that 

7 is quoted in the table on the last page of the 

8 White Paper, that's film badge data, right?

9 MR. ALLEN: Yes, that's film badge 

10 data.

11 DR. McKEEL: Okay. Well, that's 

12 what I'm saying. That's comparing -- that's 

13 not comparing exactly the same thing. That 

14 was my point.

15 MR. ALLEN: Well, it has -- the 

16 only thing it has in there is dose rate data, 

17 millirem per hour or....

18 CHAIRMAN ZIEMER: -- measurements, 

19 not from dosimetry.

20 MR. ALLEN: Right, and we only use 

21 those kind of measurements are is to then 

22 assume some amount of time somebody was 
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1 exposed to that, and multiply it by time. 

2 Whereas the film badge data is integrated over 

3 that, it takes it all into account in the real 

4 world. The idea that Dr. McKeel mentioned as 

5 far as diluting this effect with a large 

6 population, us not also doing that is the 

7 reason in the White Paper I compared the 

8 maximum to the 95th, the TBD-6000 numbers.

9 As far as real world doing this 

10 sort of recasting operation, Fernald produced 

11 hundreds of metric tons of uranium using this 

12 recast method for many decades. There is no 

13 other facility in the world that produced this 

14 kind of -- at least in the United States, that 

15 did more uranium recasting then Fernald did.

16 MR. THURBER: David, this is Bill 

17 Thurber. I'm not sure that everyone 

18 understands what I think you did, and that was 

19 you looked at 124,000 pieces of film badge 

20 information and you took the single highest 

21 value.

22 MR. ALLEN: Correct.
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1 MR. THURBER: So there was nothing 

2 higher than that. So your comparison metric 

3 of 52 rem or whatever it was, is not something 

4 that is diluted by other measurements. It is 

5 the single highest measurement at Fernald over 

6 a large number of years; is that correct?

7 MR. ALLEN: That's correct.

8 MR. THURBER: Okay.

9 MR. RAMSPOTT: Dr. Ziemer?

10 CHAIRMAN ZIEMER: Yes.

11 MR. RAMSPOTT: This is John 

12 Ramspott. May I ask Bill Thurber and David 

13 Allen a question?

14 CHAIRMAN ZIEMER: Sure.

15 MR. RAMSPOTT: I think Dr. McKeel 

16 made this point a minute ago. I just want to 

17 make sure it's not being missed. David, did 

18 you not say your White Paper was based on 

19 Fernald and recast ingots?

20 MR. ALLEN: It was based on all 

21 the data at Fernald, which includes much more 

22 of the recasting.
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1 MR. RAMSPOTT: Much more of the 

2 recasting, okay, and Bill, is there a 

3 difference, in your opinion, of recast versus 

4 virgin dingots or ingots using the 

5 Mallinckrodt process? Would there be a 

6 difference?

7 MR. THURBER: I wouldn't think so. 

8 What I understand is happening, and I don't 

9 understand the details of why it's happening. 

10 I know there's some publications about why 

11 this concentration on the surface occurs. I 

12 don't understand them. I'm not sure they're 

13 correct.

14 But regardless of that, what I do 

15 understand is that, when you remelt uranium, 

16 if you have thorium-234 and protactinium-234, 

17 and in the uranium ingot, which you will, that 

18 when you recast it, some of it moves to the 

19 surface. So if you recast it ten times, some 

20 of it's still going to move to the surface.

21 So there is no difference between 

22 casting and recasting in my view as to the 
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1 fact that the phenomenon occurs. 

2 MR. RAMSPOTT: The reason I was 

3 asking is David's is based on recast from 

4 Fernald; Mallinckrodt was doing very little 

5 recast, which I'm going to send this Work 

6 Group an email, if I may. 

7 It's a Mallinckrodt purchase order 

8 and it shows that recast was a fraction, a 

9 fraction, 30 times different than virgin 

10 ingots and dingots. 

11 This was a 1954 purchase order 

12 that I'm looking at right now, which is in, I 

13 believe, Appendix BB. It's part of the 

14 documents for that site. 

15 So if we're comparing apples with 

16 oranges, and the reason I'm saying apples with 

17 oranges is, if I understood John Mauro and 

18 some other people earlier, there's a time line 

19 involved with, I guess, the thorium, a half20 life of like 20-30 days or what have you.

21 But if you're putting a whole 

22 different step in there, which is apparently 
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1 what they're doing at Fernald, I mean they're 

2 not doing at Fernald or they are doing at 

3 Fernald. They're recasting, we're comparing 

4 apples with oranges, I thought.

5 (Simultaneous speakers.)

6 DR. ANIGSTEIN: John, your 

7 question is very well put. If I can sort of 

8 try to succinctly explain the phenomena, 

9 uranium under normal conditions, under 

10 undisturbed conditions, is always in 

11 equilibrium with its daughters: thorium 234 

12 and protactinium-234m. 

13 It doesn't matter -- it's uranium 

14 238. It doesn't matter whether you have 

15 natural uranium or depleted uranium. There is 

16 a very tiny difference in the amount of U-238.

17 CHAIRMAN ZIEMER: That is true.

18 DR. ANIGSTEIN: One is 99.3 

19 percent and the other one's maybe 99.8 

20 percent. There's all or virtually all U-238. 

21 So whether it's recast or virgin is not the 

22 issue. The issue is that the melting process 
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1 of the uranium metal, you start off with the 

2 thorium distributed uniformly throughout the 

3 uranium.

4 When you melt it, the thorium 

5 comes to the surface and stays there with a 

6 half-life of 24 days. Then every 24 days, 

7 half of it decays but it's replaced by the 

8 thorium roaming in throughout.

9 So when you start off with freshly 

10 cast uranium, you'll have this 10- to 15-fold 

11 concentration on the surface. That decays, it 

12 grows in in the middle. 

13 So after a few months, you have 

14 uniform distribution. But whether it's from 

15 virgin or whether it's scrap or however way 

16 it's produced, the effect is essentially the 

17 same. Is that clear?

18 DR. McKEEL: Well, I understood 

19 they were dealing with two different types. 

20 Apparently, Fernald's based on recast. That's 

21 why I asked the question.

22 DR. ANIGSTEIN: I mean, but this 
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1 Puzier effect will be the same for all of 

2 them.

3 DR. McKEEL: It would be the same 

4 for both, is what you're saying.

5 DR. ANIGSTEIN: That's right, yes.

6 DR. McKEEL: Can I ask another 

7 question then? Since the Puzier effect, 

8 apparently everybody agrees it's there.

9 DR. ANIGSTEIN: Yes.

10 DR. McKEEL: Would the betatron 

11 hitting at thorium make a difference, since 

12 Fernald, I think we all found out probably 

13 didn't have a betatron.

14 DR. ANIGSTEIN: The answer is no, 

15 because the betatron beam doesn't look at --

16 there's a big difference between activity and 

17 number of atoms. The number of atoms of 

18 thorium on the surface is insignificant. 

19 It just happens to be -- they are 

20 very hot, so they contribute a lot to the 

21 external dose. But as far as the reaction 

22 with the betatron beam, there is none.
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1 DR. McKEEL: There's no difference 

2 when a betatron beam hits thorium and when it 

3 hits uranium.

4 DR. ANIGSTEIN: Yes. There is no 

5 enhanced effect, because you have for every 

6 thorium atom, you have literally billions of 

7 uranium atoms. So the betatron beam effects, 

8 you know, hits each one, but it's a very, very 

9 --

10 CHAIRMAN ZIEMER: So you're saying 

11 the contribution to the output or the 

12 interactions from the betatron with respect to 

13 thorium are trivial.

14 DR. ANIGSTEIN: Exactly.

15 CHAIRMAN ZIEMER: The issue here 

16 is that of the surface radiation level of 

17 terms of handling or proximity to it?

18 DR. ANIGSTEIN: That is correct.

19 DR. MAURO: There's something that 

20 I could add that might -- when I was looking 

21 at the results, I asked myself a common sense 

22 question. I said, okay, NIOSH's analysis 
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1 says, listen, the upper 95th percentile number 

2 in TBD-6000 for the annual dose to the hands, 

3 that you estimate from TBD-6000, is 3,250 rem, 

4 okay. 

5 I said, okay, and that's what you 

6 -- if you were to go and take TBD-6000 and say 

7 I'm going to use the 95th percentile for a guy 

8 that works at a facility where he's handling 

9 an ingot, all right, that has the Puzier 

10 effect. I say, you know, that's the number 

11 that would be assigned.

12 Then I ask myself okay, knowing 

13 what I know about the Puzier effect, I know 

14 that the contact dose from regular uranium, 

15 not with the Puzier effect, is about 200 

16 millirem per hour. You may want to write this 

17 down. It's about 200 millirem per hour.

18 But then if there's the Puzier 

19 effect, it's going to be maybe ten times 

20 higher than that, okay. So now, instead of 

21 being 200 millirem per hour at the surface, 

22 it's 2,000 millirem per hour at contact. Then 
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1 I multiply by 2,000 hours per year. Okay, as 

2 if the guy was holding onto it, 2,000 hours 

3 per year. 

4 Of course, he's not doing that. 

5 But if he was, you'd get 4,000 -- you'd end up 

6 with 4,000 rem, okay, in the year. 

7 MEMBER POSTON: On the surface. I 

8 just want to make that clear. 

9 DR. MAURO: Contact dose, contact 

10 dose. Now so what I'm saying is under the 

11 most absurd, extreme assumptions that a guy is 

12 sort of hugging this Puzier ingot, 2,000 hours 

13 per year and you get 4,000 rem. But TBD-6000 

14 is assigning 3,250. Now what that tells me is 

15 3,250 is a pretty good number, okay. 

16 I mean that sort of like cleans 

17 away all of the -- you know, it's easy to get 

18 caught up in the woods in these things. It 

19 says that that upper bound of 3,250 at the 

20 95th percentile is off-the-charts high. Now 

21 if that hard to say --

22 MEMBER GRIFFON: John, can I step 
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1 into this. This is Mark Griffon. We need the 

2 --

3 (Simultaneous speakers.)

4 DR. MAURO: The dose to the hands 

5 and arms for TBD-6000, the 95th percentile 

6 value.

7 MEMBER GRIFFON: Hands and arms.

8 DR. MAURO: You got it. This is 

9 the contact dose. The contact dose at the 

10 95th percentile level in TBD-6000 is 3,250 rem 

11 per year. That's the number that they're 

12 recommending. Now they didn't do --

13 DR. ANIGSTEIN: If I can 

14 interrupt, interject.

15 DR. MAURO: Sure.

16 DR. ANIGSTEIN: I'm just 

17 supporting your comment. The Puzier actually 

18 says it could be as high as 3,000 mrad an 

19 hour, and TBD-6000 makes the assumption, the 

20 conservative assumption, that the worker is in 

21 contact with the uranium half the time. So 

22 now we're getting 1,000 hours a year and 
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1 possibly 3,000 millirads per hour. So there 

2 we go exactly; you've got 3,000 rem per year, 

3 which confirms exactly what -- the 3,250 is a 

4 good number.

5 MEMBER MUNN: It's an extremely 

6 high number.

7 DR. MAURO: It is a high number.

8 CHAIRMAN ZIEMER: Now your 

9 question, John, I guess SC&A's question is 

10 whether or not the 95th percentile is always 

11 used or what are the other options for the --

12 for evaluating a claim. Dave, could you 

13 clarify that?

14 MR. ALLEN: Like I said earlier, 

15 the TBD-6000 now says to give a distribution, 

16 period, out of that table. The GSD is five. 

17 The mean values are in the table. I think 

18 John just pointed out that the 95th percentile 

19 is pushing the realms of implausibility.

20 DR. MAURO: But on the other 

21 extreme, I also want to say I'm not too happy 

22 with the median.
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1 MR. ALLEN: Well, I don't -- Bill 

2 Thurber, he's on the phone. He mentioned 

3 something earlier about the median was not 

4 necessarily covered with the TBD-6000.

5 MR. THURBER: No. The median for 

6 the skin, other than the hands and arms, that 

7 goes with the 294 rem per year, 95th 

8 percentile value in your White Paper, the 

9 median is 21, and obviously -- 21 rem per 

10 year, and obviously, 21 rem per year is 

11 substantially lower than the empirically 

12 determined 52 rem per year from the Fernald 

13 data.

14 So you know, it's our position 

15 that the median value is not appropriate if 

16 you want to be sure that you're covering the 

17 surface concentration of these uranium 

18 progeny.

19 MR. ALLEN: That's the point I 

20 wanted to get at here because I think that's 

21 the one disagreement we have at this point. 

22 Other than that, I think we're close to 
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1 closing this issue. 

2 MR. THURBER: Yes.

3 MR. ALLEN: That's the answer I 

4 don't understand.

5 CHAIRMAN ZIEMER: What does the 

6 dose reconstructor, when you say he can use 

7 the distribution, what --

8 MR. ALLEN: He assigns the roughly 

9 21 rem as the geometric mean of a log-normal 

10 distribution with a GSD of five.

11 CHAIRMAN ZIEMER: For some people 

12 or all people?

13 MR. ALLEN: That would be for a 

14 skin dose other than hands and arms.

15 MR. THURBER: For all people.

16 MR. ALLEN: Yes, if we're 

17 assigning a skin dose.

18 MEMBER MUNN: Other than hands and 

19 arms?

20 MR. ALLEN: If it was hands or 

21 arms, we assigned the larger number.

22 DR. MAURO: You'd assign 230.
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1 MR. THURBER: 230, right, plus 

2 with a standard deviation of five, and in our 

3 view, that does not capture the possibility 

4 that the worker is going to have exposure to 

5 uranium shapes that have surface 

6 concentrations of thorium-234 and 

7 protactinium-234m.

8 MR. ALLEN: I guess the part I'm 

9 not quite understanding is I thought you had 

10 said you didn't think it was covered. Are you 

11 saying it just wasn't analyzed in the White 

12 Paper?

13 MR. THURBER: Oh no, no, no. 

14 Those metrics, we don't feel are appropriate, 

15 because the maximum is greater. That's what I 

16 meant by covered. No, no. It's not that your 

17 --

18 DR. ANIGSTEIN: In other words, 

19 they're not -- it's not claimant-favorable.

20 (Simultaneous speakers.)

21 MR. ALLEN: Because the maximum 

22 is, the maximum dose out of 120-some thousand 
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1 is greater --

2 MR. THURBER: It's greater than 

3 the median.

4 MR. ALLEN: Two and a half times 

5 the median.

6 MR. THURBER: Right.

7 DR. NETON: I want to ask a 

8 question, here.

9 CHAIRMAN ZIEMER: That's -- Dr. 

10 Neton.

11 DR. NETON: Has nothing to do with 

12 the Fernald data, but about the distributions 

13 being applied. Is it correct that it's a 21 

14 with a GSD of five that arrives at a 296 95th 

15 percentile? Is that what the number was?

16 MR. THURBER: Yes.

17 MR. ALLEN: Yes.

18 DR. NETON: And the highest value 

19 of 125,000 badges measured at Fernald was 

20 something like 50 or 51?

21 MR. ALLEN: 52.

22 DR. NETON: It's not intuitively 
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1 obvious to me that assigning that distribution 

2 wouldn't result in a higher PC calculation 

3 than assigning 51 as a constant because you're 

4 sampling that distribution and the PC is 

5 calculated at 95th percentile, in a large 

6 portion of time, you're going to be using the 

7 high end value of that distribution. So I'm 

8 not sure that it's a given that that 

9 distribution is low.

10 MR. THURBER: Well, it's a 

11 question of assigning 21 with a GSD of five or 

12 294, I think.

13 DR. NETON: No, no. I'm saying 

14 it's a model distribution that is exactly 

15 that. The 21 value, we'd have to go back into 

16 the derivation of that value. But we allow 

17 for the fact that it could be as high as 296 

18 when you sample that log-normal distribution.

19 If what we're saying is 51 is the 

20 highest ever observed in any employee working

21 with this type of metal, then one would come 

22 to the conclusion maybe 51 as a constant is 
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1 the right value. It's not clear to me that 

2 that would produce in a higher PC value than 

3 what we're currently using.

4 DR. ANIGSTEIN: SC&A did a report 

5 way back, I think in 2004, comparing for 

6 given, for certain hypothetical GSDs, what is 

7 the effect of using the entire distribution, 

8 and what is the effect of using the 95th 

9 percentile?

10 The answer is it depends. There 

11 are some cases -- in most cases, using the 

12 95th, the fixed value of the 95th percentile 

13 is the more favorable, claimant-favorable.

14 DR. NETON: Well, it depends on --

15 DR. ANIGSTEIN: We thought at one 

16 time that NIOSH OCAS had accepted that.

17 MR. ALLEN: Yes, but we're talking 

18 about -- I think Jim's point is it seems -- it 

19 would seem this comparison is legitimate, that 

20 it would be legitimate to assign the 52 rem as 

21 a constant, and that's nowhere near the 95th 

22 percentile of the distribution we'd be 
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1 assigning. It's well below the 84th 

2 percentile.

3 DR. ANIGSTEIN: I guess the only 

4 way you could really test it is to make up a 

5 hypothetical case and run IREP, and see which 

6 one comes out higher.

7 DR. MAURO: You've got a little 

8 bit of a dilemma. Let me explain a little bit 

9 of a dilemma. In the original TBD-6000, in 

10 order to create, have your construct, you said 

11 okay, what we'll do is we're going to assume 

12 the worker spends 50 percent of his time in 

13 direct contact with the uranium, where the 

14 direct contact gives you 200 millirem per 

15 hour, and you come up with a number.

16 Then you get -- then you made some 

17 other assumptions for the distribution. Now 

18 the reality is, and I'm not saying you should 

19 do this, don't get me wrong; the reality is if 

20 you were to apply to those same assumptions 

21 regarding the distribution on occupancy and 

22 close proximity to uranium, but now it's not 
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1 uranium, regular old uranium, it's Puzier 

2 uranium. Well then all of the sudden, the 

3 doses go -- so what really happened here is 

4 that when you originally did TBD-6000, you 

5 made a bunch of what you would consider to be 

6 reasonably conservative assumptions, assuming 

7 you were operating with regular old uranium. 

8 Along comes the Puzier effect and you ask 

9 yourself the question, well, we're not going 

10 to just replace the regular old uranium and 

11 now we're going to put Puzier in there because 

12 then everything goes off the charts, and it 

13 wouldn't be right.

14 So what you'll say is let's see if 

15 the approach you did use with its inherent 

16 assumptions in its own way is conservative 

17 enough when you start to look and compare the 

18 outcome to the real world, with -- and I would 

19 agree with you 100 percent that going to 

20 Fernald and looking at the data there is a 

21 good way to say "Listen, are our assumptions 

22 so conservative that it even catches the upper 
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1 end of the real world," and the answer is it 

2 does.

3 So I mean I'm not saying you 

4 should replace, you know, the Puzier ingot, 

5 replace the regular ingot with the Puzier 

6 ingot and use the same assumptions that you 

7 did to get these distributions. I agree that 

8 the upper end of the distribution in TBD-6000, 

9 using the approach you've used, does just so 

10 happen, more of an account for the Puzier 

11 effect, and the only question we have is that 

12 I don't, you know, and maybe the answer is 

13 what you just said.

14 The only question I have is that 

15 well, if you go into this problem and you're 

16 doing a guy who you do know worked with a 

17 Puzier ingot, and you used the geometric mean 

18 and standard deviation as laid out in TBD-6000 

19 as it currently is, is it possible you're 

20 going to underestimate his dose, as compared 

21 to using some fixed value at the high end of 

22 the distribution?
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1 Our sense is that yes, you 

2 probably would get a claimant-favorable and 

3 appropriate dose if you know, if you assign 

4 something in the upper end of the distribution 

5 in TBD-6000, not the full distribution. But 

6 your just saying no, that may not be the case. 

7 It may turn out the full distribution is more 

8 limiting than the upper 95th percentile 

9 deterministic. I don't know --

10 DR. NETON: And I think the 

11 problem with that is I don't think it's 

12 knowable because it's very case-specific, as 

13 Bob mentioned. I mean the risk models that 

14 are used and all the factors that go in there, 

15 it really comes down to how much is the 

16 uncertainty about the dose estimate driving 

17 the 99th percentile of the PC, versus all the 

18 other factors that are in there, which are 

19 latency period corrections and all kinds of 

20 things. So but I'm saying --

21 DR. MAURO: I don't want to shift 

22 into the PC part. I mean I was just thinking 
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1 with the --

2 DR. NETON: Well, but my point is, 

3 though, the distribution, in some cases, it 

4 seems to me that this distribution might 

5 produce higher PCs than assigning a 51 rem 

6 value.

7 DR. ANIGSTEIN: But not assigning 

8 the 95th percentile of the distribution.

9 DR. NETON: Correct. That's my 

10 point, yes.

11 MR. THURBER: Well, let me just --

12 this is Bill Thurber. I would also say that 

13 while the -- I'm sorry, the 52 rem empirical 

14 number is certainly well substantiated with 

15 the Fernald data, before you would pick an 

16 empirical number, I think you need to look at 

17 Mallinckrodt information and ElectroMet and 

18 whoever else was doing this kind of work to be 

19 sure that 52 rem did capture this empirical 

20 maximum.

21 So I would think that rather than 

22 saying one can go to an empirical maximum, one 
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1 ought to stick with the statistical 

2 distribution that's available and decide what 

3 the proper metric is. Remember, we're only 

4 talking in the case of TBD-6000 for the scrap 

5 recovery guy. 

6 We're not talking about, I don't 

7 think we are anyway, all the other jobs that 

8 are covered by TBD-6000, machining, rolling, 

9 forging, extrusion, slug canning, whatever.

10 DR. NETON: Well, I'm not sure. I 

11 mean --

12 MEMBER POSTON: Well, where does 

13 logic come in? Let me finish my statement. I 

14 mean we're talking over 200 rem, 250, 260, I 

15 don't know what the number was. I mean from a 

16 radiobiological standpoint, wouldn't you 

17 expect --

18 DR. MAURO: Damage.

19 MEMBER POSTON: Yes.

20 DR. MAURO: You get damage.

21 MEMBER POSTON: Yes, and so I mean 

22 is it reasonable to assign such a high dose? 
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1 It's totally ludicrous.

2 DR. MAURO: But I'll tell you 

3 what's not reasonable. What's not reasonable 

4 is to build a TBD-6000 that says here's the 

5 protocol we're going to use, and it's all 

6 built around regular old pure uranium, and you 

7 felt that this is a reasonable thing to do, 

8 and we agree. If you're dealing with just 

9 regular uranium --

10 DR. ANIGSTEIN: Or old uranium.

11 DR. MAURO: Or old uranium, 

12 without the Puzier effect --

13 MEMBER POSTON: It's all old.

14 DR. MAURO: And you know, yes, 

15 it's real old.

16 (Simultaneous speakers.)

17 DR. MAURO: Stay with me. So but 

18 then all of the sudden you get a monkey wrench 

19 thrown into the picture. Well holy mackerel, 

20 you know, we didn't -- all of the sudden you 

21 have a Puzier thing going on.

22 And you're saying well, we don't 
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1 care. The Puzier thing doesn't change --

2 well, no, of course it changes things. All of 

3 the sudden you're telling the world that when 

4 we originally designed and implemented TBD5 6000, it was all built around the assumption 

6 that it was uranium without this enrichment of 

7 the thorium in the crust.

8 Now we recognize that that only 

9 occurs under very special circumstances, and 

10 for a relatively short period of time. So the 

11 only question we raise is that when all of a 

12 sudden that new scenario steps into the 

13 picture, it's self-evident that somehow you 

14 have to take that into consideration.

15 You just can't go ahead and use 

16 the same models you were using before, before 

17 you realize we've got this new thing in the 

18 game now. So something has to be done to deal 

19 with this new thing in the game. 

20 MR. ALLEN: But I think that it is 

21 reasonable to throw conservative assumptions 

22 in there that can't account for smaller 
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1 effects. From what we're seeing with this 

2 data and I think from what Bill saw with some 

3 Mallinckrodt and from Simonds Saw or I can't 

4 remember --

5 DR. MAURO: ElectroMet.

6 MR. ALLEN: Was that we have 

7 accounted for this effect, and the difference, 

8 if you wanted to account for the difference of 

9 this effect versus the normal uranium, would 

10 be to lower the remaining doses. 

11 As it stands right now, the 

12 highest Fernald dose ever was the 52 rem. The 

13 median of the roughly 21 rem. I think there 

14 are maybe 20 or 30 annual doses throughout the 

15 history of Fernald that were above that. 

16 So our median is way up there high 

17 on the Fernald distribution, and 20 or 30 

18 annual doses when you were doing this 

19 operation for over 30 years, means these are 

20 probably the high guy each year for those 

21 years.

22 DR. ANIGSTEIN: But ElectroMet is 
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1 almost twice as high. The maximum at 

2 ElectroMet is almost twice as high as the 

3 maximum at Fernald.

4 MR. ALLEN: What is the maximum at 

5 ElectroMet?

6 DR. ANIGSTEIN: It's 95.

7 MR. ALLEN: And I can go and look 

8 at all those, et cetera, but you're talking 

9 about the maximum now of the country, because 

10 you're talking about Fernald, Mallinckrodt, 

11 ElectroMet. We're looking at a median that is 

12 a fifth of that. We're looking at a median in 

13 the 84th percentile of the distribution we're 

14 assigning.

15 I mean it seems to me from what we 

16 were talking earlier, I can assign that 99th 

17 as a constant, like Jim said. I'm not so sure 

18 that's going to be more favorable. That's 

19 with the Puzier effect, and we're assigning 

20 that for all the uranium.

21 So the argument really seems to be 

22 that we should have a difference, and we 
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1 should be lowering the remaining doses.

2 DR. MAURO: You know, I can agree 

3 with that. That is, if in fact the set of 

4 assumptions that we used originally weren't so 

5 conservative. You see the reason this 

6 happened is --

7 MR. ALLEN: Well, that was my point 

8 with the White Paper is I think we've already 

9 covered all the conservative assumptions.

10 DR. MAURO: It was almost like an 

11 artifact, and you adopted an extremely 

12 conservative approach to the regular uranium, 

13 and the outcome of it is gee, that's so 

14 conservative it could even account for the 

15 Puzier effect.

16 Then you said to make my case, I'm 

17 going to show you that I take the highest 

18 number out of thousands of readings in the 

19 real world where there's, you know. And the 

20 95th percentile is even higher than that. 

21 That's very compelling. So that's 

22 -- but then that brings us back, and all that 
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1 is very powerful argument. But then that 

2 brings us back, and this is really a judgment 

3 call. Is it okay to simply use the geometric 

4 means in the full distribution to apply to 

5 workers, whether they work with the Puzier 

6 effect or not? That's basically what you're 

7 saying. 

8 Does it matter? If it's a guy 

9 that wasn't working with Puzier effect, you're 

10 going to be -- he's a little bit more 

11 conservative. You're really probably giving 

12 him too much dose. If it's with the Puzier 

13 guy, well you know, it's probably okay for him 

14 but --

15 You see, to me there's enough 

16 difference. We're talking a tenfold 

17 difference in the field, and it's hard for me 

18 to accept that nothing special has to be done 

19 here. I would say it was two, yes, but we're 

20 talking 10 to 15-fold differences, and it 

21 doesn't have an effect. 

22 CHAIRMAN ZIEMER: Well, but can 
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1 you distinguish between who those folks are 

2 anyway? 

3 DR. NETON: Probably not.

4 CHAIRMAN ZIEMER: And if you 

5 can't, you use the Puzier effect.

6 DR. MAURO: Well, but they're not.

7 CHAIRMAN ZIEMER: Well, you 

8 haven't, but --

9 MR. ALLEN: Well in reality most -

10 - there's not a lot of facilities out there 

11 that melt uranium and didn't do several other 

12 operations, but we never knew where the person 

13 worked, so --

14 DR. MAURO: And I agree with that. 

15 I agree with that, yes. I mean I agree with 

16 that. I would say that the likelihood the 

17 guy's going to spend a lot of time hugging a 

18 Puzier ingot is pretty small. Except maybe, 

19 except by the way, except maybe at a GSI. 

20 We're going to get to GSI later. 

21 CHAIRMAN ZIEMER: Well just in 

22 general terms, and we'll talk about GSI 
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1 specifically at that point, but in general 

2 terms, on TBD-6000, would you -- are you 

3 proposing to include the Puzier effect, as 

4 you've described it here, or in the original 

5 model?

6 MR. ALLEN: What I was proposing 

7 originally, before we clarified at the last 

8 meeting, was to add some language to describe 

9 this, and to -- on this White Paper, and I 

10 think even from what Bill's written up, is to 

11 indicate that the conservative assumptions in 

12 TBD-6000 have this covered, leave the numbers 

13 as they are. I can't see how it can possibly 

14 account for the Puzier effect with some real 

15 live numbers without lowering all the other 

16 doses.

17 DR. ANIGSTEIN: And there's 

18 another effect, though and that is we don't 

19 actually have any film data. The film data 

20 does not tell you anything about the dose, the 

21 contact dose to the skin. This is what I was, 

22 you know -- I can't seem to get this to work.
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1 MEMBER BEACH: You turned it off.

2 DR. ANIGSTEIN: Pardon?

3 MEMBER BEACH: It was turned off a 

4 few minutes ago.

5 (Simultaneous speakers.)

6 CHAIRMAN ZIEMER: So in other 

7 words, David, what you're saying is you would 

8 discuss the Puzier effect under Issue 1, in 

9 order to show that your original assumption 

10 readily covered that effect in a general 

11 sense. 

12 MR. ALLEN: Yes.

13 CHAIRMAN ZIEMER: Now at a 

14 specific site, you may or may not, or would 

15 you?

16 MR. ALLEN: Well, like John was 

17 pointing out, the assumptions in TBD-6000 were 

18 essentially a model gamma dose and they are 

19 the same dose for each of the jobs and it was 

20 intended to be a conservative model for the 

21 deep dose, and the beta dose is a ten times 

22 factor, which really did -- it's not an 
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1 accident that I was trying to account for this 

2 effect, with kind of a 10 to 1 ratio you can 

3 see at another plant, like in Fernald, when 

4 you had this. You don't see that kind of 

5 ratio at, maybe, a chemical plant. 

6 So essentially, yes, it was there. 

7 I was attempting to account for this in a 

8 conservative manner. I think these numbers 

9 point out that it actually did manage that, 

10 and I don't think you can account for the 

11 worst-case dose and then raise it up more. 

12 You're going to have to have a 

13 difference , and in the end you're going to 

14 end up with somebody working at a facility 

15 that did this and some other jobs. You're 

16 going to pick the highest number, and you're 

17 going to end up with the same number by the 

18 time you're done anyway.

19 CHAIRMAN ZIEMER: Okay. Bob has 

20 got some additional information here. What is 

21 --

22 DR. ANIGSTEIN: This is from the 
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1 original SC&A review of Appendix BB, and what 

2 we modeled -- what we modeled here --

3 CHAIRMAN ZIEMER: Okay. For 

4 reference, for those on the line, it's Table 

5 14 in the original SC&A review, right?

6 DR. ANIGSTEIN: Yes.

7 CHAIRMAN ZIEMER: Of TBD-6000?

8 DR. ANIGSTEIN: No, Appendix BB.

9 CHAIRMAN ZIEMER: Oh. This is for 

10 Appendix BB specifically.

11 DR. ANIGSTEIN: Yes. But I mean 

12 the reason -- okay. So here, here we modeled 

13 what then we believed was the -- we still 

14 believe is the characteristic shape, which was 

15 an 18-inch cylindrical ingot with a four-inch 

16 thick slice from the middle. 

17 So the Puzier effect would only 

18 effect the outer edges, because the cut 

19 surface would not have been exposed at the 

20 time of melting.

21 So if you look at the side, the 

22 contact dose is a 1,348 mrad per hour. Go to 
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1 one foot, you're down to 58. So the film 

2 badge is not going to be any closer than one 

3 foot. More likely it will be further. You go 

4 to one meter, down to 8.7.

5 Now this falls off more rapidly 

6 than it would for a large piece of uranium, 

7 because you're looking at only -- what you're 

8 looking at is four inches wide and then 18 

9 inches in height, 18-inch diameter. So the 

10 fall-off is a little faster than it would be.

11 But the fall-off is certainly --

12 so the film badge, if it's somewhere between 

13 one foot and one meter, I mean I'm holding a 

14 piece of metal and I'm wearing a film badge, 

15 I'm more than 12 inches away, or maybe 18 

16 inches away. So somewhere in between the two.

17 Even if the skin other than the 

18 hands and arms is covered, it's captured by 

19 the film badge non-penetrating radiation 

20 reading, the open-window reading. That still 

21 does not adequately account for the contact 

22 dose, and the assumption that it was 6.5.
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1 MEMBER POSTON: Stop, stop. I 

2 don't understand what you mean when you say it 

3 doesn't count for the contact dose.

4 DR. ANIGSTEIN: It doesn't measure 

5 the contact dose, because the film badge is 

6 worn on --

7 MEMBER POSTON: But you don't care 

8 about the contact dose; you want to know the 

9 dose of the skin or the whole body.

10 DR. ANIGSTEIN: To the skin of the 

11 whole body I agree, but not to the skin of the 

12 person holding his hand and --

13 MEMBER POSTON: But you excluded 

14 that. You said the film badge was measuring 

15 the dose --

16 DR. ANIGSTEIN: No, no. I know. 

17 I know that. But I'm saying that to 

18 extrapolate from the film badge readings to 

19 the contact dose, I don't think, is done 

20 correctly, because -- yes, the 3.65 simply 

21 doesn't do it.

22 CHAIRMAN ZIEMER: You want the 
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1 contact dose from the skin of the trunk to the 

2 contact dose of the skin of the hand?

3 DR. ANIGSTEIN: The skin of the 

4 hand. The skin of the hand.

5 DR. NETON: But I thought we had 

6 different model values for hands --

7 DR. ANIGSTEIN: You do, you do, 

8 you do, and the difference is --

9 CHAIRMAN ZIEMER: But you can 

10 scale that from film badge data.

11 DR. ANIGSTEIN: Yes, but it's 

12 being scaled from film badge data, and the 

13 ratio, the median is a factor of about 11, 

14 from 21 to 230 and I would suggest that that's 

15 not enough, that if the film badge were at one 

16 foot, you would have a multiplier of 45 and 

17 not 21. If the film badge was at one meter, 

18 you'd have a multiplier of like 250.

19 MR. ALLEN: Now John just made the 

20 argument that 200 times 200 or what was your -

21 -

22 DR. MAURO: In other words, yes. 
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1 I came at the problem in a much simpler way.

2 DR. ANIGSTEIN: Now at the 95th 

3 percentile, we're okay.

4 DR. MAURO: We're okay, exactly.

5 DR. ANIGSTEIN: But if you don't 

6 use the 95th percentile, that's where we have 

7 the problem.

8 MR. ALLEN: And I'm trying to 

9 recall the median for the skin of the hand and 

10 --

11 DR. MAURO: I've got it right 

12 here.

13 DR. ANIGSTEIN: Two thirty.

14 DR. MAURO: The median is 230. 

15 The median is 230 rem per year to the hands, 

16 out of TBD-6000.

17 DR. ANIGSTEIN: So if you assume -

18 -

19 MR. ALLEN: But I guess my point 

20 all along has been by the numbers you've got 

21 there, you've got 721 millirems per hour.

22 DR. ANIGSTEIN: No, no, that's --
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1 excuse me. That's the cut. That's the 

2 average of the cut slice, where you have one 

3 side that does not have the enhanced Puzier 

4 effect. But it does have actually the 

5 betatron radiation, the radiation. So don't 

6 look at the side. Just look at the front. I 

7 mean don't look at the front; look at the 

8 side.

9 MR. ALLEN: Okay. The side is 

10 1,350 millirems per year.

11 DR. ANIGSTEIN: Per hour.

12 MR. ALLEN: Per hour, excuse me.

13 DR. ANIGSTEIN: Right. 

14 MR. ALLEN: The value we're 

15 assigning as a median is 200 rem per year. I 

16 forgot the number already.

17 DR. ANIGSTEIN: 230 rem per year, 

18 and with the assumption of 1,000 hours. So 

19 1,000 hours means you're talking about 230 

20 millirem per year, per hour, as opposed to 

21 what we model as 1,350. 

22 MR. THURBER: But the 230 millirem 
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1 per hour is an experimentally measured value 

2 presumably for uranium with a contamination 

3 distributed uniformly. It's an experimental 

4 measurement, 230.

5 MR. ALLEN: I'm getting my numbers 

6 mixed up. I need to actually look a few 

7 things up here, but --

8 DR. ANIGSTEIN: Yes. But Bill, 

9 that would be -- but that does not account --

10 that would be old uranium and not new uranium.

11 MR. THURBER: That's what I said. 

12 It's with a contamination uniformly 

13 distributed.

14 DR. ANIGSTEIN: Exactly. If I can 

15 just be --

16 MR. THURBER: It doesn't have the 

17 surface effect contamination in it, is what 

18 I'm trying to say.

19 DR. ANIGSTEIN: If I may be 

20 pedantic, it's not only a contamination; it's 

21 the natural --

22 MR. THURBER: Yes, I understand. 
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1 CHAIRMAN ZIEMER: Okay. Let's see 

2 where we are on this. The issue boils down to 

3 whether or not the original model is 

4 sufficiently conservative to cover a 

5 reasonable contribution of the Puzier effect 

6 in these facilities. 

7 That's what it boils down to and 

8 at some point, I don't know if we need any 

9 additional information, but the Work Group 

10 needs to make a recommendation on this 

11 particular item to the Board.

12 Mark, do you have any additional 

13 comments on this one? You've been kind of 

14 quiet here.

15 MEMBER GRIFFON: No, no. I think 

16 I'm sort of digesting it all, Paul. I mean 

17 the one thing; I was trying to look for those 

18 numbers and the difference on the extremity 

19 doses. But, no, I think it was a pretty good 

20 overview.

21 CHAIRMAN ZIEMER: Now let me ask 

22 you a practical question. In terms of the use 
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1 of this, David, you assign everybody the same 

2 dose; is that correct, with the distribution, 

3 but you have to look at their cancer?

4 MR. ALLEN: Yes. The dose that 

5 you're assigned here is essentially as if it 

6 were a film badge dose, and then you take DCF 

7 et cetera into account on a particular organ. 

8 So deep doses, skin dose and then a whole 

9 body and then a hands-and-forearms.

10 CHAIRMAN ZIEMER: Right. So if 

11 the cancer's in this part of the body, you 

12 assign that hand dose. If it's skin cancer in 

13 the trunk, you assign the larger value in 

14 full, right?

15 DR. MAURO: And that would be --

16 CHAIRMAN ZIEMER: And the 

17 distribution.

18 DR. MAURO: With the distribution, 

19 and that would be whether the person was just 

20 new, only working. There was no Puzier going 

21 on, or there was Puzier going on. It wouldn't 

22 change it. I guess that's --
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1 CHAIRMAN ZIEMER: Right now, as I 

2 understand it, they're saying that the uranium 

3 model originally used was so conservative that 

4 it covers that Puzier distribution.

5 DR. MAURO: And it does, certainly 

6 at the value --

7 CHAIRMAN ZIEMER: Which is well 

8 beyond the --

9 DR. MAURO: Well beyond that I 

10 mean I would say -- I would go as far as to 

11 say that assigning the 95th percentile as a 

12 fixed value would be off the charts, okay. 

13 But at the same time I would say it's not 

14 apparent assigning the full distribution is in 

15 fact claimant-favorable.

16 CHAIRMAN ZIEMER: Or not.

17 DR. MAURO: Well, yes. 

18 CHAIRMAN ZIEMER: Well, I think as 

19 Jim pointed out, that could go either way, 

20 because the effect is not as if you assigned a 

21 fixed dose at the median. I mean you're still 

22 making the selection and the PoC is still 
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1 selected way up at the tail, which is a very 

2 different -- yes, okay. Let me see if any of 

3 the other --

4 MEMBER BEACH: I guess I want to 

5 be clear. On our Issue 1, it said that we 

6 would address the matter, talk about it, and 

7 then we would leave it in abeyance until the 

8 TBD was revised. I just want to be really 

9 clear on it. Is the TBD going to be revised?

10 MR. ALLEN: She asked if the TBD 

11 is going to be revised. That's what I tried 

12 to bring up the last Work Group meeting we 

13 had, was my intent was to revise the language 

14 and point out how it's accounted for. But at 

15 the last Work Group meeting, I clarified 

16 whether we thought that really would have an 

17 effect on the numbers. 

18 The answer was yes. Now we're 

19 discussing whether it actually could have an 

20 effect on numbers. The language definitely 

21 needs to be updated. It should be accounted 

22 for the TBD --
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1 CHAIRMAN ZIEMER: If you're only 

2 talking about the change that clarifies the 

3 discussion, I think you're asking, does the 

4 applied model change.

5 MEMBER BEACH: Right.

6 MR. ALLEN: And that was the 

7 question last time, and right now my opinion 

8 is no. I mean it's covered under there. 

9 That's the discussion we're having now.

10 CHAIRMAN ZIEMER: Right. Well, we 

11 need to bring this to closure, though. Are 

12 you, David, from NIOSH's point of view, are 

13 there any other issues? Are you looking at 

14 something else that would possibly change this 

15 or --

16 MR. ALLEN: I have not. I thought 

17 this would be something that would definitely 

18 do it. Apparently, it's not. But then the 

19 question is what --

20 CHAIRMAN ZIEMER: Well, I'm not 

21 sure that that characterizes it correctly. I 

22 think SC&A is suggesting that selection of the 
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1 fixed value of the 95th may be more claimant2 favorable than --

3 DR. MAURO: I would say it's --

4 CHAIRMAN ZIEMER: But we don't 

5 know that.

6 DR. MAURO: I know how I look at 

7 it, I look at it. I'm doing --

8 CHAIRMAN ZIEMER: Well wait. Are 

9 you asking whether it's the median and then 

10 the distribution, which I think you're saying 

11 you're using a five or five to five, or 

12 whether it's a mean or what was the other 

13 value that --

14 DR. MAURO: Well, there are a lot 

15 of metrics you could pull on. We know that --

16 CHAIRMAN ZIEMER: I mean, I've got 

17 to do a 95th plus a --

18 DR. MAURO: Right, no. In theory, 

19 the options are leave everything alone, 

20 because the arguments you're making to leave 

21 it geometrically and a very large 

22 distribution, you account for it. Now for all 
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1 intents and purposes, that's basically what 

2 you're saying.

3 Another argument could be made, 

4 no. You know, if you use the 95th percentile 

5 as a fixed value, it's certainly claimant6 favorable under any circumstances to the point 

7 that maybe it's overly favorable, right.

8 Then there's the arithmetic mean, 

9 which actually falls as a fixed value, which 

10 actually falls someplace between the two, 

11 which turns out to be a number that is a 

12 little bit more, what I would say, claimant13 favorable but not over the top.

14 Now so I mean, so really what we 

15 have is these alternative strategies, all of 

16 which I would say are not all that 

17 unreasonable. I mean they seem to be ways of 

18 coming after the problem. What I confront 

19 myself with, I say I'm doing a dose 

20 construction, and I've got a guy that worked 

21 that facility. 

22 I know that one of his jobs, and 
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1 let's say I'm looking at his job description, 

2 and it turns out he spends a lot of time doing 

3 the reduction work, in other words, in other 

4 words, doing the reduction process where you 

5 make bombs and you drop out the dingot, and 

6 then maybe you go through that cycle many 

7 times. That's his job at this facility. 

8 I would imagine there may very 

9 well have been people at Fernald, and maybe 

10 ElectroMet, certainly ElectroMet, where that 

11 was their job. They took the uranium nitrate, 

12 they mixed it up with a bunch of magnesium, 

13 they heated it up and out drops this uranium 

14 ingot and then you do it again. Maybe you do 

15 it again, until you get yourself a really nice 

16 ingot and each time that happens, you're going 

17 to have this Puzier thing going on.

18 Now here we have this guy and that 

19 is his job. Now I would say that we might get 

20 a little sign, and let's say they have a film 

21 badge -- and especially if there's one, you 

22 know, on his chest or a ring badge. Then 
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1 we're done.

2 But let's say we don't have that, 

3 and we want to reconstruct this dose. I have 

4 to say right now I'm not too happy with the 

5 geometric mean and the standard deviation as 

6 used in TBD-6000 to apply to that guy. I 

7 guess that's really where it comes down.

8 MR. ALLEN: I guess the question 

9 on my part is why are you not happy with that?

10 DR. MAURO: Because I know that 

11 there's a very real possibility he's going to 

12 spend many, many hours per year in a radiation 

13 field that's 10 to 15 times higher than the 

14 one in --

15 MR. ALLEN: And what you described 

16 is essentially how it would work at Fernald if 

17 the guys were assigned to the bottom remelt, 

18 dropping this mold, you know, moving it around 

19 to the separation booth. That would actually 

20 take the mold --

21 DR. MAURO: Fine. Then you go to 

22 assign the highest value, all right. Let me 
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1 ask you this question. Are you going to take 

2 the highest value out of Fernald and assign it 

3 to this guy?

4 MR. ALLEN: Like you said, if you 

5 have film badge data --

6 DR. MAURO: You don't have to. 

7 (Simultaneous speakers.)

8 DR. MAURO: The question is what 

9 are you identifying for this guy?

10 MR. ALLEN: If I assigned a high 

11 value from Fernald for all year, then it would 

12 be at 52 rem. As Jim pointed out, I'm not so 

13 sure that's more favorable than --

14 DR. MAURO: Maybe that's for after 

15 the show. In other words, if you can show 

16 them that assigning the highest deterministic 

17 value that comes off Fernald to this guy is 

18 equivalent, maybe even more conservative, than 

19 assigning the geometric mean and standard 

20 deviation out of TBD-6000, then you've made 

21 your case.

22 MR. ALLEN: Is that the marching 
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1 orders?

2 CHAIRMAN ZIEMER: I don't know, I 

3 don't know. 

4 DR. ANIGSTEIN: Well, actually, 

5 I'm sorry. 

6 CHAIRMAN ZIEMER: Well, while 

7 you're doing that, let me ask Dave, if you had 

8 a facility where you could delineate on job 

9 descriptions the folks that handle dingots 

10 versus those that didn't, then what happens, 

11 where you could -- now I'm just talking 

12 theoretically. 

13 MR. ALLEN: If we had one where we 

14 knew the guy actually had a particular task 

15 where always, and you know, we could assign 

16 the particular doses from that particular task 

17 out of TBD-6000. I can't think of a specific 

18 example where that's ever -- where we would 

19 actually have that. Or where the facility 

20 only did want that.

21 DR. MAURO: But what if you all 

22 did, ElectroMet is a good example.
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1 MR. THURBER: The problem with 

2 ElectroMet is basically a TBD-6001 issue, not 

3 a TBD-6000 issue.

4 DR. MAURO: Well this issue 

5 applies to both, I mean whether they're 6000 

6 or 6001. In fact, I think it applies more to 

7 6001 than 6000. It's more likely you're going 

8 to be melting uranium in a TBD-6001 facility 

9 than in a TBD-6000, where most of the time you 

10 are doing a lot of grinding and rolling.

11 CHAIRMAN ZIEMER: Okay. Bob, you 

12 have a comment here?

13 DR. ANIGSTEIN: Yes. Here's a 

14 report that we put out, I believe it was in 

15 2005, on the effects, that would raise the 

16 issue that Jim Neton raised, about what's the 

17 difference between using the 95th percentile 

18 and the full distribution. 

19 Here, if you have a GSD -- well, I 

20 can just use this. 

21 DR. NETON: Bob, I don't want to 

22 stop you in your tracks here, but we're not 
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1 talking about using the 95th percentile versus 

2 a fixed distribution.

3 DR. ANIGSTEIN: Well, we were 

4 talking about -- you were saying that the 

5 distribution maybe actually more claimant6 favorable.

7 DR. NETON: Than using a 51, which 

8 is only two times the median value. That's 

9 very different --

10 DR. ANIGSTEIN: Oh, okay. 

11 (Simultaneous speakers.)

12 DR. MAURO: Let it go, let it go.

13 DR. NETON: Yes. I would agree 

14 with what you're going to present there, but 

15 what we're saying if you've double the median 

16 values, you can assign that.

17 DR. ANIGSTEIN: I got you. Okay. 

18 DR. NETON: You're still five 

19 times lower than the 95th percentile.

20 DR. ANIGSTEIN: Basically, the 

21 difference is by a factor of two. If you were 

22 to use the 95th percentile, you would get 
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1 about twice the cancer probability.

2 DR. NETON: I completely 

3 understand that, and okay.

4 CHAIRMAN ZIEMER: Okay. Any other 

5 questions on this? Work Group members, I 

6 don't know if you're prepared yet to close 

7 this out. And Mark, you're still pondering 

8 this, I guess.

9 But and I don't know if NIOSH --

10 you're not necessarily suggesting that you're 

11 going to do any further analysis or that you 

12 believe further analysis, based on our 

13 discussion here. Are you guys satisfied that 

14 this is the way you want to proceed? SC&A has 

15 raised their issues, and there's --

16 MR. ALLEN: I'm not convinced 

17 assigning anything other than that 

18 distribution is -- I'm convinced that 

19 assigning a distribution is okay as it is, and 

20 John is certainly not convinced of that and I 

21 guess my question --

22 CHAIRMAN ZIEMER: Well, you've 
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1 questioned it.

2 DR. MAURO: I questioned it.

3 CHAIRMAN ZIEMER: Yes.

4 MR. ALLEN: But you're not even 

5 saying it's wrong; you're not convinced it's 

6 correct.

7 DR. MAURO: Yes. I'm saying the 

8 median, the case has not been made that the 

9 median with this distribution is going to be 

10 appropriately claimant-favorable to a guy 

11 whose job it is to largely work with Puzier 

12 ingots. That's where I come out.

13 MR. ALLEN: But then my question would 

14 be for the Board, you know, is the Board, the 

15 Working Group satisfied and if not --

16 CHAIRMAN ZIEMER: That's what I'm 

17 asking now. Does the Work Group wish any 

18 further analysis be done?

19 MEMBER BEACH: Bob had brought up 

20 earlier about doing some hypothetical dose 

21 reconstructions. Is that something that would 

22 be helpful or --
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1 CHAIRMAN ZIEMER: Well, I ask --

2 MEMBER BEACH: That's what I'm 

3 asking. I'm asking John and Bob if that's 

4 something we need to do.

5 CHAIRMAN ZIEMER: You're talking 

6 about specific cases or hypothetical cases?

7 MEMBER BEACH: Hypothetical.

8 CHAIRMAN ZIEMER: Such as what you 

9 described versus --

10 MEMBER BEACH: Well --

11 DR. NETON: I would suggest that 

12 if we did the analysis and tried the 51 value 

13 versus the whole distribution and it was very 

14 clear, and it was only to be claimant15 favorable to use the distribution, then maybe 

16 this issue goes away.

17 DR. ANIGSTEIN: But what about the 

18 issue -- but still the point I raised, the 

19 fact that the ratio between the dose to the 

20 hands and the general skin dose, I think, is 

21 not consistent with our MCMP analysis. 

22 There's a much higher -- in other 
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1 words, depending on whether you -- the film 

2 badge is at one foot or at one meter, you have 

3 a multiplier that goes between 43 and 250, as 

4 opposed to only 11.

5 CHAIRMAN ZIEMER: Is that specific 

6 to this TBD, or is that a system-wide question 

7 that's come up in other --

8 DR. ANIGSTEIN: That's just for 

9 dose on this -- it's from the uranium, from 

10 natural uranium, basically. 

11 DR. NETON: It would be relevant 

12 to anybody who had skin dose, people with skin 

13 dose --

14 (Simultaneous speakers.)

15 CHAIRMAN ZIEMER: Are you saying 

16 that in all cases, the geometrical factor 

17 NIOSH is using for hands to body is --

18 DR. ANIGSTEIN: Yes.

19 CHAIRMAN ZIEMER: Not just here?

20 DR. ANIGSTEIN: Based on this one 

21 analysis that we did, and we can certainly do 

22 more; we did it for this --
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1 CHAIRMAN ZIEMER: Has it shown up 

2 in other cases?

3 MR. ALLEN: I don't recall.

4 DR. NETON: We did not have this 

5 issue come up.

6 DR. ANIGSTEIN: We haven't raised 

7 it before.

8 CHAIRMAN ZIEMER: Do you not have 

9 a standard correction factor for the various 

10 organ positions? I mean if you go from --

11 (Simultaneous speakers.)

12 CHAIRMAN ZIEMER: -- from a whole 

13 body badge-extrapolated, or if you want a hand 

14 dose, if someone gets a skin cancer in their 

15 hand, and then you have film badge data, do 

16 you have a standard ratio that's used?

17 MR. ALLEN: I don't believe we do. 

18 We've got TBD-6000/6001. Other than that, I 

19 think it's based on data from that facility, 

20 whatever data we would have. But no, I don't 

21 think we have a standard.

22 CHAIRMAN ZIEMER: Well, how would 
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1 you -- you're always calculating organ doses 

2 from the film badge?

3 DR. NETON: Well, we're talking 

4 about shallow dose here primarily, and then 

5 there's no organ doses other than the skin. 

6 Or for beta activity really.

7 CHAIRMAN ZIEMER: Now maybe we 

8 don't get that many skin doses.

9 DR. NETON: We don't get a lot of 

10 hand cancers. 

11 MR. ALLEN: But I did want to 

12 plant that 11, the factor of 11 that's been 

13 mentioned is from skin of the whole body to 

14 skin of the hands. The factor from deep dose 

15 through skin of the hands is ten times that. 

16 It's 110, which is consistent with the two 

17 millirem photon on the surface versus, you 

18 know.

19 DR. ANIGSTEIN: Yes. But I was 

20 specifically talking about the beta dose to 

21 the film badge and the beta dose to the -- and 

22 the surface contact beta dose. That was the 
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1 only point I was raising.

2 MR. ALLEN: Yes. I'm just 

3 pointing out that the measurements essentially 

4 on a side of uranium, the ratio seems to be 

5 reasonably consistent, about 110 to 1, when 

6 you're talking about two. So you're talking 

7 about two millirems on the surface.

8 DR. ANIGSTEIN: But now we're 

9 talking about --

10 (Simultaneous speakers.)

11 DR. ANIGSTEIN: Well, I'm only 

12 comparing it to the deep. You're comparing it 

13 to the skin.

14 MR. ALLEN: But that would imply, 

15 if it is consistent as far as deep to surface 

16 beta gamma dose ratio, and you're saying that 

17 the ratio of whole body scan to hands, skin 

18 dose is not appropriate or too low, it implies 

19 that the skin of the whole body, again, is too 

20 high. There's a measurement that basically 

21 says two and 200, that's a 101 ratio. 

22 DR. MAURO: Sure. The non-
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1 penetrating at one foot is two; the 

2 penetrating, the total at contact.

3 MR. ALLEN: At contact, not one 

4 part.

5 DR. MAURO: So yes. That's 

6 physics. That's not measurements. That's 

7 physics.

8 MR. ALLEN: And that's essentially 

9 what the ratio is in TBD-6000. It's actually 

10 a ratio of 110 to 1.

11 DR. ANIGSTEIN: But you're 

12 justifying it on the basis of the film badge 

13 reading of non-penetrating radiation, and I'm 

14 simply saying that the film badge data on non15 penetrating radiation is not being correctly 

16 extrapolated to the contact dose to the hands 

17 in contact with the metal.

18 MR. THURBER: Bob? This is Bill 

19 Thurber. The dose to the hands is based 

20 directly on the experimental measurement of 

21 230 millirad per hour or whatever. But the 

22 dose to the skin other than the hands and arms 
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1 that uses this tenfold factor of the photon 

2 dose at one foot to the dose to the skin on 

3 the neck or wherever.

4 DR. ANIGSTEIN: Fine. But the 230 

5 does not account for it. It does not take

6 into account the Puzier effect.

7 MR. THURBER: Granted that, no. 

8 But I'm just saying that the hands-and-arms 

9 doses is -- in TBD-6000, the hands-and-arms 

10 dose is derived differently from the rest of 

11 the skin.

12 In one case for the hands and arms 

13 that uses experimental measurements of contact 

14 dose, if you will, and in the other case, it 

15 uses an empirical factor which says that the 

16 ratio of the photon dose to the other skin 

17 dose is tenfold, then I would note if anybody 

18 is ever going to revise TBD-6000, the source 

19 of that information is incorrectly referenced 

20 and untraceable.

21 CHAIRMAN ZIEMER: Bill, we're 

22 going to take -- the Chair wants a comfort 
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1 break, so we're going to take a break for ten 

2 minutes right now. Thanks.

3 MR. KATZ: We'll start back up 

4 around quarter after. It's about five after 

5 right now

6 (Whereupon, the above-entitled 

7 matter went off the record at 11:03 a.m. and 

8 resumed at 11:16 a.m.)

9 MR. KATZ: Okay. We are 

10 reconvening after a short break. This is the 

11 TBD-6000 Work Group. Dr. Ziemer.

12 CHAIRMAN ZIEMER: Okay. Let me 

13 ask the Work Group members, do you need any 

14 further information on this issue? Are we 

15 ready to close it, or do you want to carry it 

16 over until the next meeting?

17 MEMBER GRIFFON: Paul, this is 

18 Mark.

19 CHAIRMAN ZIEMER: Go ahead, Mark.

20 MEMBER GRIFFON: You know, I think 

21 it may be -- I think we're very close to 

22 closing this, but I think it might be 
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1 worthwhile to see that comparison that John 

2 was mentioning, the static 95th versus the 

3 full distribution and to see what effect that 

4 has on various organ and PoC calculations.

5 DR. NETON: Mark, this is Jim. It 

6 wasn't -- I don't think he's proposing the 

7 static 95th. I think he was talking about 

8 using the highest value that they found. I 

9 think it was at Fernald, and use that as a 

10 constant versus the full distribution.

11 In other words, they thought 51, I 

12 think 50-something rem, of the highs of a 

13 125,000 or whatever measurements he reviewed.

14 DR. MAURO: You know what might be 

15 worthwhile --

16 MEMBER GRIFFON: One question I

17 had on that topic is going after the extremity 

18 question. I don't think the Fernald 

19 information is whole body values, I am 

20 assuming. So there's no extremity 

21 information. I'm not sure in TBD-6000 how the 

22 full-on hand doses were estimated. Was that 
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1 data from extremity data or --

2 CHAIRMAN ZIEMER: Dave, could you 

3 clarify that for Mark?

4 MR. ALLEN: He just pointed out 

5 that --

6 MEMBER GRIFFON: The TBD-6000 

7 Table 6.4.

8 CHAIRMAN ZIEMER: The extremity 

9 dose. He's asking how they were --

10 MR. ALLEN: How they were 

11 calculated?

12 MEMBER GRIFFON: The basis.

13 MR. ALLEN: I'd have to look at --

14 there was a model thing, I think John alluded 

15 to earlier, for all of them. The deep, the 

16 skin, the whole body and the extremity were a 

17 model dose, and I don't remember the exact 

18 assumptions in that one.

19 But to answer something you 

20 mentioned earlier, yes, the bulk of the data 

21 at Fernald is whole body film badge data. 

22 There is some ring and wrist data, but it's 
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1 very limited and I don't have who it was on 

2 or, you know, where they were. So I didn't 

3 use any of that.

4 DR. MAURO: Bill Thurber, are you 

5 on the line?

6 MR. THURBER: Yes, I am.

7 DR. MAURO: Bill, I think they're 

8 talking about the 3.65 multiplier, on how they 

9 went from the annual dose external, annual 

10 dose to skin, not including the hands and 

11 arms, which were reported for Fernald, and 

12 then from there, which was -- you know, I've 

13 got a number here of 52 rem per year. Then 

14 they multiply that by 3.65 in order to get --

15 MR. THURBER: No, no, no.

16 DR. MAURO: Okay, good. Well, 

17 you're closer to this.

18 MR. THURBER: Okay. First of all, 

19 what was done in TBD-6000 for the dose to the 

20 skin, other than the hands and arms. They 

21 took this value of two millirem per hour that 

22 we've been talking about, and they said we 
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1 have empirical data that says the dose to the 

2 skin, other than the hands and arms, is ten 

3 times the photon dose at one foot.

4 So that's how they got, and they 

5 assume that to then be the geometric mean. 

6 That's how they got the dose to other than 

7 hands and arms in Table 6.4 of TBD-6000. 

8 MEMBER GRIFFON: Excuse me, Bill. 

9 This is Mark Griffon. When you say "they" --

10 MR. THURBER: NIOSH.

11 MEMBER GRIFFON: NIOSH says they 

12 have empirical data, and most of that 

13 empirical data is from the Adley report, isn't 

14 it?

15 MR. THURBER: No, no. This is 

16 what I mentioned earlier that was confusing, 

17 and we just haven't had a chance to dig it 

18 out, because we've only been looking at this 

19 for a day or so. But in TBD-6000, they say 

20 this tenfold factor for the photon dose to the 

21 skin other than the hands and arms, came from 

22 ORAUT 2005. 
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1 Well unfortunately, there are five 

2 ORAUT 2005 references in TBD-6000. So that's 

3 what I meant. We hadn't been able to trace 

4 that number back the next step, because we 

5 don't know which reference is the correct one. 

6 Maybe somebody in the meeting does.

7 CHAIRMAN ZIEMER: Well, apparently 

8 not off the top of our heads here.

9 MR. THURBER: I would think not, 

10 but I'd just point out that our analysis has 

11 stopped at that point, because we didn't have 

12 time to go look at all those documents and see 

13 if we could find where this tenfold factor 

14 came from.

15 DR. MAURO: But Bill, I was asking 

16 more how did they get to the skin direct 

17 contact handle dose, non-penetrating?

18 MR. THURBER: The skin dose was 

19 measured. There was experimental work done, 

20 and they cite a reference, NIOSH cites a 

21 reference, and says that it's 230 rem per hour 

22 at contact.
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1 DR. MAURO: Okay. I see a 

2 footnote.

3 MR. THURBER: No, no. But that 

4 3.65, John --

5 DR. MAURO: Yes, that's my 

6 question.

7 MR. THURBER: No. That's 

8 something I invented. That's nothing to do 

9 with anything else. The 3.65 was -- I'm 

10 sorry. The NIOSH analysis that David Allen 

11 presented, as I mentioned at the beginning, 

12 related to the skin dose other than the hands 

13 and arms.

14 I tried to take it one more step 

15 and compare it to the hands and arms dose in 

16 Table 6.4 of TBD-6000, by making the 

17 assumption that the dose to the hands was 

18 3.65 times what a film badge reading was. 

19 That 3.65 factor came from OCAS 

20 TIB-0013, where they had a body model and 

21 determined that the hands have got 3.65 times 

22 what was the film badge dose. So that's where 
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1 that came from. That was my way to take the 

2 Fernald measurement, if you will, and make it 

3 kind of look like the hands and arms.

4 MEMBER GRIFFON: Can I back up, 

5 just to follow up on what you just said. You 

6 had the 230, and I believe you meant millirad 

7 per hour at contact. 

8 MR. THURBER: 230 is the dose from 

9 the hands, the annual dose in rem. Now I'm 

10 sorry. What's confusing here is that the dose 

11 to the hands in millirem per hour works out to 

12 be the dose to the hands in rem per year, 

13 because there's 2,000 hours in a year and they 

14 assume the contact is 50 percent of the time. 

15 So there's confusion, optical confusion here. 

16 But 230 rem per year is the median 

17 dose to the hands and arms in TBD-6000, and 

18 it's based on 230 millirem per hour measured 

19 dose at contact. 

20 DR. MAURO: For 1,000 hours.

21 MEMBER GRIFFON: For 1,000 hours a 

22 year.
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1 MR. THURBER: For a thousand

2 hours, yes sir.

3 MEMBER GRIFFON: Now but I don't 

4 understand how in the first, looking at Table 

5 6.4, the operator hands and forearm, non6 penetrating doses are about 750. You're 

7 talking non-penetrating here, right?

8 MR. THURBER: Right. We're 

9 talking non-penetrating. Those doses are per 

10 calendar day.

11 MEMBER GRIFFON: Right.

12 MR. THURBER: And you need to look 

13 at the after 1956 or whatever number, because 

14 again, one of the secrets underlying Table 6.4 

15 is that there are three sets of numbers for 

16 each operator and each category, and the first 

17 set is really based on a 48 hour work week, 

18 the second on a 44 hour work week, and the 

19 third on a 40 hour work week, as David Allen 

20 kindly explained to me one time.

21 MEMBER GRIFFON: Right. 

22 DR. MAURO: One of the 
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1 frustrations is we're speaking right now, SC&A 

2 is speaking from a draft document that Bill 

3 Thurber prepared yesterday, which tries to 

4 sort out all these numbers, make all these 

5 comparisons and the numbers are all jumbled 

6 around now. 

7 Why don't we deliver a White Paper 

8 in response to your paper, so everyone could 

9 look at it, the best we can, so everyone will 

10 have the same information in front of them? 

11 Maybe at that point, you know, NIOSH could say 

12 okay, we see SC&A's position as written, and 

13 then decide whether it has any virtue.

14 Because really right now, what 

15 we're really discussing is well, we're a 

16 little -- all we're really saying is, using 

17 the full distribution, based on the work we've 

18 done, which you haven't seen, using the full 

19 distribution of TBD-6000 seems to be a little, 

20 somewhat non-claimant-favorable when, in fact, 

21 the claimant is a person that had a job up 

22 close and personal to an ingot. That's it. I 
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1 mean that's all we're really saying.

2 CHAIRMAN ZIEMER: Well, John, yes. 

3 You have a document you're working from that 

4 we haven't seen, and that would be helpful. I 

5 think Mark was suggesting we not close this 

6 today, so that will give you a chance to 

7 provide that.

8 (Simultaneous speakers.)

9 MEMBER GRIFFON: I have one --

10 that you should point out to me for my 

11 understanding. If I take 230, I understand 

12 the 40, 44 and 48 hour rates, and I see the 

13 operator post '56, it says 630 millirem. I'm 

14 just trying to make the numbers work, very 

15 simplistic thing for me here.

16 CHAIRMAN ZIEMER: Yes.

17 MEMBER GRIFFON: 630 millirem per 

18 day, per calendar day. You just said 230. If 

19 I assume half time exposure, I still get 920, 

20 not 630. Am I doing something wrong here? 

21 230 times four. Shouldn't that equal the 

22 number in this table?
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1 MR. THURBER: The 630 millirem per 

2 calendar day comes from the 230 millirem per 

3 hour experimental data, times an eight hour 

4 day, times 250 over 365 to convert the 

5 calendar days, times .5 to account for the 

6 fact that the contact is half the time. That 

7 should give you 630. 

8 MEMBER GRIFFON: Per calendar day. 

9 So you're dividing this over a --

10 MR. THURBER: Millirem per 

11 calendar day, yes.

12 MEMBER GRIFFON: Okay. That might 

13 be the difference. Thank you.

14 CHAIRMAN ZIEMER: So we'll ask 

15 SC&A to put that paper in final form and 

16 provide it to us. Also, I don't know if this 

17 is something SC&A could add readily, or if 

18 NIOSH would be the one to do this, but would 

19 be it be of help to have a couple of sample 

20 cases, recognizing that that's not the real 

21 answer, because every case is different. But 

22 just to sort of demonstrate the impact of 
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1 using the distribution, as Dave has described 

2 it, versus using the value. Could you add 

3 that readily to your paper --

4 MR. THURBER: Sure.

5 CHAIRMAN ZIEMER: Again, I think 

6 these are cases where you'd have to be very 

7 careful in selecting the parameters, because 

8 as Jim has suggested, you know, it may depend 

9 on the work. Some other issues may impact 

10 that.

11 DR. MAURO: But you're talking a 

12 hypothetical case. 

13 CHAIRMAN ZIEMER: Yes, but use 

14 hypothetical cases.

15 DR. MAURO: Yes, because I don't 

16 know how many real cases we have on skin 

17 cancer of the hand.

18 CHAIRMAN ZIEMER: Probably very 

19 few.

20 MS. WOJCIK: Probably not many.

21 MEMBER BEACH: Then Paul, will the 

22 other issue that Bob brought up, the film 
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1 badge data at the source versus the one foot, 

2 is that going to be covered in some way? I 

3 didn't really hear any closure on that.

4 CHAIRMAN ZIEMER: Well, I think 

5 what they're saying is that the distribution 

6 should more than cover anything that they've 

7 ever seen in the film badges. If I were using 

8 the worse Fernald case, you're sort of --

9 you're pointing out the worse Fernald case is 

10 higher than the median.

11 DR. MAURO: Oh yes. Probably the 

12 worse Fernald case is lower than the 95th 

13 percentile.

14 MR. THURBER: Oh yes, right.

15 DR. MAURO: And that's very 

16 compelling.

17 CHAIRMAN ZIEMER: Right, right. 

18 Okay. 

19 MEMBER BEACH: So we won't lose 

20 that.

21 DR. MAURO: Oh no. 

22 CHAIRMAN ZIEMER: No. Mark, is 
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1 that agreeable with you?

2 MEMBER GRIFFON: Yes, that's fine 

3 Paul. Thank you.

4 CHAIRMAN ZIEMER: Okay. So that's 

5 where we'll go on this one. So --

6 DR. ANIGSTEIN: If I can clarify 

7 on Josie's question. My point was simply that 

8 to use film badge data at confirmation of the 

9 exposure to the hands handling the metal, you 

10 have to use a different multiplier than was 

11 used.

12 MEMBER BEACH: I understand.

13 DR. ANIGSTEIN: That's my only 

14 point.

15 MEMBER BEACH: Right.

16 MEMBER BEACH: They weren't using 

17 -- they're not proposing to use film badge 

18 data to actually calculate those to an 

19 individual during dose reconstruction.

20 MEMBER BEACH: Okay, thank you.

21 CHAIRMAN ZIEMER: Okay. Now let's 

22 move on to -- we had one, Issue 5. We were 
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1 talking about closing that, but Mark wanted to 

2 --

3 MR. ALLEN: Doctor, could I --

4 CHAIRMAN ZIEMER: Oh yes, I'm 

5 sorry. David?

6 MR. ALLEN: One point of 

7 clarification. You said something about some 

8 sample cases on that last one? 

9 CHAIRMAN ZIEMER: They will show 

10 us a couple, to try to make their point, I 

11 think is what they're saying.

12 DR. MAURO: Okay. The ball's in 

13 our court right now. 

14 MR. ALLEN: That was the part I 

15 wasn't clear on.

16 CHAIRMAN ZIEMER: Yes. We have 

17 the Adley report, a White Paper from NIOSH on 

18 the use of the Adley report. Mark hadn't had 

19 a chance to see that prior to our October 

20 meeting, and asked that we not close that 

21 issue until he had a chance to look at that. 

22 Mark, I don't know where you are 
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1 on that issue. That was Issue 5 of the TBD2 6000 matrix.

3 MEMBER GRIFFON: I mean I did look 

4 it over. I guess the biggest question I would 

5 have is the representativeness of this. If 

6 most people are comfortable with the 

7 representativeness of this data from -- I 

8 mean, this experiment was apparently carried 

9 out at the Hanford facility; correct?

10 DR. MAURO: Yes.

11 MEMBER GRIFFON: And if we believe 

12 that that, those conditions. I mean I'm not -

13 - I didn't dig down far enough to, you know, 

14 sort of look into whether I felt that that was 

15 representative of the smaller AAC facilities. 

16 But I guess that would be the 

17 question. It seems like it's in the same time 

18 frame. The data was done in the early 50's at 

19 Hanford.

20 DR. MAURO: Yes. The Hanford, the 

21 Adley report was early 50's. 

22 MEMBER GRIFFON: Yes. So I mean, 
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1 I guess -- I think my questions are addressed 

2 in that regard, you know, that it seems like 

3 it was from the right time period and you 

4 know, I guess the assumption would be is the 

5 practices were very similar. In other words, 

6 it wasn't --

7 I guess the environmental 

8 conditions, etcetera, could be assumed to be 

9 fairly similar. That would make, that would 

10 -- then the NIOSH response addresses my 

11 concerns.

12 CHAIRMAN ZIEMER: Okay. Were 

13 there -- SC&A, did you have any other issues 

14 on that?

15 DR. MAURO: No. In fact, this was 

16 an important discussion we had the last time.

17 CHAIRMAN ZIEMER: That was a large 

18 discussion last time.

19 DR. MAURO: We were --

20 CHAIRMAN ZIEMER: I thought we 

21 were in agreement that --

22 DR. MAURO: We were, yes, yes. In 
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1 a nutshell, this deposition coming out of the 

2 air, the particles. For the longest time, we 

3 were concerned that that way of predicting 

4 what might be on surfaces, mainly assuming 

5 that whatever the dust loading is, it's 

6 falling at a rate of .0075 meters per second. 

7 That's how you're going to predict what's on 

8 surfaces. 

9 And I from the very beginning had 

10 a problem with that, because I had -- I said, 

11 but that's not how the uranium at these 

12 facilities gets on surfaces. It gets there 

13 because of a lot of other things going on. Lo 

14 and behold, we looked at the incredible piece 

15 of work called the Adley report, and son of a 

16 gun -- That model works.

17 So we made a reversal. We made a 

18 complete reversal. We're saying you know, and 

19 we have comments on that on 50 separate dose 

20 reconstruction audit reports. They're all 

21 going to go away and that's good news, because 

22 every time we saw that, we said we don't like 
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1 that model.

2 Right now, SC&A's position is, no, 

3 that model in our mind has been vindicated, 

4 based on the Adley data, and I think Mark, you 

5 just wanted to make sure you took a look at 

6 that Adley data, to feel if in fact that, you 

7 know, it was powerful enough to sort of end 

8 this issue. 

9 MEMBER GRIFFON: That's right, 

10 yes.

11 CHAIRMAN ZIEMER: Okay. So if 

12 there's no further concern on that particular 

13 one, then I would ask the other Work Group 

14 members are we prepared to recommend that this 

15 issue be closed.

16 MEMBER POSTON: Yes.

17 MEMBER BEACH: Yes.

18 CHAIRMAN ZIEMER: I see agreement 

19 in there, with the Work Group members here --

20 MEMBER GRIFFON: Yes.

21 CHAIRMAN ZIEMER: And Mark, okay. 

22 So we agree to close that issue. Next we 
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1 have the status of Issue 6, and this is just a 

2 report from me. Issue 6 was the one where 

3 NIOSH used a -- well, it has to do with the 

4 resuspension factors and the discussion 

5 between NIOSH and SC&A. NIOSH had 

6 recommended, I think, a 10 to the minus 6 and 

7 SC&A recommended 10 to the minus 5 on those 

8 things.

9 It turns out that this issue on 

10 resuspension comes up not only here but in a 

11 lot of different cases. So the agreement last 

12 time was to transfer this issue to the 

13 Procedures Work Group. So it goes off of our 

14 plate. I just wanted to report that I have 

15 formally sent Wanda that item.

16 So the Procedures Work Group now 

17 will be addressing this. Now realize that 

18 this issue remains, I think, in our 

19 terminology in abeyance for us. We do not 

20 close it. So it would get closed eventually 

21 by the Procedures Work Group. They would 

22 report back.
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1 Now depending on the outcome of 

2 that, if there were a change, it would affect 

3 not only this but many other things, and that 

4 might impact on what was done on previous dose 

5 reconstructions. But that's something that 

6 would go back, and in fact this does not 

7 affect, generally doesn't affect SEC 

8 petitions, because it's not an issue of 

9 whether you can reconstruct dose in that case, 

10 but it's how you reconstruct dose.

11 So I don't think it will impact 

12 specifically on the answer to the SEC 

13 petition. But just realize that, in a sense, 

14 this remains unclosed, but it's off of our 

15 plate right now. Okay. Any questions on that 

16 one?

17 MEMBER MUNN: It will be addressed 

18 on the agenda for the January meeting.

19 CHAIRMAN ZIEMER: Of the 

20 Procedures Work Group.

21 MEMBER MUNN: Work Group.

22 CHAIRMAN ZIEMER: Thank you. Now 
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1 let's move on to the Appendix BB, which is the 

2 General Steel Industries Issue Matrix, and 

3 there are a number of issues there, but in 

4 these issues, 3 to 11 all are sort of lumped 

5 together. 

6 But let's look at Issue 1, where 

7 and as I indicated, "Clarify the outcome of 

8 the NIOSH comparison of film badge results 

9 with models." We had a very lengthy 

10 discussion on this last time, but I note that 

11 there may be additional film badge results, 

12 and there's two things here to call attention 

13 to.

14 One is, and we had indicated last 

15 time that there's an indication that there may 

16 be Picker Film Badge Company data present in 

17 the Landauer files. My understanding is that 

18 NIOSH has actually given Landauer a contract 

19 to search and examine those files.

20 I wonder, either Dave or Jim, can 

21 you give us a status report on where we are on 

22 the Picker information?
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1 MR. ALLEN: Not much, but I can 

2 tell you what I know. We did give them a 

3 contract, and the first step was for them to 

4 itemize everything. It's not just for GSI but 

5 everything in those files.

6 CHAIRMAN ZIEMER: Everything in 

7 the files, all the Picker files.

8 MR. ALLEN: And we have not 

9 received it yet after several phone calls. 

10 But they're still working on it, but we have 

11 not received it.

12 CHAIRMAN ZIEMER: So no outcome 

13 yet from that.

14 MR. ALLEN: Yes, yes.

15 CHAIRMAN ZIEMER: Okay. Now, 

16 also, we received information very recently 

17 within the last week from the petitioner, that 

18 there may be some additional film badge 

19 information available, and I think you all got 

20 a copy. It was a copy of Dr. McKeel's 

21 summary. 

22 We do not have the actual 
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1 information, but there was another company 

2 identified in that, and I don't believe 

3 anybody has that information. But, and Dr. 

4 McKeel, maybe you can confirm to us. You only 

5 have the name of the company, as I understand 

6 it, that may have supplied additional 

7 dosimetry; is that correct?

8 DR. McKEEL: Dr. Ziemer, this is 

9 Dan McKeel. Yes, you're correct. I obtained 

10 1,016 pages of FOIA information from the 

11 Nuclear Regulatory Commission, dealing with 

12 byproduct material, seal source licenses at 

13 GSI from 1962 to '74. 

14 In those license applications, it 

15 was clearly documented that the Nuclear 

16 Consultants Corporation -- Nuclear Consultants 

17 Corporation, which had offices in St. Louis, 

18 Ohio, California, did administer an active 

19 film badge program. It was at least in the 

20 1962-63 time frame.

21 That company, NCC let's call it, 

22 was later acquired and became a division of 
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1 the Mallinckrodt Chemical Works in 1966. So 

2 that information confirmed what I told the 

3 Work Group last October -- not October 2009 

4 but before the -- I'm sorry, before the 

5 November 14th Work Group, the November 10th 

6 Work Group meeting in 2008.

7 At that time, I sent Dr. Anigstein 

8 in SC&A and he shared it with the Work Group 

9 and NIOSH, some reports from one isotope 

10 worker at GSI that was headed -- and this was 

11 four quarters of film badge data in 1963, and 

12 there was one report also from '62 -- those 

13 reports were headed "AEC," and at the bottom 

14 was this Nuclear Consultants Corporation. 

15 I mentioned at the time of the 

16 November the 10th '08 Work Group meeting that 

17 Nuclear Consultants Corporation should be 

18 looked for as a source of these -- a second 

19 source of film badges at GSI.

20 So it's very clear from the FOIA 

21 material that that film badge program did in 

22 fact operate, and you know, I have no idea --
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1 NCC, I presume, went out of business when it 

2 was acquired by Mallinckrodt, but it 

3 definitely continued as a named division 

4 called Nuclear Consultants Corporation 

5 Division of Mallinckrodt Chemical Works.

6 So presumably, many of its records 

7 could still be at Mallinckrodt. One 

8 suggestion that flows from that is that that 

9 data should be aggressively sought. 

10 That's, you know, so we have that 

11 information, and that should be plenty to 

12 follow up with Mallinckrodt and see what they 

13 can tell us about where those badge data and 

14 everything went.

15 It's in the license applications. 

16 NCC plays a very important part, because it 

17 calibrated the survey instruments for GSI; it 

18 designed and administered their radiation 

19 safety program. It conducted a film badge 

20 program; it did a radiologic survey in 1962 of 

21 the Building 6 cobalt-60 radiography facility.

22 So you know, it played a huge 
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1 part, and there is ample documentation in 

2 those licenses, documents that they listed 

3 seven types of data that GSI kept, and most of 

4 this data, at least in the early '62 to '67 or 

5 '68 time frame sounds like it was collected by 

6 and overseen and supervised by this NCC 

7 company. 

8 Later on, some of those functions 

9 were taken over by St. Louis Testing. But for 

10 instance, it lists in the license that they 

11 kept radiation survey instrument calibration 

12 records, leak test certificates, quarterly 

13 inventory records, utilization logs, film 

14 badge reports in particular, which was an AEC 

15 requirement under the U.S. Code Section 

16 31.203.

17 There were pocket dosimetry 

18 reports and radiation survey records. So I 

19 think those records should be aggressively 

20 sought.

21 CHAIRMAN ZIEMER: Thank you for 

22 that additional information. One of the 
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1 questions on the issues matrix was -- also had 

2 to do with the source terms, and of course, 

3 we're well aware of the two large betatrons. 

4 We've talked a lot about the 80 

5 millicurie cobalt source and the smaller 

6 iridium source. It appears that there may 

7 have been some other sources also now, based 

8 on the latest information that Dr. McKeel 

9 provided.

10 But let me ask the NIOSH folks. 

11 In terms of the source terms and the modeling 

12 of doses, can you give us a general feel for 

13 the impact that additional source terms would 

14 have on the way the doses are modeled? 

15 For example, and there's some 

16 indication perhaps of the source sizes in the 

17 information we have, although I don't think we 

18 have that really confirmed at this point. 

19 But based on the preliminary 

20 information we have, can you describe, Dave, 

21 how that would -- if it would at all impact on 

22 the way doses are reconstructed?
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1 MR. ALLEN: Well, I think the 

2 information -- I mean, I guess you need to 

3 start from scratch. When we put together the 

4 Appendix, we had some information and 

5 considerable additional information to come 

6 out since then.

7 CHAIRMAN ZIEMER: Right.

8 MR. ALLEN: We've had discussions 

9 in here that they had, I think, quarter curie 

10 cobalt sources in the 6 Building that they 

11 were using. There's been workers who told us. 

12 I think what Dr. McKeel sent us the other day 

13 was saying .28 instead of .25. Or it seemed 

14 to be fairly consistent.

15 The radium source, as he mentioned 

16 in his email, were not something that I had 

17 heard before from any of the workers or 

18 anything like that. We had heard of other 

19 sources and it was limited as to the size of 

20 the sources or how much information we had. 

21 In general, I think we generally 

22 were going to have to do some more robust 
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1 analysis of radiography in the 6 Building with 

2 the smaller cobalt sources.

3 If this information had some 

4 source sizes or other sources that could be 

5 included in that analysis, my general thinking 

6 right now is that if you're going to do 

7 radiography and get a clear picture, you can't 

8 have too many sources in the vicinity, exposed 

9 sources.

10 CHAIRMAN ZIEMER: All at the same 

11 time.

12 MR. ALLEN: At the same time.

13 CHAIRMAN ZIEMER: Well, one of the 

14 things I was sort of getting at was, for 

15 example, how much difference would it make in 

16 the dose reconstruction if you had one source 

17 of a certain size versus two or four or ten, 

18 because they're not all going to be used at 

19 the same time.

20 MR. ALLEN: That's exactly what I 

21 was getting ready to say. You can't use them 

22 and expose them at the same time in the same 
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1 vicinity, or you're defeating the purpose of 

2 them. 

3 So I'm thinking we can try to take 

4 an inventory of what we have, develop the 

5 exposure scenario, you know, what a person 

6 could receive from those X-ray shots, and 

7 essentially pick the highest, is what it would 

8 amount to.

9 Because like I said, it's very 

10 counterproductive to -- it's not even 

11 counterproductive. It would be stupid to 

12 expose more than one source in the same area 

13 and expect to get a clear picture.

14 CHAIRMAN ZIEMER: Right, right. 

15 But is it your -- is it NIOSH's intent now to 

16 update this Appendix BB with this new 

17 information, and do you expect there to be 

18 some difference in the dose reconstruction 

19 approach? Or maybe not the approach, but the 

20 outcome.

21 MR. ALLEN: There's been an 

22 attempt to -- there's been a -- I believe that 
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1 we're going to be revising that ever since 

2 essentially found the film badge data became 

3 available. 

4 I think now with some additional 

5 storage from workers, as far as what was 

6 really occurring various areas, additional 

7 source information and the film badge data, I 

8 think it can all be put together to get a much 

9 clearer picture.

10 I'm not sure the doses are going 

11 to increase with that. 

12 CHAIRMAN ZIEMER: Right, but we 

13 don't know for sure that they won't. So it 

14 appears that it will be important as a minimum 

15 to pull all this new information together and 

16 make a determination as to whether it impacts 

17 on how doses are reconstructed and any of the 

18 assumptions made.

19 Now I think we recognize that 

20 NIOSH does not yet have all of this 

21 information, and of course the Work Group does 

22 not either. But the first step would be for 
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1 NIOSH to get the information and analyze it, 

2 and then we can evaluate it. We may need SC&A 

3 to take an additional look at things.

4 And we need to find a way, and I 

5 know NIOSH is looking into this, a way to 

6 obtain this information that's useful both to 

7 NIOSH, and which is also we can utilize what 

8 the petitioner has seen, that's fair to the 

9 petitioner in terms of perhaps personal 

10 expenses.

11 But it would also seem to me that 

12 it might be important procedurally for NIOSH 

13 to independently get that information. I'm 

14 not sure how appropriate it is to simply have 

15 a petitioner feed information to NIOSH, just 

16 in general terms, although those are -- the 

17 intention is good, but NIOSH has a certain 

18 responsibility here to having uncovered, 

19 through the petitioner, the source of this 

20 information.

21 NIOSH should obtain that 

22 information, however you do it. But I assume 
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1 that can --

2 DR. McKEEL: Dr. Ziemer, this is 

3 Dan McKeel. May I add just one thing to that? 

4 One of the other very important bits of 

5 information that was contained in these 

6 licenses was that all during this time, from 

7 1962 to '64, there was a named liaison person 

8 at GSI named [identifying information 

9 redacted], and it was his job to maintain 

10 constant contact with the Illinois State Board 

11 of Health and the Illinois Department of 

12 Public --

13 CHAIRMAN ZIEMER: Of Nuclear 

14 Safety.

15 DR. McKEEL: Well, no. It said 

16 the Illinois Department of Public Health, and 

17 --

18 CHAIRMAN ZIEMER: Oh right. I 

19 think you're exactly right. It later became 

20 the Illinois Department of Nuclear Safety.

21 DR. McKEEL: Right. But the 

22 Illinois Department, IEMA now, the Illinois 
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1 Emergency Management and its Nuclear Safety 

2 Division, they have been queried by NIOSH and 

3 by Congressman Shimkus and actually Senator 

4 Obama when he was still a senator, and IEMA 

5 says they have none of those really early 

6 records like that. 

7 But it's quite clear from these 

8 documents that both of those state agencies 

9 came to GSI, participated in joint AEC 

10 inspections, including the Building 6 

11 Radiology facility, and also there's a 

12 reference in those documents to their own 

13 requirements.

14 So it seems like there were other 

15 things that the state agencies administered, 

16 and again, I think it's extremely important 

17 for NIOSH to pull out all the stops, to get 

18 those early tracing records. I mentioned to 

19 John Ramspott that we supplied the Board with 

20 the fact that there is an Illinois Radiation 

21 Devices Registration Act that was enacted in 

22 1957.
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1 So you know, whether those records 

2 are still at the state health agencies, I'm 

3 not sure. But they clearly were the people 

4 who would have them, and they should be sought 

5 right now. 

6 I just want to add for the record 

7 that this time, NIOSH tried to get the 

8 licenses information that I got. SC&A tried 

9 to get the licenses that I got. Department of 

10 Energy was encouraged to try to get them and 

11 didn't get them. 

12 So this time, I think there have 

13 got to be written requests and really an 

14 intensive effort, and I would urge that the 

15 appropriate thing to do would be to send a 

16 data capture team to both state agencies, and 

17 to go through their records and see if we 

18 can't find those registration records that are 

19 probably at those agencies.

20 I can -- we will be happy to 

21 supply you with the documentation that the 

22 Board of Health and the Board of Public Health 
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1 later on, that those two Illinois agencies had 

2 a direct part in GSI safety programs and so 

3 forth.

4 CHAIRMAN ZIEMER: Yes, okay. 

5 Thank you, Dan. 

6 DR. McKEEL: All right.

7 CHAIRMAN ZIEMER: Now, so I guess 

8 the task here on this one will be for NIOSH to 

9 gather that information and determine the 

10 extent, if any, that it will change their 

11 approach to dose reconstruction in terms of 

12 Appendix BB. Comment, Bob?

13 DR. ANIGSTEIN: Yes. I have two 

14 comments, one is we recently, SC&A recently, 

15 through our associate who is very intimately 

16 involved with Illinois issues, because he 

17 worked for Landauer for a long time in 

18 Chicago, and he specifically asked IEMA for 

19 records, first for licensing records for 

20 General Steel Industries or General Steel 

21 Casting, the previous name.

22 Then later, when Dr. McKeel 
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1 brought up the certification issue, he called 

2 them again and said, by any chance, if there 

3 was any separate set of records for 

4 certification. Maybe they were too narrow in 

5 looking for licensing and not certification, 

6 source certification, and the answer was the 

7 same. 

8 There were no records of any kind 

9 that they could find pertaining to General 

10 Steel Industries or General Steel Casting for 

11 the time period in question.

12 As far as the NRC is concerned, 

13 all I can say is -- I won't repeat what we 

14 said before, I was -- after a number of 

15 injuries from different NRC employees and 

16 officials, I was directed to the NRC Public 

17 Documents Room, which is staffed by an NRC 

18 contractor, who simply said, oh, General Steel 

19 -- I specifically asked for General Steel 

20 Industries. I didn't say GSI. I said General 

21 Steel Industries, General Steel Castings, and 

22 they said we already performed a FOIA request 
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1 in 2006 with Dr. Daniel McKeel, and there were 

2 no records whatsoever.

3 So I saw no point in sending 

4 another request at that time. Why there was 

5 that confusion, I agree, there was an error.

6 CHAIRMAN ZIEMER: In any event, 

7 Dr. McKeel now has --

8 (Simultaneous speakers.)

9 CHAIRMAN ZIEMER: -- records, and 

10 so lots of follow-up is needed.

11 DR. McKEEL: Dan McKeel. There 

12 was no error. I did in fact file a FOIA 

13 request through the NRC in 2006. They said 

14 there were no such records, but I knew there 

15 must those records. 

16 And really, the only logical 

17 place, having gotten the same answer that Dr. 

18 Anigstein got from IEMA on several occasions, 

19 was to go back to NRC and all I did was write 

20 a straightforward simple FOIA request, asking 

21 for those license documents, and they came 

22 back and first and said there were 600 pages, 
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1 and eventually they delivered more than 1,000 

2 pages.

3 Every single record -- this is one 

4 of the few FOIAs I've ever gotten directly 

5 related to those seal source licenses. So 

6 maybe the lesson to be learned here is don't 

7 give up, it's always worth asking.

8 And as far as IEMA and records 

9 currently, I do need to point out that the 

10 Illinois State Board of Health and the 

11 Illinois Department of Public Health are two 

12 different agencies that are still in 

13 operation, and they really are not the same as 

14 IEMA and its Nuclear Safety Division.

15 So I don't really think it 

16 probably is worthwhile to go back to IEMA. 

17 But it could be if you're going to send a data 

18 capture team. But it's the other state 

19 agencies in Illinois that I think would have 

20 the registration records for radiation 

21 devices. So that would be my suggestion, to 

22 go to them.
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1 CHAIRMAN ZIEMER: Okay, thanks 

2 Dan. We appreciate that input. Let me also 

3 mention, I think you talked about, also, leak 

4 test records and things like that, and I think 

5 I would certainly be interested myself in what 

6 they found there, particularly since they 

7 apparently had radium sources. And radium 

8 sources, historically, have been notorious for 

9 leaking, and that would be very interesting to 

10 learn what they found on those radium sources.

11 DR. McKEEL: Dr. Ziemer, I also 

12 urge again that you all go to Mallinckrodt or 

13 Tyco and see if they don't have some of those 

14 records from the Nuclear Consulting 

15 Corporation, because there's a [identifying 

16 information redacted], who headed that group, 

17 a very famous alumni of the University of 

18 Ohio.

19 You know, I think Mallinckrodt 

20 should be able to shed some light on those old 

21 records.

22 CHAIRMAN ZIEMER: Okay. Well, we 
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1 have that information, and NIOSH is prepared 

2 to move ahead on that. Let's move -- so that, 

3 what I've jotted down here, and sort of the 

4 task, as it were, that one's in NIOSH's hands 

5 to follow up and gather all of this 

6 information, as it may pertain to source terms 

7 and related matters.

8 The second issue that, and the 

9 agenda indicated this with a question. Do we 

10 have a final response from DOL on the issue of 

11 a start date for the covered period? 

12 That was a question that was 

13 raised previously. It was kind of left up in 

14 the air that -- and I don't know if there has 

15 been an actual inquiry made. 

16 Dave, can you report on that?

17 MR. ALLEN: Yes. That was brought 

18 up because of the date on one memo, you know. 

19 It's debatable whether it's a stray mark or 

20 1953 changed to 1952. It's not the clearest 

21 thing in the world. As a result of a Work 

22 Group meeting, we sent a letter to the 
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1 Department of Labor with that form on it, and 

2 asked them if this would change your opinion 

3 as far as the start date, and we never heard 

4 back. I don't know if we will hear back. 

5 If they did have that data or that 

6 document, you know, prior to us sending it to 

7 them. We just brought it to their attention 

8 again.

9 CHAIRMAN ZIEMER: Do we expect a 

10 response or was it the type of letter where 

11 you're simply pointing it out and the ball's 

12 in their court?

13 Are we awaiting a response?

14 MR. ALLEN: We're not really 

15 awaiting a response. We can't do anything 

16 with 1952 unless DOL --

17 CHAIRMAN ZIEMER: So you've raised 

18 the issue with them?

19 MR. ALLEN: We raised the issue 

20 with them, pointed it out, handed them another 

21 copy of that document. But yes, it's in their 

22 ball court. 
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1 CHAIRMAN ZIEMER: Did they 

2 acknowledge at all that they received that 

3 information?

4 MR. ALLEN: That I couldn't tell 

5 you for sure.

6 CHAIRMAN ZIEMER: This went to, it 

7 would have gone to Jeff's office?

8 MR. ALLEN: No. It would have 

9 gone to -- I'm trying to think of the time 

10 frame. I'm not sure if it went to Rachel 

11 Leiton or if it went to Pete Turcic, whoever 

12 was the --

13 DR. NETON: What about the 

14 director of the program over there? Okay. 

15 It's typically their practice to respond to 

16 any letter like that. So they don't think of 

17 something, you usually get sort of a written 

18 response, what the results of their evaluation 

19 was.

20 MR. ALLEN: Well, if we sent them 

21 a letter that says that we say we think what 

22 you have currently is incorrect and here's 
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1 why, we will normally get a response one way 

2 or another. In this case, I think we sent 

3 them one saying here, this may be additional 

4 information. I'm not sure we really said that 

5 we believe it's '52 or '53. We just said we 

6 wanted to make sure you have this. 

7 CHAIRMAN ZIEMER: Bob, question.

8 DR. ANIGSTEIN: I'd make an 

9 observation on that. This change, this ink 

10 mark on it just gave me the idea that maybe it 

11 was changed. But irrespective of that, we 

12 have -- there is no documentation prior to 

13 '58, except for that one cover sheet 

14 summarizing the information.

15 So even if -- forget the ink mark 

16 -- even if that memo was written in December 

17 of '53, it does not preclude that there would 

18 -- that it doesn't tell you how long this was 

19 going on. Had it just started? Or my point 

20 was that given that the betatron was 

21 installed in early 1952, I think in January, 

22 by the Army; given that Mallinckrodt was 
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1 producing in this; given that they must have 

2 been easily aware of the fact that the 

3 betatron facility existed or was used for --

4 GSI you know, had planted the story in the 

5 local newspaper, for their publicity purposes, 

6 it is logical that it's not unlikely that they 

7 would have got the idea, hey, here's somebody 

8 30 miles away. The government owns a 

9 betatron. Why don't we take advantage of it 

10 and start using it?

11 So one thing is to be claimant12 favorable. It's a strong possibility. That's 

13 all I'm saying. I'm not saying that it's 

14 true, but it is a strong possibility, and 

15 therefore they should give them that extra 

16 year, in my personal opinion.

17 CHAIRMAN ZIEMER: But that's not -

18 -

19 (Simultaneous speakers.)

20 DR. ANIGSTEIN: I mean it could be 

21 recommended. I mean, it could have been more

22 strong if you -- to say that when there's a 
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1 recommendation. They answer more, you know, 

2 they do answer. 

3 MR. ALLEN: They already took that 

4 piece of information and started the date 

5 there, because like you said, without that 

6 piece of paper, the start date would be 1953, 

7 I think.

8 (Simultaneous speakers.)

9 DR. ANIGSTEIN: But even in '58, 

10 there was an indication in the correspondence 

11 that it had been -- there had been a previous 

12 contract, and there was that one case where 

13 there is a payment, albeit a small payment. 

14 They said we don't have a 

15 contract. We don't have a purchase order at 

16 the moment, but the administrative purchasing 

17 manager at Mallinckrodt said, I recommend that 

18 we pay this, because this is consistent with 

19 the previous contract. That's all we know, is 

20 that there was a previous contract.

21 MR. ALLEN: Yes, I agree. I mean 

22 the information is very limited there --
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1 DR. ANIGSTEIN: It is, it is.

2 MR. ALLEN: I think DOL certainly, 

3 you know, in my opinion, they were -- they 

4 didn't require documentation in '54, '55, '56, 

5 even though it looks like it was like 

6 restarting in '58-ish. 

7 DR. ANIGSTEIN: Yes. But the '53 

8 simply said -- the '53 or '52 memo, depending 

9 on the date, simply said "Regarding the 

10 radiography, betatron radiography" or 

11 something like that, of Mallinckrodt, Inc. by 

12 General Steel Casting, right.

13 MR. ALLEN: Yes, something to that 

14 effect. It's everyday, and they apparently 

15 took that information and that's what they 

16 used to create the start date.

17 DR. ANIGSTEIN: Well, actually DOE 

18 took that information, a gentleman by the name 

19 of [identifying information redacted], 

20 [identifying information redacted]. I believe 

21 that was his name. No, that was California. 

22 I forget his name, but -- I even 
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1 met him. Anyway, and he simply took that and 

2 said "Well, it's been going on since '53," and 

3 DOL picked up on that. But the idea at that 

4 time, his point was simply to get the survey 

5 date.

6 CHAIRMAN ZIEMER: Well, okay. We 

7 can't do anything more about that. I guess I 

8 don't know if there's any point in going back 

9 to Labor. You've sent them the information. 

10 I guess I'd be more comfortable if we knew 

11 that they actually received it. 

12 MR. ALLEN: I'll look. I don't 

13 know the administrative process on that.

14 CHAIRMAN ZIEMER: I don't either. 

15 I don't know if it's something that can be 

16 checked out.

17 MR. KATZ: It certainly can't hurt 

18 to send them an email and ask them --

19 DR. NETON: Well, we have biweekly 

20 phone calls with them. 

21 (Simultaneous speakers.)

22 CHAIRMAN ZIEMER: Okay. So that 
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1 will be simple. I'll just make a note, "NIOSH 

2 to confirm that they received it." Now Issues 

3 3 to 11, if you look at the matrix, you'll see 

4 basically the same answer from NIOSH for every 

5 one of those issues.

6 It has to do with the film badge 

7 data and the modeling. I guess that now, and 

8 also sort of the source terms are part of 

9 that. But I -- just for these issues, it's 

10 sort of going to be somewhat like Issue 1. 

11 It's going to be impacted or not by what you 

12 find as you pursue the other information.

13 So in my mind, we have to keep 

14 these issues open until we get the results of 

15 the new film badge and new source term data, 

16 to see if that will impact on the model.

17 MR. ALLEN: I agree. 

18 CHAIRMAN ZIEMER: Any other 

19 comments on that, Issues 3 to 11?

20 MEMBER MUNN: No, but I do have 

21 one general comment that has to do with the 

22 matrix itself. Would it be possible for us to 
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1 begin to date these responses and --

2 CHAIRMAN ZIEMER: Exactly. In 

3 fact, I had exactly the same notation for 

4 myself to bring up. When a response is made, 

5 and it's sort of like what you're doing in the 

6 matrix for the procedures, to indicate the 

7 dates that the response was made, so that we 

8 have an idea as we progress through this -- is 

9 this something really current?

10 I mean when you start to look at 

11 all the different facilities in the matrices, 

12 it's very easy to lose track of, is this an 

13 old reply that's been sitting on the table for 

14 a long time? The only way you find that out, 

15 you keep going back to earlier versions and 

16 see when it appeared.

17 But it would be very convenient 

18 just to have that on the matrix, where it says 

19 "NIOSH response" as of a certain date. SC&A 

20 reply of a certain date and so on. In some 

21 cases we have that, but like on our current 

22 matrix -- yes.
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1 DR. ANIGSTEIN: The one that I 

2 sort of took it on myself to send out a 

3 revised version of the matrix, the issues 

4 matrix and SBD, and on the cover page, the 

5 main reason for it was the cover page gives a 

6 history. 

7 We have the original date, May 

8 2nd, 2008. NIOSH response is June 19th, 2008 

9 and reissued, because that's when I sent it 

10 out, December 8th, 2009, but there were no 

11 substantive changes to it.

12 CHAIRMAN ZIEMER: Okay. But what 

13 happens is that you end up with the matrix --

14 DR. ANIGSTEIN: I think you're 

15 looking at the SEC petition matrix. I'm 

16 talking about the Appendix BB matrix.

17 CHAIRMAN ZIEMER: Okay. But you -

18 - yes, that's one where you have done that.

19 DR. ANIGSTEIN: Just now. We just 

20 now did that.

21 CHAIRMAN ZIEMER: Yes. But here 

22 on the appendix, or on the petition matrix, we 
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1 don't have those dates. We just need to be 

2 consistent.

3 DR. ANIGSTEIN: What I would 

4 suggest though, and if John agrees, is that we 

5 change the format of the matrix and simply 

6 have a little box.

7 CHAIRMAN ZIEMER: Yes, whatever.

8 DR. ANIGSTEIN: When NIOSH adds a 

9 response, they put, they type in the date. 

10 When SC&A replies to the NIOSH response, we 

11 type in the date.

12 CHAIRMAN ZIEMER: I think that's 

13 all you're asking for.

14 MEMBER MUNN: That's the simplest 

15 way.

16 (Simultaneous speakers.)

17 CHAIRMAN ZIEMER: Right, right.

18 MEMBER MUNN: Exactly, yes. Right 

19 after NIOSH --

20 CHAIRMAN ZIEMER: It would be very 

21 helpful. It would be very helpful. So Issues 

22 3 through 11 we'll await input. Issue 12. 
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1 That is -- I just put a comment here. It 

2 appear to me to be the same as Issue 6 of TBD3 6000. That's the resuspension issue.

4 So, and that item's been 

5 transferred to the Procedures Group. I don't 

6 know if we need to specifically transfer this 

7 item as well, or if we just put it in abeyance 

8 awaiting the outcome.

9 MEMBER MUNN: Regulation of Issue 

10 6, as it refers back to 6, then just in 

11 abeyance for that reason.

12 CHAIRMAN ZIEMER: Is that 

13 agreeable, or do we need to formally transfer 

14 this as well?

15 MEMBER MUNN: The same issue. 

16 It's going to be worked the same time period 

17 or the same --

18 CHAIRMAN ZIEMER: Right. Well, 

19 I'm asking do we need to formally transfer 

20 this one or do we just let it sit, with the 

21 understanding that whatever the outcome of the 

22 other, we'll make this outcome.
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1 MEMBER MUNN: In my opinion, a 

2 notation needs to be made that it's in 

3 abeyance awaiting the closure of Issue 6.

4 CHAIRMAN ZIEMER: Okay. Is that 

5 agreeable? Any objections?

6 MEMBER BEACH: Awaiting the 

7 closure of Issue 6 or Issue 1?

8 CHAIRMAN ZIEMER: Issue 6 of the 

9 other matrix. That's the overriding -- it's 

10 the TBD-6000 matrix, and that was on the other 

11 matrix. It was Issue 6. 

12 (Pause.)

13 CHAIRMAN ZIEMER: Okay. Then the 

14 last one here, the last -- well, a couple more 

15 items. I had here follow-up on new 

16 information provided by the petitioner. We 

17 actually have already discussed that.

18 MR. KATZ: Can I just ask a 

19 question? Going back to the 12 and 6, which 

20 are identical but two different matrices, and 

21 have been transferred to the Procedures, is 

22 there any work that needs to be undertaken, 
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1 for that Subcommittee to be able to address 

2 and close that issue?

3 CHAIRMAN ZIEMER: Well, I have 

4 formally transmitted by email using the 

5 format. 

6 MR. KATZ: No, I understand that.

7 CHAIRMAN ZIEMER: So it's 

8 transmitted. So the answer is what? 

9 MEMBER MUNN: It will be covered 

10 under DID-70.

11 (Simultaneous speakers.) 

12 CHAIRMAN ZIEMER: And that's in 

13 process.

14 MR. KATZ: Okay. Okay, good. I 

15 just wanted to -- didn't want time to go by if 

16 something could be done towards --

17 (Simultaneous speakers.)

18 CHAIRMAN ZIEMER: It's system19 wide. So you have this one, which is the same 

20 as the 6000 one, which is the same as the 

21 other TBD. It's all the same issue.

22 MR. KATZ: Thanks.
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1 CHAIRMAN ZIEMER: And it comes up 

2 repeatedly, and SC&A has been consistent when 

3 they find this issue of raising it basically 

4 for us in an identical way, yes.

5 A final one here, and then we'll 

6 break for lunch, a preliminary report on 

7 interview of a site expert. At our last 

8 meeting, we talked about the possibility of 

9 sort of independently reconfirming the size of 

10 some of those sources, particularly the 80 

11 curie, by knowing something about the rope-off 

12 distance that was used to achieve the two mR 

13 per hour.

14 Dr. McKeel and Mr. Dutko

15 subsequently came up with the name of an 

16 individual that they thought might be able to 

17 help with that. I have contacted that 

18 individual and conducted a phone interview, 

19 and I've committed to that individual that I 

20 would send back the written report to him, so 

21 that he can confirm that I've characterized 

22 the interview correctly before I distribute it 
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1 to anybody.

2 So I just want to confirm to you 

3 that I have conducted that interview. I've 

4 written up a report, and it will await the 

5 approval of the individual, that I have 

6 correctly characterized our discussion. 

7 Then at that point, I will share 

8 that with the group or with the Work Group and 

9 with the petitioners. But basically, that 

10 will be an added piece of information that we 

11 can put in the mix with the other new 

12 information that we're talking about. 

13 I think with that, we will recess 

14 for lunch, and then immediately after lunch, 

15 we will begin our discussion on the GSI 

16 petition and the petition matrix that you all 

17 have. We had an initial discussion on that 

18 last time, and we will get into a little more 

19 depth on that now. So we'll reconvene at 

20 1:30.

21 MR. KATZ: Can you try to get back 

22 earlier?
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1 CHAIRMAN ZIEMER: Yes. Maybe we 

2 can get back by 1:15. Let's try for 1:15. 

3 That will give us just under an hour, but I 

4 think we can do that, yes. So and for those 

5 folks on the phone then, we'll recess until 

6 1:15 local time here, which I guess is 12:15 

7 out in the -- for folks out in the Midwest. 

8 MR. KATZ: Thank you everyone on 

9 the phone, and we'll rejoin you this 

10 afternoon.

11 (Whereupon, the above-entitled 

12 matter went off the record at 12:20 p.m. and 

13 resumed at 1:20 p.m.)

14

15

16

17

18

19

20

21

22
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1

2
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 (1:20 p.m.)

3 CHAIRMAN ZIEMER: We're back on 

4 line. We almost made it back by quarter 

5 after, but not quite. So thank you all for 

6 being patient. 

7 We're ready to resume with Item 5 

8 on the agenda, which is specifically the 

9 General Steel Industries SEC Petition 

10 Evaluation Report, and the SC&A Review Matrix. 

11 Just for reference, we have a copy 

12 of the review matrix, which has an original 

13 date of October 12th on it. It includes the 

14 SC&A findings, the NIOSH responses, and some 

15 SC&A replies. So make sure we're all sort of 

16 reading from the same manuscript here.

17 What we'd like to do is determine 

18 if any further NIOSH response, if there are 

19 any further NIOSH responses to any of the SC&A 

20 replies, number one. We also want to consider 

21 some, any issues raised by the petitioner, and 

22 I believe that Dr. McKeel distributed just in 
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1 the last couple of days some concerns about 

2 the matrix issues.

3 Some of those overlap into items 

4 we discussed with regard to the main matrix as 

5 well. Then we want to identify what the path 

6 forward is on each of these items. That is, 

7 whether additional work needs to be done, or 

8 whether we are in a position to close any of 

9 them out.

10 There's ten issues in the matrix 

11 for the Special Exposure Cohort Evaluation 

12 Report review. So let's step through each of 

13 those and see where we are. On the first 

14 issue was the issue entitled Lack of Radiation 

15 Monitoring Data, and there were issues raised 

16 about some incidents on the site.

17 We also obtained some additional 

18 incident information, I believe, which was 

19 supplied by Dr. McKeel or Mr. Ramspott. But 

20 we had some additional information there as 

21 well.

22 SC&A -- or NIOSH indicated that 
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1 they accommodate the known incidents because 

2 they can specifically deal with those, and, in 

3 fact, have already, I think, incorporated 

4 specifics of one case where a dose 

5 reconstruction was done. 

6 So in general, if they know about 

7 specific instances, I think the general 

8 question being raised was was there a plethora 

9 of incidents that perhaps weren't recorded and 

10 might impact on how one goes about a general 

11 dose reconstruction, although that is sort of 

12 a generic question that one could raise 

13 anyway, I suppose.

14 I mean the general approach for 

15 reconstructing dose, where you use a model 

16 typically doesn't assign general incidents 

17 outside of known parameters, as far as I am 

18 aware. But nonetheless that's an issue that 

19 can be discussed, and I don't know if I fully 

20 characterized those. 

21 But I think the SC&A concern was 

22 what do you do about -- how do you capture 
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1 this in the overall scheme of things. 

2 DR. ANIGSTEIN: I mean the problem 

3 with this is two-fold. One is the years, well 

4 the Issue 1. There's another issue -- go in 

5 order -- Issue 1 is -- to '63, where there is 

6 no monitoring -- we have no film badge data. 

7 CHAIRMAN ZIEMER: Although we may 

8 end up getting it.

9 DR. ANIGSTEIN: We may end up. 

10 But I mean at the moment, there is no film 

11 badge data, and therefore we can certainly 

12 make estimates based on knowledge of the 

13 application of the process knowledge. We can 

14 make some estimates of the exposures from 

15 routine operations. But they cannot encompass 

16 the incidents.

17 The recurring theme, which is 

18 mentioned -- I'll mention it here because it's 

19 relevant to our discussion later, is the 

20 dichotomy of the two classes of workers, the 

21 workers who -- the betatron operators and 

22 other, and I guess by extension other isotope 
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1 operators, even though Appendix BB does not 

2 even refer to them.

3 And put into that category would 

4 be the workers who worked on the casting 

5 immediately after radiography, that they will 

6 be getting some exposure to the short-lived 

7 activation product in the castings.

8 So they are assigned one category, 

9 and then everyone else in the plant is 

10 assigned a different category, as far as dose 

11 assignment. And here are examples of 

12 incidents which involved non-radiation workers 

13 and non-steel repair workers, shall we call 

14 them.

15 So they would not have been 

16 covered by even the routine high elevated 

17 exposures as the betatron -- the radiation 

18 workers, put them in that category, were 

19 assigned. So that's one concern.

20 CHAIRMAN ZIEMER: But it seems to 

21 me you have that kind of concern on any site 

22 where you're doing this kind of dose 
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1 reconstruction. Number one, unless you 

2 operate under the assumption that incidents 

3 were, like, a daily occurrence, which I 

4 suppose you couldn't rule out --

5 DR. ANIGSTEIN: No.

6 CHAIRMAN ZIEMER: But an incident 

7 by its very nature generally calls attention 

8 to itself in some way or another. I mean the 

9 very nature of what do you mean by an 

10 incident. 

11 It's something that occurs that's 

12 out of the ordinary. The cases that we know 

13 of were always cases where something occurred 

14 that caused people to make note of it.

15 DR. ANIGSTEIN: Yes.

16 CHAIRMAN ZIEMER: So otherwise, I 

17 don't think we're generally trying to assign 

18 doses based on well, so let's assume so many 

19 incidents a week or something like that. I 

20 don't think we ever do that. And it's 

21 certainly true that any of the dose 

22 reconstruction approaches, there's always an 
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1 outside chance that someone could have been 

2 missed.

3 But what you're trying to do here 

4 is minimize that by the claimant-favorable and 

5 other assumptions that say okay, maybe we 

6 didn't account for every possible thing, 

7 because any time you mention something's 

8 possible, I can think of something else that's 

9 worse. 

10 DR. ANIGSTEIN: Yes, sure.

11 CHAIRMAN ZIEMER: So I don't know 

12 how you handle that. But I think the first 

13 thing you have to do is say -- and the issue 

14 of dividing people up, I think, is a separate 

15 thing from incidents. 

16 I mean it's -- well, regardless of 

17 what you say about incidents, if there are 

18 two classes of workers that you clearly can 

19 identify, then it's reasonable to assign 

20 those. 

21 We've done that in other places, 

22 and that's not an unreasonable thing to do. 
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1 Now and then if incidents occur, you can do 

2 special mock-ups, dose reconstructions, 

3 whatever, for those cases. But otherwise, 

4 what do you do?

5 DR. MAURO: See, when I look at 

6 all the sophistication that was brought to 

7 bear on this problem, especially the way the 

8 betatron was modeled, the MCMP --

9 COURT REPORTER: Mr. Mauro, 

10 please.

11 DR. MAURO: Sorry, I'm sorry. I 

12 know a lot of attention, a lot of discussion 

13 was directed toward how do you deal with some 

14 of these more complex physics problems. When 

15 I looked at this thing, I said wait a minute, 

16 I have a site here, where I -- and I said this 

17 before -- where people are using radioactive 

18 sources of various sizes to do non-destructive 

19 testing, and that went on for ten years, from 

20 '53 to '64 without any film badges, and we 

21 don't have a record of incident reports. 

22 We don't have anything. We have 
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1 nothing. That's what I'm hearing. We have 

2 nothing. What we do know, for ten years 

3 people are working out there in a setting 

4 where non-destructive testing of radioactive 

5 source is going on.

6 I have to tell you something. I 

7 don't need to hear any more. You can't 

8 reconstruct doses. I mean I'm sorry to say it 

9 so blatantly, but I've never seen a situation 

10 like this. 

11 Could you imagine working for ten 

12 years in a place that's handling these large 

13 sources, doing non-destructive testing, which 

14 is historically known to be a place where it's 

15 not uncommon for a source to be stuck in an 

16 open position, where people, where you may put 

17 up a boundary and people cross the boundary? 

18 It could be done under highly controlled 

19 conditions or in less than controlled 

20 conditions.

21 The whole business of non22 destructive testing using sources is filled 
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1 with these stories, and not to even have film 

2 badges on the workers, that's where the 

3 problem lies. So I mean we'll work out our 

4 differences on the betatron. I have no doubt 

5 about that. 

6 But I don't know. What do you do 

7 when you have ten years of people working in 

8 non-destructive testing and then you don't 

9 have any film badge record?

10 DR. ANIGSTEIN: And even if they 

11 get -- even if they dig up the film badge 

12 records, I mean I'm just speculating here, the 

13 very first set of film badge records that we 

14 do have are the first few weeks of 1964, and 

15 it goes back to the last six weeks of '63. We 

16 don't have the records, but we know it starts 

17 out with Badge No. 7 in the first week of 

18 January.

19 That's a handful of people. 

20 That's 18 people. So it seems unlikely -- or 

21 maybe 17. But it seems unlikely that the 

22 earlier years, there would have been more. So 
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1 we're, again, talking about plants with 

2 thousands of workers, and a minuscule 

3 fraction, true, those that are considered to 

4 be at highest risk.

5 But here, we have, again, 

6 incidents to people who even if we dig up the 

7 film badge records from those days, to -- film 

8 badge records from those people because they 

9 were not badged. They were not considered 

10 radiation workers, and -- as John pointed out.

11 Then the idea that this: .72 mR 

12 per hour is assigned based on that the only 

13 radiation -- I mean, the model -- in Appendix 

14 BB the only radiation source is the betatron, 

15 and the only exposure to the non-radiation 

16 workers is the highest skyshine dose from the 

17 betatron, which is calculated at .72 mR per 

18 hour.

19 That simply does not apply when 

20 you have these sources out in the open, with 

21 perhaps the tape, you know, a rope around 

22 them, a roped off area, where we have now, 
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1 again, anecdotal reports of a building that --

2 a cinder block structure in Building 6, and as 

3 I said, the workers would actually -- we don't 

4 know exactly how high that wall is, but --

5 they would stand on tiptoe or jump up because 

6 they were curious to see what was going on 

7 inside.

8 Again, these were non-radiation 

9 workers. Radiation workers probably would 

10 have known better. So that particular dose 

11 assignment just, to my mind just does not seem 

12 that it's -- sure, you can assign the same 

13 thing to the manager's secretary that never 

14 sets foot inside the plant, and that's 

15 probably overkill.

16 But on the other hand, that -- I 

17 mean I saw a dose reconstruction of one of the 

18 cases I reviewed, where because he was 

19 considered a maintenance man, I mean, again, 

20 the deceased worker, his daughter, I think, 

21 filed a claim, and it says well, he was a 

22 maintenance man. He worked all over the 
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1 plant.

2 So therefore, he was not assigned 

3 the radiation workers' dose, but the 

4 maintenance man could have been repairing the 

5 machinery on top of the betatron building; he 

6 could have been repairing cranes or working or 

7 operating cranes. 

8 It's a very, very nebulous 

9 situation. So that's -- I'm just elaborating 

10 on what John said.

11 CHAIRMAN ZIEMER: You know, you've 

12 got to think about some reasonableness, too. 

13 For example, there's nobody that's going to be 

14 jumping up ten hours a day for a year looking 

15 over a fence. They might do that for a couple 

16 of minutes out of their whole work year. But 

17 I can't get too excited about that.

18 Now if they're working up on the 

19 rooftop every time that source is out, that's 

20 another thing. Even that's probably an 

21 extreme. So I think we have to look at the 

22 reasonableness. 
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1 But one of my questions at this 

2 point is that in light of the fact that there 

3 may be now more film badge data, which would 

4 enrich our ability to look at those years, as 

5 well as some other source issues, can we even 

6 close this at this point? Or does that need 

7 further input?

8 And in the cases you're talking 

9 about, Bob, I don't regard those as incidents. 

10 An incident is something like the guy takes 

11 the source home in his pocket. That's an 

12 incident. 

13 Or somebody has breached some kind 

14 of lead boundary, and, I mean, these cases 

15 that people have found and the folks haven't 

16 been badged, but they know it occurred because 

17 there was a specific -- I mean it's not like 

18 somebody got up to the edge and said I wonder 

19 what's going on and stepped up and looked in 

20 and that's an incident. There's no way that 

21 that's going to contribute anything, even in a 

22 high beam, of significance where they're 
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1 working.

2 So we're talking about cases where 

3 something significant, and generally, and I 

4 don't know that you can go beyond this. 

5 Generally you know though, that -- Dave, you 

6 had a comment first, right?

7 MR. ALLEN: I forgot where I was 

8 now. It was a while back.

9 CHAIRMAN ZIEMER: But I'm 

10 wondering on this particular -- the finding is 

11 lack of monitoring data. We don't know that 

12 that's going to be the case anymore. So I'm 

13 wondering if we should keep this open until we 

14 -- I mean we can sit here and discuss how you 

15 model this vacuum of information, and it may 

16 not be fruitful to even talk about it yet 

17 until we see what else is out there.

18 DR. ANIGSTEIN: I tend -- again, 

19 to repeat the comment. Lack of monitoring 

20 data, even if more data occurs, it will be for 

21 a very tiny fraction of the workers, and the 

22 large number that could have had some 
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1 incidents of exposure, there's still no 

2 monitoring data. So we have to go with the 

3 model --

4 CHAIRMAN ZIEMER: Understood, 

5 understood.

6 DR. ANIGSTEIN: But it's not a 

7 question --

8 (Simultaneous speakers.)

9 CHAIRMAN ZIEMER: -- there's a 

10 reasonableness to -- still have the monitored 

11 workers, even if somebody wandered through an 

12 area at one time, you know, you get my point. 

13 DR. ANIGSTEIN: Yes.

14 CHAIRMAN ZIEMER: I think a 

15 reasonableness. Now, true, you have to say 

16 okay, is this both reasonable and is it 

17 claimant-favorable that maybe, maybe this guy 

18 or somebody would have done this on a regular 

19 basis. I don't know. But what's reasonable 

20 to assume on those kinds of things? Jim, you 

21 have a comment?

22 DR. NETON: No. I was just going 
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1 to point out that, you know, I was just 

2 looking through the index of documents that 

3 Dr. McKeel provided us. There's a good amount 

4 of information in the 1962 time frame about 

5 their license with these sources, inspections, 

6 some non-compliances that were identified, and 

7 General Steel's response to those non8 compliance issues.

9 So I think we need to take a look 

10 at that to see, you know, how that might 

11 affect our opinion on doing the reconstruct 

12 doses in this era. There's inspection reports 

13 and surveys taken.

14 CHAIRMAN ZIEMER: Well, it 

15 certainly might inform us on this first issue. 

16 So if it's agreeable, let's just hold this 

17 open and see. I don't see any way to close 

18 this at this point with that other information 

19 hanging out there, and maybe it will inform 

20 us, maybe not. 

21 But it certainly looks like it has 

22 the potential, particularly if there's some 
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1 independent inspections, which it appears 

2 there might have been. And incidentally, I 

3 will tell you without going into detail that I 

4 did ask the individual I talked to about 

5 inspections, and he acknowledged to me that 

6 there were. 

7 That individual told me he wasn't 

8 privy to the outcomes. That is, they didn't 

9 -- he didn't get the reports. But he 

10 acknowledged that there were inspections. So 

11 we know that somebody was in there looking at 

12 that operation. That would be very helpful to 

13 --

14 DR. ANIGSTEIN: Oh, extremely.

15 DR. McKEEL: Dr. Ziemer, this is 

16 Dan McKeel.

17 CHAIRMAN ZIEMER: Yes, Dan?

18 DR. McKEEL: There is a lot of 

19 information, letters back and forth between 

20 the AEC officials who did the inspections and 

21 GSI about what they found and the responses 

22 that GSI made to indicate that they either had 
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1 or were going to correct those deficiencies.

2 The other thing about monitoring 

3 data is there is a Nuclear Consultants 

4 Corporation radiologic survey of both inside 

5 and the area around the Building 6 radiography 

6 facility including the roof by [identifying 

7 information redacted], and that's used --

8 actually, that report is included in every 

9 license up until the renewal in 1972 that 

10 actually extended to '77 and then was 

11 terminated when the plant closed in January of 

12 '74.

13 So that radiologic survey, there 

14 are two tables that give -- so that should be 

15 very helpful. That's direct information. 

16 There are more drawings of that building and 

17 distances from various work areas, and even 

18 some estimates of how many workers were in 

19 those work areas. 

20 So that's a very useful report. 

21 It gives the dimensions of the facility, which 

22 differs from the dimensions that the workers 
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1 indicated in their testimony. But I do think 

2 it's important to look at all that information 

3 and see if any of the Picker badges or the NCC 

4 badge data can be retrieved.

5 CHAIRMAN ZIEMER: Okay. Good 

6 comment, Dan, and I certainly agree with that. 

7 So we'll keep this issue open until we have a 

8 chance to dig into that new information. Just 

9 looking on the matrix, it occurs to me that 

10 Issue 2 may be somewhat similar. It's 

11 incomplete monitoring of workers from '64 to 

12 '66. 

13 So it's sort of the same question 

14 in a different time frame. So if it's agreed, 

15 we'll keep Issue 2 open as well until we get 

16 this new information. Did we confirm that 

17 Mark was back on the line after lunch?

18 MR. KATZ: We did not confirm, but 

19 we have --

20 MEMBER GRIFFON: I am. I've been 

21 on the call.

22 MR. KATZ: Okay. The numbers were 
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1 right, so I --

2 CHAIRMAN ZIEMER: Thank you, Mark. 

3 Just wanted to make sure. Let's go on to 

4 Issue 3. Issue 3 had to do with lack of 

5 documentation. Part of this was whether or 

6 not there was radiography done prior to, was 

7 it '58? Then let's see what -- NIOSH said 

8 there was no indication of radiography prior 

9 to '58. 

10 I think, SC&A, you ask about 

11 uranium work prior to '58. Again, this one 

12 has to do though with -- let me --

13 MR. ALLEN: I might be able to 

14 help you clarify --

15 CHAIRMAN ZIEMER: I'm refreshing 

16 my memory here on what this one covered. 

17 Exposure from '53 to '58 is the focus, I 

18 guess, right?

19 MR. ALLEN: We had the documents. 

20 We had the purchase orders starting in '58 

21 on, if I remember right, it was essentially 

22 man hours.
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1 DR. ANIGSTEIN: Yes, they were man 

2 hours.

3 MR. ALLEN: Of X-ray and uranium.

4 DR. ANIGSTEIN: Not man hours; 

5 hours. So that would be like they rented the 

6 facility for so many hours.

7 MR. ALLEN: So we had the purchase 

8 orders from Mallinckrodt to GSI for starting 

9 in '58 through the end of June '66, and in the 

10 Appendix, we reviewed what those hours were, 

11 and they tapered off after, I think, '64-ish. 

12 I don't remember the exact date.

13 DR. ANIGSTEIN: Yes.

14 MR. ALLEN: They started tapering 

15 down towards the end, and in the appendix we 

16 used the, I don't know if it was the '58 or --

17 we used one of those earlier higher numbers on 

18 hours, and just extended that back through the 

19 earlier years.

20 DR. ANIGSTEIN: You used the first 

21 one, the first '58 report.

22 MR. ALLEN: All the way, and 
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1 assumed they were X-raying uranium at that 

2 pace from '53 on.

3 DR. MAURO: This is a betatron 

4 issue. In other words, when do you start? 

5 What do you assume --

6 MR. ALLEN: How much uranium was 

7 worked.

8 DR. ANIGSTEIN: Well, it's a 

9 uranium exposure issue, actually, because the 

10 betatron, they got exposed whether they were 

11 doing uranium or not.

12 MR. ALLEN: Right, and part of the 

13 justification for that was it looks like the 

14 documentation, there's some from February of 

15 '58, but the purchase orders actually start 

16 March of '58, and it looks like they're 

17 restarting some process at that point. 

18 How intensive the earlier process 

19 was is not sure. But it looks like it was 

20 high and tapered off. That's why, part of why 

21 we made that assumption that it was consistent 

22 at that higher level. So to put words in your 
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1 mouth, the SC&A comment was they had no 

2 documentation to back that up essentially.

3 DR. ANIGSTEIN: No. I mean the 

4 basic point is, you know, I agree completely 

5 with what Dave said, is the period we know we 

6 have data, have the purchase orders, '58 to 

7 '66. Fifty whatever, '52 or '53, as it may 

8 turn out to be, just my opinion -- it's a 

9 black hole. I mean it's a dark age. There 

10 could have been very little; there could have 

11 been very much, and there is just no 

12 knowledge. 

13 So it's a -- so I'm saying to 

14 simply take the very first purchase order 

15 covered I think a three-month period, and 

16 simply say this is sufficiently conservative 

17 and claimant-favorable to extend it all the 

18 way back to the beginning, and if I was asked 

19 my opinion, I don't know. 

20 DR. McKEEL: Dr. Ziemer, may I 

21 make a comment?

22 CHAIRMAN ZIEMER: Yes, Dr. McKeel.
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1 DR. McKEEL: In the NRC FOIA 

2 information, starting with the first license 

3 for the small cobalt-60 sources in 1962, one 

4 of the things they do is give a biography, a 

5 little biosketch of the work history and 

6 training of each of the radiographers by name.

7 The two longest or two of the most 

8 experienced, it says in 1962 that their work 

9 experience with the 24 MeV betatron and the 

10 radium sources -- ten years. 

11 That would take that back to 

12 around 1952. There are other comments in the 

13 narrative that accompanies the licenses, where 

14 actually they say that radiography has been 

15 going on at GSI, and this is written in 1962, 

16 for the past 20 years.

17 When I saw that, I did a triple18 take, and that statement recurs several times, 

19 and that would put it back to 1942. In 

20 addition to that, there are two documents that 

21 actually do indicate that betatron work was 

22 going on at GSI as early as 1953.
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1 One of those is the original 

2 Mallinckrodt Chemical Works matrix, the NIOSH 

3 report that describes betatron slices being 

4 made at Mallinckrodt in 1953. Then there is a 

5 Mallinckrodt AEC technical report, NYO-1358, 

6 where they're describing examination of some 

7 early ingots or ingots, and they mention that 

8 three of them were examined with the Betatron. 

9 Now interestingly, they don't say 

10 with a GSI betatron. But the only way I can 

11 interpret that statement is either there was a 

12 betatron at Mallinckrodt, which nobody has 

13 heretofore identified, or they were talking 

14 about sending it over to GSI and examining it 

15 with the GSI betatron.

16 So there are those references and 

17 allusions to radiography work at GSI from '53 

18 forward, and there are a couple of comments, 

19 not fleshed out, that radiography work was 

20 going on there for 20 years. So that record 

21 is much richer by these new documents, and I 

22 really think that they should be looked at and 
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1 examined before concluding this issue.

2 CHAIRMAN ZIEMER: So this appears 

3 then to be another case where we should hold 

4 this issue open and have the opportunity to 

5 look at that new information to see what it 

6 informs us of, in terms of those earlier 

7 years. 

8 I was little surprised about the 

9 20 year thing because if you go back to '42, 

10 I'm not sure there were radiography sources 

11 available for public use in the 40s.

12 MEMBER MUNN: Not very many, and 

13 if there were, they probably were not being 

14 used in a betatron.

15 CHAIRMAN ZIEMER: Well, yes. I 

16 think he was talking about general 

17 radiography. But betatrons is --

18 DR. ANIGSTEIN: The betatron was 

19 installed in '52. That we know.

20 DR. McKEEL: No, no. I'm talking 

21 about --

22 CHAIRMAN ZIEMER: He's talking 
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1 about '42. 

2 DR. McKEEL: I'm talking about 

3 radium sources.

4 DR. ANIGSTEIN: And if they had 

5 radiography --

6 CHAIRMAN ZIEMER: They could have 

7 had radium sources.

8 DR. McKEEL: There are no radium 

9 source licenses with the material I got.

10 CHAIRMAN ZIEMER: Well, radium was 

11 not a licensed material.

12 DR. McKEEL: Okay.

13 CHAIRMAN ZIEMER: NRC did not 

14 exercise jurisdiction over radium until within 

15 the last few years actually. It was always 

16 unlicensed because it's not byproduct 

17 material, it's naturally occurring. Some 

18 states, such as Illinois, at some point 

19 exercised jurisdiction over radium. But 

20 certainly not in `42.

21 DR. McKEEL: Dr. Ziemer, the 

22 reason I think that somebody exercised control 
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1 over it was because part of the rationale in 

2 the 1962 GSI byproduct materials license 

3 application was that they had been using the 

4 radium-226 sources with the fishbowl 

5 technique, and that that had been deemed too 

6 dangerous.

7 So either NRC, you know, AEC then, 

8 or the Illinois state agencies who were 

9 overseeing them with [identifying information 

10 redacted], must have told them to stop using 

11 those radium sources.

12 CHAIRMAN ZIEMER: Yes, one other 

13 thing that occurs. If a licensee, an NRC or 

14 AEC licensee, had radium in their mix, the NRC 

15 or the AEC's limits and requirements for 

16 byproduct material were extended to the 

17 radium. That is, dose limits for workers and 

18 so on would include both.

19 But as far as licensing, the 

20 licenses themselves never covered the radium. 

21 But in the 60s, certainly the state would. 

22 I'm just saying, if -- you referred to early 
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1 radiography in the 40s -- If that was done 

2 with radium, probably it was just done, 

3 because I don't think even the state exercised 

4 jurisdiction in those days on radium. It 

5 would be very rare.

6 But no. The bottom line is here 

7 we, this is another one where we need to see 

8 this new documentation to inform this issue.

9 DR. MAURO: I'd just like to add 

10 though, it's my understanding that what makes 

11 this an AWE facility is that it received a 

12 contract to do radiography on uranium, and --

13 now there may have been commercial radiography 

14 going on at the facility before 1953. 

15 DR. McKEEL: Right.

16 DR. MAURO: So let's make sure we 

17 don't lose sight of that. It has nothing to 

18 do with this.

19 CHAIRMAN ZIEMER: Nothing to do 

20 with this.

21 MEMBER MUNN: With the AWE status.

22 CHAIRMAN ZIEMER: That's correct.
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1 DR. ANIGSTEIN: You could not do 

2 radium radiography of uranium slices.

3 CHAIRMAN ZIEMER: Right.

4 MR. RAMSPOTT: Dr. Ziemer, this is 

5 John Ramspott, if I may?

6 CHAIRMAN ZIEMER: Yes, John.

7 MR. RAMSPOTT: All this new source 

8 information, which is now confirmed black and 

9 white AEC documents, also adds a lot more 

10 importance into the badge information, where 

11 there's no badge information during this now12 proven early period, where there were a lot of 

13 sources there.

14 CHAIRMAN ZIEMER: Right. Thank 

15 you, John.

16 MR. RAMSPOTT: I wanted to call 

17 that -- and then the other thing that's pretty 

18 important about the sources, primary work at 

19 GSI in some of those earlier years was Army 

20 work, as documented by who owned the betatron, 

21 who owned, you know, the work they did for the 

22 Navy with the, I guess, Electric Boatworks.
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1 Those sources, they may have been 

2 limited, but I would think the Navy and the 

3 Army could probably get them if they wanted 

4 to. Thank you.

5 CHAIRMAN ZIEMER: Okay, thanks. 

6 So we'll keep Issue 3 open, pending the look 

7 at the new information. Issue 4 is film badge 

8 dosimetry dependence on photon energies and 

9 exposure geometry. This is a more generic 

10 issue. I do want to ask, is this issue one 

11 that is also appearing in other evaluations, 

12 John? This is not specific to GSI. 

13 DR. MAURO: A recurring theme is 

14 the adjusting factors that need to be applied, 

15 and I believe that's what this comes into, 

16 which is it's a tractable problem.

17 CHAIRMAN ZIEMER: Yes, but I'm 

18 asking whether or not this general issue is 

19 being reviewed in other procedures or TBDs? 

20 Did it come up in the Procedures Review Group?

21 MEMBER MUNN: I believe it's one 

22 of our overarching issues, is it not?
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1 DR. NETON: Well, it's an 

2 overarching issue, but we've been dealing with 

3 it on a case-specific basis. For example, we 

4 have a TIB now to account for the response of 

5 film badges to glove box operations.

6 MEMBER MUNN: Glove boxes, yes.

7 DR. NETON: And I recall a dose 

8 calculation we did for a spill of a source at 

9 Mallinckrodt, and the relation of that source 

10 term to the film badge on the torso. But it's 

11 not possible to come up with a generic 

12 solution to all these issues.

13 If you have a unique exposure 

14 geometry that can be identified, then we will 

15 accommodate it or deal with it in some way. 

16 So that's where we're at with this particular 

17 situation.

18 DR. ANIGSTEIN: Now the aspect of 

19 it that is unique to GSI, the reason it comes 

20 up here, is the particular scenario or 

21 particular exposure source where the operator 

22 primarily has his back to the betatron 
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1 apparatus after it's been shut off.

2 Incidentally, we have come up, 

3 well my colleague, Joseph Zlotnicki, came up 

4 with the first plausible explanation I got of 

5 the source of this residual radiation. With 

6 the MCMP work, we have pretty much established 

7 that it's not activation, that it's not the 

8 activation of the aluminum cone because the 

9 MCMP-X specifically models that, and it finds 

10 very little activity in the aluminum.

11 However, Joe Zlotnicki came up 

12 with the most plausible thing, and that is in 

13 the betatron, you have a 70 kV accelerating 

14 potential. 

15 The first thing that happens is 

16 the beam, the electron beam gets accelerated 

17 to 70 kV. Then the magnetic field bends it 

18 into a circle, and you have then the magnetic 

19 induction, which then continues to accelerate. 

20 So it keeps going around in a circle; the 

21 field gets stronger and stronger to exactly 

22 keep it in the center and at the same time 
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1 continue accelerating.

2 Once the beam, once the power is 

3 cut off, the magnetic field is gone, if 

4 anything it's decreasing, so it can't 

5 accelerate the electrons any more. But that 

6 70 kV potential remains due to the 

7 capacitance. That there can be, I mean this 

8 is a hypothesis, that there can still be --

9 you still have your glowing filament. Again, 

10 that does not cool off instantly.

11 So it continues and the analogy or 

12 even the parallel situation is all black and 

13 white TVs, when you turn it off, you had a 

14 glowing spot in the center that persisted for 

15 a little while. That was due to electrons 

16 continuing to be accelerated by the 

17 capacitance.

18 So if that explanation is correct, 

19 then that explains why Jack Schuetz, who 

20 reported the measurement, and I interviewed 

21 him on the telephone, and he said there was a 

22 15 mR per hour -- and it persisted, but he 
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1 didn't say how long it persisted. He simply 

2 said in 15 minutes it was gone. So he didn't, 

3 you know, I don't have a time curve on it.

4 But I asked him, well, what about 

5 the shape? I assumed that it was a 

6 radioactive, short-lived radioactive source, 

7 in which case the radiation would be 

8 isotropic. He said no, it followed the same 

9 contour as the original beam.

10 So I said well, did you have the 

11 collimators in place, which of course wouldn't 

12 give you a narrow beam. He said no, the door 

13 -- when he made that measurement, the doors, 

14 as he called them, were open. Well, this 

15 would confirm it. 

16 This was still not, you know, 

17 basically an X-ray beam, not a radioactive 

18 source, and furthermore, in terms of the 

19 energy -- it's a 70 kV, not keV, but a 70 kV 

20 source, which would put most of the electron 

21 energies in the tens of -- I mean most of the 

22 photon energies in the tens of keV, and the 
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1 observation I made by simply inspecting a 

2 relevant table in ICRP 74, is that when you 

3 get down to 50 keV, the attenuation is such 

4 that it's only one percent. In other words, 

5 that there would be ratio between the PA and 

6 the AP exposure is .01. No, point -- yes, 

7 .01. 

8 So it would explain why the film 

9 badge readings were low and there could still 

10 be exposure from the source. Now I don't mean 

11 that it's happened, but it just indicates the 

12 possibility.

13 DR. NETON: Well, the attenuation 

14 of 10 keV your photons is pretty severe in the 

15 body.

16 DR. ANIGSTEIN: I said 50. I said 

17 50 and below.

18 DR. NETON: I thought you said 10 

19 to 20.

20 DR. ANIGSTEIN: No, no. 

21 DR. NETON: At 70 keV potential, 

22 it's going to be less than -- well, a third of 
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1 that probably.

2 DR. ANIGSTEIN: Well, the 

3 majority, but there's -- you still, you know, 

4 you get a curve.

5 DR. NETON: My point is when you 

6 get down to 20 keV, the half value thickness 

7 in the body, the attenuation is about five 

8 millimeters. 

9 DR. ANIGSTEIN: I know.

10 DR. NETON: But you're not going 

11 to get much internal organ. The worst case 

12 would be skin dose calculations.

13 DR. ANIGSTEIN: Yes, you would get 

14 a skin dose.

15 (Simultaneous speakers.)

16 DR. ANIGSTEIN: 30, 40, 50 kV, 

17 keV, you would get some dose because a typical 

18 metal -- I mean 70 kVp is a medical X-ray 

19 machine. You certainly get dose from that.

20 DR. NETON: Yes, it's more 120.

21 DR. ANIGSTEIN: Well, I remember 

22 there being --
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1 MEMBER POSTON: Mammography is 

2 down in 20 to 30 range.

3 DR. ANIGSTEIN: Pardon?

4 MEMBER POSTON: Mammography is 

5 down in the 20 to 30 range, and I don't know 

6 that there's many machines that run at 70.

7 DR. ANIGSTEIN: Today? I think 

8 there were at one time.

9 CHAIRMAN ZIEMER: Well, look. In 

10 an X-ray machine, you still have to take that 

11 beam out a window.

12 DR. ANIGSTEIN: Sure.

13 CHAIRMAN ZIEMER: You're talking 

14 about beams coming out that are hitting the 

15 sides of the generating device, I assume.

16 DR. ANIGSTEIN: No, no. I'm 

17 talking about a beam that follows the same --

18 CHAIRMAN ZIEMER: It's only on the 

19 straightaway.

20 DR. ANIGSTEIN: Yes. It passes --

21 the only thing it passes through is the --

22 yes. There will be the cone there. It will 
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1 pass through the ceramic, you know, the 

2 fraction, I forget how many millimeters is the 

3 thickness of the ceramic. But the point is, 

4 the beam was measured. I mean, he made the 

5 measurement of 15 mR per hour. 

6 CHAIRMAN ZIEMER: At?

7 DR. ANIGSTEIN: Six feet.

8 CHAIRMAN ZIEMER: At six feet.

9 DR. ANIGSTEIN: Right. That's the 

10 measurement he made. He ran out about five 

11 seconds -- he was deliberately doing it. He 

12 did the experiment for his own protection. He 

13 wanted to --

14 CHAIRMAN ZIEMER: Well see, I'm 

15 thinking it's a highly-filtered beam that's 

16 coming out of the sides, which means it's 

17 closer to 70 than it is to a regular X-ray 

18 beam. You're down about a third of the peak 

19 value. 

20 DR. ANIGSTEIN: Yes, sure.

21 CHAIRMAN ZIEMER: But on leakage 

22 radiation, which is out the side of the tube, 
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1 which this would be like you're very close, 

2 the soft stuff all gets filtered out. This 

3 should be more like a -- beam, which if you 

4 took a 70 kilovolt beam straight through, 

5 you're not going to have that 100 to 1. In 

6 fact, the front end detection would be much 

7 closer to the back. I don't think you're 

8 going to get a 100 to 1 difference.

9 DR. ANIGSTEIN: Yes. No the 100 

10 to 1 is for 50 keV. 

11 CHAIRMAN ZIEMER: The 50 keV 

12 spectrum. I'm saying --

13 DR. ANIGSTEIN: No, no. 50 keV 

14 monochromatic. This is the ICRP or the --

15 CHAIRMAN ZIEMER: Monochromatic?

16 DR. ANIGSTEIN: In ICRP 74, 50 keV 

17 monochromatic gives you .01 for 180 degrees.

18 CHAIRMAN ZIEMER: Okay. What does 

19 it give you for 70?

20 DR. ANIGSTEIN: I don't have the 

21 table in front of me.

22 CHAIRMAN ZIEMER: All I'm saying 
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1 is --

2 DR. ANIGSTEIN: Not much more in 

3 percent.

4 CHAIRMAN ZIEMER: Well, I don't 

5 know.

6 DR. ANIGSTEIN: Below 50 is 

7 essentially zero because it's rounded off to 

8 two decimal places. All I'm saying is it 

9 would explain why there could still be some 

10 significant exposure that did not show up on 

11 the film badge because there's no question 

12 that the betatron workers did go out there.

13 Maybe they didn't exactly break 

14 their ankle running, but I mean they certainly 

15 went out there at a fast clip because they 

16 were under pressure to get it going and start 

17 the next run. So it's simply --

18 CHAIRMAN ZIEMER: Well, what do we 

19 need to do with this?

20 DR. NETON: Well, so we -- our 

21 model doses are very high compared to what --

22 DR. ANIGSTEIN: That's okay. Not 
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1 to use the -- I was -- you can't use the film 

2 badge doses to model the whole body dose 

3 exposure of this particular configuration. 

4 DR. NETON: Well, they could 

5 certainly model it, use the model component --

6 as the dose, and then you have this residual 

7 15 mR per hour issue to deal with. I guess we 

8 will take that under consideration when we 

9 model the film badges, when we use the film 

10 badge data to model exposures.

11 MR. RAMSPOTT: Dr. Ziemer?

12 CHAIRMAN ZIEMER: Yes.

13 MR. RAMSPOTT: This is John 

14 Ramspott again.

15 CHAIRMAN ZIEMER: Yes, John.

16 MR. RAMSPOTT: Dr. Anigstein makes 

17 a really actually it's a pretty incredible 

18 acknowledgment of a fact I don't think any of 

19 us have heard. But I think the crux of this 

20 conversation originally was headed towards the 

21 geometry, and I hope that doesn't get lost 

22 because this betatron is to the workers' back. 
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1 The activated casting or the uranium is to 

2 his front. The difference between this and a 

3 lot of other geometry issues is there are two 

4 sources of radiation at the same time.

5 CHAIRMAN ZIEMER: Right.

6 MR. RAMSPOTT: And that really, I 

7 would think that would cause a problem for 

8 film badge reading. The badge is on the 

9 front, not on the back. So you really do have 

10 two sources. Not one, not somebody just 

11 spinning, you get part of the time. He's 

12 getting hit all the time by two sources. 

13 CHAIRMAN ZIEMER: Well, it sounds 

14 like the one source attenuates away pretty 

15 rapidly, unless they're only in there briefly.

16 DR. MAURO: Well --

17 MR. RAMSPOTT: Well, they are only 

18 in there briefly. They say the set-up time 

19 was 15 minutes, I think is what the workers 

20 said, and I think that's in Dr. Anigstein's 

21 report. I think they were at the casting in 

22 five seconds, if I read the report right. 
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1 So if they're in there 15 minutes, 

2 and that beam or that betatron is only 

3 activated or that new beam that we're hearing 

4 about now is there for 15 minutes, it's there 

5 the whole time the guys are in the --

6 CHAIRMAN ZIEMER: I would be 

7 surprised if it's more than even a minute, 

8 just like the spot on your TV. 

9 DR. ANIGSTEIN: We assumed, John, 

10 we assumed that based on Jack Schuetz's 

11 information --

12 MR. RAMSPOTT: That's what I was 

13 listening to.

14 DR. ANIGSTEIN: -- 15 mR, you 

15 know, at five seconds, and then it's 

16 essentially nothing at 15 minutes. So I 

17 assume the nothing is like background, which 

18 is a few microwatts -- thousandths of an mR. 

19 So it goes away with a half life of about a 

20 minute. 

21 So by 15 minutes, it's all gone. 

22 It's not a 15 minute steady exposure. This is 
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1 completely modeled, we integrated under the 

2 curve. But actually, in terms of the exposure 

3 during radiography of steel, not uranium but 

4 steel, the, what I call here mistakenly, or 

5 maybe not mistakenly or at least possibly 

6 mistakenly, the exposure to the doughnut, that 

7 accounts for over half the total exposure.

8 MR. RAMSPOTT: Yes, because --

9 DR. ANIGSTEIN: Because the 

10 control room doesn't get that much, and the 

11 metal doesn't get that much. 

12 MR. DUTKO: Dr. Ziemer?

13 CHAIRMAN ZIEMER: Yes.

14 MR. DUTKO: One comment please?

15 CHAIRMAN ZIEMER: Yes. John 

16 Dutco, I believe. Dutko rather.

17 MR. DUTKO: When we showed up a 

18 six foot shot with either betatron, I'd like 

19 to point out that the six foot was from the 

20 cone to the film, minus the thickness of the 

21 casting. Now if you had a casting that was 16 

22 inches thick, look how close that cone was to 
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1 us. 

2 CHAIRMAN ZIEMER: Okay, thank you.

3 MEMBER MUNN: And one cannot make 

4 the assumption that the reduction in radiation 

5 is linear from that five second to 15 --

6 DR. ANIGSTEIN: No, I said it was 

7 exponential. That's what I assumed, yes.

8 DR. MAURO: The reason I find this 

9 is important is for the longest time, when we 

10 were running -- both of us were running our 

11 MCMP, we're saying, but we're not getting this 

12 15 millirem per hour number. Where's that 

13 coming from? So we believed it, because 

14 someone went out there and measured it. You 

15 couldn't ignore them. 

16 But it sure wasn't coming out of 

17 our runs. But now, this at least what this 

18 does is it says, hmm, I think we've got an 

19 answer to why, you know, this was experienced.

20 Now I see -- and then now the 

21 issue, now so that's step one. That's very 

22 satisfying, that we think we have a reason why 
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1 that was observed. The other part has to do 

2 with this geometry issue. 

3 Now you know, I know that NIOSH is 

4 depending heavily on the post-64 film badge 

5 record as being confirmatory, that gee, look 

6 at the records we do have; the numbers are 

7 really low, nowhere near the six rem that you 

8 were ready to assign to these folks that were 

9 doing the work.

10 The only point being made here is 

11 that yes, what was observed was low, but that 

12 doesn't -- but it could very well, as many of 

13 them at zero. But that's the point being 

14 made. It's very possible that the 15 millirem 

15 per hour dose rate really never made it to the 

16 film badge, you know. It might have been 

17 attenuated by a body.

18 So what I'm getting at is that I 

19 consider all these to be tractable issues. In 

20 other words, these are issues where the 

21 physicists could sit down and come to some 

22 consensus on what's a reasonable set of 
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1 assumptions to model distances, attenuation, 

2 energy distributions, et cetera, et cetera.

3 These in my opinion, in my opinion 

4 are not SEC issues. These are tractable. And 

5 so I mean I think it's so important that we 

6 could spend a lot of concern over what I 

7 consider Site Profile issues. It's the film, 

8 lack of film badge data in those ten years 

9 that really is the place that gets my 

10 attention.

11 Everything else we can talk about, 

12 and we'll work that out. 

13 CHAIRMAN ZIEMER: But this is not 

14 in your SEC findings. Let me point out, just 

15 a quick calculation. So a 15 mR per hour 

16 beam, if it lasted a minute, you've got a 

17 quarter of an mRper run.

18 DR. ANIGSTEIN: Well, the actual 

19 calculation integrating under the curve is 

20 that I got -- okay. If there were entirely 

21 short exposures, which are five. I think 

22 they're defined as five-minute exposures, they 
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1 got 34-1/2 mR per shift, going in and out.

2 CHAIRMAN ZIEMER: From this?

3 DR. ANIGSTEIN: Just from that 

4 component.

5 CHAIRMAN ZIEMER: You're assuming 

6 exponential --

7 DR. ANIGSTEIN: Yes, I'm assuming 

8 exponential.

9 CHAIRMAN ZIEMER: But you have no 

10 evidence for that.

11 DR. MAURO: We don't know that 

12 yet.

13 DR. ANIGSTEIN: Oh, I'm just 

14 saying --

15 CHAIRMAN ZIEMER: You don't know 

16 whether it's 15 minutes or one minute. He's 

17 got one point here, one point there.

18 DR. ANIGSTEIN: That's correct, 

19 and I'm thinking the claimant-favorable 

20 assumption --

21 CHAIRMAN ZIEMER: Is that a 

22 reasonable --
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1 DR. ANIGSTEIN: That it was 

2 background, that after 15 minutes it was down 

3 to background.

4 CHAIRMAN ZIEMER: Well, you know, 

5 when you turn off, you made the analogy with 

6 the TV set. When you turn it off, that spot's 

7 not there 15 minutes. It's not there one 

8 minute. You see it for a few seconds. I mean 

9 --

10 (Simultaneous speakers.)

11 DR. MAURO: It may turn out that 

12 those are overestimates. We'll debate on that 

13 --

14 CHAIRMAN ZIEMER: All right.

15 DR. ANIGSTEIN: But I mean, we 

16 don't know what the -- is. As a matter of 

17 fact --

18 CHAIRMAN ZIEMER: Well even that's 

19 a tractable issue. 

20 DR. MAURO: Yes, it is tractable.

21 DR. ANIGSTEIN: If you can find 

22 the --
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1 CHAIRMAN ZIEMER: If we can find 

2 how fast those things bled off, that would 

3 tell you right there.

4 (Simultaneous speakers.)

5 DR. ANIGSTEIN: Yes, okay.

6 CHAIRMAN ZIEMER: Well, in any 

7 event, I guess I need to know where we're 

8 going to go with this.

9 DR. NETON: Well, we've seen this 

10 analysis that was done on the hypothesis of 

11 the source of this 15 mRper hour field?

12 DR. ANIGSTEIN: No, this just came 

13 up.

14 DR. NETON: I think we'd like to -

15 - I assume you're going to put together a 

16 document on this --

17 DR. ANIGSTEIN: Well, we really 

18 can't until we've done, unless we've actually 

19 studied the wiring diagram, to see --

20 CHAIRMAN ZIEMER: I guess we're 

21 going to take the worse case, and say okay, we 

22 have a 15-minute point that we have the 
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1 initial, all right. If you want to assume 

2 exponential, what's worse case?

3 DR. NETON: Well, but by my 

4 calculation that comes out to like 6 rem per 

5 year or something, which I think is probably 

6 pretty high. It was 33 millirem per shift.

7 DR. ANIGSTEIN: But that's just 

8 for the short run. It's a mixture of the --

9 (Simultaneous speakers.)

10 DR. ANIGSTEIN: Well, it probably 

11 will be about, eyeballing, it may be about 25 

12 per shift, 25 millirem per shift. 

13 DR. NETON: Well, you can 

14 extrapolate upwards of a five-rem-per-year 

15 exposure.

16 DR. ANIGSTEIN: Yes. Well, we got 

17 -- we ended up with 13.6 rems per year, and 

18 this was a major component of that dose. 

19 DR. NETON: Well, we're almost 

20 back to square one. If we came up with six 

21 and you took that component out, because 

22 you've got the film badge data to demonstrate 
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1 --

2 DR. ANIGSTEIN: But your six is 

3 based almost entirely on exposure to the 

4 uranium, where there was an error of 20 in 

5 calculating the dose rates from the uranium. 

6 So if you took that out, you're down to about 

7 one or two.

8 DR. NETON: Well my point is, if 

9 you have film badge data that shows it's zero, 

10 the component from the betatron itself that 

11 we've modeled -- well, you have real data 

12 showing that the betatron dose is very low. 

13 Then you're left with this residual component 

14 that needs to be modeled somehow, and you've 

15 taken a shot at it. We'd like to see your 

16 analysis of the source of that.

17 DR. ANIGSTEIN: The analysis is 

18 right in here.

19 DR. NETON: No, no, no. I 

20 understand the arithmetic. I'm talking about 

21 the mechanism.

22 DR. ANIGSTEIN: The mechanism is 
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1 just a hypothesis.

2 DR. NETON: Right.

3 (Simultaneous speakers.)

4 DR. MAURO: Remember though, this 

5 is a measurement someone made, and we're 

6 taking that -- correct. All that really 

7 happened here is ahh, this might be the reason 

8 for that.

9 DR. NETON: But I mean we've heard 

10 it verbally here, not in writing and you know, 

11 string it together so we can look at it and 

12 think about it.

13 DR. ANIGSTEIN: I can write a memo 

14 on it, but it won't be an analysis, because 

15 there's no more analysis than I've already 

16 done.

17 MEMBER MUNN: Well yes, but for 

18 all of our sakes, if we don't have the 

19 information that you have in written form 

20 somewhere, then we're never going to think 

21 about --

22 (Simultaneous speakers.)
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1 CHAIRMAN ZIEMER: Well, but at 

2 least it's a final number.

3 DR. ANIGSTEIN: But those are in 

4 here. The number won't change. We've just 

5 postulated a new explanation for this. This 

6 was -- the calculation we did was purely 

7 phenomenological. This is what was reported. 

8 This is what was measured, and we just took 

9 it and did a time integration and a distance 

10 integration, because this was at six feet, but 

11 the worker is not necessarily at six feet 

12 because the casting is at six feet. But the 

13 worker moves back and forth between that.

14 CHAIRMAN ZIEMER: And this is 

15 depicted as a skin dose or a deep dose?

16 DR. ANIGSTEIN: No, a deep dose. 

17 The 15 mR per hour was measured with a 

18 Victoreen chamber, heavily with a big plastic 

19 shield around it to get equilibrium, and it 

20 was meant for that -- that Victoreen chamber 

21 was used to measure the 25 MeV, the exposure 

22 rate from the 25 MeV for a beta run. They 
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1 didn't set up a special one for this. 

2 So I believe he used the same one, 

3 the Victoreen chamber, and then they had added 

4 a very big plexiglass shield to it, to get --

5 so you can get electronic equilibrium, because 

6 you wouldn't get it otherwise. So they 

7 measured it at six feet, and we said the 

8 worker may be going back and forth. 

9 But for the short shots, where 

10 they measure the heavy casting, the casting 

11 itself is at six feet so the worker can't be 

12 at six feet. So I'd say the worker is maybe 

13 at three feet, or the casting for the lighter, 

14 thinner casting, for the casting it at nine 

15 feet, we said well, the guy goes back and 

16 forth between three and six feet.

17 CHAIRMAN ZIEMER: This is a 

18 Victoreen R-meter here?

19 DR. ANIGSTEIN: Pardon?

20 CHAIRMAN ZIEMER: Was it a 

21 Victoreen R-meter here that was used? Or what 

22 was used?
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1 DR. ANIGSTEIN: Yes. No, a 

2 Victoreen ionization chamber.

3 CHAIRMAN ZIEMER: Oh, okay. 

4 That's what they call it in -- the R-meter. 

5 They're using a fixed equilibrium. 

6 I mean you don't use the same equilibrium 

7 chamber for kilovolts as you would for cobalt.

8 DR. ANIGSTEIN: That is entirely 

9 correct, and I'm just assuming that this 

10 person used the same set-up that they normally 

11 use to calibrate the beam and to calibrate the 

12 tubes. And the -- it was just a simple 

13 experiment he did to convince him, because he 

14 was told, you have to -- you can't go out 

15 there. You have to wait so many minutes 

16 before you're allowed to go in there, and he 

17 said, I don't want to waste the time. I want 

18 to get out there sooner.

19 So he went in and took this 

20 measurement, purely for his own protection, 

21 and he convinced himself that that's low 

22 enough, he's not going to worry about it.
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1 MR. RAMSPOTT: Dr. Ziemer?

2 CHAIRMAN ZIEMER: Yes.

3 MR. RAMSPOTT: This is John 

4 Ramspott. Dr. Anigstein, the gentleman you're 

5 talking about, Jack Schuetz, he was the 

6 technical manager for Allis-Chalmers' Company, 

7 was he not?

8 DR. ANIGSTEIN: I believe he was 

9 the service -- he was simply the service 

10 manager.

11 MR. RAMSPOTT: Yes, John was that. 

12 He definitely was not just the ordinary Joe. 

13 He was the man, and I think NIOSH contracted 

14 him for some information. 

15 DR. ANIGSTEIN: That is correct.

16 MR. RAMSPOTT: Okay.

17 DR. ANIGSTEIN: He's the only 

18 person they had that was left. 

19 MR. RAMSPOTT: Okay. He was 

20 definitely an expert.

21 DR. ANIGSTEIN: Yes. Well, okay. 

22 MEMBER POSTON: But I would like 
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1 to see something in writing, because we've had 

2 a lot of hand-waving and back and forth, and I 

3 think in order to understand this, we're going 

4 to have to look at it --

5 (Simultaneous speakers.)

6 DR. MAURO: It's part of the 

7 record.

8 DR. ANIGSTEIN: It's in our review 

9 of Appendix BB.

10 DR. MAURO: There's an explanation 

11 on now we think we have a reason why.

12 DR. ANIGSTEIN: Well now we have 

13 an explanation, I can --

14 DR. MAURO: Sure.

15 CHAIRMAN ZIEMER: If you wouldn't 

16 mind taking a look at the 15 number.

17 I'm just wondering and, Jim, you 

18 can give me your opinion on this, but if it 

19 really was like a 70 kilovolt spectrum with a 

20 heavy equilibrium chamber, I'm wondering how 

21 that would perturb the beam. It seems to me 

22 they may be underestimating that number.
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1 DR. NETON: That's a very good 

2 point.

3 CHAIRMAN ZIEMER: You could look 

4 at that. I think you could probably look --

5 DR. ANIGSTEIN: And we could model 

6 that. We could model that.

7 CHAIRMAN ZIEMER: -- to find out 

8 how far you're off if you use the wrong 

9 equilibrium chamber. Because if he's using 

10 what one used for the beam --

11 DR. ANIGSTEIN: Yes.

12 CHAIRMAN ZIEMER: You're talking 

13 about a very normal situation.

14 MEMBER POSTON: Yes, yes. Well, 

15 there are tables that tell you which to use 

16 with which detector, which equilibrium field 

17 to use.

18 DR. NETON: I also think it would 

19 be good to have a discussion, because the 

20 energy spectrum is sort of critical here, and 

21 your mechanism that you've come up with sort 

22 of postulates why this is a very low-energy 
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1 spectrum. So I think we need to think about 

2 that.

3 (Simultaneous speakers.)

4 CHAIRMAN ZIEMER: If this is 

5 scattered off the sides of the chamber and not 

6 coming out a window --

7 DR. ANIGSTEIN: No, it wouldn't be 

8 scattered off the sides, because it's --

9 CHAIRMAN ZIEMER: Well, that's 

10 straightforward, but then you have the whole 

11 rest of the thing. It must be --

12 DR. ANIGSTEIN: No, no. I mean 

13 you will have your -- you have your source. 

14 You have your filament and you have your 

15 anode, and they're in the direction, I 

16 believe, from what I recall, they're in -- I 

17 don't have my entire notebook here, but --

18 CHAIRMAN ZIEMER: But when the 

19 thing's operating, your magnetic field --

20 DR. ANIGSTEIN: But that's a 

21 normal operation.

22 CHAIRMAN ZIEMER: --keeping the 
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1 beam from hitting the sides. So when that 

2 comes off --

3 DR. ANIGSTEIN: Not entirely. If 

4 the beam never hit the side, it would never 

5 get out. So you have a deflecting voltage.

6 CHAIRMAN ZIEMER: Well, at some 

7 point.

8 DR. ANIGSTEIN: Yes, at this 

9 point, that allows that --

10 CHAIRMAN ZIEMER: But I think at 

11 this point --

12 DR. ANIGSTEIN: No, I'm sorry. 

13 I'm sorry. Forgive me, that was stupid. The 

14 electron beam keeps going in a circle. It 

15 hits the platinum target and you have a very 

16 strong forward -- x-ray have a very -- that 

17 energy has a very, very strong forward peak.

18 CHAIRMAN ZIEMER: But what's the 

19 70 kilovolt?

20 DR. ANIGSTEIN: The 70 kilovolts 

21 is the initial accelerating voltage.

22 CHAIRMAN ZIEMER: Right. 
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1 DR. ANIGSTEIN: Which is linear.

2 CHAIRMAN ZIEMER: But the magnetic 

3 field's been turned off, right?

4 DR. ANIGSTEIN: The other field's 

5 been turned off at this point.

6 CHAIRMAN ZIEMER: Then you can't 

7 have anything going in the --

8 DR. ANIGSTEIN: We don't have 

9 anything going around. I'm just saying --

10 CHAIRMAN ZIEMER: Well then it 

11 can't go out the exit.

12 DR. ANIGSTEIN: Yes, it can, the 

13 x-ray beam, not the electron. The x-ray beam 

14 is still hitting, can still be hitting the 

15 platinum target. I mean the electron beam is 

16 accelerated to 70 kilovolts. It's hitting 

17 something.

18 CHAIRMAN ZIEMER: That's what I'm 

19 saying. I'm wondering if it's hitting --

20 well, you know what I'm saying, John.

21 DR. MAURO: Yes, I do.

22 (Simultaneous speakers.)
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1 CHAIRMAN ZIEMER: If it's hitting 

2 the side and coming out, it will produce 

3 bremsstrahlung.

4 (Simultaneous speakers.)

5 CHAIRMAN ZIEMER: -- which would 

6 look more like leakage radiation in a regular 

7 x-ray, which is a very hard beam, very highly 

8 filtered.

9 DR. ANIGSTEIN: Except that Jack 

10 Schuetz again, because I questioned him on 

11 that. He said it has the same profile as the 

12 initial, as the full beam.

13 CHAIRMAN ZIEMER: Okay.

14 (Simultaneous speakers.)

15 CHAIRMAN ZIEMER: Okay. SC&A is 

16 going to provide an analysis. Thank you. Dr. 

17 Poston has to leave, I think. I'm not 

18 encouraging you to, but I know you have to 

19 catch a plane. But --

20 MEMBER POSTON: You would 

21 encourage me to have a nice Christmas, 

22 wouldn't you?
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1 DR. MAURO: Absolutely.

2 MEMBER POSTON: Everybody have a 

3 happy holidays.

4 CHAIRMAN ZIEMER: Happy holidays. 

5 Issue 5, lack of validation of models. The 

6 initial finding says that neither the film 

7 badge data nor the modeled exposures can be 

8 used to establish an upper bound of the 

9 external exposures that is claimant-favorable. 

10 DR. ANIGSTEIN: And scientifically 

11 correct.

12 CHAIRMAN ZIEMER: But this refers 

13 again to the incidents. The incidents in 

14 themselves call into question the exposure 

15 condition. But my sort of reaction at this 

16 point is similar to before. Part of that 

17 grows out of the uncertainty in the early 

18 period when there was no monitoring, I think.

19 DR. ANIGSTEIN: No. 

20 CHAIRMAN ZIEMER: No?

21 DR. ANIGSTEIN: No. This simply 

22 says that the -- it argues in the opposite 
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1 direction in a way that's saying that there 

2 seems to be no correlation between the film 

3 badge data and the models. I mean that's 

4 basically -- lack of validation. Validation 

5 means you have -- you perform a field test and 

6 see whether your model is correct.

7 And the field test, if you want to 

8 call the film badge data, the film as a field 

9 test does not validate the model. Then on the 

10 other hand, the model does not account for 

11 this exposure of 24, 70 millirem during the 

12 covered period. Nor does 75, 90 millirems in 

13 one week after the covered period, and now 

14 that we've seen the --

15 CHAIRMAN ZIEMER: Well, let me ask 

16 this question. Let's suppose you have a model 

17 for this facility, and you have a worker who's 

18 film badge showed a number that's higher than 

19 the model. What happens in dose 

20 reconstruction?

21 MR. ALLEN: We can, just as we 

22 said we did with Issue 1, we mentioned about 
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1 the individual case.

2 CHAIRMAN ZIEMER: About that 

3 individual case. So in that case, you would 

4 assign the higher dose.

5 DR. ANIGSTEIN: Yes, to that one 

6 individual. But I guess the philosophical 

7 point that I'm raising, and may not even be 

8 appropriate in this context, I'm not sure, is 

9 if we had a -- if the model was realistic. If 

10 we had a realistic model, you wouldn't expect 

11 exactly a one-to-one correspondence. 

12 But you would expect some 

13 similarity between the model exposures and the 

14 measured exposures, and there really isn't 

15 any. I have to say personally I was surprised 

16 when I saw --

17 CHAIRMAN ZIEMER: Well first of 

18 all, you would agree these two are outliers 

19 from the rest of the film badge data.

20 DR. ANIGSTEIN: Yes, they are. 

21 They are outliers.

22 CHAIRMAN ZIEMER: So --
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1 DR. MAURO: Everything else is 

2 zero. I mean there's all these zeroes, and 

3 then an occasional big one. And it --

4 (Simultaneous speakers.)

5 DR. ANIGSTEIN: And very few low 

6 in the tenth, you know, in the tens. So you 

7 get maybe a 300, and a few low ones. Most, 

8 the vast majority is M: minimal.

9 CHAIRMAN ZIEMER: Well first of 

10 all, I sort of feel like I'm defending the 

11 NIOSH thing, but I'm doing devil advocacy 

12 thing here.

13 DR. MAURO: So forget the 

14 outliers, because you only put them aside.

15 CHAIRMAN ZIEMER: Put them aside. 

16 If you have all these zeroes in the first 

17 place, even if we didn't use a model, we 

18 wouldn't accept that anyway. But you've got -

19 -

20 DR. MAURO: Missing dose.

21 CHAIRMAN ZIEMER: So the model, 

22 though, if your model says, well we know that 
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1 we weren't measuring these anyway, certain 

2 things with the film badges, whatever it might 

3 be, then you would expect that our model 

4 should be somewhere higher than whatever you 

5 would assign as a difference. The film badge 

6 data plus the missed dose, you know, all that.

7 COURT REPORTER: Gentlemen, can 

8 you come closer to the table?

9 CHAIRMAN ZIEMER: So I'm not sure 

10 you want one to one correspondence. These 

11 models generally are much more liberal. I 

12 would argue to people that the less we know 

13 about you, the better off you are, because 

14 we're going to really overestimate.

15 If we know your film badge is 

16 really correct, if somebody -- if you made the 

17 argument that we know that these film badges 

18 in this case, the energy is correct and the 

19 angularity is correct and there's no question 

20 of usage and so on, then that's the number.

21 DR. MAURO: And the regulations 

22 require that.
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1 CHAIRMAN ZIEMER: Yes. So one to 

2 one -- that doesn't surprise me so much, and 

3 to say that they don't cover a couple of 

4 outliers where we know that there's something 

5 off-normal about those, that doesn't bother me 

6 so much either. 

7 So I'm trying to get a feel for 

8 where we say, you know, how close should the 

9 model be to reality. Most of these models, I 

10 think, really overestimate things 

11 considerably.

12 DR. ANIGSTEIN: One big issue we 

13 have with the film badges, and it was brought 

14 up at a Work Group meeting oh, maybe a year 

15 and a half ago, and that is the proposed use 

16 of the film badge.

17 I don't know if NIOSH really 

18 proposes to use it that way, is to derive a 

19 log-normal distribution and use the, you know, 

20 and talk about the mean and the 95th 

21 percentile, because that is mentioned in the 

22 White Paper and is also mentioned in the SEC 
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1 Evaluation Report.

2 We did a statistical analysis of 

3 this, and showed that it simply is not valid. 

4 I mean it's something, I don't know if I 

5 should -- can people just see if I hold this 

6 up, as a -- you don't have to read. 

7 Obviously, you have to read it, 

8 but to see the shape of the curve. A log9 normal would follow this line, and it's just -

10 -

11 MEMBER MUNN: Not much of a curve.

12 DR. ANIGSTEIN: Right. It's 

13 simply not a log-normal curve. This is only 

14 in the restricted version. It's not in the PA 

15 version because it gives away too much 

16 personal dose information. 

17 So the -- it's not that the film 

18 badge data is irrelevant, but there was a 

19 proposed use of it, decide to create a 

20 distribution with a mean and a standard 

21 deviation.

22 That is only valid, such an 
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1 analysis can only be done for normal or log2 normal data. I don't know. It's never a 

3 perfectly normal or perfectly log-normal, but 

4 at least -- this is, you know, we had our 

5 statistician. Dr. Chmelynski, you know, study 

6 this. 

7 It simply did not pass the test. 

8 So it's not saying it's irrelevant, but the 

9 way the proposed use of it is something we 

10 can't agree with.

11 MR. ALLEN: Well, I would agree. 

12 I mean that graph basically shows that these 

13 are outliers, which is usually what he's 

14 saying here. They don't follow that curve.

15 I thought about it when I was 

16 putting that together, of separating this into 

17 essentially incident versus off-normal versus 

18 typical, and if you do that, you can get a 

19 frequency for how often somebody -- you get 

20 these off-normal type of events, and you can 

21 apply that frequency to everybody.

22 I mean it's only a handful --
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1 well, this is to the minor occurrence. 

2 There's only like a handful of, you know, it 

3 depends where you make the cutoffs. Say a 100 

4 millirem on a badge read. There's about seven 

5 readings, about 100 millirem through 64 to 73. 

6 But -- and they are relatively 

7 evenly spaced through the years, indicating 

8 it's not, you know, you get these kind of 

9 exposures, say once a year essentially.

10 MEMBER MUNN: When they're doing 

11 something.

12 MR. ALLEN: When they're doing 

13 something, and I mean taking that kind of a 

14 frequency and the average dose, and applying 

15 that, then removing those outliers essentially 

16 from the rest of it, you can get a better 

17 distribution. The answer ends up being pretty 

18 close to the same thing.

19 DR. ANIGSTEIN: I don't think you 

20 have any distributions, because you have 

21 something like, what was the total number? 

22 During the covered period, you have, I forget 
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1 how many thousands badge readings there were, 

2 something like 5,000. During the covered 

3 period.

4 MR. ALLEN: Almost 7,000.

5 DR. ANIGSTEIN: In the thousands. 

6 Okay. There are only 23 readings where there 

7 are numbers. There are only 20 -- of all of 

8 those two and a half years of data, covering 

9 anything from 18 to a peak of maybe 70 

10 workers, there are 23 numbers. Everything 

11 else is an M. You can create any kind of a 

12 number you want around that M for that 23 

13 number.

14 I don't, you know, leave it to 

15 question, and those 23 numbers do not follow 

16 the normal distribution. So the question is 

17 how can you construct a distribution when you 

18 only have 23 numerical values? That includes 

19 this outlier of 24, 70. It includes values of 

20 about 380, 40, 20. 

21 Oh, and of those 23, ten of them 

22 are ten, and ten is the threshold.
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1 MR. ALLEN: That is not contended.

2 DR. ANIGSTEIN: Well, but there 

3 was some --

4 (Simultaneous speakers.)

5 DR. ANIGSTEIN: Okay. And then so 

6 to take out those, you're left with ten 

7 readings. Now how can you construct -- out of 

8 ten readings, how can you construct the model 

9 and the distribution?

10 MEMBER MUNN: Now that poses an 

11 interesting philosophical and mathematic 

12 question, but in terms of reality and common 

13 sense, that would lead you to believe that you 

14 are simply dealing with an operation which had 

15 very low exposure, and in which the 

16 individuals who were exposed were extremely 

17 safe --

18 (Simultaneous speakers.)

19 DR. MAURO: And every once in a 

20 while, something happens where someone got a 

21 dose. Very rare, but it happens. What do you 

22 do with that for that ten-year period?
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1 MEMBER MUNN: And they were 

2 badged, so that you knew when those pop up.

3 DR. MAURO: Right, right. So to 

4 me, you've got -- you see, to me, I go 

5 backward again. You have ten years, nobody's 

6 wearing a badge, and you know what? Probably 

7 if your plan is to assign six rems per year --

8 , or maybe 13, whatever the number is to 

9 everybody, there's no doubt that is going to 

10 overestimate the dose to everybody.

11 MEMBER MUNN: Overestimate 

12 everybody.

13 DR. MAURO: Right, right. But the 

14 idea is there's no mechanistic relationship. 

15 There's no reasonable -- in other words, 

16 there's no reason why six makes, applies 

17 there. I mean you could --

18 DR. ANIGSTEIN: You said last 

19 meeting, pick 100.

20 DR. MAURO: Really, you could pick 

21 100. Want to pick 100 --

22 DR. NETON: Let me ask a question. 
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1 Of all these diagrams, is it possible to 

2 segregate betatron operators from general 

3 radiography operators or not?

4 DR. ANIGSTEIN: No, no. The 

5 policy was the reason they put in the badge 

6 program in the first place was to satisfy the 

7 AEC. The AEC was not concerned with the 

8 betatron, right. So they put it in. But as 

9 long as they were doing it, they gave it to 

10 the betatron operators, at least in '64. What 

11 they did before then, we don't know.

12 DR. NETON: That's my question. 

13 So you have a lot of doses are almost all non14 detects except for 20-something?

15 DR. ANIGSTEIN: Yes.

16 DR. NETON: Do we know where these 

17 20-something -- have you done a correlation 

18 with betatron operators? Do you know where, 

19 who are betatron operators to some extent, 

20 based on our --

21 DR. ANIGSTEIN: I think we know --

22 MR. ALLEN: Some people were 
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1 betatron operators. Some people were isotope 

2 operators. Many of them, we don't know. I 

3 mean what we know came primarily from the --

4 DR. NETON: Right. But I guess my 

5 question is, is there a cross-correlation we 

6 can do to show that the zeroes or the non7 detects mostly came from betatron operation, 

8 and the high values were more likely related 

9 to radiography.

10 MR. ALLEN: Not unless we could --

11 not unless the workers could identify these 

12 people, which is always a problem with the PII 

13 stuff.

14 DR. ANIGSTEIN: What about the 

15 records, these NRC records, because they 

16 apparently mentioned names.

17 DR. NETON: That's my question. 

18 If somehow one can segregate this and 

19 demonstrate that indeed, the betatron 

20 operators, at least the badges, that what was 

21 measured on their badges was very low.

22 DR. ANIGSTEIN: Well, we know that 
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1 two -- again, there was a dispute about -- you 

2 know, some people say that's not what really 

3 happened. But the two cases where there were 

4 over-exposures and the doses were subtracted, 

5 and there was documentation furnished by the 

6 workers, one by a worker, one by the worker's 

7 colleague, those exposures involved the 

8 betatron.

9 Now there was question whether 

10 maybe, you know, there is secondhand 

11 information saying no, it really wasn't the 

12 betatron. But that worker is deceased, so we 

13 didn't get anything except, you know, a 

14 secondhand account.

15 But and there were many that did 

16 both, and for instance, if I maybe I'll take 

17 the liberty of quoting John Dutko, who relayed 

18 this to me. He was a betatron operator. He 

19 was also an assistant isotope operator. 

20 CHAIRMAN ZIEMER: Well, in any 

21 event, we have a little dilemma here, but it 

22 may be another case where the additional 
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1 information will inform this to some extent.

2 DR. ANIGSTEIN: Yes.

3 CHAIRMAN ZIEMER: I would also 

4 point out that it's highly likely that the 

5 zeroes or the minimals themselves have a 

6 distribution, but it's unknown to us.

7 DR. ANIGSTEIN: Exactly.

8 CHAIRMAN ZIEMER: Between zero and 

9 ten, there's probably a distribution.

10 DR. ANIGSTEIN: Sure.

11 CHAIRMAN ZIEMER: Now you may have 

12 that distribution, and then you have these 

13 others, which are a different distribution, 

14 and in trying to combine them, you run into 

15 the -- you can't analyze them together.

16 DR. ANIGSTEIN: Yes. My point is, 

17 again, if I'm not being --

18 CHAIRMAN ZIEMER: No, no.

19 DR. ANIGSTEIN: Is not that it's 

20 are you protecting the workers, but also the 

21 mandate is to be scientifically correct.

22 CHAIRMAN ZIEMER: Okay. 
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1 MR. RAMSPOTT: Dr. Ziemer?

2 CHAIRMAN ZIEMER: Yes, sir.

3 MR. RAMSPOTT: There's another 

4 issue with this whole thing, that really needs 

5 to be brought to the forefront, that the 

6 workers did not wear their badges all the 

7 time, even they were a noted radiation badge 

8 person. As an example, managers who were 

9 badged who went in the betatron an hour a day 

10 maybe at the most, had a badge. It stayed at 

11 the office.

12 So their reading, let's say if you 

13 look at their reading for a week or for a 

14 month, and the man's only been in there one 

15 hour or four hours out of a whole month, his 

16 badge is going to look real low, but in fact 

17 he wasn't in the betatron area, yet he might 

18 have been in other areas without his badge 

19 that were hot.

20 CHAIRMAN ZIEMER: Yes, understood. 

21 And this is not unlike what we face at many 

22 sites, where workers indicate that they may 
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1 not have worn their badges all the time. If 

2 we are successful in the modeling attempt, we 

3 try to account for that in terms of these

4 overestimates, which you can't always 

5 guarantee across the board that they will 

6 cover everybody.

7 But certainly if we're 

8 conservative in that regard, that the model 

9 will try to account for that. But we 

10 recognize that that often is the case.

11 MR. RAMSPOTT: That's why the 

12 modeling doesn't match the badges.

13 CHAIRMAN ZIEMER: Well, that's one 

14 reason the modeling tends to be much higher in 

15 the model.

16 MR. RAMSPOTT: And the badges just 

17 weren't worn.

18 CHAIRMAN ZIEMER: Now are we to 

19 assume a fairly large number of hours of 

20 exposure for years with these workers?

21 MR. ALLEN: Depends on which model 

22 you're talking about. 
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1 CHAIRMAN ZIEMER: Yes, and in 

2 general that's the case. We assume a lot 

3 more.

4 MR. ALLEN: A lot more hours of 

5 operation actually occurred.

6 CHAIRMAN ZIEMER: Again, I think 

7 this, we're going to have to keep this one 

8 open and see if it's informed further by the 

9 new data. Let me see where we are. 

10 Issue 6, underestimate of external 

11 exposure of unmonitored workers. Is this very 

12 much different than the other one? It's the 

13 same issue, isn't it?

14 DR. ANIGSTEIN: No, no. These are 

15 the ones -- the other one was the issue for 

16 the period. But there was -- where we don't 

17 have data, and this is for the monitored 

18 period, but for the workers who were not given 

19 film badges.

20 CHAIRMAN ZIEMER: Right.

21 DR. ANIGSTEIN: In other words, 

22 deliberately not given film badges. Not 
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1 people who didn't wear their film badges, but 

2 we think they were never issued film badges.

3 CHAIRMAN ZIEMER: But I think in 

4 terms of the new information on source terms 

5 and so on, that could change too right, Dave?

6 DR. ANIGSTEIN: Yes. 

7 MR. ALLEN: Yes, that's possible. 

8 I took this one as meaning we didn't think it 

9 was a wise idea to have two separate models, 

10 two groups of people, radiographers and those 

11 that were associated with that, versus others 

12 like the secretaries, et cetera.

13 DR. ANIGSTEIN: Yes, and our point 

14 is that some of the people, the office 

15 personnel obviously would be a separate 

16 category, but they could be workers whose 

17 duties brought them in the vicinity, like 

18 again the use of the restroom, the use of the 

19 -- they brought them into contact with 

20 radiation sources, who were not monitored.

21 MR. ALLEN: And like Dr. Ziemer 

22 said with the new model, modeling some other 
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1 exposures we didn't know about at that time, 

2 that will obviously change the criteria for 

3 when that model applies or what groups of 

4 people that model applies to.

5 DR. NETON: We need to look at 

6 these documents that Dr. McKeel found. 

7 They're license documents, diagrams, 

8 compliance inspection reports, surveys. I 

9 mean, those kind of things we'll get something 

10 particular about the radiography operations.

11 MEMBER BEACH: Is the time period 

12 on that 53 to 63, or does it go through to 66 

13 on number six?

14 DR. ANIGSTEIN: Well, for the 

15 people who were never issued film badges, it 

16 doesn't matter which year.

17 MEMBER BEACH: It doesn't matter.

18 CHAIRMAN ZIEMER: The basis for 

19 this, there is an unmonitored group and a 

20 monitored group. 

21 MEMBER BEACH: It's the same time 

22 period, though.
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1 CHAIRMAN ZIEMER: That was the 

2 same, initially, at least. 

3 DR. ANIGSTEIN: Yes.

4 DR. MAURO: There's a group of 

5 workers that were not wearing their film 

6 badges. Whether they didn't wear them on 

7 purpose or they just weren't issued them, 

8 we've got workers without film badges, working 

9 around an area where you know that there are 

10 certain locations outside the betatron 

11 building, outside the ribbon doors, in the 

12 bathroom, on the roof.

13 There were places where people 

14 could physically be located, where the 

15 radiation fields and mR per hour could have 

16 been pretty high. Now how much time they 

17 spent there, maybe negligible. 

18 Now we also have information there 

19 were certain locations, I think it was outside 

20 the ribbon door, where people would 

21 congregate, that they may have spent some time 

22 there, and the radiation field there is pretty 
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1 high, depending on how the betatron was being 

2 operated.

3 So I mean we have locations that -

4 - where people could have been spending some 

5 period of time, where they could have gotten a 

6 substantial exposure, but they weren't wearing 

7 the film badge. 

8 MEMBER BEACH: They were not 

9 issued.

10 DR. MAURO: Or weren't issued a 

11 film badge. This all goes -- now this is 

12 within the context of the betatron. This also 

13 was in the context of the non-destructive 

14 testing of radioisotopes, which is going on 

15 also. So it applies there, too.

16 Maybe, you know, now in theory, if 

17 you have a really good health physics program, 

18 where you are controlling your radiation 

19 fields, you're making sure you're meeting your 

20 stated limits, and that's well-documented, you 

21 know, one could argue that you know no one got 

22 more than the radiation protection limits.
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1 You know, I mean if you say, okay, 

2 let's --

3 DR. ANIGSTEIN: Except when I was 

4 given information by the worker who maintained 

5 the fan on top of the building, and I 

6 specifically said, and when you had to go up 

7 there, did you communicate with the betatron 

8 operator like don't shoot, I'm up there, and 

9 he said no. 

10 He went in. He didn't go through 

11 the control room. He accessed it from the 

12 outside and there was no communication. 

13 That's firsthand testimony.

14 CHAIRMAN ZIEMER: I want to ask 

15 this question. How much is he like a betatron 

16 operator? In other words --

17 DR. ANIGSTEIN: But he's not --

18 but according to NIOSH, he's not assigned the 

19 betatron operator's dose.

20 CHAIRMAN ZIEMER: And that's why I 

21 asked the question. How much is he like a 

22 betatron operator? To argue that he was up 
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1 there every time the betatron was going --

2 DR. ANIGSTEIN: No, no.

3 CHAIRMAN ZIEMER: That's one 

4 thing. If he's up there once a year --

5 MEMBER BEACH: Which we don't 

6 know.

7 (Simultaneous speakers.)

8 MR. DUTKO: Dr. Ziemer?

9 CHAIRMAN ZIEMER: One comment.

10 MR. DUTKO: One comment on the 

11 film badge.

12 (Simultaneous speakers.)

13 CHAIRMAN ZIEMER: Hold up. Yes, 

14 go ahead.

15 MR. DUTKO: Sir, we were ordered 

16 not to wear our film badges. Probably we had 

17 100 at the peak of our department in its 

18 prime, maybe 70 percent of those people were 

19 film-badged. Magnaflux was the remaining part 

20 of the department. Magnaflux was a starting 

21 job. Those people were not issued film badges 

22 at all. 
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1 I might work eight hours in a 

2 betatron on the a.m. I was ordered to take my 

3 film badge off any time I left the betatrons, 

4 and I would work in 10 Building right outside 

5 the ribbon door, maybe on a tank hold, on the 

6 second -- on overtime on the second shift. 

7 But the reason they did not want us to wear 

8 our film badges was burning, welding, hot 

9 sparks flying all over in those areas. They 

10 were afraid of badge damages, sir.

11 CHAIRMAN ZIEMER: Yes, I 

12 understand that, and actually you would still 

13 be classified as a betatron operator.

14 MR. DUTKO: Yes, sir.

15 CHAIRMAN ZIEMER: In this model. 

16 Now we're talking about people who never were 

17 classified as betatron operators, and I'm kind 

18 of asking the question, even if there were 

19 occasional exposures to them outside the 

20 facility, do those rise to the level of saying 

21 that they deserve the same assigned dose.

22 That's a good rhetorical question 
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1 right now, but that's --

2 DR. ANIGSTEIN: But they were 

3 given the skyshine dose, which does not 

4 account for any of the exposures in the SC&A 

5 model.

6 CHAIRMAN ZIEMER: Well, I don't 

7 know if it does.

8 DR. ANIGSTEIN: Pardon?

9 CHAIRMAN ZIEMER: The only way you 

10 can answer that would be to say how often were 

11 they up there, see. You can't simply say 

12 because of the dose rate. I don't think you 

13 can argue because of a dose rate, that they 

14 ever got an annual dose.

15 We don't know. So I say if you're 

16 modeling, then you have to make some kind of 

17 assumption that this is either pretty regular 

18 or it's once a month or something. How do you 

19 distinguish?

20 DR. MAURO: I have a problem with 

21 this. You have people that were, let's say, 

22 betatron operators, and mechanistically, we 
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1 all agree here's how we're going to predict 

2 their exposures. We don't -- let's say we're 

3 pre-1964. Okay, we want to assign some dose, 

4 and we know he's a betatron operator. 

5 I'm saying right now that we could 

6 come up with a model that would say, I think 

7 that this mechanistically would place a 

8 plausible upper bound on the exposures this 

9 man might have experienced as a betatron 

10 operator, and there's a scientific basis for 

11 it.

12 But now what I'm hearing you say, 

13 Paul, though, is that well, there were other 

14 people that were out there that weren't 

15 betatron operators. But they were sort of in 

16 the vicinity where the radiation field may 

17 have been elevated, certainly above the .72 mr 

18 per hour. 

19 MEMBER BEACH: Sometimes.

20 DR. MAURO: Sometimes. So you 

21 know what we can do? We can sort of cure all 

22 things by saying well, let's give them the six 
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1 rem per year, too. But there's no mechanistic 

2 relationship there. You see, I see that as 

3 being --

4 CHAIRMAN ZIEMER: No, I'm not 

5 saying we should. I'm arguing for the fact 

6 that that maybe a different distribution 

7 should be used.

8 DR. MAURO: Yes. Oh, okay, okay. 

9 I misunderstood that. So are you saying 

10 let's just throw those in the basket?

11 CHAIRMAN ZIEMER: Oh no, no. I'm 

12 saying on that basis, would you argue that 

13 they should get the same assigned dose?

14 DR. MAURO: You couldn't, and you 

15 wouldn't know what to assign them.

16 CHAIRMAN ZIEMER: Well, you might. 

17 I mean if you could construct a reasonable --

18 (Simultaneous speakers.)

19 DR. ANIGSTEIN: It could be done, 

20 but again, my point is .72 mR per hour, it 

21 does not account for a lot of other exposure 

22 conditions. It only accounts for --
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1 CHAIRMAN ZIEMER: Maybe it depends 

2 on how long you're assigning that for. I mean 

3 I don't think you can argue that a .72 mR per 

4 hour doesn't cover a 20 mR per hour. If the 

5 .72 is, you know, a thousand hours a year and 

6 the other one was one hour.

7 DR. MAURO: So 2,400, 2,400 hours 

8 a year.

9 CHAIRMAN ZIEMER: You have to 

10 state the parameters of your model. 

11 Otherwise, dose rate is not as important as 

12 total dose.

13 DR. MAURO: I agree.

14 CHAIRMAN ZIEMER: Anyway. We're 

15 going to, on Issue 5 and 6 sir, again we'll 

16 keep those open pending further informing 

17 them. I'm wondering if Issue 7, dose 

18 reconstruction not based on the best available 

19 science, that this had to do with the 

20 irradiated uranium and the model, let's see.

21 Twenty-fold error in calculating 

22 dose rate from irradiated uranium, which they 
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1 found in the computer program. Is that, NIOSH 

2 says the comment appears to be assessing the 

3 accuracy of the dose estimate, rather than the 

4 ability to do it?

5 DR. MAURO: Right.

6 CHAIRMAN ZIEMER: So it's not --

7 DR. MAURO: It's an SEC issue.

8 CHAIRMAN ZIEMER: But it is in 

9 error. Is that being checked on, that --

10 MR. ALLEN: Yes. Santa hasn't 

11 actually found the exact place where the error 

12 is, but I don't necessarily doubt it. I kind 

13 of balked when I first saw those numbers 

14 originally, and then the rate that it decayed 

15 off. 

16 I realized well, it's possible for 

17 them to x-ray something, get that kind of dose 

18 rate, get it back and Mallinckrodt could get a 

19 more technical dose rate when it got back 

20 there. So I suppose it's possible it could 

21 happen without being caught.

22 DR. ANIGSTEIN: If he wants to get 
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1 in touch with me or with the -- we can 

2 certainly point that out to her. But she's 

3 using the files.

4 MR. ALLEN: So I mean I'm assuming 

5 that this is correct. We haven't zeroed in on 

6 --

7 (Simultaneous speakers.)

8 DR. MAURO: It's a calculation 

9 error. We can show where we think it is.

10 DR. NETON: But if we agree that 

11 this is not an SEC issue, can we take it off 

12 of this matrix? I mean this has been on here 

13 for --

14 CHAIRMAN ZIEMER: Well, I just 

15 want to agree that you'll just confirm it, and 

16 then we can close it, even if it's on the 

17 matrix.

18 DR. NETON: Yes. It should remain 

19 on the profile matrix for sure.

20 CHAIRMAN ZIEMER: Right.

21 MEMBER MUNN: You're not going to 

22 close it.
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1 DR. ANIGSTEIN: I mean, this is 

2 only one of the errors that is most notable.

3 CHAIRMAN ZIEMER: Let's just ask 

4 that it be closed. I mean, confirm that and 

5 we'll close it next time.

6 (Simultaneous speakers.)

7 DR. MAURO: I think there were a 

8 lot of places in our report that we point out 

9 differences of opinion, places where I think 

10 maybe an error was made. But these are all 

11 tractable. 

12 So I've been thinking about we, 

13 you know, the day will come when we'll deal 

14 with those. I'm more concerned about this CD 

15 we're going to get, to see what kind of -- and 

16 whether there's full badge data. Now we're 

17 where we should be. That's where the SEC is. 

18 CHAIRMAN ZIEMER: Right. Is this 

19 next one in a similar category, the 

20 underestimate of beta dose, Issue 9? 

21 DR. ANIGSTEIN: This is the 

22 Puzier. This is the Puzier effect, where I 
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1 will -- I think we will -- let's just say at 

2 this point that --

3 (Simultaneous speakers.)

4 CHAIRMAN ZIEMER: Well, it's being 

5 covered under TBD-6000.

6 DR. MAURO: Right, yes. Then as 

7 it applies specifically here, it has to do 

8 with the geometry of exposure and duration of 

9 exposure. So again, this is a tractable 

10 issue. What assumptions do you want to make 

11 regarding how much time were these folks up 

12 close and personal, to a Puzier, and get core 

13 slice? This is a tractable problem.

14 DR. ANIGSTEIN: I think, based on 

15 the offline discussion I had earlier, I don't 

16 think it applies to the Mallinckrodt data.

17 DR. MAURO: Yes, the same thing, 

18 and maybe it's not even -- maybe it's a non19 issue, if it's a fresh ingot that doesn't have 

20 any --

21 (Simultaneous speakers.)

22 DR. MAURO: That's true, too. All 
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1 of this is --

2 DR. ANIGSTEIN: I would say I 

3 think we will consider withdrawing this 

4 comment.

5 DR. MAURO: You want to withdraw?

6 MR. KATZ: You might want to 

7 explain that a little bit. I think you should 

8 explain it for the record.

9 DR. MAURO: Put that in a write10 up?

11 (Simultaneous speakers.)

12 MR. KATZ: Okay, or the write-up, 

13 whatever.

14 DR. MAURO: We have to write a 

15 second report.

16 DR. ANIGSTEIN: Oh, you mean a 

17 write-up?

18 MR. KATZ: Yes, because you didn't 

19 discuss, you know, you were discussing that in 

20 the hallway or whatever, but you didn't discus 

21 it on the record.

22 DR. ANIGSTEIN: Yes, right. Okay. 
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1 Yes. 

2 CHAIRMAN ZIEMER: So SC&A is going 

3 to give us an additional response on that.

4 DR. MAURO: We have two action 

5 items on this account. One is this 15 

6 millirem per hour issue, and the reasons we 

7 think it happened, and the second is, has to 

8 do with maybe the Puzier effect really is not 

9 in play here.

10 MR. KATZ: But there are some 

11 other issues from the TBD Site Profile review 

12 that kind of combine with that. I mean if the 

13 Puzier effect is real at certain sites, you 

14 were going to publish some new numbers.

15 DR. MAURO: The numbers go up.

16 MR. KATZ: I forget what you were 

17 going to do. But early on, I think there was 

18 a commitment on your part to provide some 

19 documentation about the Puzier.

20 DR. MAURO: Well, we can actually 

21 make that a part. In other words --

22 MR. KATZ: That's what I'm saying. 
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1 Put it in a report.

2 DR. MAURO: The doses go up and if 

3 the Puzier is real here, there are some 

4 reasons why maybe it's not, and then the 

5 Puzier goes away.

6 CHAIRMAN ZIEMER: As I understand 

7 it now, if it's fresh uranium that has been 

8 separated, it has no thorium to start with --

9 (Simultaneous speakers.)

10 DR. ANIGSTEIN: And as a matter of 

11 fact, there is justification.

12 CHAIRMAN ZIEMER: I think John or 

13 somebody asked about virgin uranium or 

14 somebody --

15 (Simultaneous speakers.)

16 DR. ANIGSTEIN: And asked about 

17 the different uraniums --

18 (Simultaneous speakers.)

19 CHAIRMAN ZIEMER: -- you may not 

20 have gotten the right answer there. Virgin, 

21 fresh uranium, freshly-separated uranium 

22 without the thorium there, you don't have the 
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1 effect.

2 DR. ANIGSTEIN: Yes, and as a 

3 matter of fact, I know --

4 CHAIRMAN ZIEMER: And anything 

5 that goes in is evenly distributed.

6 DR. ANIGSTEIN: As a matter of 

7 fact or, I now recall there was something in 

8 the Mallinckrodt TBD which said the opposite, 

9 that the dose rates are actually lower than 

10 they would be expected because the thorium 

11 wasn't there.

12 CHAIRMAN ZIEMER: Okay. We're up 

13 to Issue 10. Lack of consistency in assigning 

14 external exposures. It says, due to a 

15 calculational error, Allen and Glover assigned 

16 a disproportionately high exposure rate to 

17 workers handling uranium following 

18 radiography.

19 NIOSH said the comment appears to 

20 be discussing the accuracy of the dose 

21 estimate rather than the ability to estimate 

22 dose. So it's more appropriate to discuss it 
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1 as part of the Appendix BB. But this has to 

2 go -- do with, let's see --

3 MR. ALLEN: It's the factor of 20 

4 issue on the uranium that --

5 DR. ANIGSTEIN: That's right, one 

6 case. Then on the other hand, we disagree 

7 with steel, and we find that there is -- with 

8 the steel, there is some significant 

9 activation of the steel, because it's not pure 

10 iron. The other alloys give you longer-lived 

11 isotopes than just pure iron. So the alloys 

12 have other elements.

13 MEMBER MUNN: The alloys.

14 CHAIRMAN ZIEMER: You're talking 

15 about nickel and what else is typically in 

16 steel?

17 DR. ANIGSTEIN: Molybdenum.

18 CHAIRMAN ZIEMER: Molybdenum, 

19 that's fine.

20 DR. ANIGSTEIN: Yes.

21 CHAIRMAN ZIEMER: Is the point 

22 here those weren't considered in the 
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1 activation?

2 DR. ANIGSTEIN: They were not. I 

3 simply said well, the worst you -- in other 

4 words, they just said iron 57 is the main 

5 product. If you have less than 100 percent 

6 iron, then you'll get less iron 57, and then 

7 iron 57 does not -- is an insignificant dose, 

8 so the whole thing goes away. 

9 We took the actual alloy H180, 

10 that we were told was most commonly used, and 

11 did the details MCMP-X.

12 CHAIRMAN ZIEMER: With the 

13 activation calculation, you came up with a 

14 different dose rate.

15 DR. ANIGSTEIN: Yes.

16 MEMBER MUNN: Much higher, I would 

17 think.

18 CHAIRMAN ZIEMER: And how much 

19 higher was it?

20 DR. ANIGSTEIN: Well, we got 

21 essentially, let's see. Depending on whether 

22 -- for instance, we got about 5.9, oh, I'm 
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1 sorry. Those are hours. Not terribly high. 

2 It's a small contribution to the overall dose 

3 to the betatron operators.

4 CHAIRMAN ZIEMER: Okay. So in 

5 part, this deals with simply the accuracy of 

6 the calculation.

7 DR. ANIGSTEIN: Yes, it does, it 

8 does.

9 CHAIRMAN ZIEMER: But the actual 

10 contribution may not be significant, 

11 particularly with respect to the model itself, 

12 but --

13 MEMBER MUNN: Well, the finding 

14 itself doesn't say anything about incorrect 

15 selection of materials. We're now looking at 

16 Issue 10, right?

17 CHAIRMAN ZIEMER: Yes.

18 DR. ANIGSTEIN: Yes. Not here. 

19 We did in the main, in the review, but it was 

20 not a --

21 (Simultaneous speakers.)

22 CHAIRMAN ZIEMER: This seems to 
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1 focus on the -- well, it says exposure to the 

2 betatron --

3 (Simultaneous speakers.)

4 CHAIRMAN ZIEMER: Well, I guess on 

5 this, two things have to happen. One is, was 

6 this -- this was discussed, I guess, in the 

7 SEC Petition Evaluation Report apparently: the 

8 steel. It must have had part of bounding 

9 dose, without pulling it up to see. Do you 

10 recall, Dave?

11 MR. ALLEN: I honestly can't 

12 recall this.

13 DR. ANIGSTEIN: No, I don't 

14 believe it does. It's simply -- the SEC 

15 Evaluation Report essentially adopts the 

16 Appendix BB model.

17 CHAIRMAN ZIEMER: Okay. So this 

18 showed up in the Appendix BB model?

19 DR. ANIGSTEIN: Yes, yes.

20 CHAIRMAN ZIEMER: So but this is -

21 -

22 DR. ANIGSTEIN: But the SEC 
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1 Evaluation Report incorporates it by 

2 reference, shall we say.

3 CHAIRMAN ZIEMER: So this is kind 

4 of an Appendix BB issue.

5 DR. ANIGSTEIN: Yes, it is.

6 CHAIRMAN ZIEMER: Not a Site 

7 Profile issue.

8 (Simultaneous speakers.)

9 CHAIRMAN ZIEMER: Yes. It's not 

10 an SEC issue. So --

11 DR. ANIGSTEIN: Only in talking 

12 about the, I guess you might call it the 

13 fairness doctrine, where workers in one year 

14 get six rems and another year get one or two 

15 rems, and according to our analysis, they 

16 should be pretty much the same.

17 CHAIRMAN ZIEMER: Well, NIOSH, in 

18 their response, suggested that this be 

19 reviewed or removed from this matrix and put 

20 back into Appendix double B.

21 DR. ANIGSTEIN: Okay.

22 CHAIRMAN ZIEMER: Is there any 
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1 objection to doing that? So we'll close the 

2 issue. So we'll agree to move that to 

3 Appendix BB.

4 MEMBER BEACH: And then are we 

5 doing the same thing with nine? Is that going 

6 to 6000?

7 DR. ANIGSTEIN: Well, the nine, I 

8 think we're going to withdraw that.

9 MEMBER BEACH: Oh nine, okay, 

10 okay.

11 CHAIRMAN ZIEMER: They're going to 

12 explain their reasoning and then withdraw the 

13 issue.

14 MEMBER BEACH: Okay. I guess I 

15 wrote that on eight instead of nine. Thank 

16 you.

17 CHAIRMAN ZIEMER: Okay. That's 

18 where we are on those issues. I'm looking 

19 back here on my agenda. We want to talk about 

20 Bliss & Laughlin and we want to talk about 

21 Electro-Metallurgical. Let's take a ten22 minute break.
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1 MR. KATZ: A break, yes.

2 CHAIRMAN ZIEMER: A ten-minute 

3 break, and then we'll return and talk about 

4 Bliss & Laughlin.

5 MR. KATZ: Okay. So about quarter 

6 of, we'll start back up.

7 CHAIRMAN ZIEMER: Quarter after.

8 MR. KATZ: Quarter past, right. 

9 Quarter past.

10 MS. COGGINS: This is Pat Coggins, 

11 the petitioner.

12 CHAIRMAN ZIEMER: Yes.

13 MS. COGGINS: I wanted to clear 

14 something up that was brought up earlier, and 

15 I'm going to have to get off the conference 

16 call.

17 CHAIRMAN ZIEMER: Okay, sure. 

18 MS. COGGINS: The date of the --

19 the beginning date --

20 MR. KATZ: Would you guys stop 

21 talking?

22 MS. COGGINS: --of the petition 
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1 for the employees.

2 CHAIRMAN ZIEMER: The what? Say 

3 it again?

4 MS. COGGINS: The question about 

5 that being 52 or 53. This was before the 

6 lunch break?

7 CHAIRMAN ZIEMER: Right.

8 MS. COGGINS: Okay. I have a 

9 letter from Larry Elliott, acknowledging that 

10 he had received my petition. The original 

11 date was January 1, 1950 through January 31st, 

12 1973. This is dated February 28th, 2008 from 

13 the Department of Health and Human Services.

14 Then on the final, which is 

15 10/3/08, also signed by Larry Elliott, 39 

16 pages, and this is where the date says January 

17 1, 1953 through December 31, 1966, and the 

18 residual period from January 1, 67 through 

19 December 31st, 1992. 

20 Then NIOSH changed that in this 

21 evaluation, and they put an actual date on it, 

22 you know, from January 1, 1953 through June 
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1 30th, 1966. They had made a few changes there 

2 on it in the -- when they evaluated it. 

3 So I did want to clear that up 

4 with you, and they should have -- I can give 

5 you the SEC number if anyone needs a copy of 

6 it.

7 CHAIRMAN ZIEMER: No, I think we 

8 have the SEC.

9 MS. COGGINS: Okay. Well those 

10 are all signed by Larry Elliott, so if you 

11 need any clarification, you should be able to 

12 find it there.

13 CHAIRMAN ZIEMER: I believe, and 

14 maybe Ted, I don't know if you can clarify 

15 this. I think the dates are the ones 

16 established by Labor for that site, are they 

17 not?

18 MR. KATZ: I believe so.

19 CHAIRMAN ZIEMER: So that those 

20 could differ from your original petition. Is 

21 that what you're asking, why they differ?

22 MS. COGGINS: Yes, and I thought 
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1 that you just couldn't read my handwriting on 

2 the original one.

3 CHAIRMAN ZIEMER: No. If your 

4 petition covered a period that, under the law, 

5 is not part of the official period that has 

6 been designated by the Department of Labor as 

7 the covered period, then it would have had to 

8 have been changed. So we can only evaluate 

9 those periods that the Department of Labor has 

10 designated as covered periods.

11 MS. COGGINS: Okay, all right. I 

12 understand. Yes, you know, if you could hear

13 your conversation, it does sound like it 

14 wasn't real legible. I thought well, that 

15 sounds like my handwriting.

16 CHAIRMAN ZIEMER: I'm sure that 

17 was not the case.

18 MS. COGGINS: Okay, all right. 

19 Thank you so much.

20 CHAIRMAN ZIEMER: Thank you. 

21 We're going to take a break.

22 (Whereupon, the above-entitled 
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1 matter went off the record at 3:07 p.m. and 

2 resumed at 3:22 p.m.)

3 CHAIRMAN ZIEMER: We have on our 

4 agenda some initial look at Bliss & Laughlin 

5 Steel, and an initial look at Electro6 Metallurgical. At our full face Board meeting 

7 in October -- is that when it was, October?

8 MR. KATZ: Yes.

9 CHAIRMAN ZIEMER: Board meeting, 

10 we asked SC&A to take an initial look at the 

11 evaluation reports on those two, and that is 

12 underway. We don't have information back from 

13 them yet, but I've asked John Mauro to give us 

14 a status report.

15 I should point out on the agenda, 

16 Item 6, where I said, determine if an SC&A 

17 review is needed to clarify SEC issues, I had 

18 made a notation in my notes that we hadn't yet 

19 asked them to do that, whereas in the review 

20 of the minutes and the clarification by Ted 

21 Katz to jog the Chair's memory, we actually 

22 had already tasked them. 
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1 So they had in fact gotten 

2 underway on Bliss & Laughlin, as well as 

3 Electro-Metallurgical, which I had the correct 

4 notation on. So both of these should read 

5 status of the SC&A review and path forward. 

6 So John, first on Bliss & 

7 Laughlin, if you'd kind of tell us where you 

8 are on that and then we obviously will have to 

9 deal with some documentation once we get that. 

10 But where are you on that and can you give us 

11 any preliminary sort of heads up.

12 DR. MAURO: Both those projects 

13 have been assigned. Bill Thurber -- Bill, are 

14 you on the line?

15 MR. THURBER: I am.

16 DR. MAURO: And was Chick able to 

17 be on line? I know he might have been tied up 

18 this afternoon. 

19 MR. THURBER: I don't believe he 

20 is, John. But I can cover it.

21 DR. MAURO: Right. Could you just 

22 give us a summary of where we are on Bliss & 
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1 Laughlin and then Electro-Metallurgical.

2 MR. THURBER: Okay.

3 DR. MAURO: Thanks.

4 MR. THURBER: As you -- probably 

5 everyone knows, NIOSH has indicated that they 

6 have enough information to do bounding dose 

7 calculations for both facilities. I'm sorry. 

8 Bliss & Laughlin is, in principle, a pretty 

9 straightforward proposition. There was only a 

10 few days of uranium machining over a couple of 

11 years.

12 And we -- in our review thus far, 

13 we haven't found any substantive issues of any 

14 kind. There's a lot of minor details, that 

15 sort of thing. Probably our only concern when 

16 we wind this up is that, as is the case in 

17 several of these, we don't feel that when 

18 NIOSH says they can do a bounding dose 

19 reconstruction, that they're sufficiently 

20 prescriptive in how they would go about that.

21 I expect a lot of our comments 

22 will be in that vein. For instance, the 
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1 report on Bliss & Laughlin is silent on what 

2 you do, if anything, between the machining 

3 campaigns. These things we feel probably need 

4 to be spelled out, so that people understand 

5 how to treat it.

6 But beyond that, I don't think 

7 there's anything particular to say about Bliss 

8 & Laughlin at this time.

9 DR. MAURO: Bill, could you just 

10 give a quick description of the years, and 

11 what they were doing --

12 MR. THURBER: Well, they were 

13 doing some machining operations using a 

14 special piece of milling equipment, and the 

15 work was done in 1951 and 1952, and it was on 

16 a subcontract from Fernald. In that period, 

17 in 1951 and 1952, there were five one-day 

18 machining campaigns.

19 They do have some dust, some air 

20 sampling data available. This special machine 

21 is a machine that's made by a company named 

22 Medart, and apparently it has the ability to 
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1 turn long cylindrical shapes of uranium, to 

2 machine the surface.

3 I think I gather it kind of works 

4 more like a -- in a standard lathe, you kind 

5 of have the rod suspended from centers on each 

6 end, and it's rotated on those centers. In 

7 this kind of operation, I think it's more like 

8 a centerless grinder, where the rod kind of 

9 floats in front of the tool.

10 So that's about it, really. As I 

11 said, it was just these five days of machining 

12 over a two-year period.

13 DR. MAURO: How much air sampling 

14 data do you have?

15 MR. THURBER: Oh, probably a dozen 

16 or so samples, something like that.

17 DR. MAURO: Breathing zone and 

18 general or just general?

19 MR. THURBER: Breathing zone and 

20 general, yes. Breathing zone and general. 

21 The reliance, though, in the bounding approach 

22 is the information in TBD-6000, where they 
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1 look at the machining operations that are 

2 discussed in there, and they pick the most 

3 conservative values under the various 

4 machining operations for which there is data 

5 in TBD-6000, and that happens to be a 

6 centerless grinder, and use that as their 

7 bounding calculation.

8 DR. MAURO: So the air sampling 

9 data that's specific to this facility is a way 

10 of verifying whether --

11 MR. THURBER: It's a way of 

12 verifying and I'm pretty sure it looks 

13 conservative. But conservative in the sense 

14 that TBD-6000 gives higher values than the 

15 available air sampling data.

16 CHAIRMAN ZIEMER: Thank you, Bill. 

17 Let me ask if the petitioner is still on the 

18 line and has any questions at this time. 

19 Obviously, we are awaiting the written report 

20 from SC&A, at which time we will have -- the 

21 Work Group will have a chance to react to the 

22 findings, and discuss these issues in more 
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1 detail, as will the petitioner.

2 But is the petitioner still on the 

3 line for Bliss & Laughlin?

4 MEMBER BEACH: I believe she said 

5 she had to go when she spoke to us before the 

6 break. That's what she mentioned. 

7 DR. MAURO: Paul, I think to point 

8 out that both sites though, are put on a 

9 calendar for site visits. One of our 

10 responsibilities is to talk to workers and 

11 petitioners. So that hasn't happened yet. 

12 CHAIRMAN ZIEMER: Right.

13 MR. THURBER: And to the --

14 whether that's necessary on Bliss & Laughlin, 

15 we haven't discussed it internally, and so we 

16 don't have a position. It may not be 

17 necessary.

18 CHAIRMAN ZIEMER: Right.

19 MR. THURBER: On the other hand, 

20 there's a number of more substantive questions 

21 on ElectroMet.

22 CHAIRMAN ZIEMER: Okay. Just a 
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1 notation here. Thank you. We'll come back to 

2 ElectroMet in just a minute. Just as an 

3 oversight, and I was just reminded that I 

4 skipped over 5b on the agenda. 

5 I didn't specifically ask Dr. 

6 McKeel about his issues on the SEC petition,

7 although I had assumed that many of those were 

8 related to the newer documentation in any 

9 event.

10 But, Dan, if you're still on the 

11 line, this didn't intend to not give you the 

12 opportunity to make further comments.

13 MEMBER BEACH: Paul, I just got a 

14 note from Mark. He wants to know if we're on 

15 the line. He can't hear anything. So I just 

16 thought we'd check with him.

17 MEMBER GRIFFON: No, No. That was 

18 a while ago. Thanks, though.

19 CHAIRMAN ZIEMER: Dr. McKeel, are 

20 you --

21 DR. McKEEL: Yes sir, I am. I had 

22 a very short comment.
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1 CHAIRMAN ZIEMER: I'm sorry I 

2 didn't specifically ask you for comments on 

3 the SEC Petition Evaluation Report or the 

4 matrix, either one.

5 DR. McKEEL: Right. I had two 

6 short comments. One comment was to remind the 

7 Work Group that, before the October the 14th 

8 Work Group meeting, I submitted a rather 

9 detailed commentary, pretty much section by 

10 section on the SEC 105 Evaluation Report.

11 I would very much appreciate it if 

12 the Work Group could look at that and some of 

13 the issues definitely overlap with ones we've 

14 discussed today, and the SC&A findings matrix. 

15 But there were other issues that in 

16 particular relate to the way you bound the 

17 dose, and a different perception that I have.

18 Apparently, the way that NIOSH, 

19 and let's just say that NIOSH does the 

20 bounding doses, where if they have multiple 

21 sources, they pick the one with the highest 

22 dose, and use that as the bound for all the 
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1 other source terms.

2 In my little illustration that I 

3 put in there, it seems to me that the more 

4 proper way to do that is to make the 

5 calculation of the dose or the exposure 

6 contributed by each of the different sources, 

7 and that since doses are cumulative and many 

8 workers there could be exposed not 

9 simultaneously but one after the other or a 

10 mix of those sources, that you really, before 

11 setting a bounding dose you really have to 

12 calculate the contributions of each of the 

13 sources, which definitely has not been done up 

14 to this point. That's one comment.

15 The other comment is to please 

16 just look at the section on the uranium source 

17 terms at Mallinckrodt, because I really don't 

18 feel that the issue of the dingots and the 

19 outer crust on the dingots and what that would 

20 contribute to dose, I don't believe that's 

21 been adequately addressed and I certainly, 

22 after the comments today by SC&A, we went into 
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1 -- I went into a detailed discussion of why we 

2 now believe that in fact the original 

3 testimony that we gave about GSI workers and 

4 how they actually did corner shot, glancing 

5 betatron shots of uranium ingots and dingots, 

6 is actually true.

7 We have much more information 

8 about that, and we provided that in this 

9 critique to the Work Group. 

10 We believe now, based on documents 

11 and reports, that a major reason those 

12 glancing shots were done was not to examine 

13 the internal structure of the uranium ingot 

14 core, but to actually define that interface 

15 between the magnesium fluoride crust that 

16 always adhered to a dingot after it came out 

17 of the bomb, and was always shaggy and of 

18 different thicknesses, to define that 

19 interface so that the dingots could go back to 

20 Mallinckrodt, and then have the crust lathed 

21 off and expose just the pure uranium core, 

22 without digging into it and losing the 
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1 valuable uranium.

2 So that supposition, particularly 

3 -- well, NIOSH made a supposition that there 

4 was sort of an idealized rectangular slab and 

5 SC&A reasoned that, because the betatron 

6 couldn't possibly calculate, I mean penetrate 

7 the full 18-inch diameter or thickness of an 

8 ingot, that they must have used only slices at 

9 GSI.

10 We believe that that is really an 

11 incorrect supposition, and that needs to be 

12 calculated into the doses delivered, because 

13 we think the radiographers, the people who 

14 handled those dingots, were exposed to a much 

15 larger dingot with an outer crust on it. So 

16 that's that.

17 Then the final thing is, as I 

18 listen to the discussion of the findings, and 

19 was reading through SC&A's findings on the SEC 

20 Evaluation Report, I was struck in many 

21 instances that the primary finding was really 

22 not addressed in the NIOSH comments.
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1 In particular, on Finding Number 

2 1, the way that was expressed by SC&A was 

3 pretty powerful. They said that, because 

4 there was no badge data, no exposure data for 

5 1953 to 64, that a bounding dose could not be 

6 calculated for the external doses. 

7 Yet all the discussion and the 

8 commentary and NIOSH's responses were related 

9 to incidents. Well, I would agree with 

10 Chairman Ziemer, that the incidences, you 

11 know, they're at many centers, most, there are 

12 probably many unreported accidents and 

13 instances, and they're never really figured in 

14 dose calculations.

15 But the overall statement that 

16 SC&A had, that the bounding dose could not be 

17 determined for those ten years. If you put 

18 that in conjunction with what John Mauro has 

19 said repeatedly, that's a huge problem. If 

20 that's not resolved in favor of NIOSH, and if 

21 NIOSH doesn't address it, then that would be 

22 reason in and of itself to give an SEC to GSI 
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1 and overturn NIOSH's recommendation to deny 

2 that SEC.

3 So that's a huge issue, and I 

4 believe that NIOSH should respond directly to 

5 the primary finding. So I hope that will 

6 happen before these issues close. Anyway, I 

7 appreciate the opportunity to put that on the 

8 record. 

9 I will be happy to cooperate with 

10 getting this information, so that NIOSH can 

11 get the information from the NRC FOIA, and I 

12 just appreciate the Work Group allowing us to 

13 interact with them and provide input.

14 CHAIRMAN ZIEMER: Okay, thank you 

15 Dan. Just for clarification, I think the 

16 earlier communication that you referred to 

17 might have been the one on October 9th.

18 DR. McKEEL: Yes sir.

19 CHAIRMAN ZIEMER: I'll just call 

20 this out, so that the Work Group members can 

21 double-check it back in their records as well 

22 as NIOSH and SC&A. It's a communication dated 
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1 October 9th, and the subject line says 

2 "Addendum Petitioner Findings, SEC 105 

3 Evaluation." Is that the correct one Dan?

4 DR. McKEEL: Yes sir.

5 CHAIRMAN ZIEMER: And then that 

6 talks about the iridium and the 250 kVP X-ray 

7 source terms and the oblique betatron corner 

8 shots and related information.

9 DR. McKEEL: Yes. It's about 30 

10 pages long, yes sir.

11 CHAIRMAN ZIEMER: Now and there's 

12 -- that was the cover memo and then there's a 

13 couple of attachments there?

14 DR. McKEEL: Yes sir.

15 CHAIRMAN ZIEMER: Okay. So that 

16 should be in the mix. As we get this other 

17 material and take a look at --

18 DR. McKEEL: Okay. That would be 

19 wonderful.

20 CHAIRMAN ZIEMER: -- at the source 

21 terms and the monitoring data, to ask NIOSH to 

22 look at that in the mix and let's make sure 
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1 that we address these issues in some way or 

2 another.

3 DR. McKEEL: I appreciate that.

4 CHAIRMAN ZIEMER: Yes.

5 DR. McKEEL: Thank you.

6 CHAIRMAN ZIEMER: Now let's go on 

7 to Electro-Metallurgical Corporation, and Bill 

8 Thurber again is going to report on that?

9 MR. THURBER: Yes.

10 CHAIRMAN ZIEMER: Bill, what do 

11 you have for us on that?

12 MR. THURBER: Just by way of 

13 background, what was done --

14 CHAIRMAN ZIEMER: Oh hang-on, just 

15 before you talk. This is a TBD-6001 facility.

16 DR. MAURO: Yes. Both are under 

17 the TBD-6000 and 6001.

18 CHAIRMAN ZIEMER: Well, but Bliss 

19 & Laughlin is 6000.

20 DR. MAURO: 6000, yes.

21 CHAIRMAN ZIEMER: I believe this 

22 one is 6001.
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1 MR. THURBER: That's correct.

2 CHAIRMAN ZIEMER: And I need to 

3 ask where we are on 6001, as far as the main 

4 document is concerned?

5 DR. MAURO: I don't think we've 

6 met specifically for that one. We've only met 

7 on 6000.

8 CHAIRMAN ZIEMER: I don't think we 

9 have either. I'm asking. But remind me, 

10 because I didn't look it up. Did you review 

11 6001? I thought you did.

12 DR. MAURO: Oh yes. We have a 

13 stand-alone report.

14 CHAIRMAN ZIEMER: Is there a 

15 matrix on it?

16 DR. MAURO: And there was a 

17 matrix.

18 CHAIRMAN ZIEMER: Okay. 

19 DR. MAURO: And by the way --

20 CHAIRMAN ZIEMER: I was trying to 

21 find my matrix, and I couldn't find it.

22 DR. MAURO: I certainly will 
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1 provide it.

2 CHAIRMAN ZIEMER: I think it goes 

3 back a ways.

4 DR. MAURO: Oh yes. 

5 MR. ALLEN: One piece of 

6 information. I might be wrong, but if I'm 

7 remembering right, I know 6000 and 6001 are 

8 defaults for essentially have no data or very 

9 limited data.

10 CHAIRMAN ZIEMER: Right, right.

11 MR. ALLEN: If I remember right, 

12 the ElectroMet appendix, even though it's 

13 assigned to 6001, I think we had ElectroMet 

14 data, most of those defaults were not used.

15 CHAIRMAN ZIEMER: Weren't used. 

16 Okay. So it's Appendix C of this.

17 DR. MAURO: That's correct. But 

18 it's not --

19 CHAIRMAN ZIEMER: That's an 

20 important point, because the question I was 

21 going to raise was whether or not it was 

22 important to address 6001 matrix issues prior 
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1 to addressing this one. I think what I'm 

2 hearing is this may be self-sufficient.

3 MR. ALLEN: If I'm remembering 

4 correctly.

5 DR. MAURO: Bill, from my 

6 conversation, it sounds like they've got a lot 

7 of data on ElectroMet.

8 MR. THURBER: Yes, they do, and 

9 certainly in our review of the Petition 

10 Evaluation Report, interwoven into that will 

11 be comments relating to Appendix C of TBD12 6001, which is specifically directed toward 

13 ElectroMet.

14 CHAIRMAN ZIEMER: But are there 

15 any 6001 issues per se that have be resolved 

16 prior to addressing Appendix C?

17 MR. THURBER: I don't think so.

18 CHAIRMAN ZIEMER: Okay.

19 MR. THURBER: I haven't looked at 

20 that specifically. I don't think anybody at 

21 SC&A has, but I don't think that there are any 

22 issues of that kind at this point anyway.
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1 CHAIRMAN ZIEMER: Okay. As you 

2 guys develop your report, if you identify 

3 6001-specific issues that need to be resolved, 

4 if you would point those out, because if 

5 that's the case, we'll need to go back. 

6 I kind of put this on the back 

7 burner, because we haven't had any 6001 

8 facilities to deal with. But now that we do, 

9 it may call that whole matrix into our 

10 limelight. Okay, thanks. Proceed.

11 MR. THURBER: Okay. Anyways, 

12 operations at ElectroMet began in April of 

13 1943, and ended in June or the end of June of 

14 1953. What they did at ElectroMet, they 

15 received green salt, uranium tetrafluoride 

16 from Linde. They reduced the green salt in 

17 bombs, mixing it with magnesium metal and 

18 reducing the uranium tetrafluoride, uranium 

19 metal.

20 Then they recast the derbies in a 

21 vacuum induction furnace to produce billets 

22 that were shipped elsewhere for fabrication, 
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1 for extrusion, rolling or whatever. They also 

2 received some uranium metal scrap, which they 

3 then remelted in the vacuum induction 

4 furnaces, to produce additional uranium 

5 billets.

6 One of the interesting things 

7 about ElectroMet was that the facility was 

8 specially built under government contract, and 

9 it was built in a corner of a large industrial 

10 site where the Electro-Metallurgical Company 

11 did a lot of other things. 

12 They produced ferro-alloys, which 

13 are the kinds of additions you use in 

14 steelmaking. They produced calcium carbide, 

15 which is used to make acetylene.

16 They had a large ongoing 

17 industrial operation, and this facility, which 

18 they called the area plant, was kind of in a 

19 fenced-off area in a corner of the property. 

20 Now the thing, one of the things 

21 that I think needs to be carefully examined is 

22 this. The petition says that it addresses all 
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1 of the employees at the Electro-Metallurgical 

2 Corporation, and I think that that needs to be 

3 carefully examined in the light of the fact 

4 that this was a -- basically a satellite 

5 operation, and it was -- had its own guards 

6 and gated area, and there was very little 

7 mixing of personnel.

8 There is some evidence that there 

9 were some maintenance people that went into 

10 the facility two or three days a year, and 

11 some other maintenance facility people that 

12 might have gone in a couple of days a month. 

13 But there's this -- I haven't been 

14 able to find how big the work force was and 

15 the scope of the operations, the commercial 

16 operations, at ElectroMet were, but they were 

17 substantial.

18 So to bring all those people into 

19 this group that's under review as a Special 

20 Exposure Cohort, I think may overstate the 

21 case.

22 And along that line, one of the 
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1 reports with one of the interviewees, it was 

2 clear that the person that they interviewed 

3 had no involvement whatsoever with the uranium 

4 processing operations. 

5 He was a worker in the rest of the 

6 plant, if you will, and so there is this open 

7 question then, as to who worked there and who 

8 didn't and who should be included.

9 One of the petitioners, there were 

10 two -- there are actually two petitions, and 

11 one of the petitioners said that the people 

12 should include all the ElectroMet employees 

13 who worked in the 50 by 219 building, and that 

14 refers to the size of this area plant that was 

15 specifically built for the AEC work, 

16 originally the Manhattan Engineering District 

17 work, and that petition was merged with the 

18 other petition, and this distinction of all 

19 the workers in the 50 by 219 foot building 

20 disappeared. So as I say, I think this is, 

21 could be a substantive issue.

22 There are a lot of data at 
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1 ElectroMet for the period -- well, let me back 

2 up a second. As I mentioned, they began 

3 production there in 1943, April 1943, and they 

4 were producing uranium about 40 tons a month, 

5 and they continued to do that through some 

6 time in late 1946.

7 Then the plant was put on stand8 by. Then about a year later, they began 

9 operation again and they continued operation 

10 until September of 1949, at which time the 

11 plant went back in stand-by. There's some 

12 evidence, very poorly documented, that there 

13 might have been some work done there in -- at 

14 the beginning of 1951.

15 It obviously wasn't production 

16 work because there's -- well, apparently it 

17 wasn't production work. The records don't 

18 indicate that there was any production work. 

19 So for all intentional purposes, beyond 

20 August-September of 1949, there would have 

21 been very little exposure.

22 So there is some air sampling data 
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1 from 1944. There is urinalysis data from 

2 1944. There is lots of air sampling data, 

3 film badge data and some urinalysis data for 

4 the period 1948-49. So what's missing really 

5 is data for 1945-46 period. I'm sorry, 1943, 

6 1945 and 1946.

7 NIOSH makes the case that there 

8 was sufficient continuity of the operations 

9 and lack of process improvement from the 

10 beginning of operations until 1948, that it is 

11 not unreasonable to extrapolate the 1948-49 

12 data back to the period '45-'46. Obviously, 

13 that's an assumption that we're critically 

14 analyzing, to see whether we concur with that 

15 or not.

16 I think that's kind of the main 

17 features of the situation right now. Again, 

18 there's a lot of detail, and I'm sure we will 

19 end up with questions. Because they use 

20 Appendix C of TBD-6001 to support their 

21 bounding approach, we will have questions 

22 about whether what they say is sufficiently 
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1 prescriptive.

2 In other words, is the median good 

3 enough, the kind of conversation we had this 

4 morning at some length. 

5 CHAIRMAN ZIEMER: Okay, very good. 

6 Bill, can you or John Mauro give us a 

7 preliminary time line as to when the Work 

8 Group would expect the final product from this 

9 effort? 

10 Are we talking about a few weeks, 

11 are we talking about a month, a day? Where 

12 are we on this? I'm not pushing for any 

13 particular time. I just want to get an idea, 

14 because I think before we meet again, we'll 

15 want to have these two documents in hand, and 

16 we'll also want to have the NIOSH stuff in 

17 hand.

18 MEMBER BEACH: And the matrix 

19 6001?

20 CHAIRMAN ZIEMER: Well, the 6001 

21 matrix will not be important unless they 

22 identify it as an issue. I thought initially 
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1 we were going to have to do that, but there 

2 apparently is a lot of data, and the question 

3 is whether that data can extrapolate back to 

4 the earlier times.

5 DR. MAURO: That sounds like where 

6 we are right now, in terms of where the key 

7 issue is.

8 CHAIRMAN ZIEMER: Yes. Are we 

9 talking about having this by February?

10 DR. MAURO: Not for the February 

11 meeting.

12 CHAIRMAN ZIEMER: No, no, and we 

13 wouldn't be meeting at that time.

14 DR. MAURO: Bill, you know you're 

15 -- keeping in mind that I think this is 

16 probably going to DOE, so you want to slip a 

17 couple of weeks into that, I'll leave it to 

18 you to give me a sense. Then of course as the 

19 entire -- after you're done and Chick is done, 

20 it will go through our internal review.

21 MR. THURBER: Right, and you know, 

22 I'm sure we're going to have some serious 
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1 internal discussions.

2 DR. MAURO: Now one other thing 

3 too, Bill. this particular site, I think, is 

4 especially important for a site visit, to 

5 confirm this assumption that the nature of the 

6 operations, ventilation systems, controls, et 

7 cetera, and what transpired, was more or less 

8 uniform between '43 and '49.

9 MR. THURBER: That's correct. 

10 That's indeed correct, and how successful 

11 we're going to be in finding people that 

12 actually worked there and not in the rest of 

13 ElectroMet, I don't know how that's going to 

14 go frankly. I just don't know.

15 CHAIRMAN ZIEMER: We are talking 

16 about sixty-some years ago. 

17 DR. MAURO: You may not be able to 

18 do --

19 CHAIRMAN ZIEMER: If a person is 

20 still surviving, they're 85 or 90. 

21 DR. MAURO: Yes.

22 MR. THURBER: If they were 20 in 
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1 1945.

2 CHAIRMAN ZIEMER: And that's still 

3 pushing it.

4 DR. MAURO: Well, the only reason 

5 I bring it up is that very often, part of our 

6 SEC work usually includes some type of visit 

7 to people. But very often, that follows. In 

8 other words, we'll put our product out with an 

9 appendix that's left blank, allowing that to 

10 catch up, because very often that takes some 

11 time.

12 So for the purpose of scheduling, 

13 let's assume that the appendix, if there is 

14 going to be one, that deals with the site 

15 visit or whatever we would call it, data 

16 capture or whatever, you know, that that's 

17 going to be something that will follow.

18 So basically it's, you know, for 

19 the work that you're doing with Chick right 

20 now and others, for example, when do you think 

21 there would be a draft ready that could get 

22 into the internal SC&A pipeline?
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1 MR. THURBER: Mid-January.

2 DR. MAURO: Mid-January, okay. 

3 MR. THURBER: For both of them.

4 DR. MAURO: Okay. So it sounds 

5 like --

6 MR. THURBER: I think clearly the 

7 Bliss & Laughlin is a much simpler proposition 

8 than this one.

9 DR. MAURO: So the draft in my 

10 hands or let's say the review hands, we're 

11 talking about a month from now, and then 

12 another month after that to go through DOE 

13 clearance and so forth.

14 CHAIRMAN ZIEMER: So mid-February.

15 DR. MAURO: So we're talking mid16 February, perhaps right after the full Board 

17 meeting. That's probably as good a guess as 

18 anything.

19 CHAIRMAN ZIEMER: Okay. So 

20 MS. WOJCIK: May I ask a question 

21 before the ending of the day?

22 CHAIRMAN ZIEMER: Sure.
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1 MR. KATZ: Yes. Can you tell us 

2 who you are?

3 MS. WOJCIK: I'm Margaret. I'm 

4 the petitioner for Bliss & Laughlin.

5 CHAIRMAN ZIEMER: Oh good, okay. 

6 Very good. Go ahead.

7 MS. WOJCIK: You had mentioned 

8 earlier some machining operations done in 1951 

9 and '52, subcontracted from Fernald. There 

10 were only five one-day machining operations. 

11 Where does that information come from?

12 CHAIRMAN ZIEMER: Bill, can you 

13 answer that, or do we need Chick on the line 

14 or --

15 MR. THURBER: Well, that comes 

16 from the Petition Evaluation Report.

17 DR. MAURO: You mean the 

18 evaluation -- ER, the ER.

19 MR. THURBER: Yes, the Evaluation 

20 Report, and you know, it comes from obviously 

21 from review of the available records.

22 MS. WOJCIK: Well, we have here at 
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1 the bottom of 17, in the SEC Petition 

2 Evaluation Report, "Contaminated levels 

3 removed in 1998 tells us there were higher 

4 levels between '48 and '52. What does that 

5 tell us about the levels that were present?"

6 MR. THURBER: I'm sorry. Where 

7 are you quoting from?

8 MS. WOJCIK: Page 17, the bottom 

9 of our SEC Petition Evaluation Report. Page 

10 17 on the bottom. 

11 MR. THURBER: Okay. I'm going to 

12 have to pull that up and take a look.

13 DR. MAURO: Maybe I -- could I say 

14 something here? We're right in the middle of 

15 the process right now. There's no doubt that 

16 one of the things we do is look at every 

17 reference that stands behind the positions 

18 taken in the ER. So that we will confirm. So 

19 we do have an obligation to confirm that 

20 assumption. 

21 In other words, if there's any 

22 reason to believe that the number and the 
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1 extent of the operations is somewhat different 

2 than as represented in the ER, we will 

3 investigate that. So I mean -- so you may be 

4 pointing something out and we would very much 

5 be interested in hearing more about that.

6 MR. THURBER: But that was from 

7 the petition, the NIOSH Petition Evaluation 

8 Report; is that correct?

9 MS. WOJCIK: This is from not 

10 NIOSH. SEC Petition Evaluation Report that I 

11 received June 30th, 2009. The Evaluation 

12 Report of the SEC petition.

13 CHAIRMAN ZIEMER: Now that's the 

14 NIOSH report.

15 MR. THURBER: Okay.

16 DR. NETON: I haven't seen that. 

17 I don't see what she's talking about.

18 MR. THURBER: Let me. I'm trying 

19 to pull it up here.

20 DR. NETON: I've got it up here.

21 MEMBER MUNN: It says remediation 

22 began in late 1998. 
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1 DR. NETON: I don't see what 

2 you're referring to, ma'am.

3 CHAIRMAN ZIEMER: It's page 17, 

4 did you say?

5 MS. WOJCIK: Yes, page 17. 

6 CHAIRMAN ZIEMER: And what line or 

7 where in the report? We have it pulled up 

8 here now.

9 DR. NETON: Yes, I have it in 

10 front of me.

11 CHAIRMAN ZIEMER: So Dr. Neton is 

12 looking at page 17 now. And where on the page 

13 should he be looking?

14 MS. WOJCIK: I've got the fourth 

15 line down, "Remediation of Bliss & Laughlin 

16 site."

17 MEMBER MUNN: "Began in late 

18 1998." The last paragraph on the page.

19 DR. NETON: "Remediation began in 

20 1998 and continued through 1999." Okay, I see 

21 that.

22 CHAIRMAN ZIEMER: Yes, okay. Then 
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1 what was the question then?

2 MS. WOJCIK: Okay. At the bottom 

3 of page 17, I have here "Contaminated levels 

4 removed in '98 tells us there were higher 

5 levels between '48 and '52." So whether Bliss 

6 & Laughlin had only five one-day machining 

7 episodes or not, it's right in writing here.

8 DR. NETON: I'm not seeing that.

9 MS. WOJCIK: The levels were high.

10 MR. THURBER: I'm sorry. Are you 

11 reading "Remediation of the Bliss & Laughlin 

12 site began in late 1998, and continued through 

13 March 1999"?

14 MS. WOJCIK: No. You know what? 

15 Okay. I might have something different here.

16 DR. NETON: Yes. That's not in 

17 the report.

18 MR. THURBER: Okay. But I would 

19 make this comment, that the report does 

20 address, I believe it addresses the period 

21 after the actual machining ceased, and 

22 considers the exposure during the residual 
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1 period, which would be -- I think this one 

2 does. 

3 DR. NETON: It should.

4 MR. THURBER: It should. I know 

5 that the ElectroMet report does not, but --

6 CHAIRMAN ZIEMER: Well, let's see. 

7 We need to clarify what the question is then. 

8 Did you say that you --

9 MS. WOJCIK: Okay. What it said 

10 is that contaminated levels removed in '98 

11 tells us there were higher levels between '48 

12 through '52. What you had said earlier was 

13 that there were five, only five one-day 

14 machining episodes at Bliss & Laughlin.

15 MR. THURBER: Right. They were in 

16 '51 and '52, and --

17 MS. WOJCIK: So whether there were 

18 just five or more, there were still higher 

19 levels of contamination then in those years.

20 MR. THURBER: I can't comment on 

21 that without understanding the document that 

22 you're working from.
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1 DR. NETON: It seems like what 

2 it's trying to say is that during the period 

3 where they were processing the uranium, there 

4 were higher levels than what was measured in 

5 the residual period, in 1998; is that correct?

6 MS. WOJCIK: Yes.

7 DR. NETON: Yes. Well, that would 

8 make sense. I mean during the years where 

9 they were actually machining the uranium or 

10 doing something to it, you would have higher 

11 levels. It could certainly have. It points 

12 to a 1948 date, which doesn't make sense.

13 MR. THURBER: No. That makes no 

14 sense at all.

15 DR. NETON: We need to see the 

16 document that you're referring to.

17 CHAIRMAN ZIEMER: Is this a 

18 different document from the Evaluation Report?

19 DR. NETON: I believe so, yes.

20 MEMBER MUNN: It has to be. It 

21 has the same first sentence in it, but after 

22 that --
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1 MS. WOJCIK: Okay. Who can I send 

2 a copy of this to?

3 CHAIRMAN ZIEMER: Can you identify 

4 who's report it is to start with? You say it 

5 was a NIOSH report?

6 MS. WOJCIK: No. I've got SEC 

7 Petition Evaluation Report.

8 MEMBER MUNN: And on the top it 

9 says "SEC 00131"?

10 MS. WOJCIK: Yes.

11 MEMBER MUNN: 630-09 final, Bliss 

12 & Laughlin, and you're looking at page 17?

13 MS. WOJCIK: Yes.

14 MEMBER MUNN: It doesn't say the 

15 same thing as my page 17.

16 MS. WOJCIK: That's what it sounds 

17 like.

18 CHAIRMAN ZIEMER: Was there an 

19 earlier draft or --

20 DR. NETON: I don't think so. I'm 

21 looking at what's published on our website 

22 right now.
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1 MS. WOJCIK: Okay. Can I send a 

2 copy of what I have?

3 MR. KATZ: You know, that seems 

4 like the easiest thing to do.

5 DR. NETON: Yes.

6 CHAIRMAN ZIEMER: Yes. Who should 

7 she send it to, Ted?

8 MR. KATZ: You're welcome to send 

9 it to me actually. 

10 CHAIRMAN ZIEMER: Send it to Mr. 

11 Katz, who's our federal official.

12 MR. KATZ: And I will distribute 

13 it.

14 CHAIRMAN ZIEMER: And can you send 

15 it electronically, or do you need to mail it?

16 MS. WOJCIK: No, I will mail it.

17 MR. KATZ: You do not have it 

18 electronically?

19 MS. WOJCIK: Well, it will 

20 probably come through in pieces. I'd just as 

21 soon put it in the U.S. mail.

22 MR. KATZ: Okay, because it's 
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1 actually much easier for me to distribute it 

2 if you send it to me by email than if you send 

3 it to me --

4 MS. WOJCIK: I can try.

5 MR. KATZ: -- in paper. I don't 

6 necessarily need the whole thing at first, 

7 depending on what it is. If it's something 

8 that we have, then all I really need is enough 

9 to be able to identify it.

10 MEMBER MUNN: The first 17 pages.

11 CHAIRMAN ZIEMER: You need the 

12 first, the cover page --

13 MR. KATZ: Or even just the cover 

14 page will probably get us there. So you don't 

15 need to send the whole thing, although you 

16 know email, it shouldn't be that consuming a 

17 document in terms of --

18 CHAIRMAN ZIEMER: Well, it may 

19 depend on whether her electronic version is 

20 PDF. If it is, she may not be able to 

21 separate.

22 MR. KATZ: Right. Even so, it 
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1 should be able -- you should be able to send 

2 it by email. So send it to me, and let me 

3 give you my email address.

4 MS. WOJCIK: Okay.

5 CHAIRMAN ZIEMER: Thank you very 

6 much. Okay. Then the other question I have 

7 before we conclude here, and I'll ask, I 

8 guess, Dave Allen and Dr. Neton, do you have 

9 any feel for how long it will take to analyze 

10 the information that you referred to, that Dr. 

11 McKeel identified? 

12 I know you have to get it and it 

13 sounds like there's a lot there. That's 

14 likely to take -- well, I'm going to be 

15 surprised if you're able to have anything 

16 before February.

17 MR. ALLEN: I don't think so 

18 either, but I mean like you said, it's very --

19 it sounds like a rich source of information.

20 CHAIRMAN ZIEMER: If you would 

21 plan on an update at our February meeting on 

22 where you are on the analysis of that data.
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1 MR. ALLEN: We can do that.

2 CHAIRMAN ZIEMER: Just for the 

3 Board meeting when we do the Work Group 

4 reviews. Just give us an update on where you 

5 are, or let me know in advance, so that when I 

6 report, because I don't want to set a meeting 

7 date until I know where we are on that.

8 Because that may be, that will be 

9 a more critical path, even than these other 

10 two, because there's more urgency. GSI has 

11 been on our radar screen for quite a while. 

12 Here's a whole new batch of information. 

13 We've got to evaluate that, 

14 assimilate it and address it as quickly as 

15 we're able to within the parameters that are 

16 set by just work time limitations.

17 Because you have a whole lot of

18 things going on. Everybody's petition is 

19 pressing, but I think as soon as we can get 

20 that.

21 MR. ALLEN: So you want 

22 essentially like an email to you --
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1 CHAIRMAN ZIEMER: That would be 

2 fine.

3 MR. ALLEN: To the rest of the 

4 Working Group too?

5 CHAIRMAN ZIEMER: Yes, you can 

6 copy everybody. I just want it reported at 

7 the full Board meeting, when we talk about the 

8 Work Group reports, because this is very 

9 important.

10 MR. KATZ: And whether there will 

11 be a Mallinckrodt data capture. That's sort 

12 of question in this too, right?

13 CHAIRMAN ZIEMER: Well, there was 

14 some question about whether it might be at 

15 Mallinckrodt, some of those film badge 

16 records. But you'll have to look at the scope 

17 of what Dr. McKeel has identified, and 

18 determine --

19 DR. NETON: Some of that might 

20 even depend on what we get from the Landauer 

21 report. So there's a number of things.

22 CHAIRMAN ZIEMER: The Landauer 
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1 apparently only had the Picker part, I would 

2 guess. But anyway, if you'll plan to report 

3 on that and I think it's premature for us to 

4 set the next date until we have a better idea 

5 of where we are on those three things, the GSI 

6 data and information, and then we'll get an 

7 update on SC&A on where they are. 

8 We may have their documents by 

9 then and be underway, and digesting those. 

10 But this will be critical to our next meeting. 

11 Okay. Any further comments or questions? 

12 Mark, are you still on the line?

13 MEMBER GRIFFON: Yes, I'm still 

14 on.

15 CHAIRMAN ZIEMER: Do you have 

16 anything else?

17 MEMBER GRIFFON: No, no. I think 

18 I'm all set.

19 CHAIRMAN ZIEMER: You okay? Okay. 

20 Any other --

21 MEMBER BEACH: Well, the only 

22 thing I have is on Dan McKeel's request that 
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1 we review the SEC 105 petition. Are you going 

2 to comment back to him on these, or will the 

3 other two action items address --

4 CHAIRMAN ZIEMER: Well, on those 

5 items, I've asked NIOSH to --

6 MEMBER BEACH: I know they're 

7 intermixed.

8 CHAIRMAN ZIEMER: -- as they 

9 address it, because these have to do with the 

10 NIOSH evaluation, the Evaluation Report.

11 MEMBER BEACH: Correct. I guess 

12 my question is there's nothing the Work Group 

13 can do in answer to any of Dan's requests at 

14 this time?

15 CHAIRMAN ZIEMER: I don't think 

16 these are issues that the Work Group per se 

17 can address. I think they are questions 

18 phrased to NIOSH about their models. 

19 So you know, if you look at this 

20 and you say well, you know, that's a "no, 

21 never mind," at least tell us why. If it's an 

22 issue, then you will need to address it. 
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1 I mean we don't know, and Dr. 

2 McKeel is not necessarily claiming these are 

3 show-stoppers, but they could be. We don't 

4 know that at this point. So you'll have to 

5 critique that.

6 MEMBER BEACH: There's actually 

7 two of them, the October 9th and --

8 CHAIRMAN ZIEMER: Well, the cover 

9 letter is October 9th. I'm looking to see who 

10 was copied on this. It's the Work Group and 

11 copied, Ted's copied, Larry, and Mauro. Dave, 

12 you weren't copied on this.

13 MR. KATZ: I probably forwarded it 

14 to him. I forward everything.

15 CHAIRMAN ZIEMER: Yes. So make 

16 sure you have it.

17 MEMBER BEACH: Well I was looking 

18 at the December 14th one also. 

19 CHAIRMAN ZIEMER: Well, that's 

20 more recent and I referred to that earlier 

21 today. We just go that a day or two ago. 

22 MEMBER BEACH: Right.
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1 CHAIRMAN ZIEMER: And that had 

2 some -- that focused mainly on the new 

3 information that Dr. McKeel has discovered. 

4 MR. KATZ: If you don't have it, 

5 let me know and I can send something to you.

6 MEMBER BEACH: I just wanted to 

7 make sure all those were addressed.

8 CHAIRMAN ZIEMER: I appreciate it. 

9 Very good. Okay. I think that concludes our 

10 business for today. I appreciate everybody's 

11 time and effort on this. It sometimes feels 

12 like we're making progress and sometimes it 

13 feels like for every step forward there's 

14 three more steps to go. 

15 But thank you all, and we'll keep 

16 plugging away at these issues and try to come 

17 to closure as rapidly as we can. So we are 

18 adjourned.

19 MR. KATZ: Thank you everyone on 

20 the telephone, Dr. McKeel, John Ramspott and 

21 all.

22 (Whereupon, the above-entitled 
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1 matter went off the record at 4:13 p.m.)

2