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1

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 

+ + + + +

WORK GROUP ON TBD 6000

+ + + + +

THURSDAY

JUNE 14, 2012

+ + + + +

 The Work Group convened 

telephonically at 9:00 a.m., Paul L. Ziemer, 

Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chairman

JOSIE BEACH, Member

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT: 2

TED KATZ, Designated Federal Official

DAVE ALLEN, DCAS

BOB ANIGSTEIN, SC&A

JENNY LIN, HHS

JOHN MAURO, SC&A

DAN MCKEEL

JIM NETON, DCAS

JOHN RAMSPOTT 

MUTTY SHARFI, ORAU Team

JOHN STIVER, SC&A
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3

C-O-N-T-E-N-T-S 

Page

Welcome and Roll Call 4 

Review of NIOSH position on dose 7 

reconstruction for the General Steel

Industries residual period for SEC

Petition 00105 and response to SC&A

review.

by Dave Allen

SC&A response to current NIOSH proposal 41

and NIOSH responses to SC&A review.

by Bob Anigstein

GSI Co-petitioner comments. 54

by Dan McKeel

Work Group discussion and 93

recommendation for the GSI residual

period.

by Paul Ziemer

Adjournment 133
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4 1 P-R-O-C-E-E-D-I-N-G-S 

2 (9:02 a.m.)

3 MR. KATZ: Welcome, everyone, good 

4 morning. Advisory Board on Radiation Worker 

5 Health. It's TBD-6000 Work Group. We are 

6 going to be discussing GSI residual period 

7 during this Work Group meeting. And let's 

8 begin with roll call.

9 (Roll call.)

10 CHAIRMAN ZIEMER: Okay. Thank you 

11 very much. The focus of our meeting today is 

12 on the residual period for General Steel 

13 Industries. The agenda was distributed and is 

14 also posted online. Also, the other documents 

15 referred to, I'll just very quickly mention 

16 them sort of in the order that we received 

17 them.

18 We have a May 30th document from 

19 SC&A called, Update of Review of Site Profile 

20 for Atomic Weapons Employees that Worked 

21 Uranium and Thorium Metals, Appendix BB, 
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5 1 General Steel Industries, Battelle TBD-6000, 

2 Appendix BB, Occupational Internal Dose. 

3 That's the title on the paper.

4 We have a June 8th document from 

5 NIOSH entitled, Battelle TBD-6000, Appendix 

6 BB, General Steel Industries Response to SC&A 

7 Memo, dated May 30th, 2012. We have a 

8 document dated June 1st from the co-petitioner 

9 called, Petitioner Comments on SC&A Discussion 

10 Paper, dated 5/30/12, and gives the title of 

11 the SC&A paper, and that's by Dan McKeel.

12 And then we have a June 11th 

13 report, again, from SC&A called, Reply to 

14 NIOSH Response to SC&A Memo dated May 30th, 

15 2012. Also, just for reference, the updated 

16 resolution matrix for Petition 00105, the June 

17 1st version of that, which also has been 

18 distributed.

19 So what the intent was was to have 

20 SC&A begin with their review on the residual 

21 period. Now, keep in mind that there was an 
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6 1 original review and it wasn't clear to me that 

2 it was very specific. There weren't any 

3 findings on that residual period in that 

4 review and it wasn't clear, exactly, what 

5 SC&A's position was relative to the NIOSH 

6 recommendation.

7 So Bob Anigstein was asked to 

8 clarify the SC&A position, and that initiated 

9 this series of papers. There's been some 

10 changes, as I understand it, in SC&A's 

11 position since the first paper, but let's let 

12 Bob go ahead and kick this off. And, Bob, you 

13 can updated as you go if you wish, because 

14 things have changed a little bit on the SC&A 

15 view as you went along.

16 MR. KATZ: Paul? This is Ted, I 

17 thought you had wanted Dave to provide the 

18 initial presentation, cover the initial --

19 CHAIRMAN ZIEMER: That's right. 

20 I'm sitting here looking at an earlier draft 

21 of the agenda and I apologize for that. Dave 
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7 1 can go ahead and kick this off. Right.

2 MR. ALLEN: Okay. Thanks, Paul. 

3 This is Dave Allen, NIOSH. I was just going 

4 to briefly go over the White Paper I wrote on 

5 June 8th, and some of that was in response to 

6 SC&A's -- 

7 CHAIRMAN ZIEMER: Right.

8 MR. ALLEN: -- review, so I think 

9 Bob will then go over the update of that.

10 CHAIRMAN ZIEMER: Right.

11 MR. ALLEN: He can cut in if I say 

12 something wrong.

13 DR. ANIGSTEIN: No. I'll let you 

14 finish.

15 MR. ALLEN: The White Paper I 

16 wrote, part of that went over the methodology 

17 and the appendix, right now, for the residual 

18 period, so I just wanted to go over that, just 

19 briefly, to describe how that estimates dose.

20 It starts by using TBD-6000 slug 

21 production. The reason that was chosen is 
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8 1 that is handling quite a bit of uranium metal, 

2 that process, that is essentially what GSI did 

3 was handle uranium metal as far as airborne 

4 contamination.

5 And in slug production, it's 

6 actually the oxides of uranium metal that are 

7 inhaled. Nobody inhales a slug, or a 300-

8 pound derby, or anything. Oxides are somewhat 

9 proportional to the surface area of the metal 

10 and slugs are smaller, have a lot more surface 

11 area, so that portion of it should be higher 

12 or bounding on GSI, since they handled larger 

13 pieces of uranium metal than slugs.

14 Also, the slug production dealt 

15 with cutting and grinding on the metal, which 

16 was, by far, the highest airborne-causing 

17 operation in slug production. And GSI X-rayed 

18 uranium metal without actually manipulating 

19 the metal as far as cutting, grinding, or any 

20 kind of abrasion.

21 So this was described in the 
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9 1 appendix that the slug production should be 

2 bounding on GSI. In TBD-6000, that is assumed 

3 to be a full-time operation, the slug 

4 production, and GSI uranium work was not full5 time, so it was prorated to the time frames in 

6 the appendix of uranium work.

7 It was also assumed that the 

8 motive force to actually get this oxidation 

9 off of the uranium and into the air was only 

10 present while people were handling the uranium 

11 and it wasn't present while it was sitting 

12 there being X-rayed.

13 So in the appendix, we took the 

14 slug production airborne concentration was 

15 present in the air the whole time the uranium 

16 might have been handled and let that settle on 

17 to the floor to calculate a surface 

18 contamination level.

19 Then we resuspended that with a 1 

20 times 10 to the minus 6th resuspension factor 

21 to calculate airborne activity. That was what 
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10 1 we used for the residual period.

2 Also, calculated an external dose 

3 from that surface contamination, but that 

4 turns out to be fairly low, and then we 

5 realized it is possible to get contamination 

6 and concentrate it in one air and increase 

7 that external dose rate in a localized area.

8 And we found that that is what 

9 happened at GSI and they had a vacuum cleaner 

10 that had an external dose rate study. They had 

11 a small external dose rate coming from a 

12 vacuum cleaner from uranium inside it.

13 Still fairly small because, 

14 uranium, you don't get a great deal of 

15 external dose, and therefore, we just used 

16 that dose rate since it was higher than the 

17 calculated dose rate from surface 

18 contamination, and we used that for the full19 time in the residual period.

20 With that explanation, I think 

21 that answered a couple of misunderstandings on 
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11 1 the original SC&A review on how we had did our 

2 dose estimate, and I think Bob will probably 

3 speak to that.

4 I also mentioned, in my White 

5 Paper, in response to SC&A's first White 

6 Paper, that the times that we worked with 

7 uranium, that's somewhat in debate there. 

8 What we did was took those purchase orders 

9 based on the hourly rate and the monthly value 

10 on it.

11 We calculated a maximum monthly 

12 hours that they could have been working with 

13 uranium under those purchase orders. And, in 

14 general, in the beginning, it was $450 per 

15 month.

16 That very first purchase order for 

17 four months was actually $500, and I believe 

18 the other year was actually just an annual 

19 limit that didn't add up to that, and it was a 

20 little higher, so we increased that year.

21 In the later years, the limits 
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12 1 started going down quite a bit, but $450 is 

2 the general rule, and the thinking was that 

3 they started off with $500 a month for four 

4 months, and then dropped it to $450, and kept 

5 it at that level.

6 So we were thinking that the $500 

7 was an estimate and the $450 was what they 

8 reduced it to as a limit, so we were thinking 

9 that that is, essentially, what they learned 

10 from that first four months that they needed. 

11 And, yes, I don't think there is agreement on 

12 that, but that is what we did in the appendix.

13 And I spelled out, basically, that 

14 reason and pointed out that the rest of the 

15 purchase orders were on a fiscal year basis, 

16 but this first one started off in March, so it 

17 was only for a four-month period, and it 

18 appeared to be the start-up of, or probably 

19 restart of, some work.

20 And I pointed to a memo, a couple 

21 memos, that indicated some work that was done 
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13 1 in February, and it wasn't much. Doesn't 

2 really say uranium, but the timing all seemed 

3 to work out to where that looked like it 

4 probably was that positive. It was just one 

5 more piece of information.

6 And I believe Bob also pointed out 

7 in his review that we didn't base the external 

8 doses in the appendix on 3250 work hours per 

9 year, and we agree.

10 I mean, all the calculations we 

11 had done for the operational period for, you 

12 know, the Work Group, with those last several 

13 White Papers, et cetera, are all based on 3250 

14 hours per year, and that is what we intend to 

15 do with the residual period also when we get 

16 everything resolved and revise the appendix.

17 I think that's all the overview I 

18 intended to give there. I'm open to any 

19 questions or we can go to Bob.

20 CHAIRMAN ZIEMER: Okay. Let's see 

21 if there's any general questions for Dave 
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14 1 Allen first, and then we'll go on to Bob.

2 MEMBER POSTON: Paul, this is John 

3 Poston.

4 CHAIRMAN ZIEMER: Yes.

5 MEMBER POSTON: I just had a quick 

6 question on one of the things in Dave's report 

7 I was working through. It's on Page 1. It's 

8 the bottom paragraph. And I believe there's a 

9 unit missing there, because if you do a unit 

10 analysis, it doesn't come up d per m per day. 

11 And that's just a correction --

12 CHAIRMAN ZIEMER: You're talking 

13 about the paragraph that begins with 198 d per 

14 m per cubic meter, right?

15 MEMBER POSTON: Right. And as you 

16 go across, after fraction of time in vicinity 

17 of the uranium, it should say one year per 365 

18 days to make the units work out. It's 

19 probably just a typo. I mean, I think the 

20 numerical values are correct, but the units 

21 don't work out unless you put a year in there 
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15 1 somewhere.

2 MR. ALLEN: Oh, I see what you're 

3 saying. Yes, I think you're right. It should 

4 have said, the real conversion would have been 

5 365 days per year.

6 MEMBER POSTON: Right.

7 MR. ALLEN: I didn't put per year 

8 in there.

9 MEMBER POSTON: Yes.

10 CHAIRMAN ZIEMER: Oh, yes. The 

11 365 is there, but the year part isn't.

12 MEMBER POSTON: Right. Yes.

13 CHAIRMAN ZIEMER: Yes.

14 MEMBER POSTON: So that's just a 

15 correction that needs to be made to make it 

16 accurate.

17 CHAIRMAN ZIEMER: Right.

18 MEMBER POSTON: And it says here, 

19 but I just want to hear a yes anyway, 

20 basically, you were talking about the intakes 

21 between operations. It says you assume the 
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16 1 maximum air concentration existed the entire 

2 time the workers went in the area.

3 You took an average of that, is 

4 that what you're telling me? That's on Page 

5 2, first paragraph, last line.

6 MR. ALLEN: All I was trying to 

7 say there is, essentially, in the appendix, we 

8 estimated 15 minutes to set up the shot and 15 

9 minutes to take it down.

10 MEMBER POSTON: Yes.

11 MR. ALLEN: So I think it was 30, 

12 30, and then an hour to take the shot. And we 

13 assumed that whole time that they were in 

14 there that it was a 198 dpm per cubic meter, 

15 you know, from the second that started.

16 MEMBER POSTON: Yes. Okay. I 

17 just wanted to clarify that. That's what I 

18 got from this, but that's a pretty generous 

19 assumption, don't you think?

20 MR. ALLEN: Well, actually, I 

21 don't think that one's too generous because 
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17 1 when you're dealing with the settling, I mean, 

2 we also assumed that it disappeared instantly 

3 when they walked out of the room, which is 

4 also not true.

5 MEMBER POSTON: Oh, yes. Okay.

6 MR. ALLEN: When you're talking 

7 about the settling, it's a build-up, and it's 

8 a drop-off, and you --

9 MEMBER POSTON: Yes. It depends 

10 on the particle size and all that other stuff, 

11 yes.

12 MR. ALLEN: Yes.

13 MEMBER POSTON: Okay. I just 

14 wanted to make sure I understood exactly what 

15 you were saying.

16 CHAIRMAN ZIEMER: You're dealing 

17 with it as if it's a step function.

18 MEMBER POSTON: Yes.

19 CHAIRMAN ZIEMER: It starts off at 

20 the top and it stays there continuously till 

21 they leave.
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18 1 MEMBER POSTON: Yes. It's like a 

2 switch. When you walk in the door, it goes to 

3 maximum.

4 CHAIRMAN ZIEMER: Right.

5 MEMBER POSTON: When you walk out, 

6 the door, it goes to zero.

7 CHAIRMAN ZIEMER: Right.

8 MEMBER POSTON: Okay. All right. 

9 I understand.

10 DR. MCKEEL: Dr. Ziemer, this is 

11 Dan McKeel, may I make a comment?

12 CHAIRMAN ZIEMER: Sure.

13 DR. MCKEEL: Dave mentioned, when 

14 he was reviewing what was done at the slug 

15 production facility, he made a comment that 

16 there was no cutting, grinding, or abrasion of 

17 uranium at GSI.

18 And one of the points that I want 

19 to reinforce is that, although that was not 

20 done as a machining operation, those large 

21 slugs, I mean, the large ingots and dingots
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19 1 that were brought over from Mallinckrodt, and 

2 even the betatron slices, were so heavy that 

3 they had to be picked up and handled by chain 

4 men and by chains.

5 And, of course, those chains were 

6 hanging down from a crane, the ingots and 

7 dingots were swinging, and, undoubtedly, those 

8 chains scraped the outer surface of the ingots 

9 and dingots which had not been cleaned of 

10 their outer crust.

11 So a point that I think has been 

12 ignored throughout this consideration of GSI, 

13 but it is mentioned by SC&A in their White 

14 Paper, that there was a long path through 

15 General Steel by which the uranium from 

16 Mallinckrodt traversed, even before it got to 

17 the betatron buildings.

18 So, you know, it had to come to 

19 the loading docks, we know that it was stored 

20 before and after it got there, it had to be 

21 loaded onto their railroad transfer cars, 
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20 1 taken along the railroad tracks, which 

2 traversed many of the buildings beside the 

3 foundry, through Buildings 6, 7, 8, 9, 10.

4 The railroad tracks from Building 

5 10 went into the new betatron building, so the 

6 ORNL assumption in 1989 that the only areas 

7 that had uranium contamination were the old 

8 and new betatron buildings must have been a 

9 cost containment sort of consideration, 

10 because anybody who thinks about the process 

11 for uranium handling at GSI has to recognize 

12 that there were long pathways that probably 

13 were contaminated by chafing and scraping by 

14 the chains on those large ingots, dingots, and 

15 betatron slices.

16 So I think that is a major lack of 

17 the analysis of the residual period. There is 

18 zero data on uranium surveys at GSI. Real 

19 uranium survey, radiologic data, from 1952, 

20 when the first machine, betatron government21 owned machine, was there until the ORNL survey 
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21 1 of the old and new betatron buildings in 1989.

2 So the idea that, somehow, the 

3 dust content in a small industrial vacuum 23 

4 years after the plant closed is, in any way, 

5 indicative of the residual contamination in 

6 that plant is really, scientifically speaking, 

7 ridiculous, absurd, and really unacceptable.

8 The proper way to look at things 

9 is, there is really no representative residual 

10 period real data; air monitoring, surface 

11 concentrations. You know, we do know from 

12 worker testimony that that building, the old 

13 betatron building for instance, had been 

14 power-washed in the intervening years back in 

15 the '70s, and that small vacuum was used 

16 repeatedly, we are told, you know, every day 

17 it was emptied and so forth.

18 So all that represents is the 

19 residual uranium dust in that vacuum when it 

20 was probably last used. Nobody even knows 

21 when it was last used. And the other point 
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22 1 is, there were other vacuums, and the one that 

2 was really used to clean the floor in the old 

3 betatron building was much larger, and that 

4 one, there's no measurement of that.

5 So I think those points need to be 

6 put on the record. Thank you.

7 CHAIRMAN ZIEMER: Okay. Thanks, 

8 Dan. One connection, Dave, could you clarify 

9 the application of the activity that you're 

10 proposing. Who would this apply to, the air 

11 concentrations that you're proposing?

12 MR. ALLEN: Air concentrations and 

13 the external would apply to everybody at GSI.

14 CHAIRMAN ZIEMER: Everybody. So 

15 in a certain sense, it is considered to be 

16 present all along the pathway that Dr. McKeel 

17 mentioned, right?

18 MR. ALLEN: The assumption was 

19 that you got different carts that it might 

20 have come in on and different paths.

21 CHAIRMAN ZIEMER: Right.
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23 1 MR. ALLEN: But it all ended up in 

2 the betatron building, so that should be the 

3 higher area.

4 DR. MCKEEL: This is Dan McKeel 

5 again, I think that assumption, again, 

6 scientifically speaking, is unwarranted. You 

7 don't know that the highest concentration is 

8 in the betatron building.

9 I would think that the highest 

10 concentration might be the first chain men 

11 that put the ingot and the dingot up in those 

12 chains and it started swinging around, and it 

13 had to be placed in the chains might be the 

14 highest dose.

15 But the point is, we can argue 

16 about it all day long, but the idea that the 

17 highest value was in the betatron building is 

18 pure speculation. Thank you.

19 CHAIRMAN ZIEMER: Okay. Other 

20 questions for Dave?

21 MR. RAMSPOTT: Dr. Ziemer?
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24 1 CHAIRMAN ZIEMER: Yes.

2 MR. RAMSPOTT: This is John 

3 Ramspott.

4 CHAIRMAN ZIEMER: Oh, hi, John. 

5 We missed you earlier in roll call.

6 MR. RAMSPOTT: Absolutely. I'm 

7 actually in route to an animal hospital --

8 CHAIRMAN ZIEMER: Okay.

9 MR. RAMSPOTT: -- for an 

10 emergency. So everything is stable now. I 

11 can chat a minute. Dave, if I could ask a 

12 question, the quantity that you're talking 

13 about. Where did you get the quantity that 

14 you're talking about, the dust? Can I ask, 

15 where did that come from, that information?

16 MR. ALLEN: Are you talking about 

17 the quantity on the floor for the residual 

18 period?

19 MR. RAMSPOTT: Yes.

20 MR. ALLEN: Well, like I 

21 explained, we took the slug production 
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25 1 airborne concentration that we've seen at slug 

2 production facilities and assumed that 

3 concentration was there the whole time people 

4 could have been kicking the --

5 MR. RAMSPOTT: So are you saying 

6 you're using another site rather than GSI, and 

7 the vacuums, and all that? Is that what 

8 you're saying?

9 MR. ALLEN: For the airborne --

10 MR. RAMSPOTT: Yes.

11 MR. ALLEN: -- which then settled 

12 to the floor, yes.

13 MR. RAMSPOTT: I was curious 

14 because I heard Dr. McKeel say that if it was 

15 coming from the vacuum, you know, cleaner or 

16 what have you, that's definitely false because 

17 that thing had been emptied bazillions of 

18 times, and that other vacuum that Dr. McKeel 

19 is talking about is actually the size of a 

20 golf cart. We have pictures of it. They 

21 drove it.
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26 1 So that's how big that was. So 

2 anything that was there in a cleanup was 

3 minuscule compared to what was really there 

4 during the operation period. Okay. I'm just 

5 curious, just wanting to clarify that, and get 

6 it on the record.

7 So it's really not from GSI. It's 

8 from another site.

9 MR. ALLEN: Well, we did end up --

10 MR. RAMSPOTT: Okay.

11 MR. ALLEN: -- using the vacuum 

12 cleaner for the external dose because it was -

13 - 

14 MR. RAMSPOTT: You are using the 

15 vacuum cleaner for external, though?

16 MR. ALLEN: Right, because it was 

17 higher than what the external dose we 

18 calculated --

19 MR. RAMSPOTT: Oh, well, then 

20 that's my point. That external dose from a 

21 vacuum cleaner that they inspected in 1989 had 
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27 1 been emptied between 1966, I guess when the 

2 uranium quit, and till '89 -- I mean till '74, 

3 at least, anyway, when GSI closed.

4 And then there were other people 

5 moved into that building, that's why 

6 everything was power-washed, actually with a 

7 fire hose, it was a little power-wash, and we 

8 actually have a worker that everybody's 

9 familiar with, his son was on that crew that 

10 actually cleaned that up with a fire hose.

11 They had to clean it up so they 

12 could remodel it to use it for storage. So 

13 same thing with the new betatron. I guess my 

14 point was: there's very, very little of 

15 anything left in that vacuum cleaner in '89 

16 for the cleanup that could have been in there 

17 during the real '53 to '66 period.

18 CHAIRMAN ZIEMER: So if you didn't 

19 have the vacuum cleaner you would have used 

20 what?

21 MR. ALLEN: I'm sorry. What?
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28 1 CHAIRMAN ZIEMER: In the absence 

2 of the vacuum cleaner, what value would have 

3 been used?

4 MR. ALLEN: We would have used 

5 external dose from the surface contamination 

6 we had calculated, which is the point I was 

7 going to say was that, I somewhat agree with 

8 John. There's no guarantee the uranium or 

9 whatever radioactivity inside that vacuum 

10 cleaner, was from the Mallinckrodt uranium.

11 It could have been from other 

12 sources from natural-type of active materials 

13 that that type of site would see. But that 

14 surface contamination could get concentrated 

15 and increase the dose in a small localized 

16 area.

17 MR. RAMSPOTT: Well, I guess the 

18 point I'm getting it is: the number you're 

19 using is from an inspection in '89 and, you 

20 know, you got to empty a vacuum cleaner, so 

21 it's been emptied. So whether it's some of 
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29 1 GSI's residual dust or it's uranium dust, the 

2 original is gone.

3 DR. ANIGSTEIN: This is Bob 

4 Anigstein. I'd just like to comment on this, 

5 but perhaps I could help clarify Dave's, if 

6 Dave doesn't mind my stepping in, because it's 

7 his area. It's just one comment on the spot.

8 What they did, I mean, it's in the 

9 report, but perhaps it needs to be 

10 highlighted. What ORNL did was they put a 

11 survey meter right flat against the vacuum 

12 cleaner. In other words, in contact with it. 

13 They took the exposure rate. What NIOSH did 

14 was: they assumed that a worker was in contact 

15 with this vacuum cleaner. Now, first of all, 

16 that's way overstatement because the survey 

17 meter has an active volume of a few cubic 

18 inches.

19 The volume of a human body is much 

20 larger than that, and yet we're assuming that 

21 the entire body got that dose rate. So even 
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30 1 if they were standing with that vacuum cleaner 

2 pressed against the abdomen, well, possibly an 

3 organ right there would have gotten that dose 

4 rate.

5 They were assuming that every 

6 worker in that place was, basically, hugging 

7 that vacuum cleaner for eight hours a day or 

8 their whole shift, and that is a very 

9 conservative bounding estimate.

10 However, the point of this is to 

11 bound the doses and it's highly unlikely that, 

12 even if there were any other gamma sources in 

13 the plant that had been overlooked, we're not 

14 talking about going back to '52 or '53, we're 

15 going back from '66 on, when there was no more 

16 uranium being brought in, and this is what 

17 NIOSH found.

18 This was the only thing that was 

19 found, and all I can say is, it seemed like a 

20 very conservative estimate to bound the doses. 

21 And I'm sure if there had been other sources 
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31 1 around, NIOSH and SC&A would have looked at 

2 them.

3 But, you know, we do the best we 

4 can. I don't think there's any site that ever 

5 has perfect data, that ever has the kind of --

6 in other words, if we had a time machine and 

7 could go back, say, we knew we were going to 

8 do this study and we were given adequate 

9 budget, we would have traveled back to July 

10 1st, 1966 and went around with a team of 

11 surveyors with survey meters and looking at 

12 the entire plant, along the railroad tracks, 

13 any place where plausible that uranium could 

14 have been, and we would have tried to find it.

15 But we do the best we can with 

16 what we have.

17 CHAIRMAN ZIEMER: Okay. Thank 

18 you.

19 DR. MCKEEL: Dr. Ziemer? I really 

20 would like to respond to the last couple of 

21 comments.
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32 1 CHAIRMAN ZIEMER: Sure.

2 DR. MCKEEL: My comment is that, 

3 no, the point is not to bound the dose, the 

4 point of the SEC and the residual period is to 

5 bound the dose with sufficient accuracy. 

6 That's the test, sufficient accuracy. And I 

7 would agree that the assumptions made with 

8 respect to that tiny vacuum cleaner in 1989 

9 are very conservative or claimant-favorable.

10 But my point is, it's really the 

11 larger point, that small vacuum cleaner is not 

12 representative of any plant-wide value of 

13 residual uranium at all. It's one point. One 

14 little, teeny-tiny area in the old betatron 

15 building that is separated by 100 yards from 

16 the rest of the plant complex.

17 And when Bob Anigstein says we try 

18 to do our best and no site has perfect data, I 

19 really have a problem with that kind of 

20 thinking. In an operation such as this, which 

21 is supposed to be based on good science, not 
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33 1 only is the data not perfect at GSI, there 

2 almost is no real measured data.

3 And I would suggest that at many, 

4 many, many sites that are on the record, the 

5 residual period is full of air breathing data, 

6 film badge monitoring data, all sorts of data, 

7 hard, measured data, that could be used to 

8 bound the dose with sufficient accuracy.

9 But to somehow say that the best 

10 we can do is sufficient, really means to me 

11 that, given any data at all, datum at all, one 

12 piece of data, a single piece of data, that 

13 NIOSH, I guess with SC&A's dissent, is willing 

14 to bound the entire residual period from 1966 

15 to 1992.

16 And the proper conclusion, the 

17 proper scientific conclusion, in my opinion, 

18 has been, from the very outset, that NIOSH 

19 lacks the data it needs to bound the dose in 

20 either the covered or the residual period with 

21 sufficient accuracy.
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34 1 So, no, I don't accept. The co2 petitioner, and I'm speaking for [Identifying 

3 information redacted], the petitioner as well, 

4 we do not accept the idea that trying to do 

5 our best, of course everybody tries to do 

6 their best with the data that's available, but 

7 the best you can do with this available data 

8 is to conclude that it's insufficient to say 

9 that NIOSH is able to reconstruct the dose and 

10 bound the dose during the residual period with 

11 sufficient accuracy. Thank you.

12 DR. ANIGSTEIN: I'd like to 

13 answer.

14 CHAIRMAN ZIEMER: Do you have a 

15 response, Bob?

16 DR. ANIGSTEIN: Let Dave go first.

17 CHAIRMAN ZIEMER: Yes.

18 MR. ALLEN: No, go ahead, Bob.

19 DR. ANIGSTEIN: Okay. Actually, 

20 what Dr. McKeel said about film badge data. 

21 There is film badge data during the residual 
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35 1 period because the Landauer film badge program 

2 continued right until GSI shut down operations 

3 at the end of 1973.

4 And during the residual period,

5 which looks over those data also, just like 

6 during the operational period, the vast 

7 majority of film badges read M for minimal, 

8 meaning less than detection limit, which is 

9 approximately 10 millirem per week.

10 So with a very small number, I 

11 have here in front of me, there were three 

12 cases during this whole period of July 1st, 

13 '66 through end of '73, where you had a large 

14 number, fair number, declining, but as their 

15 work activity declined, the number declined, 

16 but nevertheless, there were -- just doing in 

17 my head what it would be, seven and a half 

18 years times 50, so you had something like 1500 

19 weeks.

20 No, excuse me, that's wrong. 

21 Sorry. 350 weeks with anything from 30, 40, 
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36 1 50 workers per week, badges per week, and of 

2 those, there were only six which were over 

3 100 millirem, which is where it becomes a 

4 significant weekly dose, and one of them was 

5 in error.

6 So there were no exposures. If 

7 there had been some high sources of exposures 

8 during the residual period, you know, they 

9 only count if a human being was exposed to 

10 them, and we always assume that the badged 

11 workers would be most likely the ones with the 

12 highest exposures.

13 So I think that this NIOSH 

14 assumption is a reasonable one. I mean, 

15 that's SC&A's position.

16 DR. MCKEEL: This is Dan McKeel. 

17 I have to respond to that because the record 

18 has got to be crystal clear. Yes, it's true, 

19 there was some film badge data during the 

20 residual period, and let's be clear how much 

21 that was and what that data represented.
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37 1 There is Landauer film badge data 

2 on 108 individuals who were badged at GSI. 

3 All of those people were men who were 

4 radiographers who were either betatron 

5 operators or isotope operators. The workforce 

6 at General Steel that's included in the SEC 

7 105 Class is at least 3000, and some of the 

8 earlier year's newspaper reports suggest that 

9 they were hiring and it was higher than that.

10 So if you do that arithmetic, then 

11 the film badges cannot be representative of 

12 any more than 3 percent of the workforce.

13 And if you further calculate, as I 

14 have done in my reports several times, that 

15 the GSI radiographers wore film badges only 

16 part of the time, and that was while they were 

17 in the betatron buildings, not, for example, 

18 while they were along the whole uranium 

19 pathway, you know, and you multiply that times 

20 the number of hours, including the hours that 

21 should have been monitored in those unbadged 
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38 1 workers, as we've pointed out many times, who 

2 handled activated uranium and so forth, were 

3 exposed to the cobalt sources, exposed to the 

4 radium sources, exposed to the iridium 

5 sources, if any of those people had had 

6 badges, and they should have, then that should 

7 be figured into the person hours that we're 

8 talking about, then that 3 percent number 

9 decreases to about 0.3 percent.

10 You know, so there is a minuscule, 

11 non-representative amount of film badge data 

12 for GSI workers in only one job category, and 

13 there were hundreds of job categories at GSI 

14 and, in fact, the doses that NIOSH, and Allen, 

15 and SC&A, and Dr. Anigstein, have come up with 

16 in 2012 show a reversal.

17 In 2008, their models showed that 

18 the betatron workers got the highest doses and 

19 that the layout workers, that they say 

20 represent the rest of the workforce, had far 

21 lower doses by about a tenfold difference.
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39 1 Now that ratio has been reversed 

2 with new models, new assumptions, and compared 

3 to 2008, now the layout workers have the 

4 highest doses by far and the betatron operator 

5 doses have decreased by tenfold.

6 CHAIRMAN ZIEMER: We're getting 

7 out of the residual period.

8 DR. MCKEEL: Okay. I'm sorry.

9 CHAIRMAN ZIEMER: The residual 

10 period, it's unlikely that anybody's film 

11 badge is going to show something from uranium 

12 contamination. The uranium contamination 

13 really, as far as dose is concerned, is going 

14 to be an internal dose problem.

15 I can't imagine any levels that 

16 you could postulate of uranium contamination, 

17 even in the worst plants we've looked at where 

18 the external dose during the residual period 

19 is going to be the driver.

20 We've got to be looking here and 

21 the real issue on the residual period, I 
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40 1 think, is going to be internal dose and 

2 whether or not there's reasonable assumptions 

3 on the uptakes of the contamination, and that 

4 includes the resuspension and all of those 

5 kinds of things.

6 These external doses are going to 

7 be trivial compared to that, I would think. 

8 Dave, can you comment?

9 MR. ALLEN: Well, I mean, I agree. 

10 Like I said, we calculated from our surface 

11 contamination and found very little, but we 

12 were worried about that vacuum cleaner and the 

13 idea that it could be concentrated is why I 

14 used that. And like Bob said, we --

15 DR. ANIGSTEIN: This is Bob. I'd 

16 like to comment on one thing even though it's 

17 outside today's agenda, that's about the 

18 reversal between 2008, 2012. In 2008, we 

19 calculated doses to the layout men that were 

20 actually very close. They were competitive 

21 with the doses of the betatron operator. The 
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41 1 operator came out slightly ahead.

2 The reason for the change was, in 

3 that 2008, we did not have film badge data. 

4 The SC&A analysis was based on the most 

5 conservative assumptions about the radiation 

6 coming out of the betatron itself, about the 

7 shielding, about the work practices.

8 When we got to re-assess this, 

9 which we did earlier this year, the film badge 

10 data showed that the betatron workers got 

11 minimal doses. Your typical betatron worker 

12 left GSI, after however many years he was 

13 there, with minimal. Not a single film badge 

14 reading came out above M for minimal. That 

15 was a typical worker.

16 There was a minority of the 

17 workers, there were 23 film badge readings, 

18 two of which were due to the same worker, so 

19 there were 22 workers that had anything other 

20 than M, and of those 22, about half of them 

21 were given a single value of 10 millirem, 
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42 1 which is the lowest that is ever assigned.

2 Anything below that goes into the 

3 M category. So we, naturally, SC&A, 

4 naturally, took this into consideration, we 

5 revised our estimate, and then we went back to 

6 the layout men because during the time, even 

7 though he might have been alternating at his 

8 job as betatron operator, but during the time 

9 he was doing the layout work, he was not 

10 carrying his badge, so we assumed that there 

11 was an eight-hour-a-day full-time layout man 

12 in the worst possible location.

13 Then, again, we got additional 

14 information --

15 CHAIRMAN ZIEMER: But you've 

16 explained that before --

17 DR. ANIGSTEIN: Okay.

18 CHAIRMAN ZIEMER: -- and that's 

19 out of the residual period.

20 DR. ANIGSTEIN: Right. Okay.

21 CHAIRMAN ZIEMER: Let's stick to 
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43 1 the agenda here.

2 DR. ANIGSTEIN: Very good.

3 CHAIRMAN ZIEMER: Okay. So let's 

4 go on to your report, Bob.

5 DR. ANIGSTEIN: Okay. Well, to 

6 begin with, we've heard two reports, memos 

7 really, one, May 30th, the other one, June 8th 

8 it was released, and when I first started to 

9 review the residual period, the residual 

10 period is based on the deposition of uranium 

11 dust during the operational period.

12 So I went back and looked at the 

13 operational period, really, with a fresh eye 

14 after four years, and the first thing that 

15 caught my eye was a reference to Table 7.8, I 

16 believe it was, in the parent document, TBD17 6000, which was issued in 2006 by Battelle.

18 Dave Allen made some partial 

19 revisions in 2011, so I'll refer to it as 

20 Allen 2011. The portion that I'm referring to 

21 are identical in the two documents. I just 
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44 1 wanted to make reference to the latest 

2 document.

3 And I'll admit, I got confused, 

4 because I was looking at the Table 7.8 and it 

5 was hard to get those numbers out of 7.8, and 

6 I jumped to the conclusion, wait a second, if 

7 I take this number during the 1950 to '55 

8 period, which is stated in picocuries per day, 

9 and calculate the breathing rate and the 

10 exposure rate, I said, gee, I come up with the 

11 same numbers as in Appendix BB in dpm per day.

12 So I jumped to the conclusion, 

13 wait a second, they forgot to convert the 

14 units. That was an incorrect assumption, but 

15 Dave Allen came back and corrected, I looked 

16 back again, and the problem was, the reference 

17 should have been to Table 7.6, which lists the 

18 198 dpm per cubic meter on which 7.8 is based, 

19 but it was a little hard to follow.

20 So going back to 7.6 it was 

21 straightforward. And actually, it had been 
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45 1 obvious. I had found this in 2008, and over 

2 the four years, my memory of that might have 

3 been slightly imperfect and I redid it, and, 

4 as I said, I made an error.

5 So that was the reason for 

6 changing that thing. Going on, but we still 

7 had other issues. We had the issue with the 

8 resuspension rate. Sorry, resuspension 

9 factor, make sure I use a different quantity, 

10 and we had made this observation.

11 We didn't belabor it in the 

12 review, the 2008 review, of Appendix BB 

13 because we had, at the same time, John Mauro's 

14 on the line, was the lead on reviewing the 

15 TBD-6000.

16 So rather than raise the same 

17 issue in two reports we simply said, this 

18 issue has been handled already in TBD-6000. 

19 And it remained a finding in the TBD-6000 

20 issues matrix, which was never resolved 

21 because the 1 times 10 to the minus 6th per 
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46 1 meter remained in TBD-6000.

2 Dave Allen pointed out that this 

3 had been referred to, and that was correct at 

4 a slightly earlier time. Dave is just a 

5 couple of weeks behind times. That was 

6 correct that it had been referred to to the 

7 Procedures Work Group, which, Member Wanda 

8 Munn is on the phone, so she could attest to 

9 that.

10 And the Procedures Work Group 

11 found that the issue had been resolved in the 

12 latest version of OTIB-70 that was issued in 

13 March. And at the last Procedures Work Group 

14 meeting, it was decided that this is -- we 

15 thought, actually, Steve Marschke, who is our 

16 lead on reviewing procedures, was simply 

17 tasked with verifying that, in fact, it was 

18 resolved as the author, Mr. Sharfi, I believe 

19 his name is, of OTIB-70.

20 Now, OTIB-70, essentially, bounces 

21 the ball right back to the individual site 
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47 1 review team, you know, the site Work Group, 

2 and the NIOSH people, and the SC&A people 

3 involved for any particular site, they said it 

4 can vary and it has to be determined on a 

5 site-specific basis.

6 So given that, and as a matter of 

7 fact, at the very latest round, which is the 

8 latest review that I made, the memo of June 

9 8th, is, well, since there is some 

10 uncertainty, as always, we make the claimant11 favorable assumption.

12 And, as it happened, at the Mound 

13 site, NIOSH had agreed to use, for the 

14 inhalation of stable tritides, meaning 

15 chemically stable tritium metal compounds, 

16 they had decided to assign it 5 times 10 to 

17 the minus 5 as being a conservative upper 

18 bound.

19 It's not the highest number 

20 mentioned in OTIB-70. There are tables and 

21 reviews of the literature which go as high as 
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48 1 10 to the minus 2, but it's on the high end. 

2 It was the one that was used by NRC at one 

3 point in a document called NUREG/CR-5512 

4 Volume 3, senior author was Beyeler, and they 

5 had proposed 5 times 10 to the minus 5.

6 NRC took another look at it. CR 

7 stands for contractor, so this was a 

8 contractor report. NRC issued its own report, 

9 which is NUREG-1720, so if you don't see the 

10 CR, that NUREG means that it's a staff report, 

11 even though sometimes it's written with 

12 contractor help, but it means that the NRC 

13 stands behind it.

14 And that one said 10 to the minus 

15 6th, but that's only for a facility that has 

16 undergone cleanup. So all the easily 

17 removable contamination was removed. It had 

18 been swept, scrubbed, washed. If they wanted 

19 to remove all contamination they would have 

20 simply chipped away the concrete. It doesn't 

21 require it, but it's something that has been 
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49 1 cleaned up, and also, it's a quiet area. 

2 Nobody is stomping around, driving trucks over 

3 it, raising up dust. So during a quiescent 

4 stage, 10 to the minus 6 is a good number for 

5 a decommissioned facility.

6 So this would not apply to GSI. I 

7 mean, there may have been some washing, but we 

8 don't accept the fact that it was, certainly 

9 during the operational period, that this would 

10 be good. So the latest thing, which is 

11 actually an update from my earlier memo of May 

12 30th, because I hadn't looked at the OTIB, I 

13 wasn't aware of the Mound -- the precedent 

14 that was set by NIOSH.

15 So to be consistent and 

16 conservative I would say 5 times 10 to the 

17 minus 5. I mean, we're just throwing it on 

18 the table. We're not taking a rigid position 

19 on this, but we're just throwing it on the 

20 table that this might be a good number to use 

21 for resuspension.
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50 1 So resuspension would affect the 

2 residual period. It would also affect the 

3 exposure of workers in between betatron 

4 operations. Now, I'll go back and underline 

5 and italicize that, in between betatron 

6 operations.

7 During betatron operations, we 

8 agreed that the 198 dpm per cubic meter is a 

9 reasonable upper bound. This was actually 

10 measured during actual operation where there 

11 was more disturbance than would be true at 

12 GSI.

13 And also, I want to clarify and 

14 answer to a couple of Dr. McKeel's points 

15 about the uranium being moved throughout the 

16 plant. Sure, we recognize that, but this is a 

17 gigantic plant. I forget how many acres it 

18 was, and ten cleaning and finishing buildings, 

19 and a large number of other buildings.

20 The NIOSH analysis assumed that 

21 that 198 dpm per cubic meter prevailed 
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51 1 throughout the entire plant during the hours 

2 that uranium was handled.

3 Now, the uranium was not being 

4 handled in every building, even if it came in 

5 on the railway, as I recognize, and was 

6 handled on the loading dock, locally, you 

7 could have had some here, some there, some 

8 further down, it would not have been 

9 everywhere all at once.

10 So consequently, this, again, 

11 seemed like a conservative, claimant-favorable 

12 assumption. Now, as far as the hours, we do 

13 have an issue with that because the simple 

14 picture of half and half, half an hour for 

15 setup, half an hour for takedown, one hour for 

16 the shot.

17 First of all, that would not be 

18 the case even with the idea of a slice, which 

19 as I admit, most likely, it's not the only 

20 shape that was radiographed, but even with the 

21 slice, it would have required several shots. 
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52 1 So it would not be half an hour in-between 

2 each shot.

3 Also, some of the shots were 

4 shorter. There is a record of small-diameter 

5 rods at Weldon Spring being radiographed 

6 somewhere. And the somewhere, we'll assume, 

7 is GSI because I'm not aware of any other 

8 radiographic facilities for uranium in that 

9 area, so it might have very well been.

10 So the fraction of time inside the 

11 control room and inside the shooting room is 

12 variable. It's an uncertain number and I 

13 would suggest that we simply take the 

14 conservative approach and just say, if they 

15 worked 500 hours a year, just assume that that 

16 was for uranium handling, because the time 

17 spent by, say, the chain men loading it onto 

18 the railroad car, the little electric railcar 

19 inside the plant, may not have been figured. 

20 This may not have been.

21 When GSI billed Mallinckrodt, they 
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53 1 may very well not have included the time spent 

2 by the betatron team in setting up the shot, 

3 shooting it, and getting it out of the 

4 betatron building. My guess is they probably, 

5 Mallinckrodt and AEC may have raised an 

6 eyebrow and said, wait a second, you're 

7 charging us $16 an hour for simply 

8 transporting it from one place to another?

9 So it may not have included that, 

10 but it was probably not that much time. So if 

11 you make this other assumption that no time 

12 was spent in the control room, that would seem 

13 to offset any time outside the betatron 

14 building where the uranium might have been 

15 handled, not just sitting, but just handled, 

16 so that there was some disturbance.

17 So we think that if they simply 

18 eliminate the factor of 2, we will be 

19 comfortable with the rest of that. And let me 

20 just take another glance. I think that sums 

21 up the -- oh, yes, and the hours themselves, 
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54 1 we would even go slightly -- I just made the 

2 argument that maybe it should have been 500 

3 for the early years, 500 hours or 450, when 

4 rethinking it, why not just -- since we don't 

5 know, really, what was going on during that 

6 time.

7 In other words, we have the '53 to 

8 the first quarter of '58, but let's just say a 

9 round number, '53 through '57, so that's five 

10 years, where we don't have firm information on 

11 the hours, and then we have '58 through '66, 

12 which is eight years, eight and a quarter, 

13 where we do have detailed data.

14 So 8 out of 13 years is a good 

15 sample and I would take the highest of those 

16 years, not the first, but just going back 

17 over, take the highest, because that's what we 

18 do with a lot of other data.

19 If you do a co-worker, we say, 

20 well, don't know what this person got because 

21 he was not monitored, but other workers were 
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55 1 monitored, and a conservative value would be, 

2 let's just say he got the highest dose of all 

3 the monitored workers.

4 It's unlikely that he would have 

5 gotten higher. That's the same thing I would 

6 say here. For those five years, give it the 

7 highest number of hours of any year covered by 

8 those purchase orders. And again, the 

9 increase is not huge. It goes from something 

10 like 337 hours to 437 hours a year, if I 

11 remember correctly.

12 So with those modifications or 

13 suggestions, we think that the internal dose 

14 analysis, both for the operational period and 

15 for the residual period, is reasonable, 

16 claimant-favorable, and sufficiently bounding. 

17 So that's basically our position.

18 CHAIRMAN ZIEMER: Okay.

19 DR. ANIGSTEIN: John Mauro, do you 

20 have anything to add on this?

21 DR. MAURO: No, you did a 
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56 1 wonderful job, Bob. Thank you. 

2 DR. ANIGSTEIN: Thank you.

3 DR. MAURO: I think you covered 

4 everything we've been working on and talking 

5 about.

6 CHAIRMAN ZIEMER: Any questions, 

7 Work Group Members, for Bob? Or others have 

8 questions? Okay. Then we want to hear from 

9 Dr. McKeel. You have his document of June 1st 

10 and, Dr. McKeel, if you would, to focus, I 

11 think the issues relating to sort of NIOSH 

12 procedures, and tasking, and so on, I don't 

13 want us to get into that here.

14 I think that's something you will 

15 work with Ted on, but can we focus on your 

16 technical issues?

17 DR. MCKEEL: Yes, sir. This is 

18 Dan McKeel, can you hear me all right?

19 CHAIRMAN ZIEMER: Sure.

20 DR. MCKEEL: Okay. I'm going to 

21 focus entirely on the residual period. The 
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57 1 first comment I'd like to make is that, when 

2 you reviewed the papers that I had submitted. 

3 On 6/13, I submitted a four-page response to 

4 the Allen June 8th, 2012 memo, and I sent that 

5 to everybody in the Work Group; all the Work 

6 Group Members; Doctors Anigstein and Mauro, 

7 and also sent it to Dr. Neton and to David 

8 Allen.

9 So that comment needs to be 

10 entered on the record and it was sent --

11 CHAIRMAN ZIEMER: Oh, thank you. 

12 Great.

13 DR. MCKEEL: Okay.

14 CHAIRMAN ZIEMER: And the date on 

15 that was?

16 DR. MCKEEL: 6/13.

17 CHAIRMAN ZIEMER: 13?

18 DR. MCKEEL: Yes.

19 CHAIRMAN ZIEMER: June?

20 DR. MCKEEL: Right. Let's see. 

21 So the next point I'd like to make is, since 
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58 1 we were just finishing with the SC&A 

2 presentation, while I have it front of me 

3 here, on the very last page, on Page 3 of this 

4 June 11th SC&A memo, it states that in Allen 

5 6/08, it stated that all new GSI assessments 

6 would be based on 3250 hours, so that was no 

7 longer an issue.

8 Well, I think the issue is that 

9 everyone has agreed on the 3250 hours, and I'm 

10 talking about SC&A and NIOSH, since the 

11 October 2007 meeting when that number was 

12 established, and it has not been incorporated 

13 into a revision of Appendix BB.

14 So although everybody may agree 

15 with it, and may use it in calculations and 

16 technical papers, as far as being incorporated 

17 into Appendix BB, that hasn't taken place.

18 CHAIRMAN ZIEMER: Right. The Work 

19 Group has also approved that and we're 

20 certainly aware of -- it's sort of an internal 

21 NIOSH thing as to when the revision will 
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59 1 occur. So, yes, I understand the frustration 

2 there, Dan, but go ahead.

3 DR. MCKEEL: Well, as I said 

4 before, it's not a matter of frustration, it's 

5 a matter of --

6 CHAIRMAN ZIEMER: Well, I think it 

7 is.

8 DR. MCKEEL: The fact is, Dr. 

9 Ziemer, that NIOSH wrote to me and said the 

10 reason that they had not revised Appendix BB 

11 by now is because they were waiting, and I 

12 presume still are waiting, this was from 

13 Stuart Hinnefeld, the Director of DCAS, that 

14 they were waiting for the Work Group to 

15 conclude its deliberations on Appendix BB 

16 issues.

17 CHAIRMAN ZIEMER: Right.

18 DR. MCKEEL: And those still 

19 haven't been clarified. And in fact, Ted Katz 

20 wrote me recently that there probably would be 

21 a meeting about resolving those, but that 
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60 1 meeting hasn't yet been scheduled. So anyway, 

2 moving on.

3 The next thing I want to talk 

4 about is the Brownfield letters that are 

5 mentioned by David Allen in his 6/08 

6 memorandum. And the Brownfield letters refer 

7 to a payment that GSI is making for $48 to 

8 Mallinckrodt Weldon Springs.

9 And the idea that both NIOSH and 

10 SC&A seem to accept, or at least they didn't 

11 question in their reports, is that that 

12 purchase order refers to uranium. Well, the 

13 letters themselves don't say anything about 

14 uranium.

15 And what John Ramspott and I want 

16 to point out to you is that, there is, on 

17 record, a purchase order that Mallinckrodt 

18 uranium division issued to General Steel 

19 Industries for a piston rod and that would be 

20 a purchase order that they called U-83621-F, 

21 and that can be found on Page 30 of the FUSRAP 
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61 1 IL.28-5 report on GSI.

2 And that's the major report that 

3 contains all the purchase orders. So the 

4 Brownfield letters that Dave Allen refers to 

5 are on Pages 17 and 21 of that document, and 

6 the piston rod purchase order is on Page 30.

7 So Mr. Ramspott and I would 

8 suggest that those two letters by Brownfield, 

9 which really don't figure in the calculations, 

10 and should not, under any circumstances, be 

11 construed as any evidence that NIOSH has more 

12 data on GSI uranium shipments from 

13 Mallinckrodt prior to the first purchase order 

14 in 1958; they don't. And those letters should 

15 not be used as any kind of proof of that fact.

16 Okay. The second thing I want to 

17 talk about is just to remind everyone that, 

18 when we're talking about the TBD-6000, the 

19 parent document, and the slug production 

20 facility, that this is surrogate data that has 

21 to be used because there is no uranium, 
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62 1 surficial or surface, surveys before the 1989 

2 ORNL survey, which we've talked about this 

3 morning.

4 The second this is that, ORNL, in 

5 1989, in their reports, provides no 

6 justifications why it limited its surveys to 

7 only the two GSI betatron facilities. So 

8 except for postulating that might have been a 

9 cost-saving measure, we don't know about that.

10 The third thing I'd like to say is 

11 that, both the Board and NIOSH have developed 

12 discrete surrogate data criteria by which they 

13 judge the use, and appropriateness of use, of 

14 surrogate data from one site being applied to 

15 another site.

16 And in my comments, including the 

17 one from yesterday and the previous one, I 

18 pointed out, and previously, that there has 

19 been no justification that the slug facility 

20 was similar enough to GSI to make that a valid 

21 source of surrogate data.
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63 1 And in fact, Dave Allen outlined 

2 many differences in even the type of source 

3 term, that is that the slugs were smaller, 

4 they had been cleaned of their crust and their 

5 magnesium fluoride crust, with its 

6 concentration of contaminate radionuclides, so 

7 the source terms were different and what was 

8 done with the source terms was different.

9 So the uranium at GSI, of course, 

10 was bombarded with 24/25 MeV betatron, which 

11 not only activated it, but also, as we've 

12 demonstrated through published peer-reviewed 

13 literature, actually caused fission, at very 

14 low levels, but caused fission of up to 1 or 2 

15 percent of the uranium molecules.

16 So I just don't think those two 

17 facilities are comparable at all and I want to 

18 put on the record that we do, the petitioners, 

19 object to using the slug facility as surrogate 

20 data.

21 We've already talked about the 
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64 1 uranium route at GSI and I guess the surrogate 

2 data issue is the one that I would point to 

3 about this. I understand that the slug 

4 facility airborne uranium concentration, the 

5 air concentration, that's what's used for all 

6 the plant at GSI. I appreciate that fact.

7 But the point is, this blind 

8 acceptance that a value from a completely 

9 different facility, with lots of data, can 

10 just be, by fiat, applied to GSI, and that 

11 that is a sufficiently accurate bounding, and 

12 that it's a claimant favorable one. You don't 

13 know that.

14 And again, I point out, you can do 

15 all the reasoning you want to, all the 

16 calculations you want to, all the modeling 

17 with computer code that you want to, but you 

18 don't actually know what the airborne 

19 concentration of uranium was at General Steel 

20 Industries at any time from 1952 through 1992. 

21 So that's all I really want to say on that 
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65 1 point.

2 The fifth point I want to bring up 

3 is that, we have now had very good and 

4 thorough explanations of why SC&A believes 

5 that the resuspension factor used in TIB-70 is 

6 inappropriately low by a factor of about 

7 twofold for GSI.

8 And I just want to say that the 

9 petitioners agree with that sort of reasoning 

10 and believe that a higher resuspension factor 

11 should, in fact, be used for GSI. So I think 

12 that's an issue that needs to be resolved by 

13 the Work Group and by the full Board.

14 The other comment I want to make 

15 is that, on the last page of the first SC&A 

16 response to Dave Allen, not to Dave Allen, but 

17 just on the first reviewed memo of May 30th 

18 that SC&A wrote about this topic.

19 They mention the formula developed

20 by Sharfi and the Procedures Review 

21 Subcommittee, and they mention that this 
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66 1 formula could be used to calculate the 

2 midpoint of the uranium levels in the air 

3 during the residual period, and that, based on 

4 that, you could provide a uranium amount in 

5 the air for each year of the residual period.

6 So again, this is a house of cards 

7 built on a house of cards. It's taking an 

8 assumption from two surrogate document 

9 sources, TBD-6000 and TIB-70, and coming up 

10 with a derivative formula that allows you to 

11 make a calculation of data that didn't, in 

12 reality, exist at all.

13 And, you know, there are recent 

14 analogies to that, I believe, in the financial 

15 world. And anyway, I think it's wrong, 

16 scientifically, and I hope the Work Group will 

17 reject that type of reasoning.

18 The final thing I want to say is 

19 about the last point that was discussed by Dr. 

20 Anigstein. We've talked about the use of the 

21 3250 hours, but that number, you know, is more 
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67 1 solid because it's backed up by worker 

2 testimony.

3 There's a lot of hours calculation 

4 that are made at GSI based solely on the 

5 presence of purchase orders from Mallinckrodt 

6 uranium division. And the point that has 

7 always struck me about those purchase orders 

8 is that, in and of themselves, they really 

9 don't prove anything about uranium actual 

10 usage at GSI.

11 They are a purchase order. 

12 There's no confirming receipt that GSI 

13 received that amount of uranium from 

14 Mallinckrodt. There's no receipts from 

15 Mallinckrodt that GSI ever returned a given 

16 amount of uranium to them. There are no shot 

17 records of the betatron shot records, which we 

18 know existed, by which you could gauge all 

19 that.

20 So, you know, I think that also --

21 and it does reflect on the uranium mass, the 
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68 1 source term itself, that was present during 

2 the residual period. If we don't know, with 

3 sufficient accuracy, the source term for 

4 uranium that existed at GSI during the 

5 operational period, how could we possibly 

6 accurately know the source term mass during 

7 the residual period? And I suggest we can't 

8 do that.

9 So I guess that concludes my 

10 thing. I really appreciate the opportunity to 

11 address the Work Group one more time and I'll 

12 be interested in the further deliberations for 

13 the afternoon. Thank you very much.

14 CHAIRMAN ZIEMER: Okay. Thank 

15 you, Dan. Questions for Dr. McKeel.

16 DR. ANIGSTEIN: Yes. This is Bob. 

17 Three comments. One is about the Brownfield 

18 memo, which is really the same memo that was 

19 sent out twice, once in February and I think 

20 once in June, or later in the year, in the 

21 latest SC&A memo of June 8, we do make the 
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69 1 statement that we don't think that this is --

2 we didn't question that it was tied uranium, 

3 we just said, it does not cast any light on 

4 the usage on the monthly hours.

5 So I think that's a non-issue and 

6 NIOSH also did not also explicitly base its 

7 hours on that. It simply said that, maybe the 

8 hours were less.

9 As far as the purchase orders, 

10 these are limits. These are legal limits that 

11 said, you will not bill us any more than. The 

12 earlier ones where I said this is the 

13 estimated amount, the later one, in later 

14 years, they said, this is the limit. We're 

15 not authorizing you to do any work to exceed 

16 these purchase orders.

17 And being a commercial entity, 

18 there's no reason they would have done more 

19 work than they were being paid to do.

20 DR. MCKEEL: Dr. Anigstein?

21 DR. ANIGSTEIN: Yes.
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70 1 DR. MCKEEL: How can you be 

2 positive that the purchase orders that exist 

3 now are all of the purchase orders that were 

4 issued? And I suggest you can't possibly know 

5 that.

6 DR. ANIGSTEIN: They are 

7 continuous. Starting with March 1958 going 

8 through June 30th, 1966, they are continuous.

9 DR. MCKEEL: I understand that, 

10 but how do you know there were not purchase 

11 orders before 1958 that we don't know about?

12 DR. ANIGSTEIN: Oh, no, of course. 

13 That's the whole point. NIOSH and SC&A agree 

14 that, prior to 1958, there was some uranium 

15 work being done. The only documentary 

16 evidence, besides the Brownfield memo, the 

17 February, which is just prior to the first 

18 purchase order that we have on record, there 

19 is only the cryptic one-liner, which is 

20 apparently a cover sheet to some other 

21 documents, which no longer exist, and it says, 
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71 1 and I'm going by memory now, regarding General 

2 Steel, or General Steel Castings, uranium 

3 ingots, something about X-rays of uranium 

4 ingots done by General Steel Castings.

5 And it's dated December 1953. And 

6 apparently, it's a cover sheet to a file, 

7 which doesn't exist, so that's the only 

8 evidence that work was done prior to -- you 

9 know, going back as far as 1953. And the DOE 

10 finding as part of the FUSRAP program, long 

11 before the current EEOICPA was even thought 

12 of, said that it may have started as early as 

13 1953.

14 And also, just to go on record, in 

15 answer to something else Dr. McKeel's longer 

16 submission a little earlier that I believe he 

17 refers to as the 11-pager, we also made the 

18 observation that the work may have started as 

19 early as 1952. It couldn't have started any 

20 earlier because they didn't have a betatron.

21 But early in 1952, I found a short 
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72 1 notice in the New York Times, obviously based 

2 on, probably, a publicity release from General 

3 Steel, saying that this 24 MeV betatron has 

4 been installed by the Army in Granite City in 

5 January '52.

6 So our position has always been 

7 that '52 should be included, but since it is 

8 not up to NIOSH or the Work Group to make this 

9 determination, DOL has not acted on that, but 

10 that, you know, is one of the issues we raised 

11 in our comments on Appendix BB.

12 And if I can just finish up, the 

13 last comment Dr. McKeel raised about we don't 

14 know the mass of uranium. Well, true, they 

15 don't know the tonnage of the uranium ingots, 

16 but none of the analysis uses that 

17 information. It's not needed.

18 We simply say there was enough 

19 uranium to give us this concentration of a 198 

20 dpm per cubic meter, because that's the 

21 highest that was recorded for this type of 
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73 1 operation. And the volume of the uranium is 

2 not what's at issue. It's how much 

3 disturbance is going on.

4 DR. MCKEEL: Dr. Anigstein.

5 DR. ANIGSTEIN: Yes.

6 DR. MCKEEL: You're replying to my 

7 comments and I've got to reply to yours.

8 DR. ANIGSTEIN: Excuse me? I have 

9 to reply to your comments.

10 DR. ANIGSTEIN: Sure.

11 DR. MCKEEL: Once again, let's 

12 take it in reverse order. No, what I'm saying 

13 is that, the slug facility, the surrogate 

14 data, where you get the 198 figure, is not

15 based on GSI data at all.

16 DR. ANIGSTEIN: I agree.

17 DR. MCKEEL: It's based on data 

18 from another place --

19 DR. ANIGSTEIN: Correct.

20 DR. MCKEEL: -- that has not been 

21 shown to be similar enough, I think, to GSI. 
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74 1 And the second thing is, when I asked Dave 

2 Allen about the Brownfield memos, he told me 

3 that, certainly, SC&A knew about those in 2008 

4 and pointed me to a November the 10th, 2008 

5 Work Group meeting where, on Page 103, you, in 

6 fact, did allude to two letters that talked 

7 about shipments with Mallinckrodt that were 

8 before the advent of the purchase orders, but 

9 that's all you said.

10 You didn't say anything about what 

11 they were, or what the source was, or where 

12 they were from --

13 DR. ANIGSTEIN: Yes, but in my 

14 June 8th memo I specifically discussed the 

15 Brownfield memos.

16 DR. MCKEEL: Yes, I understand 

17 that.

18 DR. ANIGSTEIN: Okay.

19 DR. MCKEEL: But I'm talking about 

20 what Dave Allen told me. And then he also 

21 said that I knew about them in 2008 because my 
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75 1 name showed up on Page 104 of that same 

2 transcript, so I got the transcript and read, 

3 and actually, what I said on Page 104 and Page 

4 105 amplifies what you just said about the New 

5 York Times article showing that the Army 

6 actually installed the betatron January 1, 

7 1952.

8 And what I put on the record was 

9 that John Ramspott and I went over to the 

10 Missouri Historical Society, got the GSI Board 

11 minutes for 1952, '52, and it's quite clear in 

12 there that, not only did they have on record 

13 that the government built and tried to give to 

14 them the betatron, the betatron facility, and 

15 several other facilities at General Steel 

16 Industries, and that the Board, later in 1952, 

17 actually turned down the offer to accept those 

18 as a gift and take care of them.

19 So I think there are two good 

20 pieces of evidence that there was a betatron 

21 installed at GSI and I think it's a very 
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76 1 reasonable comment of yours and I think, I 

2 actually, it should actually be persuasive to 

3 the Department of Energy that, maybe, the 

4 uranium operation started in 1952 rather than 

5 1953, but that's an issue for another time.

6 And anyway, I think I would just 

7 make my final comment that the purchase 

8 orders, I agree with you, they are continuous 

9 from the first one in '58 through '66, 

10 however, my comment about the lack of 

11 corroborative evidence that those amounts were 

12 actually shipped; maybe the mass term is 

13 lower.

14 But I'm just saying that, in and 

15 of themselves, all they are is a statement of 

16 what could be done. And I think we've all 

17 been in industry long enough that we know 

18 perfectly well that, purchase orders get 

19 modified at the last minute, a note, or a 

20 call, is made that's not recorded on paper, 

21 and that, sometimes, purchase orders are 
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77 1 changed.

2 And particularly, in an area like 

3 uranium production for nuclear production 

4 during the 1950s and 1960s, the requirements 

5 of the AEC and Mallinckrodt for that kind of 

6 work, I'm sure, was shifting all during that 

7 period.

8 So I just would say that purchase 

9 orders are a valuable resources, but they're 

10 not the total picture. Thank you very much.

11 DR. ANIGSTEIN: If I can just make 

12 a minor comment on this. As an employee of a 

13 government contractor, and being a project 

14 manager on other contracts, I can say, you 

15 don't bill the government for anything that 

16 you're not authorized to bill.

17 If we found that we got a contract 

18 for X number of work hours, X number of 

19 dollars, during a given year, whoops, we found 

20 that the work is going to take more time, each 

21 and every time we would have our contracts 
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78 1 manager write a letter to the relevant 

2 government agency's contract manager, contract 

3 officer, and say, you know, we request an 

4 amendment of our contract due to the following 

5 reasons, and this how much more.

6 And usually, they would agree, and 

7 we would get a new and amended contract, 

8 Amendment Number 2, Amendment Number 3, 

9 Amendment Number 4, to the contract as 

10 necessary before we could bill a single penny 

11 in excess of the authorized amount.

12 So those purchase orders, it could 

13 not have been done by a verbal because 

14 Mallinckrodt was working for the government. 

15 They were not going to pay GSI unless the 

16 government paid them. And they would need a 

17 paper trail. So it's highly unlikely that 

18 such a thing would have taken place without a 

19 paper trail.

20 MR. RAMSPOTT: Dr. Ziemer?

21 CHAIRMAN ZIEMER: Yes. Comments?
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79 1 MEMBER BEACH: Paul, this is 

2 Josie.

3 CHAIRMAN ZIEMER: Yes, Josie, go 

4 ahead and then John Ramspott.

5 MEMBER BEACH: Okay. Sorry to cut 

6 in on you, John, I want to make two points, or 

7 ask two questions, basically, the first one is 

8 on the surrogate data issue. We haven't heard 

9 from SC&A about the comparison between the 

10 Board criteria on surrogate data, so I'm 

11 interested to hear SC&A's take on that.

12 And then the other one is for 

13 NIOSH, the resuspension factor being too low. 

14 On Page 3 of your report you say, in Bullet 

15 2, that this should go back to the Procedures 

16 Work Group and the Procedures Work Group sends 

17 it back to our Work Group, so I want to hear a 

18 little bit more about that.

19 DR. ANIGSTEIN: John, would you 

20 answer that? The first part.

21 DR. MAURO: Yes, perhaps I could 
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80 1 weigh in. This is John Mauro. Josie, you're 

2 correct. Very often, when surrogate data has 

3 been used, especially at these AWE facilities, 

4 we usually have a separate section that says, 

5 okay, let's review the surrogate data and how 

6 it was used against a five-board criteria. We 

7 have not done that.

8 MEMBER BEACH: Okay. I would like 

9 to see something like that done, Paul.

10 DR. NETON: Paul, this is Jim 

11 Neton, I think the TBD-6000 was reviewed and 

12 approved for use as surrogate data. I mean, 

13 it's a little different here because it's 

14 based on multiple sites. It's not just a 

15 single abstraction from, like, one facility to 

16 another.

17 CHAIRMAN ZIEMER: Right. TBD18 6000, the findings matrix on TBD-6000 has been 

19 completed and those issues are closed, and 

20 you're right, this is not a single site that 

21 TBD-6000 is based on. There's kind of a 
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81 1 compilation of sites, and I don't recall off 

2 the top of my head what all they were, Jim. 

3 Do you recall?

4 DR. NETON: I can't recall off the 

5 top of my head, but it was several different 

6 documents that were written in the early years 

7 of AEC operations.

8 CHAIRMAN ZIEMER: Yes. But I 

9 think in certain sense, we've assumed that the 

10 appendices under that are appropriate, but 

11 explicitly, I don't think we have established, 

12 and I think Dr. McKeel's question is certainly 

13 a valid one that, you have to, in essence, 

14 establish that the parent document is an 

15 appropriate surrogate for the appendices for 

16 which it's being used.

17 Keep in mind that a lot of these 

18 things occurred, sort of, concurrently, the 

19 surrogate data criteria were being developed, 

20 sort of, at the same time as some of these 

21 others. And so we have sites that were 
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82 1 handled in the absence of explicit surrogate 

2 data approaches and we have others that the 

3 surrogate data criteria were specifically 

4 addressed as part of the analysis.

5 I'm quite certain that we haven't 

6 done a surrogate data analysis for GSI 

7 relative the parent document.

8 MEMBER MUNN: This is Wanda. I 

9 have to comment that we have had a great deal 

10 of discussion with respect to the impression 

11 that there is something truly mysterious about 

12 uranium metal, that there are many things that 

13 are unknown about uranium metal.

14 This bears on the surrogate data 

15 issue. Uranium metal has been very thoroughly 

16 handled, very thoroughly studied, and very 

17 thoroughly analyzed over the last, almost, a 

18 100 years. And we certainly do know a great 

19 deal about uranium and what its 

20 characteristics are, both physically and 

21 chemically.
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83 1 There's nothing very mysterious 

2 about the uranium that is in question at GSI. 

3 That's not really in question. It's known 

4 what it is. Therefore, when we assert that 

5 there is something unusual about the 

6 "surrogate data" here, we're not really posing 

7 a question that is a valid one, simply 

8 because, this is not the kind of surrogate 

9 data issue that we normally address.

10 This is a simple straightforward 

11 issue with respect to what can be anticipated, 

12 what can be shown, to be exposures that can be 

13 gained from a known metal over a known period 

14 of time, and that's what's been done here.

15 There's nothing very mysterious 

16 about uranium. We know uranium as we know how 

17 it behaves. We know what its source term is.

18 DR. MCKEEL: Dr. Ziemer, this is 

19 Dan McKeel. May I comment, please?

20 CHAIRMAN ZIEMER: Sure.

21 DR. MCKEEL: Well, to Wanda Munn's 
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84 1 comment. I would disagree. I think there is 

2 a lot known about uranium metal, and actually, 

3 I have labored hard to get into the record 

4 that we have not addressed the Work Group, 

5 SC&A and NIOSH, have not addressed some of the 

6 key issues that really have to be researched 

7 and documented in order to know exactly what 

8 uranium came over to Mallinckrodt from both 

9 the Weldon Spring site and from the 

10 Mallinckrodt Destrehan Street site.

11 There is even a question about the 

12 mix of uranium that came over as ingots; as 

13 dingots. Ingots and dingots, by the way, if 

14 you look at the total chemical composition of 

15 the uranium plus the outer crust, it's 

16 different between those two.

17 And for Dave Allen to say the main 

18 form of uranium that was deposited on the 

19 surfaces was oxides, may not be true. I am 

20 sure that those chains rubbed off some of the 

21 magnesium fluoride crust with its contaminant 
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85 1 radionuclides.

2 Mallinckrodt and Weldon Spring, 

3 and all the other uranium production 

4 facilities, went to great lengths and did many 

5 experiments, that are documented in technical 

6 reports, to get the uranium content as pure as 

7 possible, but no matter how hard they tried, 

8 that's not possible.

9 You know, and there were trace 

10 contaminants that matter. Now, in a pure, 

11 fresh uranium metal ingot, you know, we know a 

12 lot about it. But then you have to know how 

13 old that was to know how those daughter 

14 products factored in and so forth.

15 And you can take two views. One 

16 is, you can say, all of that is unimportant 

17 and insignificant, but to say that we know 

18 all, everything, about the uranium from the 

19 Mallinckrodt Uranium Division to GSI, is 

20 simply not square with the facts.

21 There's evidence that they used 
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86 1 some recycled uranium, and that's even 

2 acknowledged in the NIOSH technical reports.

3 MEMBER MUNN: And no one has ever 

4 said that any of the exposures were 

5 insignificant. What I said was that they can 

6 be -- what I inferred was, that they could be 

7 bounded. We know enough about the metal to 

8 know that we can bound them and we can bound 

9 them with a good degree of scientific 

10 accuracy.

11 That's what NIOSH has gone out of 

12 their way to attempt to do and has, in fact, 

13 done with respect to the folks who worked at 

14 GSI.

15 DR. MCKEEL: Well, you get to make 

16 the recommendation, and I respect that that's 

17 your opinion, and, you know, I tried to put on 

18 the record why I do not think that's an 

19 accurate assessment, but that's where I think 

20 it needs to rest.

21 What the statement that you said 
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87 1 is that, the physical and chemical composition 

2 of the uranium sent to GSI was not in 

3 question, we know what it is. And I'm saying, 

4 it is in question, and you don't know what it 

5 is, and Mr. Thayer, who's the head of 

6 Mallinckrodt, has a table, that John Ramspott 

7 sent you, about the composition of some of 

8 their uranium products.

9 And the composition of it, 

10 chemically, changes from run to run, from 

11 ingot to ingot.

12 MEMBER MUNN: To clarify --

13 DR. MCKEEL: And I understand what 

14 you say that there are no significant 

15 differences, but the truth of the matter is 

16 that, if you looked at the universe of metal 

17 products in any one Class, let's say, ingots, 

18 or more to the point, let's say dingots, the 

19 direct ingot process, and you actually had a 

20 table of all the chemical compositions of each 

21 and every dingot that Mallinckrodt produced, 
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88 1 I'm sure you'd find differences.

2 You might say they're small, but 

3 I'll bet you there would differences in 

4 measured radioactivity, let's say, of a 

5 counter placed 1 inch away from the surface of 

6 the dingots. So, you know, I've seen that in 

7 many technical reports.

8 So to say that we have sufficient 

9 information, I guess that comes down to your 

10 definition of what is sufficient accuracy. 

11 And my overall comment that I'm going to make 

12 to the Board six days from now is that, it's 

13 amazing to me, and it is true, that the 

14 definition of sufficient accuracy is still 

15 being established, that NIOSH is charged, as 

16 one of its recommendations under the ten-year 

17 review, to further define sufficient accuracy.

18 So, you know, at the moment, 

19 that's a definition, operational, it's an 

20 operational definition, and it certainly 

21 varies among individual observers.
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89 1 And then the final comment I have 

2 to make is, I'm not clear, from what the 

3 discussion was, but what is the answer to 

4 Josie Beach's request? And that was that she 

5 would like to know how the surrogate data 

6 criteria apply to GSI and the slug facility, 

7 and I would too.

8 And I don't think it's clear what 

9 the Work Group is going to do about that. 

10 Thank you.

11 MEMBER MUNN: I wanted to clarify 

12 on one statement. Yes, there are, in fact, 

13 differences from ingot to ingot which can be 

14 identified with finely-tuned instruments. 

15 That does not change the fact that enough is 

16 known about the activities, and the about the 

17 type of metals that we're dealing with, to be 

18 able to sufficiently bound them, and that is 

19 my point. The only point I wanted to make.

20 DR. MCKEEL: Well, this is Dan 

21 McKeel, I have to make one final comment. 
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90 1 There is well-documented AEC technical reports 

2 from Weldon Spring that show that they were 

3 alloying uranium with various alloys, uranium 

4 dingots now, that they were alloying them with 

5 various trace components.

6 And the point of this was to 

7 stabilize those dingots as uranium fuel 

8 elements in the Hanford reactors where you 

9 work. And they did that for several years. 

10 They tinkered with the composition and then, 

11 finally, they decided that the tinkering 

12 really hadn't resulted in a more stable 

13 product, so they went back to a more baseline 

14 configuration.

15 So I'm saying that, even during a 

16 two or three-year period, the basic structure 

17 of dingots changed. They made experimental 

18 dingots and some of those, undoubtedly, found 

19 their way over to GSI, although, that 

20 information is not very well documented on the 

21 record we have available to us.
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91 1 But the fact that those 

2 experiments were going on, and those 

3 manipulations were taking place at Weldon 

4 Spring, is very well documented. So I really 

5 need to be quiet about this, but when comments 

6 like that are made I just must respond to 

7 them. So thank you very much.

8 CHAIRMAN ZIEMER: I'll make a 

9 comment here and then we're going to hear from 

10 John Ramspott. I think John's been waiting in 

11 the queue. My understanding of the TBD-6000 

12 document is that there's a sufficient number 

13 of different facilities from which the data 

14 has been used that it purported to cover, sort 

15 of, the spectrum of the types of uranium 

16 materials, and alloys, and forms that one 

17 would find.

18 It certainly, in terms of the 

19 exposure rates, would be hard to imagine an 

20 alloy having a higher exposure rate than pure 

21 uranium, so an alloy, itself, would be bounded 
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92 1 by the pure uranium values that one would 

2 otherwise use.

3 All right. John Ramspott, you had 

4 a question that you were waiting.

5 MR. RAMSPOTT: Thanks, doctor. 

6 Yes, it was a clarification in response to Dr. 

7 Anigstein's comment that there was really no 

8 early proof of uranium work at GSI based on 

9 the purchase orders, except for one little, I 

10 think he said, sketchy letter.

11 And I question that because, I'm 

12 actually looking at an AEC research and 

13 development report, NYO--1358, dated October 

14 15th, 1953, and that report clearly spells out 

15 that the pilot plant uranium from Mallinckrodt 

16 was betatron tested.

17 So there's definitely other proof 

18 besides some sketchy little letter. The fact 

19 that the POs don't exist from '53 to '58, I've 

20 said earlier, and I still feel positive that, 

21 if you look, the Weldon Spring plant opened in 
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93 1 June of '58. The Destrehan plant transferred 

2 everything out there.

3 When you transfer one massive 

4 plant to a wholly different plant, there's a 

5 lot of things that can happen. If you look at 

6 the purchase orders, you'll see there is 

7 actually two separate purchasing departments. 

8 So the fact that early purchase orders don't 

9 exist, I would have to say that's probably 

10 because somebody didn't look for them with the 

11 MCW documents.

12 And the other point, maybe today, 

13 nobody does anything for the government unless 

14 they have a PO, but I'd like to ask everybody 

15 just to keep in mind the two attachments, and 

16 I was off the phone, I had to take care of 

17 some business real quick, when you were 

18 talking about the two attachments, A, B 

19 letters, talking about some work done for 48 

20 bucks.

21 All you have to do is look at 
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94 1 those letters and they actually say they did 

2 work for Mallinckrodt before any purchase 

3 order was issued. That's what that whole 

4 little dissertation is about, the fact that 

5 they are now trying to collect on something 

6 that was done without a purchase order.

7 So being in business myself, I'll 

8 guarantee you, and I had it happen person, 

9 when the manager of a nuclear power plant 

10 calls and says, I need this, I'll guarantee 

11 you their purchasing people will get on the 

12 phone, have a vendor go out with the product, 

13 and they'll take care of the paperwork later.

14 When an emergency happens, they 

15 don't necessarily take two weeks to cut a 

16 purchase order to get something done. I mean, 

17 I've actually had that personally happen. So 

18 at Mallinckrodt, those two letters that they 

19 were talking about earlier, are proof that it 

20 happened.

21 So I hope that clarifies it and, 
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95 1 Wanda, the type of uranium, I totally 

2 understand what you're talking about, or I 

3 think I understand what you're talking about, 

4 but Dan, I think, makes a perfect point.

5 There were different types of 

6 uranium that I would be more concerned with, 

7 not the chemical structure, but the size, 

8 shape, because there is a big difference in 

9 exposure when a worker works on 20 pieces of 

10 something in an hour versus 1 of something in 

11 an hour.

12 The exposure has to be greater 

13 because they're in there with it and that 

14 applies to GSI with the corner shots versus 

15 some slice, maybe, that does take two hours, 

16 because they are trying to go through the 

17 entire thickness of it.

18 The ingots, we have that document, 

19 and I have the Mallinckrodt, and I've sent 

20 this before, procedure book that shows what 

21 they were doing. They were shooting those 
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96 1 ingots on the corners to figure out the 

2 thickness of the crust, the slag, so they 

3 could then take it back to have it lathed off. 

4 This is a Mallinckrodt document.

5 This states what that's for. 

6 Well, when a worker is shooting 15-minute 

7 shots versus two hours, he's definitely in 

8 there more. It doesn't have to deal, so much, 

9 with the structure of it, is it's the time 

10 you're right next to it. You can do a whole 

11 lot more when you're doing short shots.

12 So I think you both make a valid 

13 point. I'm more worried about the time the 

14 workers are next to it. So thank you. I 

15 appreciate it.

16 CHAIRMAN ZIEMER: Okay. Well, we 

17 keep moving back into the active period, but 

18 on the residual period, we have several 

19 options today. One option is to have a motion 

20 either to agree that doses can be 

21 reconstructed or to agree that they can't. 
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97 1 Another is to defer action pending additional 

2 information if people believe they need more 

3 or there may be additional information that 

4 you wish to request. I don't know if the 

5 surrogate data issue is part of that, Josie, 

6 or if it's part of the main issues on the 

7 Appendix BB itself.

8 But let me hear from Work Group 

9 Members how you wish to proceed in terms of 

10 the residual period.

11 MEMBER BEACH: Paul, this is 

12 Josie. I did want to hear from NIOSH on the 

13 resuspension factor because the points in both 

14 the latest papers kind of reflect back to the 

15 Procedures Work Group and/or the Site Profile. 

16 So I just wanted to make sure I understood 

17 that, if Dave could comment.

18 CHAIRMAN ZIEMER: Right. And let 

19 me comment first and then I'll ask Dave or 

20 John Mauro to comment, and Wanda is also here, 

21 representing -- it's the Procedures 
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98 1 Subcommittee, actually, it's not a work group, 

2 but it's a subcommittee, but in any event, it 

3 was pretty well agreed that 1 times 10 to the 

4 minus 6th would only apply to periods that 

5 involve previously cleaned facilities.

6 And I think Bob Anigstein 

7 described it already. And we've already 

8 agreed, I think, that the 1 times 10 to the 

9 minus 6th would not apply here.

10 MEMBER BEACH: Okay.

11 CHAIRMAN ZIEMER: And the --

12 DR. NETON: Dr. Ziemer, this is 

13 Jim Neton. I might take exception to that 

14 characterization.

15 CHAIRMAN ZIEMER: Okay.

16 DR. NETON: I think my 

17 recollection was that we agreed on TIB-70 that 

18 there are a variety of resuspension factors, 

19 and as Bob characterized earlier, we agreed 

20 that they would be taken up on a case-by-case 

21 basis --
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99 1 CHAIRMAN ZIEMER: Right.

2 DR. NETON: -- because the 

3 situations are very different among the 

4 different plants. And it didn't necessarily 

5 determine that the 1 times 10 to the minus 6th 

6 would only be applicable to the facilities 

7 that had been cleaned.

8 CHAIRMAN ZIEMER: Well, okay. I 

9 should I have stated it in the --

10 DR. NETON: That has been SC&A's 

11 position all along.

12 CHAIRMAN ZIEMER: Right.

13 DR. NETON: But we take exception 

14 to that. I think that --

15 CHAIRMAN ZIEMER: Oh, I got you. 

16 Okay.

17 DR. NETON: I think where this 

18 thing lies right now, Josie, is that the 1 

19 times 10 to the minus 6th is debatable. SC&A 

20 has stated their position, but we believe that 

21 there are interpretations of these NRC 
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100 1 documents that we can go through and 

2 demonstrate that it's applicable here.

3 And this, in my opinion, becomes a 

4 Site Profile issue for this particular, you 

5 know, site. You know, I think everyone agrees 

6 there is some number that's valid. It's what 

7 is the valid number, and I think that we would 

8 be willing to discuss this at the Site Profile 

9 level, whether it's 1 times 10 to the minus 

10 6th or 5 times 10 to the minus 5th or some 

11 other value.

12 I think there are NRC documents 

13 out there that talk about aged facilities, 

14 where uranium has been present on the ground 

15 for a period of time having this same 

16 resuspension factor.

17 So anyways, I think we need to 

18 take that up and discuss it further.

19 MEMBER BEACH: Thank you.

20 CHAIRMAN ZIEMER: Okay. So 1 

21 times 10 to the minus 6th, it's not that it 
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101 1 wouldn't necessarily apply in this case, but 

2 that it certainly can be applied in cases 

3 where it's already been cleaned. I think 

4 we've agreed to that.

5 DR. NETON: We did agree to that, 

6 but I think in this particular instance we 

7 would just like further justification for our 

8 use of this value.

9 CHAIRMAN ZIEMER: Right.

10 MEMBER MUNN: And the discussion 

11 is easily referenced in the Procedures 

12 Subcommittee's discussions of the last two 

13 meetings.

14 CHAIRMAN ZIEMER: But it would 

15 have to be established for this facility that 

16 that would assume that it was agreed that this 

17 could be bounded and then it would be an issue 

18 of, what's the correct resuspension factor?

19 DR. NETON: Correct.

20 CHAIRMAN ZIEMER: Okay. Who had a 

21 comment? Bob Anigstein?
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102 1 DR. ANIGSTEIN: Yes. Well, I just 

2 wanted to answer Jim's comment. He said NRC 

3 would discuss this. Here's a direct quotation 

4 from NUREG-1720, which is an NRC report 

5 referring to the 10 to the minus 6th.

6 It says, it is assumed that 

7 surfaces will be cleaned or washed during 

8 decommissioning. This will remove most of the 

9 loosely bound and some of the more tightly 

10 bound particles. Following the above 

11 discussion, surfaces that have been cleaned 

12 will be expected to have a smaller 

13 resuspension factor than surfaces that have 

14 not been cleaned, given the same level of 

15 contamination.

16 So it specifically limits this to 

17 decommissioned facilities that have been 

18 cleaned up.

19 DR. NETON: I don't disagree with 

20 that statement, but we could take this up at 

21 another event, I think --
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103 1 DR. ANIGSTEIN: Okay.

2 DR. NETON: -- but I've gone 

3 through all the -- Dave Allen and I have 

4 looked at all the studies that they refer to 

5 and I think that there's room for 

6 interpretation. That's all I'm saying.

7 DR. ANIGSTEIN: All right.

8 CHAIRMAN ZIEMER: Any other 

9 comments?

10 DR. ANIGSTEIN: Yes. I'd like to 

11 make a couple of comments on this last part of 

12 the discussion. Dr. McKeel and John Ramspott, 

13 and that is --

14 CHAIRMAN ZIEMER: Are you 

15 discussing the residual period? I don't want 

16 to get back --

17 DR. ANIGSTEIN: I withdraw my 

18 comment.

19 CHAIRMAN ZIEMER: Yes, okay.

20 MEMBER BEACH: All right, Paul, 

21 this is Josie. I think I still need to hear 
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104 1 more on the use of surrogate data from the 

2 slug facility. I'm not a 100 percent clear on 

3 that.

4 CHAIRMAN ZIEMER: Okay. And the 

5 implication for you on this issue of the 

6 residual period is to delay action on it? Is 

7 that --

8 MEMBER BEACH: For the residual 

9 period, yes, because it's my understanding 

10 that it's all surrogate data based on OTIB-70 

11 and 6000, and I just want to be -- I'm just 

12 not quite clear on how those two meet with the 

13 criteria that we had set up. So that's just 

14 me.

15 CHAIRMAN ZIEMER: Yes. That's 

16 fine. Are you making a motion to defer action 

17 on the residual period?

18 MEMBER BEACH: Yes, I believe I 

19 am. I will say that I would like to wait 

20 until I see some more on that topic.

21 CHAIRMAN ZIEMER: Okay. There's a 
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105 1 motion. Is there a second?

2 MEMBER POSTON: Paul, I'll second 

3 it so we can discuss it.

4 CHAIRMAN ZIEMER: Okay. So a 

5 motion is to defer action on the residual 

6 period. Now, the effect of that would be, 

7 when we report to the Board next week, we 

8 would have a report on Work Group actions on 

9 the active period and then actions on the 

10 residual period.

11 Now, the Work Group simply brings 

12 recommendations. The Board is not obliged to 

13 accept our recommendations one way or the 

14 other. They may choose to defer everything. 

15 They may choose to vote on everything. All 

16 this would be, would be a recommendation and I 

17 guess, Josie, is the motion passes, the Board 

18 would spend additional time on the residual 

19 period as well as dealing with other issues on 

20 the main Appendix BB site profile, or Appendix 

21 BB document.
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106 1 MEMBER BEACH: Absolutely.

2 CHAIRMAN ZIEMER: Other comments? 

3 Ted, did I state that correctly from a, sort 

4 of, a procedural point of view? The Board can 

5 do as it wished on this.

6 MR. KATZ: Yes. I mean, the Board 

7 trumps the Work Group in any event. Yes.

8 CHAIRMAN ZIEMER: Now, it's 

9 probably unlikely that the Board would go 

10 ahead and act if the Work Group recommended 

11 deferring action on this and there are cases 

12 where, and in fact, any number of cases where 

13 we've dealt with the residual period 

14 separately from the main period on a petition, 

15 isn't that correct?

16 MR. KATZ: Yes. I mean, normally, 

17 the Board waits and lets the Work Group 

18 complete its work. And where a Work Group is 

19 asking to do more work to resolve an issue, I 

20 mean, the Board has always respected those 

21 requests from the Work Group. In fact, I 
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107 1 suspect it would in this case too.

2 DR. ANIGSTEIN: This is Bob 

3 Anigstein, I just want to make one comment, 

4 and that is, the question of the -- I mean, 

5 I'm not sure that this is, you know, my proper 

6 place to comment on this, but what we're 

7 really talking about is the intake of uranium 

8 dust, the internal. I mean, there is a small 

9 external dose during the residual period, but 

10 it's a very, very minor part of the total dose 

11 in any dose reconstruction.

12 And if there is uncertainty about 

13 the internal dose, about the intake of 

14 uranium, it would have a much more of an 

15 effect on the operational period than on the 

16 residual period.

17 All of the uranium source term in 

18 the residual period is based on assumptions 

19 about the uranium contamination levels and the 

20 uranium air concentration during the 

21 operational period.
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108 1 So I just want --

2 CHAIRMAN ZIEMER: Well, that's 

3 correct and I think that, for the residual 

4 period, and maybe Jim Neton, or Dave Allen, 

5 can help me on this, but I think that it's 

6 only the inhalation that would deliver any, 

7 sort of, I don't necessarily want to call it 

8 significant, but compared to external, it's 

9 the inhalation, and certainly, even much 

10 greater than ingestion, would be orders of 

11 magnitude greater, I would think, than the 

12 other two components, is that not correct?

13 DR. NETON: That's correct for the 

14 residual period, but I think what Bob is 

15 pointing out, which is --

16 CHAIRMAN ZIEMER: Yes, I 

17 understand that, but on the residual period, 

18 the only issue is inhalation.

19 DR. NETON: It's the key issue I 

20 think. Yes.

21 MEMBER BEACH: So you're saying 
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109 1 there would be no ingestion during that time 

2 period; or limited?

3 CHAIRMAN ZIEMER: Well, I think 

4 even if you postulated ingestion, and you 

5 certainly would, and also external exposure, 

6 those numbers are going to be orders of 

7 magnitude less than you would get from, I 

8 think, inhalation whatever number you selected

9 for the contamination level.

10 DR. ANIGSTEIN: Yes, this is Bob, 

11 I've reviewed a number of the dose 

12 reconstructions, and in all cases, the 

13 ingestion dose with the current NIOSH 

14 methodology is about two orders, just off the 

15 top of my head, two orders of magnitude, 

16 typically, factor of a 100, or maybe even 

17 smaller, than the inhalation.

18 Assuming the same source term, 

19 assuming the same amount of activity, uranium 

20 activity in the air at resuspension, it is a 

21 much, much smaller quantity. So I personally, 
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110 1 when I reviewed these, I even stopped paying 

2 attention to ingestion because, no matter what 

3 it is, it's not going to affect the dose 

4 reconstruction.

5 CHAIRMAN ZIEMER: Other comments? 

6 We have a motion on the floor to defer action 

7 on the residual period, for the Work Group to 

8 defer action today. Okay. No other comments. 

9 Are you ready to vote?

10 MEMBER POSTON: Paul, I still need 

11 some clarification. I know we've been going 

12 around and round, but I guess the question is, 

13 what's going to happen and who's going to make 

14 it happen if we go to the Board next week and 

15 say, we deferred action.

16 Ted says they can override us but 

17 they're unlikely to. So does that mean we're 

18 going to do it ourselves?

19 CHAIRMAN ZIEMER: Well, that means 

20 at our next meeting, I mean, we still have 

21 work before us regardless, just on -- let's 
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111 1 say the Board decides that there either would 

2 or would not be an SEC, we still have to 

3 resolve the issues on the TBD-6000 Appendix 

4 BB, the main document, because you always will 

5 have dose reconstructions.

6 Even if you had an SEC, you have 

7 to do dose reconstructions for people who 

8 don't get one of the specified cancers or who 

9 don't meet the 250-day criteria.

10 If there is no SEC, you still have 

11 to do that, so we still have work to do and 

12 all this would do would be to keep the 

13 residual period open for further discussion 

14 and maybe resolution of the question that 

15 Josie raised as to, I think, the question of 

16 whether or not there's a surrogate analogy 

17 that's correctly applied here, I guess, was 

18 the question, right, Josie?

19 MEMBER BEACH: Yes. That's pretty 

20 close. So just to be clear, Paul. We've got 

21 two periods. The operational period is going 
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112 1 forward to the Board. The residual period is 

2 in question. Is that correct?

3 CHAIRMAN ZIEMER: That's correct.

4 MEMBER BEACH: Okay.

5 MR. KATZ: This is Ted. Paul?

6 CHAIRMAN ZIEMER: Yes.

7 MR. KATZ: Okay. I want to make 

8 certain I was off mute. I'm finding myself a 

9 little bit confused about what's the thinking 

10 here, and this is just to amplify what Bob 

11 just raised.

12 I mean, if there's an issue about 

13 the use of surrogate data here, I'm wondering 

14 if, one, if you can't actually hash it out 

15 now, because you've been involved in the TBD16 6000 review, actually, there's quite a lot of 

17 discussion already, and knowledge, with 

18 respect to the basis for that, and you have 

19 Jim Neton on the line, he knows quite a lot 

20 about that too.

21 The reason I raise that question 
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113 1 is because, if you have a question about the 

2 surrogate data, the surrogate data is applied 

3 during the operational period as well as the 

4 residual period. I'm misunderstanding, I 

5 guess, if there's a reason to distinguish in 

6 terms of addressing surrogate data.

7 CHAIRMAN ZIEMER: Well, I guess 

8 this issue just has come up. I can't say 

9 beyond that. You know, a question's been 

10 raised as to whether or not this is 

11 appropriate.

12 MEMBER BEACH: And meets the 

13 criteria that the Board set up.

14 DR. MAURO: This is John Mauro. 

15 Maybe I can help out a little bit here. It 

16 would always be convenient to be able to 

17 separate the operations period and, of course, 

18 then the Board and the Work Group could 

19 recommend an SEC, because I know that's before 

20 us on the operations period. And then 

21 separate that and the residual period from 
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114 1 that, but we have a little bit of, 

2 unfortunately, a monkeywrench in this. The 

3 methodologies, the assumptions that were used 

4 to do the residual period, and Bob, please 

5 clarify, are also used in the in-between times 

6 during the operations period.

7 CHAIRMAN ZIEMER: Exactly.

8 DR. MAURO: And so you have 

9 resuspension going on with the surrogate data 

10 during operations. So, in a way, you really 

11 can't parse them cleanly. So if you're going 

12 to speak about the operations period, and, of 

13 course, we've addressed many, many SEC issues 

14 and the Board has actually come to a position 

15 regarding the operations period and the 

16 various external exposures, but what we have 

17 before us now is that the resuspension issue 

18 of surface contamination is an exposure part 

19 of the operations period also.

20 Now, that being said, the question 

21 becomes, can it be resolved over the phone 
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115 1 now? That is, because it does have play, not 

2 only during the residual period, but it also 

3 has play during the operations period.

4 And all I can say is this: that 

5 TBD-6000 offers up a whole menu of exposure 

6 scenarios associated with the handling of 

7 metal, uranium metal. A whole range of them. 

8 And it is a judgment call which of those 

9 scenarios are best suited as a surrogate for 

10 any particular facility where you don't have 

11 the airborne data and you could go to one of 

12 the more extreme scenarios.

13 I have to say, off the top of my 

14 head, I don't recall whether slug machining is 

15 one of the higher scenarios where you're 

16 really generating lots of aerosols. I suspect 

17 it might be.

18 DR. ANIGSTEIN: No.

19 DR. MAURO: No? I'm wrong?

20 DR. ANIGSTEIN: No, it's not.

21 DR. MAURO: Okay. My apologies. 
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116 1 And I'm not trying to draw conclusions here. 

2 What I'm trying to say is, though, I think the 

3 issue that's in front of us is, do we have an 

4 SEC issue in front of us with respect to 

5 surrogate data? Yes, this is surrogate data. 

6 This draws from TBD-6000.

7 TBD-6000 has been thoroughly 

8 vetted and has all been agreed that the sweep 

9 of operations on uranium metal have been 

10 exhaustively studied by a very large amount of 

11 data which captures the full range of kinds of 

12 activities that could have taken place to 

13 generate an aerosol.

14 And so one could argue, since 

15 that's been vetted, and it's been agreed, that 

16 somewhere in that distribution you could find 

17 a bounding scenario that applies to your 

18 circumstance. One could argue, then, the 

19 surrogate issue has been resolved. It's just 

20 a matter of picking the right scenario.

21 So one could argue, well, then 
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117 1 it's not an SEC issue. We may disagree that 

2 the slug handling is the most limiting, but we 

3 probably, certainly could find one that is 

4 more appropriate and more bounding.

5 So in one respect, the person 

6 could argue, well, it's not an SEC issue 

7 because of that. On the other hand, until you 

8 actually do that, and in this respect, I would 

9 be saying something that would support with 

10 Josie, well, until you actually do that, you 

11 haven't really put the surrogate issue to bed.

12 So I mean, what I'm trying to do, 

13 as best I can, is show both sides of the 

14 judgments that have to be made at this time.

15 CHAIRMAN ZIEMER: In principle, if 

16 one were to say that the uranium slug scenario 

17 is inappropriate, you could select a different 

18 one on a TBD-6000, because I don't recall 

19 where the slug thing was in terms of air 

20 concentrations, but certainly it wasn't the 

21 highest.
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118 1 DR. ANIGSTEIN: No, Dr. Ziemer. 

2 Actually, it's the lowest.

3 DR. MAURO: Oh, okay. It's one of 

4 the lower ones. And, Paul, you're right. So 

5 the question is, well, let's say, in the end 

6 of the process one judges that, well, perhaps 

7 there's a more appropriate, more limiting --

8 so, I guess, here's the question, since we've 

9 already agreed that TBD-6000 does establish 

10 boundaries on airborne dust loadings 

11 associated with the handling of uranium for 

12 virtually every circumstance we might 

13 encounter, and that's why it was reviewed, to 

14 see, does it do a good job in accomplishing 

15 that.

16 On that basis, one could argue 

17 that, all you really have is a site profile 

18 issue, to pick the right one within that 

19 range. So that would be one side of the 

20 argument. The other side would be, well, 

21 until you actually do that, it might still be 
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119 1 an SEC issue.

2 And I think that's the question 

3 that's before the Work Group at this time.

4 CHAIRMAN ZIEMER: Well, 

5 previously, we had agreed that the TBD-6000 

6 approach would bound the airborne activity for 

7 the active period.

8 And in principle, if you say that, 

9 then you would say, then it also will apply in 

10 the residual period, and then it's a matter of 

11 selecting the correct resuspension factor, 

12 which is, you know, it could still be debated, 

13 but at least, in principle, you can 

14 reconstruct dose with that approach.

15 And if we opened the residual 

16 period and say we're not prepared to make a 

17 recommendation, I guess, Ted, you're asking, 

18 does that, in principle, say then, why could 

19 you do it for the active period?

20 DR. ANIGSTEIN: This is Bob. If I 

21 can comment. Just, perhaps, to refocus. The 
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120 1 residual period does not directly use 

2 surrogate data from TBD-6000. What is used is 

3 -- the air concentration that's listed in TBD4 6000 for the slug production operator is used, 

5 then, to calculate the deposition on the 

6 surfaces.

7 Then it is assumed that the 

8 highest year based on the maximum number of 

9 hours in a given year for uranium handling, 

10 assuming that whatever gets deposited during 

11 that year, then it remains constant from that 

12 year, which is, I think, 1961 through 1993.

13 So it's simply, whatever is 

14 deposited, using the TBD-6000 numbers for the 

15 deposition rate, then remains on the ground, 

16 on the floors and continues on. So the two 

17 are inseparable. If you accept the surface 

18 concentration during the operational period, 

19 then it simply continues during the residual 

20 period.

21 CHAIRMAN ZIEMER: Right. Right. 
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121 1 And what I was saying was, sort of, in 

2 reverse, if you don't accept it for the 

3 residual period, why did you accept it for the 

4 active period? Yes.

5 DR. MAURO: Yes.

6 DR. ANIGSTEIN: Exactly, agree.

7 DR. MCKEEL: Dr. Ziemer?

8 CHAIRMAN ZIEMER: Yes.

9 DR. MCKEEL: I know this is not my 

10 time, so to speak, but I really would 

11 appreciate being able to put a short sentence 

12 on the record.

13 CHAIRMAN ZIEMER: Sure.

14 DR. MCKEEL: And that is, this is 

15 not the first time that I brought up about the 

16 inappropriateness of the slug facility and the 

17 use of surrogate data related to that 

18 facility. Now we've learned that the amount 

19 of airborne uranium from that facility was one 

20 of the lowest, or lowest, of the scenarios in 

21 TBD-6000.
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122 1 My previous comments were really 

2 made in conjunction with the operational 

3 period and I think it would be fair to say, as 

4 has been confirmed this morning, that although 

5 that subject has been brought up, that no 

6 other TBD-6000, Class 6001, or TBD-6000 Work 

7 Group Member has ever called for a formal 

8 comparison to see whether the slug facility 

9 meets the Board's surrogate data criteria.

10 So, you know, of course, I applaud 

11 the idea of doing that. I think it's 

12 absolutely necessary. And, you know, I think 

13 all the comments made by Dr. Mauro just now, 

14 and Dr. Anigstein, point to the fact that the 

15 surrogate data issue transcends the period and 

16 stretches all the way from 1952 to 1992.

17 So I strongly encourage that that 

18 needs to be done and that that be factored 

19 into the equation. Thank you.

20 CHAIRMAN ZIEMER: Thank you. 

21 Board Members, any other comments? Okay. So 
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123 1 we have a motion to defer action on the 

2 residual period. Are you ready to vote? I 

3 guess we need to do it by roll call, Ted. 

4 Ted, are you on there?

5 MEMBER BEACH: He's probably 

6 muted.

7 MR. KATZ: I am. Thank you, 

8 Josie.

9 MEMBER BEACH: You're welcome.

10 MR. KATZ: If I could get us to 

11 vote with a very good roll call. Okay. Now, 

12 let's do this again.

13 Dr. Poston.

14 MEMBER POSTON: Yes.

15 MR. KATZ: Okay, so that's a yes 

16 to deferring. Okay, and then Ms. Munn.

17 MEMBER MUNN: No, I think we've 

18 covered that previously.

19 MR. KATZ: And then Ms. Beach.

20 MEMBER BEACH: Yes.

21 MR. KATZ: And then Dr. Ziemer.
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124 1 CHAIRMAN ZIEMER: I guess I'll 

2 vote to defer. I don't know that it 

3 accomplishes anything at this point, but I'll 

4 try to accommodate here the concerns of our 

5 fellow Board Member. So I guess the motion 

6 carries then, correct?

7 MR. KATZ: Yes. The motion 

8 carries. That's three votes in favor.

9 CHAIRMAN ZIEMER: Okay. So I will 

10 report to the full Board that we're not ready 

11 to make a recommendation yet on the residual 

12 period. 

13 MEMBER BEACH: And will we see 

14 some work on this surrogate data issue, Paul? 

15 What's the thought there?

16 CHAIRMAN ZIEMER: Well, you know, 

17 we'll have to schedule a Work Group meeting 

18 later in the summer after our Board meeting is 

19 over and then we'll have that on the agenda. 

20 I don't know at this point, I need to look at 

21 this, but I don't know if we need to -- got to 
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125 1 think about this, well, I guess, let's find 

2 out what the Board wishes to do at this point.

3 But I think what we'll need to do, 

4 and the full Board can task this, I think we 

5 may need to ask SC&A to look at that issue. 

6 Is this an appropriate surrogate for GSI? 

7 Ted, is that something we can task at the 

8 meeting?

9 MR. KATZ: Yes, we can task it now 

10 or at the meeting, but since you're going to 

11 end up discussing this at the meeting anyway, 

12 we'll task it at the meeting. Unless 

13 something unexpected happens at the Board 

14 level, even if you don't state it at the Board 

15 meeting, I'll make sure that this is tasked 

16 immediately after.

17 And certainly, SC&A is not going 

18 to get to this before the meeting, so there's 

19 no real reason to task it right now.

20 CHAIRMAN ZIEMER: Right. There's 

21 no time to do anything between now and then 
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126 1 anyway.

2 MR. KATZ: Right. I think so.

3 DR. NETON: Paul, this is Jim. 

4 I've got a question. I'm a little bit 

5 confused as to what is going to be the Work 

6 Group's position on covered period now?

7 CHAIRMAN ZIEMER: I think that 

8 nothing has really changed on the covered 

9 period. I mean, intrinsically, it appears 

10 that it has, but we've only taken this action 

11 on the residual period right at the moment.

12 DR. NETON: Well, I'm not sure how 

13 you can do that because, like, as Bob pointed 

14 out, they're inseparable. If the conclusion 

15 comes to be that it's inappropriate use of 

16 surrogate data, it affects the covered period 

17 as well. I mean, they're the same thing. I 

18 don't know, I guess I'm confused as to how one 

19 would --

20 DR. MAURO: Jim, I agree with you. 

21 This is John.
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127 1 DR. NETON: I don't know how you 

2 can take two different positions when the same 

3 issue appears in both pieces.

4 MEMBER MUNN: Exactly.

5 CHAIRMAN ZIEMER: That's exactly 

6 right.

7 DR. ANIGSTEIN: If I could make a 

8 suggestion, this is Bob, perhaps since I spoke 

9 up about saying that the slug production is 

10 the lowest concentration of the ones that were 

11 considered here, the reason they used slug 

12 production is that every other operation, and 

13 perhaps Dave Allen can clarify this in more 

14 detail, involved much more disturbance of 

15 uranium.

16 I mean, there's just a list of 

17 these in summary on the tables. It's not a 

18 long list. Extrusion, rolling, forging, 

19 machining, and scrap recovery. So each of 

20 these, I believe, NIOSH considered involved 

21 actually roughing up the uranium, certainly 
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128 1 machining, whereas, the slug production 

2 involved the least amount of handling and is 

3 closest to what happened at GSI, where there 

4 was no disturbance, except inadvertent, as Dr. 

5 McKeel pointed out, putting the chains on.

6 So when I said it's the lowest, we 

7 did not question. We did review this, 

8 originally, as part of our Appendix BB review, 

9 and we agreed that this was a limiting 

10 scenario, if anything, it was a conservative 

11 scenario because it probably involved more 

12 disturbance of the uranium than was used.

13 And then furthermore, NIOSH now 

14 used, again, in the slug production, and you 

15 have four categories of workers, depending how 

16 close they were to uranium: operator, general 

17 laborer, supervisor and clerical.

18 And basically, the same air 

19 concentration, but said, well, the operator is 

20 there eight hours a day, the general laborer 

21 goes in only half the time because he has 
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129 1 other work, the supervisors are even less and 

2 the clerical is even less.

3 So there was a very good 

4 rationale. You know, we're talking about 

5 tasking SC&A, I should be saying, gee, don't 

6 give us any more work, but at the moment, we 

7 can say, we did review this issue. We can 

8 certainly do more reviews on it, but it has 

9 not been left untouched, unquestioned.

10 And, you know, as has been made 

11 clear, we had a number of comments, issues, 

12 criticisms of NIOSH's methodology and 

13 assumptions about the operational period, and 

14 those were primarily external doses, this 

15 wasn't one of them.

16 We thought that this was a 

17 reasonable assumption. If anything, it was a 

18 very conservative one, but was based on the 

19 data available, the studies they have made, 

20 this was the best. This was the most suitable 

21 and claimant-favorable.
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130 1 DR. MAURO: This is John, I think 

2 we're asking the right questions here. Dr. 

3 McKeel brought up a point that says, well, I 

4 think it may very well have been roughed up a 

5 bit, perhaps roughed up in a way that might 

6 have been of a different nature and different 

7 type than, let's say, the way the slugs were 

8 handled, okay?

9 So let's assume that for a minute. 

10 We don't know for sure. We haven't aired it 

11 out, but the real question, this goes toward 

12 whether or not you could address the SEC issue 

13 for the operations period at the Board meeting 

14 or does this prevent you from being able to do 

15 that until you get resolution.

16 I would argue, and I'll do what I 

17 often do, but when we looked at the range of 

18 activities that are embraced by TBD-6000, and 

19 Bob just alluded to it, it's all coming back 

20 to me, one could ask the question, could you 

21 conceive of the possibility that we can't find 
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131 1 one of those scenarios which we believe to be 

2 plausibly bounding as applied to GSI?

3 Okay? Now, here's where I will 

4 gladly stick my neck out, because I think it 

5 needs to be done, I am very close with what's 

6 going on in GSI, I am very close with TBD7 6000, and I could say with a high degree of 

8 confidence that you can find a scenario within 

9 the full range of scenarios, and not only the 

10 kinds of things they did, but the class of 

11 workers, the matrix, that would bound the 

12 operations and circumstances that, I 

13 understand and I'm familiar with, took place 

14 at GSI.

15 If you accept that, and I fully 

16 understand why you may not want to accept my 

17 making such an outrageous statement at this 

18 time, and just leap to a conclusion, I find 

19 that, you know, my sense is, because I have 

20 been working so close to this, my belief is 

21 that we're dealing with a site profile issue 
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132 1 is, the boundaries are there, did we pick the 

2 right boundary?

3 But you certainly could find one 

4 and as I said, I know I'm sticking my neck out 

5 a bit, but I feel as though I can, because of 

6 how much time I've spent on both these 

7 subjects.

8 Now -- because I am concerned 

9 that, unless I said what I just said, it's 

10 very possible that it's not going to be 

11 possible for you to address the SEC issue, 

12 which we've been waiting for a long time, on 

13 the operations period, unless I made the 

14 statement I just made.

15 CHAIRMAN ZIEMER: Well, in 

16 essence, if we defer the residual period, then 

17 we almost have to defer the main period as 

18 well because they are -- it's one or the 

19 other. We either can or we can't and if 

20 there's a question about whether you can do 

21 that and use this as a surrogate, you know, my 
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133 1 own feeling is that, if one decides that it's 

2 a different scenario, you can select a 

3 different one, but it can be bounded.

4 DR. MAURO: Does that make it an 

5 SEC issue which would prevent the Board from 

6 making a judgment on whether to grant or deny 

7 the SEC?

8 CHAIRMAN ZIEMER: I mean, you can 

9 still go back and see if you selected the 

10 right, if you want to call it, surrogate from 

11 TBD-6000. You can still do that either way. 

12 I mean, you can still recommend an SEC for the 

13 residual period and still examine what value 

14 you're going to use.

15 But if we say that, I think Jim 

16 Neton is quite correct that, you can't have it 

17 both ways. You know, you can't recommend 

18 going ahead on the main period and not 

19 recommend going ahead on the other based on 

20 this issue. So that's the dilemma.

21 MEMBER MUNN: This is Wanda. I'm 
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134 1 sorry I didn't speak sooner when we were 

2 debating prior to calling a vote, but the 

3 reason that I voted no is because this issue, 

4 in my memory, was well vetted when we 

5 addressed the original TBD-6000 document.

6 And it has the feel to me of re7 invention. It isn't as though we haven't been 

8 here before and my memory was that this was 

9 satisfied, accepted for our purposes and the 

10 Board's use.

11 CHAIRMAN ZIEMER: Any other 

12 comments?

13 MR. KATZ: I'll just note, and of 

14 course, it's just a matter of procedure. I 

15 mean, you can take another vote on the matter 

16 you just voted on as well, if you want to 

17 think differently about it, having heard from 

18 John.

19 CHAIRMAN ZIEMER: Well, and we 

20 could also recommend deferring action on the 

21 SEC till later as well.
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135 1 MR. KATZ: Right. Indeed.

2 CHAIRMAN ZIEMER: As a matter of, 

3 sort of, practicality for the Board, and 

4 particularly for the new Members, there's a 

5 lot of material to absorb and one would wonder 

6 whether or not the Board is going to be ready 

7 to vote in any event on this issue; on either 

8 the active or the residual period.

9 MEMBER BEACH: Well, Paul, I'll 

10 step out and make a motion that we also 

11 postpone the operational period, but I do 

12 believe that we need to take a full time to 

13 review this before the Board. So my motion is 

14 to postpone the operational period as well as 

15 the residual.

16 CHAIRMAN ZIEMER: Postpone action.

17 MEMBER BEACH: Yes.

18 CHAIRMAN ZIEMER: In other words, 

19 we would bring to the Board the findings to 

20 date but recommend that action not be taken at 

21 this meeting. You're making that as a motion?
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136 1 MEMBER BEACH: Yes. Well, we can 

2 clean it up and just say my motion is to delay 

3 the operational period as well as the 

4 residual, so just operational.

5 CHAIRMAN ZIEMER: Delay action --

6 MEMBER BEACH: Delay action, yes.

7 CHAIRMAN ZIEMER: All right. Is 

8 there a second to that motion? I'm not 

9 hearing a second.

10 MEMBER BEACH: No.

11 MEMBER POSTON: Paul, I second --

12 CHAIRMAN ZIEMER: We do have a 

13 dilemma, though, that --

14 MEMBER BEACH: Dr. Poston was --

15 CHAIRMAN ZIEMER: Yes, John.

16 MEMBER POSTON: Yes, I'll second 

17 the motion so we can get out of this dilemma.

18 CHAIRMAN ZIEMER: Okay. The 

19 motion has been seconded. So we would proceed 

20 and present everything, but recommend that 

21 action not be taken on the SEC at this 
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137 1 meeting. That would give us time to resolve 

2 any open question on this issue of what you 

3 might call a surrogate data issue as it 

4 applies to both the residual period and the 

5 operational period. Is that the motion?

6 MEMBER BEACH: Yes.

7 CHAIRMAN ZIEMER: I mean, the 

8 motion doesn't have to say anything about the 

9 surrogate data part, it just says that we're 

10 not recommending action at this meeting.

11 MR. KATZ: This is Ted, and I 

12 think whether it's in the motion or not, I 

13 would think you would want to explain to the 

14 Board the surrogate data issue, where it 

15 stands, and that that's the basis for your 

16 recommendation.

17 CHAIRMAN ZIEMER: Right. Even 

18 though, in principle, we covered that on the 

19 operational period, but it's sort of been 

20 reopened, I guess you'd have to say. Okay. 

21 Any other comments? Anyone want to speak 
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138 1 against the motion?

2 MEMBER MUNN: I'll speak against 

3 the motion simply because I do believe we are 

4 revisiting material that we have addressed in 

5 other places and we're getting into a do-loop 

6 here. Everyone wants to move forward with 

7 this and have a definition on it, and yet, we 

8 repeatedly ask for additional opportunity to 

9 review data that we have.

10 It just seems to me that we're in 

11 a do-loop. So I speak against it.

12 CHAIRMAN ZIEMER: Okay. Anyone 

13 else? Okay. Let's vote. This is to 

14 recommend that no action be taken on the SEC 

15 petition at this meeting.

16 MR. KATZ: Right. So, Dr. Poston?

17 MEMBER POSTON: Yes.

18 MR. KATZ: Ms. Beach.

19 MEMBER BEACH: Yes.

20 MR. KATZ: Wanda Munn.

21 MEMBER MUNN: No.
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139 1 MR. KATZ: And Dr. Ziemer.

2 CHAIRMAN ZIEMER: Yes.

3 MR. KATZ: Okay. The motion 

4 passes, three in favor. So there will not be 

5 a recommendation for action on this SEC by the 

6 Work Group.

7 CHAIRMAN ZIEMER: Okay. I believe 

8 that concludes our business for today. Any 

9 other items that need to come before us?

10 MEMBER MUNN: None here.

11 CHAIRMAN ZIEMER: If not, we'll 

12 see you all next week at the meeting in Santa 

13 Fe. Thank you very much. We are adjourned.

14 (Whereupon, the above-entitled 

15 matter went off the record at 11:41 a.m.)

16 

17 

18 

19 

20 

21 
This transcript of the Advisory Board on Radiation and Worker Health, TBD 6000 Work Group, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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140 1 

2 

3 

4