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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 WELDON SPRING

+ + + + +

TUESDAY 

FEBRUARY 14, 2012

+ + + + +

 The Work Group convened, via 

teleconference, at 10:00 a.m. Eastern Standard 

Time, Richard Lemen, Acting Chairman, 

presiding.

PRESENT:

RICHARD LEMEN, Acting Chairman

DAVID B. RICHARDSON, Member

 
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2

ALSO PRESENT:

TED KATZ, Designated Federal Official

RON BUCHANAN, SC&A

MONICA HARRISON-MAPLES, ORAU Team

DAVID HARRISON, ORAU Team

STU HINNEFELD, DCAS

KAREN JOHNSON

MARY JOHNSON

JENNY LIN, HHS

ROBERT MORRIS, ORAU Team

MARK ROLFES, DCAS

LAVON RUTHERFORD, DCAS

DAN STANESCU, ORAU Team

JOHN STIVER, SC&A

TINA TRIPLETT
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3

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

Call to Order 4 

 

Roll Call 4 

 

SC&A Review of NIOSH Response Concerning 8 

the Daily Weighted Exposure Data

 Ron Buchanan 8, 24, 25, 27

 SC&A

 John Stiver 14, 23

 SC&A

 Mark Rolfes 19, 28

 NIOSH

 Robert Morris 20, 23, 24, 26, 27

 ORAU

 Questions and Comments 17, 31, 41

 

Rolfes-Clawson Correspondence on WS 36

Operational Dates - Thorium Processing

 Mark Rolfes 36

 NIOSH

 Questions and Comments 39, 57
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4

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

2 (10:01 a.m.)

3 MR. KATZ: Okay. Dick, do you 

4 want to, then, lead? We have an agenda. It 

5 is posted on the website, and I believe there 

6 is a document associated with it which should 

7 also be posted on the website. That is the 

8 NIOSH website under the Board section of the 

9 website, under meetings.

10 And, Dick, it is your agenda, I 

11 guess. We don't have Mike here.

12 MEMBER LEMEN: Okay. I am not 

13 really prepared, but I will start and we will 

14 just follow the agenda and see where we go.

15 The first item on the agenda is 

16 the SC&A review of NIOSH response concerning 

17 the daily weighted exposure data. I believe 

18 that they submitted a report in January, and I 

19 believe Ron Buchanan was the senior person on 

20 that.

21 So, Ron, can you take over from 
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5

1 here?

2 DR. BUCHANAN: Okay. Thank you.

3 This is Ron Buchanan with SC&A.

4 Just to give you a little bit of 

5 background, we had a number of SEC issues and 

6 we have addressed those over the last year and 

7 a half, two years. One of the last ones was 

8 concerning the daily weighted exposures that 

9 was to be used for the thorium data air 

10 concentrations.

11 What this entails is that in the 

12 SEC evaluation, they did have a table in there 

13 of thorium air concentrations. One of the 

14 things that had been identified at other sites 

15 was what was the accuracy of this data. In 

16 other words, was there any errors in recording 

17 this data or the calculations?

18 And so, NIOSH went back and looked 

19 at some of the data from 1958 through `65 and 

20 did an error analysis on the air sampling 

21 data, the daily weighted average, to see what 
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6

1 the errors were, and they came up with the 

2 fact that they identified some errors in the 

3 data and that this was about a 2 to 4 percent 

4 error rate, which agreed somewhat with 

5 previously published articles in the Health 

6 Physics Journal.

7 And so, what SC&A did was try to 

8 see if this applied to the thorium data that 

9 was listed that was going to be used in dose 

10 reconstruction. So, we did an evaluation of 

11 this last summer or fall and issued a report 

12 in September of 2011. NIOSH responded to that 

13 report, and this was discussed somewhat at the 

14 28th of November Weldon Spring Work Group 

15 meeting.

16 We responded to their response, 

17 which came out just a day or so before the 

18 meeting, which we didn't have time to analyze 

19 for the meeting. And so, the 17th of January, 

20 we responded to their second revision, or 

21 their first revision of their original paper.
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7

1 What we found out was that we went 

2 back and looked at this 82 lines of data, 

3 which essentially NIOSH had gone into the data 

4 pool, looked at the method that was used to 

5 record this daily weighted average, and looked 

6 at the errors. And so, we looked at the 82 

7 entries in there to see how they applied to 

8 thorium data. And so, this was our response 

9 of the 17th of January of 2012.

10 Essentially, some of it was 

11 carryover from what we had said in our 

12 September report. NIOSH did provide a section 

13 in there on how to apply the data and came up 

14 with the Monte Carlo simulation and the 4 

15 percent error rate.

16 But we had questioned, SC&A had questioned the 

17 representation of the data to the thorium data 

18 that was used. The data that made up the 4 

19 percent error rate came from 1958 to 1965. 

20 Now I am summarizing.

21 Mark, you can correct this if I am 
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8

1 wrong when you explain your position on it. 

2 But we found that 82 lines in there was from 

3 `58 to `65, the sample, and we had several 

4 problems with it. Number 1 was there was a 

5 limited amount of sample in data of the 

6 original handwritten material. And so, you 

7 could only go back to the handwritten material 

8 to analyze errors to see how they transcribed 

9 or miscalculations. And so, the error rate 

10 was determined from looking at all this data.

11 The No. 1 question we had there on 

12 our paper was that the data was limited, but 

13 not all of it was used. And so, we could not 

14 see what the criteria was for what data was 

15 used and what wasn't used. It didn't seem to 

16 be the highest data, the highest daily 

17 weighted average. So, we weren't sure why 

18 some of it was used, some of it wasn't.

19 And secondly, of the 82 lines of 

20 data, from `58 to `65, only 17 corresponded to 

21 the thorium error data taken. The thorium 
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1 data did not have any of the raw data 

2 recorded. The way my understanding was, there 

3 was no raw data, and I couldn't find any raw 

4 data on the thorium. It had the summary 

5 results.

6 And so, we are applying the 

7 uranium taking data over `58 to `65 to thorium 

8 data from `63 to `66 to determine the error. 

9 Now we are not using the same data. We are 

10 just saying, what could the possible error 

11 rates be?

12 And so, we found that only 17 of 

13 these lines, these entries, corresponded to 

14 the `63-to-`66 error that the thorium was 

15 used, and that would be applied to in dose 

16 reconstruction. So, you could see that there 

17 would be different operators taking this data 

18 at different times.

19 So, we have mainly the problem in 

20 our summary, as we say, of the 

21 representativeness of the uranium data that 
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10 1 was used to determine the 4 percent error 

2 rate. Is it applicable to the thorium data? 

3 Why wasn't all the data used?

4 John Stiver, would you like to add 

5 anything to that? That is a summary of that 

6 paper that we turned in on the 17th. You have 

7 worked on this at Fernald and some of the 

8 other sites. Would you have anything to add 

9 to that?

10 MR. STIVER: Yes, thanks, Ron. I 

11 think you summarized it pretty well, although 

12 I would like to make a distinction here.

13 When we are talking about the 

14 limited data, there is an issue not in the 

15 representativeness as an issue, not because 

16 necessarily we are looking at thorium or high 

17 DWEs, because we are essentially looking at a 

18 human error rate in transcription. So, I 

19 mean, it doesn't matter; when you are using 

20 it, you are looking at the same process. 

21 Basically, you are looking at the exact same 
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11 1 calculations for DWE, whether you are looking 

2 at thorium or uranium.

3 So, the nuclide or the magnitude 

4 of the particular DWE doesn't count. What 

5 counts is which operators were doing the 

6 calculations and whether the operators who 

7 were sampled in this small set of data can be 

8 considered to be representative of the types 

9 of errors that might occur during the period 

10 when we are interested. And so, I think we 

11 ought to make that distinction.

12 As far as the approach they used, 

13 I think it is a very scientific, credible 

14 approach, doing the Monte Carlo calculations 

15 of the distribution of DWEs without the 

16 blunders or the errors as a baseline set, and 

17 then constructing an error rate distribution 

18 at the rate at which the errors occur during a 

19 Monte Carlo calculation or simulation. You go 

20 out and sample from that error distribution 

21 and, then, create a second distribution for 
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12 1 comparison as a baseline.

2 And that is what they did, and 

3 they found about 2.5 percent higher at the 

4 geometric mean and 4.5, 4 percent or so, at 

5 the 95th percentile. And so, this was a 

6 little higher than what you might expect from 

7 the human error rate, which is typically about 

8 1 percent or so.

9 Although what was kind of 

10 interesting is it did look like they captured 

11 one of the bad actors here, if you want to 

12 call it that, because I think it was 40 out of 

13 50 of the arithmetic errors were attributed to 

14 one operator who made the same mistake 41 

15 times. And so, when that particular person 

16 was removed, you are looking at close to about 

17 a 1 percent error rate, which is kind of a 

18 random-type area you consider.

19 But that does kind of raise the 

20 question of, well, you captured one guy who 

21 was making a lot of mistakes, but because you 
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13 1 have such a limited dataset, were there 

2 potentially others that might have resulted in 

3 more error? I guess the bottom line on this 

4 whole exercise is that 4 percent of the 95th 

5 percentile is not really all that large of a 

6 magnitude, I think the reason being that most 

7 of these errors result in a factor of two or 

8 less under-representation and some result in 

9 an overestimate. And so, there is a tendency 

10 to balance each other out a bit.

11 And it is also interesting that 

12 the magnitude and types of errors that were 

13 identified in this dataset were virtually the 

14 same as identified in the Adam Davis and Dan 

15 Strom paper from 2008, which is the 

16 fundamental basis for the uncertainty 

17 estimates that are used in the DWE coworker 

18 model.

19 That's really all I have to say. 

20 I would say SC&A is fairly satisfied with the 

21 approach. We are a little concerned that the 
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14 1 data may not be, because it is such a small 

2 dataset, that it may not be representative of 

3 the full range of errors that may have 

4 occurred.

5 That's all I have to say on the 

6 subject.

7 MEMBER LEMEN: Okay. This is Dick 

8 Lemen.

9 Before we go to NIOSH for their 

10 response, could I ask Board Member Richardson, 

11 I know that you had comments in the Tampa 

12 meeting. Would you have any comments at this 

13 time, Dave?

14 MEMBER RICHARDSON: I was less 

15 concerned about kind of the error issues than 

16 going back to what sounded from your report 

17 about perhaps the lack of clarity in how NIOSH 

18 had selected the data or the lines of data, as 

19 you are describing them, for inclusion versus 

20 exclusion. Is that still on the table, this 

21 issue that you called representativeness of 
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15 1 the limited data?

2 MR. STIVER: This is John Stiver 

3 again.

4 We would like NIOSH to at least 

5 identify what the criteria were for selection 

6 because it looks like there were some 

7 handwritten calculations that were not used, 

8 but there was no explanation as to why they 

9 were excluded from the analysis.

10 MEMBER RICHARDSON: Okay. I would 

11 just like to keep that, because, to me, it 

12 sounds like it was a question that you had 

13 posed before that hadn't been addressed and it 

14 has been posed again. I don't want to lose 

15 sight of that.

16 MEMBER LEMEN: Any other comments, 

17 Dave?

18 MEMBER RICHARDSON: No, that's it.

19 MEMBER LEMEN: Okay. Mark Rolfes, 

20 do you want to make any comment on this? Or 

21 is there someone else at NIOSH that would 
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16 1 rather speak?

2 MR. ROLFES: Well, I will give a 

3 sentence or two, and, then, probably refer to 

4 Bob Morris here to answer some of the 

5 technical aspects of things.

6 I think SC&A summarized both their 

7 position as well as our position pretty well. 

8 Let's see, we used the raw data that were 

9 available to us. Although we might have had a 

10 summary report much more frequently, we didn't 

11 always have all the raw data available to us. 

12 So, we used the raw data that we had 

13 available to us.

14 I think we covered about 1400 

15 different operations and had about 80 pages of 

16 data that were analyzed to look at the error 

17 rates or blunders in the daily weighted 

18 exposure reports. And then, we went back and 

19 corrected those blunders and came up with the 

20 roughly 4 percent difference in thorium intake 

21 at the 95th percentile, once we addressed all 
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17 1 those errors in how the data was recorded and 

2 reported.

3 I think, as far as the number of 

4 operators that were involved in completing 

5 these reports, I believe that was a limited 

6 number of people who were reporting these 

7 results.

8 That is my intro, and I would like 

9 to turn it over to Bob to maybe address some 

10 of the specific questions and concerns 

11 regarding the representativeness of the data. 

12 That is the biggest concern that we are 

13 discussing.

14 MR. MORRIS: Okay. Hello. This 

15 is Robert Morris. I am a health physicist 

16 with the ORAU team.

17 As you said, I think we have all 

18 agreed this is a rehash of what I said in our 

19 last Work Group meeting, which is that we had 

20 no bias and no sampling plan going into the 

21 process of identifying. I mean, we had 
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18 1 initially hoped to identify DWE reports and 

2 the corresponding raw data that went into 

3 generating those reports and then selectively 

4 picked the ones that were very pertinent to 

5 the operations of interest.

6 When we got into the data and 

7 actually looked to see what was available, 

8 what we found was that the raw data were not 

9 available with the reports, and it was only in 

10 rare cases where we could make a positive 

11 association between a worksheet and the daily 

12 weighted exposure report.

13 Excuse me. At some locations, 

14 they called it daily weighted average. At 

15 some locations, this practice was called daily 

16 weighted exposure. So, since I have been 

17 working on sites that have these in common, I 

18 am using the term identically. I don't mean 

19 to imply there is any difference in the 

20 process, whether I use the word exposure or

21 average at the end.
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19 1 So, what we found was that we have 

2 identified all of the data in our evaluation 

3 that we could positively associate with the 

4 daily weighted exposure report. And then, we 

5 took all of that data and we sampled it. As 

6 you said, the blunders we identified are 

7 tabulated at the end of the report. I think 

8 we identified about 1400 opportunities to make 

9 a mistake, and then we identified the 80 

10 mistakes, or something like that.

11 So, I am a little bit puzzled 

12 because the report that we got back from SC&A 

13 with the critique on this doesn't really give 

14 us the specifics of what we did wrong in terms 

15 of finding data that they succeeded in 

16 finding. I think that is one of the comments 

17 that you have had, but we haven't been able to 

18 substantively address that because I don't 

19 have the details.

20 So, maybe I will just throw that 

21 back. If it is of interest, we need more 
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20 1 information to actually follow your leads that 

2 were developed, Ron and John.

3 MEMBER LEMEN: Does SC&A have 

4 something to respond to that? 

5 MR. STIVER: Ron, did you want to 

6 say anything?

7 (No response.)

8 MR. STIVER: I am not aware of 

9 what data that may have been available that 

10 wasn't used. It was just our understanding 

11 that maybe there might have been some 

12 available data that was not used. From what 

13 Bob Morris is saying, you did indeed capture 

14 all the data that were available that could be 

15 associated with DWEs, is that correct?

16 MR. MORRIS: Well, that was our 

17 intent. We worked hard to try to find the 

18 data. I am not saying we were perfect in 

19 finding all of it, because, you know, it is 

20 spread over hundreds, or perhaps thousands, of 

21 pages of handwritten records. But, you know, 
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21 1 we made a good effort to try and find it, and 

2 we spent a bit of time on it.

3 If you have some other leads for 

4 us, we will be happy to look at them.

5 DR. BUCHANAN: Okay. Yes. This 

6 is Ron Buchanan with SC&A.

7 Okay. So, I went back and looked 

8 at some of the Site Research Database 

9 references that you provided. Some of the 

10 data, the handwritten data was like it might 

11 be pages 8 through 14 and maybe the ones that 

12 you referenced was page 8 and 11, or 

13 something. And then, there was other data in 

14 between, if I recall right.

15 Are you saying that you didn't 

16 have the summary report that corresponded to 

17 those other sheets?

18 MR. MORRIS: In general, that 

19 would be the case. We couldn't make a 

20 positive relationship between an air sample 

21 result, for example, and the daily weighted 
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22 1 exposure document that it may have been 

2 associated with. Where we did succeed in 

3 finding those positive, direct relationships 

4 between a data entry on a form and an exposure 

5 is where the working papers happened to have 

6 been filed along with the final report. That 

7 generally was not the way they have handled 

8 the record at Weldon Spring.

9 And then, we were hesitant, if 

10 there was an air sample, well, could this air 

11 sample have been associated with that daily 

12 weighted exposure report? It could have. 

13 Could we prove that it was? No, we couldn't. 

14 There was a lot of ambiguity in the 

15 relationship because the working papers were 

16 associated with the final reports.

17 DR. BUCHANAN: Okay, yes, I guess 

18 that is the clarification that we hadn't had 

19 in the past. Let me reiterate a few things 

20 here so we understand each other.

21 You are saying the summary report 
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23 1 or the calculations were done and the raw 

2 data; you wanted to make sure that those two 

3 correlated, and there might have been more raw 

4 data there available but you didn't have a 

5 summary report that correlated exactly with 

6 that. And so, you didn't use, say, page 9 and 

7 13 and 11 because it didn't correlate to a 

8 given summary report. Is that correct?

9 MR. MORRIS: You said it well, 

10 Ron.

11 DR. BUCHANAN: Okay. And so, 

12 there was more raw data than you could use 

13 because you didn't have the summary report 

14 that showed the calculations and that you 

15 could do an error analysis on.

16 MR. MORRIS: That's correct.

17 DR. BUCHANAN: Okay.

18 MR. MORRIS: We didn't want to use 

19 data that we couldn't correlate to a daily 

20 weighted exposure report. We knew that there 

21 were air sample results out there that were 
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24 1 not directly mapped -- that we chose not to 

2 use because we couldn't map them to a daily 

3 weighted exposure report.

4 DR. BUCHANAN: Okay. That is a 

5 clarification that we needed.

6 And then, also, I just want to 

7 clarify another issue is that the thorium data 

8 did not have any of the raw data with it, 

9 right? The thorium data was only summary 

10 reports and you couldn't cross-compare it to 

11 the raw data?

12 MR. MORRIS: Yes, we tried hard, 

13 and we could not unequivocally make those 

14 correlations of this air sample correlated 

15 with this report. So, we chose not to use 

16 them instead of trying to be misleading. We 

17 wanted our conclusions to be directly 

18 supportable.

19 DR. BUCHANAN: Okay. Well, John, 

20 I think that that answers our question on why 

21 were there more data. When I looked at it, I 
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25 1 seen there was more data, but it wasn't used. 

2 It is that there wasn't a calculational sheet 

3 to go along with the raw data. And so, I 

4 think that clarifies it for me. Do you have 

5 any other questions on that?

6 MR. STIVER: No, that clarifies it 

7 for me, too.

8 MR. MORRIS: So, back to my 

9 comments further, then, I wanted to point out 

10 that, in the interim since we did the Weldon 

11 Spring evaluation of the errors and blunders -

12 - and this has always been a touchy subject 

13 about whether we caught blunders -- NIOSH did 

14 not invent this term about blunders. It comes 

15 from an ISO standard about how to express 

16 uncertainty. And blunder is a technical term 

17 in that. So, if I use that word, it is not in 

18 a derogatory manner in any sense. It is just 

19 it happens to be the technical language of 

20 that standard that we worked against.

21 So, when we actually got the 
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26 1 commission from another Work Group to do this 

2 same evaluation at Fernald, the Fernald 

3 records were organized differently. We were 

4 able to identify about 17,000 records or data 

5 points or transcription opportunities or 

6 calculational opportunities that were 

7 available in the sample that we picked at 

8 Fernald.

9 We spent two or three weeks. 

10 Because we knew how bad the representation of 

11 the data was at Weldon Spring, we thought, 

12 well, let's go look at a sister plant with an 

13 identical process, an identical procedure, and 

14 again, transcribing and transcriptions and 

15 calculations without calculators.

16 And so, we overdid the sampling at 

17 Fernald. What we found was that the error 

18 rate at Fernald was significantly less, closer 

19 to the 1 percent, as you might have expected. 

20 The impacts were about half as much as they 

21 were at Weldon Spring. Again, Fernald was 
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27 1 below both the Adam Davis/Dan Strom evaluation 

2 for AWE sites and for the Weldon Spring site.

3 So, we have got one more important 

4 data point on exactly how humans interact with 

5 this procedure that was invented at the Health 

6 and Safety Lab of the DOE in the 1940s, and 

7 find again that the error rates are pretty 

8 much where you would have expected them, based 

9 on our observation from this Davis and Strom 

10 paper.

11 So, when we look at this all 

12 together, I think that you can say that this 

13 is a snapshot of data that confirms the idea 

14 that the human errors that went into the 

15 calculations are limited, essentially, because 

16 you are trying to report a number between a 

17 minimum and a maximum as an average value, and 

18 if you have a number that is below or above 

19 that minimum/maximum, any proofreading is 

20 going to discover most of those errors. If 

21 your average is higher than your maximum, you 
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28 1 sort of go, that was a big mistake and you 

2 redo it.

3 So, inherently, the magnitude of 

4 the errors is somewhat constrained, and the 

5 impact of the errors tends to take the median 

6 value where SC&A has recommended we do 

7 calculations for intake rates for most people, 

8 and it is in the 2 or 3 percent range. It 

9 increases about 2 or 3 percent.

10 So, we feel that we have answered 

11 a question that was specifically asked and 

12 have shown that the impact of the human 

13 blunders on the uncertainty of intake rates 

14 calculated at Weldon Spring for daily weighted 

15 exposure methods is not large and can be 

16 bounded.

17 COURT REPORTER: Speaker, please 

18 identify yourself.

19 MEMBER LEMEN: This is Dr. Lemen.

20 I ask NIOSH, in light of the 

21 discussion we have just had, what they feel 
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29 1 the next steps should be with the Weldon 

2 Spring dataset. Do you have a recommendation 

3 of where we should go with Weldon Spring at 

4 this time?

5 MR. ROLFES: Well, this is Mark 

6 Rolfes.

7 As of right now, what we have 

8 proposed in our Evaluation Report, that we can 

9 bound thorium intakes based upon the daily 

10 weighted exposure values that we have just 

11 discussed. We now have presented information 

12 showing that the intakes calculated from the 

13 daily weighted exposure data are reliable and 

14 have a small error associated with them of 4 

15 percent, which is pretty insignificant.

16 We have previously been assigning 

17 thorium intakes for the Weldon Spring plant 

18 based upon information from the Fernald 

19 facility. We have presented this new daily 

20 weighted intake approach to demonstrate that 

21 the thorium intakes can be bound.
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30 1 So, ultimately, I believe it is in 

2 the Advisory Board's hands to decide whether 

3 or not our proposed method of doing thorium 

4 dose reconstructions at the Weldon Spring 

5 plant is agreeable to them, is agreeable to 

6 the Advisory Board.

7 MEMBER LEMEN: Dave Richardson, do 

8 you have any further comment at this time?

9 MEMBER RICHARDSON: No, I don't.

10 MEMBER LEMEN: With that in mind, 

11 I am not sure if it is appropriate -- do we 

12 need another recommendation in writing from 

13 NIOSH to the Board, or where do we go from 

14 here, Ted? I'll need your help on this one.

15 MR. KATZ: Sure. Hi. This is Ted 

16 Katz.

17 I think this conversation has been 

18 excellent for clarifying matters that weren't 

19 clear. So, I think the transcript is probably 

20 adequate without a new report, although, 

21 ultimately, depending on how this is handled, 
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31 1 if there is a TBD revision, for example, down 

2 the road, that things would be stated more 

3 clearly there, and what have you.

4 So, I am not sure that there is 

5 more for NIOSH or SC&A to do on this front. 

6 It is really now a matter for the Work Group 

7 to consider, just as Mark said, what your 

8 judgment is on this, and then to report this 

9 out the Board, which can consider the same 

10 matter.

11 MEMBER LEMEN: Do you think that 

12 we would be able to, unless Dave has an 

13 objection to this -- and I haven't talked to 

14 Mike, who is the Chairperson; ultimately, he 

15 has the final say -- that we, as the Board, 

16 could, as the Working Group, I mean, could 

17 present to the Board in the February meeting 

18 what we have gone over today and then get the 

19 Board's comments, and go ahead and close this 

20 matter out and get Weldon Spring moved 

21 forward?
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32 1 MR. KATZ: Yes, Dick, this is Ted 

2 again.

3 So, I mean, this is one of the two 

4 matters the Board wanted the Work Group to 

5 finish up on. Yes, I agree, I think you can 

6 report this out, either Mike or yourself, 

7 depending on who is in attendance.

8 You know, reporting it out, I 

9 guess you have to make a judgment as to 

10 whether you are satisfied with this method or 

11 not. Your recommendation is to the Board. 

12 You know, the Board will make its judgment, 

13 but it is useful to have a recommendation from 

14 the Work Group as to its view on each of these 

15 matters.

16 MEMBER LEMEN: Okay. I don't know 

17 how to get a hold of Mike. But if you can do 

18 that, Ted, maybe --

19 MR. KATZ: No, Dick -- I'm sorry, 

20 this is Ted again. Mike, if he is not in 

21 attendance, he is not part of the 
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33 1 deliberation. I mean, so it is really --

2 MEMBER LEMEN: Up to me and Dave?

3 MR. KATZ: It is really you and 

4 Dave that are here to make a judgment for 

5 that. Again, it is not really a critical 

6 matter. You are reporting out to the Board, 

7 but the Board will take up the matter itself 

8 as a whole and make a judgment.

9 MEMBER LEMEN: All right. So, 

10 with that said, I suppose we should go to the 

11 next item, and we can, at the end of this, 

12 where we have a discussion of report to the 

13 Board, we can decide where we go from there.

14 But the next item happens to be 

15 the response to Brad Clawson, Member of the 

16 Board, from NIOSH. Could you talk about that, 

17 NIOSH?

18 MR. ROLFES: Sure. Thanks, Dr. 

19 Lemen. This is Mark Rolfes again.

20 At the December Board meeting in 

21 Tampa, Brad Clawson had identified a document 
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34 1 that was written up, I believe, as part of an 

2 epidemiology study conducted by Oak Ridge 

3 Associated Universities around 1991.

4 This document, the subject was 

5 Mallinckrodt Chemical Works: Four-Plant Study 

6 Classifications of Radium, Radon and Thorium 

7 Exposure. This document had basically 

8 described historical use of various 

9 radionuclides at Mallinckrodt as well as 

10 Weldon Spring.

11 I will go over my response. 

12 Basically, Brad had identified this document, 

13 Brad Clawson, and also Jim Lockey had 

14 mentioned it to me in the hall at the Board 

15 meeting, that this document had identified 

16 that there was thorium production operations 

17 going on at Mallinckrodt and then, 

18 subsequently, for the time period of 1958 

19 through 1966, at the Weldon Spring plant.

20 When this was identified in this 

21 document, it was identified as thorium 
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35 1 operations. And so, that is what I believe 

2 had caught Brad Clawson's eye, was that there 

3 was thorium processing going on at Weldon 

4 Spring plant for this entire time period.

5 The thorium processing that was 

6 done was the extraction of thorium-230 from 

7 the ore concentrates, the uranium ore 

8 concentrates, and not necessarily production 

9 of thorium-232, which only occurred from 1963 

10 through 1966 at the Weldon Spring plant.

11 So, this document had identified 

12 plain thorium. It didn't specify necessarily 

13 in the text whether or not it was thorium-230 

14 or thorium-232. You have to read the context 

15 of the report to determine whether they are 

16 referring to the extraction of thorium-230 

17 from uranium ore concentrates or whether they 

18 are referring to the production of thorium-232 

19 metal, for example.

20 That was the clarification that I 

21 had. Basically, all the information that we 
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36 1 have gathered and all of the research that we 

2 have conducted indicates that thorium-232 

3 operations were conducted in short campaigns 

4 in the time period of 1963 through 1966. We 

5 also have information on the specific 

6 operation and the duration of those campaigns, 

7 by building, within our Evaluation Report.

8 I don't recall what table it is 

9 right off the top of my head, but if you give 

10 me just a second, I can pull that up and 

11 identify it for the record. Let's see. I am 

12 flipping through my report at this time.

13 Let's see, in Table 5-2, we have a 

14 chronological summary of thorium operations at 

15 the Weldon Spring plant and we have given an 

16 operation title, the building number and the 

17 time period broken down by month and year that 

18 operations were conducted in each of the 

19 buildings. This is on page 19 of our 

20 Evaluation Report for SEC 143.

21 MS. JOHNSON: Mark, this is Karen 
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37 1 Johnson, petitioner.

2 MR. ROLFES: Yes, Karen?

3 MS. JOHNSON: Can you tell me what 

4 source was used for that table?

5 MR. ROLFES: Let me see. Under 

6 the table, in our Evaluation Report, we have 

7 the source. The note says, created with 

8 information from Weldon Spring feed materials, 

9 summaries of dust concentrations at production 

10 jobs. And it is MCW, 1958 through 1966.

11 If I go back to the end page 

12 -- excuse me -- back to the reference section, 

13 let me see if I can get you any additional 

14 information that might help you.

15 Okay. It is MCW, 1958 through 

16 1966, summaries of dust concentrations at 

17 production jobs, Weldon Spring feed materials 

18 plant, Mallinckrodt Chemical Works, Uranium 

19 Division, 1958 through 1966. This came out of 

20 our Site Research Database.

21 MS. JOHNSON: Okay, so you have 
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38 1 any original time period document?

2 MR. ROLFES: Yes, we do.

3 DR. BUCHANAN: This is Ron 

4 Buchanan of SC&A.

5 Karen, also, I went back and 

6 checked this out, double-checked it. The 

7 reference ID, I don't know if you have access 

8 to the reference ID, but the reference ID 0400 

9 and 8252, verifies the receipt of thorium at 

10 Weldon Spring.

11 MS. JOHNSON: Okay. Thanks.

12 MEMBER LEMEN: Any other 

13 questions, Karen?

14 MS. JOHNSON: I actually do have a 

15 question back on raw data for thorium, on the 

16 first item. I guess I am confused about how 

17 that is being calculated, because I thought I 

18 heard somebody say there is no raw data for 

19 thorium.

20 MR. ROLFES: This is Mark Rolfes, 

21 Karen.
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39 1 The method, we were basically 

2 addressing the error rates in the methodology 

3 that was used to determine an individual's 

4 airborne exposure, irregardless of the type of 

5 radionuclide. This method was, this daily 

6 weighted exposure method was used for uranium 

7 as well as thorium. We had a positive 

8 association between a Daily Weighted Exposure 

9 report and raw data that we can conclusively 

10 say that this raw data was used to develop 

11 this DWE report.

12 We focused on those relationships 

13 where we knew that this raw dataset was 

14 associated with this particular report. It 

15 may be that we have raw data for thorium 

16 operations. However, we weren't able to 

17 conclusively say that these data were tied to 

18 this evaluation, Daily Weighted Exposure 

19 Evaluation Report.

20 Does that answer your question?

21 MS. JOHNSON: Yes. I guess I 
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40 1 really just am not trusting all of this data. 

2 To me, that's a lack of data. So, I guess I 

3 am just not agreeing with the process.

4 MR. ROLFES: Now, keep in mind, we 

5 do have the summary data for thorium 

6 exposures. We just didn't have the raw data 

7 available, and we are using the summary data 

8 available to us to assign thorium intakes to 

9 Weldon Spring plant workers.

10 MEMBER LEMEN: When you say 

11 "summary intake" -- this is Dick Lemen again 

12 -- when you say "summary intake," could you be 

13 a little bit more specific on that?

14 MR. ROLFES: Well, we had the 

15 range of concentrations, the air 

16 concentrations, to which a worker might have 

17 been exposed. However, we don't have the 

18 calculations that support those air 

19 concentrations in all instances, that we can 

20 conclusively say this dataset was used to 

21 develop this report.
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41 1 MEMBER LEMEN: So, you cannot say 

2 for any individual exactly what their 

3 exposures were?

4 MR. ROLFES: Well, one couldn't 

5 conclusively say what any individual's 

6 exposure was. What we are doing is assigning 

7 an intake that is bounding, and we believe 

8 will overestimate the actual intake incurred 

9 by workers at the Weldon Spring plant.

10 MEMBER LEMEN: But this is taken 

11 from summary data and not from actual 

12 measurement data on the worker, is that 

13 correct?

14 MR. MORRIS: Mark, this is Bob. 

15 Can I interject?

16 MR. ROLFES: Yes, Bob. Yes, 

17 please.

18 MR. MORRIS: This is Robert Morris 

19 with ORAU team.

20 Dr. Lemen, to address your 

21 question, when we say "daily weighted 
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42 1 exposure," what we are trying to convey here 

2 is that there is an average air sample 

3 concentration that represents the workplace. 

4 And so, for example, we will take an air 

5 sample -- I don't say "we". I take this as my 

6 data analysis, I have used it so often, but it 

7 is not my data.

8 An air sample would be taken to 

9 represent the concentration in a room, for 

10 example, on three or four different days. 

11 Those would be averaged. That average, then, 

12 goes into the calculation of how often a 

13 person was in that room.

14 So, what we have got is the final 

15 report that says this person was in this room 

16 for 10 minutes and the average concentration 

17 was 100. And so, you weight that into how 

18 many minutes are in the day, and that is how 

19 you do a weighted exposure.

20 Now what we are missing, in terms 

21 of the raw data being directly associated, is 
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43 1 maybe there were four air samples, as I said, 

2 taken to represent the concentration in that 

3 room. We can't tell you which four air 

4 samples in the large list of air samples that 

5 were out there were the four that went into 

6 getting the average. But we do have the 

7 average.

8 MEMBER LEMEN: Okay.

9 MR. MORRIS: So, when we say can't 

10 go all the way back to the raw data, that is 

11 true. But there is really no reason to think 

12 that people can't take average numbers and, in 

13 general, report them correctly.

14 We have actually quantitated how 

15 important those -- when people do make 

16 mistakes, how important those mistakes are, 

17 and they seem to have a 2 to 4 percent impact 

18 increasing the outcome -- increasing the 

19 intake rate calculation.

20 MEMBER LEMEN: Bear with me a 

21 second.
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44 1 These are general room samples? 

2 Is that what you are telling me?

3 MR. MORRIS: I am using general 

4 room samples as an example. We also would 

5 take samples representing a process. Maybe it 

6 was opening a container. Maybe it was loading 

7 a furnace. And each of those would have been 

8 sampled a few times to get the average air 

9 concentration that occurred when that event 

10 occurred.

11 MR. ROLFES: Bob, this is Mark.

12 To clarify what you said, and 

13 maybe help explain, Dr. Lemen, they might 

14 focus on one chemical operator doing a drum15 dumping operation for an hour at a given air 

16 concentration. And then, in combination with 

17 that one-hour exposure at that air 

18 concentration, they would also say, well, he 

19 was also in the area while someone else was 

20 doing the work for 30 minutes, and they would 

21 apply a general area air concentration for 
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45 1 those 30 minutes. Then, they might have 

2 tracked him to another job possibly or to 

3 lunch and had either a breathing-zone-specific 

4 air sample result or the background air 

5 concentration result for a given amount of 

6 time in the cafeteria. So, those are all 

7 combined to add up to an eight-hour day or an 

8 eight-and-a-half-hour day. I don't recall 

9 which one was used.

10 MEMBER LEMEN: So, what you are 

11 saying is that, while he is working, there is 

12 sampling being done. And then, they may 

13 follow that worker while he is on a break or 

14 in the lunch room and continue that sampling. 

15 And then, the average is taken from both of 

16 those areas. Is that correct?

17 MR. ROLFES: The worker --

18 MR. MORRIS: That is correct. In 

19 fact, this method has been used ever since it 

20 was first invented at the Health and Safety 

21 Laboratory in the 1940s. It has been used up 
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46 1 until today in industrial hygiene practice. 

2 And it is a very common approach to trying to 

3 define the exposure potential of a worker, 

4 whether he is working around, he or she is 

5 working around gasoline vapor or dust --

6 silica dust. This daily weighted averaging 

7 concept is widely used.

8 MEMBER LEMEN: I know that, but I 

9 was concerned about the sampling being taken 

10 in the work area and then averaged with 

11 sampling taken where, supposedly, there is no 

12 exposure in the cafeteria area.

13 MR. MORRIS: The 30 minutes in the 

14 cafeteria is part of the daily exposure. And 

15 so, that is included in the time-weighted 

16 average exposure for the worker.

17 MEMBER LEMEN: Okay.

18 MR. MORRIS: We have described 

19 that in our original paper on how daily 

20 weighted exposure measurements are done.

21 MEMBER LEMEN: I understand.
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47 1 MR. MORRIS: That sort of goes 

2 back, what, two years, is that right, John 

3 Stiver?

4 MR. STIVER: Yes, that is about 

5 right.

6 I think the important thing is 

7 that, for any given worker, there are going to 

8 be a series of breathing zone samples. There 

9 would be a lapel-type sampler to try to get a 

10 more representative sample of a particular 

11 operation that might have involved a higher 

12 exposure potential.

13 But, say, scrubbing out a 

14 reduction pot liner, or something, one of the 

15 dirtiest jobs. Very high concentration, but 

16 relatively short duration, maybe about 30 to 

17 45 minutes, if I recall correctly.

18 And so, what they do is they 

19 follow this worker. They outline the 

20 different tasks involved in his particular 

21 job. So, for each one of those tasks, there 
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48 1 is a certain time allotment associated with 

2 it, and, also, concentrations. For those 

3 operations that are particular to that job, 

4 they would use the breathing zone samplers. 

5 And then, for, say, going to the cafeteria or 

6 changing out in the locker room, and so forth, 

7 they would use a general air sample to 

8 represent the time spent in that particular 

9 environment.

10 And then, at the end of the day, 

11 basically, what we would have is about eight12 and-a-half hours' worth of time, total time, 

13 allocated among these different tasks. And 

14 so, we would multiply the concentration, the 

15 average concentration for a task, times the 

16 time it took to take that task, sum all those 

17 values up, and then divide by the total time. 

18 That gives you the weighted average.

19 MEMBER LEMEN: Dave Richardson, do 

20 you have any comment on this approach?

21 MEMBER RICHARDSON: No, not on 
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49 1 this approach.

2 MEMBER LEMEN: Are you satisfied 

3 with it?

4 MEMBER RICHARDSON: Yes.

5 MEMBER LEMEN: Okay. Any other 

6 comments on this particular area?

7 MS. JOHNSON: This is Karen 

8 Johnson again.

9 I guess I am still confused 

10 because I have been told over those years that 

11 there were very few air samples taken at 

12 Weldon Spring. Can you comment on how many 

13 samples there actually were?

14 MR. ROLFES: This is Mark Rolfes.

15 Bob Morris has spent quite a large 

16 amount of time going through the air sampling 

17 results. I would defer to him at this time.

18 I can get a response back to you 

19 on a better idea of the number of air samples. 

20 There is definitely a large quantity of air 

21 sampling data, and I think we had identified 
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50 1 in these daily weighted exposure reports 

2 roughly 1400 different operations which were 

3 air-sampled. Now this is just what was 

4 available to us at the time we did the 

5 analysis. I believe there probably are 

6 additional air samples.

7 But, Bob, maybe if you might have 

8 a better feel for the quantity of air samples 

9 available from the Weldon Spring site?

10 MR. MORRIS: Sure. I don't know 

11 the number. We certainly can make an effort 

12 to try to find that, about what is available 

13 in our record-set.

14 But I think it is worth noting 

15 that there was a person whose job it was, 

16 maybe two people whose job it was, to go out 

17 and sample air routinely around the plant. 

18 There are air samples representing most days 

19 at some place most days.

20 So, I don't think it is accurate 

21 to say there were very few air samples taken. 
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51 1 Somebody's job was to go take air samples.

2 MS. JOHNSON: Okay, and one of my 

3 concerns is, in speaking with hundreds of 

4 workers over the last 10 years, none of them 

5 remember having their area monitored for air 

6 sampling or their breath sampled.

7 MEMBER RICHARDSON: And this is 

8 David Richardson.

9 I think what was said, both things 

10 that have been said probably are true. I 

11 mean, it is getting to a distinction between 

12 what is meant on average to be able to 

13 characterize a place and a time and what would 

14 be necessary in terms of data collection to 

15 characterize a person's potential exposure and 

16 its variation over time, over decades.

17 So, while there are many samples 

18 that were collected, you are being asked to 

19 extrapolate from those samples to characterize 

20 exposure concentrations that were dynamic and 

21 were not identical for everybody in every 
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52 1 place. So, if there was one or there were two 

2 people who were moving through collecting 

3 samples, that is not the same as an individual 

4 having experience in a plant and having a 

5 recollection that they were wearing an air 

6 sampler the way that somebody might wear a 

7 radiation dosimetry badge, and have to wear it 

8 every day onsite while they are being exposed. 

9 It wasn't that kind of monitoring program.

10 MR. MORRIS: That's right, and you 

11 have put your finger on a real key. That is 

12 one of the items that we have had long 

13 conversations about over the past two years. 

14 That is why we have as an uncertainty 

15 estimator value. When we take the value that 

16 is reported in the daily weighted exposure 

17 dataset for a given building for a given year, 

18 we multiply that. It has got an uncertainty 

19 factor of plus or minus a factor of five 

20 associated with it, unlike most of the kinds 

21 of internal dose assessments we do, which has 
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53 1 a multiplier, times or divide factor of three.

2 So, this has got a really large 

3 uncertainty factor associated with it to 

4 accommodate just exactly what you raised as a 

5 concern. That is called the geometric 

6 standard deviation as opposed to the standard 

7 deviation, which is a plus-or-minus kind of 

8 uncertainty. This is a times-or-divide kind 

9 of uncertainty. So, it really spans a big 

10 range of data when we put that in, and it 

11 becomes very favorable to the claimant by this 

12 approach.

13 MR. ROLFES: Karen, this is Mark 

14 Rolfes once again, regarding the number of air 

15 dust samples that were taken.

16 I am looking back through our 

17 Evaluation Report, at the end on page 80 of 

18 90. We have listed a summary of the holdings 

19 that we have in our Site Research Database for 

20 the Weldon Spring plant. It doesn't tally up 

21 the quantity of air sample results, but it 
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54 1 does give you a feel for how many documents we 

2 might have that contain radiation monitoring 

3 information, air dust sampling results.

4 Just looking back on page 80, 

5 about in the middle of the page, we have a 

6 statement that we have uploaded, roughly, 230 

7 documents back in 2009 with information that 

8 had urine and air dust samples, radiological 

9 surveys, air pathway analyses. Let's see, the 

10 next on there, there is some additional 

11 sampling information.

12 If you would like maybe a better 

13 estimate of the number of air samples that 

14 were collected, we can see if we can possibly 

15 get a better response for you.

16 MEMBER LEMEN: Is it possible to 

17 get that to the claimant and to the Board, 

18 just so we will have it on record?

19 MR. ROLFES: We sure can. We will 

20 work to get that as best we can as soon as 

21 possible. This will just be a ballpark 
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55 1 estimate that we will try to get to you as 

2 soon as we can.

3 MEMBER LEMEN: Are there other 

4 questions from the petitioners at this time?

5 MS. JOHNSON: I don't have any 

6 more. Thank you.

7 MEMBER LEMEN: Any other 

8 petitioners with questions?

9 (No response.)

10 Hearing none, I guess the last 

11 item --

12 MEMBER RICHARDSON: Yes, before we 

13 move to the last item, during this discussion 

14 we sort of moved back to the agenda item 1. 

15 I would like to close out with the second 

16 item, about processing dates or operational 

17 dates.

18 MEMBER LEMEN: Okay. Who is 

19 speaking?

20 MEMBER RICHARDSON: David 

21 Richardson.
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56 1 MEMBER LEMEN: Oh, hi, David.

2 MEMBER RICHARDSON: Hi.

3 MEMBER LEMEN: Go ahead.

4 MEMBER RICHARDSON: Am I correct 

5 in understanding the discussion today that a 

6 substantial basis for the dates, for 

7 establishing the dates on which thorium 

8 processing was done is the air monitoring 

9 data? That seemed to be the description of 

10 kind of the cited information for the dates 

11 that were quoted from the table.

12 MR. ROLFES: Yes. This is Mark 

13 Rolfes.

14 And the reference that we had 

15 identified was the dust study document, I 

16 believe. I don't recall if we had conducted 

17 any kind of interviews. Maybe Bob might be 

18 able to remind me.

19 Do you recall if we asked anyone 

20 from the Weldon Spring plant?

21 MR. MORRIS: Yes, we did interview 
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57 1 people and asked those questions. But, 

2 frankly, it has been years now, and I don't 

3 remember the specific answers. But we did 

4 look into more than one source of data to try 

5 to find the operational dates.

6 MR. ROLFES: I think that is 

7 correct, Bob. From what I recall, I think 

8 maybe Karen and the petitioners may have 

9 identified this issue to us during our 

10 Evaluation Report.

11 Let me see if we have addressed 

12 this or discussed anything additional here in 

13 our Evaluation Report. I am not seeing it 

14 jump out at me at this second.

15 But I know we did hear this 

16 concern from the petitioners, and this was 

17 something that we did conduct a series of 

18 interviews about. Yes, there were concerns 

19 about, let's see -- is that correct, Karen? 

20 Am I stating something that is correct? I 

21 thought you did express earlier concern about 
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58 1 the thorium exposure potential in earlier 

2 years of the site. We have discussed this 

3 before, I believe. Is that accurate?

4 (No response.)

5 Karen?

6 MEMBER LEMEN: Karen, are you 

7 still there?

8 MS. JOHNSON: This is Karen.

9 I do recall, that has been a big 

10 concern of ours because, as we have gone 

11 through FOIA documents, we have compiled a 

12 small stack of documents that do state that 

13 thorium was processed on a larger-scale basis. 

14 It appears they are talking of thorium-232. I 

15 don't know for sure.

16 Tina may know more about some of 

17 that than I do. I don't know if she is still 

18 on the line.

19 But that is a big concern of ours 

20 because we are not sure where the `63 to `66 

21 is coming from.
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59 1 MEMBER LEMEN: In what respect do 

2 you mean that? Can you explain a little bit 

3 better?

4 MS. JOHNSON: Well, we have just 

5 seen in the Site Profile, in an Evaluation 

6 Report, it is stated that thorium processing 

7 was done between 1963 and 1966 and that it 

8 wasn't there earlier than that, maybe for a 

9 very brief period at one point. But we are 

10 not sure what references are being used to 

11 determine that.

12 MEMBER LEMEN: Well, do you have 

13 evidence that it was there before 1963?

14 MR. ROLFES: I think the reference 

15 that Karen is mentioning was the same one that 

16 Brad Clawson had identified during the 

17 Advisory Board meeting in December. And that 

18 was the reason for the preparation of our 

19 response on basically separating out 

20 thorium-230 extractions from uranium ore 

21 concentrates versus thorium-232 production.
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60 1 DR. BUCHANAN: This is Ron 

2 Buchanan with SC&A.

3 If you look at reference ID 8252, 

4 pages 26 through 29, and especially table 6 on 

5 page 28, it gives the receipt of thorium at 

6 Weldon Spring. It shows their inventory and 

7 their incoming and outgoing inventory receipts 

8 each year from `58 through `66, through `67, 

9 actually. And that inventory sheet shows that 

10 it was that they didn't really ramp up until 

11 `64, actually.

12 They had 44 kilograms in a barrel 

13 that apparently remained unopened. It was on 

14 every year, the same amount. And then, in 

15 `63, they received 5 kilograms, and then, in 

16 `64, they received 13,000 kilograms; in `65, 

17 313,000 kilograms; in `66, 614,000 kilograms, 

18 and none in `67.

19 So, that was a base document that 

20 I found on the Research Database. It is 8252.

21 MS. JOHNSON: Ron, this is Karen 
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61 1 again.

2 I guess that is something that we 

3 are at a disadvantage with. We haven't seen 

4 any receipts for shipping or inventory. Is 

5 there any way we can get copies of those?

6 MR. ROLFES: Karen, this is Mark.

7 You certainly can request this 

8 information under the Freedom of Information 

9 Act. And I believe you are familiar with that 

10 process.

11 MS. JOHNSON: Yes.

12 MR. ROLFES: If you have any 

13 questions --

14 MS. JOHNSON: Okay. We thought we 

15 had already requested absolutely everything.

16 MR. ROLFES: I think you requested 

17 everything related to thorium operations. I 

18 actually had gone through some of these 

19 documents to identify which ones had 

20 information related to thorium.

21 MS. JOHNSON: I think we did 
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62 1 receive a small number of receipts, but it 

2 appeared that was all there was for Weldon.

3 MEMBER RICHARDSON: Just as a 

4 comment, and I haven't been on the Board that 

5 long, but if that type of inventory 

6 information was available and could be 

7 included as supporting basis in any of the 

8 documents related to this, that would seem to 

9 me more standard, in my limited experience, 

10 with describing the dates than relying on air 

11 monitoring, kind of the period during which 

12 monitoring was done.

13 Because, personally, I start to 

14 have a level of discomfort with saying, 

15 because there was monitoring done or not done 

16 in a period, there was potential for exposure. 

17 It is almost putting the cart before the 

18 horse.

19 MR. ROLFES: Sure, sure.

20 MEMBER LEMEN: So, you will 

21 provide that?
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63 1 MR. ROLFES: I am sorry. This is 

2 Mark. Dr. Lemen, in order for us to provide 

3 this reference, if we have not provided it 

4 yet, we would have to receive a FOIA request 

5 from the petitioners.

6 MEMBER LEMEN: Well, I thought 

7 Dave just asked you to provide it, too.

8 MR. ROLFES: Oh, we certainly can 

9 provide it to the Advisory Board. However, we 

10 can't provide it directly to the petitioners 

11 without a FOIA request for it.

12 MEMBER LEMEN: I understand that, 

13 but, as I understood what Dave just said, I 

14 think he was requesting you provide it to the 

15 Board.

16 MR. ROLFES: Oh, sure.

17 MEMBER LEMEN: Is that correct, 

18 Dave?

19 MR. ROLFES: Definitely. We can 

20 identify that document and provide it.

21 MEMBER LEMEN: That is what you 
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64 1 were asking, right, Dave?

2 MEMBER RICHARDSON: Yes, I was 

3 also sort of thinking -- I don't know where 

4 you are with closing this issue out, but in 

5 terms of technical documents, whether it is 

6 the Site Profile document or something else, 

7 that it would become part of the cited 

8 literature and the basis for setting these 

9 dates.

10 MEMBER LEMEN: Okay. If we could 

11 ask you to provide that to the Working Group, 

12 I would appreciate it.

13 MR. ROLFES: I sure will.

14 MS. TRIPLETT: This is Tina 

15 Triplett.

16 And there are several documents 

17 that show that thorium was processed since 

18 1958, actually, even from the Atomic Energy 

19 Commission. So, I am not sure. I mean, if it 

20 is there, it should be given the benefit of 

21 the doubt to the petitioners that it was there 
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65 1 the whole entire time.

2 MEMBER LEMEN: Can you respond to 

3 that, Mark?

4 MR. ROLFES: Yes. Thanks, Dr. 

5 Lemen.

6 Tina, this is Mark.

7 If you could provide these 

8 documents to us -- I haven't seen anything 

9 different from what we have available to us 

10 from ORAU's epi study that I had referred to 

11 earlier. If you might be able to send in 

12 these documents to us, we would definitely 

13 take a look at them.

14 MS. TRIPLETT: Okay. I am pretty 

15 sure that this information you already have 

16 because this is some of the stuff that came in 

17 the FOIA request. But there's tons of 

18 documents out there that state it was there 

19 the whole time. So, I can send you what I 

20 have, but you should already have it.

21 MR. ROLFES: That would be great, 
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66 1 if you could identify those documents.

2 MEMBER LEMEN: Would it be 

3 appropriate -- I don't know, like Dave, I am 

4 new to the Board; I have only been on a short 

5 time -- but is it appropriate for us to ask 

6 NIOSH to get together and discuss these 

7 documents, since it appears they have already 

8 been provided in the FOIA, with the 

9 petitioners, so that we cut down on some time? 

10 In other words, the two of you just directly 

11 talk to one another.

12 MR. ROLFES: I am definitely 

13 available to have any sort of discussion 

14 needed. If there is information regarding 

15 thorium processing earlier on, it would be new 

16 to us. We have no indication that there was 

17 any kind of thorium-232 operations being 

18 conducted at the Weldon Spring plant prior to 

19 1963, and that is consistent with every source 

20 of information that we have available to us.

21 MR. HINNEFELD: This is Stu 
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67 1 Hinnefeld of DCAS.

2 I joined a little late. So, I 

3 didn't introduce myself at the beginning.

4 But we should be able to do that. 

5 We do try to maintain open lines of 

6 communications with petitioners on all our 

7 petitions. I don't see this as being outside 

8 of those lines of communications. So, unless 

9 my lawyers advise me differently, I think we 

10 can pursue that.

11 But, to Mark's point, though, 

12 typically, a FOIA request in many cases 

13 results in very, very many documents being 

14 delivered. And so, if petitioners could 

15 identify to us the specific ones that they 

16 feel show the presence of thorium prior to 

17 `63, that would help us and facilitate that 

18 discussion quite a lot.

19 MEMBER LEMEN: Could I ask -- and

20 again, I don't know if this is appropriate 

21 because I haven't been on the Board that long. 
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68 1 Ted will tell me if it is not, I'm sure, or 

2 one of the lawyers.

3 But could I ask NIOSH to initiate 

4 that discussion with the petitioners?

5 MR. ROLFES: This is Mark Rolfes.

6 We would have to have the document 

7 available first before we could discuss it, I 

8 guess.

9 MEMBER LEMEN: No, but, I mean, 

10 couldn't you pick up the phone and talk to the 

11 petitioner?

12 MR. ROLFES: Oh, sure, definitely, 

13 we can.

14 MEMBER LEMEN: And try to identify 

15 the documents. And then, you could pull the 

16 documents and look at them, and then you could 

17 get back together and discuss what the 

18 petitioners are talking about?

19 MR. ROLFES: Oh, definitely. I 

20 would be happy --

21 MEMBER LEMEN: So that we 
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69 1 eliminate all the red tape of going through an 

2 FOI again and all that kind of stuff.

3 MR. ROLFES: Yes, definitely.

4 What amount of time would be 

5 reasonable for you to take a look, Tina, for 

6 me to contact you?

7 MS. TRIPLETT: I mean, I have it 

8 in front of me. So, I don't know how to get 

9 it to you.

10 MR. ROLFES: Well, I would be 

11 happy to give you a call after this conference 

12 call is over.

13 MS. TRIPLETT: Okay.

14 MEMBER RICHARDSON: This is David 

15 Richardson.

16 So, one of the issues that you 

17 have brought up, because we have discussed 

18 this issue earlier in the call, is the 

19 distinction you are making between thorium on 

20 site and thorium-232, is that right?

21 MR. ROLFES: The issue that was 
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70 1 identified in this ORAU team document, I can 

2 read over my response. I am not sure if you 

3 have seen this, Dr. Richardson. But this 

4 might not be so clarifying, but I will go 

5 ahead and read my email to Brad Clawson here.

6 It says, "At the Advisory Board 

7 meeting in Tampa, you had mentioned finding 

8 documentation of thorium processing operations 

9 at the Weldon Spring plant from 1958 through 

10 1966. The two documents which were embedded 

11 in the attached PDF" -- in my email -- "which 

12 have information regarding thorium operations 

13 during this time period were produced by ORAU 

14 in 1991 and 1998.

15 "These documents included 

16 information on all thorium operations 

17 conducted at both Mallinckrodt as well as the 

18 Weldon Spring plant, and don't clearly 

19 delineate differences between thorium-230 and 

20 thorium-232."

21 I identified that he was correct 
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71 1 that thorium operations occurred at the Weldon 

2 Spring plant from 1958 through 1966, and that 

3 NIOSH was also aware of this.

4 "The operations during this time 

5 period in its entirety, 1958 through 1966, in 

6 the context of the two ORAU references, were 

7 related to thorium-230 operations, operations 

8 involving the dissolution and chemical 

9 separation of uranium from uranium ore 

10 concentrates which contained primarily 

11 thorium-230 and other uranium decay chain 

12 progeny.

13 "NIOSH has information regarding 

14 the potential exposures to thorium-230 and 

15 other ore concentrate radionuclides in the 

16 Site Profile for Weldon Spring and, also, in 

17 Special Exposure Cohort Petition Evaluation 

18 Report and other White Papers specific to the 

19 Weldon Spring plant.

20 "On the other hand, thorium-232 

21 production operations were conducted at the 
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72 1 Weldon Spring plant only during the 1963-

2 through-1966 time period on an intermittent, 

3 campaign-driven schedule. Potential exposures 

4 to thorium-232 at Weldon Spring plant are 

5 discussed in the Weldon Spring plant Site 

6 Profile, the SEC Petition Evaluation Report, 

7 and in White Papers for the Weldon Spring 

8 plant as well."

9 So, that was my summary attempt to 

10 try to delineate the differences between 

11 thorium operations of, you know, operations 

12 involving the extraction of thorium-230 from 

13 ore concentrates and the production of 

14 thorium-232 on a campaign-driven basis in the 

15 later years.

16 MEMBER LEMEN: This is Dick Lemen 

17 again.

18 Dave, do you have more comments or 

19 questions?

20 MEMBER RICHARDSON: No.

21 MEMBER LEMEN: It looks to me --
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73 1 and if I am misstating this, please correct 

2 me; I am sure you will, anyhow -- but it seems 

3 like, with this last discussion, we have just 

4 had another rock put in the middle of the road 

5 as far as coming to some conclusion on Weldon 

6 Spring. Is that the reading the rest of you 

7 are getting?

8 (No response.)

9 Hearing no comment, I guess that 

10 must be true.

11 I suppose what we need to do is 

12 get a report back from NIOSH after they have 

13 talked to the petitioners about this time 

14 period before 1963 that is in question, before 

15 we can make a further recommendation to the 

16 Board. Is that something you agree with, 

17 Dave?

18 MEMBER RICHARDSON: I mean, I 

19 think that sounds useful, just to be diligent, 

20 making sure that these concerns are addressed.

21 MEMBER LEMEN: So, with that in 
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74 1 mind, I think, Ted, that might be our report 

2 to the Board. We can talk to the Board about 

3 having resolved at least the questions in 

4 point one and two on the agenda. But I think 

5 we have to wait to present any final 

6 recommendation to the Board from the Working 

7 Group until we have this last rock removed 

8 from the road.

9 Is that in agreement with you, 

10 Dave?

11 MEMBER RICHARDSON: Sure.

12 MEMBER LEMEN: Ted?

13 MR. KATZ: I am sorry. This is 

14 Ted.

15 I managed to disconnect myself in 

16 the last minute. And so, I gather, the last I 

17 heard you were saying there is a rock in the 

18 road, and then I just heard you pick up with 

19 there is a rock in the road and you can't make 

20 a recommendation until we remove it.

21 MEMBER LEMEN: Basically, that is 
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75 1 correct. And the holdup on that would be for 

2 NIOSH to pick up the phone and talk to the 

3 petitioners and identify these documents that 

4 indicate the data gap on the missing material 

5 that they feel is there prior to 1963, and 

6 then for NIOSH to report back to the Working 

7 Group their findings on that. That is where I 

8 was going.

9 MR. KATZ: Okay. Thanks for that 

10 recap, Dick. I am sorry, but I just pressed 

11 the wrong button at the wrong time.

12 So, yes, you have a couple of 

13 options. I mean, Weldon Spring is on the 

14 agenda for the Board for this next meeting. 

15 It sounds to me like it is relatively quick 

16 work to have this conference -- I mean, I 

17 don't know what will come of it -- but 

18 relatively quick work to have this conference 

19 with the petitioners and sort out whatever 

20 discrepancy there is in their different 

21 understandings of what data are available.
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76 1 So, I mean, I think you could ask 

2 Mark, or whoever is going to be presenting for 

3 NIOSH, to present at the Board meeting on the 

4 results of that discussion and whatever 

5 confusion has been sorted out from that.

6 It doesn't give an opportunity for 

7 the Work Group to meet again, but Weldon 

8 Spring was already on the Board's plate and 

9 was discussed at the last Board meeting as 

10 well. So, whether or not the Board wants you 

11 to return and have another Work Group meeting 

12 or not is unclear to me. It may be that it --

13 MEMBER LEMEN: This is Dick Lemen 

14 again.

15 I am not sure that is necessary. 

16 I think your idea, Ted, is a good one, for 

17 Mark to get this done before the California 

18 meeting and report to the full Board. I 

19 think, at least on my part, and I hope on 

20 Dave's part, that we could resolve this issue 

21 maybe at the Board meeting with this 
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77 1 additional information from Mark after the 

2 discussion.

3 Is that agreeable to you, Dave?

4 MEMBER RICHARDSON: Yes.

5 MEMBER LEMEN: It is agreeable to 

6 me, too, Ted. So, that is the way I would 

7 like to handle it.

8 MR. KATZ: That sounds good. That 

9 sounds efficient.

10 And then, the other thing is just, 

11 I mean, you and David haven't really opined on 

12 the first issue, the blunders issue, yet, but 

13 you have to decide whether you want to make a 

14 recommendation regarding closing out that 

15 issue, where you come down as a recommendation 

16 for the Board.

17 And sort of related to that, I 

18 think Ron Buchanan could sort of summarize. 

19 We have the latest SC&A response to the NIOSH 

20 response on that issue.

21 But it would be nice to have, 
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78 1 since we won't have a transcript at that time, 

2 it would be nice if Ron could just write up a 

3 final document sort of resolving the ambiguity 

4 that there was up until this meeting about 

5 that issue.

6 MEMBER LEMEN: All right. Maybe 

7 if that is done, Dave and I can talk and maybe 

8 we can talk -- I don't know when it is on the 

9 agenda, I don't remember, for the California 

10 Board meeting. Is it the first or second day?

11 MR. KATZ: Let me think.

12 MR. ROLFES: This is Mark again.

13 I believe it is the second day.

14 MR. KATZ: Yes, I think that is 

15 right.

16 MEMBER LEMEN: If it is the second 

17 day, maybe Mike and Dave and I can have a few 

18 minutes to just discuss this before, and we 

19 could make a presentation, then, at the second 

20 day to the Board and maybe get Weldon Spring 

21 included.
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79 1 MR. KATZ: Yes, you certainly can 

2 talk and present at the Work Group meeting. 

3 Would you like Ron to write up a little sort 

4 of summary of at least the technical 

5 resolution of the blunders questions?

6 MEMBER LEMEN: Yes.

7 MR. KATZ: Okay.

8 MEMBER LEMEN: And I would like 

9 him to, then, circulate that to me, Mike, and 

10 Dave, if he could.

11 MR. KATZ: Yes, well, I will 

12 actually circulate that to the whole Board 

13 because they will have these other documents 

14 that have come in most recently as well to 

15 look at, or the last document from SC&A at 

16 least.

17 MEMBER LEMEN: All right.

18 MR. KATZ: Yes.

19 MEMBER LEMEN: Are there any 

20 comments, further comments or final comments, 

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

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80 1 MS. JOHNSON: You know, there was 

2 one other item that came up at the last Board 

3 meeting.

4 Sorry. This is Karen Johnson 

5 again.

6 And it had to do with lack of 

7 worker data for, I think it was monitoring 

8 data, for the first few operating years at 

9 Weldon. Am I right about that?

10 MEMBER LEMEN: I don't know the 

11 answer to that.

12 DR. BUCHANAN: This is Ron 

13 Buchanan, SC&A.

14 And I think what you are referring 

15 to is we did that limited initial data 

16 completeness-and-accuracy test last summer. 

17 We found that the overall badging and bioassay 

18 rate was around 90 to 94-5 percent, but that 

19 there was no badging in `67, of course, and 

20 when the plant was closed down, and that the 

21 years 1958 and 1959 were not as high as their 
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81 1 averages. It was more like -- I don't recall 

2 -- I think maybe 60 or 70 percent rather than 

3 95 percent.

4 MS. JOHNSON: Okay. Thank you.

5 MEMBER LEMEN: All right. Any 

6 other comments, Karen or Tina?

7 MS. JOHNSON: I think that's it 

8 for me for now.

9 MEMBER LEMEN: Any other 

10 petitioners on the line?

11 (No response.)

12 If not, I think where we stand is 

13 that Ron is going to summarize what we 

14 discussed on issue one. I guess, as far as 

15 issue two, do you want to add that in your 

16 summary or do you want to keep that separate?

17 DR. BUCHANAN: Well, are you 

18 speaking to me, to Ron?

19 MEMBER LEMEN: Yes, and I was 

20 wondering if maybe Mark Rolfes could just give 

21 you that information and you could throw it 
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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COURT REPORTERS AND TRANSCRIBERS 

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82 1 into your report.

2 DR. BUCHANAN: Well --

3 MEMBER LEMEN: Or do you think 

4 that is two separate issues that should be 

5 done separately?

6 DR. BUCHANAN: Yes, I think it is 

7 two separate issues. I would like to get this 

8 out, so the Board would have it before the 

9 meeting.

10 If Mark would call Tina and get 

11 that document, look at that, and then provide 

12 a response to the Work Group, I think that 

13 would work best.

14 MEMBER LEMEN: All right. That 

15 will be fine.

16 Are there any other comments? I 

17 think we have an action plan and a path to 

18 follow. Any other comments by you, Dave, 

19 or --

20 MEMBER RICHARDSON: No.

21 MEMBER LEMEN: Okay. Anything 
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed and 

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COURT REPORTERS AND TRANSCRIBERS 

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83 1 further from SC&A?

2 DR. BUCHANAN: I don't.

3 MR. STIVER: Nothing here. This 

4 is Stiver.

5 MEMBER LEMEN: Anything further 

6 from NIOSH?

7 MR. ROLFES: I don't believe so, 

8 Dr. Lemen.

9 MEMBER LEMEN: Okay. Ted, I will 

10 turn it back to you because I think we have 

11 concluded this Working Group meeting. I will 

12 let you finish it up.

13 MR. KATZ: Well, I would just like 

14 to say to everyone, the petitioners, the 

15 staff, everyone, Board Members. I think this 

16 was a productive meeting.

17 And, Dick, you get the pleasure of 

18 adjourning it.

19 MEMBER LEMEN: What?

20 MR. KATZ: We are adjourned.

21 MEMBER LEMEN: Oh, okay. Thank 
This transcript of the Advisory Board on Radiation and Worker Health, Weldon Spring Work Group, 

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

information has been redacted as necessary. The transcript, however, has not been reviewed and 

certified by the Chair of the Weldon Spring Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to change. 

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COURT REPORTERS AND TRANSCRIBERS 

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84 1 you.

2 MR. KATZ: Thank you.

3 (Whereupon, at 11:24 a.m., the 

4 meeting was adjourned.)

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