NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Subcommittee for Procedure Reviews

Tuesday, Feb 15, 2022

The Subcommittee convened via Teleconference at 

11:00 a.m. EST, Josie Beach, Chair, presiding.
2

Members Present:

Josie Beach, Member

Loretta Valerio, Member

Paul Ziemer, Member

Also Present:

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Dave Allen, DCAS

Bob Anigstein, SC&A

Bob Barton, SC&A

Kathy Behling, SC&A

Fin Black, SC&A

Ron Buchanan, SC&A

Grady Calhoun, DCAS

John Cardarelli, DCAS

Rose Gogliotti, SC&A

Lara Hughes, DCAS

Alek Kranbuhl, DCAS

Lori Marion-Moss, DCAS

Robert McGolerick, HHS

Michael Rafky, HHS

Lavon Rutherford, DCAS

Tim Taulbee, DCAS
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Subcommittee for 

Procedure Reviews Tuesday, Feb 15, 2022 1

Roll Call/Welcome 4

Carry-over Items from Feb. 13, 2019, Feb. 18, 

2021, & Nov. 3, 2021 Subcommittee Meetings

5

ORAUT-OTIB-0006 6

OTIB-0011 9

OTIB-0001 12

ORAUT-TKBS-0060 20

DCAS-PER-087 43

OTIB-0088 48

ORAUT-OTIB-0049 58

Newly Issued SC&A Reviews 75

Battelle-TIB-5000 "Default Assumptions 

and Methods for Atomic Weapons 

Employer Dose Reconstructions" 76

DCAS-PER-045, Subtask 4 "Aliquippa 

Forge TBD Revision" case review 96

Preparation for April 2022 Full ABRWH 

Meeting: Review of Technical Guidance 

Documents Ready for Full Board Approval 103

Newly-Issued Guidance Documents and 

Supplemental Topics 108

Next WG Meeting/Plans 126

Adjourn 127
4

Proceedings

(11:00 a.m.)

Roll Call/Welcome

Dr. Roberts: So welcome to the Advisory Board on 

Radiation and Worker Health. This is a meeting of the 

Subcommittee on Procedures Review. I'm Rashaun 

Roberts and I'm DFO for the Board. 

There is an agenda for today. It's on the NIOSH 

website. It's under February 2022.

Now since the Subcommittee will be discussing a 

number of different documents some of which involve 

specific sites, we do need to address our conflicts of 

interest. So if a conflict does happen to come up 

during the course of the meeting, Subcommittee 

members do need to recuse themselves from the 

discussion where their conflict may apply.

So as we move through the roll call, Subcommittee 

members and others, please state whether you have 

a conflict of interest. And we will start with Chair 

Beach.

(Roll call.)

Dr. Roberts: Okay. Great. All right. Well, thank you 

and again welcome to all of you. I do need to go over 

a couple of additional items before I give the floor 

over to Josie Beach, who is our chair.

In order to keep everything running smoothly and so 

that everybody can be heard, please mute your 

phone unless of course you're speaking. If you don't 

have a mute button, please press *6 to mute. To take 

yourself off, press *6 again. And again the agenda, 

the presentations, background documents, et cetera 

that are relevant to today's meeting can be found on 

the DCAS website. And all of these materials were 

sent to the Board members and other staff prior to 

this meeting.

So with that, Josie, over to you.
5

Chair Beach: Okay. Thank you, Rashaun. 

So as Rashaun said, our meeting agenda is posted. I 

do want to ask -- we're scheduled to (telephonic 

interference). And we typically don't take a full lunch 

break. If that's going to be an issue with somebody, 

please message me or let -- speak up. We'll go half

way through the agenda and then take a 15, 20-

minute break and then get back onto the agenda. We 

do have a full agenda and I'm wondering if there are 

any changes in the order that people need to possibly 

do one before the other. Is there anything like that 

happening today? 

Kathy, do you know of anything?

Ms. Behling: No, Josie. The only thing I will mention 

is if the presentations that are coming in perhaps this 

afternoon, the PER presentations, if they start to 

encroach on the 3:00 time frame, I think we should 

move to items such as selecting documents that have 

already been reviewed by the Subcommittee that we 

want to present at the full Board meeting in April so 

that we cover all of those items before maybe all of 

the presentations. So we'll base that on the time 

frame.

Chair Beach: Okay. That sounds good. And we are 

scheduled to go to 3:30, so --

Ms. Behling: Yes.

Carry-over Items from Feb. 13, 2019, Feb. 18, 

2021, & Nov. 3, 2021 Subcommittee Meetings

Chair Beach: -- we'll definitely keep an eye on that. 

So thank you for that.

I do want to mention that there was a lot of work that 

went into -- if you were reading and getting prepared 

for this meeting, you saw that there was a lot of work 

that went into prepping for this meeting. So I want 

to thank everyone for that ahead of time. 

And we are going to start with the carry-over items. 
6

I know we're not going to be able to close out all of 

them. There may be a couple. Kathy said she was 

prepared to take us through those. And of course, 

NIOSH, jump in where you would need to. 

So with that said, if there's no other comments or 

announcements, we can go ahead and start with our 

carry-over items and the OTIB-0006.

Kathy, are you going to present anything during the 

carry-overs?

Ms. Behling: There's going to be some presentations, 

yes. 

Chair Beach: Yes.

Ms. Behling: I can lead into that. And I can also put 

the agenda up on the screen, if you want. I just --

Chair Beach: Sure.

Ms. Behling: -- have not been able to share my --

okay. Looks like I am able to do that now. Okay. Hold 

on one second. 

(Pause.)

ORAUT-OTIB-0006

Ms. Behling: All right. There's the agenda.

All right. We're going to start with, as Josie said, 

OTIB-0006, and that's the dose reconstruction for 

occupational medical X-ray procedures. And Ron 

Buchanan has been involved in this OTIB, so I'm 

going to turn it over to him and let him give just some 

response to this carry-over item.

Chair Beach: Okay. Thank you.

Dr. Buchanan: Okay. Yes, this is Ron Buchanan. Can 

you hear me okay?

Chair Beach: Yes.

Dr. Buchanan: Okay. This is OTIB-0006, which is the 
7

occupational dose reconstruction for medical X-ray 

procedures. And this is a fairly lengthy one. It's been 

revised six times, and so I'll go back and just let you 

know that what we're focusing on here is the Revision 

6 to see if it addressed our issues from our evaluation 

of Revision 5.

So Revision 5 was issued in August of 2018, and 

SC&A did an evaluation of Revision 5 and issued a 

report in January of 2019. We had no findings. We 

had 7 observations and about 10 documentation 

items to address.

And so in the meantime Revision 6 was issued in 

September of 2019. And so in January of 2021 the 

chair of this Committee tasked SC&A with a focused 

review to determine if Revision 6 addressed our 

concerns from our evaluation of Revision 5. 

And so we performed that review, that focused 

review, and issued a report on the 3rd of February of 

2021. And this Committee discussed that during a 

meeting on February 18th of 2021 and seven 

observations -- of the seven, five were closed during 

that February meeting a years ago and two remained 

open. And the two that remained open was No. 2 and 

No. 7 and most of the documentation issues were 

addressed and satisfactory during that meeting a 

year ago.

Now the two that remained open concerned the chest 

thickness being changed from 23 centimeters in older 

editions of OTIB-0006 to 24 centimeters in Revision 

5 and 6. And so we didn't have a problem with it 

being changed from 23 to 24 centimeters because 

the literature showed that it ranges from 20 to 25 

centimeters, but did want some documentation on 

how they arrived at that. 

And NIOSH responded to our concerns about 

documentation on the BRS on February the 19th of 

2021, a day after that Committee meeting, and 

stated that they derived that 24 centimeters using 

the Monte Carlo neutron-photon edition on ICRP1010 and they arrived that 23.9 centimeters and 
8

rounded it up to 24 centimeters.

And so we -- that's the information we requested and 

so we at this time recommend that that observation 

be closed; it's been satisfied.

Chair Beach: Okay. So let me make sure I 

understand. So we closed 2 at the last meeting, so 

the last one was just the update for 7, and you're 

recommending you -- closure?

Dr. Buchanan: No, this was 2. We closed all but No. 

2 and No. 7, yes. And I was discussing No. 2, which 

is the chest thickness. And we received 

documentation on that, on the BRS. And we agree 

with that, and so we recommend that the Committee 

close Observation 2. 

Chair Beach: Okay. I just had 2 as closed last

meeting, so I have that incorrect. Okay. Thank you.

Dr. Buchanan: Okay.

Chair Beach: And then --

Dr. Buchanan: No. 7.

Chair Beach: Yes, go ahead.

Dr. Buchanan: Okay. And then No. -- yes, No. 7 had 

to do with Procedure 61. Now Procedure 61 was being 

phased out and replaced by OTIB-0006 revisions, and 

Attachment C contained a breakdown of medical Xray doses for the skin other than entry dose. And so 

we had been using it in a dose reconstruction, been 

using it. And OTIB-0006 Revision 5 and 6 no longer 

contained that information in it. And so we 

questioned on how we were supposed to do it. Then 

we had some discussion and then NIOSH said they 

would respond in a BRS, and they did on the 29th --

let's see, the 19th of February. They explained that 

page 24 of the new revision of OTIB-0006 provided 

equations. Instead of using the tables out of 

Procedure 61 or OTIB-0006 that we were to use the 

table out of NCRP-102(b)(8), I believe it was. And so 
9

we followed that trail and we agreed with that. And 

so we recommend closure of Observation 7 also.

Chair Beach: Okay. Thank you, Ron.

Questions, Paul or Loretta?

Member Ziemer: I have no questions. Thank you.

Member Valerio: I don't have any questions, Josie.

Chair Beach: Okay. So then we're in agreement with, 

Ron, your assessment of that and agree to close.

Member Ziemer: I'm comfortable with closing, yes.

Chair Beach: Okay. Thank you.

Member Valerio: I'm good, Josie, thank you.

Chair Beach: Okay. Thank you.

Thanks, Ron. 

Dr. Buchanan: Okay. Thank you.

Ms. Behling: Okay. I think can we move on?

Chair Beach: Yes, please.

OTIB-0011

Ms. Behling: Okay. The second item under the carryover is OTIB-0011, and OTIB-0011 is the dose 

conversion factors for radon working level months. 

And to the best of my knowledge, when I went back 

through this, the only thing that I could see that 

might be outstanding is during the last meeting Steve 

Marschke presented information regarding OTIB0066, and OTIB-0066 -- let me go here and -- that is 

calculation of dose from intakes of special tritium 

compounds. And as part of our review of OTIB-0066 

our first finding had to do with the fact that they were 

recommending using the methodology in OTIB-0011, 

and that was imbedded into OTIB-0066. However, 

that -- we discussed that finding and as a resolution 

to that Finding 1 NIOSH did remove those statements 
10

and they are no longer referring to OTIB-0011 for 

calculating doses from intakes of organically-bound 

tritium. So that resolved the issue. And that's the 

only thing that I could find under OTIB-0011. So it 

was discussed at the November meeting and I believe 

it was closed.

Now did you have something else in mind when you 

put that on this list, Josie?

Chair Beach: Well, from what I remember it was a 

clean-up item in the BRS. And without being able to 

backtrack and look at the BRS, I'm going to have to 

go with your comment there. 

Ms. Behling: Okay.

Chair Beach: So that's all that was.

Ms. Behling: Okay.

Chair Beach: And that's the note that I wrote down.

Ms. Behling: Okay. 

Chair Beach: So I --

Ms. Behling: And that's good. 

Chair Beach: -- (telephonic interference) --

Ms. Behling: And, yes, what we should make sure to 

do, I have put together along -- Josie and Lori 

Marion-Moss -- we put together a temporary BRS 

matrix. And we should make sure that this item gets 

put in there so that when we do get access to the 

BRS again we update any information associated with 

OTIB-0011.

Chair Beach: Yes, and I think we need to do that with 

the previous one, too, 0006. So, yes.

Ms. Behling: Yes, anything that we talk about today 

-- when I put together that BRS matrix, I tried to 

include all of the discussions that we had at the last 

meeting. The prior meeting in February I had the 
11

opportunity to actually go into the BRS and update 

the BRS before we lost access. So the temporary 

matrix that we have will include anything from the 

last meeting and all of the items that we discuss 

today.

Chair Beach: Okay. Yes, and that was my whole point 

of this was just trying to clean up so things made 

sense when we --

Ms. Behling: Right.

Chair Beach: -- went into the BRS. Ms. Behling: 

Great. Great.

Chair Beach: So, perfect. So we can consider that 

item closed out, thank you --

Ms. Behling: Okay.

Chair Beach: -- and added to the matrix.

Ms. Behling: Okay.

Chair Beach: Paul, Loretta, okay with that? No 

disagreement?

Member Valerio: I'm good with that, Josie.

Member Ziemer: Yes, we're good.

Chair Beach: Okay. Thanks.

Mr. Barton: This is Bob. If I might though -- and 

maybe this is not the 

right --

Chair Beach: Sure.

Mr. Barton: -- moment for this, but we've talked 

about how NOCTS is never coming back the way it 

used to be and the SRDB is going to be different. Is 

the BRS going to be essentially the same, or do we 

not even know at this stage how that's going to 

progress? (Telephonic interference) --
12

Mr. Calhoun: This is Grady and --

Mr. Barton: Yes.

Mr. Calhoun: -- I think we don't know for sure. 

They've committed to us that everything including 

NOCTS and BRS is going to have the same 

functionality, but it may not look the same and it may 

function differently but still be able to do what we 

want. So something will be available and it should be 

similar, we hope. That's what we're hoping for. So 

that's all I can really tell you.

Mr. Barton: Fair enough, Grady. Fair enough.

Chair Beach: Thanks.

OTIB-0001

Ms. Behling: Okay. If we're ready, we'll move on to 

Item No. 3, which is OTIB-0001. And OTIB-0001 is 

maximum internal dose estimates for Savannah 

River site. And that was actually canceled, and based 

on the note on the internet on the NIOSH website the 

guidance was moved to OTIB-0018. 

So at the last meeting I believe Josie indicated that 

there are still some open findings in OTIB-0018 and 

we need to go back and look at those. 

So I did that and what I found from OTIB-0018 -- and 

I will mention that I believe I updated the information 

that we found -- in fact it was Lori that provided me 

with the PDF from the BRS that she had luckily 

captured before we lost access. And I uploaded that 

to the ABDA virtual volume so you can look at what 

the discussion was throughout the time frame. 

And actually we reviewed that back in like the 2006 

time frame and the Finding 5 that is still open; it's in 

progress, has to do with -- we felt that there should 

be a more thorough evaluation of their monitoring 

programs at the DOE facilities in order to ensure that 

OTIB-0018 represents claimant-favorable approach 

to assessing internal dose.
13

And there was a great deal of discussion at various 

meetings in 2007 and 2008 and I think what it really 

came down to is Mark Griffin was on the Board at the 

time and he had some very specific questions. He 

was concerned that the list of radionuclides did not 

include all the worst-case radionuclides and 

specifically associated maybe with Mound. 

And he had questions such as what is NIOSH's 

evidence that sites covered by OTIB-0018 had a 

robust air sampling program? He also asked what is 

NIOSH's evidence that those sites took appropriate 

action when air sample action levels were exceeding 

and are the worst-case radionuclides covered. 

Specifically he was referring to various radionuclides 

at the Mound site.

And NIOSH's response was that there was not a 

rigorous review program, but that they really needed 

to go to the authors of the various TBDs and that the 

authors would need to be queried again for more 

definitive information to answer his questions. And 

that's the last that we had any discussion on this 

issue. And I'm not sure that there was -- that NIOSH 

followed through with that and so I'm really not sure 

how to proceed from here.

Chair Beach: Well, and, Kathy, that's one instance, 

but I also went back through and I read the 

transcripts from that 10/2/2007 meeting and 

nowhere did it talk about that specific 0018. So that 

was the other thing I had. There was quite a bit of 

notation in that whole document that shows that it 

was discussed and decided and closed, but really if 

you go back and read that transcript, it's not there. 

So I think that was one of my issues with 0018. And 

I don't -- has 0018 even been revised since that? It's 

an old document.

Ms. Behling: It is. No, it has been. And in fact that 

was going to be my next comment. Our other finding 

was Finding 6 and we indicated that OTIB-0018 may 

not be claimant-favorable for organs of the 

respiratory tract. And the response to that was 
14

NIOSH indicated that they were going to put more 

specific information into that OTIB to ensure that the 

dose reconstructors understood that. And that was a 

comment that was made back in 2007 and the 

revision -- there has been no revision to OTIB-0018. 

Rev. 1 was dated August 9th, 2005 and it has not 

been revised. But that's (telephonic interference) --

Dr. Taulbee: This is Tim. 

Chair Beach: Yes, go ahead, Tim. Thanks.

Dr. Taulbee: I just wanted to give an update that we 

are revising OTIB-0018. It is currently working its 

way through the review cycle at this time so there is 

a new revision of OTIB-0018 that will be coming out.

Chair Beach: Terrific. Okay. So I guess I would 

propose that we hold this discussion. This was a 

twofold: We hadn't fixed the findings, but there was 

also some question on the BRS and being able to 

backtrack who put what in. And there was two I think 

that were transferred, but it never said where they 

were transferred. There were several that said they 

were closed, but there was really no notation or 

documentation that the Subcommittee closed. It was 

just recommended closing. 

So I guess I would say that we hold off on any more 

discussion on this until the new issue is released and 

then we can task SC&A to review. Does that seem 

agreeable?

Member Ziemer: Could you clarify for me now -- and 

this is Paul. So OTIB-0001 is canceled. That was 

correct to start with, right?

Ms. Behling: Correct, that was my understanding.

Member Ziemer: (Telephonic interference) that's 

canceled. On 0018 is -- Kathy, is -- Findings 5 and 6 

were the only ones you said appeared to be still open, 

or was there --

Ms. Behling: That's correct
15

Member Ziemer: -- lack of documentation on the 

other ones, on the other findings?

Ms. Behling: As Josie mentioned, some of them were 

transferred, but I do agree with Josie, I think we need 

to go back and review all of these findings once again 

and especially in light of the revision that's going to 

be coming out.

Member Ziemer: Yes, that makes sense. And take a 

look at the revision and any findings that need to go 

forward or haven't been handled in the revision. Even 

if they have we need to make sure that we've handled 

5 and 6 and any of the others that are unclear.

Ms. Behling: Yes, agreed.

Dr. Taulbee: Josie, can I make a recommendation 

here that you kind of close out the OTIB-0001 since 

that document is canceled and just make this OTIB0018, because that seems to be the concern here?

Chair Beach: Yes, I would agree with that. 

And we would want to add that to our matrix, Kathy, 

if that seems agreeable to everybody. Because 0001 

is canceled, correct?

Ms. Behling: Yes. Yes, definitely we --

Chair Beach: Okay.

Ms. Behling: -- should move it to OTIB-0018. 

Chair Beach: Okay. So let's do that formally today if 

everybody's in agreement and document it in the 

matrix and then with the notation that things are 

moving to the OTIB-0018. And then we'll add the 

revision and review also. 

Does that make sense, Paul and Loretta?

Member Ziemer: Yes. 

And, Tim, could you clarify, when is the timeline 

roughly on the revision?
16

Dr. Taulbee: I knew you were going to ask that. I'm 

sorry, Paul.

Member Ziemer: Well, I don't -- I know you can't fully 

commit, but I mean are we talking in the next few 

months or is this off a ways, I mean in the priority 

list?

Dr. Taulbee: I'm hoping it's in the next few months, 

but it could be longer than that. It could be six 

months because --

Member Ziemer: Okay.

Dr. Taulbee: -- of some of the other things -- other 

TBDs we're trying to get out right now.

Member Ziemer: Yes. Likely it will be this year 

though? That's (telephonic interference) I'm getting 

at, yes.

Dr. Taulbee: Yes.

Member Ziemer: Okay. Thank you.

Chair Beach: And, Tim, this is Josie. You said that 

was in the review process. Has it been updated?

Dr. Taulbee: It has, but one of the -- several of the 

review comments are quite significant, so it's --

Chair Beach: Okay.

Dr. Taulbee: -- kind of going back.

Chair Beach: Okay. So we'll keep track of that. And 

then if you could let us know when that comes out?

Dr. Taulbee: Yes, will do.

Chair Beach: Okay. Everybody agree with that?

Member Ziemer: One other question. So have we --

by this action are we actually tasking SC&A to do 

those things once the revision is out?

Chair Beach: That's a great question. I would agree 
17

with that, however I'll have Rashaun answer that, if 

that's something we can do in advance.

Dr. Roberts: I would suggest waiting for the revision.

Chair Beach: Okay.

Ms. Behling: Okay. This is Kathy, and would you like 

to move on? 

But if I may -- and this is something I was going to 

discuss later in the day under the supplemental 

topics, but since it seems relevant now and I'm not -

- I'm hoping we're going to get to the supplemental 

topics. One of the things that has become a little bit 

more challenging for SC&A at this point in time is 

becoming aware of when new revisions are put out, 

when new documents have been issued, when 

documents have been canceled. 

And I know that there's usually some type of an email 

sent out, but I'm wondering if we could set up better 

communications or a more formal means or 

communication so that we become aware when these 

documents have either been revised or newly issued 

or canceled. Is that something we can talk about now 

in light of this OTIB-0018?

Chair Beach: I don't see why not. And I found in my 

documents there's a review status of NIOSH's 

technical guidance documents and we received it --

this is dated as of October 21st, 2018, and it was --

it's a whole -- several pages of all the documents. So 

I know that they have that in their system. I'll turn it 

over to Tim or Lori to answer the full question though 

if that's something that we can have access to more 

often.

Ms. Marion-Moss: Josie, this is Lori. Normally when a 

document has been revised and published an email 

was sent to Rashaun. I mean I can add you guys, 

SC&A, on the distribution of that when that happens 

the document, the published document into a folder, 

their old O: drive. So now I'm sure most of you are 

aware that I have the approved documents in the 
18

virtual volume and I will continue to add documents 

to that as they are published. 

I guess the question remains (telephonic 

interference) else be added to the distribution that I 

send out when the document is (telephonic 

interference). 

Ms. Behling: And I would appreciate --

Ms. Marion-Moss: I still --

Chair Beach: Oh, go ahead, Lori. Oh, I'm sorry. 

Kathy.

Ms. Behling: Okay. I was going (telephonic 

interference) that in the past -- and I don't know this 

is -- but Ted used to send to SC&A like a (telephonic 

interference) a list of documents that were recently 

issued or revised to ask us if we could review that, 

look it over and to ask if we thought that it was worth 

being -- having it reviewed. So that was what we 

used to do in the past also. So I don't know if 

Rashaun wants to do that or if we want to just add 

SC&A onto some distribution list.

Dr. Roberts: I think just maybe to regulate this a little 

bit I can take up that practice that Ted had and do 

that --

Ms. Behling: Okay. Thank you.

Dr. Roberts: -- do what was done in the past.

Ms. Behling: Yes. Okay. That would be very helpful 

for us.

Chair Beach: Well, and since we're on this, does that 

include the templates, too, Lori?

Ms. Marion-Moss: Sorry. I didn't hear your question.

Chair Beach: Oh, I was wondering does that also 

include the templates when they're revised, because 

I know those go through revision occasionally. Would 

that be added to that?
19

Ms. Marion-Moss: Templates?

Chair Beach: Yes.

Member Ziemer: Yes, I think you're talking about the 

work books that -- there was something in the 

discussion for today's meeting that mentioned that a 

couple of I think the work books got changed and 

SC&A wasn't aware of it.

Ms. Behling: Yes, they're called templates. They're 

dose reconstruction methodology --

Member Ziemer: Yes, templates.

Ms. Behling: -- templates, yes.

Member Ziemer: Yes.

Ms. Behling: Yes, we will have that discussion during 

one of my presentations.

Member Ziemer: Right, but I think she --

Ms. Behling: Perhaps (telephonic interference) --

Chair Beach: -- Josie's asking if you should get 

notified when those are revised or changed. 

Chair Beach: I was asking Lori --

Member Ziemer: Wasn't that what you were asking, 

Josie?

Chair Beach: Yes, I was asking Lori if that -- if her 

documentation that she sends to Rashaun -- if that 

includes the templates. That's what I was asking.

Ms. Marion-Moss: In the past, Josie, it did not include 

the DR methodology templates.

Member Ziemer: Okay.

Ms. Marion-Moss: And I guess that's something we 

can discuss.

Chair Beach: Okay. We'll leave that for later 
20

discussion though because I know it's coming up. I 

just thought I'd check with you now.

Okay. Any other questions or comments regarding 

the last issue?

Member Valerio: I don't have any, Josie.

Chair Beach: Okay. Thank you.

And I know, Paul, you asked one.

The next issue --

Member Ziemer: Yes. No, we're good on the path 

forward. Sounds good.

ORAUT-TKBS-0060

Chair Beach: Okay. Thanks, Paul.

And the next issue is (telephonic interference) 0060. 

And I know that NIOSH has a memo issued, so, Lori, 

-- or not Lori, NIOSH, are you going to take that up 

or is Kathy going to go through it?

Mr. Kranbuhl: Yes, this is Alek Kranbuhl. Can 

everyone hear me okay?

Chair Beach: Yes. Hi, Alek.

Mr. Kranbuhl: Hi. Like I said, I'm Alek Kranbuhl. I'm 

the site lead for Grand Junction so I'll be just covering 

the memo real quick.

So we issued this memo in response to the five 

observations --

Chair Beach: Can I ask a question? Can that be 

posted on the Skype since we have Skype? Can these 

(telephonic interference) --

Mr. Kranbuhl: I can try to share my desktop if that's 

okay.

Chair Beach: I was thinking Kathy's already sharing. 

She may have that available.
21

Mr. Kranbuhl: Oh, sure.

Chair Beach: (Telephonic interference).

Ms. Behling: Do I have access to that? I'm not sure I 

have it. 

Chair Beach: Oh, I don't know if you do. Yes, 

(telephonic interference).

Ms. Behling: Oh, okay. Okay. Was it put on the 

website?

Chair Beach: Yes, it was.

Ms. Behling: Okay. Let's see if I can find that.

Chair Beach: It was one of the earlier ones.

Ms. Behling: Okay. Now was this put on the virtual 

volumes, or was this actually posted on the website.

Ms. Marion-Moss: Kathy?

Ms. Behling: Yes?

Ms. Marion-Moss: This is Lori. It was put on the 

website as well as virtual volumes.

Ms. Behling: Okay. I am scrolling through here. Do 

you see my screen? Okay. And this is --

Chair Beach: Sorry to throw that at you.

Ms. Behling: No, that's okay. I'm just not seeing it. 

(Pause.)

Mr. Rutherford: Is it down under discussion papers?

Ms. Behling: Okay. Because I --

Chair Beach: It was the meeting -- one of the biggest 

problems with this situation is we don't have access 

to those readily.

Mr. Barton: I think I see it. It's actually under the 

Grand Junction web page --
22

Chair Beach: Yes.

Mr. Barton: -- instead of under the procedures. 

Ms. Behling: Okay. I can go there.

Ms. Gogliotti: And perhaps for record keeping we 

could get it added to the meetings for future 

meetings.

Chair Beach: I thought it was in the meetings list.

Ms. Behling: I am not having much success here. 

Chair Beach: Should I give control over to NIOSH at 

this point? I apologize.

Chair Beach: Yes. Yes, that's probably --

Ms. Behling: Okay. I'm going to stop presenting. 

Mr. Kranbuhl: All right. I should be sharing my 

screen. I don't know if everyone can see.

Chair Beach: No, not yet. 

Mr. Kranbuhl: No?

Chair Beach: Oh, there (telephonic interference).

Mr. Kranbuhl: Okay.

Ms. Behling: (telephonic interference).

Dr. Taulbee: Try now, Alek.

Mr. Kranbuhl: Okay. Let me try again. 

Chair Beach: Ah, there we go. Seeing something.

Mr. Kranbuhl: All right. Should be seeing a memo.

Chair Beach: Yes, it's there, Alek. Thank you.

Mr. Kranbuhl: Oh, okay. Is this a good size for 

everybody? Do I need to zoom? I'll zoom in a little 

bit.
23

Okay. So like I was saying, we issued this 

memorandum in response to the five observations 

that SC&A had for the Site Profile for Grand Junction. 

So the first observation was just concerning some 

unclear language in the occupational medical dose 

section. The wording in there basically said that preemployment, annual, and post-employment PA and 

AP X-rays be assigned for each year, which would be 

incorrect. So they were to do that literally. So since 

we will be revising the technical basis document 

based on some other observations we're going to go 

ahead and commit to just straightening out that 

language. So making sure that's clear that the preemployment and post-employment X-rays are only 

one time and then annual PA and AP exams for each 

year of employment.

And I guess I'll go ahead and after we address each 

one I'll open up to questions. Or if there are no 

questions, I can just move onto the next one.

Dr. Buchanan: Yes, this is Ron Buchanan with SC&A 

and we reviewed that and we agreed with that.

Mr. Kranbuhl: Okay. So for the second observation -

- so this was pertaining to the use of the incorrect 

DAC to -- for co-exposure intakes after 1990. So this 

is table 5-6 from the TBD. So the issue was that when 

the TBD was written and the values in the table were 

calculated a DAC of 3 times 7 minus 12 microcuries 

per milliliter was used for thorium because it was the 

more limiting DAC. The issue is that the site was 

actually using a DAC of 7 times 7 minus 12 as their 

actual control level for thorium-230. So based on this 

we're going to have to revise that table using the 

correct DAC value. And like I said before, this is kind 

of the main reason that we will be revising the TBD.

So we verified this, the 7 times 7 minus 12. This was 

actually in a couple different site documents as well 

as some of their radiological work procedures, so we 

have reasoning to think that seven should be correct.

So are there any questions about this one?
24

Chair Beach: None here.

Mr. Kranbuhl: Okay.

Chair Beach: I was just pulling up the matrix because 

if you have access to the matrix it is -- all of these 

listed in that as well.

Mr. Kranbuhl: Okay. 

Ms. Marion-Moss: This is Lori Marion-Moss. Before we 

move on, Josie, I have a question. Are we going to 

determine the status of each of these observations 

after Alek presents?

Chair Beach: Yes.

Ms. Marion-Moss: Okay.

Chair Beach: And I guess we can do each one of them 

if that's easier. 

Subcommittee, what do you think? Each one or just 

take them at the end?

Member Ziemer: I'm okay either way. I'll let it be 

your call, Josie, whether --

Chair Beach: Okay. Well, maybe -- let's see, we've 

covered a couple of them. The first one I know SC&A 

agreed with. 

Any comments on the second, Ron?

Dr. Buchanan: No. This is Ron Buchanan. We agree 

with that.

Chair Beach: So you agree with both the first and the 

second one? Okay. 

Dr. Buchanan: Correct.

Ms. Marion-Moss: So the status -- this is Lori again. 

The status would be what? In abeyance, closed, or -

-

Chair Beach: I believe those would go into abeyance, 
25

correct, since we're waiting for the revision?

Mr. Barton: Yes, Josie, this is Bob. I think that's the 

way we normally do things because there's an 

agreed-upon path forward.

Chair Beach: Yes.

Mr. Barton: But we still need to see the change 

actually manifest itself. So I think in abeyance is 

correct here.

Chair Beach: Okay. I agree. Yes, I agree with that 

also. 

Okay. Alek, if you want to go ahead and move to the 

next one?

Mr. Kranbuhl: Yes, I will move on. Thank you.

So the third observation had to do with potential 

exposure. So there's a fairly large radon calibration 

chamber at the site and so the technical basis 

document basically says that any exposure while 

working around the chamber would be calculated as 

working level month and should be in the worker's 

exposure files. 

So we went back and we reviewed several -- really 

all the claimant files that we could find. And reviewing 

transcripts from a couple of interviews with 

individuals from the site really the radon calibration 

chamber was the only routine airborne radioactivity 

area on the site. And based on interviews it was really 

only posted as an airborne area while it was in use. 

And then once they were done calibrating with 

whatever equipment they were calibrating, the 

chamber was actually -- the radon in the chamber 

was exhausted to the environment and then the 

chamber was de-posted prior to anyone going in the 

chamber. 

So we went back and looked at records and there 

were actually no working level month entries in any 

of the records that we reviewed, so I don't think we 
26

see this as a potential issue, not being bounded by 

the levels from Building 30B. And I will -- if anyone 

has questions on this one, we'll go ahead and --

Chair Beach: Ron, any discussion on this one?

Dr. Buchanan: No, we had no -- they did what we 

asked them to do, to look at the working level months 

in the records and there wasn't any there. We haven't 

had a chance to -- did you interview -- you said this 

would have been recent that you interviewed a 

former employee?

Mr. Kranbuhl: No, this was a pervious interview. I 

think this was Tom Tomes' interview from a few years 

ago, but I -- going through the transcript they were 

very clear in the actual controls that were used for 

operating the chamber. And then so that coupled 

with the fact that there were no working level month 

entries in any files kind of would suggest to me that 

the area should be bounded by the same levels as in 

the building.

Dr. Buchanan: No, we have no further issues with it 

as far as SC&A is concerned.

Mr. Barton: I mean, this is Bob. I'm a little 

uncomfortable here because I mean it's one 

interview. And like you said, it was an airborne 

radioactivity area, but we don't have any 

measurements from what that is. And we have the 

one interview that says nobody would be in there. I'm 

not sure that the simple lack of records means that 

the approach is going to be bounding. I'm not sure 

this is a real serious issue, but I mean simply not 

having reports of working levels in a claimant's 

record I'm not sure really justifies the approach from 

a separate area.

I don't know, it's just -- we haven't had a lot of time 

to look into this I guess, but again I mean it's basing 

it on one interview (telephonic interference).

Chair Beach: Yes, I was going to bring that up, too. 

I'm not sure I'm comfortable with that one either. 
27

That's something we're going to have to determine 

where we would go from here on in.

Other Subcommittee members?

Mr. Barton: Well, that's the other thing. As Ron 

mentioned, I mean NIOSH went and did what we 

were asking for was to go look through the claimant 

files.

Chair Beach: Correct.

Mr. Barton: And certainly a weight of evidence could 

be -- argument could be made that we're not seeing 

any monitoring for it, so it wasn't actually a real 

source term per se I guess, but lack -- is lack of 

evidence -- evidence.

Member Ziemer: Was the original question whether 

or not the chamber was evacuated or purged prior to 

people going into it?

Mr. Kranbuhl: The original question was --

Mr. Barton: The original question was that it had 

stated in the TBD that any workers who were in there 

possibly exposed would have been monitored and 

had a working level exposure report in their files. And 

so we asked well, do you actually see that ever 

happening? And the answer to that is no, none of the 

claimants have any of that monitoring record. And so 

the question is is it an actual exposure source that 

we need to be worried about? And again weight of 

evidence would be that we have at least the one 

employee interview that said nobody would have 

been in there ever if it was in use. At the same time 

it is labeled as an airborne radioactivity area. 

So again it come down to weight of evidence. I'm not 

sure that we need to spend that much time really 

debating this, but it (telephonic interference) the 

question of we were expecting to find these 

monitoring records for at least a few employees who 

would have been involved. Those don't exist, so is 

the approach that's being proposed bounding? And 
28

I'm not sure that we have a connection between the 

number right now, which is 5.7 picocuries per liter 

with Building 30B as being reflective of if there is 

even is a potential exposure source with these radon 

chambers.

Dr. Taulbee: This is Tim. If I could follow on here, I 

mean what is it that you're wanting us to go and 

demonstrate here? I mean we've looked at 

interviews, we've looked into what people have said 

about -- the chamber was evacuated and nobody 

would go into there. I mean do you want more 

interviews? What is it that you're looking for here?

Mr. Barton: No, I understand, Tim. I understand 

because the question is what would be a viable path 

forward to get through this? I just -- I want to point 

out that basically the statement was made in the 

TBD; it probably should be removed certainly, that 

says that these records would exist in the claimant 

files. We have no evidence that that occurred. And 

now it's just simply a question of whether the chosen 

radon value would sufficiently bound it. And I guess 

I'm not seeing that connection between Building 30B 

and -- I guess the argument that's really being made; 

and you can verify this, is that it's simply not an 

exposure source. Do I have that correctly?

Dr. Taulbee: Yes, that's how I would interpret it.

Member Ziemer: Where is the 5.7? Where does the 

5.7 picocuries per liter value come from? Was that a 

typical background measurement for the room in 

which the chamber exists, or existed?

Dr. Buchanan: No, this is Ron with SC&A. No, 5.7 was 

the -- they did a survey and found that the radon 

concentration was highest in Building 30B. And so 

they used that as a limiting intake to assign. And the 

rest was less than that. And so that's where the 5.7 

came from before they tore these buildings down.

Mr. Kranbuhl: Yes, the radon chamber was actually 

in Building 32, so 5.7 -- 30B was the highest 

(telephonic interference).
29

Member Ziemer: Well, they must have had some 

measurements from 32 as well then. Did they or not?

Mr. Kranbuhl: I would have to double check but I 

believe so.

Member Ziemer: Well, so if you're calibrating 

instruments you can't have somebody in there while 

they're calibrating them. The instrument has to be --

Chair Beach: Correct.

Member Ziemer: Yes, so the only way you could have 

someone in there -- so to make up this scenario, oh, 

somebody forgot to evacuate the -- or to purge the 

chamber before it was opened for further use. So if 

somebody opens the door and the radon that's in 

there escapes into the room or something like that, I 

suppose -- I don't know how big this chamber is 

compared to the room, but I suppose one could 

calculate what the mixed value or the concentration 

would be in the room if the radon were allowed to 

escape into the room instead of into the atmosphere. 

But I don't see people being in there when -- with the 

radon level at whatever it was for calibrating the 

instruments because you couldn't do that. As soon as 

you open the door you lose that even if you forgot to 

purge it. But they must have also have had a 

procedure. Do we have the -- a written procedure for 

how you --

Mr. Kranbuhl: So I managed to actually find the 

technical manual and there is an operating procedure 

for the chamber within that document.

Member Ziemer: Okay. So the SOP would -- I mean, 

you'd have to say they routinely ignored the SOP for 

someone to not purge the chamber before -- you 

know, you have to open it up to change instruments 

and so on.

Mr. Barton: Well, this is Bob again. It seems like the 

issue here was that it was identified as a potential 

source of exposure in the TBD (telephonic 

interference). And so --
30

Member Ziemer: Yes. Yes.

Mr. Barton: -- perhaps we're just getting too far 

ahead of ourselves and we should just think about 

the fact that it really wasn't an exposure source. So 

the fact that you're using the radon (telephonic 

interference) other buildings is sort of beside the fact, 

that we don't really have necessarily a credible 

source of exposure and so we don't need to 

necessarily worry about it. 

Member Ziemer: Yes.

Mr. Barton: I guess that's what I'm hearing.

Chair Beach: Okay. Bob, I'm going to back to you. 

Are you comfortable with closing this or do you want 

some internal discussion on a path forward? Do you 

agree with the 5.7? I don't think that's going to 

change in the revision.

Mr. Barton: Right. 

Chair Beach: You mentioned --

Mr. Barton: I mean I think it would be -- just for due 

diligence I think it would be important for SC&A to 

look through that SOP and verify exactly what's being 

said so that we can all come to closure that it really 

wasn't an exposure pathway that needed to be 

considered. It was -- and we're adding on the amount 

from the highest building on site, so even if it was an 

exposure pathway, it's not being ignored completely. 

So I think if we could look at that SOP, I think that 

might just close out this issue.

Chair Beach: What about records from Room 32? Any 

need to look at those?

Mr. Barton: Well, Ron, you can correct me, but I don't 

think that we had measurements necessarily from 

this area, which is what kind of spawned the whole 

issue to begin with. That's why we were using the 

surrogate essentially of 30B to reconstruct doses 

potentially from this exposure pathway which may or 
31

may not have even existed.

Ron, I mean please weigh in here. If we had 

measurements from that room that were credible, I 

mean I don't know why wouldn't have used those in 

the first place. I'm a little confused here.

Dr. Buchanan: Yes, I'm not aware of any unless 

NIOSH has some. The way I understood it they went 

around and took measurements and then used the 

highest one at the building. I don't know if -- I'm not 

aware of continuous measurements they did that 

would reflect operating -- through operating time of 

the chamber, unless NIOSH has other information.

Mr. Kranbuhl: There wasn't anything that I saw 

reviewing, going through a lot of the old records.

Chair Beach: Okay, so moving --

Dr. Buchanan: That's what I understood.

Chair Beach: Oh, sorry.

Dr. Buchanan: Yes.

Ms. Behling: And this is Kathy. I think perhaps we 

should also look at the interview information. It didn't 

seem to me that Ron had access to that.

Chair Beach: Okay. So moving forward could the 

interview notes and the SOP be put onto the website? 

In this folder.

Ms. Marion-Moss: The virtual volume?

Chair Beach: Yes, the virtual for Grand Junction. 

Could that be added?

Dr. Taulbee: Yes, we can do that.

Chair Beach: Okay. Thanks, Tim. And then we'll keep 

this one in progress. Any other comments or 

questions? We can move on to 4.

Member Ziemer: So Observation 3 will remain open 

then, right?
32

Chair Beach: Correct. We'll carry it over to our next 

meeting.

Member Ziemer: Thank you.

Chair Beach: Okay.

Member Valerio: Josie?

Chair Beach: Yes.

Member Valerio: So just to clarify --

Chair Beach: Yes.

Member Valerio: -- they're going to provide us with 

the interview and the standard operating procedures, 

correct?

Chair Beach: Yes. That's what I asked for. And I'm 

not sure if I got enough affirmation on that or not.

Ms. Marion-Moss: Yes, we'll get that here. The 

volume.

Chair Beach: I guess Tim did say he would.

Member Valerio: Thank you.

Chair Beach: Yes. So that's what, and then the SC&A 

can look at that and we'll carry it over to the next 

meeting.

Member Valerio: Got it. Thank you.

Chair Beach: All right, thank you, everyone.

Ms. Marion-Moss: Josie, this is Lori. So that status 

will be in progress on this --

Chair Beach: Correct.

Ms. Marion-Moss: -- observation?

Chair Beach: Correct.

Ms. Marion-Moss: Okay. Thank you.
33

Chair Beach: Thanks.

Mr. Kranbuhl: Okay, I'll go ahead and continue with 

Observation 4 if that's okay.

Chair Beach: Yes, that's great. Thank you.

Mr. Kranbuhl: Okay. So Observation 4 had to do with 

assignment of 95th percentile neutron doses only to 

personnel under the job category. Sorry?

Chair Beach: Alek, can you advance your screen 

because it's not showing. We're still on 3.

Mr. Kranbuhl: Okay.

Chair Beach: Anybody else see that?

Dr. Taulbee: Actually, it's on 4 for mine.

Mr. Barton: Actually, it's showing 4 to me.

Chair Beach: Ah. Maybe mine froze up. Okay, go 

ahead then. I'll just --

Mr. Kranbuhl: Okay. So the TBD has personnel under 

the job title of geologists being assigned 95th 

percentile. And basically they're the only individuals 

who would be assigned there.

So SC&A's observation was that there is a possibility 

that people other than geologists were handling 

neutron sources at the site. And after the review we 

concur that there is a possibility that workers who 

weren't just geologists were handling the sources.

So we're kind of in the process of continuing to 

investigate this. And we'll need to come back to this 

after we've looked into it a little more at the next 

Subcommittee meeting.

Chair Beach: Okay. Any questions or comments on 

that?

Ms. Behling: So that observation will be in progress?

Chair Beach: Correct.
34

Ms. Behling: Okay, thank you.

Member Ziemer: Yes. Agreed. Agreed.

Member Valerio: Agreed.

Mr. Kranbuhl: Okay. And then, so for the final 

observation. So the technical basis document didn't 

do a good job of explaining why neutron co-exposure 

doses don't need to be applied after 1995.

So after reviewing, going back and actually looking 

at dosimetry records from the site, as well as there 

is a large amount of dosimetry records from Idaho 

National Lab for the Grand Junction site. So we went 

back, looked at all these records.

And from looking at this documents, every non-zero 

neutron dose that was in site documents shows up in 

rems. As well as additional doses where you can see 

from internal documents where they did dose 

investigations, personnel who were exposed to 

neutron sources but came back with a TLD reading of 

zero.

They were actually going back. They were doing in 

investigations and assigning neutron doses based on 

co-worker exposures.

So just based on the volume of dosimetry records, 

both from the site and INL, we think that it's safe to 

think that all of this information made it two rems. 

So the rems data is complete after 1985.

Mr. Barton: So this is Bob. So the, I guess 

presumption here is that if you don't have it in your 

records there will not be a co-exposure assignment 

of neutron dose after 1985, is that correct?

Mr. Kranbuhl: Correct. Yes.

Dr. Buchanan: Were they doing neutron logging, 

usage neutron sources after 1985?

Did they like remove most of them at that time?
35

Do you know if there is a definite time that they 

shipped these neutron sources out or they just wasn't 

using them as much or do you know any history on 

the use of the neutron sources? A cutoff date or 

something.

Mr. Kranbuhl: Yes. So you can pretty clearly see, so 

I was actually able to find some old source 

inventories from the site. And after really around 

1981 there was a large shift in how they were 

controlling the sources at the site.

And then about 1985 they really dropped off. And 

that's when they also started reporting neutron doses 

via rems. So that's kind of why that is the cutoff 

based on this.

So they were doing less logging. A lot of the sources 

actually went away. And then on top of that they 

were reporting the neutron doses in rems.

Dr. Buchanan: Well --

Mr. Barton: This is Bob. The question here is, and we 

encounter this all the time is, we have records. There 

was positive neutron doses after 1985. And the 

question is, is there the potential for workers to be 

out there who don't have the record of their neutron 

dose.

I think this is one that we might have to carry forward 

because, I mean, this is one of those co-exposure 

issues where you have records. We have monitoring 

records.

But is there the potential out there for claimants who 

have been exposed who either their records are, 

happen to be missing or they weren't monitored up 

to monitoring standards like we usually expect. 

Where we want to apply some sort of total exposure 

dose to sort of fill in those gaps.

I mean, I guess --

Dr. Taulbee: Bob?
36

Mr. Barton: I mean this is completely -- yes. Go 

ahead.

Dr. Taulbee: Bob, this is Tim. I mean, if you look at 

the dosimetry results that we got there from those 

SRDB numbers, I mean, there is over 16,000 of them 

here in this time period.

So there are a large number of people who are 

monitored here. So I guess I would ask SC&A to look 

at those then. If you still have concerns about it then 

we can talk about it.

But I think when you look at all of the information 

here noted in our response that I think you'll come to 

the same conclusion as us. Maybe not. But certainly 

--

Dr. Buchanan: They were monitored -- this is Ron. 

They were monitoring for neutrons after '85. Was 

everybody at the site or were just the geologists?

Was there some places would monitor for 

beta/gamma and only specific employees would be 

monitored for neutrons. In this case, did Grand 

Junction do that after '85 or were they, was the 

neutron, I mean, according to all these records you 

have, dosimetry records, did they include just a 

couple neutron dosimeters or was everybody in a 

zero or what did that look like?

Mr. Kranbuhl: So from what I saw the area 

monitoring program really ramped up in the early 

'80s. So they had several, I think they had 30 

different area of neutron dosimeters.

And so those area of badges, I think there were only, 

I'd have to go back and double check to look at the 

actual data. But really I think there was only, Building 

30 was the one that was higher than background.

And in the dose records they do list zeros for neutron 

doses for zero dose. So that's the values that they 

were getting from INL were zeros for neutron.
37

Dr. Buchanan: Was everybody wearing these neutron 

badges?

Mr. Barton: Yes, how were we doing --

Mr. Kranbuhl: I can't confirm that.

(Simultaneous speaking.)

Mr. Barton: I mean, if it was Building 30 where it was 

slightly elevated above background, were the 

employees in Building 30 all monitored?

I mean, it sounds like there were area badges that 

indicated that, but how do you assign an area badge 

to a claimant necessarily. And that's where my coexposure question really arises.

I guess if everybody in Building 30, which is the 

location that was, that had elevated results, was also 

monitored via a neutron dosimeter than great. It just

seems like a very high bar to set to say, everybody 

who should have been monitored was monitored. And 

we have all those records.

And there would be nobody that we don't have a 

record for that might have been exposed. Even if it 

was just slightly above background. I think that's 

where we're coming from.

Chair Beach: Okay.

Dr. Buchanan: Yes, were individuals assigned 

neutron dosimeters or were everybody? I guess 

that's the question at this point.

And recorded as zero or do we just assume that if a 

few people were monitored for neutrons, they were 

the only ones with potential exposure? I guess that's 

the question at this point.

Dr. Taulbee: So this is Tim. If I can summarize. 

You're wanting us to demonstrate that people with 

the potential to exposure to neutrons that all of them 

were monitored?
38

I'm not quite sure how you're wanting us to 

demonstrate that but I guess we'll see what we can 

do from that standpoint. I think more importantly, if 

we were to get more of the details on the monitoring 

of the personnel of everybody, if the badges all 

contained neutron TLDs in this time period, then that 

would really put this to bed when you look at all of 

the zeros that we see in the dose records, correct?

Dr. Buchanan: That's correct. Yes.

Member Ziemer: Yes, I, this is Ziemer. I think they're 

asking whether the 66 doses were the only people 

monitored or were those 66 that were non-zero and 

there is, what, 16,000 other values of zero. Or 

whatever.

Dr. Buchanan: Right.

Member Ziemer: Whatever it is.

Dr. Taulbee: I can tell you --

Member Ziemer: That should be fairly simple to 

answer that, I think. And then put this to bed. But I 

guess we need to take a look at it.

Mr. Barton: Yes, I think --

(Simultaneous speaking.)

Mr. Barton: -- rare to assume that everybody was 

monitored. I think it's pretty rare in this program that 

we just blanket assumption that there was no 

unmonitored person out there that shouldn't be 

assigned some form of co-exposure value. I think 

that's, it's that.

I mean, we're not asking you to verify that everybody 

was absolutely monitored and we have all those 

records. I think we're saying that given the potential 

uncertainty there that I think it's kind of rare to not 

have any sort of co-exposure approach for workers 

who, you know, you look at their file, they're rad 

workers, and they might have been exposed. And 

usually something is assigned.
39

So to have a situation where we're saying, no, 

everything was complete and there doesn't need to 

be any sort of co-exposure approached, it's 

somewhat rare. It seems rare to me anyway.

Dr. Taulbee: Well, I can tell you, Bob, from looking 

at the records coming from INL and their printout, I 

mean, virtually everything I'm looking at here is zero. 

And I scroll down page after page after page of 

dosimetry data. And it's got, it's broken out for skin, 

whole body and neutron. And they're all zeros here.

So the big question in my mind right now, what 

you're raising is, is that are these zeros actually 

measurements from that TLD, and if they are, then 

with all of these zeros, with a large number of people 

that are being monitored, I don't think there would 

be a need for a neutron co-exposure model from that 

standpoint.

If the monitored people with neutrons, with neutron 

TLDs are all showing zero except for a few 66, then I 

don't see a need for a co-exposure model. I mean, 

we are talking here in the modern era of this is a 

post-1986 type of time frame out through 2007.

So this is a, there is a lot of records here showing 

zero dose is what I'm trying to get to. And I just need

to verify, I think we just need to verify that those 

neutron measurements are in fact neutron 

measurements. And there is hundreds of people here 

being monitored and they're all showing zero dose.

So if your monitored workers are showing zero dose, 

your unmonitored workers, why would they have a 

positive dose?

Member Ziemer: Or would it even, as a maximum, 

be any higher than the 66 that you have positives. 

Anyway, yes.

Dr. Taulbee: Sure.

Member Ziemer: Can you confirm that those are 

actually monitored values, those zeros? That should 
40

answer the question easily.

Dr. Taulbee: Yes. And we will do that.

Mr. Barton: And I certainly didn't want to infer that 

there was this group out there that is going to be 

higher than the 66. I was simply pointing out the fact 

that if there is a group out there doesn't have that 

monitoring record, they're getting assigned nothing 

rather than even just the 50th percentile of those 66 

measurements or something like that. I mean, it 

seems like something so standard that we usually do, 

but we're not doing it in this case.

I don't think we need to belabor this much longer. I 

think, Tim, you're correct characterizing who is 

getting monitored, checking those neutron doses to 

see they are in fact positive neutron doses. I think 

that's going to get us a lot closer.

Chair Beach: Okay, thank you. Any other discussion 

on 5? So that one will remain in progress with the 

action on NIOSH and then SC&A to follow up.

Let's circle back to the first and second. Paul and 

Loretta, you agreed with NIOSH. We talked about 

putting those in abeyance waiting for the update on 

60. Do you agree to close both the first and second 

observation? I think we talked about the first one 

already.

Member Ziemer: Yes, I agree.

Chair Beach: Okay. So we're good. And, Loretta --

Member Valerio: Quick question, Josie.

Chair Beach: Yes.

Member Valerio: I have meeting notes that 

Observation 2 would remain in abeyance.

Chair Beach: Correct.

Member Valerio: Okay. So is it closed --
41

Chair Beach: Yes.

Member Valerio: -- or is it going to remain in 

abeyance?

Chair Beach: Well the issue is closed. It will stay in 

abeyance for the, until the updated --

Member Valerio: Okay.

Chair Beach: -- 60 comes out. And then it will be 

verified.

Member Valerio: Okay.

Chair Beach: And then it will go away.

Member Valerio: Okay.

Chair Beach: Assuming that it --

Member Valerio: Got it.

Chair Beach: -- gets followed up then properly. So 

then I have for 3, that's an SC&A action after NIOSH 

puts those two documents in for review, 4 is in 

progress with a NIOSH action, and 5, NIOSH with a 

follow-up on SC&A. Does that close those out and we 

can move on?

Member Ziemer: One other quick question. Can we, 

or maybe you already agreed to do this and I missed 

it. Will a copy of this document be distributed to us, 

I don't think I have it.

Chair Beach: Oh, it's in the virtual, so that's, yes.

Member Ziemer: Yes, I mean I'm looking at it --

Chair Beach: Yes.

Member Ziemer: -- but can we get a copy of it? Yes.

Chair Beach: Can that be sent to NIOSH to, well, I 

don't know if you can get it on your personal because 

it's in the NIOSH --
42

Mr. Barton: Yes, it's posted on the website. It's 

posted on the website.

Chair Beach: Yes.

Mr. Barton: So we can send him a link. We can send 

a link. That's fine.

Chair Beach: Oh, perfect. Okay.

Ms. Behling: And, Josie --

Member Ziemer: Thank you.

Ms. Behling: -- one last question.

Chair Beach: Yes, go ahead.

Ms. Behling: And, Josie, one last question. This is 

Kathy. I just want to confirm that Observation 1 and 

2 are in abeyance? They are not --

Chair Beach: Correct.

Ms. Behling: -- close they're in abeyance? Great. 

Okay, thank you.

Chair Beach: Oh, you're right. Yes. Yes, we agreed to 

move them into an abeyance. You're correct.

Ms. Behling: Okay, thank you.

Chair Beach: Thanks.

Member Ziemer: Will this be posted on the meeting 

website for the public? There is nothing in this one 

that's confidential, is there?

Ms. Behling: No it is not.

Mr. Barton: It's already been posted.

Ms. Behling: It's been PA-cleared and posted under 

the Grand Junction site.

Member Ziemer: Oh, it is already there? Okay. Sorry.

Ms. Gogliotti: But for posterity it would be good if we 
43

could get it posted under the meeting files also.

Chair Beach: Yes. And no reason not to.

Dr. Roberts: Yes, I believe Lori had done that. I'm 

not sure.

Ms. Marion-Moss: This is Lori. I'll follow up on that to 

get it posted under the meeting.

Chair Beach: Thank you, Lori. Okay, are we ready to 

move on to PER-087? The next carryover item.

DCAS-PER-087

Ms. Behling: Yes, Josie. PER-087 is Clarksville and 

Medina Modification Center. And there was, we had a 

discussion on this at the last meeting. And Finding 1 

had to do with substantiating the use of the Pantex 

dose data as the surrogate for Clarksville.

And I believe we were waiting on NIOSH to provide 

that clarification. I don't know if they're in a position 

to do that.

Dr. Taulbee: This is Tim. And I can provide an update 

on this. Okay.

Ms. Behling: Okay.

Dr. Taulbee: We concur with SC&A's finding that we 

need to do a, we need to justify the use of surrogate 

data for Clarksville from Pantex.

Now, in going through this we felt this was going to 

be fairly straightforward. And it is for the years post1967. However, for the earlier years it's not as 

straightforward.

The monitoring at Pantex when they were coming 

online was much diminished, as I believe SC&A even 

pointed out in there. And so as we go in to look at 

this more, what we found is that Pantex, in the TBD 

that we are using, basically back extrapolated from 

their latter year work two years prior to 1957.
44

Now for the Pantex plant that was clearly bounding 

because they didn't have a lot of the cores onsite in 

doing that type of work. And so that was one of the 

issues that was closed out during the SEC evaluation.

But for Clarksville they did have them in that time 

period. So what we've done is we've looked hard at 

the Clarksville's data.

That we're doing, people that were doing the 

modification work, and there was a large number of, 

not large, but a number of Sandia workers stationed 

at Clarksville that were doing this work. And these 

workers appear to have been monitored during this 

early time period in 1949 and 1957.

In reviewing this data set though we realized the data 

set is incomplete. We only have examples of it in the 

SRDB. And so we're currently requesting the 

complete data sets from Sandia. And once we get 

that, then that is the data we'll be using for 

Clarksville.

So it won't be a surrogate from Pantex anymore from 

that standpoint. We concur with SC&A that when we 

started to do the justification we really couldn't.

So we're working on developing an exposure model 

approach for the model based upon the dosimetry 

that we have examples of. But we recognize that it's 

not complete. Doesn't meet the implementation 

guide standards for co-exposure.

But we are requesting that additional data. 

Unfortunately we don't have a time line for the 

receipt of this yet. But once we do we will be updating 

the Clarksville TBD.

And very likely issuing another PER from that 

standpoint. At least we will be evaluating which way 

the doses go up or whether they go down from that 

standpoint. So is there any questions with Finding 1?

Chair Beach: No, but thanks for that update.
45

Dr. Taulbee: Okay.

Chair Beach: SC&A, questions?

Mr. Barton: This is Bob. That sounds like the right 

path forward to me.

Ms. Behling: Agreed.

Dr. Taulbee: All right. So this one I would say is in, 

or not in abeyance but in progress.

Chair Beach: Right. Yes.

Dr. Taulbee: Our goal is that once we get the 

exposure model done, before we put it into the TBD 

I would like to present it to the work group, or to the 

Subcommittee here, if that's okay. Kind of get your 

buy in before we go through the revision process.

Chair Beach: Yes, that sounds like a good idea, Tim. 

Thank you. Yes.

Dr. Taulbee: Okay. And so the other open issue with 

Clarksville PER-087 was the observation. And we 

agree that the language, I believe we agreed to this 

during the last meeting, we agree that the language 

is not clear from that standpoint. And the calculation 

that SC&A noted in their observation is the one that 

we are actually following.

So when we revise the TBD for this, for the early 

dosimetry issue, early exposures, we will also clarify 

that language. So this one I would basically say we 

agree, the language is not clear and we will clarify it. 

And so I would suggest or recommend that you all 

put this one in abeyance.

Chair Beach: Okay.

Ms. Behling: It's currently in abeyance.

Chair Beach: And that's what my suggestion was 

going to be. Thank you. Any comments? And --

Ms. Behling: Just --
46

Chair Beach: -- Kathy, can you make a note to 

update the matrix for this new information?

Ms. Behling: Yes, I will. And both the Finding 1 is 

currently in progress. And the Observation 1 is in 

abeyance. But I will add wording to the effect of what 

we talked about today.

I just want to add one additional item to this. During 

our discussion of Finding 1, Finding 1 was actually 

Finding 7 from our original review of the Clarksville 

Medina TBD. And that was done back in 2012.

And I think Lori asked, if the findings from that 2012 

TBD review were being tracked. And I attempted to 

find an answer to that without having access to the 

BRS.

And I do not think they have been tracked. And I 

don't think that they exist in the BRS at this point. So 

I made a note in our temporary matrix that once we 

have access to the BRS all of those findings will be 

updated.

Chair Beach: Okay, great. That's --

Dr. Taulbee: This is --

Chair Beach: -- clarification on that.

Dr. Taulbee: This is Tim. If I could add on to that a 

little bit. When we started researching this as well we 

ran into quite a bit of difficulty tracking down the use 

of Pantex data as well. And part of this is because of 

the way the SEC is evolved for Pantex and then for 

Clarksville and then back to Pantex under admin 

review.

So, it actually got really jumbled as to us trying to 

figure out the basis that we initially had here. So 

when you go through and you're looking through 

that, Kathy, I guess I would ask that you look at the 

SECs as well. Because I think some of those early 

findings may have gone away due to the SECs that 

were established.
47

Ms. Behling: Okay, very good. Thank you.

Dr. Taulbee: Okay.

Ms. Behling: Okay, I'm making a note of that. Thank 

you. Okay, are we ready to move on to OTIB-0088?

Ms. Marion-Moss: Before we do that --

Chair Beach: Yes.

Ms. Marion-Moss: -- Lori, I have a question.

Chair Beach: Go ahead.

Ms. Marion-Moss: Josie, I was thinking, I know this, 

these findings for Clarksville are tied to PER-087. But 

is there a way for the Subcommittee to consider 

closing out the review of 87, the PER itself, and 

basically transfer these findings to the Clarksville 

TBD?

Chair Beach: Oh, yes. Without confusing it even 

more. I don't see, as long as we document it, that 

that would be a problem. Kathy, what do you think?

Ms. Behling: I agree. I think it should be under the 

Clarksville Medina. It's more easily to be tracked 

under that.

Chair Beach: Okay.

Ms. Behling: But yes, I can do that once we have 

access. I think it's a good idea.

Chair Beach: Okay. And it would just mean updating 

this temporary matrix to say what we're --

Ms. Behling: Okay.

Chair Beach: -- doing and why.

Ms. Behling: Okay. All right.

Chair Beach: And that way we can keep track of it 

here.
48

Ms. Behling: Okay.

Chair Beach: So yes, I think that's a good idea. 

Thanks, Lori.

Ms. Marion-Moss: No problem.

Ms. Behling: All right, let me just --

Chair Beach: Can you, what's the Clarksville number?

Ms. Behling: Good question. The TBD number?

Chair Beach: Is that the, is that under 039? No, that's 

the older one. You can give that to us, we can get 

that later. That's okay.

OTIB-0088

Ms. Behling: Okay. All right. Okay. All right, we will 

move on them to OTIB-0088 if we're ready.

Chair Beach: Yes.

Ms. Behling: OTIB-0088. Okay, OTIB-0088 is the 

external dose reconstruction to OTIB. And we had 

reviewed Rev 1.

And there were two observations. Observation 4 and 

Observation 5 that were still in abeyance after the 

last meeting.

And as a result of that, the Subcommittee tasked 

SC&A to review Rev 2 and determine if that closed 

these in abeyance items. And Ron has done that. And 

I will attempt to see if I can pull that up.

I don't know why I'm having problems here. I'll go a 

different route. I'm pulling up Ron's presentation. 

Can you see that?

Chair Beach: Yes.

Dr. Buchanan: Yes.

Ms. Behling: Okay. Hey, Ron, are you ready.
49

Dr. Buchanan: Okay. Okay, this is Ron Buchanan 

again with SC&A and I'll be presenting SC&A's 

focused evaluation of OTIB-0088, Revision 2 for 

external dose reconstruction.

Next slide. Okay, now, OTIB-0088, just to refresh 

your memory, Revision 0 was issued in 2018. 

Revision 1 was issued in 2019. The Subcommittee 

tasked SC&A with a review of Revision 1 in March of 

'21. And we had performed that review and issued 

our report in September of '21.

Now, while we was doing that, Revision 2 was issued 

in June of '21.

(Telephonic interference.)

Ms. Behling: Sorry about that. Let me see if I can go 

back here. Can you hear me?

Chair Beach: Yes.

Dr. Buchanan: Yes, I can hear you.

Ms. Behling: Okay. I'm sorry.

Dr. Buchanan: We just have --

Ms. Behling: Yes, I'm sorry. Let me see how I get out 

of this. Rose, can you give me assistance.

Ms. Gogliotti: You're in the slide master.

Ms. Behling: Okay. How do I get out of here? Close 

slide master view. Okay, I'm sorry about that. Go 

ahead. I thought I was going to make it a bigger 

screen and I didn't do that.

Ms. Gogliotti: If you hit view, Kathy --

Dr. Buchanan: Okay.

Ms. Behling: Pardon me?

Ms. Gogliotti: View at the top of the screen. And then 

you can show it as a presentation.
50

Member Ziemer: Well, you're back on the slide so 

you're okay now.

Dr. Buchanan: Yes. Yes, I think it's okay.

Ms. Behling: Okay.

Dr. Buchanan: Let's see. We was, Revision 2 was 

issued during Revision 1. So the Subcommittee asked 

SC&A to do a focused review on Revision 2 to see if 

it answered our earlier items. And that was during 

the November 3rd, 2021 committee meeting. And so 

SC&A did that focused review and issued a report on 

January 7th of 2022.

Okay. Now, to just go over the review here. The 

purpose of this OTIB was to provide external dose 

reconstruction guidance using the approved 

documents. Such as IG-001 technical base 

documents, site profiles and ORAUT procedures. And 

there was concern with exposure to photons, 

neutrons, electrons, ambient dose and x-rays.

Now an overview. Their approach was to look at 

external dose records, occupational medical x-ray 

doses, incident investigation reports, types of 

external radiation exposures and a conversion of 

external dose to organ dose and uncertainties.

The document contained three attachments, A, B and 

C. Attachment A was concerned with assigning miss 

dose. Attachment B was concerned with onsite 

ambient dose. Attachment C was a list of DOE 

neutron weighting factors according to ICRP, which 

were implemented at DOE sites in approximately 

around the year 2010. And we'll talk a little more 

about that as we go on here.

Okay. So our focused review was to evaluate the 

changes in 02 to compare it to 01 to determine if our 

five previous observations had been addressed by 

these changes and/or were addressed by the 

discussion we had during the recent November 2021 

committee meeting.
51

Okay, now if you look at the Revision 2 of this OTIB 

you will see the notes with changes was on Page 16 

were recommended applying the ICRP Publication 60 

weighting factors after the dates listed in Appendix 

C. And K-25 was added to that list.

Now, a little background. Before 2010 DOE sites were 

using the NCRP neutron weighting factors. And then 

in around 2010 they started applying ICRP 60 

neutron weighting factors which were more 

conservative and had a other factor of two greater 

than NCRP.

So the data at the sites, when they were recorded, 

used NCRP. And so when we do dose reconstruction 

they had to take that recorded dose and multiple it 

by a correction factor to convert to the ICRP. And 

usually it's ran around the factor of about two.

But after the DOE site implemented the ICRP neutron 

weighting factor in their dose recording methods for 

neutrons, then that conversion factor should not be 

applied because you'd be increasing the dose by a 

factor of two shouldn't. And so that's what Appendix 

C of OTIB-0088 lists the dates that each individual 

DOE site implemented this weighting factor. And we 

concur with these changes that NIOSH has made so 

far in Revision 2.

Now one of the questions on, we formally had 

Observation 1 was path forward concerning 

Procedure 60 data contained in OTIB-0088. And we 

discussed this at the November meeting. And I'll just 

briefly go through these because we just did it a few 

months ago. But I'll cover the ones that were closed 

there also.

And they indicated, NIOSH indicated that the specific 

external ambient dose that was contained in 

procedure 60 would be included in the revised site 

profiles. So the committee accepted that action and 

closed this Observation 1.

Observation 2 was concerning the x-ray doses that 

were to be assigned. And SC&A pointed out the 
52

diagnostic and therapeutical x-ray doses were not 

supposed to be included.

And NIOSH indicated that dose reconstructors were 

well aware of this and would not sign those. And so 

the Committee, they discussed that and closed 

Observation 2.

Observation 3 was concerned with unmonitored 

worker potential exposure. And we discussed that 

during a November meeting.

And NIOSH stated that they would remove that in the 

next revision of 0088. The statement that in general 

it is expected that reconstructed dose to unmonitored 

workers will be less than doses to monitored workers. 

Discussed that and the Committee accepted that and 

closed Observation 3.

And Observation 4 was concerned with use of 

multiple badge records. And this was discussed 

during the November meeting.

And what this consists of is that some places, such 

as INL, you use different badges depending on what 

facility you was at there. And so we brought that to 

NIOSH's attention.

Because they had stated in there for cases in which 

multiple badges were issued for a particular 

monitoring period, only one zero measurement 

should be assigned per monitoring period. But in 

some DOE sites you should use all the badges.

And so NIOSH will revise this statement in the next 

revision. And the Subcommittee accepted that. And 

it remains open pending the review in the OTIB and 

our review of that.

Chair Beach: Should this one --

Dr. Buchanan: Observation --

Chair Beach: I'm sorry for interrupting, Ron. Should 

Observation 4 be moved to in abeyance?
53

Dr. Taulbee: This is Tim. I would actually like to 

clarify this a little bit, if that's okay?

Chair Beach: Sure. Go ahead.

Dr. Buchanan: Okay.

Dr. Taulbee: Okay. What we had stated, that we 

would review that particular statement, I didn't recall 

acknowledging that we would revise the statement in 

the next revision, but maybe I did say that 

mistakenly during the last meeting. But we have 

reviewed this over the past couple of months.

And so I have an update for you all. And basically we 

agree with SC&A that all dosimeters need to be 

considered.

One of the things that SC&A indicated in their 

previous review is that they believed that all 

dosimeters were being considered in dose 

reconstructions. And while this is generally correct, 

it's not actually true for all cases, as we have learned 

over the past couple of months. It's generally for just 

overestimating type of cases where the dose 

reconstructor will go through and thumb through all 

the dosimetry. And then the INL TBD has specific 

guidance on how to address multiple dosimetry.

But another site, Hanford, doesn't specifically 

address this. So during best estimate cases the 

language in OTIB-0088 is what is actually followed. 

That we only assign one measured dose.

But we agree that this is not what we should be doing 

from that standpoint. So simply deleting the 

language, as indicated here, of revising the 

statement doesn't really make the issue, doesn't 

really fix the issue for us. So because we need to 

issue some guidance of what are we going to do for 

dose reconstruction.

So a little bit of background here. Early in the 

program, in Rev 0 and Rev 1 of the external dose 

implementation guide, there was guidance on how to 
54

handle all dosimeters when people were issued 

different dosimeters in multiple locations.

And then in 2005, 2007, in Revisions 2 and 6 of IG001, that guidance got removed. In the past couple 

of months we've done a few, we've done quite a bit 

of research. Going through meeting transcripts, 

historic emails. We asked Jim and Stu to go through 

theirs and see what they could recall as to the reason 

that guidance was removed.

And we have not been able to find anything specific 

to that. So we went through work group meetings 

back in the 2007, 2006 time period. And we can't find 

anything as to why that guidance was removed.

Our best guess is that the removal was inadvertent 

in an attempt to be responsive to a different 

comment that the uncertainty discussions in the 

external Imp Guide were complex and needed to be 

simplified and streamlined. That's where we think 

this guidance got removed.

And so, our initial proposal was to simply reinstate 

this early programmatic guidance. And keep in mind 

that that guidance was developed back in 2001. And 

our program has advanced quite a bit over the last 

20 years.

So, as we're working through that, during the internal 

review last month we identified the significant 

weaknesses with the method that these were actually 

identified by our statistical team and it causes some 

pause here. So we're working with our statisticians 

currently to develop some new guidance to consider 

all the dosimeters with a situation where a worker 

has multiple dosimeters across the same facility, 

during the same exchange site.

We're not ready yet to present that to the 

Subcommittee here, but we are working on that. I 

would like to point out though that this is really only 

an issue for some workers at a few facilities. Hanford 

and INL are the two, two of the biggest ones.
55

This isn't a widespread dose reconstruction issue for 

the complex. And it's really only workers that would 

have dosimetry issued at multiple facilities.

So much like the Clarksville discussion before, we 

plan to present this new methodology for discussion 

at the next Subcommittee meeting. And once agreed 

upon we'll revise OTIB-0088 to incorporate that.

So this one, although Josie had just mentioned to put 

it in abeyance, I actually feel like this one is in 

progress on our end to come up with the new 

methodology and present it to you all.

Chair Beach: Okay. How does that sound --

Dr. Taulbee: Any questions?

Chair Beach: Thanks, Tim. Any other Subcommittee 

members or SC&A questions for Tim?

Member Ziemer: Well, it's clear based on what Tim 

said that this is not in abeyance, an abeyance issue, 

we need to keep this open and review the material 

that NIOSH presents next time.

Chair Beach: Yes. No, no, I agree with that. I was 

wondering if you had any other clarifying questions 

for Tim.

Member Ziemer: No. It's kind of puzzling as to what 

happened. But it is certainly something that is worth 

putting back in. We need to have some particular 

approach to this issue.

Ms. Behling: And this is Kathy. Tim, you did indicate 

that this new guidance will be put into OTIB-0088. 

Because you mentioned also, IG-001. And I think it's 

best put into 0088 as opposed to IG-001 because it's 

more, it doesn't get used as much, I wouldn't think, 

by the dose reconstructors.

So I --

Dr. Taulbee: That's correct. Actually, it's going to end 

up in both.
56

Ms. Behling: Okay.

Dr. Taulbee: But IG-001, when it's revised for IPR-P116, at that time we'll add it into IG-001 as well.

If you noticed, OTIB-0088 actually is what the dose 

reconstructors use, you are correct. But it actually 

parrots everything that's in IG-001. So it provides 

some additional clarification but it follows IG-001, 

which is why it's clear in the language that it is going 

to be removed.

(Telephonic interference.)

Dr. Roberts: All right, please make sure your phone 

is on mute.

Ms. Behling: Okay, this is Kathy. I think that's a good 

idea to enter them both, IG-001 and the OTIB-0088. 

And good, that answers my question.

Chair Beach: Okay. Does that cover 5 as well or can 

we move on to 5.

Dr. Buchanan: Okay, Observation 5 was clarification 

of an NCRP to ICRP correction factor. And I discussed 

that a little bit earlier and we recommended that the 

site profile contains the recommendation to convert 

from NCRP to ICRP up until the date, 2009 to 2010, 

or excuse me, 2011 time frame. Most the DOE sites 

converted around 2010.

And this was discussed again at the November 

meeting. And that the, NIOSH indicated at that time 

that there was, this item was --

(Telephonic interference.)

Dr. Roberts: Hi. Can we take a minute to try to figure 

out where that's coming from?

So if anyone, if everybody could check their phones.

Dr. Buchanan: Okay, it sounded like we got it fixed.

So this was discussed at the November meeting. And
57

NIOSH indicated that there was a section in the 

Revision 2 that addressed this. And so the 

Subcommittee tasked SC&A with a focus review of 

that to determine if its observations was adequately 

addressed.

So we can go to the next slide. Okay, so we reviewed

Revision 2 and found that they did add text on Page 

16 concerning missed neutron dose. Not to apply the 

ICRP weighting factors if implemented at DOE sites.

However, we feel that that didn't completely answer 

the question because it also needs to state measured 

neutron dose. You wouldn't want to apply it to 

measure as well we missed.

And so it could be correctly simply by adding 

measured, or just say neutron dose. And so we 

recommended Observation 5 remain open. And for 

that to be corrected.

We can go to the summary. So in our --

Dr. Taulbee: Can I --

Dr. Buchanan: -- evaluation we find that the 

discussion during the November meeting addressed 

and closed Observations 1, 2 and 3. Observation 4 

we just discussed on a multiple badge records and 

that remains open pending that insertion and our 

review of that.

And Observation 5, we just recommend it be worded 

to include all neutron doses and not just missed dose. 

So we recommend that Observation 5 remain open.

Dr. Taulbee: Could I comment on these here?

Chair Beach: Yes. I was just going to ask you for your 

comments, Tim.

Dr. Taulbee: Okay. Observation 5, we don't have any 

problems with updating the language since we're 

reopening OTIB-0088. If we weren't reopening OTIB0088 I'd probably be arguing more about not doing 

so.
58

But because we know from Observation 4 we got to 

revise OTIB-0088, we will incorporate observation, 

actually Number 3, which we committed to early, to 

modify whenever we open OTIB-0088 again. And 

we'll do the same with Observation 5. We'll clarify 

that language.

So I'd like to propose to you, Josie, that Observation 

3 and 5 be held in abeyance and Observation 4 be in 

progress. That's my proposal to you.

Chair Beach: Okay. And I am in agreement with that. 

I just opened up the matrix and was going to ask 

Kathy to update that. Because that, right now, 4 and 

5 are both listed as in abeyance. And I believe 3 is 

listed as closed. So, Kathy, if you don't mind making 

note of that?

Ms. Behling: Yes. I will make that change.

Chair Beach: Okay, thank you. And other 

Subcommittee Members agree?

Member Ziemer: Yes, I agree with Tim's 

recommendations.

Member Valerio: I agree, Josie.

Chair Beach: Okay. I do too. So I believe that closes 

out OTIB-0088.

We have one more if we could, I don't think OTIB0049 is too long, if we could go through that and then 

--

Ms. Behling: Okay.

Chair Beach: -- and do a quick summary and then 

we'll take a break.

ORAUT-OTIB-0049

Ms. Behling: All right. OTIB-0049, that's our Super S 

OTIB. And I believe it was Observation 7, SC&A asked 

if we could have an internal discussion over the 

issuance of whether this OTIB should have a PER 
59

issued in its behalf. And we did that.

And Rose presented OTIB-0049. And I'll let her 

continue with this discussion.

Ms. Gogliotti: Sure. Just a brief reminder, OTIB0049, the purpose was to specify a biokinetic model 

for the use in evaluating the deposition and retention 

of inhaled very insoluble plutonium. Which we 

generally call type SS, or Super S, plutonium.

And the old model you see as an adjustment factor, 

a factor of four, we saw it a lot. However, when we 

reviewed the new revision NIOSH made quite a few 

changes to the method.

It's kind of a hybrid approach that uses updated 

guidance from ICRP 130, 67 and 30. And they 

developed a whole new workbook called IDOT. And 

our Observation 7 had to do with a PER.

We thought a PER would likely be necessary because 

our preliminary calculations showed that organs in 

the thoracic and extrathoracic regions would receive 

higher doses in some instances.

And when we discussed this at the last meeting 

NIOSH indicated that they did not have a PER in the 

works currently. And didn't really have a plan to 

implement a PER. Or weren't going to put it into the 

queue because they intended to eventually update all 

of their guidance to newer ICRP guidance. Specifically 

including ICRP-141.

And it was our position that that will eventually lower 

all doses. And it would be a lot of work essentially to 

do a PER to increase doses when they plan to 

eventually decrease those doses again with a new 

ICRP guidance.

And where we left it last time was SC&A requested to 

discuss some things internally to make sure we were 

all on the same page going forward. And we have had 

those discussions.
60

But there is a few things we'd like clarified just 

because that was not the path forward that we 

thought. Rev 2 is currently being used is that correct?

Mr. Allen: Yes, that's correct. This is Dave Allen.

Ms. Gogliotti: Okay. So it was our previous 

understanding that any change in dose 

reconstruction method that increased dose would 

lead to a PER or at least minimum --

(Simultaneous speaking.)

Mr. Allen: That is correct. I'm sorry, go ahead.

Ms. Gogliotti: But we have an instance here where 

dose is increasing but you don't plan to do a PER and 

so we are kind of curious what decides when a PER is 

necessary and when it actually gets done.

Mr. Allen: Okay. I can speak to that. The standard 

approach is we make a change, we look to see if any 

doses go up.

If they do we put it on the list for a PER and the first 

step in our PER process is to determine whether 

additional changes are coming in the future.

If we know there are additional changes coming then 

we say it's, you know, my wordage is it's not ripe for 

a PER yet.

We hold off on it and we usually put the new steps 

somewhere else in our project plan and we link to 

that so that the PER does not start until those steps 

are all done.

So in this case the standard approach would be we 

would put the OTIB-0049 PER on, actually I'd 

probably call it Super S PER, on our plan and link it 

to implementing ICRP-141, which would be several 

years down the road to get it completely done.

Once that is done then we would be looking at the 

PER for Super S. However, we already know 

implementing ICRP-141 is a big chore and it involves 
61

much, much more than plutonium and we also 

already know that the doses would be lower.

Therefore, it seems silly to put it on there only to 

eliminate it later because it would no longer be a 

Super S PER. It's going to be an ICRP-141 PER. 

Actually, ICRP-130 PER is what it would amount to.

I don't know if that made any sense, but that is pretty 

much our standard approach is we make a change, if 

we know additional changes are coming we do not 

PER it until we are done with all the changes.

Otherwise, we would be piecemealing these PERs 

frequently and that's a testament that you can see 

by all the different revisions to all the different TBDs 

you have seen over the years.

Ms. Gogliotti: So this is the standard approach --

Mr. Barton: This is Bob. Thank you for that clarity, 

Dave. And, again, I think we were sort of caught off 

guard because, like you even intimated, you know, 

when a dose reconstruction method changes, 

especially if it's going to increase dose then the PER 

gets put on the schedule.

And what I think we wanted as far as to approach 

and closure for this was sort of to clarify how that 

process works because I think even some of the 

Subcommittee members were a bit confused.

If you look at the transcript saying, well, if the doses 

are going up you have to do a PER, and I guess the 

question from our standpoint was, well, how does 

that process either get initiated or put on hold.

I completely understand from a pragmatic sense 

what you are saying, that, listen, we're going to be 

overhauling the entire system.

I guess where it's a little troubling for us is the notion 

that, well, it's going to be a few years down the line 

and there could be claimants out there, we don't 

know for sure, but, you know, that certain illnesses 
62

are more affected by Revision 2 of this TIB that we 

might increase their doses to say that, well, we're not 

going to re-work your dose reconstruction because 

we're going to, we would essentially end up changing 

it a few years down the line anyway, which would 

lower the outcome.

I guess we were just seeking that sort of clarity of 

how the process works because, again, we were 

taken aback a little bit saying, well, if the doses go 

up then you have to do a PER.

But I think we certainly all agree from a pragmatic 

sense what you are saying that you can't have a 

constant influx of PERs, it just doesn't make sense.

But we just wanted the clarity you provided on how 

that decision is made because we were certainly 

unclear on it from SC&A's side and I think it's 

important that the Board also understands the 

approach because there could be a claim that was 

evaluated under Revision 1 that might get comped 

under Revision 2 but wouldn't be comped under 

Revision 3, which is a few years down the line.

And so that process was a little murky for us and I 

appreciate your candor in explaining how it is that 

that decision is made. I don't know if the 

Subcommittee has any comments on that front.

Chair Beach: No. This is Josie. I don't. I agree with 

that and the clarification is helpful. Loretta? Paul?

Member Ziemer: Well it makes sense if we get those 

other items that we know will result in changes that 

are possibly in process or about to be in process.

Otherwise, if there is no immediate prospect for a 

change I think you can just say, well, there might be 

in the future. I assume, Dave, you are talking about 

cases where you know there is a change coming.

Mr. Allen: Right. I mean it's not a speculation that 

maybe just someday there will be some. I will clarify 

that one time. There was a little bit of speculation if 
63

there is like an SEC review or a TBD review going on 

and they are still sorting out findings.

At that point I can't really say there is definitely a 

change coming on, but a lot of times we will wait until 

those reviews are settled before we try to proceed 

with the PER because they often result in a change.

Member Ziemer: Exactly.

Mr. Allen: But other than that --

(Simultaneous speaking.)

Member Ziemer: Yes. I agree with that, yes.

Mr. Allen: Okay. I was going to say other than that it 

just has to be --

(Simultaneous speaking.)

Member Ziemer: But typically you will know what's 

going on that could affect it and if there is nothing 

going on then you have to take action.

Mr. Allen: If there is nothing going on, yes. I can't 

just speculate that there may be some day.

I will point out one thing about this particular one, it 

was for the example case that SC&A wrote in their 

review, it was ET2 dose and L and ET dose were the 

only ones that actually went up and I don't think ET2 

dose even went up much.

There are very few -- Just to point out, there are very 

few cases that actually use those as the organ of 

interest. Those that do are either very easily 

compensated already without the Super S part of it 

or there are a very small intake in no matter how 

high, you know, like a small short-lived 

environmental intake, short-term environmental 

intake. Those are so low it doesn't matter how high 

we do it.

So it kind of comes down to the, you know, there is 

a slim, very little chance that anybody's case is 
64

actually going to flip because of this little bit.

And, as I said, we already know there is going to be 

another change that is going to actually knock it 

down below where we used to be, so the decision is 

fairly clear on this one that we don't want to go 

through and try to PER this at this point when we 

know we're going to have to do that PER again in a 

few years.

And it's not like it's small -- Well --

(Simultaneous speaking.)

Ms. Gogliotti: You just made a document that was a 

small PER.

Mr. Allen: I was going to say it's hard to say, it's not 

a small PER but it is, it takes a lot because it's not 

one site.

You have to go through 50,000 claims pretty much 

to figure out what your population is and then at that 

point I know it's a pretty small population.

But then there is no way to say anything other than 

just calculating the doses again and in reality a 

hundred claims is pretty small when it comes to 

50,000 claims, but that's still a lot of recalculating 

and a lot of documentation to deal with in a PER.

So, I don't know, there it is. It is what it is at that 

point. Like I said, our standard approach is we know 

there is something coming soon or coming in the 

future that we are not going to PER this at this point.

Member Ziemer: Thank you, Dave.

Ms. Gogliotti: Have you actively started working on 

that --

(Simultaneous speaking.)

Mr. Barton: Dave, at the same time you just pointed 

out that it wouldn't be a huge population, so in that 

case it's like, well, if it's not that difficult then why 
65

aren't we doing it with this kind of --

(Simultaneous speaking.)

Mr. Allen: Granted. I know I just pointed that out but 

I also know that it was based on SC&A's review of an 

example case. I can do example -- I am not sure if 

all example cases are going to end up being ET2 and 

L and ET.

It could end up being lung and then it ends up being 

a much larger population. I don't know at this point. 

I would have to do some more calculations, but I 

think there is probably scenarios where it could be 

lung.

And at that point you've got 20 percent of the cases, 

or about 10,000, you have to calculate numbers for 

that you don't want to. I think it would only be a 

really weird situation where it would be lung, but then 

you are looking at it's only lung cancers with only 

acute and not a chronic intake or something along 

that line.

That is impossible to figure out without going through 

case by case by case and it has the potential of 

blowing up into a huge issue.

And, again, I didn't want to dig that deep into it just 

because we are going to change things and we know

it's going to go down. So just back to the standard 

approach is we don't do it if we know there is another 

change coming.

Ms. Behling: And, Dave, this is Kathy Behling. I am 

hearing that you have not run any calculations on 

your end to determine which cancers may be 

impacted. You are just basing it on our calculations.

Mr. Allen: I have done similar and probably more 

than what SC&A has done, but it comes down to the 

idea that there is no definitive calculation you can 

make.

It's pretty much all scenarios and there is an infinite 
66

number of scenarios that changes with the length of 

chronic intakes and whether or not it's chronic or 

acute.

I think ingestion might affect it versus inhalation. I 

know injection does. It just gets ugly as far as trying 

to show or prove that you've got the right population.

But I mean normally my approach would have been 

essentially all respiratory tract, and I would have to 

look into GI tract, I'm not quite sure on that one. I 

think that's okay, but I would have to look, and, 

again, that would be some 10,000 claims or so to 

deal with.

So I have no belief that it would affect a large number 

of claims even at this point if we intended to leave it, 

but I think I would have to go through some 10,000 

claims to show that is kind of my point.

Ms. Behling: Thank you.

Ms. Gogliotti: Is there a timeframe that you have 

come up with to implement your changes?

Mr. Allen: No. I mean this was something that long 

ago we wanted to implement with ICRP-116, if I 

remember right, which is the external dose 

conversion factors.

The thought early on, we would implement ICRP-130 

changes along with ICRP-116 and have all the -- This 

will affect every claim ever done.

This is all the DCS for external dose and all the 

internal dose models for every isotope. This is not a 

small deal, obviously. I also think the 116 might beat 

us to the punch on 130.

So, again, it's not going to be a small deal. As far as 

timeframe, I have absolutely no clue. It's going to be 

quite some time. It's going to be a few years for sure.

Dr. Taulbee: So if I can add on to that just a little bit. 

Part of why this is going to be, you know, a few years 

is that programs such as IMBA use the old models, 
67

so there would be a new program to implement the 

ICRP-130.

And so there is a lot of work that is here, beginning 

in the background here, but it's going to take a few 

years for us to get and, you know, that's kind of 

where we are at right now.

Mr. Barton: And this is Bob. I think that's where we 

kind of got kind of hung up on this thing because --

We understand the process, and, again, thank you 

for clarifying that because I don't think it was quite 

clear at the last meeting.

But, you know, if we are looking at years down the 

line it's just a, it's difficult to, or it would be difficult 

to explain to a claim how their dose might be 

calculated going up, but since we are changing 

something that may take years -- And like you said 

you'd have to re-write IMBA essentially or create an 

entirely new IMBA program.

So I mean if this thing was like, yes, well, we're 

making changes, you know, in a couple months so 

we're obviously not going to do a PER, you know, of 

course that makes sense, but when we're talking 

about years, without really a definite date, I think 

that's what gave us pause.

But, you know, I think the whole purpose here was 

to gain clarity on the PER process, how NIOSH's 

procedures work in that avenue, and I think that we 

accomplished that.

We know how it works. We know how it works now.

Chair Beach: Okay. Good discussion. That leaves us 

with seven. Are we satisfied with that? Should we put 

that into --

(Simultaneous speaking.)

Mr. Barton: I think the resolution was to have that 

conversation that we just had about how the PER 

process works and how the decisions are made in the 
68

best interest of the program.

Chair Beach: Yes.

Mr. Barton: So I mean I would recommend, and I will 

defer to Kathy here, certainly, but I think we're 

probably ready to close that one out.

Ms. Behling: I would like to hear the Subcommittee's 

feeling on whether a PER should be issued or not 

based on this conversation.

Chair Beach: I don't think -- Paul, do you have any 

comments on that?

Member Ziemer: Yes. On this one, this is one where 

-- Well, let me ask first, what was the observation 

itself again, how is it worded?

Ms. Gogliotti: We just noted that a PER may be 

required.

Member Ziemer: Yes, okay. And I think we heard 

from Dave that that will occur when the other items 

that are underway are resolved, isn't that correct, 

Dave, on this one?

Mr. Allen: Yes, that's correct.

Member Ziemer: Yes. So --

Chair Beach: And, Paul, they are tying it to ICRP-141, 

which we already know is years in the making, so 

essentially the PER is a long ways off, correct?

Mr. Allen: Correct. Let me -- Can I point out one last 

thing before you finish this discussion?

Chair Beach: Certainly.

Mr. Allen: I mean we're talking about a PER here. 

We're not talking about using the doses. We are 

currently using OTIB-0049 Rev 2.

So some people are going to get a dose 

reconstruction between now and the time we 

implement this that we know is going to be a little 
69

more elevated than it should be. That happened and 

that's not part of the PER process.

The PER process is whether we go to the Department 

of Labor and ask them about all those previous claims 

that we have already completed long ago and 

whether we should get them back and then redo the 

dose reconstruction to make them higher and get 

them paid before we change the things that we know 

is going to happen to cause the doses to go down 

again.

Chair Beach: Right. What's the possibility of doing 

that?

Mr. Allen: I don't know. I mean we do PERs all the 

time but the assumption is always that the change is 

done, or at least we don't know of any that are going 

to be coming.

I mean to get these claims back, which is the only 

purpose of a PER is to get a claim back that's already 

been completed, to get it back we've basically got to 

tell DOL the real dose should have been higher, you 

need to vacate your final decision and return the 

claim to us, and I am not going to say that because 

I know it shouldn't be higher.

Chair Beach: Yes.

Mr. Allen: It's temporarily higher.

Mr. Barton: This is Bob. I understand. I understand 

absolutely where you are coming from.

I guess the only retort to that would be, you know, if 

you were the claim submitted the day before Rev 2 

started being used in dose reconstruction you got a 

lower dose than you would have got if you submitted 

your claim the day that Rev 2 started being put in 

use, and I think that's what we are looking at.

And, again, it's the timeframe on this where it is 

years down the line that it would actually be changed 

and would there really be a PER, not necessarily for 
70

the Super S, because those are going down.

But, again, I think we just needed clarity on the 

entire process, the thought process, and what 

procedures were in place and how those decisions are 

made, because I think, at least I know I was taken 

aback last weekend, or the last meeting, by the 

discussion that happened.

But ultimately it is NIOSH's -- What I am hearing is 

ultimately it is NIOSH's decision when and where to 

hold the PER and there is no timing restrictions.

It's really just pragmatically how you evaluate the 

situation, what changes might be coming down the 

line. I think that's the summary here, right?

Chair Beach: Yes. I think you're right.

Mr. Calhoun: Yes, this is Grady. That's correct.

Chair Beach: And I don't think the Subcommittee can 

probably override that, at least I don't believe we 

have that power. Paul, and you were --

Member Ziemer: Yes. Well, it seems to me the 

Subcommittee right now we're dealing with whether 

or not SC&A is satisfied with NIOSH's, I don't know if 

I would say position, but has NIOSH satisfied the 

issue that they have raised.

Whether or not a PER should actually occur now, to 

me that's a -- The issue that was described on this 

particular case seems me that would be a Board 

decision whether you would wait for -- Theoretically 

you could, you raise some values, you may pay some 

claims which you know if you waited longer wouldn't 

be worthy of paying, so that's kind of the issue.

Chair Beach: Right.

Member Ziemer: I think that's the issue.

Mr. Calhoun: This is Grady. I think to be clearer on 

that --
71

Member Ziemer: All right. I think --

(Simultaneous speaking.)

Mr. Calhoun: The issue is that we know that there is 

another one coming up. You know, we don't care if 

they get paid or not, it's just the function of our 

workload.

We know that there is another item coming up that 

could affect the process of the PER. So I wouldn't put 

it such that, well, they shouldn't get paid because 

we're not going to pay so we're not going to do it.

Member Ziemer: Okay.

Mr. Calhoun: That's not our position.

Member Ziemer: Yes, I understand what you are 

saying. It has to do with just the process itself and 

not anticipating who or who will not get paid. It's just 

when --

Mr. Calhoun: That's correct.

Member Ziemer: It's just -- Do you do the process, 

overload the system, doing it twice in a sense.

Mr. Calhoun: That's exactly right.

Ms. Behling: Yes. And this is Kathy. As Bob 

mentioned NIOSH has answered our question and we 

do understand the process.

I think the confounding variable was the timeframe 

for the new revision coming out and I think OTIB0049 there was a PER back in like 2005, so there 

would be some cases.

But, no, we are satisfied with I think NIOSH's 

response. I just wanted to hear from the 

Subcommittee about --

(Simultaneous speaking.)

Chair Beach: Thanks, Kathy.
72

Member Ziemer: Yes. And typically if SC&A is 

satisfied with NIOSH's response we normally 

recommend closing the issue.

Chair Beach: Yes, I agree with that.

Mr. Barton: Hello. Dr. Ziemer, this is Bob. I mean 

certainly we are looking for the clarification we got 

and I think basically what has been said is that it's 

not our purview at SC&A or really the purview of the 

Subcommittee to --

(Simultaneous speaking.)

Mr. Barton: -- those PERs take place. That's kind of 

what I have been hearing. I mean maybe I am 

misconstruing things here, but --

Member Ziemer: No. I think you are correct that our 

process for this Subcommittee is what you just 

described. It's not to at this point recommend how 

NIOSH handles their workload.

Chair Beach: Okay. I agree with that. So we are in 

agreement to close Observation 7. And, Kathy, if you 

don't mind again updating that matrix.

Ms. Behling: Yes, I will do that. Okay, so --

Chair Beach: Okay. All right, so with a recap on the 

carry-over items, there were two that were dropped 

from the list and I am just going to circle back to 

those briefly to ask NIOSH for an update, the DCASPER-073, the Birdsboro Steel, I'm sure I said that 

wrong, and the Peek Street template.

Is there any -- Do you have any idea of when we can 

move forward with those?

Dr. Taulbee: This is Tim. We are -- Fortunately, we 

have assigned people to those now.

Chair Beach: Okay.

Dr. Taulbee: Those are crazy things that were being 

transitioned as people had left and so forth. Mark 
73

Rolfes will be taking over Birdsboro and Angelica 

Gheen will be taking over for the Peek Street, I guess 

response in a sense.

So we do have those assigned. I don't have a 

timetable but I am hoping that by the next 

Subcommittee Meeting, as long as it's not in, you 

know, the next month type of thing --

Chair Beach: Yes, no.

Dr. Taulbee: -- we should be able to address those.

Chair Beach: Okay, great. So we'll carry those over.

Dr. Taulbee: But those appointments were just made 

a few weeks ago, so we don't have an update.

Chair Beach: Okay. So we'll carry those forward to 

our next Subcommittee Meeting, which I am sure is 

going to be two to three months, maybe four months 

out. So, okay, thank you.

Any other comments on the carry-over items?

Member Valerio: None here, Josie.

Member Ziemer: No. I have no further comments.

Chair Beach: Okay. Thanks, Paul and Loretta. A break 

time, let's take, does 15 minutes work for everybody?

Member Ziemer: That will work for me.

Member Valerio: Works for me.

Ms. Behling: That's fine.

Dr. Roberts: So reconvening at 1:40?

Member Ziemer: Reconvene at -- Okay.

Chair Beach: Sure. Is that enough time for people? I 

know there is no lunch break included in this, but we 

do have a lot to get to.

Member Valerio: And that's going to be 15 minutes, 
74

Josie?

Chair Beach: Yes.

Member Valerio: Okay.

Member Ziemer: Okay.

Chair Beach: Be back at 1:40. Thanks.

Member Valerio: All right.

(Whereupon, the above-entitled matter went off the 

record at 1:24 p.m. and resumed at 1:40 p.m.)

Dr. Roberts: Okay, great, all right, well, then I will do 

a quick roll call.

(Roll call.)

Dr. Roberts: So, Josie, did you want to give Loretta a 

couple of minutes to get back on?

Chair Beach: Yeah, I think we need to, don't we?

Dr. Roberts: Well --

Chair Beach: Or are we okay with just Paul and I?

Dr. Roberts: Yeah, I think that's a quorum, but we 

could certainly wait a couple of minutes.

Chair Beach: Okay.

Dr. Roberts: And in the meantime, if people who are 

on, there is like a lot of racket or something in the 

background, so make sure that your phone is on 

mute and that you're not off mute in Skype 

somehow.

Chair Beach: Yeah, that was a pretty noisy break 

time, wasn't it?

Dr. Roberts: It really was. I heard all kinds of noises.

Member Valerio: Rashaun and Josie, this is Loretta. 

I'm back on.
75

Dr. Roberts: Oh, great.

Chair Beach: Terrific.

Dr. Roberts: All right, so we are back.

Newly Issued SC&A Reviews

Chair Beach: Okay, so this is Josie again. We are onto 

the newly issued SC&A reviews. And understanding 

these are new, I don't expect NIOSH to be ready to 

pursue any of these, though I may be wrong. I've 

been wrong in the past, so we'll just go through each 

one of them. 

And keeping in mind the time, Kathy, how much time 

do we need at the end for the Board prep and the 

newly issued guidance documents? Is 30 minutes 

enough or do you need more you think?

Ms. Behling: I think 30 minutes is plenty of time, yes.

Chair Beach: Okay, so at 3:00, we'll stop the new 

presentations.

Ms. Behling: Right, because we'll also need to plan 

for the next meeting, so I think half an hour will be 

plenty of time. Thank you.

Chair Beach: Correct, okay, thank you. So, we can 

start with the Battelle-TIB-5000.

Ms. Marion-Moss: Josie, this is Lori. Before you get 

started, I just wanted --

Chair Beach: Okay.

Ms. Marion-Moss: -- to mention that the NIOSH DCAS 

memo on Grand Junction is now located on the 

meeting page on the web under the discussion paper 

section.

Chair Beach: Okay, great, thank you.

Ms. Marion-Moss: You're welcome.

Chair Beach: Appreciate it. Okay, the Battelle-TIB-
76

5000, that is Bob Anigstein, and Bob, are you on the 

line? Okay, I --

Dr. Anigstein: Hello?

(Simultaneous speaking.)

Dr. Anigstein: All right.

Mr. Barton: We can hear you, Bob.

Dr. Anigstein: Yeah, I'm just trying to figure out how 

to get my presentation on the screen.

Ms. Behling: Okay, I gave up control, so you can take 

control. At the bottom, on the right-hand side --

Dr. Anigstein: Okay, feel free to start sharing, and 

it's the -- okay, sorry. Okay, okay, here we go. Feel 

free to start sharing and I don't -- it keeps --

Ms. Behling: Okay, at the bottom, there is a screen 

with an arrow in the corner, if you select that?

Dr. Anigstein: I'm sorry. On the bottom, I have the S 

for Skype with a red dot on it. Oh, I see. I got you. 

Start sharing your desktop.

Ms. Behling: And that will bring up the --

Dr. Anigstein: Okay.

Ms. Behling: There we go.

Dr. Anigstein: And, oh, it keeps coming up and then 

disappearing.

Ms. Behling: We're seeing it.

Battelle-TIB-5000 "Default Assumptions and 

Methods for Atomic Weapons Employer Dose 

Reconstructions"

Dr. Anigstein: No, I'm trying to use -- I have a --

okay, now let's see if I can get this, all right. Yeah, I 

got it now.
77

Okay, well, last year, just about a year ago at the 

meeting of the SCPR, SC&A was tasked with 

reviewing Battelle-TIB-5000. Now, the Battelle-TIB5000, the title is default assumptions and methods 

for atomic weapons employer sites.

This TIB was issued, was completed in 2006 and was 

adopted in 2007, so it's 15 years old. It was prepared 

by a statistician, Daniel Strom, working for Battelle 

at the time, and is heavy on statistics and statistical 

theory, but also includes procedures for dose 

reconstruction and related matters.

Being a 15-year-old document, we naturally 

anticipated there would be some obsolescence in it, 

there would be some differences, and so therefore, 

we sort of reviewed it with a light hand. We didn't 

have any findings. 

If this had been a more recent document that was 

currently in use, some of these may have been 

elevated to findings, but instead, whenever we found 

an issue, a discrepancy, we called it an observation.

And so, there are 13 observations in all of various 

degrees. Some of them are technical, minor, but we 

felt we should call attention to anything we found 

which should be -- we avoided any editorial 

comments. We found that's not, from previous, those 

aren't necessary welcome.

So, I'll go through in order. So, okay, now the 

observations, we issued the report on the review, I 

believe it was January 10, and it's the same 

observations, but because of the limitations of the 

format of the PowerPoint slides, we're limited to how 

many characters, how many words can go into the 

title of each slide.

So, since I wanted to make the observations the 

titles, some of them are abbreviated or condensed, 

so if you were to look at the full report, it's the same 

observation, but the wording is a little lengthier.

Okay, so there was a program called LOGNORM4, 
78

which is a freeware computer program that was 

developed prior to the issuance of TIB-5000 and is no 

longer publicly available, and even if we were able to 

get a copy of it, it wouldn't do very much good 

because it's a 16-bit computer code and all Microsoft 

Windows computers running Microsoft Windows 7 or 

later require at least a 32-bit code or a 64-bit code, 

so they cannot -- even if we could get it, we couldn't 

use it.

So, the options we propose to NIOSH is to make a 

Windows 10 compatible version, which could be done 

by simply taking the -- they could get the original 

source code, I assume it's in Fortran, and simply 

using a new compiler, a contemporary compiler. 

Anyway, NIOSH responded that the program is no 

longer is used, and considering the Cybersecurity 

Modernization Initiative, developing a Windows 

compatible version is not likely to occur. So, that 

remains unresolved. It's not a major issue.

Okay, observation two, the wording a little cryptic 

because it had to be condensed, but there are more 

modern methods than the ones that TIB-5000 

proposes for treating censored data.

Now, censored data, you run across censored data 

frequently when you have sets of environmental 

measurements or it could even be urine specimens, 

and that is when there are some measurements that 

are below the lower level of detection.

So, then all we know is that there is, for example, 

there is uranium in the soil and all we know is it's 

greater than two picocuries per gram. I'm just 

making this up. So, you don't ignore those samples 

that were below. And a more common way that you 

would have censored data is if you took background 

samples. 

You have your contaminated site and you take 

samples from it, but you know there's uranium in the 

soil everywhere, so you go offsite to a representative 

area and collect samples there and come up, say, 
79

with a distribution or an average, and you subtract 

and those are your background samples that you 

subtract those from your samples of your real data 

that you're interested in.

And sometimes the background will be higher than 

the measured value, and so rather than reporting it 

as a negative value, it just gets reported as censored. 

That's censored, left censored, left because, you 

know, you go from left to right, so left is at the 

bottom of the scale.

You can also have, which is less common and I 

haven't run across it, but in theory, you could have a 

right censored where the instrument gets 

overwhelmed. Maybe a counter cannot count such a 

high count rate, and so you simply say well, we know 

it's more than 1,000 picocuries per gram or we don't 

know how much more.

So, there is a method called regression on order 

statistics and that can be used to fit below normal 

distribution to a value that contain, to data sets that 

contain some values that are less than some number 

or reported as zero.

And this was a good method. I used it myself, but it's

outmoded and there is a more modern one. For 

example, there is an R package. R is a programming 

language for statistical analysis and there is a 

program called NADA, which is available on the web, 

which has a more sophisticated method, which I 

won't go into the details. The function is little, in 

lowercase letters, ros, so that's our observation two.

Observation three, which we were getting to, deals 

really with an error in transcription where we thought 

it necessary -- somebody called attention to it in our 

group, necessary.

And this is a table that is taken from the TIB-5000 

data and it shows rather than individual 

measurements, it's groups of measurements in 

ranges. So, here is the exposure in milligrams per 

cubic meter, and in 1949, there were 13 samples 
80

between zero and 0.1 milligram per cubic meter, 14 

samples between 0.1 and 0.5, and so forth.

Two or three pages later in the same report, there's 

a section, Section 2.1.4.1, states the first data point 

in 1949 represents 13 of the 119 total observations. 

The second, 14, the third, 31, and the final point, 64.

Well, if you add up these numbers that I told you, 

they're not 119. They're 122. So, what's the correct 

value? Well, we go back to the table and the four data 

points for 1949 do add up to 119, so presumably 

those are the correct values from the observations, 

right, and 61 is the correct number for the fourth data 

point and 64 is an error.

We just brought this up because it shows perhaps a 

lack of proofreading, a lack of QA in the original 

document, which does not reflect well on it even 

though it is of any great significance in this instance.

Okay, now going back to the censored data, they 

proposed a mirror image method to characterize zero 

or negative results, and according to TIB-5000, this 

sounds counterintuitive. It took a little while for me 

to grasp it.

You delete -- you have a set of data, some of which 

includes values of zeros and includes negative 

values. You delete all of your positive values, and 

then for each negative value, you add a new record 

which has the same absolute value, but is positive 

instead of negative.

So, if you have a value of minus two, you add a plus 

two to the record. If you have a zero, you add 

another zero, and the result is a symmetric 

distribution centered on zero by definition. Since 

there is just as many minus twos as plus twos, the 

average is going to be zero or the sum would be zero.

And so, if you plot these, you get something to the 

left, which are your negative values, and something 

to the right of the y-axis, which are your mirror image 

of the negative values.
81

And then the analyst computes the standard 

deviation of the new symmetrical distribution and 

constructs a normal distribution with a mean of zero 

and a new standard deviation.

Then there is another method which TIB-5000 uses 

called the preserved mean and variance method, and 

the instructions are to characterize a normallydistributed measurement uncertainty and an 

underlying lognormally distributed measurand, which 

is the true but unknown value of the specific quantity 

subject to measurement. 

So, according to TIB-5000, it's a more sophisticated 

alternative to the crude mirror image technique and 

is based on four assumptions, but whenever you see 

quotation marks in this presentation, those are direct 

quotes from TIB-5000 unless there's another 

document which would be referenced.

So, we have the observed probability density function 

is the result of combining a normally-distributed 

measurement uncertainty with a lognormaldistributed measurand.

The reason for this, the logic behind this is random 

errors in measurement or the lack of complete -- you 

never have total accuracy in measurements, or you 

measure the same quantity 100 times, if your 

measurement is precise enough, you have 100 

different results, but the average should be the true 

value and the error or the discrepancy is normally 

distributed. You have just as many on the right as on 

the left and it follows a family bell-shaped curve. 

That's for a single measurement.

The underlying data is lognormally distributed. In 

other words, the logarithms of the measured values 

follow a normal, have a normal distribution.

So, now you have two different shapes, and then the 

-- anyway, according to the next step, the mean of 

the lognormal true value of nature is equal to the 

mean of the observations. That's an assertion. 

Hopefully it's true unless there is some bias.
82

The mean of the uncertainty is zero. That just 

explains just as many high values as low values. The 

error goes equally on both sides, so the mean would 

be zero.

The variance of the sum, X and Y, where is X and Y 

are some quantity being measured, is equal to the 

sum of the, excuse me, equal to the sum of the 

variance of X and the variance of Y. The variance is 

just the spare of the standard deviation, provided X 

and Y aren't correlated.

If there are enough data to estimate the variance of 

the uncertainty of the measurement procedure, say 

by repeated measurements of blank samples, then 

there remains only one parameter to be estimated, 

the variance of the lognormal dose distribution.

Okay, observation four, the mirror image and 

preserved mean and variance methods are not 

supported by theory. There is no literature on this. 

These two methods are not supported by any 

technical background in statistical theory of which 

SC&A is aware.

The examples given in TIB-5000 which applied these 

methods are just that, examples, not proofs. 

Conclusions are based on the specific data sets used 

in the analyses, but are not necessarily applicable to 

other data sets. So, we basically reject these 

methods.

Going onto the discussion of uncertainty in biokinetic 

models, I'll preface this by saying that in 1998, I 

believe, NCRP issued commentary number 15 which 

was titled Evaluating the Reliability of Biokinetic and 

Dosimetric Models and Parameters Used to Assess 

Individual Doses for Risk Assessment.

And the focus of that commentary was ICRP 30. ICRP 

30 came out in 1979. It was an improvement on ICRP 

2, which was, I think, from the 1960s, and they did 

an extensive critique. I, frankly, didn't read the entire 

report, but the relevant portions. They also 

mentioned an NCRP model, which I don't believe is 
83

widely used now, which came out later.

In the meantime, ICRP Publication 66 had been 

issued in 1994, but the commentary 15 deals fairly 

lightly with it. They have one small section on it. Most 

of it discusses ICRP 30 which was no longer the 

accepted model. I don't know the history behind 

those decisions.

So, the author, Daniel Strom, of Battelle-TIB-5000, 

felt it necessary to have some evaluation of the 

reliability or the accuracy of the current, by this time, 

ICRP 66, which was the -- let me just read the title 

of it. It's the human respiratory tract model for 

radiological protection.

So, that was used and there were major changes for 

some radionuclides, particularly for the actinides and 

alpha emitters, but there is not an evaluation of the 

reliability of the ICRP 66 model.

So, what TIB-5000 did was simply say well, we'll use 

the ICRP 30, the critique of ICRP 30, and then he said 

the results of the ICRP Publication 66, which is 

incorporated into IMBA, may not be that much better 

than the ICRP 30 models for some radionuclides in 

cases where f sub 1, which is a fractional absorption 

in the gastrointestinal tract, is the dominant 

uncertainty.

Well, we're critical of that because ICRP 66, by its 

title, is a lung model. Now, there is an absorption in 

the alimentary canal incorporated into this model in 

that when you inhale radioactive material, 

radioactive dust, some of it lodges, gets localized in 

the region called ET2, the extrathoracic, I always 

have trouble with that word, the extrathoracic region, 

which is the back of the nasopharynx.

The anterior portion is just your nose, which is 

aligned with skin and therefore is not absorption, and 

the ET2. And when it lodges there, some of it ends 

up going into the mouth, into the esophagus and gets 

swallowed. 
84

So, in that sense, there is some absorption from the 

alimentary canal of inhaled material which does not 

stay in the lung, but is swallowed. 

However, that does not seem to be a very 

appropriate criticism, and just the wording of it may 

not be that much better, is subjective and to me 

sounds pejorative since that is the model that is 

being used now.

So, I just, the observation is that the TIB-5000 lacks 

a sound basis for speculating what I just briefly said. 

I won't repeat it.

Also on this same topic, there was an email cited from 

three members of the -- they were then members of 

the team, Donald Bihl, Liz Brackett, who is still 

working on the project, and Richard Toohey, who 

retired some years ago.

And the email justified the use of a lognormal 

distribution with a GSD of three and said this is 

reasonable consistent with NCRP findings. 

However, NIOSH no longer possesses that email, so 

we could not examine it to determine whether or not 

this, in fact, supported what is said to be supported 

here, the use of three.

Going onto observation six, in our summary 

observation is a GSD of ten is excessive for a sitewide 

assessment of individual workers.

The background of that is TIB-5000 stated that the 

current default assumption when no information is 

available on uncertainty in aerosol measurements is 

that they are lognormally-distributed with a GSD of 

five for a single process or activity and a GSD of ten 

for an entire site, plant, or factory.

So, the GSD for a single process, this is based on a 

publication by Christofano and Harris which is 

entitled, I believe it's the Industrial Hygiene of 

Uranium Processing, and this was performed in 

conjunction with the AEC HASL laboratory, Health 
85

and Safety Laboratory.

 They were in charge of inspecting various sites that 

were working under contract with the Atomic Energy 

Commission.

So, this is a very extensive document, very detailed. 

It contains a large number of tables, of data sets 

based on actual measurements for different 

processes at different plants or calculated values.

What we are critical of is that they mix the TIB-5000, 

mixes the single process where you have a single 

worker and you have values for the time-weighted 

average, or daily weighted average as they call it, for 

the working environment, so t's a fair representation 

of his exposure during the workday.

And sometimes there are also spot measurements. 

They simply take a -- there is a procedure which 

might, like an opening, and I'm just sort of making it 

up, which might cause some activity in the air, but 

for a very short period of time, and they use this also.

So, the data analysis combines the daily averages 

and the spot measurements of different plants, and 

that is not a fair way of representing a worker's 

exposure day in and day out during the work year for 

purposes of dose reconstruction, so we disagree with 

that assumption.

So, we tried to reproduce what NIOSH did. They 

didn't go into detail, not NIOSH, what TIB-5000 did, 

and we picked -- we noted that Christofano and 

Harris listed 33 instances that they labeled as daily 

weighted averages or simply weighted average, 

probably means the same thing, that represent the 

chronic exposures of workers form a given process, 

and for each one of them, they listed a range, a max 

and a minimum and the average.

So, we applied the equation that's in TIB-5000, they 

call it Equation 10, which is based simply on the 

definition. It can be derived directly from the 

definition of a lognormal distribution.
86

So, the natural log of the geometric standard 

deviation sigma equals the square root of twice the 

logarithm of the average value minus the logarithm 

of the minimum minus the logarithm of the 

maximum.

And of these 33, in four cases, the quantity under the 

square root sign was negative, so in physical 

measurements, a negative square root does not 

make any sense. We took it to indicate the data did 

not, in fact, fit a lognormal distribution and those four 

sets were rejected.

Of the remaining 29 sets, we were able to evaluate 

the GSD and we got a range of values from 1.07 to 

4.57, so we concur that -- we take the 4.57 and 

round it off to five and say GSD equals five is a 

plausible upper bound for the exposures of a single 

worker at a given uranium refining plant. So, we 

agree with the single process. We've verified with the 

single process evaluation.

Now, we're trying to see where did they come up with 

the ten? So, we took the entire set of aerosol 

concentrations for 136 processes tabulated by 

Christofano and Harris.

 So, in each case, there was an average. We just 

took the average and performed a fit to a lognormal 

distribution, and we ended up with a GSD of 9.05. 

So, if you round that up, you get ten, so that would 

account in my mind for how they got to ten, but that's 

not an appropriate number to use for dose 

reconstruction because these 136, no one worker 

would ever have been exposed to all of the processes 

all day long, particularly in they are from seven 

different refining plants. 

So, it might be a -- we don't really know what the 

meaning of that is or what meaning to attach to that 

result, so we say the GSD of ten is not a useful value.

All right, then the TIB-5000 raises the question what 

happens if there is a large variation of values in this 
87

set of measurements? So, this was data taken -- let 

me backtrack.

There was a report, a trip report by a man named 

Heatherton in 1951, and he was working most likely 

for the -- it was done in conjunction with the Health 

and Safety Laboratory, and took radon 

measurements over a two-day period at the Lake 

Ontario Ordinance Works.

And there were a number of operations that were 

discussed. The one in question right now is simply 

called removing covers. Now, BZ stands for breathing 

zone, removing covers at the Lake Ontario Ordinance 

Works.

So, on May 8, 1951, we presume, there were two 

samples taken, starting time 2:55 p.m., stopping 

time 2:56.5 p.m., and we're not sure what the AT 

stands for, but obviously it's the interval during which 

the sample was collected, 1.5 minutes. 

Then the second one was taken over a four-minute 

period starting a minute and a half later, and then 

the next day, there were four samples taken, each of 

them of less than 0.5 minutes in duration, again one 

or two minutes apart, and there's a wide range of 

values.

Now, the TIB-5000 makes the assertion these came 

from two different populations because they're so 

different and there is no historical or physical basis 

for asserting that.

They were taken at practically the same time and 

they were taken under the same conditions from the 

same process, so it just happens that there is a lot of 

variation.

So, what TIB-5000 maintains is that they're not from 

the same population. Three were in the range of 0.1 

to 17 times 100 picocuries per liter and three were in 

the range of 450 to 2,370, so they called these two 

separate populations.
88

And since the entire operation was known to occupy 

24 minutes -- not a single, but this occupied 24 

minutes out of the worker's work day, so whatever is 

the radon exposure during these operations should 

be apportioned over 24 minutes.

Well, what TIB-5000 did was simply say okay, these 

are two separate populations. The low values, even 

though they were taken on two different days, were 

one population, and then the high values are the 

second population.

And we'll assume that each of these represent a 

separate operation, and they will take the 24 minutes 

for the total removing covers and divide it into two 

operations of 12 minutes each. We simply find that 

this is not justifiable, that these samples -- I'm 

basically repeating myself, so I won't read the slide.

So, the way we suggest as an alternative way of 

handling it is to simply take all six values, weight 

each one by the sample duration. 

The sample that was collected over a four-minute 

period has a greater statistical weight than one 

collected over a half-minute period. And we ended up 

with a median value of 5.65 times 100 picocuries per 

liter, a very high GSD of 31, but we did calculate the 

95th percentile of 1,612 times 100. 

And we got a confirmation in that there was a square 

of the correlation coefficient by setting this through a 

lognormal distribution of 0.944, which is a very high 

correlation, but it's a good fit to a lognormal 

distribution.

However, we would propose, if this analysis was to 

be employed, rather than taking the entire 

distribution, because that's a very wide range, take 

the 95th percentile. 

And to see whether this is plausible, we see, 

remember this 5.65 median, 1,612, and the 1,600 is 

just below the top value between the highest value 

and the second highest value, and the median is 
89

among the low values. Remember, this are slightly 

distorted because there's weighting. 

So, I'm not saying that this is the best answer, but 

it's a reasonable answer, and it does not involve this 

artificial breakup of the exposure into two 12-minute 

periods. 

So, you have a 12-minute period with high exposure, 

a 12-minute period with low exposure, so the low 

exposure, for all the effect it has on the outcome, 

could be a zero, so you're cutting his exposure period 

in half and that is not justifiable and it's not claimant 

favorable.

Okay, observation eight deals with inadvertent 

ingestion, and this, the committee should be familiar 

with, because it was involved in it.

TIB-5000 states that the intakes by inadvertent 

ingestion are determined according to OCAS-TIB009. That's the TIB on ingestion that was written by 

Jim Neton, a former associate director for science 

with DCAS, and it's still in use for ingested intake, 

inadvertent ingestion during the operational period at 

AWE sites.

However, it has at times been incorrectly applied to 

the -- let me just go into the logic of this. The logic 

of this is there is -- I won't go into the details of this

TIB, but the conclusion from the TIB is that if you 

take the ingestion pathway, which includes an open 

beverage container, hand to mouth contamination, 

and I think other contamination with food, it happens 

that the calculated amount is equal to 20 percent of 

the activity in one cubic meter of air during that time.

However, this was incorrectly applied during the 

residual period where the airborne, the residual, the 

concentration on the floors or on the accessible 

surfaces is still there and was accumulated during the 

operating period, but now there is, instead of the 

airborne activity which contributed to that floor and 

surface contamination, you now simply have 

resuspension.
90

There's no more uranium, say, is being produced, 

and no more is being handled, and you simply have 

resuspension, and resuspension is much lower. So, 

therefore, using that 20 percent is not valid, and I 

think it was NIOSH that actually brought it up.

And there were meetings. The SCPR met twice to 

discuss this and NIOSH proposed a solution to the 

problem which is to take the last year of the 

operational period and the calculated ingestion rate 

to then be assigned to the first year of the residual 

period. 

In successive years of the residual period, you should 

still use the same number as a basis, but now 

decrease it by the annual depletion factors 

recommended in ORAUT-OTIB-0079, Rev. 01. 

And everyone, the subcommittee and SC&A agreed 

with that, so that is the current methodology. So, you 

know, the TIB-5000 was not wrong at the time. It's 

just that information is outdated.

And then here, TIB-5000 refers to occupational 

medical dose guidance that has been revised. There 

is a problem here with this slide and with the report 

and that is, as I learned during the earlier discussion 

this evening, the current version of OTIB-0006 is 

Rev. 06, not Rev. 05. 

We were not aware, we meaning the team working 

on this review, was not aware of that, so we focused 

on Rev. 05. TIB-5000 said that you should use Rev. 

03 because that was the current version at the time 

and one significant difference --

And Rev. 05 is a complete revision, a complete 

rewrite of the earlier revisions, and the primary 

impact that I saw was the direction not to assume 

photofluorography. 

The photofluorography results in a much higher 

radiation exposure, but was most likely not used at 

AWE sites, so it should not be assumed.
91

Next, observation ten is the protocol for assigning 

missed doses is inconsistent with current guidance. 

Again, this is a matter of the age of the document.

TIB-5000 prescribed the procedures in OCAS-IG001, Rev. 01, and ORAUT-OTIB-0020, Rev. 01, for 

assigning external doses to normally monitored 

workers whose doses were not reported or recorded 

for one or more time periods.

Both documents have been revised since the release 

of TIB-5000 and replaced by the current OCAS-IG001 is Rev. 03, and the ORAUT-OTIB-0020 is also 

Rev. 03.

And those are the procedures, and I won't go into the 

details, that should be followed for assigning missed 

dose, but specifically the guidance in Rev. 01, which 

is to substitute a value for each dosimeter reading, 

assign a triangular distribution with a minimum of 

zero, a mode of one-half the LOD, and a maximum 

of equal to the LOD is no longer recommended. That's 

the significant difference.

Observation 11 is a minor one. There was a section 

on environmental dose where TIB-5000 lists five 

components of environmental dose, but omits the 

ingestion pathway, which should be added, 

inadvertent ingestion from environmental sources.

And there's the issue of equilibrium factors for radon 

isotopes. So, exposures to workers with inhalation of 

a radon isotope results in radiation doses almost 

entirely from the short-lived alpha-emitting progeny.

The radon itself does not really interact. It's an inert 

gas that does not interact with tissues chemically.

As a practical matter, the concentrations of these 

progeny are usually unknown, so the direct 

calculation of doses to the lungs is generally not 

feasible.

Instead, input to IREP is in the form of working level 

months, which is a product of the working level and 
92

the exposure duration in work months.

So, reading this slide, the concentrations of a radon 

isotope, Radon-220, which is also known as thoron 

or Radon-222, which is commonly just referred to as 

radon, in the ambient air are known, but the actual 

concentrations of its short-lived progeny are 

unknown.

The working level, which is a unit of potential alphaenergy concentration, that's the concentration of 

alpha emitters, of alphas in a volume of air stretched 

out to infinity, meaning until all of the alpha emitters 

are decayed, which isn't very long, which in reality is 

they have a short half-life.

And so this is used to assess the effect of exposure 

to radon isotopes, can be in principle estimated by 

assigning equilibrium factors.

An equilibrium factor is defined as the actual PAEC to 

the PAEC that would prevail if all the decay products 

in each series were in equilibrium with the parent 

radon or thoron, as the case may be.

According to TIB-5000, lognormal distributions are 

assumed for equilibrium factors with mean values of 

0.4 for radon and 0.02 for thoron.

Well, we don't have a quarrel with the radon. That's 

a commonly accepted value of 0.4. However, with 

thoron, the UNSCEAR, the United Nations Scientific 

Committee on the Effects of Atomic Radiation, report 

to the General Assembly states that more caution 

should be exercised in assuming the average value 

of the equilibrium factors for dose assessments from 

inhalation of thoron decay products.

Objection to the use of thoron gas measurements for 

dosimetric purposes is that thoron may not be wellmixed in the indoor air because its short half-life, 

which is less than one minute.

Only where a room fan is used would thoron be wellmixed and a large variation of the thoron 
93

concentrations in the room not be found. Thus, the 

use of any grouping factor for thoron should be 

limited to situations where large spatial variation is 

not found.

And more recently than that, Harley et al. in 2010 

derived an equilibrium factor for both outdoor and 

indoor thoron environments, 0.004. Outdoors is 

never a problem, and 0.04 for indoor. Now, this is 

twice the value that is suggested in TIB-5000.

So, we just say that representing the equilibrium 

factor by a lognormal distribution with a mean of 0.02 

is questionable. I'd say that any equilibrium factor for 

thoron should be carefully looked at.

And finally, our final observation deals with 

assumptions, and this is a little redundant from 

earlier discussion, that the air sample distribution is 

unbiased.

By that, it means that the errors in measurement 

cancel out and you get a true value of the 

measurement in the air sample. Therefore, the 

uncertainty distribution due to lack of 

representativeness must be unbiased, that is, have 

an arithmetic mean of one.

And our opinion of SC&A, that even if the true 

underlying distribution of concentrations were 

lognormal, there is no real reason to submit a 

distribution of the uncertainty if the representative 

parameter is also lognormal. We just question that 

assertion, that assumption. Any questions?

Chair Beach: I suspect there's probably a few.

Dr. Anigstein: Excuse me?

Mr. Barton: Yeah, Josie, that was a lot of material and 

really well explained. Like you said at the outset, I 

think we probably need to give NIOSH a chance to 

really look at this and get back to us. 

One of the issues, as Bob pointed out, it's an older 
94

report, so some of the issues may no longer even be 

in practice, but they do appear in this document 

which hasn't been canceled, so I think it's --

I mean, certainly NIOSH, if you have comments to 

make at this stage, great, but obviously this only 

came out last month, so it's new.

Dr. Taulbee: This is Tim. Our only comment is just 

we are looking at this, but as Bob had pointed out 

multiple times throughout this, you know, this is kind 

of a dated document that was still out there on our 

books.

And I can note from the observations going through 

that there's many of the things we don't do anymore, 

and so one of the things we're actually looking at with 

this is potentially canceling this document.

What we've got to do is make sure that all of the 

guidance that's in there is actually in other 

documents, which we believe it is, you know, if 

there's anything in there that we are using. 

But with regards to these observations and so forth, 

you know, we'll get back to you on it, but my 

impression at this time is that we are probably going 

to end up canceling this document because it is so 

dated.

Dr. Anigstein: All right.

Chair Beach: Okay, thanks, Tim.

Dr. Anigstein: There is one -- the only result that I 

came across which is being incorporated into current 

DR procedures is the assumption of a lognormal 

distribution with a GSD of five when there is no other 

information to the contrary, and that is incorporated 

and cited in the, what is, TBD-6000, which is heavily 

used in dose reconstruction, and it cites that value.

Dr. Taulbee: Okay, thank you, Bob. We'll look 

specifically at that.

Dr. Anigstein: Okay, I guess in this case, I'll sign off.
95

Chair Beach: Okay, thank you so much, Bob, good 

presentation.

Dr. Anigstein: Okay, thank you for the opportunity to 

present it.

Chair Beach: Yes, we appreciate it. We'll leave that 

in progress and wait for NIOSH to report back on 

that. I don't know if the next meeting -- I guess we 

can tentatively put that on for the next meeting, at 

least an update from NIOSH on that document.

So, looking at the time, we have just about 20 

minutes to get us into that time frame. Is 045 

something that we can go through, Kathy? It looks 

like it might be a little longer than -- well, there's, 

what, 15 or 16 slides? Kathy, are you online?

Ms. Behling: Okay, I'm sorry. I was talking on mute. 

Forgive me. I can -- PER-045 should not take me very 

long. I was hoping I would actually get the 

opportunity to go through PER-052, which is quite a 

bit longer, but I'm not sure about the time element 

here. Let's start with 045.

Chair Beach: Yeah, I think --

(Simultaneous speaking.)

Chair Beach: Okay, sorry, Kathy. Yeah, I think we're 

going to run out of time for that, so.

Ms. Behling: Okay, all right.

Chair Beach: Okay.

Ms. Behling: Let me share my screen here. Can you 

see that?

Chair Beach: No, I cannot, but --

Ms. Behling: Okay.

Dr. Taulbee: We're getting a message that says all 

windows are minimized.

(Simultaneous speaking.)
96

Ms. Behling: You don't see that?

Mr. Barton: It's up on my screen, Kathy.

Ms. Behling: Okay.

Chair Beach: Well, it's not on mine, but I have it up 

from the website, so I'm good. I don't know about 

anybody else.

Member Ziemer: I'm not seeing it, but I can pull it up 

also. Actually, I had to pull up from the distribution 

from Rashaun in fact.

Chair Beach: Right, that's true. She did print that out.

Ms. Behling: Right, yeah.

Chair Beach: Mine says all windows are minimized, 

so, but like I said, I'm okay. Loretta?

Member Valerio: I'm pulling it up on the website now.

Chair Beach: Okay --

Ms. Behling: Okay, I'm sorry.

Chair Beach: -- I think you can go ahead, Kathy.

DCAS-PER-045, Subtask 4 "Aliquippa Forge TBD 

Revision" case review

Ms. Behling: All right, okay, this presentation is the 

review of one reworked case for the Aliquippa Forge 

TBD revision that was initiated under PER-045.

And just as a reminder that, you know, due to PA 

concerns, Privacy Act concerns, when I'm discussing 

this case, you know, I will be vague and -- however, 

I have uploaded the full report onto the virtual 

volumes, so you do have access to that.

I will move on here, but I'm sorry if you can't see 

this, but on slide two, Aliquippa Forge produced 

uranium rods from uranium billets. Their operational 

period was from January of 1947 to the end of 

February of 1950.
97

And the residual period spanned two time periods, 

the first being from March 1 of 1950 through the end 

of 1987, and again January 1 of 1989 through 

December 31 of 1992. NIOSH --

Participant: I guess you heard that.

Dr. Roberts: Excuse me, someone is off mute. Please 

mute your phone.

Ms. Behling: Okay. All right, I will move on then to 

Slide 3. And NIOSH issued PER-045 in April of 2012, 

as I said, due to the changes in the Aliquippa Forge 

TBD. The revision resulted from the identification of 

new data, and incorporating revisions to OTIB-0070.

External doses increased during the residual period. 

And although in most years the internal doses 

decreased, there were some years where there was 

some increase in internal dose.

So, SC&A submitted our review of PER-045 in August 

of 2014. And as part of that review, we had not 

previously reviewed the Aliquippa Forge TBD 

methodology, so that was incorporated into our 

review. And as a result, we had eight findings and 

two observations. I'll just briefly summarize the 

findings.

Finding 1, the TBD did not account for 

decontamination and decommissioning effort that 

was done in 1988, and the 1993-'94 time frame.

And Finding 2, since D&D was not considered, a back 

extrapolation to years prior to 1988 would 

underestimate external doses.

In Finding 3, we were unable to match the inhalation 

and ingestion rates that were given in Table 3 of the 

TBD.

Finding 4, the TBD did not use the reported air 

sampling data that was 20, approximately 20-fold 

higher than the assumed value of the approximately 

9 dpm per cubic meter.
98

If we go on -- oh, I'm not moving this. I'm sorry.

We move on to Slide 5. Finding 5, NIOSH used a 

measured air concentration of the 9 dpm per cubic 

meter and reduced it by more than 42-fold to a 

modeled air concentration. And SC&A considered this 

to represent a major error in deriving the inhalation 

and ingestion doses for the period of 1950 through 

1995.

Finding 6, the resuspension factor of 1 times 10 to 

the minus 6 cubic meters -- meters was associated 

with a post-AEC work which is inappropriate for 

active operation.

Finding 7, the use of the 1992 survey data postdates 

interim decontamination efforts in 1988.

And Finding 8, NIOSH did not derive inhalation and 

ingestion doses in accordance with the 

recommendations of OTIB-0070 Rev. 1.

There were also two observations.

Observation 1, the minor issue that NIOSH should 

rephrase the role of OTIB-0070 in the PER. They 

indicated that the PER was initiated because of 

revisions to OTIB-0070, when actually the TBD 

predates OTIB-0070, so the wording should have 

stated the existence and substitution of OTIB-0070 

Rev. 1, the revision.

Observation 2, neither of the TBD revisions, the 

Aliquippa Forge TBD revisions have been reviewed by 

SC&A. And as part of our PER review, we focused only 

on the methodology for deriving the residual period 

exposures.

All of those discuss -- all of these findings and 

observations were discussed at the May 16th, 2016 

Subcommittee meeting. And most of the findings, or 

some of the findings they were, they were actually 

resolved in a Revision 2 of the TBD.

So, if we move on to our Subtask 4 review, which is 
99

the case review, SC&A assessed a reworked case in 

behalf of the issuance of PER-045. And the case was 

selected based on criteria that the internal and 

external doses were assigned during the residual 

period.

We submitted our review of that case in December 

2021 to assess those pathway doses and that those 

doses were derived in accordance with OTIB -- oh, 

PER-0056.

When NIOSH reworked their case they used all the 

applicable dose reconstruction tools and current 

methodology. They recalculated all the doses, and 

they reran IREP. However, the revised report was not 

sent to the Department of Labor because 

computations did not change.

A little background regarding the case.

The EE worked at Aliquippa Forge for two brief time 

periods during the residual period.

The EE worked throughout the site and was not 

monitored.

And the EE was diagnosed with a qualifying cancer 

approximately 25 years after employment 

termination.

On Slide 10 I show you a comparison table and just 

put in percentages the Privacy Act issues. But as you 

can see on this table, the external doses significantly 

increased, which is expected because of the change 

to the PER to this TBD. But in this case, the internal 

doses did decrease somewhat.

All right. For the original external dose, it was 

calculated using doses from what was Table 13 of 

Rev. 1, PC-1 of the TBD. The doses were prorated for 

partial years of employment.

And what was stated in the report regarding the dose 

conversion factors was that it was based on the 

thyroid as being the surrogate organ. However, when 
100

we reviewed the documentation we realized that they 

actually used the maximum thymus DCF value, which 

resulted in a slight over-estimate.

The total dose that were -- that was assigned to the 

cancer sites was approximately 300 millirem.

For the reworked external dose calculations, they 

used, obviously, the revised external doses from 

Table what is now 5-1 of the TBD. NIOSH for the 

rework they did not prorate for partial years of

employment, which is a claimant-favorable 

approach.

They applied the -- (telephonic interference) -- from 

the Implementation Guide 001 for the thyroid as a 

surrogate organ, which is appropriate, and which 

resulted in a total dose of approximately 1.1 rem to 

the cancer site.

So, SC&A evaluated the external doses. And we 

found that NIOSH appropriately selected values from 

Table 5.1, the revised TBD.

And based on TIB-005, Rev. 5, selection of the 

surrogate organ was appropriate.

They also applied the appropriate DCF value from IG001.

As I mentioned, no prorating was claimant-favorable.

Doses were correctly entered into IREP.

And the external doses did increase.

And so, SC&A had no findings with the calculation of 

external dose.

For the internal dose, the original dose reconstruction 

calculated inhalation and ingestion intake from Table 

13. They compared uranium solubility types M and S. 

And S resulted in the higher dose. And this resulted 

in a total assigned dose of approximately 2.2 rems 

for each of the cancer sites.
101

For the reworked internal dose calculations they 

selected inhalation and ingestion values from Table 

5.1 -- 5-1.

They also compared solubility types M and S, with S 

representing the more claimant-favorable dose.

And based on these updated values, internal values 

in the TBD, they calculated a total dose that was 

nearly -- approximately 400 millirems, which is a 

significant reduction from the original.

For SC&A's conclusion on the internal dose, SC&A 

reviewed the CADW files. We confirmed that the 

correct intakes were entered from Table 5-1.

We also verified that the type S solubility resulted in 

the higher dose, and that the annual doses were 

appropriately entered into the IREP table, and that 

these doses were assessed to the data for cancer 

diagnosis.

And we had no findings for the internal dose.

So, that sums up PER-045 Subtask 4.

Do you have any questions?

Chair Beach: Thank you, Kathy.

Questions, Subcommittee?

Member Ziemer: I have no questions. I think the 

review was very thorough.

Member Valerio: I have no questions, Kathy. No 

questions.

Chair Beach: Great. Thank you.

And, Kathy, I have just a -- we kind of talked about 

report size last Subcommittee meeting. And it would 

seem after reading the White Paper for PER-045 and 

the Subtask 4, it would seem that both reports and 

your slide presentation satisfies both Subtask 4 and 

5.
102

Is that a correct assumption?

Ms. Behling: Yes. Yes. We, Subtask 5 is really just us 

publishing, submitting a report on our PER review, 

which includes Subtasks 1 through Subtask 3. And 

then a review of one or several cases representing 

certain selection criteria.

So, Subtask 5 is just really submitting the reports for 

the review of the PER and the case review.

Chair Beach: Yeah, which this satisfied I would say. 

So, okay.

Member Ziemer: Right.

Chair Beach: Perfect.

Member Ziemer: What you've done here easily.

Chair Beach: Yep.

All right. So, I am in agreement. I think this has been 

presented and we can consider this closed.

Ms. Behling: Okay. Now, --

Chair Beach: All right.

Ms. Behling: Go ahead.

Chair Beach: Well, I was going to say, again, I didn't 

mention it for Battelle-TIB-5000, but if we could add 

that to the matrix and this one as well, so we can just 

keep track of what we discussed.

Ms. Behling: Yes. I will, I will do that, yes.

Chair Beach: And I'm thinking we're going to need to 

carry over to the next meeting PER-052, 059, and 

062.

Ms. Behling: Okay.

Chair Beach: And then move on to the next two 

topics: the preparation for the full Board, and then 

the newly-issued guidance, so we have time to do 
103

both of those.

Ms. Behling: Okay. If you'd like, I can begin.

Chair Beach: Yes.

Preparation for April 2022 Full ABRWH Meeting: 

Review of Technical Guidance Documents Ready for 

Full Board Approval

Ms. Behling: With regard, okay, with regard for 

preparation for the April full Board meeting, I, I 

developed a handout. And we, actually we had put 

this together, I think, for the previous meeting.

And the -- I did not have this PA cleared, but you 

should have all received it and it is in the virtual 

volumes.

And so, so documents that we think are ready for full 

Board discussion are in this table. And what I've 

done, I've updated this table somewhat, as I've 

updated the handout to include documents with no 

findings. Because we had discussed that with the full 

Board. And they said even if there were no findings, 

let's have a brief discussion of what that TBD entailed 

and what we looked at, and so on and so forth.

So, I added those documents to this handout.

I also added a column for the date of document 

review and a column for comments. And what I did 

is I tried to sort on those comments. And we're going 

to do that in a little bit. So, that may help us in 

determining what documents would be most relevant 

to present at the next Board meeting.

And then, finally, I added a column for full Board 

closure date. And so, you should be able to see that.

So, what, and the very first document that we have 

in Table 1 on this handout is OTIB-0014. And I should 

have actually included something in the comments 

that indicated the finding associated with this 

document has to do with OTIB-0052, the 

construction trade worker OTIB. And that is a 
104

complete discussion onto itself.

In fact, that was going to be a part of my discussion 

in the PER-062 review.

There's a long history there. And I think there are 

several documents in several PERs and this particular 

OTIB that when we discuss the construction trade 

worker topic we combine those all together.

So, what I am going to suggest to the Subcommittee 

is that perhaps the next five I would say, five to six 

OTIBs.

There's an OTIB-066; there's a Report 86; there's 

PER-080, and PER-067, and those are both general 

steel industries, so I would like to keep those 

together; and there's also a PER-063.

And PER-063 would be the first one that has no 

findings, so I'm going to try to be creative here in 

coming up with a nice presentation for that.

But based on, based on the last time that we made a 

presentation to the full Board, I presented five, five 

reviews, document reviews. I expected it to take 

maybe an hour. However, there were no Board 

comments, so we were able to do that presentation 

I'd say within 30 or 35 minutes.

So, even though PER-057 does have 11 findings, just 

based on what transpired during the last full Board 

meeting, I think I would suggest maybe five to six of 

these document reviews. And just wanted to get your 

opinion on that.

Chair Beach: Well and, Kathy, this is Josie. I think we 

could probably include PER-065. That's, that's a 

relatively quick one. And that would take us to six, 

which I think we were actually slated for the last 

meeting but then you pulled one.

Ms. Behling: Rashaun, I guess I'm going to ask you, 

have you determined what kind of a time frame we 

have at the next meeting in April? Do we have a full 
105

hour?

Dr. Roberts: It really depends on what you want to 

present. I suspect that there will be planning upon 

for you to go an hour. Could be more if you need it.

Chair Beach: Okay. So, I would suggest going to six. 

And I don't know if even incorporating the next one, 

064. But, you know, that's your workload, too, Kathy.

And other Subcommittee members holler. Loretta, 

any comments?

Member Ziemer: Well, I think you've got a better feel 

for how much time that would take. And so I'm not -

- I'll defer to what, what you feel you need on that.

Chair Beach: Okay. Thank you.

I'd just assume move through these quicker, if we 

can, and get rid of some of our backlog. That would 

be my feeling, as long as we have the time.

Ms. Behling: Josie, this is Kathy. I, I could certainly 

try to fit in seven. That's fine with me. And the 

seventh one on the list is zero findings. So, we 

shouldn't have a lot of discussion on that.

So I, I certainly have the time to put together a 

presentation with seven, if that's what you're inclined 

to do.

Chair Beach: Yeah. I think with hearing from others, 

if it goes the full hour, if we get into an hour and 15 

minutes, or an hour and 30 minutes I think we'll be 

okay.

I'm inclined to says an hour and 30 minutes. That 

way we have room for that one with 11 and any 

questions.

Ms. Behling: Okay.

Member Ziemer: I wouldn't anticipate that there 

would be a lot of input from the Board. I think we've 

handled these and they, they mostly are pretty 
106

straightforward. I think the Board won't have a lot of 

questions, so.

Ms. Behling: Yeah, I agree.

Member Ziemer: That should be adequate, yeah.

Ms. Behling: Okay. And I stand corrected. I think we 

did get this PA cleared. So, okay. And so it is on the 

website.

Chair Beach: Oh, okay. Great.

Member Valerio: Josie, this is Loretta.

Chair Beach: Okay. Hi, Loretta.

Member Valerio: Hi. So, I think going with the seven, 

and I agree completely to go through as much of this 

backlog as we can. I think we should maybe 

anticipate maybe a little more than an hour. If we 

finish earlier, then we do, if there's not a lot of 

questions. But we should always try to present as 

much as we possibly can to get these older ones 

cleared up.

So, I think an hour and 15 minutes or an hour and a 

half. I think an hour and 15 minutes should be 

enough. Again, I question the General Steel 

Industries with the 11, you know, items to be 

presented. That might take a little bit longer just 

presenting it. But, again, that's just my thought on 

it. I would say at least an hour and 15 minutes just 

to be safe.

Chair Beach: Okay. And we'll leave that fine tuning 

for the time when the presentations are underway.

Kathy, if you feel like they're going to take longer, 

you can let us know or let Rashaun know.

Ms. Behling: Okay. Very good.

Chair Beach: All right, thank you.

Ms. Behling: We can have this, yeah, we can have 
107

this prepared as what you said. And if we don't have 

the time, we don't, but at least they'll be prepared, 

ready to go.

Member Ziemer: Are you certain that the GSIs were 

not presented before, General Steel?

Ms. Behling: Not to the full Board. I don't believe they 

have been presented to the full Board.

And the one that has the 11, the 11 findings is from 

our case reviews of tests of --

Member Ziemer: All the case review ones. Okay, got 

you.

Ms. Behling: Yes.

Member Ziemer: Got you.

Ms. Behling: Okay?

Member Ziemer: Okay.

Ms. Behling: Yeah.

Member Ziemer: Uh-huh. Got you.

Ms. Behling: All right. Is it okay if I move on to the 

newly issued guidance and supplemental topic?

Chair Beach: Yep. I was just going to suggest that, 

so.

Ms. Behling: Okay. All right.

Now, I do have this up on the screen. I don't know, 

is anyone seeing it? I'm showing that I'm presenting 

it, but.

Chair Beach: I don't have it. But I think mine was 

disrupted. I actually have it up on my screen, so I'm 

okay.

Ms. Gogliotti: Kathy, we can see your screen.

Member Ziemer: Yeah, it is showing.
108

Chair Beach: I think I just lost connection. Though 

I'm fine.

Member Valerio: I can't see it either.

Newly-Issued Guidance Documents and 

Supplemental Topics

Ms. Behling: Okay. All right.

I'm going to start by just identifying, at least to the 

best of my knowledge, there have been two new 

reports issued that have not been reviewed by SC&A. 

I'll just give you a summary.

One is Report 97. And the title of that is Breathing 

Zone to General Air Concentration Ratios in Small 

Rooms. And it's pretty much what the title says.

They've evaluated several air sampling studies that 

were performed in small rooms and developed this 

report. And so I just wondered if that's something 

that the Subcommittee would like us to review?

Chair Beach: I would be agreeable with that.

Rashaun, can we do our tasking here or would you 

prefer to do it via email after the meeting?

Dr. Roberts: Well, we can go ahead with the tasking.

Chair Beach: Okay. Other Subcommittee members?

Member Ziemer: Yes, let's proceed with that.

Member Valerio: Yes, Josie. Thank you.

Chair Beach: Okay. So, yes, you are tasked with that 

first one, 0097, Breathing Zone to General Area Air 

Concentration Ratios in Small Workrooms.

We can go ahead and move forward.

Ms. Behling: Okay. And the second report is Report 

0102. And this is the Assessment of Los Alamos 

National Labs Plutonium Bioassay Programs from 

1996 to 2001.
109

And this is actually the development of a co-exposure 

model. So, I felt it might be something you would like 

us to look at.

Chair Beach: Yeah. I would agree with that for sure.

Mr. Barton: Well, also, I think we're having a meeting 

about LANL pretty soon. Correct?

Dr. Taulbee: This is Tim. This is Tim. This, I think, 

should actually be addressed under the Los Alamos 

Work Group.

Ms. Behling: Okay. I was wondering. Because I, I 

looked ahead and I wondered, is that Work Group still 

active? I didn't see much.

Chair Beach: Yeah. We are actually having a meeting 

in March, the 23rd of March.

Ms. Behling: Okay.

Chair Beach: To have a presentation from NIOSH, so.

Mr. Rutherford: Yeah. I will be presenting that, that 

report.

Chair Beach: Yes? Okay.

Mr. Barton: That came together very recently, I 

think. That's, that's why it appears in this 

presentation.

But, yeah, I mean, we're talking about the two 

reports from LANL that LaVon just mentioned, or 

LaVon intimated. So, I think that probably could go 

under the LANL Work Group.

Ms. Behling: Yeah, I agree.

Mr. Barton: As a simple paperwork issue.

Ms. Behling: Okay. I agree.

Yeah, I apologize because when I looked at the Los 

Alamos National Lab I didn't see that there was a lot 

of activity going on when I put this together. So, I 
110

apologize for that. Okay?

Chair Beach: Oh. No, no apology necessary.

Ms. Behling: All right. Okay, there have also been 

three newly-issued PERs.

The first one is PER-090. And that's for Grand 

Junction. And, again, external and internal exposure 

pathways impacted.

And we've been looking at all of the other Grand 

Junction TBDs, so I thought it was appropriate to look 

at this PER-090.

Dr. Taulbee: This is Tim.

If I could interject here again. Please remember that 

we're going to be revising the Grand Junction TBD 

following the review that SC&A just did. Specifically, 

we're going to be revising that table. I can't 

remember if it's 2 or 5. But it was Observation 2 that 

SC&A had.

And so, we're going to be redoing that.

And, you know, at that time we'll be basically doing 

another PER to see, you know, what goes on. So, I 

would actually recommend you defer on this one until 

we revised the Grand Junction TBD that we thought 

we were done with.

Ms. Behling: Well, I know in the past we usually look 

at all of the PERs. But that's up to the Subcommittee. 

Just like with I know there's been multiple PERs for 

various facilities, various sites, GSI and so on and so 

forth. And we usually take these as, as they're 

issued, so.

Dr. Taulbee: Yeah. This is up to the committee from 

that standpoint. But you just, you know, identified 

several observations in the Grand Junction TBD which 

is part of your PER process, you look at all of this. 

You know, are there any outstanding issues, or 

findings, and that type of thing?
111

And we've already acknowledged that we're 

addressing some of those and going to be revising 

them.

So, it seems to me that's duplicative work. That's my 

only comment.

Ms. Behling: Okay. Well --

Mr. Barton: Tim, this is Bob. I mean, part of our job 

here is to look at the process as a whole, though. So, 

I mean, obviously --

Ms. Behling: And the other example -- Excuse me. 

I'm sorry, Bob.

The other thing that will happen is when the new PER 

is issued for Grand Junction, the cases that are going 

to be looked at are going to exclude anything that 

was already looked at under PER-090.

So, we need to also ensure that the selection criteria 

for this, up until this point in time, is appropriate.

Mr. Allen: This is Dave Allen. That's absolutely not 

true. Any PER, we evaluated all the changes from the 

what it is today versus, you know, what it was in the 

past essentially. If it was, if a population was already 

reviewed under PER, an earlier PER and nothing 

changed with those things, that's not being somehow 

that we zeroed the population down and not have to 

review them.

But, I mean, if we change something like, say, 

increase the intakes at Grand Junction, we will look 

at all the cases.

Ms. Behling: Okay. And the next PER it would be a 

reduced population because of anything you've 

already looked at under this PER. Correct?

Mr. Allen: If we -- it will, it will reduce the population 

if we already looked at it, yes. But if we're doing 

something in the next revision that affects 

everybody, then we will redo all the cases.
112

I mean, we don't eliminate them because they were 

reviewed under PER-090. We, we look at what it is 

today, and could anything have been missed in the 

past, essentially.

Ms. Behling: Okay.

Chair Beach: Well, we would typically do a review and 

then do a focused review of the next one that comes 

out for any changes. Yeah.

And, Tim, did you say Grand Junction is in the works, 

correct, but there was not really a time frame?

Dr. Taulbee: That is correct. I mean, we've got two 

issues but we are, but since there's three, 

Observation 1 is in abeyance, Observation 2 is in 

abeyance. Observation 2 is the big one, that's where 

the intakes are changing, so the internal bases are 

going to change from that standpoint.

And Observation 3 you guys are going to be following 

up on.

Observation 4 is in RCORP for the neutron exposures.

And Observation 5 is for us to better define why we 

don't think neutron doses, why you need -- why you 

don't need a co-exposure model for the latter years.

So, my point though is, is that really Observation 2 

is changing the internal doses, so.

Chair Beach: Right, right.

Paul, Loretta, any comments on that, postponing or?

Member Ziemer: Yeah. My inclination would be to do 

the whole thing at the same time.

I think if you go ahead and do the revision, anything

they do there, the other will still carry forward, you'll 

see where it was before. Those observations you can, 

I don't see why you can't still look at those and look 

at the total package of what the final product is.
113

My inclination would be to go ahead and wait for --

now, again, we're talking about a timeline that's not 

too far distant; right? Maybe later in the year?

Dr. Taulbee: That's correct, yes.

Chair Beach: That's the hope.

Okay. Let's kind of keep this in mind, Kathy, but just 

let's not assign that one at this time.

Ms. Behling: Okay. I understand. That's fine.

The next one is PER-092. And that's the Weldon 

Spring Plant Division. This involved changes to 

environmental intakes and onsite ambient doses. And 

Uranium-234 intakes were added.

I don't know that there is a Work Group for Weldon 

Spring.

Chair Beach: It may have been retired.

Ms. Behling: Yes. Not an active Work Group, right.

Chair Beach: Correct.

I'm okay with tasking this one.

Member Ziemer: I am too.

Member Valerio: I'm okay with that, Josie.

Chair Beach: Okay. So, Weldon Spring has been 

tasked.

Ms. Behling: Okay. And then the last PER is PER-093, 

and that's Texas City Chemicals, TBD revision. And 

this revision increased the ingestion intakes during 

the residual period.

Chair Beach: Okay. And I don't believe we have a 

Work Group for that either at this time. So, I am okay 

with tasking that as well.

Paul and Loretta?
114

Member Valerio: I'm okay with tasking that as well.

Member Ziemer: I am, too.

Chair Beach: Those three have been tasked.

Ms. Behling: Okay. I had a few other supplemental 

topics to talk about. However, I don't know if we still 

have time to discuss those or if you want to start 

preparing for the next meeting?

Chair Beach: The next meeting is actually a date 

which we could probably send around. Or, I think we 

could have that meeting fairly soon, within the 

timeline that we need for the notification.

Member Ziemer: We can decide that online, can't we?

Chair Beach: Yeah. Yeah, I think so.

And I'm okay with carrying on if we have about 15 

minutes left.

Rashaun, are you okay with that?

Dr. Roberts: Sure. That's fine.

Chair Beach: Okay. But I would add that I think we 

should schedule another Subcommittee meeting as 

soon as possible in the time constraints that we have, 

because we do have items we could go forward with 

ready right now, so.

Ms. Behling: Okay. If we're ready to move on.

Prior, I'm just going to preface with this, prior to 

losing access to the BRS, when I was generating this 

table of Subcommittee-approved documents that still

need, you know, Board review and approval, I 

encountered several limitations with the BRS, the 

tracking system, that I just wanted to bring to your 

attention.

And I just want to note that Lori Marion-Moss and I 

discussed this, so it's not a surprise to her. And, you 

know, she seemed to be in agreement that, you 
115

know, if there could be improvements to the BRS at 

some point in time, that would be a good thing.

So, when you go into the BRS and you generate a 

report, there is no indication that the document's 

been canceled, or it's been revised, or that there is a 

new document.

And so when I generated the report and I started to 

put together these tables I realized, oh, well, this 

really, this document is not really of relevance 

anymore because the document's been canceled. 

And I couldn't prioritize things very easily unless I 

went into each and every document and tried to trace 

back where we are with that particular document.

I guess the other issue was I would generate a report 

that would show one finding. And I assumed there 

was a finding there. But when I went into the BRS, I 

realized it was just an entry that says there are no 

findings associated with this report.

So, it would be nice in the future if the BRS could 

possibly be updated with this type of information. I 

don't know if that's a possibility or not, but I'm just, 

just putting that out for consideration by the 

Subcommittee.

I will move on.

Chair Beach: Well, Kathy.

Ms. Behling: Okay, go ahead.

Chair Beach: Well, no, before you move on.

Ms. Behling: Okay.

Chair Beach: So, this is something that I think is 

necessary. However, with what Grady said earlier, we 

don't know really what the BRS is going to look like.

So, my question is can you add these items to our 

matrix so we don't lose them, so we can, when we do 

have access and we know what it's going to look like, 

then we can work with you and Lori and try to figure 
116

out if we can add these?

Ms. Behling: Yes.

Chair Beach: Does that seem reasonable, Lori? I 

think you're a big part of this. What are you, what 

are your comments?

Ms. Marion-Moss: This is Lori.

Yes, this sounds reasonable, Josie.

Chair Beach: Okay. So, maybe add this as a matrix 

just to keep, so we don't lose track of it, Kathy, if you 

don't mind.

Ms. Behling: Okay. Not at all.

Okay, going --

Member Ziemer: I can under -- Let me insert one 

comment on handling the assignments tissue. It 

would be very easy to add a minor column to the 

matrix that says "number of findings."

Chair Beach: Correct. Yeah. To the BRS.

Ms. Behling: Okay. Okay, yes, I can do that.

I do have it in the handout with the documents for 

that have already been approved by the 

Subcommittee. But I could add also to the matrix. 

Okay.

All right, moving on.

Earlier today during our earlier discussions, I did talk 

about the fact about communicating to SC&A when 

there are canceled documents or revised documents 

or new documents. And I think we resolved that 

issue. And we will be included in that notification.

Chair Beach: Except for, except for the templates. 

We didn't really finalize it for that.

But we can probably keep that for our 052 discussion 

--
117

Ms. Behling: Right.

Chair Beach: -- unless we can cover it now. I don't 

know if we have time or if anybody has an answer. 

That would fall under Lori again.

Ms. Behling: Yeah. And I guess this has been a topic 

that I know I personally have brought up several 

times during previous meetings. And I thought at one 

point in time, and we had gone through and looked 

at some previous discussions, and there was, you 

know, various discussions in the 2015 and '16 time 

frame, 2017.

And the templates are not, as far as SC&A is 

concerned, we don't have access to the templates. 

We -- they are not published anywhere. They're not 

on the NIOSH website. There's no real location, even 

under the controlled documents where we can access 

or see those documents.

We sometimes stumble across them. And it would be 

nice if, and I've mentioned this before, and I thought 

that Ted was even going to put together what I was 

going to request, is a list of all of the sites that have 

a template generated for them or and that's their 

means of dose reconstruction methodology.

And it would also be nice if the Subcommittee would 

be aware as to what those documents are and when 

they are changed, when they get changed. Because, 

as we'll discuss under the PER-052 I believe, we, we 

realized that there was a PER issue because of a 

change to a, to a template. But we also recognized 

that there were two additional revisions made. In 

some cases that doesn't get a PER because the doses 

decreased.

And but I just think it would be useful for the 

Subcommittee to, or the Board to be aware of these 

changes, and of the existence of these documents.

Chair Beach: Yeah. Kathy, and you mentioned that. I 

thought we did get a list a couple of years ago about 

the templates when we were discussing it prior to 
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this.

Does anybody remember that? I'd have to go back 

through.

Ms. Marion-Moss: I do. This is Lori.

I sent a list of all the sites' names that had templates. 

Date was September the 28th, 2018.

Chair Beach: Yeah, okay. I thought we had.

If you could resurrect that and send it or put it in the 

virtual volumes again, or send it to Kathy. Is that 

something you could do, Lori?

Ms. Marion-Moss: You should receive it in a couple 

minutes.

Chair Beach: Oh, thank you. Yeah, I thought we had 

done that. So, okay, perfect.

Ms. Marion-Moss: Yeah.

Chair Beach: And I don't know if you're updating that 

or have updated that from the 2018 time frame. I 

guess that's something we can discuss moving 

forward.

Ms. Marion-Moss: Sure.

Ms. Behling: Okay, that's for Lori.

Yeah, I was under the impression I had that Ted had 

distributed that list. But I don't know whatever 

happened to it. And I don't think -- somehow that 

may have fallen through the cracks. And I, I think 

that's something that would be very useful to 

resurrect.

So, I think your recommendation to include this is a 

good one.

Chair Beach: Let's add that to the matrix, also, that 

we discussed it, and that we looked -- we'll look at 

the two, the one that Lori just sent you and then 

discuss it at the next meeting, where we go from 
119

there.

Ms. Behling: Okay. And I guess just to get back to 

the two -- the BRS again. And Josie, I know you had 

identified the fact many meetings ago that review of 

the BRS just lacks clarity.

And examples of that that I came across when I was 

preparing for the full Board meeting were things like 

OTIB-0052, OTIB-0020. There were discussions of 

OTIB-0052 for the full Board. And even though we 

had closed the findings, there were a lot of follow-up 

questions by Board members. And that didn't really 

get captured anywhere.

And so I'm thinking that when we gain access to the 

BRS and I update it with information from the full 

Board finalization process that I'm going through 

right now, that I include this, this expanded, 

hopefully expand on some of these findings and 

follow-up discussions when we get access to the BRS, 

if that's agreeable to the Subcommittee.

Chair Beach: Yeah, it is to me, because I think we 

definitely need to have clarity in all of this so that 

years later we can go back and understand what was 

done, why, and who. So, I agree with that.

Anybody else?

Member Ziemer: Yeah, I agree as well.

Member Valerio: I agree as well.

Ms. Behling: Okay. And then, lastly, again, as I was 

putting together all this information and going --

went back through transcripts of documents that 

were already presented to the Board, several items 

came up, came to my attention for regarding followup issues.

In the past -- and I made sure that this didn't, you 

know, or I tried to be sure that this didn't happen in 

today's, in our discussions today -- but we've closed 

findings that were designated as in abeyance with the 
120

indication from NIOSH that this procedure is going to 

be revised and updated, and it was going to take care 

of all of the findings associated with that.

And as I was going through, as I said, the 

documentation, OTIB-0017 is an example of one that 

was going to be revised many years ago, but that 

didn't happen. There were overarching issues in 

under the skin exposure, the overarching 009 --

0009.

And, like, OTIB-0011, these are all examples of 

where the Subcommittee felt comfortable in closing 

the findings that perhaps should have been kept in 

abeyance until we followed through. Because then we 

can track those a lot easier.

That is one thing we can sort on in the BRS. What are 

the in abeyance items that are still out there?

Have they been resolved?

Has there been a revision to that TBD or to that 

document?

And so, I would just encourage the Subcommittee to 

continue on the path that you've been doing. But in 

the past somehow that got away from us. And that is 

the not-closed items that should be in abeyance 

because there needs to be a change to a TBD or 

procedure.

Member Ziemer: Kathy, I'm wondering if those go 

back to some of the earlier times when we might 

have actually added the category of "in abeyance" to 

handle that very question.

I think, I think you're right. Originally we closed stuff 

when we were sure they were going to be changed. 

But have you found any of those? The ones you 

mentioned, were they more recent in the sense of 

within the past few years?

Ms. Behling: No.

Member Ziemer: Because I think the abeyance 
121

category was added to actually handle this issue.

We didn't --

Ms. Behling: Right.

Member Ziemer: I don't think we originally had that 

as a category.

Ms. Behling: Yeah, it was added. But there were, I 

did certainly find circumstances where we said, okay, 

it was in abeyance for a couple meetings here. And 

now NIOSH says they're in the process of reviewing 

this TBD. I am clear there was a lot of discussion on 

that on the OTIB-0017.

So, we all walk away feeling comfortable with that, 

and it just didn't happen.

And that only came to light --

Member Ziemer: Those closed too soon.

Ms. Behling: Right.

Member Ziemer: Closed too soon.

Ms. Behling: And it only came to light when I went 

through the transcripts to prepare for Board meetings 

that had already been set.

Member Ziemer: All right. Okay, thank you.

Ms. Behling: Uh-huh.

Chair Beach: So, I guess moving forward, as -- And 

I don't really want to task you with going through all 

the transcripts and coming to closure on these, but 

the ones that you have identified here we probably 

need to think about, moving forward, how to capture 

these and correct them, or at least add verbiage that 

we closed it but the procedure never got updated. So, 

now where are we at?

I guess we need to think about that. And maybe have 

it as a topic at our next subcommittee meeting.
122

Ms. Behling: And I do know when we had access to 

the BRS, occasionally I would prepare a table for 

Wanda of in abeyance findings that were still out 

there. And we would make that a topic of discussion 

during these meetings.

But with not having access to the BRS right now, that 

would be a little bit difficult.

We have recently discussed this OTIB-0017 issue 

with NIOSH where they did indicate that they are 

definitely working on an update for that, a revision 

for that. Which I assume --

Chair Beach: Okay. I think the best thing to do here 

is just categorize these in a BRS matrix item and list 

these last several slide topics we talked about, so 

that when we do have access we can figure out how 

to move forward with them all.

So, just for clarity in, you know, finishing things up.

Ms. Behling: Okay. And then, lastly, again, in reading 

through transcripts I remember when I made the 

presentation on OTIB-0082. And that happened to be 

a document that we reviewed. We didn't have any 

findings. But because of the complexity, we did 

present it to the full Board.

And as a result of that, the Board members had 

questions and a lot of follow-up, or maybe one or two 

follow-up questions. And that doesn't get captured 

anywhere.

And I don't know that they, the questions were ever 

really answered.

And the same with OTIB-0052. There is a series of 

questions that were asked by the full Board that I've 

lost ends and you don't see any follow-up.

And Lori and I have talked about this, too, because 

we feel almost that for OTIB-0052, because of just 

the long history, we almost need, like, an internal 

discussion on that one by itself.
123

But I think somehow we need to capture when the 

Board members have questions during the 

finalization process and not lose that.

Chair Beach: Yeah. And I think we have that well in 

hand going forward. But, yeah, we, how do we go 

back and capture the past closures?

Any comments or thoughts on that, Paul or Loretta?

Member Ziemer: Yeah. I'm mulling that over in my 

mind. Certainly, going forward, if the Board, if the 

Board has issues that they want clarification on or 

don't -- basically, in those cases we, we should say 

the issue is not closed.

Typically, when we say it's closed in the 

Subcommittee, we are recommending closures. Isn't 

that the case? The Board has to put the final stamp 

on it, I think. And if that doesn't occur at the meeting, 

then we've got to continue it some way.

Chair Beach: Yep. And I would say the only way to 

go back to 0082 or 0052 is to go back through the 

transcripts and capture those questions, document 

them, and then move forward with the answers. I 

mean, that would be a tasking for --

Member Ziemer: Well, we need to have a -- do we 

need to differentiate in the matrix something like the 

Subcommittee's recommendation and then have a 

final column "Board's action"?

Ms. Behling: In my temporary matrix I do have a 

Board action resolution column. And it was designed 

for exactly that.

However, in the BRS as it exists, like after I did the 

OTIB-0082 presentation, I -- there was nothing 

added to the BRS that would indicate there should be 

a follow-up. So, that, it was easily lost because we 

didn't really have a mechanism to capture that.

Member Ziemer: Yeah. Well, when we get the new 

system we can look at that. But it seems to me a 
124

possibility would be to differentiate between the 

subcommittee's recommendation to the Board and 

the final Board action.

Ms. Behling: Yes. Yes.

Ms. Marion-Moss: This is Lori. Shortly before we lost 

access to the BRS we did add a feature in the BRS. 

We just didn't use it. But the feature had been added 

to distinguish what issues or findings closed by the 

Subcommittee, and which ones were closed by the 

Board, the full Board.

Member Ziemer: Well, that's good. Yeah.

Ms. Marion-Moss: We just have not implemented it.

Member Ziemer: Uh-huh. But it can be done readily 

then, or at least conceptually it can be done.

Ms. Marion-Moss: I think that's the right, that's the 

right term, Paul.

Member Ziemer: Right.

Chair Beach: Yeah. My recommendation is, again, to 

capture this in the temporary matrix and under the 

BRS wish list, or whatever you want to call it. And, 

and once we have access, then we'll have a whole list 

of things that we're going to have to work on, it 

sounds like.

Ms. Behling: Okay.

Chair Beach: If that seems agreeable to everyone. 

Obviously, we can't really do anything now.

Member Ziemer: Right.

Member Valerio: Second to that. But I agree. I'm 

sorry, this is Loretta.

Going back to the OTIBs, it seems the only way to 

capture the information that we need, OTIB-0082, is 

this something that we're going to have to do on 

other OTIBs, go back through old transcripts?
125

Chair Beach: Probably. At least which ones have been 

presented to the Board, and then see if there was any 

comments that didn't get resolves at some point. 

Yes, I would say yes.

Ms. Behling: And I have already done that. I have 

already gone back through all of the previously 

presented documents and gone through the 

transcripts and made notes of what was discussed. 

And so I've already done that.

Chair Beach: Okay. Is that something that you can 

put together in a White Paper or a presentation of 

some kind or just so we --

Ms. Behling: Okay.

Chair Beach: -- so we don't lose track of all that?

Ms. Behling: Okay, yes.

Chair Beach: I would say that was a tasking that the 

Subcommittee would need to agree on.

Ms. Behling: Okay.

Chair Beach: Since you've already done it, it would 

be nice to finalize at least what you have done.

Ms. Behling: Okay. Sure.

Member Ziemer: You know, and Kathy, if you do that 

or you have done it, but sort of a difference between 

answering some questions for the Board and having 

the Board say we don't want you to close this. You 

know what I'm saying?

Ms. Behling: Yes.

Member Ziemer: The Board, Board may raise 

questions in a discussion, and we may say we have 

to come back and let you know the answer to that. 

But in the meantime, they are not objecting to closing 

it.

Ms. Behling: Absolutely.
126

Member Ziemer: If we can restate it. Yeah. Yes.

Ms. Behling: Yes, you are 100 percent correct. There 

were a lot of -- now, I think OTIB-0052 they maybe 

want to close everything. Or, I don't know, there was 

just a lot of questions there.

But with, I think, OTIB-82 they just wanted some 

follow-up questions, not that they didn't want to close 

out that document review, but there were some 

follow-up questions that I don't think were 

addressed.

Okay, that's all I have for the supplemental part.

Chair Beach: Okay. Again, thank you for all the work, 

extra hard work that went into this.

Next WG Meeting/Plans

Chair Beach: I think the last thing is just sending 

around dates for a new meeting. And unless there's 

other comments, questions?

Member Valerio: Josie, this is Loretta. I do have a 

question on Texas City Chemicals.

Is there still an active Work Group on that site or has 

that moved over as part of the AWE Work Group?

Chair Beach: I believe that was closed. But Rashaun 

maybe has a better idea.

Dr. Roberts: Yeah. I will have to look at my notes 

then and see, and see what happened with that 

group?

Member Ziemer: I think AWE handled it. But, yeah, 

Rashaun needs to double check.

Ms. Behling: Yeah, I think --

Mr. Barton: Yeah. This is Bob. I agree with that. I'm 

not sure there was ever a Texas City Chemicals Work 

Group separate from the AWE Work Group. I think it 

was all just handled --
127

Member Ziemer: Yeah, I don't remember one.

Ms. Behling: There was, I think --

Member Valerio: There was one I believe with -- I'm 

sorry, I didn't mean to interrupt. This is Loretta.

I believe there was one. But two of the members are 

no longer on the Board. And I didn't know if there 

had been new members assigned or it had been 

retired. I don't recall.

Ms. Behling: Yeah. And I'm sorry for interrupting 

Loretta.

I'm looking on, under Texas City on the NIOSH 

website, and it looks like there were a lot of 

discussions for this particular site under the 

Surrogate Data Work Group. Because there was a 

discussion of using surrogate data for the Texas City 

Chemicals.

So, it seems like, and that's the last meeting for --

under the Surrogate, the Surrogate Data Work Group 

was back in two thousand and -- November of 2010. 

So, that's why I included it in this review.

Chair Beach: Okay. Any other comments or?

(No audible response.)

Adjourn

Chair Beach: Then I move that we adjourn.

Member Ziemer: Agreed.

Member Valerio: Agreed.

Chair Beach: I'm waiting for Rashaun. I think she 

must be looking at Texas City.

Dr. Roberts: Yeah. That's something I'll need to look 

further into. I don't see where that has been put with 

other groups off the top. So, I'll need to consult a 

little bit further.
128

Chair Beach: Okay. Are we okay to close then, 

Rashaun?

Dr. Roberts: Yes.

Chair Beach: All right. Thank you, everyone.

(Whereupon, the above-entitled matter went off the 

record at 3:41 p.m.)