THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

PUBLIC HEALTH SERVICE 

CENTERS FOR DISEASE CONTROL AND PREVENTION 

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 

convenes the 

WORKING GROUP MEETING 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

NEVADA TEST SITE 

The verbatim transcript of the Working 

Group Meeting of the Advisory Board on Radiation and 

Worker Health held in Cincinnati, Ohio on March 27, 

2007. 
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C O N T E N T S 

March 27, 2007 

WELCOME AND OPENING COMMENTS 

DR. LEWIS WADE, DFO 

INTRODUCTION BY CHAIR 10 

ENVIRONMENTAL INTAKES AT NTS 12 

COMMENTS 6 AND 7 57 

COMMENT 23 59 

TBD DISCUSSION 71 

COMMENT 1: RADIONUCLIDE LISTS 72 

COMMENT 2: REACTOR TEST RE-ENTRY 84 

COMMENT 3: DOSES FROM LARGE PARTICLES TO GI TRACT 94 

COMMENT 4: ORO-NASAL BREATHING 98 

COMMENT 8: EXTERNAL DOSE DATA FOR 1963-1966 99 

COMMENT 9: ENVIRONMENTAL EXTERNAL DOSE DATA FOR 

1968-1976 103 

COMMENT 10: PRE-1963 EXTERNAL ENVIRONMENTAL DOSE 105 

COMMENT 11: CORRECTION FACTORS 105 

COMMENT 12: RADON DOSES IN G-TUNNEL 110 

COMMENT 13: ENVIRONMENTAL DOSES DUE TO I-131 VENTING 

114 

COMMENT 14: INTERNAL DOSE FOR PRE-1967 121 

COMMENT 15: BLAST WAVE 128 

COMMENT 17: INGESTION DOSES 130 

COMMENT 18: ORAUT-OTIB-0002 145 

COMMENT 19: PRE-1966 BETA DOSE 148 

COMMENT 20: INTENTIONAL NON-USE OF BADGES 150 

COURT REPORTER’S CERTIFICATE 186 
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TRANSCRIPT LEGEND 

The following transcript contains quoted material. Such 

material is reproduced as read or spoken. 

In the following transcript: a dash (--) indicates 

an unintentional or purposeful interruption of a 

sentence. An ellipsis (. . .) indicates halting speech 

or an unfinished sentence in dialogue or omission(s) of 

word(s) when reading written material. 

-- (sic) denotes an incorrect usage or pronunciation 

of a word which is transcribed in its original form as 

reported. 

-- (phonetically) indicates a phonetic spelling of 

the word if no confirmation of the correct spelling is 

available. 

-- "uh-huh" represents an affirmative response, and 

"uh-uh" represents a negative response. 

-- "*" denotes a spelling based on phonetics, 

without reference available. 

-- (inaudible)/ (unintelligible) signifies speaker 

failure, usually failure to use a microphone. 
 

 

 

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P A R T I C I P A N T S 

(By Group, in Alphabetical Order) 

BOARD MEMBERS 

EXECUTIVE SECRETARY 

WADE, Lewis, Ph.D.

Senior Science Advisor 

National Institute for Occupational Safety and Health

Centers for Disease Control and Prevention 

Washington, DC 

MEMBERSHIP 

CLAWSON, Bradley

Senior Operator, Nuclear Fuel Handling 

Idaho National Engineering & Environmental Laboratory 

MUNN, Wanda I.

Senior Nuclear Engineer (Retired)

Richland, Washington 

PRESLEY, Robert W.

Special Projects Engineer

BWXT Y12 National Security Complex

Clinton, Tennessee 

ROESSLER, Genevieve S., Ph.D.

Professor Emeritus 

University of Florida

Elysian, Minnesota 
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IDENTIFIED PARTICIPANTS
 

BEHLING, HANS, SC&A

CHANG, CHIA-CHIA, NIOSH

ELLIOTT, LARRY, NIOSH

HOWELL, EMILY, HHS

KOTSCH, JEFF, DOL

MAKHIJANI, ARJUN, SC&A

MAURO, JOHN, SC&A

MCDONOUGH, ALEX, SEN. HARRY REID

NETON, JIM, NIOSH

ROLFES, MARK, NIOSH

ROLLINS, GENE, ORAU

SMITH, CHERYL, DADE MOELLER AND ASSCS. 
 

 

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P R O C E E D I N G S

 (9:30 a.m.) 

WELCOME AND OPENING COMMENTS 

DR. LEWIS WADE, DFO 

DR. WADE: This is the work group. We’re 

about to begin. This is Lew Wade and as 

always I have the privilege of serving as the 

Designated Federal Official for the Advisory 

Board. And this is a meeting of a work group 

of the Advisory Board. This work group is 

focused on the Nevada Test Site site profile. 

It’s ably chaired by Robert Presley. Members 

are Munn, Clawson and Roessler. They are all 

here with us in the room. 

First, I’ll ask if there are any other 

Board members on the call by telephone. Any 

other Board members? 

 (no response) 

 DR. WADE: Clearly, we don’t have a quorum 

of the Board, and that’s a good thing. So we 

can do our business. 

What I’d like to do is our usual sort 

of marathon introductions. We’ll start by 
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going around the table here, and then I’ll ask 

for on the phone other members of the 

NIOSH/ORAU team, other members of the SC&A 

team, other federal employees who are on the 

call by virtue of their employment, members of 

Congress, their staff, workers, worker reps, 

and then anyone who would like to be 

identified. 

When we do our introductions, 

particularly for Board members, for NIOSH/ORAU 

and for SC&A, please identify if you have any 

conflicts relative to the topic today, and 

that’s the Nevada Test Site. Then we’ll 

conclude the introductory comments with some 

discussion of phone etiquette although we’re 

getting better. We had two meetings 

yesterday, and they were relatively background 

noise free. 

So this is Lew Wade. Again, I work 

for NIOSH and serve the Advisory Board. 

MR. ELLIOTT: Larry Elliott, I work for 

NIOSH, and I have no conflicts. 

DR. ROESSLER: Gen Roessler, Board member, 

no conflicts. 

DR. MAURO: John Mauro, SC&A, no conflicts. 
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MR. ROLFES: Mark Rolfes, NIOSH health 

physicist, no conflicts. 

MS. MUNN: Wanda Munn, Board member, no 

conflict. 

DR. BEHLING: Hans Behling, SC&A, no 

conflicts. 

DR. MAKHIJANI: Arjun Makhijani, SC&A, no 

conflict. 

MS. HOWELL: Emily Howell, HHS, no conflict. 

DR. NETON: Jim Neton, NIOSH, no conflicts. 

 MR. PRESLEY: Robert Presley, Board member, 

no conflicts. 

 MR. CLAWSON: Brad Clawson, Board member, no 

conflicts. 

 DR. WADE: Okay, let’s go out to telephone 

land and look for other members of the 

NIOSH/ORAU team. 

MR. ROLLINS (by Telephone): This is Gene 

Rollins, O-R-A-U team, no conflict. 

MS. SMITH (by Telephone): Cheryl Smith, OR-A-U team, no conflicts. 

 DR. WADE: Other members of the NIOSH/ORAU 

team? 

 (no response) 

 DR. WADE: Other members of the SC&A team? 
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 (no response) 

 DR. WADE: Other members of the SC&A team? 

 (no response) 

 DR. WADE: Other federal employees who are 

on the line by virtue of their employment? 

MR. KOTSCH (by Telephone): Jeff Kotsch, 

Department of Labor. 

 DR. WADE: Welcome, Jeff. 

MS. CHANG (by Telephone): Chia-Chia Chang, 

NIOSH. 

 DR. WADE: Okay, Chia-Chia, we spoke to you 

earlier. 

Any other federal employees? 

 (no response) 

 DR. WADE: Members of Congress, their staff, 

workers, worker reps? 

MR. McDONOUGH (by Telephone): Alex 

McDonough, office of Senator Harry Reid. 

 DR. WADE: Welcome, sir. 

Members of Congress, staff, worker, 

worker reps? 

 (no response) 

 DR. WADE: Anyone else who would like to be 

identified for the record? 

 (no response) 
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 MR. PRESLEY: Could we go back and get the 

person for Congressman Reid’s office to 

identify, please? 

 DR. WADE: Our court reporter had trouble 

picking up your name, sir. 

MR. McDONOUGH (by Telephone): Alex 

McDonough, office of Senator Harry Reid. 

 DR. WADE: Thank you for joining us. We 

appreciate your time. 

Okay, again, relative to phone 

etiquette, please, if you’re not speaking, put 

the phone on mute, put your equipment on mute. 

If you are speaking, speak into a handset as 

opposed to using a speaker phone. Be mindful 

of background noises. And sometimes if you 

put people on hold, there’s elevator music 

that plays, and sometimes we get to hear that. 

Just again, a bit of thought about it and this 

will be a productive vehicle for the work 

group to be able to use. 

With that, Robert, it’s up to you. 

INTRODUCTION BY CHAIR

 MR. PRESLEY: If it’s all right with 

everybody, what I would like to do is have a 

copy, and everybody should have it on their 
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computer, of the NIOSH’s response to SC&A’s 

issues for five, six, seven and 23. What I 

would like to do is for us to spend the 

majority of our time going through this and 

saying yea or nay on what we approve or 

disapprove. And then after we get this done, 

go back and start with issue one in the 

comments and go back through the matrix and 

try to iron out any problems that we have with 

any ongoing problems. Is that all right? 

DR. MAKHIJANI: Just a clarification, we’re 

not starting with the matrix? 

 MR. PRESLEY: If y’all want to start with 

the matrix we can. 

DR. MAKHIJANI: No, no, no, I just wanted to 

know what we’re starting with. 

 MR. PRESLEY: I just wonder about going 

ahead and spending, if you want to start with 

one, I have no problem with that. 

DR. MAKHIJANI: Oh, you’re starting with 

certain matrix numbers. 

 MR. PRESLEY: Yeah, what I would like to do 

is start with five, six, seven and 23, and 

let’s go through this first and take care of 

it. 
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MR. ROLFES: Just for clarification I just 

wanted to make sure that everyone had received 

those two separate e-mails that I sent out. 

One contained the matrix, and the second 

contained a white paper discussing comments --

DR. NETON: It’s the one that came out over 

the weekend, right, Mark? 

MR. ROLFES: Yeah. 

 DR. WADE: Does anybody need a hard copy? 

 MR. PRESLEY: The matrix we want to use is 

the one that’s got a note at the top that says 

Notes from 3-21-07. Is that correct? 

MR. ROLFES: Yes, I believe so. 

 MR. PRESLEY: Mark, do you want to kick us 

off and have a, since it’s you all’s comments. 

ENVIRONMENTAL INTAKES AT NTS 

MR. ROLFES: Well, a lot of the issues that 

we’re trying to address are the issues of 

environmental intakes at Nevada Test Site. 

And we’ve gone back and forth. We realized 

our initial model had some gaps in it and some 

shortcomings. And so we were in the process 

of updating our Technical Basis Document to 

address those gaps. And also at the same time 

we were receiving comments from SC&A and the 
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Advisory Board members. 

So in order to address those gaps we 

began with a new model, a mass-loading model. 

And also concurrently we had received some 

comments from Dr. Lynn Anspaugh, pointing out 

additional shortcomings. So I believe Gene 

Rollins is on the telephone. 

MR. ROLLINS (by Telephone): Yes, I’m here, 

Mark. 

MR. ROLFES: Okay Gene, would you like to go 

through what you have done to address some of 

the issues with the environmental intakes at 

Nevada Test Site? 

MR. ROLLINS (by Telephone): At SC&A’s 

request we went back and evaluated using a 

mass-loading model, using actual dust-loading 

factors experienced in the Yucca Mountain NTS 

environment. And when those factors were 

applied, the maximum intakes increased 

significantly not unexpectedly. And we went 

back and I have adjusted the numbers for 

maximum intakes in the TBD. 

And in addition, I have revised the 

TBD to provide instructions to dose 

reconstructors about how these maximum intakes 
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should be applied. I hope everybody has had 

an opportunity to read the attachment because 

there’s some very important words towards the 

end about how these intakes should be applied. 

Simply put these intakes are really 

only going to be important in terms of 

probability of causation for a small number of 

organs. And that would be mostly respiratory, 

liver and bone surfaces. So what I have 

proposed to do, even though these numbers can 

get, these intakes can get fairly high doses 

to these particular organs, what I propose to 

do is we will apply the maximum intakes to all 

cancers across the board, and then we will 

determine whether or not those intakes are 

affecting compensability. 

And if those intakes are affecting 

compensability, then the dose reconstructor 

will have to, as you will, sharpen his pencil 

and to try to figure out whether they are 

reasonable or not. And there are a number of 

circumstances that are outlined in the 

verbiage that I’ve added to the TBD that will 

allow the dose reconstructor some discretion 

as to how these intakes are applied. 
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But I guess what we need to decide 

among us today is whether or not these maximum 

intakes as calculated by the mass-loading 

model are indeed bounding and whether 

additional adjustments need to be made. And 

so I guess I would like to open up what I’ve 

done to discussion to see what type, what your 

feelings are about how we’re applying them 

now. 

I have provided some tables in the 

back, about page six that give you an idea of 

the magnitude of the doses. These numbers --

you’ve seen these before by the way. They’ve 

been adjusted slightly. But these are 30-year 

organ doses resulting from ten years of intake 

at the maximum intakes that have now been 

adjusted as shown in Table 1 which is on page 

five of the white paper. 

And you can see, the first column 

there on Table 1, those were the maximum 

intakes that were in the original Rev. 0 of 

the TBD. And then the next column over is the 

maximum using the mass-loading model including 

Area 30 which I have given several reasons in 

this paper as to why we don’t think it’s 
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appropriate to use Area 30. So the third 

column there are the annual maximum annual 

intakes without Area 30 included in the 

weighting. 

Now, I’d like to point out that 

there’s some text in this white paper, I 

didn’t have a chance to go through it real 

thoroughly, but on the second page under 

Response 5, the first paragraph, there’s some 

discussion there about the use of average 

intakes. And that will have to be removed. 

That should not have been in this white paper. 

I thought I’d gotten it out, but it somehow 

crept back into this paper. 

DR. MAKHIJANI: How does the paragraph 

start? 

MR. ROLLINS (by Telephone): The paragraph 

starts Response 5 in bold on page two, and you 

can just, if you would, please, --

DR. ROESSLER: Gene, you’re going awfully 

fast. Are we on the just one document now? 

MR. ROLLINS (by Telephone): Correct. 

DR. ROESSLER: Okay, and I found Table 1, 

and I found Table 2. Now where are you? 

MS. MUNN: Now he’s gone back to page two. 
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DR. ROESSLER: Page two. 

MS. MUNN: Response 5. 

MR. ROLLINS (by Telephone): Okay, I’m 

sorry. 

DR. ROESSLER: Response 5, is that correct? 

MR. ROLLINS (by Telephone): Yes, the last 

two sentences of that first paragraph should 

be deleted. We’re not going to be dealing 

with average intakes anymore. 

DR. MAKHIJANI: So from, “It should be noted 

that average values ...” 

MR. ROLLINS (by Telephone): Correct, just 

delete that to the end of the paragraph. 

Although what I’ve said here is really still 

true because the average intakes because 

they’re much smaller, they really don’t impact 

compensability at all and so we don’t have to 

consider them. That’s why I’m going to 

simplify the TBD, and we’re not going to be 

discussing the application of average intakes. 

 MR. PRESLEY: Gene, Bob Presley, you’re 

taking out the last three sentences in that 

first paragraph. Is that correct? Where it 

says, “However, average intakes...”? 

MR. ROLLINS (by Telephone): That’s correct. 
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DR. ROESSLER: That’s three sentences or 

lines? 

 MR. PRESLEY: That’s three lines. I’m 

sorry. 

DR. ROESSLER: I think it’s actually, and 

get the sentence before that, too, Bob, where 

it starts, “It should be noted...” 

 MR. PRESLEY: Oh, okay, I’m sorry. I got 

it. 

MR. ROLLINS (by Telephone): Just get all of 

that out of there because that’s really not 

important to the discussion anymore. 

 MR. PRESLEY: Thank you. 

DR. ROESSLER: Gene, this is Gen Roessler. 

I’m getting up to speed here. You mentioned 

Area 30, and I lost, I didn’t catch why Area 

30 is not included. 

MR. ROLLINS (by Telephone): Area 30 is a 

very remote area of the site where they did 

the PLOWSHARE, some of the PLOWSHARE projects 

like basically digging trenches. It’s a 

relatively small area, inaccessible and 

typically not inhabited by anybody. It’s 

where a lot of the soil contamination still 

resides because of the nature of the tests 
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that were done there. 

DR. MAKHIJANI: I had a question about that, 

Gene. Are there job cards similar to Rocky 

Flats at NTS that would allow you to determine 

like who went out there to do the digging and 

so on as opposed to who did not? I haven’t 

noticed such job cards, but then I haven’t 

gone through every DOE file in the claimant 

files so I don’t know. 

MR. ROLLINS (by Telephone): My 

understanding is, and my experience in looking 

over some of the records and doing the actual 

dose reconstructions, people that were allowed 

or approved to go into these areas of high 

contamination, they would have gone in on a 

radiation work permit, and they would have 

entry cards issued by Nevada Operations. 

DR. MAKHIJANI: And that would be in their 

DOE record that you would get when NIOSH 

requested the DOE record, that entry permit? 

MR. ROLLINS (by Telephone): Yes. 

 MR. PRESLEY: Gene, this is Bob Presley 

again. Plus there ought to be dates where 

they kept that area closed down. You know, 

that was one of the areas where you just did 
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not go in unless you had a valid reason to. 

Do you agree? 

MR. ROLLINS (by Telephone): Yes, I do 

agree. 

DR. MAKHIJANI: And was there typically like 

bioassay done after people went there or 

that’s the thing, I mean --

MR. ROLLINS (by Telephone): I can’t respond 

what their, I don’t know exactly what their 

criteria was for bioassaying the people coming 

in and out of areas of known contamination. I 

can research that and get back to you, but I 

don’t know exactly what that criteria would 

be. 

DR. MAKHIJANI: Because, I mean, if we’re 

excluding Area 30, the implicit assumption is 

that whoever went in there was appropriately 

monitored so it’d be in the record. So you 

don’t need to pay special attention to that 

area in terms of the (unintelligible) dose. 

So it would be good to see, I think it would 

be good to just verify in a couple of examples 

that that’s actually the case unless there’s 

documentation otherwise or some procedure or 

something like that. 
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 MR. PRESLEY: Gene, this is Bob Presley. 

Have you run up on any documentation on that 

that shows when that area might have been 

opened for entry and when it may have been 

closed for entry? 

MR. ROLLINS (by Telephone): No, not 

personally, but I’m sure it exists. 

 MR. PRESLEY: Yeah, because I have never 

been up there, but if my memory serves me 

correctly, you had to come up with all kinds 

of special permission and a real need to even 

begin to get close to that place. 

MR. ROLLINS (by Telephone): That’s my 

understanding, also, Bob. 

DR. MAURO: Gene, this is John Mauro. I’ve 

got a couple of questions that go into the 

actual resuspension model and the assumptions. 

And I do have a document in front of me called 

Attachment B, Mass-Loading Model. I assume 

that’s the correct document to be working 

from. 

MR. ROLLINS (by Telephone): Right. 

DR. MAURO: And first of all I think that 

this is the strategy in my opinion that is the 

most relevant, that is, a dust loading as 
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opposed to a resuspension model for the older 

radionuclides. Then in going into the key 

parameters I sort of circled three. And the 

first one is I see you’ve adopted -- and 

correct me if I’m wrong -- a default value of 

a dust-loading five milligrams per cubic meter 

as being, that’s the assumed dust 

concentration. 

MR. ROLLINS (by Telephone): Where are you, 

John? 

DR. MAURO: I’m on the first -- see, I may 

not have -- I’m on a document called Appendix 

B, by Rollins, and the very first page has the 

equation in the middle of the page and then 

the definition of each of the terms. 

MR. ROLLINS (by Telephone): You can also 

find this in Attachment 1 to the white paper. 

It’s on page 12. 

DR. MAKHIJANI: Oh, so that’s the same as 

Attachment B that --

MR. ROLLINS (by Telephone): Same as 

Attachment B, correct. 

DR. MAURO: Now, I just want to confirm, so 

your dust loading is five milligrams per cubic 

meter. For anyone where you applied this 
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model, I understand that there were only 

certain circumstances and people under which 

you would apply the model, but when it is 

being applied, it’s assumed that for whatever 

time period the person’s out there in the 

field doing his job, you’re going to assume 

that during that time period he’s chronically 

exposed to five milligrams per cubic meter of 

dust loading? 

MR. ROLLINS (by Telephone): That’s the 

starting point. It’s been pointed out to me 

that that might be a little on the high side, 

but I --

DR. MAURO: I agree. 

MR. ROLLINS (by Telephone): -- that was for 

what was termed an active environment. 

DR. MAURO: Yes, and I would agree certainly 

there will be time periods when it could go 

higher, but not for a protracted time period. 

So I mean, my first reaction just for the 

benefit is -- And in reading this over the 

weekend getting ready for the meeting, my 

first reaction was that’s a good number. 

 MR. PRESLEY: Claimant favorable. 

DR. MAURO: Yeah, a claimant favorable 
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number. Here I’m showing some of my 

ignorance. A relaxation length, one 

relaxation length is E to the minus 1? Right? 

And that number is what, 2.7? In other words 

I’m trying to get to the depth of -- So in 

other words --

DR. MAKHIJANI: One over two lengths. 

DR. MAURO: One over two, so therefore, 

you’re saying -- let me see -- the average 

activity, in other words, you’re starting with 

Becquerels per meter squared from an aerial 

survey or some other data, and you’re now 

going to convert that to Becquerels per gram. 

You have to get that conversion. 

So what you’re saying is all those, 

there is actually an exponentially declining 

concentration vertically in the soil with a 

relaxation length of 2.3 centimeters. Just to 

help me out a little, that puts what 

percentage of that total activity, that 

Becquerels per meter squared, in what depth? 

Could you help me out with that? I just want 

a feeling whether or not you’re putting the 

activity --

MR. ROLLINS (by Telephone): I believe, 
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John, it puts most of it in the first three 

centimeters. 

DR. MAURO: Good, that’s what I thought. I 

just wanted to, by the way, when I say good, 

I’m giving you my own reaction. And certainly 

other folks may not necessarily agree. 

DR. MAKHIJANI: Yeah, it’d be about 70 

percent, I think the first three things, maybe 

75. 

DR. MAURO: Especially if it’s aged, 

somewhat aged. In my opinion, my familiarity 

with the subject, that’s a good conservative 

assumption. 

Now, the only place -- and then I’ll 

step back after this -- in looking at the 

models I noticed that you have all these 

different areas. You have sort of broken up 

the whole site into 30 areas, each having its 

own radionuclide concentration distribution. 

But later on you had mentioned that you’re 

assuming that you’re going to actually apply 

this resuspension model to the activity 

averaged over a 500 square mile area. Is that 

correct? 

In other words the area, in other 
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words the person that’s being exposed, that is 

out there, you’re not going to say, well, he 

was in Area number, you know, number eight, 

for so many hours. You’re basically saying 

that, no, we’re going to assume that whatever 

he experiences is averaged over a 500 square 

mile area. I’m getting that out of page five 

of the Appendix B that the heading of the 

paragraph is Spatial Variations in 

Radionuclide Soil Concentrations. And I have 

to say that 500 square miles, as I understand 

the write up, is quite a large area to average 

over, and it may not --

MR. ROLLINS (by Telephone): Actually, John, 

these maximum intakes that are provided in 

Table -- what is it? Table 1 there or Table 

4.2.2-3 of the Rev. 1 TBD, those are actually 

maximum for any area. 

DR. MAURO: Okay. 

MR. ROLLINS (by Telephone): So it’s not 

really even averaged. 

DR. MAURO: Okay, so what is this 500 square 

mile? I’ll read the sentence. “Currently, 

the area used in developing the concentrations 

represent approximately one-third of the site 
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or 500 square miles.” I guess I misread that. 

MR. ROLLINS (by Telephone): Well, I 

probably wrote it poorly which is why you were 

confused. 

DR. MAURO: So you actually did work with 

the smaller areas? 

MR. ROLLINS (by Telephone): That’s correct. 

DR. MAURO: Excellent. Okay, I have no more 

comments. 

MS. MUNN: I understood, the way that the 

table was laid out, I understood we were 

having an opportunity to look at those 

dispersions including Area 30 which is highly 

improbable. I doubt that there’s more than a 

dozen people that would be involved in that, 

and without Area 30 which is the more logical 

one. I had interpreted that as being the 

reason we were making that, unless you can 

identify that the individual was, in fact, in 

Area 30, then Area 30 really should not apply. 

Am I reading that correct, Mark? 

MR. ROLFES: Correct, yes. 

MR. ROLLINS (by Telephone): Maybe it will 

help you a little bit if you start reading the 

reasons that I have provided for why we 
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believe it’s claimant favorable. And number 

one basically says the 39.3 Becquerels per 

year, which is the maximum intake that we will 

be applying, was calculated using the massloading model only for Area 8 which happens to 

be the area of highest soil contamination. So 

when we give that individual 39.3 Becquerels 

in a year what we’re basically assuming is 

that he was out there in Area 8 2,600 hours 

for the year. 

DR. MAKHIJANI: Highest for what 

radionuclide, Gene? 

MR. ROLLINS (by Telephone): Well, in this 

particular case it was Plutonium-239. 

DR. MAKHIJANI: Now what, is there a time 

cutoff closer than what you don’t apply this? 

That is, you’re applying the mass-loading long 

after deposition is there. I forgot whether 

you defined that long or is this the model to 

be applied whenever people go in? 

MR. ROLLINS (by Telephone): This is, we’re 

basically going to apply this. And you 

remember the original resuspension basically 

leveled out after about two years. 

DR. MAKHIJANI: Right. 
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MR. ROLLINS (by Telephone): And that’s when 

it was pointed out to me that it would be 

appropriate to move to a mass-loading model. 

As it turns out, the way that I have applied 

this mass-loading model, it will, in my 

opinion, you could look at it or we could talk 

about it, but my mass-loading model the way 

it’s designed right now will continue to 

overestimate potential intakes even for 

periods less than two years. 

Is that what you’re asking? 

DR. MAKHIJANI: Yeah, that is what I’m 

asking, and the reason I’m asking that is not 

because of the mass-loading factor there in 

your equation, but because of the radionuclide 

list. I think Dr. Anspaugh pointed out when 

you get close to the time of the tests, you 

have to worry about the short-lived 

radionuclide. 

MR. ROLLINS (by Telephone): I would like to 

make an observation on that. As you can 

imagine, those calculations can become quite 

complex when you get into short times after 

time zero. Even Dr. Anspaugh and others have 

agreed that dose from fission and activation 
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products is bounded by external exposure. And 

so it’s my belief that anybody that was near 

these areas, especially after 1957, would have 

had external dosimetry; and therefore, they 

would have measured this exposure to the 

fission and activation products. 

DR. MAKHIJANI: I don’t know that I agree 

that, I mean, the whole problem in that 

initial period as I read it is that that was 

the assumption then. That is, the external 

exposure’s the main thing. And then when we 

went back to try to look at that assumption, 

it turned out that in many cases it wasn’t 

right, but internal exposure potential was 

important which is why we have to go through 

all this stuff. And so that’s the question 

that I’m raising. 

DR. ROESSLER: From the very short-lived 

things? Isn’t that what you’re talking about 

now? 

DR. MAKHIJANI: Maybe not, maybe not from 

the short-lived. 

DR. ROESSLER: Yeah, I think that was the 

point here. 

 MR. PRESLEY: I don’t know how you’re going 
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to get an ingestion on those short-lived 

things because, I mean, there was very few 

people around the thing, and there was, at 

that time there was nothing in the air or 

ingestion or anything like that to get. It 

would have to be an external exposure. 

DR. MAURO: By way of orientation for me 

now, my understanding was this model is being, 

was developed and is going to be used, for 

post-’62 time period. 

MR. ROLLINS (by Telephone): That’s correct. 

That’s correct. 

DR. MAKHIJANI: So actually this is --

DR. MAURO: So in other words, what we’re 

saying is all the tests have been completed so 

therefore, what we really have here is 

residual radioactivity on the ground from 

previous tests. And we’re making an 

assumption that by and large it’s aged to the 

degree that it has commingled to some degree 

with the soil. As a result, a dust-loading 

model makes sense. Certainly, if it was 

during the test period where you have fresh 

fallout then one could question whether you 

would use dust-loading. 
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DR. MAKHIJANI: No, I agree. It’s the postatmosphere. 

DR. MAURO: For pre that’s a different 

problem. 

DR. MAKHIJANI: And I think that caveat just 

has to be up front or I woke up too early or 

something. 

 MR. CLAWSON: This is Brad Clawson. I have 

a question here. It says, “therefore this 

intake does not apply to miners or tunnel 

workers”. I guess my question is when we were 

in Nevada, we heard many people discuss their 

question of their classification because they 

were actually a mechanic out of the central 

facility out there that if they needed a 

mechanic or whatever, he would go up to the 

tunnels, work on that, but he worked 

throughout the whole test site. 

And is there a very distinguishing 

between the miners and the tunnel workers as 

far as this overall workforce that they had. 

I understand why you feel the miners and the 

tunnel workers wouldn’t be there, but I think 

they kind of had a commingling of people that 

went in and out of there. 
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MR. ROLLINS (by Telephone): My experience 

in looking over the records with the entry 

logs it’s fairly easy to tell those that were 

working underground and those that were not. 

 MR. CLAWSON: Okay. 

DR. MAKHIJANI: John, has Lynn looked at 

this, Lynn Anspaugh? 

DR. MAURO: No, I don’t recall him 

specifically. 

DR. MAKHIJANI: I don’t think he’s had a 

chance to come. Have you all sent it to Dr. 

Anspaugh? 

MR. ROLFES: We’ve sent it out probably 

about four times and didn’t get any comments 

on it. 

DR. MAKHIJANI: I guess we have to call him. 

DR. MAURO: Well, I’ll give him a call. I’d 

like to hear what he has to say, but as I 

said, my reaction was just fundamentally 

exactly what I sort of had in mind when I made 

the comment originally. 

DR. MAKHIJANI: Right, because basically, 

this is your comment that --

DR. MAURO: That was my comment from the 

beginning. 
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DR. MAKHIJANI: It would be good to have, 

since a lot of this started, since a lot of 

this started with Dr. Anspaugh’s paper, and 

the interpretation of the paper I think would 

kind of close that circle. It would be good 

to have his comments so maybe I can --

DR. MAURO: I’ll take care of it. 

MS. MUNN: You’ve seen it. Please say 

something. 

 MR. PRESLEY: Go ahead. I’m sorry. 

DR. MAKHIJANI: No, Mr. Presley, I was just 

telling John that since a lot of the, this 

questioning of the resuspension model started 

with the interpretation of Dr. Anspaugh’s 

paper, that it would be good to close the loop 

on this to get a response from him about this. 

Because if you’ll remember, in our review of 

the site profile we had a different 

interpretation of Dr. Anspaugh’s paper than 

what NIOSH had. And so we asked Dr. Anspaugh 

to comment on it, and he had some criticisms. 

And so this came out of that. So I thought it 

would be good if we got some kind of answer 

from him, if you agree. 

MS. MUNN: So whose action is that? 
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DR. MAURO: Mine, point of clarification 

though, originally the model was a 

resuspension-factor model where resuspension 

factor as low as ten to the minus nine per 

meter was one of the parameters. And so our 

reaction was that’s awful low, and perhaps, 

especially if we’re talking about age, this 

sort of sets the perspective for age fallout. 

You wouldn’t use a resus -- So but at that 

point we said let’s talk to Lynn and see what 

he thinks, and that’s when we brought him in. 

So what really started out was how do 

you best use his resuspension-factor model for 

this kind of situation. And the answer was, 

well, you really don’t use it. You use the 

dust-loading model. So I think that, I mean, 

I won’t speak for him, of course, but I think 

that the very fact that that we converted to a 

dust-loading model is going to be a very 

favorable. 

Now, of course, he may have some 

commentary on the five milligrams. He may 

have some commentary on the vertical profile 

depth. I don’t know. I gave you my response. 

I suspect that he’ll have an opinion on that 
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and also interesting because he knows the site 

so well, his perspective on the data that was 

used to characterize different contamination 

areas, the different Areas 1 through 30, and 

whether or not, yeah, that’s probably good 

numbers. 

And so, yeah, it’d be great to have 

him. I will take it as an action item to 

forward this on to him and just ask him if he 

had, because I don’t think it’d take very much 

time for him to read it and give us his 

impressions if that’s okay. 

DR. ROESSLER: It looks to me like the 

numbers you’re looking at in that model were 

taken from his paper. 

DR. MAURO: Oh, is that right? 

DR. ROESSLER: The reference is right above 

there, and I’m assuming those were Lynn’s 

numbers. 

MR. ROLFES: Yeah, we referenced quite a few 

of his documents. 

 MR. PRESLEY: I won’t speak for the whole 

working board. I have no problem with this, 

but I would like to have his comments back 

ASAP to the Board and to Mark. So if there’s 
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anything that we need to work with and change 

and we can do this. What say you, Board? 

MS. MUNN: If we need to talk about this 

particular point again, I’d like for us to be 

able to do it at least on a conference call 

before our next meeting. 

 MR. PRESLEY: Right, because I mean, this is 

something right here that’s about as claimant 

favorable as you can possibly get. 

MS. MUNN: Yeah, that’s as far over backward 

as you can go without turning back flips. 

MR. ROLLINS (by Telephone): This is Gene 

Rollins. I would encourage everyone to read 

the reasons provided for why we believe the 

model to be claimant favorable. I think I’ve 

numbered them there, one, two, three, four, 

five. 

DR. MAKHIJANI: What page are you on? 

MR. ROLLINS (by Telephone): Any part of 

those discussions that you don’t understand or 

I haven’t explained adequately, please get 

back with us and give us a chance to explain 

it better. 

DR. ROESSLER: This is page two of the massloading --
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 MR. PRESLEY: Yeah, about halfway down where 

it starts. 

DR. ROESSLER: “NIOSH believes this guidance 

to be claimant favorable for several reasons:” 

DR. NETON: Gene, this is Jim Neton. Now, 

you did say earlier though that this would be 

applied as a worst case analysis for a 

claimant unless he’s gotten in the position 

where there was, there needed to be a better 

estimate, right? 

MR. ROLLINS (by Telephone): That’s correct. 

DR. NETON: And is that guidance in here 

somewhere? 

MR. ROLLINS (by Telephone): If you go back 

to the attachments where I’ve actually 

inserted, the attachment is actually the 

proposed revision to Section 4.2.2 of the 

Technical Basis Document. 

DR. NETON: That’s Attachment 1 to this 

white paper that came out over the weekend, 

correct? 

MR. ROLLINS (by Telephone): Correct. And 

if you go back, the discussions and the advice 

and the directions to the dose reconstructors 

starts on about 14 and gets into the meat of 
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the situation about page 15. 

DR. NETON: I think that’s important for 

people to look at because, again, this model 

is very claimant favorable and is not 

necessarily going to be applied to all 

claimants. So I think a good look at the 

rationale in Attachment 1 would be appropriate 

as well. 

DR. MAKHIJANI: Would you clarify that, Jim, 

that this would be applied only in the socalled worst case denial or also for 

compensability? 

DR. NETON: No, I believe what Gene said was 

this would be a worst case analysis for 

denials. 

MR. ROLLINS (by Telephone): And in cases 

where it affects compensability which will be 

for the organs of the respiratory tract and 

possibly liver and possibly bone surfaces, the 

instructions allow dose reconstructors 

discretion as to how these intakes are to be 

applied. 

DR. NETON: Could be applied, but there’s 

some discretion there. 

DR. BEHLING: Could I ask a quick question 
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regarding Table 2, the particular tissues? 

What is LN? Is that lymph node? 

MR. ROLFES: Yes. 

DR. MAKHIJANI: So in principle a dose 

reconstructor could look at a claim and apply 

this 39 Becquerel intake, and if you get over 

50 percent, the person could be compensated? 

DR. NETON: In principle they could, but I 

guess, I haven’t read through this attachment 

yet, but I’m assuming that there are factors 

that come into play like 2,600 work hours and 

the area and that sort of thing. 

DR. MAURO: Yeah, Gene, this is John Mauro 

again. It sounds to me that when you use the 

worst-case assumptions, for example, regarding 

where he was located, duration of exposure, 

the five milligrams per cubic meter, you’re 

placing what I would call a plausible upper 

bound. I wasn’t quite sure whether you’re 

going to be using this exclusively for denials 

or possibly use it for a compensation also. 

And that’s what you mean by leaving it up to 

the discretion of the dose reconstructor? 

I see there was some language in here 

whereby there was judgment by the dose 
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reconstructor on how he will apply this. It 

will be up to him. And I guess at that point 

it’s really on a case-by-case basis then. And 

I wasn’t quite sure of how much leeway, you 

know, how that would be done if, in fact, he 

decides to do something different than what’s 

in Appendix B. 

MR. ROLLINS (by Telephone): John, the only 

situation that I could envision where these 

intakes would be applied in a compensable case 

would be one that the job description would 

indicate that the individual spent a majority 

of the time outdoors and either he was in Area 

8 the entire time or we don’t know where he 

was. I don’t think those situations are going 

to present themselves very often, but they 

could. 

DR. MAKHIJANI: At least that clarifies it. 

MS. MUNN: And thank you for that language 

on page 14. Until I got to that part I was 

particularly concerned about how these 

extraordinarily over-favorable numbers were 

going to be applied. So thank you for that. 

MR. ROLLINS (by Telephone): What this will 

allow us to do is to efficiently process a 
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large number of claims as far as these 

environmental intakes are concerned. 

MS. MUNN: That’s good. 

DR. MAKHIJANI: I had one other question. 

You have under Table 1, I guess that’s 4-point 

-- I’ve got two different documents open, and 

you see under the assumption that 50th 

percentile expected intakes are those in 

Tables 2 and 3, the 95th percentile value would 

be (unintelligible) by a factor of plus or 

minus ten. And I just wondered where that 

plus or minus ten came from. 

MR. ROLLINS (by Telephone): There really is 

not much technical basis in that. It was just 

professional judgment, but in fact, the way 

these intakes are currently being applied 

since they are bounding --

DR. MAKHIJANI: It’s on page 12. 

MR. ROLLINS (by Telephone): I understand 

what you’re asking, but the way these intakes 

are typically being applied now is because 

they are bounding upper, they are upper 

bounds. They are being applied as constants. 

So the geometric standard deviation doesn’t 

come into play. 
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DR. MAKHIJANI: So which is the upper bound? 

Is it the 95th percentile and you already 

multiplied by ten or is it the 50th percentile 

that’s the upper bound? I’m a little confused 

here. 

MR. ROLLINS (by Telephone): There has not 

been a statistical evaluation performed on 

this data. If you’re looking for the 

variability in the data, that has not been 

done. 

DR. MAKHIJANI: Yeah, I kind of gathered 

that, you know, from reading this that there 

wasn’t, that this was a kind of a judgment 

number. 

MR. ROLLINS (by Telephone): It is. 

DR. MAKHIJANI: But we’ve got to have 

something that underpins the judgment, and now 

I don’t know whether the numbers that we’re 

talking about in intakes are your 50th 

percentiles, which are those in Tables 4.2.2-2 

and dash-3, and the 95th percentile values so 

upper 95th percentile would be ten times that. 

So you’re not proposing to use that 95th 

percentile --

MR. ROLLINS (by Telephone): I would not 
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characterize those intakes the way you’re 

trying to characterize them. 

DR. MAKHIJANI: I’m just reading from here 

so I’m just, I guess, not understanding that 

sentence. 

DR. ROESSLER: But you’re jumping from a 

table in Appendix B back to a table in, of the 

document I think. 

DR. MAKHIJANI: No, I am in that document on 

page 12. 

MR. ROLLINS (by Telephone): I am probably 

going to have to rework that sentence because 

I don’t think that’s appropriate to have that, 

the way that I have presented this data, it’s 

not an average. It’s not a mean. It’s not 50 

percentile. It’s actually, what I’m 

presenting here are maximums. And average, 

those really aren’t true averages because they 

aren’t even weighted averages. So I need to 

go back and look over that language again 

because I don’t think it’s correct, and I’m 

glad you pointed that out to me. 

DR. MAKHIJANI: Where is equation 4-1? 

Because you say you’re going to calculate your 

GSD from that so I’m just trying to find it 
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MR. ROLLINS (by Telephone): That’s in the 

early part. That’s a pretty standard 

equation. That’s in the early part of the 

TBD. 

DR. MAKHIJANI: Oh, 4-1 in the TBD. 

MR. ROLLINS (by Telephone): Right. See, 

what you’re reading is actually an insert 

that’s going into the TBD. 

DR. MAURO: Gene, this is John Mauro again. 

I have a quick observation. I’m just looking 

at the combination of assumptions. The way I 

look at it is you pick the dust loading, which 

right off the bat, which is a chronic five 

milligrams per cubic meter, you’ve already 

capped it off. From then on all the other 

parameters that you might want to use, such as 

Becquerels per square meter, probably should 

be your best estimates because you don’t want 

to have an upper bound, you don’t want to use 

an upper -- in other words, a five milli --

basically, I’m backing off in terms of the 

degree of conservatism. I’m saying that if I 

understand the model correctly, you have come 

up with a deterministic model which places a 
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plausible upper bound for screening purposes. 

Because by adopting five milligrams, you’ve 

capped it. Then after that if you’re going to 

say, well, what do I use for my Becquerels per 

meter squared, it seems to me in keeping with 

the philosophy that has been embraced by NIOSH 

and we’ve agreed with, is you don’t pick, if 

you have four or five parameters that go into 

your equation, you don’t pick the upper 95th 

percentile for each one of those. You may 

pick one and say we’re going to go with a 

bounding one such as the five milligram, and 

then the others we’re going to try to be 

realistic. And that brings you to a place 

where you want to be. You want to be at the 

upper end of the distribution and use that as 

a constant. So I guess I’m not quite sure 

where the uncertainty comes in in this 

analysis. What I’m hearing is that you will 

be applying some kind of distributions when 

you use your input to do these dose 

calculations, and I guess, I don’t see where 

it would be. You know, where would the 

uncertainty be? 

DR. MAKHIJANI: This whole thing confuses me 
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because I looked at the site profile and 

equation 4-1 is just the ratio of the 95th 

percentile and 50th percentile which are going 

to have those numbers to use the equation. 

It’s just a standard statistical equation for 

lognormal distribution and --

DR. MAURO: Am I correct that --

DR. MAKHIJANI: -- and we don’t have the 

numbers to put into it. 

MR. ROLLINS (by Telephone): That’s correct, 

and I’m going to go back and revisit that 

language because it’s probably not 

appropriate. It’s an artifact from the other 

TB –- from the web zeros. I just need to 

update that language. 

MR. ELLIOTT: What you’re seeing here is 

Gene’s proposed draft of a revision to the 

Technical Basis Document that hasn’t even gone 

through NIOSH comment resolution yet. So --

DR. MAKHIJANI: I mean, it’s just --

MR. ELLIOTT: -- these are good things to 

talk through --

DR. MAKHIJANI: -- just going through it the 

question came up, and I didn’t see, so I 

presume it’s fair. 
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MR. ELLIOTT: Yes. 

MR. ROLLINS (by Telephone): John, I 

appreciate your input on conservatism in the 

deterministic model. And there are a number 

of areas that I’d identified, reasons one 

through five, and methods that we could use to 

reasonably reduce these intakes. I might be 

interested in having your input of those five 

identified, claimant favorable assumptions. 

And don’t answer me now. Maybe you 

can get back to us a little bit later about 

which of those do you think would be areas 

that we should consider providing additional 

guidance or additional information to the dose 

reconstructors for potentially coming up with 

a best estimate. I’d like for you to look 

through those five items that we’ve identified 

as conservatisms, and I’d like your input, 

your thoughts on where we might be able to use 

some of those to provide a best estimate. 

DR. MAURO: I appreciate that, and I will 

take up that offer. I look forward to doing 

it, working with you on that. 

DR. MAKHIJANI: My only other comment, Gene, 

is going back to the Area 30 thing. It would 
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be good to, I mean, I trust these things will 

be in the records of the workers because 

otherwise it becomes almost impossible, 

especially for places like the Test Site, for 

a survivor claimant because they have no idea 

what their family member did. And they could 

never specify what happened if their family 

member obeyed the law. 

So I think it would be good to go, I 

don’t know if there are claimants whose 

records we could look at. But if you know of 

a couple, it would be nice to see the work 

permits and the monitoring following the 

outside work. And that’s my only other 

comment. 

DR. MAURO: In a way -- this is John Mauro. 

What I’m seeing here is that you’ve built a 

method to place a plausible upper bound for 

that first cut, and in my mind it certainly is 

an upper bound. But then I also noticed that 

you are going to leave quite a bit of 

discretion to the dose reconstructor on when 

to back off from that and what data. 

So I guess the only place where, there 

are certain judgments that are going to be 
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made based on a case-by-case basis whereby 

that dose reconstructor is going to say, well, 

based on the information I have it appears 

that he was really never in Area 8. Or it 

appears that he only was out there for a 

certain amount of time. I suspect that 

certainly if you have a high level of 

confidence in those records, you could use 

those assumptions. 

But my guess is that sometimes these 

records are, you can’t have that much 

confidence, in fact, we had this conversation 

during breakfast this morning with Brad. That 

is, all I would offer is when you’re doing a 

case, and you’re really not quite sure, you 

may find yourself always regressing to the 

more conservative assumption, as simple as 

that. 

DR. NETON: Even under these very 

conservative assumptions, I’m looking at Table 

2, there are about four or five organs, as 

Gene pointed out, that are fairly high. But a 

30-year dose to the lung is only one rem. I 

mean, so even under those conditions unless 

there’s some other extraneous exposure, that’s 
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not even going to be close to 50 percent. 

Those would be down in the --

MR. ROLLINS (by Telephone): For example, in 

the case of the lung, just for your 

information, most of the workers that we’ve 

evaluated have a smoking history, and we 

typically are seeing lung doses in the range 

of 45-to-70 rem before we have a compensable 

situation. So, and that’s a good point that 

you’ve made. One rem to the lung usually is 

not going to be important. 

DR. NETON: Right, so I think that the idea 

here is, as John pointed out, is almost like a 

screening value that would be applied. And 

even under these conditions you’re not going 

to bother to look at the areas that the worker 

was in. You’re going to assume he was in Area 

8 the whole time. And almost in all of these 

situations, with the possible exception of 

some of the lymph nodes and maybe, I can’t see 

too many of these going over 50 percent even 

under these extreme conditions. 

 MR. CLAWSON: This is Brad Clawson again. 

But still we come back to one underlying 

factor and that is data reliability. And so 
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many times in a lot of the interviews and the 

people have made the comments in there that if 

you go back to their work area they say they 

only worked in this one area, where they 

worked throughout the whole site. That was 

where they were based out of. 

They’ve got a central facility there 

at NTS, and they went out throughout all of 

the site and were working all this. But when 

you look in their records, it said that was 

their normal place. I take myself, for 

example. If you were to look at my records, 

it would say C-P-P-6-6-6, but it doesn’t take 

in P-B-F-10, M-T-R-749, Three Mile Island. It 

doesn’t take into account any of those. So we 

need to be very careful when we classify this 

person, well, he couldn’t have been in this 

area because a lot of times they could have 

been. 

DR. NETON: Yeah, I agree. 

MS. MUNN: But, Brad, I think the argument 

that’s being made is those people were badged. 

It isn’t that they weren’t badged. So I think 

what’s being said here is their badge would 

have indicated any unusual exposure from 
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having been above ground more than their job 

description indicated. 

 MR. CLAWSON: Well, we’re looking at a massloading out here. Let’s take a mechanic or 

whatever like that. There’s a lot of times 

they may be out there, right, well, we need 

you to go out to this place in the area and 

take and stuff. We’re looking at massloadings of dust and everything else. I know 

the wind never blows in Nevada, but guess 

what, it, this is the point --

MS. MUNN: Which means none of this would 

ever have been covered up. It would all have 

been laying on top. 

 MR. CLAWSON: Or dug up and blown 

everywhere, too. So this is the point that 

I’m trying to get to because so many times we 

use a worker’s, well, he was only in this area 

and this is only going to affect, and I think 

that’s an assumption that we use. And I don’t 

really feel that comfortable with it because I 

know from experience of where we get around 

to. 

MS. MUNN: Well, and even I with my 

magnificent memory, could not tell you where I 
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was 50 years ago. 

DR. NETON: Right, but I think the approach 

to be taken here is these Area 8 values, 2,600 

hours, five milligrams per cubic meter, would 

be used if, almost as a default. If you 

didn’t use these values, then it has to be 

fairly well documented in the dose 

reconstruction why that was not used. And 

then presumably we’d have some pretty good 

evidence to put in there that would make that 

fact. And, of course, the claimants have the 

right to look at that and --

MR. ROLFES: In the absence of information 

for a specific claim, we would default to 

maximum intakes for that person. 

DR. BEHLING: Will this be converted into a 

workbook if it’s adopted? 

DR. NETON: I don’t know what ORAU’s plans 

are, but I would assume it might be, yes. 

Actually, it wouldn’t be that, it’d almost 

have to be at some point because these 30-year 

doses wouldn’t be applicable. We’d have to go 

back and do the annual dose by year. So 

there’d be some sort of a spreadsheet 

workbook. 
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DR. BEHLING: Yeah, that’s quite complex if 

you try to do this manually, by hand. 

DR. NETON: Oh, yeah, I don’t think the dose 

reconstructors would be doing this by hand. 

There would be a spreadsheet of some type 

adopted. 

 MR. PRESLEY: I guess the only action item 

we have on this is that Gene Rollins is going 

to re-do the resuspension model write up. And 

then John’s going to have -- I’m having a 

senior moment -- Lynn Anspaugh give us his 

comments. 

DR. MAURO: Yeah, I have two action items. 

Let me make sure I’ve got it right. One is to 

check in with Lynn, and the other is to work 

with Gene on the five reasons for why this is 

conservative and deterministic business. 

 MR. CLAWSON: Wasn’t NIOSH going to look at 

this? You guys have -- have you been able to 

look at this? 

MR. ELLIOTT: Well, what will happen, I 

think, here in this particular instance, the 

Board’s working group thoughts on this 

particular draft are going to be addressed by 

Gene, and then they’ll be put into our review 
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process. So it’s kind of an interesting 

anomaly we see here. Typically, we produce 

something and put it on the table and you 

react to it as a final. Here we have a closed 

approach in draft form. So that’s 

interesting. We’ll see how this goes. 

 MR. PRESLEY: Hopefully, we don’t muddy the 

water up. 

 DR. WADE: Yes, Brad, NIOSH is going to take 

this discussion and modify their document 

based upon what was said here. We can’t 

forget Brad’s point that, make sure if we 

don’t know where a worker was or if there’s 

some question, then we need to default to the 

maximum. 

MR. ELLIOTT: The benefit of this as I see 

it will knock out an issue here on 

environmental dose from resuspension. So if 

that gets us to the end game faster in 

producing something in final form for you to 

react to that’s all well and good. 

DR. NETON: Well, a lot of working groups 

have gone this way. I mean, Bethlehem Steel 

went on for a year where we negotiated, maybe 

that’s not the right word, but we discussed 
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internally quite a number of options, and 

until we got to the point where we were all 

comfortable with the approach, then we adopted 

it. So we kind of --

MR. ELLIOTT: I don’t think we produced 

draft section language for TBDs though. 

DR. NETON: No, this has gone a little bit 

further what is a draft. The concepts were 

there. I mean, we --

MR. ELLIOTT: We discussed the concepts, 

didn’t discuss the language. 

DR. NETON: The language was not nailed 

down. You’re right. 

 DR. WADE: Language in this case was just 

used as a mechanism to convey the thought. 

DR. MAKHIJANI: And that’s the spirit in 

which I took it anyway. We’re not nitpicking 

the grammar, word-smithing for you. 

COMMENTS 6 AND 7

 MR. PRESLEY: Mark, do you want to talk 

about Comment 6, 7? 

MR. ROLFES: Did we cover a little bit of 

those? 

 MR. PRESLEY: I think we did. 

MR. ROLFES: Our response to Comment 6 was 
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see Response 5. 

MS. MUNN: That’s good. 

 MR. PRESLEY: Did you have the same thing on 

seven? 

MR. ROLFES: Seven was referring to the 

short-lived radionuclides which would be 

primarily during the atmospheric weapons 

testing, and that has been designated as an 

SEC for the prior to 1963 time period. So we 

don’t feel that a resuspension model needs to 

account for the short-lived radionuclides 

associated with the atmospheric weapons 

testing time period. 

DR. MAKHIJANI: The comment, Mark, is about 

the early re-entry tunnel. 

MS. MUNN: Early re-entry work. 

DR. MAKHIJANI: Oh, okay, so this, this, I 

have to go to the original review. 

DR. MAURO: My understanding of -- we’re on 

seven now -- is that this deals with a time 

period prior to 1963. 

DR. MAKHIJANI: I’m just checking what our 

finding was. Sometimes from the very short 

comment there in the matrix, it’s very hard to 

figure out what all is said in the findings. 
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MS. MUNN: It’s expanded a little underneath 

that, the original comments are there. 

DR. MAKHIJANI: I’m just trying to find 

22.6. Oh, here it is. Yes, I believe Finding 

6 is about that in the review. That’s right. 

It’s the same as Finding 5. 

COMMENT 23 

MR. ROLFES: That will take us on to 23. 

SC&A’s comment was the adequacy of soil data 

for estimating resuspension doses needs to be 

evaluated, for instance, in relation to hot 

spot detection and plutonium soil data. And I 

believe we’ve alluded to this as well in 

Response 5 with our discussion of the massloading model. So using the maximum intakes 

from Nevada Test Site and excluding Area 30, 

unless that person worked specifically in Area 

30. 

DR. MAKHIJANI: Now, as I recall Lynn had 

made some comments in the site profile. We 

also made some comments about the crudeness of 

the grid for sampling. And also in the, the 

areas that were designated as not hot areas, 

but I guess you’ve taken care of that by 

focusing on Area 8. So I guess the remaining 
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comment from that in terms of 23 would be the 

variance within Area 8 and how the average 

relates to that. 

Gene, was your plus or minus ten 

related to that by any chance? 

MR. ROLLINS (by Telephone): No. 

DR. MAKHIJANI: Then how do we deal with a 

sort of inside area variability? 

MR. ROLLINS (by Telephone): I touch on that 

in those responses one through five. There’s 

going to be a certain amount of dispersion and 

averaging going on just through natural 

processes. I just don’t think it likely that 

someone would have extended exposure to hot 

spots. 

DR. MAKHIJANI: But these areas are pretty 

big. I don’t know how big Area 8 is. I don’t 

remember. Mr. Presley might remember. 

MR. ROLLINS (by Telephone): The procedures 

at the site require that areas of known high 

contamination are barricaded and usually 

fenced. And entry into those areas requires 

permits from Nevada Operations Office. And 

they know where those areas are. And so I 

just believe that we should be taking some 
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credit for dispersion and environmental 

attenuation. 

DR. MAKHIJANI: Area 6 is 36 million square 

meters. 

MR. ROLLINS (by Telephone): It’s pretty 

big. 

DR. MAURO: This is John Mauro. 

DR. MAKHIJANI: I mean Area 8, sorry. 

DR. MAURO: I can help out a little bit 

here. I remember originally the reason for 

this comment was I believe you were averaging 

over the whole site. In other words, there 

was very little texture to the, how you were 

breaking the site up. No, is that --

DR. MAKHIJANI: No, no, I think in the 

original also it was broken down by area. 

DR. MAURO: I can help out in terms of I ran 

into this problem, I did some work with EPA 

when they were concerned with the clean up of 

sites and where there was soil contamination. 

And they would have adjustment factors. And 

said, okay, well, listen, if a person is 

standing on contaminated soil, and he’s 

breathing, he’s inhaling airborne 

radioactivity, the air that he’s breathing 
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reflects the average activity over some area. 

Certainly, it does not reflect the activity 

under his feet. 

So it’s some area where it’s realistic 

to say, okay, what is the integrated, what’s 

the area of what you really want to average. 

And there’s literature on that. Now I guess, 

you folks may have already looked into this, 

but it may not be a bad idea to take a look at 

this Area 8 and its size. And then there is 

this literature on what the averaging area 

should be when you’re dealing with this kind 

of problem because it’s been looked at a lot. 

And it may turn out that maybe Area 8 

is very large, and you may have enough, I 

guess I don’t know if you have enough 

information to break it up into sub-areas or 

whether you need to do that or not. But I 

think Arjun’s right, and if it’s that large, 

it’s probably something that needs to be at 

least explored a little bit, whether or not 

we’re averaging over too large an area. 

MR. ROLFES: I don’t find it credible to 

find a person standing in the hottest spot 

within that area --
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DR. MAURO: I agree. 

MR. ROLFES: -- for 2,600 hours per year. 

DR. MAKHIJANI: No, no, I’m not saying that. 

That’s not the construct. In a very large 

area when you’ve done a survey with a crude 

grid, then you have some variability. And the 

question is, is the number that you’re using 

for site contamination, what is the 

variability in that, and how well is that 

represented in the intake. So the question is 

not are we putting a person at the hottest 

spot within a factor of a hundred more than 

the average, is not that for 2,600 hours. 

That’s not the comment that I’m making. It’s 

just for clarity. The idea was related to how 

the survey was originally done and what that 

implies for how comfortable we are with the 

number that we’re using and what the 

variability of that is. 

MS. MUNN: (Unintelligible) compared to the 

other areas? 

DR. MAKHIJANI: No, but all these, I mean, 

the Test Site is huge so (unintelligible) huge 

areas. 

MS. MUNN: I know the Test Site itself is 
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huge, but Area 8 isn’t really. 

DR. MAKHIJANI: No, Area 8 is not one of the 

larger areas. 

MR. ROLLINS (by Telephone): No, Area 8 --

this is Gene Rollins -- Area 8, the 

contaminated area that was identified by 

McArthur is 13.3 square miles, and that’s out 

of a total contaminated area of 510 square 

miles. And the total NTS area is like 1,350 

square miles. 

DR. MAURO: So how many miles? I think in 

terms of three-by-three. What is it, four-byfour? 

DR. MAKHIJANI: Yeah, well, three-and-a-half 

by three-and-a-half. Yeah, that’s 36 million 

square meters. 

DR. MAURO: In the level of information that 

you have in terms of -- I’m just thinking 

through the problem. If I were asked to look 

at this problem, I would say, okay, I’ve got 

this area that’s three miles by three miles, 

and I know that a person spent some of his 

time there. Now certainly, there’s reason to 

believe that he spent a few hours here, a few 

hours there, all over the site, yeah, then you 
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would work with the, you’d do it exactly the 

way you did it. 

If there’s reason to believe that no, 

there’s reason to believe that, no, that there 

is quite a bit of variability within that 

three-by-three, let’s say it would be a 

tenfold difference, and there’s a couple of 

square miles over here that are ten times 

higher than over here. I feel as if I owe it 

to myself to say, okay, is it reasonable to 

say that, well, maybe a person could have 

spent quite a bit of time in that section. 

But at the same time you’ve got to ask 

yourself when the wind is blowing and resuspending it is an integrating factor. What 

is really in operation here? Does the wind 

pick up and you inhale dust that may be blown 

from two, three miles away? I seem to believe 

that’s the case by the way. 

I seem to recall that we’re talking 

about when you’re working in an area, and 

you’re inhaling dust, the dust you’re inhaling 

is not only the dust that’s being re-suspended 

from your immediate vicinity, it’s also the 

stuff that’s being blown from a mile or so 
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away. So it may turn out that everything is 

just where it should be, but all I’m saying is 

I would sort of explore it a bit and air it 

out. 

DR. NETON: I’m sorry. I stepped out for a 

second. It seems you’re now questioning or 

discussing the appropriate value to use for 

the Area 8 dust-loading model. 

DR. MAURO: Yes. 

DR. NETON: How does that bounce against 

your previous comment though that we’ve 

already taken five milligrams per cubic meter 

as a very large number, and you just said five 

minutes ago we need to go back and look at the 

extra conservatism we built into these things. 

DR. MAURO: I’m not saying --

DR. MAKHIJANI: That has not to do with the 

dust loading. For the five milligrams okay, 

but the radionuclide content per milligram of 

that is what we’re talking about. 

DR. NETON: No, but what John was saying 

though is if you already start at five 

milligrams, and you’ve made a very 

conservative assumption at that point then, I 

heard John, I think, say then you might want 
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to consider what you pick for your 

representative values for these other factors 

because you’re already at the high end with 

the dust loading. And so if you pick the high 

end dust loading and then maybe the high end 

of the concentration is maybe a little bit of 

overkill. 

DR. MAKHIJANI: No, Jim, that wasn’t the 

spirit of the comment. 

DR. NETON: Okay, I stepped out --

DR. MAKHIJANI: -- a couple of times. So 

the idea wasn’t that you place somebody in a 

hot spot for 2,600 hours. That wasn’t the 

comment that was made. The comment, I think 

the matrix item is essentially what was the 

nature of the grid that was used in the 

sampling. It wasn’t (unintelligible). What 

is the variability in this number that we’re 

looking at and what do we know about it? 

So it’s not that we should use a 

higher number or place somebody there for 

2,600 hours. If we’re going to use this, 

especially in denial cases and worst cases, 

that we should have some idea of the 

relationship of these numbers since it’s a 36 
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million square meter area. 

DR. NETON: I think that’s fair, and that 

sort of falls into that category where John 

agrees to work with Gene on these other 

factors is what’s appropriate. 

DR. MAURO: I’m just thinking it through; in 

fact, while I was talking it out I tried to 

visualize. The impact is within miles. So I 

think maybe it’s right where it should be. In 

other words, I wasn’t saying you should use a 

conservative assumption. I just want to 

demonstrate that, yeah, the assumption we’re 

using by averaging over the entire Area 30 

area is certainly a reasonable, appropriate, 

realistic assumption. And I would want to 

convince myself that that’s the case. 

DR. NETON: Sure. 

DR. MAKHIJANI: Okay, so is this going to be 

thrown into that pot where you --

DR. MAURO: Yes. 

DR. MAKHIJANI: -- where you kind of look at 

the degrees of conservatism? 

DR. MAURO: Yes, yes. That’s what I 

suggest. 

DR. NETON: It seems appropriate. 
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 MR. PRESLEY: How about a seven-and-a-half 

or ten-minute break here? 

DR. NETON: Start your stopwatches. 

 DR. WADE: Is there another document that’s 

going to come out that’s going to be discussed 

there are any copies of? 

MR. ROLFES: No, there’s not. I apologize 

for the confusion. 

 DR. WADE: But you’re saying the matrix? 

You said after we do these items --

 MR. PRESLEY: What we’re going to use is the 

matrix that Mark put out. 

 DR. WADE: Does anybody need a copy of that? 

 MR. PRESLEY: Ray does, he says. 

 DR. WADE: Ray does. So I need a copy to 

copy. We’re going to take a break for ten 

minutes, however long ten minutes is in this 

time zone. We’ll find out, but we’ll be back 

to you. 

(Whereupon a break was taken from 10:47 a.m. 

until 11:02 a.m.) 

 DR. WADE: Okay, we’re getting ready to 

begin again. Might I ask who’s on the line? 

MR. ROLLINS (by Telephone): Gene Rollins is 

here. 
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 DR. WADE: Hello, Gene. 

UNIDENTIFIED (by Telephone): Kathleen from 

Senator Reid’s office. 

 DR. WADE: Thank you. 

MS. SMITH (by Telephone): Cheryl Smith. 

 DR. WADE: Welcome. 

Okay, that just gave me a sense of 

who’s out there. We are ready to begin. 

Mr. Presley? 

 MR. PRESLEY: What I would like to do, we’ve 

gone through items five, six, seven and 23. 

Are there any more questions about item 23, 

Comment 23? 

 (no response) 

 MR. PRESLEY: I guess what I’d like to do 

now is start with item one, and let’s go back 

through the matrix. I think Lew was printing 

everybody a copy. And we’ll just start going 

through each comment, and what I would like to 

do is where we are working on the TBD for 

completeness, Mark is prepared to give us an 

update on where we stand on that. 

And unfortunately or fortunately, we 

have added to their problems by putting a 

couple more things in there that they have to 
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look at before this TBD can come to us. So, 

Mark, do you want to talk about the TBD first 

since it pertains to probably 60 or 70 percent 

of these comments? 

TBD DISCUSSION 

MR. ROLFES: A lot of the issues that we 

discussed today were at the heart of the 

issues being discussed. The mass-loading 

model took up quite a bit of the, many of the 

comments were addressed or related to the 

mass-loading model and the environmental 

intakes at Nevada Test Site. 

We had attempted to provide that to 

the Advisory Board for discussion prior to it 

being an official approved document. This was 

just done to try to expedite things rather 

than present our research and findings and 

then receive comments after we had approved 

the document. This is just to try to simplify 

things and try to get everything, try to 

expedite things and get comments addressed 

before we have an official document that we’re 

using for dose reconstructions. 

A lot of the comments we have resolved 

with draft methodologies that have not been 
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approved in a TBD yet. We are trying to 

address as many of these issues as we can 

before we put that TBD out and use it for dose 

reconstructions. So we can provide some 

updates to you on where we stand with these 

various issues and indicate whether we have 

the work completed and whether it’s ready to 

use. 

 MR. PRESLEY: Okay, thank you. 

COMMENT 1: RADIONUCLIDE LISTS 

Why don’t we start with Comment 1. It 

had to do with the list of radionuclides and 

looking back at that the documents were 

changed. I believe everything is complete on 

that, and the working group is waiting on the 

TBD to go through. Is that correct? Anybody 

have any more comments on that? 

DR. MAKHIJANI: I wondered why Sodium-24 and 

Neptunium-239 were not added for tunnel reentry workers, and why that addition was 

restricted to those three. 

MR. ROLFES: Well, for the short-lived 

radionuclides, because we have a special 

exposure cohort from the time period covering 

1951 through the end of 1962, we will not be 
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reconstructing internal doses from the shortlived radionuclides. 

DR. MAKHIJANI: Yeah, I know. I was talking 

about the tunnel re-entry workers. 

MR. ROLFES: Okay, Gene? Gene? 

DR. MAKHIJANI: Or maybe the -- was the 

review comment only for atmospheric testing? 

I don’t remember. 

 DR. WADE: Gene, are you with us? 

MR. ROLLINS (by Telephone): Yes, I’m here. 

 DR. WADE: Okay, Mark would like to prime 

you. 

MR. ROLFES: Gene, could you tell me whether 

we have incorporated any internal dose 

approach or description for tunnel re-entry 

workers post-1963 into our TBD? 

MR. ROLLINS (by Telephone): We have 

provided some instruction. 

DR. MAKHIJANI: Our finding did relate to 

both atmospheric and (unintelligible). 

 DR. WADE: Arjun had a question about two 

radionuclides. What were they again, Arjun? 

DR. MAKHIJANI: Sodium-24 and Neptunium-239. 

We had an original list in Table 1 of our site 

profile review on page 26, and of those, I 
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thought the three that you added -- let me 

just cross-check here. 

MR. ROLLINS (by Telephone): This is Gene 

Rollins. We have, or are in the process of 

developing, tables based on Hick’s data that 

show the relative abundance of various 

radionuclides time after detonation. And we 

will be evaluating whether Sodium-24 or some 

of the other short-lived radionuclides 

represent radionuclides that would be 

important to dose. 

DR. MAKHIJANI: Yeah, but you included 

Aluminum-2 at 28 which has a half life of only 

2.24 minutes. And you didn’t include Sodium24 which has a half life of 15 hours. So that 

kind of raised the question in my mind as to 

why you picked these three out of the list in 

Table 1, and left out the Sodium-24 15 hours, 

and 279-Neptunium 2.36 days. So it seemed a 

little backward, but 2.2 minutes would seem 

not so relevant for tunnel re-entry workers. 

MR. ROLLINS (by Telephone): We will go back 

and look at these lists once again in terms of 

the Hick’s data. And we will decide which 

ones need to be considered. 
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DR. MAURO: Gene, regarding the Hick’s 

Tables, I recall using them in the past, and 

sometimes in some tests they included 

activation products. And sometimes they were 

limited to just the fission products. And I 

know Hans is pretty familiar also with the 

Hick’s Tables. I guess the only thing is it 

sounds like your set of Hick’s Tables include 

activation products, and that’s good. 

DR. BEHLING: Well, they will include things 

like cobalt and iron and others, but the key 

element here I believe is Neptunium-239 

because it’s produced in large quantities at 

least for some of the detonations that I’ve 

looked at. It’s one of the most prominent 

radionuclides in the immediate aftermath of a 

detonation. 

DR. MAKHIJANI: And it could also affect 

quite a number of workers because it has a 

half life of --

DR. BEHLING: It’s 2.6 days. 

DR. MAKHIJANI: You go out a week or two 

with this. 

DR. BEHLING: And I don’t believe Sodium-24 

is included in the Hick’s Table. 
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MS. MUNN: That’s the issue. How 

significant is --

DR. MAKHIJANI: I don’t know, Wanda. 

MS. MUNN: My memory which could be flawed. 

 MR. PRESLEY: Gene? Gene, this is Bob 

Presley. Are you there? 

MR. ROLLINS (by Telephone): Yes. 

 MR. PRESLEY: How significant is the sodium? 

I don’t recall using that much of it or seeing 

that much of it used. 

MR. ROLLINS (by Telephone): I really can’t 

respond quantitatively to that question, but 

qualitatively I would be surprised if it was 

very important. 

DR. MAKHIJANI: This is just a raised here 

as an activation product from natural sodium 

which you would expect to be present in the 

geologic environment. 

 MR. PRESLEY: Yeah, a geological 

environment. 

DR. MAKHIJANI: So that’s why it was raised 

in the context of the tunnel re-entry workers. 

Because you would expect an activation just 

like you do with sea water. 

MS. MUNN: Yeah, but it’s such a small 
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fraction, well, it’s worth looking at to see 

if it’s --

DR. MAKHIJANI: I think this list that was 

in our review was from the National Academy 

report in ’89, but that one was in the context 

of atmospheric testing. So, yeah, it may be 

that neptunium is important and sodium is not, 

but it’s worth checking. 

MS. MUNN: Are there any other radionuclides 

you’re concerned with, Arjun, that haven’t 

been covered by these tables? 

DR. MAKHIJANI: I don’t remember what’s in 

the TBD, but I have in front of me what we had 

in our review which was Neptunium-239, Sodium24, Manganese-56. We picked up Chlorine-38, 

Aluminum-28. They’re very short-lived, and 

Scandium-46? 

MS. MUNN: Scandium-46, those three --

DR. MAKHIJANI: And 134-Cesium and Cobalt60. 

MS. MUNN: Cesium and Cobalt-60 are surely 

in there, aren’t they? I’m trying to think --

DR. MAKHIJANI: Now, I don’t know why I 

included them in this table if they were not, 

they must have not been in the TBD. I’d have 
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to go back and check if they were, but I 

presume that they were not in the TBD; that’s 

why they were in this table. 

MS. MUNN: So Cobalt-60 and --

DR. MAKHIJANI: Cesium-134. 

DR. BEHLING: Are they short-lived? 

DR. MAKHIJANI: This is on page --

No, no. Cesium-134 is two years and -

-

DR. BEHLING: No, no, I was going to ask 

about the short-lived radio-iodides included 

in the TBD, 132, three, four and five. 

DR. MAKHIJANI: No, this is activation, the 

title of the table is “Activation Products 

Important for (unintelligible)”. We raised 

the iodine issue separately. 

MS. MUNN: And the real question then 

becomes how significant are they, and do they 

need to be included, correct? 

DR. MAKHIJANI: Yes. I think this was 

raised at the time before the SEC petition as 

a combination that would apply to all workers 

potentially, but some of them may be only 

relevant for atmospheric testing workers. And 

we haven’t gone back after the SEC petition 
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and actually checked which one would be 

relevant. But I presume that NIOSH would be 

checking that. 

MS. MUNN: Yeah, I would think so. Well, my 

question is because if there are issues with 

respect to the table, it would be beneficial 

for all of us to cover any issues that exist 

without bringing more up later. 

DR. MAKHIJANI: Well, my memory’s a little 

bit dim from having researched this a year and 

a half ago, but I can remember we raised all 

the activation products that we had concerns 

about in this table. 

 MR. PRESLEY: That’s why I bother about 

bringing this up because a year ago we said 

that that list of nuclides that was put out 

there was fine, no problems. Everybody was 

agreed that we would go with what we did about 

a year ago. So if we’ve got new things that 

we need to put up here, we need to make sure -

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 DR. WADE: These were not raised in the 

original SC&A review. Now the question is --

DR. MAKHIJANI: These are not new, Mr. 

Presley. These were raised as omissions from 
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the site profile in the original review that 

we filed. That’s what Comment 1 is. Exactly 

from the table that I’m reading, Comment 1 is 

about the table that I’m reading which was 

from August, from December 2005. 

 MR. PRESLEY: Okay, I thought we were --

MS. MUNN: And if they’re insignificant, we 

should say so. 

DR. MAKHIJANI: No, we’re not adding 

anything, but we just don’t, we did not parse 

at the time what was important for atmospheric 

or underground. And that’s the thing that we 

did not do. It’s all mooshed in there in one 

set. 

MS. MUNN: We wanted to make sure we were 

covering them all. 

MR. ELLIOTT: As we revise the Technical 

Basis Documents to address, not in presumptive 

cancers for the class, we’ll have to factor 

this into that figure as well as the postclass periods. 

MS. MUNN: If it’s insignificant, it’s easy 

to say so. 

DR. MAKHIJANI: Yeah, actually I have some 

explanation here that the TBD actually has a 
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matrix, if I remember, of which radionuclides 

are relevant and which circumstances, and 

Cobalt-60 is listed as being relevant for 

tunnel re-entry and mine back operations. So 

I think Cobalt-60 is not an issue because it’s 

already covered in the TBD. 

MS. MUNN: It’s already covered. 

DR. MAKHIJANI: So the others --

MS. MUNN: At least manganese and cesium, 

neptunium and sodium. 

 MR. PRESLEY: What I’ve got here is that 

NIOSH will go back and look at sodium and 

neptunium and see if they need to be added to 

the list. 

DR. MAKHIJANI: And there are a couple of 

others perhaps. 

DR. BEHLING: Is (unintelligible)-67 

included? 

DR. MAKHIJANI: I didn’t have that 

originally, no. 

DR. BEHLING: I don’t know if that’s an 

important in an aqueous environment only or it 

was a very important radionuclide in the 

Pacific. 

 MR. PRESLEY: If we need to be adding it, 
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let’s add it now instead of waiting for the 

next time we have a meeting. 

DR. MAURO: This is John Mauro. I guess I 

see this as an area of vulnerability. I’ll 

explain what I mean by that. The list of 

radionuclides that are associated with these 

things are very, very long. And the 

activation product list is often incomplete. 

And I guess I just caution that, you know, 

there’s always going to be, I can see it down 

the road. There’s always going to be 

something that’s going to pop up that we 

didn’t look at. All I’m just saying is that 

we are dealing with something that, a complete 

list to make sure we captured all --

DR. MAKHIJANI: Zig*-67 is stable. 

DR. MAURO: Pardon me? 

DR. MAKHIJANI: Zig*-67 is stable. 

DR. BEHLING: Only has a couple year half 

life. 

DR. MAURO: We ran into it as a big deal at 

the Marshall Islands. 

DR. BEHLING: Or 65, maybe it’s 65. I don’t 

remember which number. It’s relatively longlived. It does concentrate at least in the 
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marine environment. 

DR. ROESSLER: Two hundred and forty-three 

day half life. It has 67 stable. 

DR. BEHLING: Okay, stable. 

DR. MAURO: You may want to look into some 

of the research and work done in the DTRA 

world, the Defense Threat Reduction Agency 

world. They have an incredible amount of 

information on this subject. That is, the 

radionuclide inventory. You probably have 

already done that. But that is a resource 

that will -- see, they’ve been struggling with 

this problem of veterans of activation 

products, making sure they had a complete 

list. And it may be helpful just to look 

under that rock. 

DR. MAKHIJANI: Yeah, at this stage, I think 

you know, maybe geological data on the Nevada 

Test Site and which activation products may be 

important might be the best way to narrow this 

down quickly and things that are very short 

half life can be omitted and screened out. I 

think 67 clearly has a long half life. 

DR. BEHLING: No, it’s 65. 

DR. ROESSLER: At least it’s stable. That’s 
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very long. 

DR. MAKHIJANI: Now you’ve got like a 

proton, right? 

 MR. PRESLEY: Okay, Mark, you going to take 

that as an action item, please? 

MR. ROLFES: Okay, we’ll look into the 

radionuclide and verify that it is complete. 

 MR. PRESLEY: Okay, the list. 

COMMENT 2: REACTOR TEST RE-ENTRY 

Comment 2 has to do with the guidance 

for dose estimation for gonads, skin, 

gastrointestinal tracts of the early reactor 

test site personnel for large hot particles. 

MR. ROLFES: All right, Gene. Gene? 

MR. ROLLINS (by Telephone): Yes. 

MR. ROLFES: Could I have you speak about 

hot particles, ingestion of hot particles and 

skin deposition of hot particles, please. 

MR. ROLLINS (by Telephone): We have 

provided a response to the concerns to the 

issue of using NRDL techniques, and our 

conclusion has been, as we have stated in this 

matrix that we sent to you, is that the 

factual information necessary to employ the 

NRDL methodology is limited to a very small 
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dataset. 

And to try to extrapolate that to 

other situations is intractable. And I 

believe we said here that in those cases where 

we do have the data available, we will employ 

them as appropriate, but we don’t know how to 

move that methodology to other environments. 

DR. MAKHIJANI: I actually, you know, the 

question had arisen for skin deposition in the 

context of how you average from a very small 

hot particle to a larger area how you actually 

calculate a probability of causation from a 

very high but very local dose. And that was 

the question about the VARSKIN model as 

related to what the NRDL said. 

And then so a more complex version of 

that would be for the GI tract and how you, 

how do you, what kind of guidance do you give 

as to when this model is to be used? Because 

you suggest that the NRDL model might be used 

sometimes, but I didn’t see anything specific 

as to how the dose reconstructor would decide 

how that would be translated --

DR. NETON: That issue has been put onto the 

overarching issues list. That’s one of the 
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ones that we’re working on and specifically 

the skin and the GI tract model. I presented 

a brief on that somewhere. I forgot where I 

discussed that, but --

DR. MAKHIJANI: I think you did. 

DR. NETON: So our recollection there is no 

special requirement, no special dosimetry 

required for transport of hot particles 

through the GI tract. And I pulled out some 

relevant literature to discuss that. And the 

hot particle model for deposition on the skin, 

VARSKIN, of course, would model anything you 

give it, and I think we had some default 

language we were working on to put in there 

would only go down to average over no less 

than one square centimeter. 

DR. MAKHIJANI: I remember there was some 

question of averaging, and I could not 

remember what it is, and where we are about 

that. 

DR. NETON: That’s wrapped up in this 

overarching issues list. It’s not done yet. 

We’re working on that. Maybe this would be 

noted in here as an issue that NIOSH is 

addressing. Don’t lose it from the context of 
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this review, but possibly table that to our 

addressing this on a complex-wide basis, just 

a suggestion. 

DR. MAKHIJANI: The reason I guess I got 

confused and I forgot that it was in a 

different list is because here it says TBD 

will add guidance to Chapter 5, but doesn’t 

mention that other paper. 

DR. NETON: Yeah, we need to make sure 

that’s --

DR. MAKHIJANI: And so I kind of did not 

know what was happening there. And I did 

forget that you had added that. 

 MR. PRESLEY: So what you’re saying this is 

going to be complex wide? 

DR. NETON: There will be complex-wide 

guidance on how to deal with hot particles 

from skin contamination and ingestion prepared 

by NIOSH outside of this TBD. But we’ll need 

to, I guess, make sure that that issue doesn’t 

get lost from this matrix so when we close out 

this complex-wide issue, it will be back 

through here. 

DR. MAURO: Given that the technical issues 

certainly are tractable, that is, VARSKIN, we 
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can come up with something, I guess I view the 

tougher question is okay, now that we have 

tools, how do you apply it them to, let’s say, 

a particular claimant that may have been 

exposed to hot particles. How do you, you 

know, that’s --

DR. NETON: That’s a different subject. 

That’s the implementation of it, and I’m not 

sure where we go with that. 

 MR. PRESLEY: Okay. 

MS. MUNN: This brings up another issue with 

respect to timing, Jim. How are we going to 

deal with the overarching issues issue? Is 

the timing, are we going to be able to address 

those one at a time? We had, what, six or 

eight of them as I recall. 

DR. NETON: Eight now, eight to nine. 

MS. MUNN: And are we going to be able, 

what’s the plan --

MR. ELLIOTT: They’re going to come forward 

as we see the complete development of the 

position that we’re going to take. And so it 

may be that, I think Jim’s probably close in 

May, at the May meeting, to present two or 

three. 
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DR. NETON: Two or three are going to --

MR. ELLIOTT: And then once we get your 

input in those, we’ll finalize those and the 

site profile that is affected here will be so 

referenced and others as well. 

DR. NETON: But the answer is we’re working 

on these in parallel, not serially. It’s just 

as we can. 

 DR. WADE: And I think the tracking 

mechanism is that Larry in his report at each 

face-to-face Board meeting will give an update 

of status on these. Hopefully, that update of 

status will trigger Jim presenting a product, 

but you’ll see the full list at every Board 

meeting. 

MS. MUNN: Yeah, my concern was the timing 

concern with respect to whether or not the hot 

particle issue is going to be fully addressed 

in time for us to incorporate it into what 

we’re doing at NTS or since we clearly have an 

issue --

 DR. WADE: I don’t think there’s any 

guarantee of that. 

MR. ELLIOTT: They’ll come forward as 

they’re developed. Some may be sooner than 
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others. 

DR. NETON: We’d love to put together a list 

that says here’s the delivery date on all of 

these, but the nature of our business these 

days --

MS. MUNN: I know that’s impossible --

DR. NETON: -- is difficult. 

MS. MUNN: -- I was grasping for whether or 

not hot particle was close enough for us to be 

thinking --

DR. NETON: I think the guidance that we 

could put out there is not that difficult. 

John alluded to that. I mean, we can 

reference what we’re going to do and how we’re 

going to do it technically. The difficult 

part comes into how we implement it and how do 

you know when a person’s been exposed to a hot 

particle. I think I see some verbiage in here 

that says, well, when we do know it, we’ll use 

it. 

MS. MUNN: Yes. 

DR. NETON: But it gets to that situation of 

how you deal with a negative. How do you that 

people weren’t exposed to hot particles? Are 

you going to default and give everyone a hot 
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particle dose? These are the kind of issues 

that --

MR. ELLIOTT: Or do we have an indication 

that certain activities or jobs were more 

likely to have --

DR. NETON: Yeah, it looks like --

MR. ELLIOTT: -- found themselves in those 

circumstances. 

DR. NETON: -- like the rocket experiment 

here seems to be a prime candidate for hot 

particles. 

MR. ELLIOTT: Yes, we’re not necessarily 

able to capture this level of detail in our 

CATI interview, especially with survivors. So 

then do we go forward and ask for medical 

reports? In many cases you’re not going to 

find those. 

DR. NETON: You might not have even known 

you had a hot particle. 

MS. MUNN: Yeah, it still may not be helpful 

even if you have the medical report. 

DR. NETON: I’m pretty sure the GI tract 

issue will go away from a technical 

standpoint. I’ve looked at this and the 

dosimetry is not that different. The skin 
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dose, of course, the smaller you make the 

surface area or activity per unit surface 

area, the larger the dose. I don’t know where 

we can end up defaulting on that. 

MR. ELLIOTT: Now in a worker outreach we 

can ask these kinds of questions, you know, 

are there activities where splinters were 

found all the time and people got sent to 

Medical to get the splinters taken out. We 

can assist ourselves that way, but it’s still 

not going to be straightforward. We’re still 

going to have to apply it, I think, in a 

general context rather than in an individual 

context. 

 DR. WADE: But the tracking issue, Wanda, is 

an interesting one. I mean, it’s possible 

that this work group could close its work but 

with the caveat that that is contingent upon 

how the particle issue is being resolved. I 

mean, there has to be a way that we keep this 

alive until it’s actually done. 

MS. MUNN: And that’s really my concern is 

when we can say we’re good to go with NTS. 

 DR. WADE: And I would think closing it, if 

it’s on the complex-wide list, I think closing 
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the review with the caveat that it’s 

contingent upon that issue being resolved, I 

think is not an unreasonable way for the Board 

to conduct its business. 

DR. NETON: That’s the approach we took at 

Bethlehem Steel. It was closed given that 

NIOSH was going to develop an overarching 

approach for oro-nasal breathing. But we 

determined that that was an issue larger than 

just that one site profile. And this, in 

fact, is one I hope to be able to present in 

May at the Board meeting in Denver. 

MS. MUNN: That would be great. 

DR. MAKHIJANI: Actually, Jim, for Bethlehem 

Steel we agreed that oro-nasal breathing 

wasn’t very important to the dose, and so we 

closed it --

DR. NETON: Closed it --

DR. MAKHIJANI: -- for that site. 

DR. NETON: --- for that site, right. 

DR. MAKHIJANI: But that’s not the case 

here. 

 DR. WADE: On the fifth call I have a sort 

of a curious agenda item that goes to the 

completeness of the Board reviews, and that’s 
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part of it where we have to be careful that we 

don’t put something to bed here with the 

understanding it’s going to be dealt with 

somewhere else and do the same thing there and 

then wind up without closing the review. So I 

think we need to talk a little bit about that 

methodology. 

COMMENT 3: DOSES FROM LARGE PARTICLES TO GI TRACT

 MR. PRESLEY: Comment 3 is essentially the 

same thing, dose from large particles of the 

GI tract and skin of the workers in early 

atmospheric testing period. Would this 

comment not fall under the two? 

MR. ROLFES: Correct. 

DR. MAKHIJANI: The only new thing in the 

response here, Mr. Presley, is in the second 

sentence in the second paragraph which is 

historically measurement of hot particles was 

not conducted at NTS. So that kind of raises 

this issue we were just talking about. And it 

says that although insufficient or nonexistent hot-particle data from NTS makes dose 

calculations intractable, any documented hotparticle external exposures can be addressed. 

So I think what NIOSH has said here is 
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kind of making the identification problem very 

acute. So if there is some, I’ve heard 

informally that in the testing program at NTS 

in contrast to, say, Pacific Proving Grounds, 

it was not a hot-particle issue, but that’s 

being an informal kind of observation that 

people say these things. I haven’t seen any 

documentation or measurements or some 

radiological evaluation. Have you all come 

across anything like that? 

MR. ROLFES: Gene, have you seen anything to 

answer Arjun’s inquiry? 

MR. ROLLINS (by Telephone): As to whether 

there were surveys for hot particles? 

DR. MAKHIJANI: Yeah, or any comment that it 

was in an official or health physics or 

radiological survey document that, you know, 

this had happened at PPG, but it’s not a 

problem at NTS. An informal opinion is 

sometimes offered about that, but I’ve never 

seen any documentation to that effect. 

MR. ROLLINS (by Telephone): I have not 

either. 

DR. MAKHIJANI: So I guess this kind of goes 

back to the earlier problem of how you 
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identify the workers. So it is in that 

respect the same as item two. 

MR. ROLLINS (by Telephone): But kind of on 

the other hand, we don’t have documentation, 

or I haven’t seen documentation that suspects 

hot particles might be a problem at NTS. 

DR. MAKHIJANI: Yeah, this is what Jim was 

saying. 

 DR. WADE: It’s a conundrum. 

MR. CLAWSON: Well, I thought odd in talking 

about it. You know, they talked earlier about 

the early propulsion systems and if that was a 

hot particle problem there because some of the 

surrounding areas would be closed down during 

those processes until the buildings could be 

washed down and so forth like that because of 

the hot particles. 

DR. MAKHIJANI: Now that was a documented 

hot-particle problem. There were measurements 

made post-reactor tests, and they did quite a 

lot of studies about that. So I guess you 

could say the absence of studies in the 

testing might say something. I don’t know how 

you would argue that, but it’s an issue. 

DR. NETON: Yeah, it’s something we’re going 
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to have to deal with. It’s almost more of a 

policy issue than a science issue. 

DR. MAKHIJANI: Yeah, maybe a policy issue. 

I agree. If you don’t find any documentation, 

and you had it at Pacific Proving Grounds, 

then, which is, you know, not exactly the same 

type of test site obviously, it raises a 

question for NTS, and then I guess it becomes 

a policy issue which takes out, maybe, out of 

our, SC&A’s realm. 

 DR. WADE: I think the Board would care 

about how it was addressed. 

DR. NETON: I mean, this is post-atmospheric 

testing we’re talking about now, so we’re not 

talking about raining down of the immediate 

shot. So then one wonders how much, how far 

you’ll be exposed to from the resuspension 

pathway and possibly in the tunneling and 

drill backs. 

DR. MAKHIJANI: In the drill backs is where 

I’m thinking because that’s when you’re 

resuspending significant sized particles, not 

in the resuspension as in relation to 

breathing fine particles in the suspension of 

large particles. 
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DR. NETON: Right, we have to look at that 

and see. I don’t have a feel for that at all 

right now. 

MS. MUNN: You must be talking about a very 

small number of workers. 

 MR. PRESLEY: Yes, yes, very small. 

Okay, what I’ve got on this is it will 

be addressed in the site-wide report the same 

as Comment number 2. Is that correct? 

 (no response) 

COMMENT 4: ORO-NASAL BREATHING

 MR. PRESLEY: Go to Comment 4, ingestion. 

It has to do with reactor testing and the 

nuclear weapons testing workers for oro-nasal 

breathing. It says it needs to be evaluated. 

MS. MUNN: It’s one of the overarching 

issues. 

 MR. PRESLEY: That’s what I remember. I’ve 

got a note here that says included in the 

Board’s meeting schedule. 

DR. NETON: It’s similar to the ingestion 

issue where hot particle oro-nasal breathing 

is being addressed, and that’s hopefully the 

one that’s going to come up in May, I hope. 

We never promise any more but --
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 MR. PRESLEY: We can say that this will be 

coming up --

 DR. WADE: Say Jim Neton promised it’d be. 

DR. NETON: Checks will be in the mail by 

Christmas, I remember being quoted as saying. 

COMMENT 8: EXTERNAL DOSE DATA FOR 1963-1966

 MR. PRESLEY: We’ve done five, six, seven, 

eight. There’s the external dose data from 

’63 to ’66 not claimant favorable. I’ve got a 

notation on this that the TBD will address 

some guidance to the Chapter Six revision. 

DR. MAKHIJANI: You’ve published a revised 

TBD, right? 

MR. ROLFES: That’s correct. We did update 

the TBD with a page change revision so that 

has been addressed and an approved document 

that’s available for dose reconstruction at 

this time. 

 MR. PRESLEY: Can we say that Response 8 

then is complete and off of our table? 

DR. MAKHIJANI: Mr. Presley, I don’t know 

what the procedure is if NIOSH has completed 

and the revision of the review are we review 

that and make sure that the comment was 

addressed or if the TBD has been published 
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then a separate action reviewing that is 

required by the Board. Or I’m not clear what 

happens in a circumstance like that. 

 MR. PRESLEY: Lew, you got any? 

 DR. WADE: Yeah, I think it’s up to the 

discretion of this work group. I mean, NIOSH 

was instructed to do something. NIOSH reports 

it’s done that. The work group can (a) take 

it on faith, (b) review it itself or (c) ask 

its contractor to review it. 

DR. MAKHIJANI: Because we, pending 

instruction from you, we haven’t done, and I 

sent you an e-mail about that I think. We 

have not done any reviews of changes that have 

been published pending instruction from the 

working group. 

MR. ROLFES: It’d be a simple one to review. 

It’s really just one or two pages. 

DR. MAKHIJANI: Yeah, I mean, to be formal 

about what we do I wanted to be --

 DR. WADE: It’s up to the work group. 

 MR. PRESLEY: Do I have a consensus that we 

need to let SC&A review this and get back with 

us with their comments? 

MS. MUNN: Actually, as Mark points out, 
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it’s not that big a thing, but I had expected 

personally to have time to review both Section 

Five and Section Six, which have been re-done, 

and shamefully, have done neither. And so my 

personal preference would be to have an 

opportunity to go over those two chapters 

myself. My feeling is that probably if the 

issues have been addressed appropriately, then 

it’s difficult for me to evaluate whether they 

have or have not since I have not read those 

two chapters which are now available for 

everybody. They’re up on the web, and I just 

have not read them. Have all the other Board 

members reviewed them? 

 MR. PRESLEY: No. 

DR. ROESSLER: You’re putting us in a 

corner. 

 DR. WADE: Don’t ask me to join her in the 

corner. 

MS. MUNN: Welcome to my corner. 

 MR. PRESLEY: I’m with you in the corner, 

too. At this point I would suggest that we 

let SC&A review this, get back to us with 

their comments. 

DR. MAURO: It sounds like the issue was 
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that external doses from ’63 to ’66 were not, 

basically, are being reconstructed using 1967 

data. And our concern was can they do that. 

I guess you folks have answered that, yes, you 

can. Can you just give us a quick, 30-second 

sound bite on the strategy? 

MR. ROLFES: Sure. Yes, I will refer to the 

change that we made in the Technical Basis 

Document. We received a master dosimetry 

gamma dose sheet for individuals monitored 

from 1945 so there were some individuals that 

were at the Trinity site, but beginning in 

1951, these would have included the people at 

Nevada Test Site all the way up, I believe we 

have, this sheet just has through ’83, but I 

believe we do have more recent dose 

information. 

What we did, we were able to get 

information on the number of people that were 

monitored at Nevada Test Site, and the number 

of people that fell into various dose 

categories and had doses between one and 50 

millirem, 50 to 100 millirem, 100 to 150 

millirem and on up all the way from 7,500 

millirem up to 10,000 millirem. So we have 
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incorporated this into the Technical Basis 

Document I believe. 

Is that correct, Gene? I want to make 

sure that I’m referring to the correct thing 

that we incorporated this master dosimetry 

table that we received for assigning 

unmonitored doses for 1963 through 1966. 

MR. ROLLINS (by Telephone): Yes, that has 

been incorporated. 

MR. ROLFES: Okay. 

DR. MAURO: So let me see if I understand. 

You do have dosimetry data from ’63 to ’66 

upon which to do dose reconstructions or at 

least build a coworker model --

MR. ROLFES: Correct. 

DR. MAURO: -- for those who weren’t 

monitored from ’63 to ’66. 

MR. ROLFES: Correct. 

DR. MAURO: And the data is in your 

amendment. 

MR. ROLFES: Yes, that’s correct. 

DR. MAURO: So I can look at that. It’s 

easy. 

COMMENT 9: ENVIRONMENTAL EXTERNAL DOSE DATA FOR 1968-

1976 
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 MR. PRESLEY: Comment 9, and it’s the same 

response as Comment 8. It has to do with the 

environmental external dose ’68 to ’76. 

Anybody have any problems with what we have 

there to be taken care of in Response 8? 

MR. ROLFES: Same issue, same response. 

 MR. CLAWSON: Let me ask one question. When 

you do a change to the TBD like that, you 

change the one on the web, right? 

MR. ROLFES: Yes, that’s correct. The one 

on the web will have an indication that 

there’s a page change revision, and it’ll have 

the date that the revision was made. 

 MR. CLAWSON: Okay, so I need to keep 

updating my TBDs because I’m just looking at 

mine, and it’s a year or so old there. That’s 

what I need --

MS. MUNN: You also have to look under NTS. 

MR. ROLFES: There’s a lot of information 

out there. It’s overwhelming. 

DR. MAKHIJANI: As a reviewer let me say 

that it’s very helpful when you revise 

something that in the beginning of the revised 

document you have a notation of the changes 

that have been made, the sections and if there 
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are specific changes. That’s very helpful. 

Or if the whole document has been changed, 

then you need, then you know you’ve got to go 

through the whole thing again. But otherwise 

it really is very efficient to know what to 

review the second time around. Thank you. 

MS. MUNN: Mark in the margins. 

COMMENT 10: PRE-1963 EXTERNAL ENVIRONMENTAL DOSE

 MR. PRESLEY: Comment 10. It has to do with 

pre-’63 external environmental dose relating 

to unmonitored workers. And again, that has 

been addressed or will be addressed in the 

TBD. 

MR. ROLFES: Correct. And this will be 

addressed by the Comments 8 and 9. Our 

response is the same information will be used, 

the master dosimetry gamma dose table that 

we’ve incorporated into the Technical Basis 

Document. 

 MR. PRESLEY: Pardon me. I want to make 

sure I get the right response on here. 

COMMENT 11: CORRECTION FACTORS 

Comment 11, correction factor for the 

external environmental dose, and that also has 

to do with the TBD review. 
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MR. ROLFES: Yes, that’s correct. I’ll give 

a brief description and then let Gene make 

comments if necessary. 

We did evaluate, this was an issue 

about correction factors for external dose 

from environmental contamination. There was a 

concern that correction factors needed to be 

developed specific to these unique geometries 

associated with contamination disbursed in the 

soils. It was more of a geometrical 

correction I believe. 

But what we did, we did go through and 

evaluate various correction factors and found 

that these were typically less than what we 

are currently using in our Technical Basis 

Document. So we didn’t feel that it would be 

appropriate to reduce the dose that we’re 

assigning based on these new numbers that we 

had developed. Everything was pretty much 

close to unit, roughly one, a dose conversion 

factor of one. 

Is that a correct description of what 

we did, Gene? 

MR. ROLLINS (by Telephone): I think you 

captured it, Mark. 
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MR. ROLFES: Okay. So we did evaluate these 

numbers and come up with new dose conversion 

factors that could be used. However, many of 

them were less than one so we didn’t think it 

was appropriate to use a lower number than 

what we already had. 

DR. MAKHIJANI: I had two questions about 

this response, one of which was -- what, are 

you done with the whole thing or just the 

first part of that? 

MR. ROLFES: No, I’m finished. Go ahead. 

DR. MAKHIJANI: Referring to the second 

paragraph, the energy ranges, I understand the 

minimum and maximum assumptions, but you 

don’t, say, give any guidance for best case 

estimates there. 

MR. ROLFES: Gene, for, well, I take that 

back, when minimizing or providing a best 

estimate --

DR. MAKHIJANI: Oh, or providing, sorry. 

MR. ROLFES: -- the photon energy range 

assumption is 25 percent, 30 to 250 and 75 

percent greater than 250 keV. And this was 

already added into the TBD. 

DR. MAKHIJANI: And there is a technical 
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basis for that in the TBD? 

MR. ROLFES: Gene, do we have measured data 

for the 25/75 split? 

MR. ROLLINS (by Telephone): Yes, if you go 

to Attachment B. We did an evaluation of 

Table B-1 in the revision. 

DR. MAKHIJANI: Oh, B as in boy? 

MR. ROLLINS (by Telephone): B as in bravo. 

DR. MAKHIJANI: Okay. Is this in the same 

set of revisions as Comment 8, 9, 10 or in a 

different set of revisions? 

MR. ROLFES: Let me refer back to this. 

Gene, was this incorporated into the 

approved Technical Basis Document with the 

dose table with the recorded gamma dose table? 

I’m not certain. I don’t --

MR. ROLLINS (by Telephone): I’m not sure 

what you’re asking, but I’m sitting here 

looking at the approved revision. Are we 

still talking about energy ranges? 

MR. ROLFES: Yes, that’s correct. 

MR. ROLLINS (by Telephone): That’s in the 

revision. 

MR. ROLFES: Okay, great. So SC&A can 

verify that it’s in there. 
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DR. MAKHIJANI: We can just look at it. 

MS. MUNN: I must be looking at the wrong 

thing. 

MR. ROLLINS (by Telephone): Actually, it 

occurs on page 94 of 113. 

MR. ROLFES: Okay, so we have addressed that 

as well. That’s in the approved Technical 

Basis Document that was recently put out with 

the page change. 

DR. MAKHIJANI: All right. And then the 

last question is I guess it says TBD work 

completed, but I guess this still remains to 

be done? Oh, workers job category job 

matrices added, but the correction factors 

haven’t been developed. Is that right? 

MR. ROLFES: We did evaluate the correction 

factors, and we determined that they were 

roughly unity or less than unity. 

DR. MAKHIJANI: Including for the geometry 

of exposure from --

MR. ROLFES: That’s correct, for 

environmental contamination, that’s correct. 

We didn’t want to lower the dose estimates any 

more than necessary. It didn’t add much to 

the Technical Basis Document. There was a lot 
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significant change. 

DR. MAURO: Does SC&A have an action item on 

this in terms of checking --

DR. MAKHIJANI: It’s all the same I think. 

All in the same revisions. 

COMMENT 12: RADON DOSES IN G-TUNNEL

 MR. PRESLEY: Comment 12, radon dose in Gtunnel. It also has to do with the Gravel 

Gertie radon dose. They are not discussed, 

could be substantial. That is also to be 

reviewed in Chapter Four of the TBD. 

MR. ROLFES: And we did speak with some 

people from Nevada Test Site, and we did 

determine that they did not routinely use the 

Gravel Gerties at Nevada Test Site. They were 

limited to the tests for the design of the 

Gravel Gertie back in 1957. 

And they basically had put some high 

explosives into it, into the Gravel Gerties to 

determine whether they would be able to 

contain any radioactivity with an explosion or 

detonation of high explosives. We haven’t 

found any indications that there was continual 

occupants of the Gravel Gerties. But if we do 
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in the future find someone that did routinely 

work in Gravel Gerties, then at the time we 

could assign the radon intakes. 

 MR. CLAWSON: What about G-tunnel? 

MR. ROLFES: The G-tunnel? Radon intakes, I 

do believe we have updated the information. 

Gene, could you --

MR. ROLLINS (by Telephone): Yes, yes, yes, 

there was a -- I went back and you were 

correct. It wasn’t claimant favorable the way 

it had originally been constructed. So I had 

gone back and revised the wording so that 

we’ll be using the G-tunnel concentrations, 

the higher concentrations. 

 MR. CLAWSON: Okay, so that’s going to be a 

part of the review that SC&A, it’s the same 

chapter --

DR. MAKHIJANI: Isn’t this, Brad, I don’t 

think this would need any review because 

there’s already a specific recommendation on 

our part as to what they should do. So I 

think it has been done. I mean, we could go 

back and read the page, but I don’t think 

there’s any new technical review to be done 

because what’s done is part of the review 
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already. 

MS. MUNN: I believe that one’s complete. 

MR. ROLFES: Okay, great. 

 MR. CLAWSON: So number twelve would be 

complete? I’m filling in for Bob for a second 

here by the way. 

DR. ROESSLER: Why don’t you call for a 

lunch break, Brad? 

 MR. CLAWSON: I don’t think it’s lunchtime 

right yet. 

 DR. WADE: It’s five of 12:00. 

 MR. CLAWSON: Oh, is it? 

 DR. WADE: You can do that. You’ve got the 

authority. 

 MR. CLAWSON: Why don’t we break for lunch 

then. Let’s go to a lunch break here then and 

Bob can pick up --

 DR. WADE: Back at 1:00? 

 MR. CLAWSON: Back at 1:00. 

 DR. WADE: Okay, we’re going to go to lunch. 

We’re going to be back at 1:00. We’re going 

to break the contact with the line and then 

call back in when we get back here. Okay, 

enjoy your lunch. 

(Whereupon a lunch break was taken from 
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11:55 a.m. until 1:10 p.m.) 

 DR. WADE: Okay, we’re going to go back to 

our deliberations. I guess I would only ask 

if there are any members of the Board joining 

us by telephone, I’d like them to identify 

themselves. Any members of the Board? 

Okay, someone’s speaking. We can hear 

you. I don’t think you realize we can hear 

you. Someone is speaking about contract 

value, and we can hear you. There’s somebody 

out there who’s having a discussion about 

contract value and billing, and we can hear 

you. Hello? 

 (no response) 

MS. MUNN: They must not care. 

 DR. WADE: Well, we can’t hear it. Let’s 

begin. 

 MR. PRESLEY: We stopped at 12; we finished 

with 12. Let’s start with Comment 13. 

 DR. WADE: Just a brief report on Brad’s 

leadership. He completed an item, and he 

called for lunch. Very well done. 

 MR. PRESLEY: He did a good job. Number 12 

is completed. 

 DR. WADE: Let the record show. 
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COMMENT 13: ENVIRONMENTAL DOSES DUE TO I-131 VENTING

 MR. PRESLEY: Number 13, Comment 13 has to 

do with the environmental dose due to venting, 

needs to be taken into account non-monitored 

workers. Again, this is an item which the TBD 

has addressed in Chapter Five revision. Does 

anybody have any comments one way or the other 

on this? 

DR. MAKHIJANI: I guess as I read it, it 

hasn’t been done yet? 

MR. ROLFES: Well, Cheryl, are you on the 

line? 

 (no response) 

MR. ROLFES: Gene or Cheryl? 

MR. ROLLINS (by Telephone): Yes, I’m on the 

line, Mark. 

MR. ROLFES: I’m going to see if we can, I 

believe Cheryl had gone through some 

calculations for our bounding environmental 

intake scenario, and that bounding scenario 

was the Baneberry venting. And I believe she 

was putting together some calculations in a 

white paper or in some spreadsheets. 

MR. ROLLINS (by Telephone): I have those. 

I can speak to those. 
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MR. ROLFES: Okay, great. 

MR. ROLLINS (by Telephone): Let me get my 

papers straightened out here. What we did was 

to go back and look at the actual measured 

concentrations of iodine that occurred after 

several of the ventings. And the highest one 

that was measured was from the Baneberry 

event, and it was measured on the plume center 

line a few hours after the event. But we 

corrected, actually, a few days after the 

event, but we corrected -- no, no, no. 

We did decay corrections, but the 

highest concentration that was measured that 

someone theoretically could have been exposed 

to was 1.85 ten to the minus 12 microcuries 

per cc at Camp 12. And what we did was 

postulate a two-hour exposure to that 

concentration. And the doses are very small 

to the thyroid, actually less than a millirem. 

So we don’t deem that to be important to dose 

reconstruction, the worst case scenario. 

DR. MAKHIJANI: Are these calculations 

incorporated or, I guess they’re not 

incorporated in the TBD. 

MR. ROLFES: They haven’t been incorporated 
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into an approved version of the TBD, but the 

draft calculations have been completed. I 

don’t believe they’ve been provided to anyone 

other than internally within ORAU and NIOSH 

right now. This is one of those things that 

we will be incorporating into the approved 

document when it’s --

DR. MAKHIJANI: Did you look at the other 

iodine, short-lived --

MR. ROLLINS (by Telephone): Yes. 

MS. MUNN: He looked at 131, 32 and 33 and 

35. 

MR. ROLLINS (by Telephone): Yes, we have 

methods to handle those, and they have been 

included in the calculations. All of them 

added together I should say resulted in less 

than a millirem of a dose to the thyroid for a 

two-hour exposure to the maximum 

concentration. 

MS. MUNN: I read some of that in the 

Chapter Five revision that’s already out. 

DR. MAURO: Excuse me, where is Area 12 in 

relative to where the release occurred? 

MR. ROLLINS (by Telephone): It’s Camp 12. 

DR. MAURO: Area 12, Camp -- okay. 
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 MR. PRESLEY: It’s up on the mesa. 

DR. MAKHIJANI: Is that where the people 

were caught in the plume? There were a bunch 

of workers at Baneberry who were caught in the 

plume. 

MR. ROLLINS (by Telephone): I can’t speak 

to that. 

 MR. PRESLEY: I can’t either. 

DR. MAURO: The question becomes is that 

where the people are? If that’s not the case, 

that’s the case. 

DR. MAKHIJANI: I thought that must be where 

the --

MR. ROLLINS (by Telephone): Let me make 

this comment. Let me make this comment. As 

we all know, atmospheric conditions were 

closely monitored. Of course, they didn’t 

expect a loss of containment at Baneberry, but 

they typically waited until atmospheric 

conditions were favorable so that anything 

that might be released would not be blowing 

towards populated areas. So although I don’t 

know this to be a fact, it seems to me that 

what they tried to do here was measure center 

line concentrations which may or may not have 
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been where people were expected to be. 

DR. MAKHIJANI: Yeah, I mean, Baneberry was 

obviously an unplanned venting, and as I 

understand it there was a group of several 

dozen workers who were caught in the plume 

inadvertently, of course. And so that’s why 

the question is were the doses evaluated for 

them. Obviously, that was shortly after the 

venting. I don’t remember the time. 

MR. ROLLINS (by Telephone): I’m speaking 

from memory now, but it seems to me that I 

have seen one or two of those cases -- well, I 

better not say, but it seems to me I remember 

seeing bioassay results on those individuals. 

But I can’t say for certain. 

MS. MUNN: That was going to be my next 

question. Wouldn’t that have been known? 

MR. ROLLINS (by Telephone): Typically, 

those people that were involved in that type 

of incident would have been --

MS. MUNN: I would think that --

DR. MAKHIJANI: It’s quite possible. I 

don’t remember actually. We raised that as a 

question in the review, and I can tell you 

what we said. Baneberry test in December 1970 
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was the last unplanned venting. TBD has not 

specified any approach to estimating external 

environmental dose during those years. 

MR. ROLFES: Okay, external? 

DR. MAKHIJANI: That’s this particular 

finding. I mean, we have a number of places 

where we mention Baneberry. 

MR. ROLFES: The external doses would 

obviously be recorded by a person’s film 

badge. And if a person were hypothetically 

unmonitored in that area, we have coworker 

information now. We have the gamma dose table 

that we referred to earlier that we could also 

use as well. 

MR. ROLLINS (by Telephone): There should be 

no one unmonitored externally. 

DR. MAKHIJANI: I guess we also had raised 

an internal question. Oh, yes, here it is. 

Area 12 Camp personnel who were 

decontamination -- they had decontamination 

showers -- personnel were instructed to 

provide urine samples. So okay, they did have 

urine samples. 

MS. MUNN: And then they recorded what the 

limits of detection for both urine and fecal 
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analysis were. 

DR. MAKHIJANI: So I guess that’s why we 

raised that external dose. 

MR. ROLFES: Okay, so I think the bottom 

line is that we need to incorporate just some 

of our bounding calculation or a description 

of the bounding scenario for exposures to 

radio-iodines associated with venting from 

Baneberry, and that will result. Does that 

sound correct? 

 MR. PRESLEY: Yes. 

 DR. WADE: You’ll do that and then the work 

group can decide if they want SC&A to --

 MR. PRESLEY: Fourteen. 

MR. ROLLINS (by Telephone): And is that the 

decision that we’ll include a summary of this 

discussion in the TBD? 

DR. MAKHIJANI: No, I was understanding 

you’ll include your calculation, not this 

discussion. 

MR. ROLFES: Okay, would the Advisory Board 

like for us to show a sample calculation --

 MR. PRESLEY: Yes, I think so. 

MR. ROLFES: -- in the TBD? Okay. 

MR. ROLLINS (by Telephone): This is Gene 
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Rollins again. I’m trying to understand if 

the Board is asking that sample calculations 

be put into the Technical Basis Document. 

 MR. PRESLEY: One, Gene. 

MS. MUNN: A single example, Gene. 

 MR. PRESLEY: Did you get that? 

MR. ROLLINS (by Telephone): Okay. 

COMMENT 14: INTERNAL DOSE FOR PRE-1967

 MR. PRESLEY: We’ll move on to 14. There 

are no internal monitoring data available 

until 1955 or ’56, some plutonium from then, 

some tritium from ’58, plutonium, tritium, 

mixed fission products from ’61, and full 

radionuclide coverage established in 1967. It 

says that the TBD does not provide sufficient 

evidence for estimating internal dose for the 

pre-’67 period for many radionuclides. And 

SC&A has said that once the mass-loading model 

is approved that we as a working group would 

get this back for comment. 

Is that correct, Mark? 

MR. ROLFES: Yeah, this issue can be 

resolved by the mass-loading model as well. 

So when we get that reviewed by the Advisory 

Board and SC&A, we’ll incorporate that into 
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the Technical Basis Document. We feel that 

will address this issue. 

DR. MAKHIJANI: Well, I didn’t understand 

that actually because the internal doses for 

the tunnel workers -- so the atmospheric 

testing thing is resolved by the SEC. 

MR. ROLFES: Yes, correct. 

DR. MAKHIJANI: The internal doses for the 

tunnel workers are more than resuspension 

doses, correct? 

MR. ROLFES: Uh-huh, uh-huh. 

DR. MAKHIJANI: Because you would be going 

in and working in a contaminated environment 

and exposed to tritium, for example, or a 

number of other radionuclides. And I don’t 

see how resolution of Comment 5 covers the 

internal exposure, which is an environmental 

dose, it covers the internal exposures for the 

workers in tunnels. 

MR. ROLFES: All right. We typically see 

for people that are entering -- I’m sorry, 

entering tunnels, we do typically see those 

are the people that are typically bioassayed. 

Those were obviously the people that were in 

higher exposure categories, both from external 
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dose as well as internal dose. And we 

typically see higher recorded results or more 

frequent positive doses for bioassay sampling 

with those people. 

Gene, do you have anything to add 

about the tunnel re-entry workers during this 

time period? Is my explanation an accurate 

one? 

MR. ROLLINS (by Telephone): The individual 

that was talking was breaking up a little bit, 

and we have several issues related to tunnel 

re-entry, but could you please restate what 

the concern is? 

MR. ROLFES: There’s a concern about 

unmonitored intakes, I guess, with the tunnel 

re-entry workers, and my explanation was that 

we typically see a larger portion of these 

employees participating in a bioassay program. 

MR. ROLLINS (by Telephone): That’s correct. 

MR. ROLFES: So these are the people that 

were in radiation zones that were, that had 

the potential for higher internal exposures, 

and hence, they were the ones that were 

monitored. 

MR. ROLLINS (by Telephone): That’s correct. 
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The security officers and the radiation 

workers. 

DR. MAKHIJANI: Well, the specific content, 

you know, as you look at the periods into 

which the comment is divided, it was that 

there wasn’t a full radionuclide coverage for 

the monitored people. So this comment was 

directed only partly at the non-monitoring 

which has been resolved by the atmospheric 

testing SEC. 

But for the underground testing it was 

directed not at non-monitoring but partial 

monitoring because there wasn’t full 

radionuclide coverage until 1967. So the 

thing, I guess, that I was looking for was 

what’s the guidance for converting, say, mixed 

fission product results which might be 

available to, into a dose. 

MR. ROLFES: Gene, correct me if I’m wrong, 

but in those cases where we have a person that 

was, say, bioassayed for gross fission 

products, I believe it’s our policy to use one 

of the most claimant favorable or the 

radionuclide that results in the highest dose 
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MR. ROLLINS (by Telephone): That’s correct. 

MR. ROLFES: -- of the potential 

radionuclides that might be encountered. 

MR. ROLLINS (by Telephone): That’s correct, 

and the same is for gross alpha. 

DR. MAKHIJANI: So I guess that’s guidance 

that, I guess that’s the thing that, that was 

the reason for the comment. 

MR. ROLFES: Okay, great. 

DR. MAKHIJANI: Is there some rule for what 

you do? 

MR. ROLFES: Yes, I do believe we have a 

description of that in the TBD. 

Gene, do we have directions to the 

dose reconstructor for --

MR. ROLLINS (by Telephone): We have those 

written in a document called “Approach to NTS 

Dose Reconstruction”. It’s my understanding 

that that text was going to be included in the 

next revision of the TBD. 

MR. ROLFES: Okay, great. 

MR. ROLLINS (by Telephone): And it 

basically provides instructions as to what the 

dose reconstructor should do when they come 

upon gross beta, gross gamma, gross alpha. 
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And we see that quite frequently at NTS, but 

we do have instructions, claimant favorable 

instructions as to how to handle those types 

of analyses. 

DR. MAKHIJANI: Okay, and we haven’t 

reviewed this, this is a separate document 

that we haven’t reviewed. 

MS. MUNN: I think that’s correct. But also 

much of this information is contained in 

Section Five of this new revision to the TBD 

that we discussed earlier that I haven’t had 

an opportunity to review myself. 

DR. MAKHIJANI: I think Gene said that it’s 

not in Section Five as yet. Did I understand 

that? 

MR. ROLFES: Correct. He said it’s --

MS. MUNN: It’s not. 

MR. ROLFES: -- like a dose reconstructors’ 

guidance document. 

MS. MUNN: That’s a different document. 

 MR. PRESLEY: Yeah, it’s a totally different 

document. 

 DR. WADE: Will that be included in the --

MR. ROLFES: Yes, it will be included in the 

revised Technical Basis Document. 
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Correct, Gene? 

MR. ROLLINS (by Telephone): Yes, that’s 

correct. 

 DR. WADE: So the Technical Basis Document 

will be revised to include these instructions. 

MR. ROLFES: Yes. 

 DR. WADE: At which case the Board can 

review and ask SC&A if it wishes to --

 MR. PRESLEY: Okay. 

MS. MUNN: Do you have any idea of when? 

Are we almost down to that? 

MR. ROLFES: Gene, how do we stand as far as 

the timing --

MR. ROLLINS (by Telephone): I think we were 

looking, the revision to Chapter Five is 

imminent. We have it mostly ready to go. It 

should not be very much delay from here. 

MS. MUNN: So that will include the workbook 

instructions? 

MR. ROLLINS (by Telephone): That’s correct. 

MS. MUNN: Thank you. 

MR. ROLFES: As we’ve been discussing 

already, I know that we do want to wait until 

we get a couple of comments from SC&A before 

we do approve the Technical Basis Document so 
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that we don’t have to go back and change an 

approved document once again. So we’d like to 

get as much done as possible before we approve 

a new document rather than going back and 

having to re-review it, update it and approve 

it again. 

MS. MUNN: Good. 

COMMENT 15: BLAST WAVE

 MR. PRESLEY: Comment 15 has to do with 

resuspension of radionuclides by the blast 

wave. Again, our response has to do with 

Comment 14, and I presume this is going to be, 

fit into the work going into Chapter Five of 

the TBD on this. 

MR. ROLFES: Yes, and we’ve indicated that 

the work is completed, and I think it’s --

Gene, I can’t recall. Has this been, 

is this in an approved Technical Basis 

Document, our response to the resuspension of 

radionuclides by the blast wave? 

MR. ROLLINS (by Telephone): The 

resuspension by blast wave we’re back into the 

atmospheric time period. 

DR. MAKHIJANI: This is no more an issue. 

DR. MAURO: I do have a question. We’re at 
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an interesting confluence of the 250 workday 

issue and the site profile. I know that as 

part of the 250 workday issue where this is an 

issue. And one of the things that’s happening 

is I believe NIOSH is looking into the new 

DTRA methodologies for estimating intakes. 

And that’s part of the process that’s going on 

right now with regard to the 250 workday 

issue. Now does that have any, I mean, is 

there a place where these two come together 

now all of a sudden? No. So the answer is 

no. So for the purpose of the site profile 

what I’m hearing is the issues related to 

exposures during above ground testing are 

just, even though their --

DR. MAKHIJANI: Internal, internal dose. 

DR. MAURO: Just internal dose, right, are 

completely off the table. I just want to make 

sure I understand that. 

DR. MAKHIJANI: Well, Mr. Presley, that 

would be my understanding that if there’s 

anything we covered in the 250 day, and we 

copy everything we do in regard to the Nevada 

Test Site to this working group. I mean, 

those, as I understand it, are our 
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instructions. 

MS. MUNN: That’s what I thought they were 

going to do. 

 MR. PRESLEY: So we can mark this complete, 

not an issue. 

DR. MAKHIJANI: Yeah, I think that’s right. 

 MR. PRESLEY: Okay, now, what about 16 then? 

DR. MAKHIJANI: It’s the same thing. 

 MR. PRESLEY: And it’s the same thing on 

that one. So we can mark this? 

Eighteen. 

DR. MAKHIJANI: Seventeen. 

 MR. PRESLEY: I’m sorry. 

MS. MUNN: That was, the TIB’s 18. 

COMMENT 17: INGESTION DOSES

 MR. PRESLEY: I’m sorry, missed a header. 

Investigate doses needed to better evaluate 

findings 11, 12, issues 5.5.6 and 5.6.5. And 

again, we go back to the mass-loading model. 

MS. MUNN: We have or have not revised OTIB18? 

MR. ROLFES: We have a --

MR. ROLLINS (by Telephone): OTIB-18 did not 

need a revision. OTIB-18 contains a 20 

percent addition for ingestion pathways. 
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DR. MAURO: John, maybe I can help out a 

little bit. OTIB-18 is a default method to 

reconstruct inhalation doses based on the 

maximum permissible concentrations that were 

in effect at the time, and the expectation 

that there was a health physics program in 

place. So basically it’s a default way to 

come up with a what we consider to be a 

realistic upper bound on the inhalation 

exposures. 

Now it was also included doses, okay, 

once you have an idea of what the inhalation 

exposures might have been, you could estimate 

what the ingestion dose is by a rule of thumb 

whereby if the rule of thumb is saying that 

the ingestion doses are 20 percent of the 

inhalation doses. 

And that’s based on certain 

assumptions that I believe are being 

revisited, mainly, inherent in that 

relationship is assumptions regarding the 

deposition velocity of airborne particulates 

from the air onto surfaces and the fraction of 

the material that might be on surfaces that’s 

inadvertently ingested. I believe that that 
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approach, we’ll call the 20 percent rule, that 

has been widely used and is continuing to be 

used is being revisited. 

Jim is here. He can probably help us 

out a bit. I don’t know if anyone else is 

familiar. I know it was revisited on behalf 

of Bethlehem Steel. Whether or not it’s being 

revisited on a more broad basis and a 

different strategy being applied for deriving 

ingestion doses, I guess that’s the question. 

The response here I believe is that 

you are adopting what I call the 20 percent 

rule, and that’s what you can plan to use. 

And that’s fine, but our understanding is that 

approach is being revisited, and whether or 

not you’re going to revise it for this 

application also is the question. It was 

revised at Bethlehem Steel, but maybe you feel 

that it doesn’t need to be revised here 

because it’s a different setting. I guess 

we’d like to hear a little bit more about 

that. 

 MR. PRESLEY: Well, we’ve got a note in here 

that says that this activity is contingent on 

the resolution of Comment 5. 
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DR. MAURO: Oh, I didn’t see that. 

 MR. PRESLEY: And I’m just wondering if 

that’s not one of --

MS. MUNN: Well, my understanding from the 

Bethlehem Steel discussion was that this OTIB, 

this particular issue, was one of the 

overarching issues. And because Bethlehem 

Steel certainly is not the only place where 

deposition is an issue. 

DR. MAURO: And they came up with a fix. 

Okay, so then what I’m hearing is that this 

aspect of the -- is filled, that aspect, the 

ingestion portion, really is going to wait 

until there is a facility-wide approach for 

dealing with ingestion? 

DR. MAKHIJANI: At this time I don’t think 

so. 

DR. MAURO: I’m not sure. 

DR. MAKHIJANI: As I remember -- this is 

also from long-time memory, but there was, 

because Bethlehem Steel had rolling only, part 

of the time there was an ad hoc model 

developed for that that accounted for mixtures 

of non-radioactive, increasing mixtures of 

non-radioactive and radioactive dust. 
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MS. MUNN: Very short periods of time. 

DR. MAKHIJANI: Yes, so the pure uranium was 

only once a month or twice a month, whatever 

the rolling was. 

DR. MAURO: That was part of it, but there 

was a more fundamental part which established 

an empirical relationship between what’s on 

the surface and what’s ingested. And it’s an 

empirical relationship which basically 

replaced the other method which started from, 

what’s in the air, the original, if you know 

what the dust loading in the air is, we’ll 

assume it’s five micron AMAB and will fall at 

a rate of .000. I remember the number, 7 5 

meters per second, and you somehow could get 

to what’s on the surface. 

MS. MUNN: That was to come from this. 

DR. MAURO: Yeah, so what I’m getting at is 

there is a, in my opinion, you’ve come up with 

a very sound approach. NIOSH has come up with 

a very sound approach based on empirical 

information. If you know what’s on the 

surface, you could predict what might be 

ingested which divorces itself from what’s in 

the air which is good. 
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Now my question is, is that, right now 

OTIB-18 doesn’t do that. In other words OTIB18 still has the old method imbedded. 

DR. MAKHIJANI: I think so. 

DR. MAURO: Yeah, so I guess that’s my 

question to NIOSH whether or not there’s any 

consideration to revisit that aspect of OTIB18 as it pertains to ingestion. 

MR. ROLFES: At this time I don’t think 

there is. If we have indication that 

ingestion was a larger player in internal 

doses, then I think it would be appropriate at 

that time to consider higher ingestion doses 

or higher ingestion intakes. I haven’t seen 

any indication of ingestion being a great 

concern. Typically, for internal dose 

reconstructions inhalation is the most 

important pathway and ingestion is a fraction 

of the internal dose concern in comparison to 

inhalation. 

MR. ROLLINS (by Telephone): This is Gene 

Rollins. A question for John. 

John, were you involved, we had these 

similar discussions for SRS. 

DR. MAURO: I’m not sure. We have had this 
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discussion before on other sites. I’m not 

sure whether it was SRS. 

DR. MAKHIJANI: Nevada Test Site is a little 

bit particular because of ingestion dose would 

be highly time dependent. 

MR. ROLLINS (by Telephone): I’m sorry, I 

didn’t --

DR. MAKHIJANI: Because ingestion doses 

would be highly time dependent, and you could 

have other than hot-particle doses, you could 

still have GI tract doses and so on that are 

very different than what you would, say, get 

in a place like Rocky Flats or Fernald or Y12. 

MR. ROLFES: I would agree that the 

ingestion doses might be important during like 

an atmospheric weapons test period when a 

person would be exposed to some of the shortlived fission products. 

DR. MAKHIJANI: How about re-entry? 

MR. ROLFES: Okay, that could be an issue, 

but for the majority of the claims that we’re 

seeing I don’t believe that the ingestion 

pathway is that significant. I really don’t 

see that many people being exposed to fresh 
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fission products where it would be an over, 

there’s not very many scenarios that I’ve seen 

that ingestion intakes and the internal doses 

resulting from those ingestion intakes would 

exceed that which we’re assigning from 

inhalation pathways. 

MR. ROLLINS (by Telephone): This is Gene 

Rollins again. I think the example that we 

did for Savannah River if I can remember it 

was we basically had someone standing on 

contaminated soil. We used the EPA typical 

ingestion, soil ingestion, and with the dose 

conversion factors, the calculation that we 

ran out showed that ingestion would typically 

be only one percent of the dose that you would 

expect from inhalation. 

DR. MAURO: I’m not disagreeing with you at 

all that ingestion is going to be a small 

contributor compared to inhalation. All I’m 

saying is the fundamental model that is 

currently in the OTIBs and many of the site 

profiles uses the .2 rule of thumb, not the 

approach that you just described, for example. 

But I think that in other words you’d 

basically be adopting something like 50 to 100 
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milligrams per day as a default ingestion rate 

which is an EPA number. But even that, as Jim 

has pointed out, has some deficiencies. All 

I’m saying is that I think that the -- it’s 

really a question -- I believe that the 

ingestion point portion of OTIB-18 that’s 

referred to here in your response, I believe 

that approach is no longer being used, or the 

intention is to no longer use that. It may 

still be being used in carryover because it 

has a certain amount of inertia, but I believe 

that NIOSH -- and this is really a question 

for NIOSH -- is there going to be a general 

change in approach for ingestion? 

MS. MUNN: That gets back to my original 

question. Have we made any revision to OTIB18? Because there’s been discussion about 

incorporating an entirely different approach. 

If we have not, then it seems to me this work 

group has to decide whether or not we would 

recommend that revision or whether we would 

recommend that NIOSH incorporate words in the 

TBD that Mark just gave us that justifies the 

utilization of the current process. 

MR. ROLFES: It sounds to me like it’s more 
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of a TIB-18 issue than a Nevada Test Site 

issue, and that’s, if the Advisory Board 

thinks it’s appropriate to review TIB-18 and 

the methodology used to assign ingestion 

intakes in TIB-18 that can be reviewed. But 

and then at that time we can apply it to 

intakes for Nevada Test Site, but I don’t see 

that that being a site-specific or a site 

profile issue right now. 

 MR. PRESLEY: Well, that’s more of a general 

issue. 

DR. MAURO: OTIB-18 is on the agenda for as 

one of the procedures that will be, we didn’t 

review it as part of our last round of, in our 

procedure reviews. So it’s sitting on the 

shelf, on your shelf, but we have not yet had 

an opportunity to have a working group work 

that particular set of procedures. And I’d 

like to add that OTIB-18 is going to be a very 

interesting one where there’s going to be a 

lot to talk about because it’s come up time 

and again. 

 MR. CLAWSON: I thought this was kind of 

part of the overarching issue. 

DR. MAURO: It is an overarching issue. 
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MS. MUNN: That puts us back in the same 

area we brought up this morning. 

 MR. CLAWSON: That’s why we brought up OTIB18 to be reviewed by SC&A after it being 

completed. 

DR. MAKHIJANI: In the review -- I’m just 

going back to see where these matrix entries 

came from in our review. And on page 47 

there’s finding 11 on soil ingestion pathways 

in which we affirm for the most part what Mark 

and Gene have been saying is right, but for 

the higher actinide plutonium and so on, your 

uptake from the gut is so small that 

inhalation will dominate the dose. 

But because you have a mix of 

radionuclides not confined to higher actinide, 

some radionuclides could have greater bioavailability from the gut. And in those cases 

it’s a competition whether inhalation would 

dominate or ingestion would dominate. 

And I think, I mean, the comment is in 

the context that there may be a crossover for 

some radionuclides, not higher actinides, that 

needs to be evaluated. And so as I said there 

is a site-specific aspect to the Test Site for 
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the ingestion comment because of that problem. 

Because normally you wouldn’t see 

ingestion dominating, but we raised the 

question that in the case of some 

radionuclides, it may dominate. We didn’t do 

the calculations. 

MR. ROLFES: I’m trying to picture a 

scenario when ingestion might be a larger 

contributor, and I can’t think of anything 

other than during like an atmospheric testing 

time period. 

DR. MAKHIJANI: Cesium. 

MR. ROLFES: Cesium, okay. 

DR. BEHLING: The only thing it doesn’t have 

to be metabolically significant. For 

instance, in the case, and I did a lot of dose 

reconstructions in the Marshall Islands. The 

bulk of the GI tract dose was due to the 

simple passage of the bolus as opposed to the 

metabolic uptake. So you have to be careful. 

It doesn’t have to be soluble as long as it’s 

there and doing, and usually it’s the colon or 

rectum that is the limiting tissue, the 

epithelial tissue. So it doesn’t have to be 

metabolically taken up to deliver a GI tract 
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dose. 

DR. MAURO: For a GI tract cancer, this 

might be a limiting pathway. 

DR. BEHLING: And also we would raise the 

question about the relationship between 

inhalation dose because if the pathway is one 

of simple transfer, you can have radioactivity 

on the table here, and without resuspension or 

dust loading, the intake from transfer from 

surfaces to your mouth has nothing to do with 

the air. And so the blanket assumption of the 

20 percent value has no relationship to 

transfer from surface contamination to 

airborne inhalation. There’s no connection 

really. 

DR. MAURO: I think that’s what we’re saying 

is that I think it’s been accepted that there 

are circumstances under which the 20 percent 

rule doesn’t work. And when that happens --

DR. MAKHIJANI: We did that for Bethlehem 

Steel. 

DR. MAURO: And we did that there, and there 

are other places. This might be one of them. 

In my opinion I think we would be best served 

to deal with this when we get to OTIB-18. 
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This is going to apply across the board to 

everything. 

DR. MAKHIJANI: Including GI tract for these 

specific --

DR. BEHLING: Especially if you talk about 

neptunium which has a 2.6 day half-life. 

It’ll have no metabolic value because it’s too 

short-lived. Usually the bolus will have a 

transit time to the GI tract of about 48 hours 

which is already approaching the half-life of 

neptunium. So you have to be careful in not 

excluding non-metabolic active nuclides. 

MS. MUNN: Hans, do I hear you saying that 

the in vitro information data that we have 

then is --

DR. BEHLING: Yeah, you won’t measure, for 

instance, if the material isn’t taken up, a 

subsequent whole body count days later will 

not reveal anything that’s already been 

excreted. And so --

MS. MUNN: I’m thinking about fecal samples 

and urine samples. But even though you passed 

the half-life, you still have detectable 

quantities there. So it seems to me that 

perhaps what we’re discussing may be a little 
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bit academic if you have in vitro analyses. 

DR. MAURO: There’s empirical data that 

establishes the robust relationship between 

what’s on surfaces and what’s ingested. And 

that’s been documented. Jim’s documented it. 

And I think it probably applies here. 

DR. BEHLING: In vitro if you incorporate 

urinalysis, you will not see. So for 

urinalysis to be indicative of an uptake, you 

have to decide what has to be metabolized. In 

fecal samples the only other option for in 

vivo analysis that would reveal a transitory 

exposure that is not metabolically involved. 

MR. ROLFES: When you’re referring to 

cesium, you had mentioned cesium would be one 

of those contributors for ingestion of --

DR. MAKHIJANI: Cesium would be taken up. 

MR. ROLFES: That’s exactly the point --

DR. MAKHIJANI: You’re talking about things 

that pass through. 

DR. BEHLING: Yeah. 

DR. MAKHIJANI: This may be more important. 

DR. BEHLING: Especially when you’re talking 

about oxides of, high temperature oxides that 

are inside of a definition, the transuranics, 
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one anyway. 

 MR. PRESLEY: Can we go ahead and say then 

that we’re going to wait on OTIB-18 review to 

discuss this? Because right now I don’t see 

us going anywhere. 

DR. MAKHIJANI: Well, OTIB-18 has to be 

revised before it can be reviewed. I think. 

 MR. PRESLEY: John’s going to have a --

OTIB-18. 

DR. MAURO: And this is part of the concern. 

So eventually we’re going to get there. But 

maybe that’s the best place to do it. 

 DR. WADE: There is a work group that, well, 

Wanda’s the Chair on Procedures Review, so 

that --

DR. MAURO: We’re going to get there. 

 DR. WADE: -- your review of OTIB-18 should 

come before that work group. 

 MR. PRESLEY: What I’ve got here is awaiting 

OTIB-18 review on this subject. 

COMMENT 18: ORAUT-OTIB-0002 

Recommended use of OTIB triple O two 

for post-1971 tunnel re-entry workers, and I 

have this marked as complete. When we get the 
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Technical Basis Document, we are to review it 

for completeness. Is that -- Anybody have any 

comment on this? 

MR. ROLFES: I think the issue that we had 

just been speaking about, number 17, can be 

addressed by the application of OTIB-0002 

intakes. I think this --

DR. MAKHIJANI: Inhalation intakes. 

MR. ROLFES: Well, inhalation as well as, 

well, this is inhalation intakes but you’re 

referring to ingestion. I apologize, so thank 

you. 

MS. MUNN: And I have a question about the 

wording of that comment. When I read that 

second sentence, I wasn’t sure what I was 

reading. It’s use may not be satisfactory 

even with restrictions. For instance, for 

reactor testing and? or? early re-entry 

workers? I wasn’t really --

DR. MAKHIJANI: No, this, the early re-entry 

workers involved in reactor testing, not and. 

MS. MUNN: Okay. So for early re-entry 

workers involved in reactor testing. 

DR. MAKHIJANI: Right, this was, that 

comment was too compressed from the finding. 
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MS. MUNN: I looked at that and couldn’t 

make sense of it. 

DR. MAKHIJANI: I guess basically NIOSH 

agrees with the comment, right? 

MR. ROLFES: We feel that the intakes that 

we’re assigning are bounding intakes. 

However, I think it was a concern about the 

discussion of dates associated with TIB-0002. 

Now, TIB-0002 had some information in it 

precluding its use prior to 1970, I believe, 

unless there’s specific justification within a 

dose reconstruction. And I think that the 

issue was more along those lines, but wasn’t 

necessarily a technical issue. It was more of 

an issue with what had been documented in TIB0002. But I believe --

Gene, could you comment on that, Gene? 

How did we resolve that --

MR. ROLLINS (by Telephone): I believe the 

original concern was that OTIB-0002 was being 

used prior to 1971 where there was specific 

instructions within OTIB-0002 that said not to 

do that. So what we have done is added 

information into the Technical Basis Document 

that says basically you must follow all 
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restrictions of all TIBs, OTIBs, and that 

includes OTIB-0002. And so what we’re doing 

more of now is applying OTIB-18 to those 

situations as opposed to OTIB-0002. But we 

have added those cautions to the TBD. 

MS. MUNN: So are we okay, Arjun? 

DR. MAKHIJANI: Yeah, I think that’s fine. 

MS. MUNN: We’re done. 

DR. MAKHIJANI: If this was just a 

procedural comment that restrictions are not 

being followed so if there’s guidance that it 

should be followed, then it’s resolved. 

 MR. PRESLEY: What I had marked on this 

then, this item is complete, and we should see 

OTIB-18. Is that correct? That should take 

care of that. 

COMMENT 19: PRE-1966 BETA DOSE 

Nineteen, there are no beta dose data 

until 1966. The Technical Basis Document does 

not specify procedures for estimating pre-’66 

beta dose. And again, we have marked that 

work complete, and the working group will 

review for completeness. 

Mark, do you have anything? 

MR. ROLFES: I believe this is in our 
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approved Technical Basis Document now. We 

have some, I think, SC&A had recommended some 

specific -- I’m trying to recall the 

gentleman’s name, the author of the document. 

Was it -- it started with a B. There was a 

document that you had referred us to, and I 

believe we --

DR. BEHLING: And I think that the person 

involved was the person who was doing dose 

reconstruction for DTRA? 

MR. ROLFES: Yes, that’s correct. I can’t 

think of the gentleman’s name. It starts with 

a B. 

DR. ROESSLER: John (unintelligible)? 

DR. BEHLING: No, he recently published an 

article in Health Physics Journal that talks 

about the relationship between beta dose and 

gamma dose various distances above the 

contaminated surface. And much of that work 

involves the Pacific Proving Ground dose 

reconstruction for beta. Neal Barrs (ph). 

DR. ROESSLER: Barrs, yes. Yes. 

MR. ROLFES: But anyway I do believe we have 

incorporated some methodology based on the 

Barrs’ reference into the approved Technical 
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Basis Document which is now available on the 

website, too. 

MR. ROLLINS (by Telephone): That’s correct. 

That went into Attachment C. 

 MR. PRESLEY: This item should be complete. 

Is that correct? 

MR. ROLFES: That’s correct. 

 MR. CLAWSON: That’s still got the hot 

particle issue, but we’re taking care of that 

and OTIB’s taking care of, it’s --

DR. MAKHIJANI: This is in volume six. 

MR. ROLFES: Gene that’s -- yes, correct, 

volume six. And that was added as part of the 

page change I believe with the dose table that 

we inserted as well. 

DR. MAKHIJANI: Is this covered by the 

earlier kind of that we take care of, review 

the page change or not, review the page change 

or --

MR. ROLFES: You’ll be reviewing the page 

changes I believe. So this is part of the 

page change that was made to the Chapter Six 

of the Nevada Test Site TDB. 

COMMENT 20: INTENTIONAL NON-USE OF BADGES

 MR. PRESLEY: Item 20, one of their more 
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popular items. 

MR. ROLLINS (by Telephone): Actually, Mark, 

let me qualify that. Actually, the 

Attachments A, alpha through delta, they went 

in as Revision 1-A. 

MR. ROLFES: Okay, so it was prior to the 

page change. 

MR. ROLLINS (by Telephone): Well, it’s 

dated September 8th, 2006. 

MR. ROLFES: Okay, so it’s been out there 

awhile then. 

MR. ROLLINS (by Telephone): Correct. 

DR. MAKHIJANI: So I guess, Mr. Presley, I 

guess we need a specific direction from you 

whether to leave it because this is different 

than the page change. Direction from you as 

to whether to leave it alone or review it. 

MS. MUNN: Well, I guess it would be a good 

idea for you to agree if this has not been 

resolved adequately to your --

DR. MAKHIJANI: Yeah, one of the, the 

original comment was that there were no beta 

monitoring data at all until ’66. So I think 

it’s a pretty big issue in terms of gaps in 

monitoring specially for skin cancer. And so 
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I think in my just, from a technical point of 

view -- and the working group may want to 

review it by themselves. But I think someone 

should look at what NIOSH has done in regard 

to addressing the skin dose. 

MS. MUNN: I agree, yeah, and in my view 

SC&A ought to review that. Is there any 

reason why not? 

 MR. PRESLEY: I have no problem with that. 

When can we expect a review on this back to 

the working group? 

DR. MAKHIJANI: Mr. Presley, can I consult 

with John on that tomorrow and get back to 

you? It should not be long because I think we 

have people who can review external dose 

fairly straightforward. 

 MR. PRESLEY: Lew, is this within the 

guidelines? 

 DR. WADE: Yes. 

 MR. PRESLEY: Okay. I’m going to put on 

here that SC&A will review. 

DR. MAKHIJANI: Yes, and I’ll get back to 

you with a suggested deadline to see if it’s 

acceptable to you. 

 MR. PRESLEY: Okay. 
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 MR. CLAWSON: I guess I’m a little confused 

here. When SC&A has brought up this issue and 

NIOSH has changed it, I thought in the process 

that we would automatically review the 

comments that came back on that to agree or 

disagree. I guess I’m wondering how it got 

changed to that document. We haven’t reviewed 

it. 

DR. MAKHIJANI: Well, I wasn’t, you know, 

each working group has adopted a, you know --

MS. MUNN: Slightly different --

DR. MAKHIJANI: -- different, and so I, and 

this discussion has come up before as to 

whether we’re doing things that have been 

explicitly authorized by the working group. 

So I just wanted to be sure that if NIOSH has 

made changes corresponding to our comments, 

that if the working group wants to review 

those changes themselves, I mean, that’s 

clearly your prerogative and then we wouldn’t 

be involved. But if, since the issue has come 

up, in the beginning we just automatically 

reviewed everything and resolved comments. 

Like at Bethlehem Steel I think we did that. 

But in Rocky Flats there were some issues that 
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came up as to whether we’d been explicitly 

authorized by the working group to do some 

things. And so I thought it better not to 

proceed until we received authorization from 

the working group. 

 DR. WADE: There are two issues. Brad, I 

think, may be even raising a slightly 

different issue. If, in the course of the 

work group process, NIOSH hears that there 

needs to be a change to a site profile, NIOSH 

can go ahead and make that change, and then 

the Board review the change. 

It’s also possible in some cases we 

had this morning, that the work group might be 

reviewing drafts that NIOSH is proposing 

before they’ve actually made the change. And 

it happens both ways. I think NIOSH does what 

it thinks it needs to do expeditiously so that 

the dose reconstruction can proceed as 

appropriate. 

In some cases that might mean there’s 

a TBD change that the Board has to review 

after the fact. And the Board can do that and 

then comment and NIOSH might have to modify it 

again. In some cases they’re reviewing it as 
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a draft. We haven’t decided that one 

methodology is preferable to the other. It 

really just depends upon the timing. 

 MR. CLAWSON: And I know that each one of 

these sites has their own little special twist 

to it, and I know how difficult it is. But it 

seems like to me that when SC&A makes a 

comment, and there’s an issue and NIOSH 

addresses this issue, that there ought to be 

something, they ought to be able to review 

before it gets put into the TBD. 

 DR. WADE: That has not always been the way. 

And again, it’s a matter of --

 MR. CLAWSON: How we’re doing. 

MS. MUNN: How straightforward is it? 

 DR. WADE: How straightforward, and again, 

we want to move forward and see the dose 

reconstructions are done correctly and now 

hold that process up while we go through this 

process. So in some cases the cart is before 

the horse. In some cases it’s the other way 

around. In any case if the work group decides 

that NIOSH’s modification isn’t sufficient, 

then NIOSH will have to modify it again. 

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 MR. PRESLEY: Twenty, like I said, is our 

non-use of badges. NIOSH had a response that 

says coworker -- sorry about that. 

Mark, have you got the one’s that got 

the, y’alls --

MR. ROLFES: Yes, yes, I do. 

 MR. PRESLEY: Go ahead. Let me get my 

computer back up. 

MR. ROLFES: I can discuss this a little 

bit. If we encounter, we really didn’t have 

an approach to assign any kind of dose to a 

person that could have been unmonitored or 

intentionally took off their badge because 

they were asked to do so. Now in our review 

you would have had to have had someone that 

was approaching an administrative dose limit 

or a regulatory dose limit and that would 

really be the only reason for someone to have 

to work in an area. 

I’m sorry, yes, if you have a person 

that’s approaching the administrative dose 

limit, that would really be the only time that 

I could imagine a person would be asked to 

take off their badge. 

MS. MUNN: What if they would opt to take 
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off their badge? 

MR. ROLFES: Right, but these are a case-bycase type of situation that we would have to 

look at the work that was being done, the 

amount of dose that the person was routinely 

receiving in this job category. And we’d have 

to go into the records, look through that case 

specifically in order to make a determination 

whether someone could have been in such a 

situation where they were approaching 

regulatory dose limit or would have been in a 

situation where they were asked to remove 

their badge. 

Then in that case we have an approach 

to address any unmonitored dose that they 

could have received. And we can add the 

coworker dose tables that we received in, I 

believe the current page change only accounts 

for the time period prior to universal badging 

which was in April of 1957. So we can extend 

those dose tables from 1957 forward if 

necessary. 

 MR. PRESLEY: I think that that would be 

necessary. 

MR. ROLFES: Okay. 
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DR. MAKHIJANI: There were, I don’t know 

whether NIOSH checked the couple of people who 

spoke before the Board on specific instances, 

publicly, about their own pains, and whether 

their cases were checked for problems. 

MR. ROLFES: I don’t know what I can say as 

far as Privacy Act concerns are, but I have 

looked into some cases. And from an external 

dose standpoint I haven’t seen this issue. 

I’d be happy to discuss a specific claimant’s 

scenario outside of this conference call if 

necessary. I’m not sure exactly what 

precautions I need to protect. I don’t want 

to discuss someone’s specific case right now. 

 DR. WADE: If you’re talking in generalities 

as you are, that’s fine. 

MR. ROLFES: Okay, all right. I don’t know 

if I get into speaking about the types of dose 

and the job categories and such without 

mentioning a person’s name. I’m not sure if I 

would be --

 DR. WADE: Well, you’ve looked at individual 

claims that have been raised that this 

practice took place, and you’ve seen no 

evidence in the data to support that? 
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MR. ROLFES: As far as the, I’ve seen 

certain workers exceed dose limits, but they 

were not external dose limits. It was a 

combination of both external as well as 

internal dose. And that’s a different 

scenario than what we are discussing here. 

This is related, this Comment and our response 

is related only to the external dose that a 

person would have received. I can answer this 

offline if we’d like to go into a discussion 

of a specific claim. 

DR. MAKHIJANI: But actually, you don’t 

expect, it’s the opposite of what you said, 

you don’t expect to see external dose exceeded 

because the claim is that people took off 

their badges when they were approaching the 

limit. They were told to, or decided 

themselves, that they wanted to do that. And 

I thought that NIOSH was going to develop 

some, look into the data to see if there were 

cases where people that, where there were many 

people, say, in certain situations like tunnel 

work or ground zero entry work or certain 

kinds of work, were approaching dose limits 

and then did not overstep those dose limits. 
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I thought that that was --

 DR. WADE: Is that what you remember? 

DR. MAKHIJANI: -- if I remember correctly, 

that was the action item that was to be done. 

And apparently, that was not deemed feasible. 

I don’t know how to read this. 

 MR. PRESLEY: I’ve got TBD work completed on 

this thing. 

MS. MUNN: It was my understanding that 

these specific cases were going to be looked 

at individually to see whether it was feasible 

to assume that any claim of removed badge 

looked realistic. I don’t know how else you 

can approach it. When the claim is before 

you, then that’s one of the items that must be 

addressed. 

 MR. PRESLEY: I don’t think that you can go 

out here and paint a big old picture with a 

paintbrush and say we’re going to do the whole 

group this way at all. It has to be 

individually taken into consideration. 

MR. ROLFES: It depends on the specific 

case, the scenario, the job category of the 

worker, the job being done, the time period. 

There’s many factors that would be very 
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difficult to encapsulate, I guess, every 

unique scenario within a broad guidance 

document that we’re using. These issues are 

related to specific claims that need to be 

evaluated carefully on a case-by-case basis 

rather than as a large guidance document 

that’s attempting to cover thousands of 

people. 

 DR. WADE: And so one logical approach would 

be to identify the pattern that you would 

expect to see if this practice was to take 

place. If that pattern is identified, then 

there are methodologies used to assign this 

dose. 

MR. ROLFES: Sure. 

 DR. WADE: So that’s what you’re doing? 

MR. ROLFES: One might expect that if a 

person were to take off their badge, they 

obviously wouldn’t do it if they only had, 

say, 50 millirem recorded for that -- we would 

expect to see this if it occurred at a person 

that, say, had 4,900 millirem and was trying 

to stay below five rem per year. If we have 

indication that a person was approaching a 

regulatory dose limit, then at that time if we 
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have indications that the person was not 

wearing their badge into a radiation zone, and 

they were doing the same job that they had 

previously been doing when they received that 

large amount of dose, then we would need to 

address that in some manner. 

DR. BEHLING: I think you can really only 

approach that with a CATI report statement 

that says I was asked to do this or even I may 

have voluntarily done this. Because in the 

absence of such a statement you don’t know if 

the person was perhaps reassigned anywhere to 

avoid this overexposure in which case there 

was a legitimate reason for him to approach 

the dose limit or admin limit and not exceed 

it. And for all the right reasons he didn’t 

receive it because a supervisor said you’re 

off the job for the duration. 

MR. ROLFES: And even for a person that’s 

monitored, a person, an individual, is not 

going to know when they are approaching the 

administrative limits. They’re not going to 

be able to --

DR. BEHLING: Well, they could know if they 

used concurrent air ionization chambers that 
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they carried with them, and in those days they 

used to track it that way so as to monitor 

throughout the wear period where they are in 

order to, if there was a quarterly, there was 

a time when there was three rem per quarter, 

they might have been only assigned a quarterly 

badge. 

But they were tracking it by way of a 

pocket air ionization chamber and thereby 

realizing that as they’re approaching the 

limit, you may have to take this person off 

this particular job and reassign them. Or as 

some of the claimants, might be right. They 

might have simply said take off your badge. 

But it would have to be indicative of comments 

made in the CATI report that would legitimize 

that particular issue. 

DR. MAKHIJANI: The difficulty I’ve always 

had with this at the Nevada Test Site issue 

compared to, say, a general statement is the 

following. So there’s been this kind of 

allegation at many sites, and this has been 

brought up, but I think there’s some 

particularities at the Nevada Test Site that 

are very special that I don’t feel are being 
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captured by this discussion. And that 

particularity is that the senior health 

physics staff have independently said that 

this happened. 

So in both sets of interviews which 

were done, that we did, it came up 

independently. So the interviews that Kathy 

and Tom Bell did, apart from what I did, it 

came up. And then in the interview that I did 

it came up independently. The documentation 

about employment practices with references to 

the documentation at the time shows that there 

was economic incentive. 

And then the usual, what we normally 

call allegations or assertions in a CATI or by 

claimants that this was happening which may 

require more proof actually supplemental to 

that. So they’re happening in a different 

context than, say, somebody giving an 

affidavit saying my supervisor asked me to do 

this. And then you wonder whether you can 

accept that. So here you’re starting from 

documentation about employment practices and 

interviews from senior health physics 

personnel. 
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So I think if interview data from 

health physics personnel such as at Rocky 

Flats is to be accepted when there is no 

documentation, for instance, we know that 

large quantities of magnesium-thorium alloy 

did not arrive at --

MS. MUNN: Were not there. 

DR. MAKHIJANI: -- okay, there’s no 

documentation. So we have contrary 

information actually, but it’s senior 

management, and we’re leaving it there. 

MR. ROLFES: Uh-huh. 

DR. MAKHIJANI: Okay. So that’s a problem 

that I’m having with this is if this is not to 

be accepted as having occurred in a fairly 

pervasive manner, at least for certain groups 

of workers that were at high risk, not for 

everyone --

MR. ROLFES: We’re not saying that it didn’t 

occur, but it would be very limited. 

DR. MAKHIJANI: That’s the thing I’m 

questioning. These certain groups of workers 

were represented by claimants were in 

situations that can verify were at risk of 

high exposure like to the workers at ground 
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zero. And these are the same workers that 

we’re considering in the less than 250-day 

question for atmospheric testing that also 

applies. 

For this group of workers I think it’s 

very hard for me to think of rejecting, or not 

accepting this as a base hypothesis without 

some justification that somehow the senior 

health physics personnel here are different 

than the senior personnel elsewhere whose sort 

of verbal memories and expert testimony we 

accept generally when there’s no contrary 

evidence. So I think it’s going to raise an 

issue of consistency that’s pretty serious. 

MS. MUNN: But it seems to me that there’s 

no rejection of the senior health physicists’ 

comments. Item 2 here in the response under 

Response 20 is key. That cohort dosimetry is 

probably not available because the entire 

cohort is likely to have adopted the same 

practice at the same time. 

That’s essentially the type of thing 

that the senior health physics staff was 

relating. That being the case what this 

response says, I believe, is that in those 
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cases where this is a possibility, you have to 

be particularly careful because you don’t have 

cohort information that you can rely on. It’s 

doubly important that you look at the 

individual case and the circumstances 

surrounding it. 

Am I misinterpreting what I think I’m 

reading? 

MR. ROLFES: We’re not saying that this 

practice didn’t occur, and I don’t want to 

imply that in any manner. It very well could 

have occurred. And if we have health 

physicists saying that it occurred, people 

that were in a position to know that this 

occurred, then we accept that. 

However, we need to look at on a caseby-case basis, there would be no reason for a 

person to remove their badge if they weren’t 

approaching some sort of regulatory dose 

limit. There simply wouldn’t be any reason to 

remove their badge if they’re not going to 

exceed dose limits. I could understand if the 

badge was going to get damaged, they might 

have a replacement badge or a temporary badge 

to use. 
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But what we would need to do is to 

look to see, on a case-by-case basis, if a 

claimant had dosimetry that was approaching 

regulatory limits. And in that case if a 

person said that they removed their badge to 

do the work because they were approaching dose 

limits, then we would need to address that for 

that case. 

DR. MAKHIJANI: Well, I think -- there are a 

number of issues there. (A), you don’t always 

know when you’re very close, and so you’re 

going to have a problem of what’s close. Is 

it 4.9 or in the case of three rem per quarter 

is it 2.8 or is it 1.9 or what it is. 

Secondly, most of the claimants are 

survivors. You cannot discover this 

information in a CATI. There are rare cases 

where a claimant -- and there are cases where 

a survivor claimant is thoroughly well 

informed, and they have presented to the Board 

in public meetings. But for the most part and 

from what I understood from interviewing, 

talking to lots of claimants and survivors is 

that they have no clue what went on in the job 

generally, much less into the details of the 
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practices. 

So I think if you accept that this 

practice happened, then the guidance doesn’t 

correspond to, and, you know, to some extent 

this is a generic issue because the question 

of survivors from our procedure review has 

never really been addressed because NIOSH has 

said we can’t do anything about this inequity. 

And now we’re confronting it in a very 

specific situation where that item which was 

resolved supposedly by NIOSH by saying we 

can’t do anything about this inequity, you 

know, that life is not fair. And now we have 

a situation where you’re saying that, you’re 

relying on the CATI for dose reconstruction 

when in most cases you can’t discover the 

information in a CATI. 

MR. ROLFES: That’s not necessarily true 

because if we see someone, if their dose of 

record is routinely approaching the 

administrative limits or the regulatory 

limits, that would be something that would be 

a flag to us to say, well, this is one of the 

individuals that might have been affected, 

might have been asked to remain in the 
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radiation area and continue work on the job to 

get the job done. And I understand. I have 

heard accounts during the time period right 

before the, excuse me, in the late ‘50s right 

before the test ban -- I’m trying to think --

DR. MAKHIJANI: The moratorium. 

MR. ROLFES: Yeah, the moratorium, thank 

you. 

Right before the moratorium we were 

rushing to get in as many tests as we could. 

And so there was a limited number of staff 

that were able to complete the job. And so we 

did have some staff at Nevada Test Site or 

some of the employees go in, and there were 

some people that exceeded the regulatory dose 

limits, combined regulatory dose limits. 

And that is very well documented 

within those people’s files. So I haven’t 

seen any cases where a person has routinely 

been approaching those regulatory limits and 

has no documentation. Like I said, it’s a 

case-by-case basis that we would have to look 

at. 

Gene, are you on the line there? Do 

you have anything to add to this discussion? 
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 (no response) 

MR. ROLFES: No? 

 DR. WADE: So if you were to see a worker’s 

file that had a worker approaching a 

regulatory limit, and then there is no data, 

then that’s a pattern that should, in our 

mind, signal the fact that this could be a 

case where someone was told to or volunteered 

to remove their badge. And then you would 

have to generate dose for them using some 

methodology. 

MR. ROLFES: Yes. 

MS. MUNN: Especially if this individual 

were a worker who received consistently high -

-

MR. ROLFES: Exactly. 

MS. MUNN: -- near limit doses and previous 

or following --

MR. ROLFES: That would be something that 

would trigger us. 

MS. MUNN: -- periods. 

MR. ROLFES: Exactly, that’s a very good 

point because that would be what we would look 

for in a dose reconstruction or in someone’s 

DOE dosimetry. We would have to look for 
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someone that was routinely receiving five rem 

per year or whatever the administrative 

control was at the time. That would be the 

indicator. If we routinely saw someone that 

was receiving 4.9 rem each year, and they 

indicated that they had been asked to remove 

their badge in order to continue working or 

get the job done, that would set up a flag to 

us when we do a dose reconstruction. 

 DR. WADE: Mark, just let me stop you there. 

Even if they didn’t say they removed 

their badge, if you see this pattern develop, 

and it’s a survivor, then you have reason to 

say this could have happened. And then you 

need to take appropriate steps to assign dose. 

MR. ROLFES: Yes, uh-huh. 

MS. MUNN: The individuals who would be most 

likely to fall in that category would be the 

well-trained individuals who were trained for 

those specific jobs and who would be 

anticipated as the leaders in that activity. 

You would not send an untrained worker who had 

no idea what was going on in to do one of 

those setup jobs or for that matter follow-up 

jobs. 
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DR. MAKHIJANI: So then what do you do? You 

don’t have coworker data, and you don’t have 

the worker’s data. 

MR. ROLFES: Well, we do have coworker data, 

this datasheet. And that’s what we’ve 

proposed is to add this table. Right now our 

page change revision to Chapter Six only 

incorporates the years from 1951 through April 

of 1957 because that was the time period that 

universal badging was not in place at the 

time. Now, we have data from ’45 all the way 

up through ’83 on this sheet, but I do believe 

’83 forward is available to us as well. And 

there are indications of individuals, let’s 

see, in 1962 there’s individuals, there were 

15 individuals that received in between five 

rem and 7,500 millirem during 19 --

DR. BEHLING: Would you conclude that some 

of those people may have been guilty of this 

issue? And my experience has been the people 

who are most prone to do this are contract 

workers who are being potentially washed out 

from overtime. That used to be the biggest 

incentive. They wanted work to come to an 

outage. They wanted to work as many hours, 
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60, 70 hours a week, and in order to avoid 

being washed out they’ll take off their badge 

or do something. And unfortunately, those 

cases you don’t have any documentation because 

it was a voluntary decision on their part as 

opposed to a supervisor. In other cases there 

may be a supervisor who encourages. 

 MR. CLAWSON: And that’s true, Hans, because 

we’ve got to look at this, and we’ve got to 

look at the mindset of the people. You talk 

to any of the survivors or whatever like that, 

and they feel that they were as much at war as 

anybody. And for them to be able to complete 

this, as the gentleman that gave us the tour, 

I’m not going to let my badge get in the way 

of me completing. 

MS. MUNN: Yeah, this is the job I had to 

do. 

 DR. WADE: So there are two parts to it. 

One is you have to identify where this might 

have happened, and then Arjun’s question, what 

do you do about it. 

DR. BEHLING: Yeah, what do you do about it. 

 DR. WADE: And those are your questions that 

have to be answered. 
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DR. MAKHIJANI: The problem you have, you 

know, even accepting your first part of your 

diagnosis which I really have some problems. 

But accepting that for the moment, the problem 

you have when you have a set of data where 

your highly exposed workers tail off, and 

there’s a piece of the exposure that you don’t 

know for the whole cohort, you have no idea 

what the upper limit is, because you can’t 

fill that. By definition you look at your 

Item 2 in their own statement, or dosimetry 

probably not available. That means whatever 

coworker data you have, the high doses among 

that will share this limitation so you can’t 

fill the gap. So this --

MR. ROLFES: That’s very possible. We don’t 

know that for a fact though. 

DR. MAKHIJANI: No, we do know that for a 

fact because it arises from the nature of the 

problem. We can define the problem. Maybe we 

cannot define the solution, but I think we can 

define the problem. If this was a pervasive 

practice, then, as you say, you’re not going 

to have cohort dosimetry for the very workers 

who are approaching their dose limits. 
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Whether, how you define approaching is a 

different matter and solvable. But by the 

very nature you don’t have a coworker database 

to fill that gap because it’s a systemic 

problem. It’s not an individual problem. 

 MR. PRESLEY: Can I say something. I’ve got 

to go. I’m sorry. I apologize. We scheduled 

this meeting for two o’clock. The only flight 

that I can get back is the one after four. 

I’ve got to get to the airport. We’ve beat 

this -- I hate to say it -- to death, and we 

can continue to beat it death for the next 

five or six years. 

What I would like to do is to ask Mark 

to come up with a solution to this from NIOSH, 

and let’s go back to SC&A with the solution. 

And we’ve done this half a dozen times, but 

there’s got to be a simple solution to this. 

The other thing is when you get all of 

the paperwork done to the OTIBs and to Chapter 

Five, I believe, could you make sure that the 

people on the working group all get a copy of 

that and the pertinent data that goes with it. 

And also send Arjun a copy? 

MR. ROLFES: Sure. 
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 MR. PRESLEY: And I would like to have that 

hard copied because there’s going to be a 

tremendous amount of it. 

MR. ROLFES: All right. 

 MR. PRESLEY: And that way we will have a 

copy. Everybody’s got the same thing, and 

then we will sit down and talk about a phone 

call maybe before our May meeting. 

Is that all right, Lew? 

 DR. WADE: Yes. 

 MR. PRESLEY: Try to come back with these 

issues, and I’m going to ask Brad to continue. 

I cannot miss this plane. I’ve got some stuff 

at home that I’ve got to do. 

DR. BEHLING: Can I make a recommendation of 

how you might want to look at the data? 

MR. ROLFES: Sure. 

DR. BEHLING: Obviously, the dose limits are 

usually defined by yearly limits, either five 

to the minus 17 for those that can go more 

than the five rem per year. And what you want 

to do is look at first quarter, second 

quarter, third quarter. If you see first 

quarter one rem or one and a half rem, and 

second quarter, and then as you approach the 
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regulatory limit, the questionable problem 

comes into play in the third and fourth 

quarter. 

And they realize they’re now 

approaching the (unintelligible). And so what 

I would do is look at high dose workers and 

compare first quarter. They’re doing the same 

job, hopefully. First quarter, second 

quarter, third quarter, and if you see 

something trailing off on the fourth quarter, 

all of a sudden there’s nothing and the guy is 

still on the job, then you have to be 

suspicious. 

 MR. ROLFES: Sure, exactly, I agree. 

DR. BEHLING: Because it’s usually a yearly 

limit that dictates whether or not you get 

kicked off your job in the third or fourth 

quarter. And this would be a trigger for you 

to say I think there’s reason to be suspicious 

here. 

 DR. WADE: For many triggers. 

 MR. CLAWSON: Actually, all I was going to 

say, Hans, is it would be more of a quarterly 

limit because I know I monitor --

DR. BEHLING: Yeah, a quarterly limit would 
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be then obviously also a trigger to --

 MR. CLAWSON: Now, if you come up and hit a 

plateau every quarter, it’s something to be 

able to throw up there. 

MR. ROLFES: Maybe that would be the best 

resolution to this, this is something that has 

to be done on a case-by-case basis. It’s not 

something that you can --

 MR. CLAWSON: Do for everybody. 

MR. ROLFES: Exactly. And so maybe what we 

should do is put a little bit of discussion 

referring to what you’re discussing -- I’m 

sorry, a little bit of description if a person 

does routinely receive say one or two rem on 

his badge each quarter, and then all of a 

sudden has zero dose, and he does indicate 

that he was removing his badge, then at that 

time then I think we should put some 

discussion in the Technical Basis Document 

that we’re aware of this practice that 

potentially occurred, and we will come up with 

some, an approach to address this. 

DR. BEHLING: The approach could be then to 

say, well, if he’s getting one rem every 

quarter and the fourth quarter is nothing, 
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say, well, you’re on the same job, the average 

of your previous quarters were --

 DR. WADE: The highest of the previous 

quarters. 

DR. BEHLING: The highest, it is a 

reasonable approach to filling in those gaps. 

MR. ROLFES: Yes, exactly. 

DR. ROESSLER: It would be interesting to 

note, too, how many people this might apply 

to. Is this a very pervasive situation or is 

it just two individuals? I mean, you can look 

at the records and look at some of the numbers 

and --

DR. BEHLING: It would only be the high dose 

workers. 

DR. ROESSLER: And I mean from my point of 

view, I’d be interested in knowing just what 

is the population that we’re talking about. 

DR. BEHLING: And it’s small. It’s small. 

DR. MAKHIJANI: It’s a minority. 

DR. BEHLING: As Arjun pointed out clearly 

the coworker data is exactly missing those 

people, and so you can’t rely on this. 

DR. MAKHIJANI: It’s clearly a minority of 

workers. 
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 DR. WADE: But there are three, so there are 

three things I think you need to do. One is 

you develop sort of a litmus test to say that 

this is a problem. And you know, Hans has 

talked about it. There are many logical 

models you could develop to say I think 

there’s something wrong here. So what are 

those? You can explain that to the working 

group and SC&A. 

Then the next question is what do you 

do about it. You don’t have coworker data. 

You give them high dose. How do you determine 

what high dose is to give them. And then 

Gen’s question could you also then in that 

document share, from a statistical point of 

view, evidence you have as to how prevalent 

this might be based upon what you’ve looked at 

to this point. And I think then you may have 

a starting point to move on. 

 MR. CLAWSON: Okay, since Mr. Presley put me 

in charge, how about a break? 

MS. MUNN: I think that’s --

DR. MAKHIJANI: We have actually scheduled a 

meeting with a petitioner at three 

anticipating the meeting. Now we can call 
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them, but I think it’s going to be all very 

crazy. 

DR. BEHLING: And they may have already 

left, and you don’t want to disappoint them. 

DR. MAKHIJANI: Yeah, we meet them at three. 

So this is a --

 DR. WADE: How far do you have to go to get 

there? 

DR. MAKHIJANI: I think it’s about half an 

hour, 40 minutes. 

 MR. CLAWSON: Okay, can we conclude by 

adjourning this? 

 DR. WADE: We could adjourn. I think we put 

that action item on, and then I think you’d 

need to look at following up possibly with a 

phone call in the near future to finish this 

list. 

 MR. CLAWSON: So we’d need to finish 

Comments 21 through 24. 

DR. ROESSLER: Except for 23. 

MS. MUNN: We have five comments. 

DR. ROESSLER: Twenty-three we finished. 

 DR. WADE: And I think the work on 20 is 

important work, and then SC&A also has its 

task to begin to look at the page change and 
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the other work that’s been done. I think we 

can adjourn. 

 MR. CLAWSON: We can adjourn. 

MS. MUNN: Have we established a time for a 

phone call? 

 DR. WADE: Well, we better check with 

Robert. I’ll try and do that this week. We 

could do it, so the rest of you if you want to 

pick a time you’ll have to notify Robert. 

MS. MUNN: Why don’t we do that? 

 DR. WADE: Okay, let’s pick a time for a 

phone call. 

DR. MAKHIJANI: Sorry for the multi-tasking 

schedule. 

 DR. WADE: Okay, let’s look at an 

opportunity. Robert said before the May 

meeting. So let’s start with that as a 

solution space. 

MS. MUNN: What if we do, how about giving 

ourselves a couple of weeks and say the Monday 

after Easter, the 9th of April? 

 DR. WADE: Would that give you enough time, 

Mark, or do you want --

MR. ROLFES: I’m sorry, what was the -- I 

didn’t hear what you said. 
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MS. MUNN: The 9th of April? 

MR. ROLFES: Ninth of April. 

 DR. WADE: This would be a call to complete 

the matrix, so you really wouldn’t have to 

have anything done. 

MR. ROLFES: Yeah, I think that’s fine. I’m 

just trying to think. I do have some travel 

coming up in the next week or two and that’s 

what I was trying to think about. 

DR. ROESSLER: I have another conference 

call at noon. 

MS. HOWELL: The only thing about the 9th is 

that you have meetings here scheduled the 10th 

and 11th . If any of the Board members or Ray 

are traveling then on the 9th we could get into 

a problem. 

MR. ROLFES: Yeah, I do have a meeting on 

the 10th here. The Chapman Valve Working Group 

is meeting on the 10th . 

MS. HOWELL: And the subcommittee on the 

11th . 

MS. MUNN:

 DR. WADE:

 I’m traveling on the 10th . 

What about the 18th? 

MS. MUNN: What about the 18th? The 18th 

would be fine with me. That’s the day before 
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then. 

 DR. WADE: Right, there’s a Rocky Flats call 

on the 19th . 

MS. MUNN: Yeah, uh-huh, the 18th would be 

okay for me. 

 DR. WADE: Okay, 18th okay for you? 

 MR. CLAWSON: I will make it where it’ll 

work. 

 DR. WADE: So I’ll check with Robert as soon 

as I can, and we’ll say 11:00? 

DR. ROESSLER: So this is April 18th . 

MS. MUNN: April 18th . 

 DR. WADE: Eleven a.m., probably two, three 

hours to finish the matrix. 

MS. MUNN: Eleven eastern time? 

MR. ROLFES: We may not even need that much 

time, maybe only an hour. 

 DR. WADE: Tentatively, I’ll get an e-mail 

out, check with Robert and get an e-mail out 

before the end of this week. 

And now I think we’re adjourned. 

Thank you on the phone. We’re adjourned. 

(Whereupon, the working group meeting 

concluded at 2:38 p.m.) 
______________________________ 

186 

1 CERTIFICATE OF COURT REPORTER 

STATE OF GEORGIA 

COUNTY OF FULTON 

 I, Steven Ray Green, Certified Merit Court 

Reporter, do hereby certify that I reported the 

above and foregoing on the day of March 27, 

2007; and it is a true and accurate transcript 

of the testimony captioned herein. 

 I further certify that I am neither kin 

nor counsel to any of the parties herein, nor 

have any interest in the cause named herein. 

 WITNESS my hand and official seal this the 

19th day of June, 2007. 

STEVEN RAY GREEN, CCR 

CERTIFIED MERIT COURT REPORTER 

CERTIFICATE NUMBER: A-2102