NEAL R. GROSS

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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

124th Meeting

Thursday, August 23, 2018

The meeting convened at 8:30 a.m., Eastern Time, 

at the Hilton Providence, 21 Atwells Avenue, 

Providence, Rhode Island, Ted Katz, Designated 

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

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 2

Members Present:

Henry Anderson, Chair

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member*

David Kotelchuck, Member

James E. Lockey, Member

Wanda I. Munn, Member

David B. Richardson, Member

Genevieve S. Roessler, Member*

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member*

Ted Katz, Designated Federal Official

Registered and/or Public Comment Participants:

Adams, Nancy, NIOSH Contractor

Barrie, Terrie

Barton, Bob, SC&A

Blaze, D'Lanie

Calhoun, Grady, DCAS

Domina, Kirk

Fitzgerald, Joe, SC&A

Hammond, Lokie, DOE

Hinnefeld, Stu, DCAS

Hughes, Lara, DCAS

Nelson, Chuck, DCAS

Neton, Jim, DCAS

Rutherford, Lavon, DCAS

Stiver, John, SC&A

Taulbee, Tim, DCAS
This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been 

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

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 3

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 124th Meeting 

Thursday, August 23, 2018 1

Roll Call/Welcome 4

Idaho National Laboratory SEC Petition 219 6

Presentation from Bob Barton, SC&A 6

Presentation from Tim Taulbee, NIOSH

12

Questions on Presentations 17

Update on Evaluation Report 238 and 83.14

26

Questions on Presentation 33

De Soto Facility SEC Petition #246 47

Questions on Presentation 54

Adjourn 82
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 4

Proceedings

(8:31 a.m.)

Roll Call/Welcome

Mr. Katz: Welcome. This is Day 2, the Advisory 

Board on Radiation and Worker Health here in 

Providence. Welcome again, and welcome, everyone 

on the line as well.

A few preliminaries before we do roll call, for folks on 

the line who are following along today, we have a half 

day meeting. We're covering INL Pacific Proving 

Grounds and De Soto. Two of those are SEC 

petitions.

The materials for today are posted on a NIOSH 

website under this program schedule of meetings, 

today's date. You can go there and pull up all the 

presentations that are going to be given today as well 

as background reading related to those 

presentations.

And you also can pull up the agenda for today, and 

the agenda has on it Skype information so that 

people remotely can follow along with the 

presentation as the slides are being given, if you want 

to do that. You don't need to. You could also just 

pull up the presentation itself -- those are PDFs or 

PowerPoints -- and view the slides on your own at 

your own pace, whichever you want.

And I'd also just ask everybody who's on the line, 

please keep your phones muted. There's no public 

comment session today. So really, Board Members 

are the only people that should have open lines. And 

if you don't have a mute button, for the rest of you, 

please press *6 to mute your phone and *6 to take 

your phone off of mute.

The only exception to this is petitioners, of course, 

will have an opportunity to comment for INL. And 
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 5

they can open their lines when that -- you'll see on 

the agenda when your opportunity comes up or we'll 

talk about it during that session.

Okay, roll call. Before I get into roll call, let me just 

address a conflict of interest because it's easier for 

me to address that than the Board Members as we 

go through this. But for the INL session, we have 

one Board member who's recused, Mr. Clawson. And 

he's already recused himself although we need him 

for roll call. It's okay. He's present. And that's it. 

That's the only recusal we have today.

Okay, then roll call. So we'll do that alphabetically. 

(Roll call)

Mr. Katz: Great, welcome. Okay. So we have full 

attendance. We have our quorum. And with that, 

just a couple notes about the -- we're beginning with 

the INL site. And it's a little bit complicated, their 

presentation scheme.

We have the SEC Petition 219. That's sort of the 

prime matter for today, and it's sort of evolved into 

more update -- extensive update than anything. But 

it'll be helpful for the next Board meeting, given the 

timing and work that's going on. And you'll hear 

about that today.

So we have two presentations on that petition, Mr. 

Bob Barton and Tim Taulbee from NIOSH -- Bob 

Barton from SC&A. We'll follow that by an 

opportunity for the petitioners for that petition to 

comment. And then after that, we'll have a 

presentation by Mr. Bob Barton giving an update on 

work that SC&A is doing related to a petition that the 

Board has already acted on, which is the 83.14 you 

might recall for its separate period.

So that's how that session will work. And with that, 

let's get started with INL.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 6

Idaho National Laboratory SEC Petition 219

Presentation from Bob Barton, SC&A

Mr. Barton: Good morning. My name is Bob Barton, 

and I'm with SC&A. And we're going to be discussing 

a status update on the Idaho National Laboratory SEC 

Petition 219.

For just some background to kind of review how 

we've gotten here, the petition was received on July 

8th of 2014. The original requested class and the job 

titles and/or job duties where all employees who 

worked in any area for a period of employment from 

January 1949 through December 31st, 1970. In 

September 2014, the petition qualifies for evaluation. 

And then March of 2015, NIOSH releases the first 

revision of the Petition Evaluation Report.

The original proposed SEC class included all workers 

with evidence of external dosimetry at the Idaho 

Chemical Processing Plant for the period from 

January 1963 through the end of 1974. And I'd add 

that post-1974 at that time was being held in reserve 

for a potential 83.14 evaluation.

This original proposed class was discussed by the 

Advisory Board at the regular meeting that was in 

March of 2015 of that year. In July of 2015, Revision 

1 of the Petition Evaluation Report was completed. 

The reason for this change was mainly that 

documentation had been captured that suggests 

from the period of March 1970 through the end of 

1974, a worker could actually enter the Chemical 

Processing Plant with any INL dosimetry badge as in 

a CPP-specific badge was not required. You could 

have a badge from any major area of INL, Central 

Facilities, Test Area North, and use that badge to 

enter the Chem Plant.

Well, at that time, the class definition was revised to 

effectively split it into two time periods which are 
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 7

labeled Part A and Part B in the actual definition 

which is up here on the slide. I won't read the whole 

thing.

But essentially, Part A is from 1963 through February 

1970. And that requires a CPP-specific badge. Part 

B is from March of 1970 through the end of 1974. 

And that's the period, as I just said, you could use 

any INL badge to get into the Chem Plant.

More on the Revision 1. This was discussed for the 

first time in that same month it was released, July 

2015, and again in March of 2016. And also, the INL 

Work Group discussed this in July and November of 

2015 and also January and March of 2016.

At that Advisory Board Meeting in March of 2016, the

INL Work Group recommended that the Part B of the 

class definition move forward for expediency to get 

that class through while Part A, which is the class that 

still requires a CPP badge from 1963 through the 

earlier part of 1970, to be further evaluated.

So the primary consideration for Part A is obviously 

the fact that you require an actual CPP-specific 

dosimetry badge. So it's a little narrower 

requirement than Part B that requires simply a badge 

at INL.

During the course of NIOSH, SC&A, and the Work 

Group review, it was discovered that temporary or 

visitor badge records at CPP during this time were not 

always migrated to the main INL -- and it says, 

dosimetry system. A better term would be the 

dosimetry index or radiological exposure index.

As this has been explained to me, essentially, this is 

an electronic system that sort of gives a roadmap for 

an individual worker to then go in and pull their 

scanned pages of dosimetry records, put them 

together, and then transmit them to NIOSH or DOL 

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

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 8

So these temporary badges were not always being 

included in the files to NIOSH and DOL. And it sort 

of breaks down like this. If you had a temporary 

badge with a positive dose, then usually you were 

transferred into that index and that record would be 

provided with the Energy employee's file. If a 

temporary badge had no dose, then they were 

generally not migrated into that index. And so they 

were not being included.

So what are the SEC implications of this? Well, 

because the class definition requires a CPP badge, if 

you were a worker who were monitored by a 

temporary or visitor badge and you did not accrue 

that recorded dose and you were not migrated into 

the index, then that record would not be included in 

your file when a request came in from Department of 

Labor or NIOSH.

So in response to this, DOE and INL conducted a 

significant coding and indexing effort to assure all 

these temporary badges, which were available on site 

in hard copy form essentially, were migrated into this 

INL dosimetry index and so would be correctly 

included in the individual's file for SEC adjudication.

Work Group discussions subsequent to this remained 

concerned that some difficulties might arise related 

to this coding effort and how effective it would be in 

getting these, essentially, handwritten records coded 

and indexed and properly included.

Some of the concerns were name misspellings on the 

original records. Like I said, they're handwritten 

generally on small cards about the size of a credit 

card. Name variations that could be used for the 

same individual. When these are entered into the 

indexing system, do we know that that's actually the 

same individual if there's a slight variation in the 

name spelling? And finally, human error that might 

just be associated with such a massive indexing 

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

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 9

So at that time, the INL Work Group requested that 

SC&A develop a verification and validation strategy 

to evaluate how effective this new coding and 

indexing effort was and actually identifying workers 

with their temporary badges during this Part A of the 

SEC period. And again, that's January 1963 through 

February of 1970.

So SC&A's initial V&V strategy, essentially a proof of 

concept, was sent to the Work Group in September 

of 2016. And at that time, we had identified 32 

individual claimants which covered a total of 51 

temporary visitor badges that we knew we had as 

being captured by NIOSH. But when we looked into 

the dosimetry file for those claims as they were being 

transmitted to NIOSH, those badges were not 

permanently included.

So the idea is that then NIOSH could take those 

individual claimants, re-request those records. And 

based on that new indexing effort, they should be 

properly migrated into the Energy employee's 

permanent file.

So that initial proposal was discussed in a Work 

Group meeting in May of 2017. At that time, the 

Work Group requested that SC&A expand from just 

32 claimants and 51 badges to a larger group that 

could be considered for V&V evaluation.

SC&A delivered its revised strategy in August of 

2017. We found, from 32, we went up to 228 total 

claimants and nearly 1,800 associated temporary or 

visitor badges. Obviously, this is sort of a 

cumbersome number. We can't do a V&V on all of 

those. So what we did is we went in and sorted and 

ranked the claimants we had found.

So there's significance in the V&V activity to really 

narrow down our focus and hopefully get some 

meaningful results. And the factors that were 

included in this sorting was we wanted to include 
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

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various subcontract workers in addition to the prime 

contract workers so that we get a cross section of 

different employers.

We wanted some cases where we had observed name 

variations or spelling variations or mistakes. And this 

last point was the necessity of a future dose 

reconstruction. This is simply because this cost DOE 

resources that they could be using for other claims 

that needed to be processed. So if they still would 

require a dose reconstruction, then this research 

would have to be done anyway and the resources 

wouldn't necessarily be wasted.

So the Work Group discussed this revised V&V 

approach during the meeting in August 2017. And 

the Work Group elected to proceed with the records 

request for the first group of claimants which were 

30 in total. It was 30 claimants and about 670 

temporary badges.

And the idea at that time in August of 2017 that was 

once we received the records for the 30 claims and 

had a look at them, then we would go ahead and 

send, if it was deemed worthy, the second group and 

so on. So it would be sort of a stepwise approach.

So what do you have as progress to date? Right after 

that August meeting, NIOSH requested the external 

dosimetry records for that first group. There was 

some communication from the DOE on what we were 

really looking for. Some wires got crossed. And later 

that year in the fall of that year and into the winter, 

we found that the records we were getting back really 

weren't sending those temporary visitor badges like 

we'd expect.

So NIOSH was able to clarify the issue with the site, 

and the records were resubmitted or the requests 

were resubmitted to INL in March and May of earlier 

this year. As of last month, we had received -- the 

dosimetry files are updated -- dosimetry files for '18 
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of those 30 claims that were in the first group. So 

SC&A went and reviewed these revised monitoring 

records to supply some interim results on what we 

were seeing.

So there were 420 badges among these 18 reviewed 

claims. And when we went through the external 

dosimetry files, we found that 332 of those 420 

temporary badges had been correctly migrated into 

the indexing system and were appropriately being 

included and transmitted to NIOSH and would be 

transmitted to DOL, if that was the case. And in one 

of those cases, none of the 31 temporary badges that 

we had identified had been included in the file.

In addition to the 420 temporary badges that we had 

attributed to Group 1 claims, we had 32 additional 

badges that we thought had name variations or 

misspellings that we wanted to look at and see if 

those sort of variations that could associated with 

human error. Again, different people would give their 

name perhaps at the guard post or different 

variations in spelling. And only 3 of those 32, or 

about ten percent, were included in the updated 

record.

So where does that leave us? These issues were 

discussed earlier this month with the INL Work 

Group. And the Work Group at that time voted to 

continue gathering and evaluating the rest of the 

records for the remaining 12 in that first group. So 

we had gotten 18. We took a look at them. These 

are the 18 interim results. Let's look at the remaining 

12.

And in tandem, NIOSH was to work with DOE and INL 

personnel to really determine the root cause for some 

of these observed missing badges that were currently

being evaluated by SC&A.

And so with that, if anyone has any questions.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

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Mr. Katz: Why don't we have Tim present and then 

the two of you can have questions. That, I think, 

would make more sense.

Presentation from Tim Taulbee, NIOSH

Dr. Taulbee: Good morning. Thank you very much 

for this opportunity to provide a few thoughts along 

with this validation and verification.

Before I get started, I do want to acknowledge Mitch 

Findley. He's been instrumental in helping me pull 

this information together. And Bob, you did a 

fantastic job of summarizing everything that has 

been going on for the last few years. And so thank 

you very much for that. Okay.

I wanted to try and reemphasize a little bit of our goal 

of the SEC class definition. If you recall, we 

designated this class due to exposures to 

transuranics and plutonium in CPP. That was the 

exposure that we couldn't estimate. These would be 

people who would be working in the process cells, 

working in the sampling aisles, working in the 

operating corridors as well as the laboratories. Okay. 

So that's the first part. That was the exposure we 

could not estimate.

So the goal of a class definition is to identify who are 

those workers. And so to do this, what we do to 

ensure we don't miss anyone, we cast the net fairly 

wide. And so what we identified as the class 

definition was a single badge at CPP and 250 days of 

employment. Remember, the 250 days is required 

from a health endangerment standpoint as part of the 

SEC class.

So why do we choose a single batch? There is a 

potential for some administrative personnel to be on 

annual dosimetry staring in 1966. Thus, 250 days of 

employment at CPP, they might only have a single 

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

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

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Now, to have that happen, that meant they would 

have to had started on the first day of the badging 

cycle and then ended employment basically on that 

last day which is pretty rare to do. Most likely, they 

would start somewhere in the middle, go along, and 

then get a second badge. Okay. But we wanted to 

make sure that we caught this type of a worker as 

well.

The other thing I'd say is administrative personnel 

were the only ones on this annual dosimetry, that 

everybody else, these operators that we were looking 

at who are going into the process cells, who are the 

laboratory folks working with the trans-plutonium 

materials were all on monthly dosimetry, engineers 

who were in between and on a quarterly type of 

dosimetry. So this is why we chose this single badge 

definition.

So this class definition identifies all the routine CPP 

workers with some potential for exposure to 

plutonium and transuranics but eliminates non-CPP 

workers that don't have a potential for exposure. For 

example, workers 30 miles away at Test Area North 

who never went to CPP, people in Central Facilities 

who never went to CPP.

And we've interviewed people over the past several 

years out there and asked them, did you work at 

CPP? And there have been several that said, no, they 

didn't want to work there. It was a dirty place. It 

wasn't a place that they wanted to go to.

So the simplified definition does include some 

workers who may not have 250 days of exposure at 

CPP. They are temporary workers. Most of them had 

a few days of work at CPP, up to a week on a single 

temporary badge. So to get to 250 days, you'd have 

to have at least 52 temporary badges, typically more 

because many of these badges were only for a single 

day. But again, our goal was to cast the net wide to 

be inclusive of people so that we didn't miss anybody.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 14

One of the benefits of this simplified single badge 

definition is that routine workers, the people we're 

really targeting, were on a monthly badge sequence. 

But these temporary workers, as Bob was pointing 

out, there is the potential for misidentification due to 

incorrect name spelling on the temporary badges. 

These were filled out by security guards.

And I can tell you with the last name of Taulbee, 

every time I go to a restaurant and you look at how 

they spell my name, it is all over the board. And so, 

I mean, this is just along those lines of these people 

filling this out. So we were expecting to have some 

of this misspelling names. But again, to enter the 

class, a single badge.

This also eases the need to identify all the temporary 

badges. Some of these are illegible. You'd look at 

them and you just can't read it over time. But we 

felt there was a low probability in missing 52 badges 

and missing a worker who was truly exposed at CPP 

for the 250 days. That was one of the benefits of this 

single badge definition.

There is potential concern that the single badge 

definition is too broad. It includes workers who did 

not routinely work at CPP and who may not have 250 

days of exposure. However, it's difficult to sort out 

the actual dates from the dosimetry. It's not 

impossible. You can. You can go through and look 

at their names and match them all together.

And SC&A has done a great job of identifying people 

who have name misspellings and they're the same 

worker. But then you got to go to the dates and look 

at how many days was this badge issued for: was it 

one day, two days, was it for five days, that type of 

thing. So if you were to try and make the class more 

narrow, you would have to increase the criteria for 

the name spellings as well as making sure you got all 

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

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 15

So here's a table of SC&A's results and this is to date. 

And as Bob pointed out, we are still evaluating this. 

So from the current class definition, 17 of the 18 CPP 

temporary workers were identified and would've 

been entered into the class. One case, Case K, was 

misidentified by DOE under the current review.

And if you go down this table, we've also added in 

here the expected number of badges and the actual 

number of badges. And if you look at the expected 

number, there's only one worker that has over 52 of 

them of the 18 that have so far been looked at that 

would have over 250 days at CPP.

There are other temporary workers that routinely 

went into the site and so they would have those 250 

days. But again, we're requiring a single badge. 

That's all that we're requiring to be entered into the 

class.

So let's look at what would happen with this one 

worker with the missing badges -- or with the missing 

badge. Without the temporary badge indicating work 

at CPP, DOL would've determined they were not part 

of the SEC class. They filed a claim, and so the claim 

would be referred to NIOSH for dose reconstruction.

During dose reconstruction, the NOCTS file would 

indicate work at CPP. It would probably catch it 

during a CATI or one of the computer-assisted 

telephone interviews. Plus, during the dose 

reconstruction, an inquiry would be sent back to DOL 

about the SEC class inclusion with the CPP 

documentation and DOL would have reevaluated the 

classification. Thus, due to this follow-up -- checks 

and balance, if you will -- the worker would likely 

have been reclassified and included in the SEC.

Now, having said all of that, that one case where they 

missed all 31 of those badges, DOE erred. We have 

talked to them about it. They do not know why that 

they missed those. They should have found at least 
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 16

one badge. SC&A found 31 badges. When we went 

back through the records, we found 32 for this 

worker. Based on the 32 badges for this particular 

worker, he worked at CPP for 95 days. We went 

through and added up all of those individual days.

The temporary worker is part of the class. This is a 

worker that we were casting the net wide. Yes, they 

don't have 250 days actually at CPP. But this is one 

of the, I guess, in a sense, outcomes of this simplified 

class definition to keep from having to go through all 

of the details. Sorry, this thing is jumping around on 

me here. But again, like I said, casting the net wide, 

we wanted to make sure we didn't miss anybody that 

would have 250 days.

We contacted DOE to find out more about this Case 

K and why they missed it. An interesting part is the 

initial response in October of 2017, the dosimetry file 

they sent had 296 pages of dosimetry. They added 

the CPP dosimetry information. They did the index, 

as Bob pointed out. And their June response had 281 

pages. So somewhere along the lines, not only do 

we not get the CPP, but they decreased in the amount 

of records.

DOE, again, recognized there was an issue with the 

case. They're not certain as to the reason the 

temporary badges were missed and why the second 

response is actually less than the first response. 

They did commit, though, to resend the full response 

for Case K and that is currently in process.

Case F is one that I also want to point out here from 

SC&A's evaluation. Although they would be part of 

the class, DOE only found 6 of the 48 badges. And 

we felt they should've found a lot more from that 

standpoint. And so we questioned DOE about it, and 

it turns out they only sent a partial response, some 

of the temporary badges but not the full dosimetry 

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

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cautioned that this transcript is for information only and is subject to change. 17

The May response that we got only had 16 pages in 

it. The response we got last October had 531. And 

so clearly, they did not send us the full dosimetry file 

as we had requested. And again, they committed to 

resend this particular case.

So in summary, as Bob had pointed out, we've had 

many discussions here about the completeness of the 

dosimetry badges. The routine dosimetry badges are 

complete. The construction dosimetry badges are 

complete. These temporary badges is this remaining 

issue that is out there, and SC&A's V&V of this, this 

is the group with the highest vulnerability. All of the 

others were in IBM system. They were typed into a 

system. They're easy to read the records, and there 

shouldn't be any problem with them. This is the 

highest vulnerability group.

And even with that, 94.4 percent of the temporary 

workers were accurately placed in the SEC by DOE 

with the current definition. However, we have 

notified DOE of their error with that one particular 

case and they're reviewing their process to improve 

their current accuracy.

So with that, I'll be happy to answer any questions.

Questions on Presentations

Mr. Katz: Thanks, Tim. So questions for either Bob 

or Tim? Anderson?

Member Anderson: In your last statement there, you 

say 94 percent were accurately done. But really, it's 

only of the 18 cases that were reviewed, 94 percent.

Dr. Taulbee: That is correct.

Member Anderson: So it's not appropriate to claim 

that all of the temporary workers, 94 percent of them 

would've been. So it's really a pretty small sample.

Member Richardson: We could go further than that.
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Dr. Taulbee: That is correct, yes.

Member Richardson: Because you first requested 

records for 30 people --

Member Anderson: Yes.

Member Richardson: -- and they responded with 

zero, and so -- right? I mean, that was the narrative.

Mr. Barton: Maybe I wasn't quite clear on that. 

When the first requests went out, we got files back 

from DOE. But it was clear that much smaller 

percentage of these temporary badges were being 

included and that's what occurred on those.

Member Richardson: Yes, you'll have to go back and 

say that because I thought you said there seemed to 

be the wires were crossed. It was a 

misunderstanding, and then you directed them that 

you wanted the temporary badges. But would that 

be the standard procedure?

Dr. Taulbee: No, no, no. What ended up happening 

was we captured the temporary badges for CPP in a 

separate data capture. When they did their indexing, 

they did it off of a different set of temporary badges 

and actually missed the CPP ones when they did their 

indexing.

That's what they went back this past winter and 

indexed all of those. They actually missed the entire 

set that we were looking at. And when we started 

getting those responses back, we recognized they got 

some of them from the latter time periods but not 

that early set. And that was when we talked to DOE. 

That's the wires being crossed that Bob mentioned. 

DOE went back. They recognized it, and they 

indexed all of those. And so this V&V is testing the 

whole system now.

Member Richardson: And why are there 12 -- when 

you requested 30, why are there 18 that we're 
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focused on evaluating? Where are the other 12?

Dr. Taulbee: They're still in the process. INL is 

currently short staffed with regards to response. In 

fact, they're down to 50 percent of their staff. They 

had two people responding. One of them has moved 

to a new job. So they have one person.

And due to this, they requested we only submit ten 

at a time so that they can maintain their normal 

claimant response because we are continuing to get 

claims for INL. And they have 60 days to respond to 

those claims. So they're working these in with that. 

And so in batches of ten, they agreed to respond 

within 60 days for each set of ten.

Member Richardson: Okay, thank you. I'm just 

trying to figure out what the denominator is for when 

we're calculating the accuracy or validity of the 

classification.

Dr. Taulbee: And Dr. Anderson, you are absolutely 

correct. This is a limited sample at this time, and I 

recognize that. But I did just want to point out that 

currently we've got one of the claims that DOE 

effectively missed. And we have notified them of 

that.

Mr. Katz: Other Board Members, questions in the 

room? Dave, again?

Member Richardson: In the similar slide, it was the 

group with the highest vulnerability where it was the 

information regarding temporary badges and the 

other dosimetry information was stored in an IBM 

system you said; is that correct?

Dr. Taulbee: That is correct. These were printouts, 

so the names were entered in by a security badge 

number, Social Security number. And so there was 

other methods to make sure that that person is there 

so you don't have the name misspelling issues.
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Member Richardson: So for Case K and Case F, 

between 2017 and 2018 when you did repeated 

filings for the same person and there was not just 

temporary badge information missing but other 

pages, was some of that missing information which 

would've been in the IBM system?

Dr. Taulbee: Yes, because they did not respond to 

the full request, especially on Case F, if you go up 

here.

Member Richardson: Hundreds of pages, right?

Dr. Taulbee: Yes, hundreds of pages.

Member Richardson: So is the assumption that the 

highest vulnerability information is the temporary 

badge information versus the IBM information when, 

in fact, we see two people with IBM information which 

is missing in an audit of 30 -- or 18?

Dr. Taulbee: Right. What I believe happened in this 

particular case is that whoever was doing the 

response thought they were just to respond to the 

new information and didn't go and print out the other 

500 pages and send them to us, but --

Member Richardson: So the person who is doing this 

in the staff, in fact, knows that they're involved in an 

audit, that this is a repeated request for information 

on somebody --

Dr. Taulbee: No, we were trying to make sure they 

didn't know that they were --

Member Richardson: So how could they --

Dr. Taulbee: -- part of an audit.

Member Richardson: -- have suppressed information 

thinking that they only wanted the updated 

information? They would've had to know that there 

was a prior request.
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Dr. Taulbee: I don't know. I really don't know.

Member Richardson: Certainly, the IBM machine 

shouldn't know that. You would think that someone 

would ask for the dose records.

Dr. Taulbee: When you take a person's name in, you 

get a printout of all the pages.

Member Richardson: Yes.

Dr. Taulbee: In all 531. And you're supposed to go 

to those files, print out that page, collect it all into a 

single PDF and send it to us. That did not happen. 

And we've asked DOE, why didn't that happen, and 

they don't know.

Member Richardson: Could I ask a different 

question? You described a card like -- and I don't 

know if you said it was like a baseball card or I can 

sort of -- the information on the temporary badge 

was a small card which had handwritten information 

on it.

Dr. Taulbee: Yes.

Member Richardson: And is the unique subject 

identifier just the name?

Dr. Taulbee: Yes, but that's not necessarily unique. 

I mean, you could have the same last name, same 

contractor. But yes, it is.

Member Richardson: Yes, so that's a daunting 

linkage process. I mean, because it's a huge site.

Dr. Taulbee: Right. And exactly, that is part of why 

we chose a single badge is to get one single badge 

that's tagged to this person to be included into the 

class.

Member Richardson: And are those cards just in 

chronological order, or have they already been 

sorted?
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Dr. Taulbee: In this particular time period, they've 

actually been typed onto a form from the cards. And 

so there's a temporary badge report for each badge 

exchange cycle, typically on a weekly basis. And so 

there'll be a listing of -- it could 30 to 60, 70 people 

listed on these pages with their dosimetry results off 

to the side.

Member Richardson: Because somebody went 

through the effort already for the non-zero temporary 

badge dosimetry records, I'm imagining of 

alphabetizing them, reconciling names because they 

had to associate not just garbage names with 

workers. But for the nonzero badges, associate those 

with the worker and put those into the system.

Dr. Taulbee: What they did is these were in books of 

pages, I think in three-ring binders but they weren't. 

They were the old records with the single metal tab 

things that pulled over. They went through those, 

tabbed all of the pages that had a positive dosimetry. 

So you can scan down the right-hand column. You 

can see those. They moved them to the top, to the 

front of that particular folder. And those they 

scanned and those they typed into the index 

originally. So they're all at the front. All of the 

positives are at the front of each of these folders, and 

they didn't do anything with the back of it.

Member Richardson: But --

Dr. Taulbee: What they've done in this case is 

they've gone through all of it that was in the back 

that they didn't do initially.

Member Richardson: But they have some procedure 

for reconciling names, right?

Dr. Taulbee: Yes, yes, they do.

Member Richardson: So this is where I'm thinking 

that whether you have one temporary badge or 30 

temporary badges, it's only been reconciled to a 
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single consistent name across those 30. It would 

seem as though when there's legibility issues or 

alternate spellings, for the search, there's only one 

search. I don't think there's -- they don't have a --

we, before, created an AKA file where you could 

associate a person with 75 different names.

Dr. Taulbee: I don't know all of their searching 

criteria. I don't know that they just put in the Social 

Security number. I believe they would also look at -

-

(Simultaneous speaking.)

Member Richardson: I mean, but --

Dr. Taulbee: I don't know that.

Member Richardson: -- that gets to the question of 

this assumption of because it's one versus 30, if 

they've all been reconciled to a single assigned 

homogenous name, it doesn't increase the 

probability that you're going to be find the person 

because there was a spelling mistake. Because 

somebody had to make a decision to say Jane and 

James were the same person. Okay, I think. I'm just 

trying to --

Dr. Taulbee: Again, I don't know what --

Member Richardson: -- understand the process.

Dr. Taulbee: -- DOE's criteria was and how they're 

going through that whole process.

Member Richardson: Yes, because that's really hard. 

Because aren't there -- there's 100,000 people or 

something like that?

Dr. Taulbee: When you include the temporary 

workers, it's way more than that.

Member Richardson: Yes, yes.
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Dr. Taulbee: Many of these are visitors. I mean, 

they were there for just a few days.

Member Richardson: I have another question.

Member Richardson: I'm sorry. Just because I'm 

interested in the problem.

Member Richardson: As I understood this, the 

starting point of the issue was these people didn't 

appear in an index of the temporary badges. And so 

I was thinking when you would do the first search of 

a random sample, you wouldn't take 30 people and 

see if they appeared in the computer index.

It'd be a very quick thing to take 1,000 people and 

see if -- or to have the index file and see how much 

it's grown after they entered the names. But there's 

no characterization, none of this detailed actual hard 

copy recovery of the information. But just now, do 

the people who you believe should be in the index 

appear in the index?

Dr. Taulbee: The problem would --

Member Richardson: It would be labor intensive for 

DOE.

Dr. Taulbee: But the index tells them which file to go 

to which has a number, like 30-15222, and this 

person is found on page 256. But you get to that 

page, it could be external dosimetry. It could be a 

skin contamination report. It could be bioassay. It 

could be a whole body count. You don't know what 

that page is. It's that level of details not in the index. 

It tells them there's a RAD record at that location. 

And they go there, they print out that page, and 

that's what they assemble and send to us.

Member Richardson: So when these people didn't 

appear in the index before, is it that they didn't 

appear in the index before or that something has 

been added? I mean, again, I thought the issue was 
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that there were a group of people who were 

temporary visitor badge people with zero doses 

hadn't been added into the index.

Dr. Taulbee: That is correct.

Member Richardson: And so does the --

Dr. Taulbee: If you look --

Member Richardson: -- index include new names, or 

are you saying that those people already may have 

been in the index but now they're not tagged to that?

Dr. Taulbee: Both.

Member Richardson: Okay.

Dr. Taulbee: Both. If you take Case K, for example, 

he's got -- this particular person has, what, 296 

pages of dosimetry. They were a routine worker at 

Test Reactor Area. This was a person who 

occasionally went into CPP due to their work from 

TRA. So there are almost 300 pages of dosimetry 

and exposure information from Test Reactor Area for 

this particular worker. What we're trying to pick up 

is when he went into CPP. And again, a single badge, 

he becomes part of the class.

Member Richardson: All right. Thank you.

Mr. Katz: Other Board Members in the room with 

questions? How about our Board Members on the 

line? Do we have quick questions from any of you? 

Paul?

Member Roessler: No questions here.

Mr. Katz: Gen? Bill? Gen, can you speak up?

Member Ziemer: I have no questions, Ziemer.

Mr. Katz: Paul, sure.
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Member Ziemer: No questions, but I appreciate 

Dave's questions. I thought they were excellent.

Mr. Katz: Okay, thanks. So Paul, you didn't have a 

question, right?

Member Ziemer: I didn't have a question.

Mr. Katz: Right.

Member Ziemer: I will raise this now, however, but 

you're probably going to discuss it. What are the 

next steps on this issue?

Mr. Katz: Oh, okay. No, they weren't, so go ahead, 

Bob.

Mr. Barton: Yes. Hi, Dr. Ziemer. This is Bob. The 

next steps are sort of twofold. "A", we're going to 

get the rest of the 12 dosimetry files for that group 

of 30 claimants that we originally wanted to take a 

look at. So that's in progress. And at the same time, 

NIOSH is inquiring with DOE and INL as to try to find 

the root cause of the problem. And again, we're 

going to take another look at some of these cases 

and I think that's pretty much the path forward as of 

now.

Mr. Katz: Right. Before we go on then to -- Bob has 

another presentation on follow-up work that they've 

been doing on the class that's been added. But first, 

do we have petitioners for this petition on the line? 

And if you are on the line, maybe you're muted and 

we're not hearing you. Okay.

So Bob, you can do part two now.

Update on Evaluation Report 238 and 83.14

Mr. Barton: Okay. So that was Petition 219 which, 

again, covers the period from 1963 through 1974. 

And as I said in the last presentation, for the period 

after 1974, at the time, NIOSH had held that in 
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reserve so that it could be evaluated for a potential 

83.14 process which is where NIOSH determined 

themselves that there is a potential infeasibility in 

dose reconstruction beyond the standard petitioner.

So on July 20th, 2017, NIOSH released its Evaluation 

Report 238 which is part of the 83.14 process. 

NIOSH recommended an addition to the SEC class for 

workers at CPP for the period of 1975 to 1980. 

Similar to the period we were just talking about, this 

class definition requires a CPP-specific dosimetry 

badge.

And so this was presented to the Advisory Board in 

August of 2017 at the meeting in Santa Fe, New 

Mexico. And the Advisory Board voted to accept the 

proposed 83.14 class, again, for the period from '75 

to 1980. And at that same meeting, SC&A was 

tasked with performing an evaluation of the 

dosimetry completeness in a very similar fashion to 

what was done for the previous 83.13.

So SC&A's approach to this completeness evaluation 

sort of had four facets that we wanted to look at.

Item No. 1 is let's take a look at the completeness of 

the routine badges for both the regular CPP workers 

and those designated as construction workers. They 

actually kept separate dosimetry lists for each 

designation. So we can mention that in a previous 

class review, that was also done. We looked at the 

routine badges as well.

Item 2 is, again, let's look at the completeness of 

those temporary visitor badges.

Item 3 is almost identical to the SC&A report that we 

just presented in that let's see if we can identify 

claimants who are in those temporary badge records 

and see if they're correctly coded and identified. 

Again, a very similar process to what we did for that 

Part A definition under the 83.13.
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And Item 4 was to review a subset of claimants to 

assess the practice of requiring a separate dosimetry 

badge for each area entered at INL during a single 

monitoring cycle. This is often referred to as the 

multiple badges for multiple areas policy.

And this one is especially important because as you 

remember the period immediately prior from 1970 to 

1974, all you had to have was an INL badge from any 

area. You didn't have to actually have a CPP badge.

So we wanted to take a look in there and see if it was 

the actual policy that if you went into CPP, you had 

to stop and get a CPP badge. If you could get in there 

with a badge from Test Area North, well, then the 

narrower definition doesn't really work.

So Item 1, and this was to look at the completeness 

of the routine records for both your regular CPP 

workers and the construction workers. SC&A had 

essentially two observations from this review.

Observation 1, a comparison of the expected number 

of monitored workers listed in the dosimetry branch 

activity reports to those tabulated in the available 

dosimetry logbooks contained in the area and 

construction exposure reports was only available for 

49 of the 72 months of interest, about 68 percent. 

The largest temporal gap was about 11 months. All 

others were three months or less.

So what we're really saying in here is you have two 

sources. You have the logbooks that actually list all 

of the found badges and what the results of those 

were, then you have a summary report essentially 

saying in, for example, July 1980, we monitored 600 

people.

So then you go into the actual logbooks and you see 

how many individuals you actually have there and 

make a comparison as to whether those records are 

complete. If they said they monitored 600 people 
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and we only receive records for 400,that would 

obviously be a completeness issue.

This observation is noting that that comparison of the 

number of monitored workers was only available for 

49 of the 72 months. So the question is, well, what 

do you do with the months where you don't have a 

comparison to make? So what SC&A did is we said, 

well, it's not quite as good of a comparison. But we 

also know how many dosimeters were processed in a 

given period in these summary reports.

So instead of counting the number of monitored 

people, let's go in and count the number of 

dosimeters we see in a given month. And this was 

the subject of Observation 2 which I'll read.

SC&A's analysis of the total number of dosimeters in 

available records compared to the total number of 

dosimeters that were reported to have been 

processed during those observed temporal gaps 

showed reasonable agreement for both regular 

badges and construction badges. SC&A found no 

indication that available dosimetry logbooks for 

regular and construction badges are incomplete 

during these periods.

And again, those are the periods where a comparison 

between the number of monitored workers couldn't 

be made. So we made a comparison of the total 

number of badges.

Item 2 resulted in two SC&A findings. Finding 1, 

SC&A located temporary badge reports during the 

period of interest; however, it is apparent that the 

currently available records are incomplete. And by 

that, I mean the records available that NIOSH has 

captured and have been uploaded to the SRDB for us 

to use

Additional temporary badge reports are available at 

the site but have not been captured due to the focus 
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of previous data capture efforts. It would be 

beneficial that such reports be obtained and reviewed 

to assure completeness of dosimetry records for use 

in potential SEC adjudication. And again, we're 

talking about temporary badges now whereas the 

previous item was looking at regular badging --

routine badging.

Finding 2, based on a review of the limited available 

temporary badge reports from 1975 and 1980, 

workers who accrued zero measured dose and did not 

have a permanent Health Physics badge indicated in 

the temporary badge report do not appear to be 

consistently migrated into the official area exposure 

reports. This is the same problem we had during the 

'63 to '70 period.

However, it does indicate that determinations of the 

completeness of records using area exposure reports 

alone are likely based on incomplete data and 

information. And again, that's because we simply 

can't verify the completeness of these temporary 

badges because we have not captured them all.

So this was, again, discussed earlier this month. And 

the path forward on these two findings was that 

NIOSH was to perform the additional data capture at 

INL to obtain the full set of temporary badges for a 

completeness evaluation. And this says, SC&A to 

participate as appropriate as of yesterday. I'll be 

going along with Tim and Mitch Findley.

Item 3, can we identify V&V cases? Well, as you 

probably guessed, not really because we simply don't 

have that many temporary badges to be able to 

compare against claimants and then pull those 

temporary badges, check against our actual record to 

find cases where they may be currently missing.

That resulted in Observation 4. And based on its 

review of limited temporary badges and also 

dosimetry entries designated as a "visitor" in the 
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main reports, SC&A was able to identify just 18 

dosimetry entries from the claimant population that 

could be used for V&V. Now, this is 18 actual 

temporary badges. That's as compared to the over 

400 we had from just the 18 people in the earlier 

period. So that might give some idea as to how many 

badges might still be out there to go capture.

The conclusion of this Observation 4 is when the full 

set of temporary badge reports is captured at INL, 

the available population of V&V candidates would 

likely increase markedly. That's Item 3 which was, 

again, can we find V&V cases to judge the 

effectiveness of the coding effort and indexing effort?

Item 4, this gets back to, again, where did you have 

to have a CPP-specific badge during this period to 

enter the plan, or could you have used a badge from 

another location?

So what we did is we went into a semi-random set of 

the claimant population, and it was about 25 percent 

of the total or 115 claims were reviewed. We wanted 

to examine a sufficient cross section of job titles and 

time periods to determine if there were certain jobs 

that maybe were let into the plant on a regular basis 

without a CPP-specific badge.

And this resulted in two observations. SC&A 

Observation 5, with the exception of one job category 

-- which I cannot name for Privacy Act reasons. But 

let's just say I'm not surprised that they didn't have 

multiple badges. All the sample job categories 

showed evidence of multiple area badges during a 

single dosimetry cycle.

That means we didn't really find, except for one job 

which was unique. Every other job, we had examples 

where they would be badged in multiple areas. So 

they'd have a CPP badge, a TAN badge, a CFA badge, 

what have you. And the maximum number of badges 

we saw for a single dosimetry cycle was six, as in that 
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person was actually badged in six separate areas at 

INL during the same monthly time period.

SC&A Observation 6, the practice of multiple area 

badges during a single dosimetry cycle was observed 

for at least some of those sampled claims during 

every month during the period of interest. 

Furthermore, there does not appear to be a 

discernible temporal trend in the percentage of 

claims exhibiting multiple area badges per dosimetry 

cycle; thus, the use of multiple area badges appears 

to be a consistent policy during the 83.14 period.

So conclusions and path forward on this. As for 

conclusions, again, this is going back over the items 

we just discussed. Evidence strongly suggests that 

routing badges for both regular CPP workers and the 

CPP workers designated as construction are complete 

and available. That was Review Item 1.

All available temporary and visitor badges have not 

yet been captured by NIOSH; therefore, 

determinations related to the completeness of those 

badges -- as in, are we missing any; not just missing 

them in the file, but are they still available on site --

can't be made and honestly can't find very many V&V 

cases at all because of the limited amount available 

to us at this time.

SC&A's analysis of a significant portion of the INL 

claimant population concluded that workers were 

required to obtain area-specific badges when moving 

among the major site locations. And again, that's 

one key element of the SEC class that was already 

voted on because it has the criteria that you need an 

area-specific badge.

So again, the path forward is NIOSH is going to 

perform additional data capture at INL to get all those 

temporary badges so we can do a completeness 

evaluation for them and perhaps flesh out the V&V 

population. SC&A will be there working with them on 
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that.

So if there are any questions.

Questions on Presentation

Member Richardson: I have a question. So taking 

an example of -- let's take the extreme example you 

said of somebody who was badged in six areas in a 

badging cycle. Well, administratively, is the worker 

assigned to one main health physics area? And then 

the others are what we're referring to as temporary 

or visitor, would they have one main badging record 

in the IBM system and in that same badging cycle, 

five temporary visitor badges?

Mr. Barton: No, they would actually have a routine 

badge that would remain at that individual sites that 

as they move regularly between the different site 

areas, it'd have a routine badge to pick up at that site 

area.

Member Richardson: And so the IBM record would 

show for a quarter badging cycle six lines of badging 

results?

Mr. Barton: Well, typically, they are separated by 

site area. So each site area will have a printout.

Member Richardson: Okay.

Mr. Barton: But yes, it's the same exact IBM printout 

--

Member Richardson: So what we're referring --

Mr. Barton: -- for each area.

Member Richardson: -- to as temporary or visitor 

badges are something different?

Mr. Barton: Very much so because we have the same 

problem essentially that those temporary badges 

weren't being migrated to the indexing system. So 
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they wouldn't appear necessarily in those printouts.

Member Richardson: So who would be issued a 

temporary or visitor badge?

Mr. Barton: Well, any number of -- if they were only 

going to be there temporarily for perhaps a week or 

a day or two --

Member Richardson: So let's imagine a health 

physicist who's moving around the site and you're 

contending that they don't wear a single badge as 

they move around the site. So health physics staff 

who move between areas would be on the routine 

basis or on the temporary basis of having -- where 

would their dosimetry information appear?

Mr. Barton: Well, like I said, it would depend on the 

individual situation. But certainly, there were 

workers who had a -- I don't want to say permanent 

but a routine badge in each area. As they came out 

of one area, they would drop their badge, go to the 

next area, pick up the other badge, and then go into 

that area. So that's the multiple -- area multiple 

badge.

Member Richardson: And maintenance, painters, 

construction, are they all maintaining multiple 

badges across the site?

Mr. Barton: When we looked at -- which included 

subcontractors, we saw evidence that some of them 

were. Now, of course, there are still the temporary 

badges which we haven't captured a large 

percentage of them to my knowledge. So --

Member Richardson: So --

Mr. Barton: -- really, the answer is, it's a 

combination.

Member Richardson: Okay. And if we think in terms 

of maybe -- I don't know if you have a sense of this. 
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Well, one, the number of records, nonzero and zero 

of temporary badges. But more importantly, the 

collective dose recorded in the temporary badging 

system, do you have a sense of how large that is?

Mr. Barton: I really don't. That would be part of the 

completeness analysis because we'd have to do a 

similar thing of figuring out how many temporary 

badges were issued for a site area -- in this case, CPP 

-- in a given month. And then we'd have to see how 

many we have that month.

Member Richardson: Because really what I'm 

thinking is we've pointed to the problems of linkage 

by poor legibility name. And potentially, is it a full 

name? Is it a full first name and a last name? Or is 

it an initial?

Mr. Barton: Sometimes, it's a first full name, but 

usually, it's a first initial, middle initial, and last 

name.

Member Richardson: And if there's a substantial 

amount of the collective dose that's recorded in the 

system like that which is indexed only by name and 

we've focused on the correct classification of the zero 

records. But I would be equally concerned about the 

misclassification of the nonzero records, if that's just 

-- sometimes we think about these visitor badges as 

being sort of inconsequential.

But if it's being used and it actually represents a 

substantial amount of the collective dose which is 

being distributed, we've got problems of assigning 

dose to people with very similar names. Somebody 

is losing it and somebody else is picking it up.

Mr. Barton: I understand your question, and Tim 

might be able to get into this better than I. But I 

understand it, if you had a positively accrued dose, 

then you would essentially be assigned what's known 

as an S number which is a security number, I guess. 
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Also, they have HP numbers. But once you're 

assigned that S number, typically, you've made it 

into the IBM system.

Now, the question about name spellings and such, I 

guess that would be --

Member Richardson: Okay.

Mr. Barton: -- separate.

Member Richardson: So they're doing some sort of 

greater scrutiny on the nonzero badges and they're 

trying to assign them a unique number which will --

yes.

Mr. Barton: Yes. No, I know.

Member Richardson: It's tricky because they're 

temporary badges again, right? And they would have 

to link them back.

Dr. Taulbee: This is Tim Taulbee. That's absolutely 

correct. Whenever the dosimeter came back as 

positive, regardless of what it was, they got issued 

an S number, as Bob pointed out, and then they were 

entered into the IBM system. So there really isn't a 

large collective dose missing out there from that 

standpoint. That's really not the issue. It's the zeros 

is where the problem is, somebody going into an 

area.

And if I could just elaborate on your health physics 

question, a rad tech going around. If you take, say, 

a health physics technician from TRA and then they 

needed to do work at CPP as well and they had a 

badge at both locations. So they might just have two 

routine badges, but then they got assigned to go 

down to the burial grounds, then they would be 

issued a temporary badge if they weren't on the 

routine badging for that area. So it's a mix.

Member Richardson: Yes.
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Dr. Taulbee: It's not just one or the other. It's a 

mix. If they were routinely going into an area, they 

had a routine badge. These temporary badges that 

we're looking at are people who did not routinely go 

into the area.

Member Richardson: Mm-hmm.

Member Ziemer: This is Ziemer. So am I correct in 

understanding then that if they had multiple badges, 

which could be up to six, they would never be 

wearing more than one of those in a given area; is 

that correct?

Dr. Taulbee: That is correct.

Member Ziemer: Okay. So the dose of record is 

always from the dosimeter that's assigned for that 

particular area then?

Dr. Taulbee: They could have a dose in one area and 

a dose during the same cycle in another area, and 

both of those would be included in the record.

Member Ziemer: Yes, okay. I see what you're 

saying, right.

Mr. Katz: Any other questions?

Member Lockey: Yes, I guess I have one question to 

Bob. I think I understand your concern, but I'm not 

sure. So if somebody had a temporary badge and 

there's actual dose assigned to that badge, then 

they're issued an S number --

Dr. Taulbee: That's correct.

Member Lockey: -- is that correct?

Dr. Taulbee: Yes.

Member Lockey: And when they're issued an S 

number, is the demographic information more 

complete?
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Dr. Taulbee: Yes, to be entered into the system, the 

full name, Social Security number, the S number.

Member Lockey: So does that take care of your 

question?

Dr. Taulbee: I guess so. But operationally, I'm not 

quite sure I see how it happens. The information was 

recorded on an index card. And then how are they 

following back and getting that? It would seem like 

--

This is from the procedures that we were able to read 

about if a positive dose, they were given an S number 

and they were entered into the dosimetry system. 

We've talked to the technician who did this. She's 

actually still alive. But we didn't go into that level of 

detail. How did they do the follow up? I don't know.

Member Richardson: Because you would have the 

record, right.

Dr. Taulbee: But it's in the record saying that they 

did.

Member Richardson: I mean, they've just got a 

badge at that point, and they're processing at least 

temporary badges.

Dr. Taulbee: Well, to go into the site, you had to 

have had a contract or a reason to be there --

Member Richardson: Oh, no.

Dr. Taulbee: -- or reason to --

Member Richardson: Oh, no. I'm saying for how 

they're reassigning, how's the S number retroactively 

being assigned to the dosimeter based on 

information which they don't know whether it's going 

to be positive or a nonpositive in a reading cycle?

Dr. Taulbee: After they read it, my understanding is 

they did follow up to make sure that person got 
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entered into their system.

Member Lockey: I was trying to figure out how they 

went from a temporary badge where nothing was 

recorded, that person is lost to a temporary badge 

where they have a dose. And then they apparently 

follow up, gather the necessary tracking information. 

That's what you're saying happened, correct?

Dr. Taulbee: That's correct.

Mr. Barton: That's our understanding.

Member Anderson: So would a worker have, if they 

went into different areas, multiple S numbers?

Dr. Taulbee: No.

Member Anderson: So how would they know --

Dr. Taulbee: So they have a single security number.

Member Anderson: -- if it's you've got a temporary 

badge that's positive, it's assigned an S number?

Dr. Taulbee: That person is assigned an S number, 

that person is. So then they go into another area --

Member Anderson: But if there's an error in the 

name or something, it would appear as a different 

person.

Dr. Taulbee: Well, that positive badge, they would 

do follow up to identify the person and get a Social 

Security number and get the other information, get 

the right spelling --

Member Anderson: Okay.

Dr. Taulbee: -- that type of thing. There's not many 

of these temporary badges that are positive. Okay? 

And if they are positive, they're actually typically a 

routine worker, one of the Phillips Petroleum workers 

who's going from TRA to CPP type of thing to do a 
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job.

You don't see a lot of the temporary badges, people 

from subcontractors of subcontractors that are 

actually positive. Because remember, construction 

was actually kept separate. So you'll see a few 

construction in the temporary badges but not many. 

It would be the odd construction that would come in. 

The regular construction folks that were allowed to 

go in those areas were on routine badges.

Member Richardson: So you're getting back to my 

question. Your sense of the collective dose on the 

temporary or visitor badges is very small?

Dr. Taulbee: That's correct.

Member Lockey: But it's still recorded?

Dr. Taulbee: Yes.

Member Lockey: Okay. Small but recorded, right?

Dr. Taulbee: It is.

Member Lockey: Is there any evidence of the 

temporary badge where there was a dose? Or you 

don't have additional information, you didn't get an 

S, I guess you wouldn't have that information or 

maybe you do?

Dr. Taulbee: I don't know the answer to that.

Mr. Katz: Other questions, Board Members? Okay 

then. Thank you, Bob. Thank you, Tim. More to 

come. I expect INL will be on the agenda for the next 

meeting. Because by then, we should have a followup on a number of all these matters, I think. Okay.

So we move on to Pacific Proving Grounds. This is a 

follow-up. We've had more extensive presentation 

on this. We had an issue raised, and Jim will remind 

you what the issue was and --
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Mr. Hinnefeld: Ted, just one comment. This is also 

a PDF, and so it's not on this. I can't show it on 

Skype, but I can show it to the room.

Mr. Katz: Okay. So for folks who are following by 

Skype, you can pick this material up on the website. 

But you won't have a page-by-page following of that 

by Skype.

Dr. Neton: Thanks, Ted.

Mr. Katz: Next we have Jim. Thank you.

Dr. Neton: Just like my presentation yesterday, this 

is not a new slide deck. This is an excerpt of the 

presentation that Dr. Lockey gave back at the Santa 

Fe Board Meeting in August of last year. About a year 

since this issue has been raised, but it took us a while 

to get there. But I think we've resolved the issue.

Just to remind everyone, Pacific Proving Grounds, I 

looked up this morning, was SEC 20. That's quite a 

while back, back in 2005, I believe, where Pacific 

Proving Grounds was granted an SEC for the entire 

covered period of 1946 to '62.

Subsequent to the issuance of that SEC --

establishment of that SEC, SC&A years later was 

tasked with reviewing the Site Profile for the site, Rev 

00, and that was around the 2013 time frame. And 

the Work Group took that task to heart. And over 

the next several years -- and these are just some 

summaries of excerpts of what Dr. Lockey went over. 

I just want to establish the review cycle we went 

through here.

We went through a series of Work Group meetings. 

There were a number of findings issued. All findings 

-- an agreement was made to resolve all the findings 

and put in advance until Rev 01 was issued. Rev 01 

came out in July of 2016, and SC&A reviewed Rev 01 

to make sure that we followed up on those issues and 

correctly close out the issue of the revision.
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And the review came out in December 2016. They 

concurred with all of the revisions that we made and 

recommended closure. And in April 2017, the Work 

Group concurred with SC&A's recommendation and 

closed all the findings.

This is when Dr. Lockey presented in August last year 

and said the Work Group concurred with the findings. 

But at that time, Dr. Melius had a question, and this 

relates -- and I've highlighted in yellow here the 

specific issue Dr. Melius raised which specifically 

refers to Findings 3, 4, 8, and 9. They're all sort of 

related to the same thing. They're related to issues 

related to cohort badging, estimation of missed dose, 

and use of the 50th percentile.

And one thing that caught Dr. Melius' eye was what I 

highlighted in the first bullet under there that said

that these issues are intractable. Well, sort of by 

definition, that means they can't be solved or not 

readily solved. And nonetheless, the finding was 

closed saying the use of 95th percentile was 

reasonable.

I agreed at that time to go and look at the Site Profile 

and see what we could do about this sort of 

incongruity that was apparent. And I did. I went 

back and looked at the Site Profile.

And it turns out in the Site Profile for the Pacific 

Proving Grounds, there's a number of tests that 

occurred, about 15 or so, that were covered in the 

Site Profile. And each one had data that was based 

on categorical data or summary data bins of exposure 

categories. We knew how many badges there were 

and there was a listing in these DOE reports of 

exposure from 0 to 40 milliroentgen and 40 to 100 

and so on, up to about 3 roentgen to whatever.

And so we didn't have a complete data set. We had 

a summary of the data, and we fit a lot of normal 

distribution of that. And that's what we used for the 
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coworker model.

Well, interestingly, when I went back through the 

Site Profile to review it, a sentence caught my eye 

which said, this categorical data provides a 50th dose 

for each operation and can be used as coworker dose 

until such time as coworker data is available.

So it was intended to be temporary all along. And in 

discussing this with Tim Taulbee, he informed me 

that the Department of Energy indeed had all the 

badges. And we should get them and develop a 

coworker model from that. And that's, indeed, what 

we did.

With a little help from -- we had to persuade them a 

little bit. But when they finally eventually provided 

us 57,000 individual badge reads for all those sites, 

those badge reads were coded -- individual badge 

reads. And log-normal distributions fit to each shot 

from those badge reads. And we developed the 95th 

percentile values from them.

A little bit of a glitch here in the sense that these did 

not exactly -- in some cases, they did not fit a lognormal distribution very well because for the higher 

dose shots, as you get higher up into the exposure 

range, it tails off like you would expect when people 

start approaching the exposure limits. It's a wellknown phenomenon in occupational monitoring 

where that can happen when you get into the higher 

exposure rates.

So instead of that, we did not end up using the lognormal distribution but we use an empirical fit to the 

95th percentile rank order value of the distribution. 

And so now, indeed, we issued -- in July, I think, a 

couple of months ago or last month, we issued Rev 

02 of the Site Profile which has individual coworker 

models based on all the data that we obtained from 

the DOE for the individual badge results.
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And I believe that that solves this issue. It gets rid 

of -- we incorporated missed dose into this model. 

The cohort badging issue, in my mind, goes away at 

that point. And use of the 50th percentile didn't 

make a lot of sense because you really don't know 

what these people did.

When you go there, a job category is really not that 

informative of what the potential exposure would've 

been. So everyone would receive the 95th percentile 

missed dose if they weren't badged. And if they were 

badged, I think the Site Profile now says that to 

compare the two and take the 95th percentile or the 

collective dose that was reported in the badges and 

pick the higher of the two. So you're always going to 

be claiming favorable in that respect.

Member Richardson: So at this point, many people 

would have individual badging records?

Dr. Neton: Yes. We have individual -- DOE always 

provided us individual badge results. They wouldn't 

just parse them out of their database and give them 

to us. We requested the entire databases, included 

other cells. And that's how we developed the 

coworker model. We're no longer relying on those 

categorical data sets that were extracted from 

summary reports.

So I think that solves or addresses this issue. And 

I'll take Dr. Lockey's part here, but the Work Group 

met last week on August 10th. The Work Group met 

on August 10th and concurred with our resolution on 

this issue.

So that's all I have to say.

Mr. Katz: Dr. Lockey, do you want to say anything?

Member Lockey: It's well said. I think we've come 

to a conclusion with this particular -- with PPG. And 

I think we can present to the Board that we should 

accept the NIOSH recommendations and close it.
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Mr. Katz: Questions from Board Members?

Member Lockey: It's a great data set.

Mr. Katz: Not hearing any questions on the phone 

from Board Members? 

Member Roessler: None here.

Mr. Katz: Okay. Lacking any questions, we have a -

-

Member Ziemer: Well, did this result in a PER or 

what's the overall outcome on this in terms of impact 

on previous done dose reconstructions?

Dr. Neton: Yes, good question, Dr. Ziemer. This is

Jim Neton. Yes, a PER will be initiated on this. Some 

of the 95th percentiles were actually higher in a 

number of cases than the categorical 95th 

percentiles, so yes.

I would say there aren't that many cases. I think I 

checked this morning, and we have 223 total cases 

from the Pacific Proving Grounds, three active and it's 

in SEC already, of course. So it would only involve -

- we're doing cases that were not paid by the SEC.

Mr. Katz: Any other questions? Okay then. So we 

have a recommendation from the Work Group that 

the Board conclude its review of this Site Profile. And 

we don't need a second for that. So if everyone is 

ready, we'll take a vote.

Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?
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Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.

Mr. Katz: Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer?

Member Ziemer: Yes.

Mr. Katz: And it's unanimous. The motion passes, 

and that Site Profile review is completed. And much 

thanks to the Chair, the Work Group Members, SC&A, 

NIOSH for all the work that went into getting this 

review done. It's great. Okay. Without my glasses, 

I can't read the time. I think it's 9:47. Thank you. 

So we finished a little early, and the next up is De 

Soto. I'm looking for the petitioner.

Okay. So let's take a break. What I'm hoping to do 

is actually start that session early. Since we have the 
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petitioner here, I think we could do that. So right 

now -- I mean, our break is listed to go to 10:30, but 

we're early.

So why don't we try to -- assuming that I can find 

the petitioner, we can get started early. Why don't 

we plan -- it's 9:50. Well, it's pretty close to time. 

Let's try to start at about 10:05, if we can be back 

here then. And if the petitioner is ready, we'll do 

that. Otherwise, we'll wait till 10:15.

Thank you.

(Whereupon, the above-entitled matter went off the 

record at 9:50 a.m. and resumed at 10:12 a.m.)

Mr. Katz: So we're back after a recess. We're just 

going to start a little bit early for the De Soto -- barely 

early for the De Soto session. So let me just check 

and make sure I have my Board Members on the line. 

Paul and Gen?

Member Ziemer: Yes, we're here.

Member Roessler: This is Gen. I'm here.

Mr. Katz: And Bill?

Member Field: Yes, I'm here.

Mr. Katz: Super, thanks. Okay then. Off we go. 

Lara?

De Soto Facility SEC Petition #246

Dr. Hughes: Okay. Thank you, Ted. Good morning, 

everybody. This is the NIOSH presentation for the 

De Soto Avenue Facility SEC evaluation.

At this point, I'd like to acknowledge the support from 

our contractor, Monica Harrison-Maples, who did the 

majority of the work of bringing the Evaluation 

Report together.
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So the De Soto facility is closely related to Area IV of 

the Santa Susana Field Laboratory of which you are 

somewhat familiar with because we've had actually 

four different SEC petitions in the past -- SEC-93, 

156, and 234 -- all recommended classes to be added 

to the SEC effectively resulting in the entire 

operational period of Area IV being covered under an 

SEC.

There was also one prior SEC evaluation for the De 

Soto facility that was related to issues with internal 

data or bioassay data. And that goes from 1959 

through 1964. The current SEC Petition 246, at this 

point, NIOSH does not recommend adding a class to 

the SEC.

This petition was received December 2017, and 

additional supporting documents were provided in 

February and March of 2018. The requested class 

was all workers who worked at the De Soto Avenue 

Facility from a period from January 1st, 1965 through 

December 31st, 1995. This is the entire operational 

period, not including a remediation period in 1998.

This petition qualified on March 1st of this year. We 

did not modify the petitioner requested class in any 

way. The Evaluation Report was completed and sent 

to the Board in July of this year within the 180-day 

time frame. And NIOSH does not recommend a class 

to be added to the SEC.

The reasons this petition qualified was that the 

previous evaluation for Area IV was added to the SEC 

because of issues with thorium and americium 

exposures that cannot be reconstructed at Area IV. 

Now, this sites are closely related. They share health 

and safety oversight, health physics oversight. They 

share workers. So naturally, it seems likely that the 

same issues pertain to the De Soto Facility.

The petition requested us to look into americium and 

thorium at the De Soto Facility related to the SRE 
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relations. There are some called the TRUMP-S 

program and the SNAP reactor, a fuel fabrication. 

There's some indication of thorium fabrication work.

And NIOSH is also aware of the issues with controls 

with environment pollution as the bioassay 

contractor from '92 to '94. This was the subject of a 

previous evaluation for Area IV. And so we naturally 

needed to look into that for the De Soto Facility as 

well.

A little bit of the statistics, the total number of claims 

that are submitted to NIOSH for dose reconstruction 

are 292 as of July. The total number of claims for 

workers who worked during the period under 

evaluation in this petition evaluation is 255 -- 210 of 

those are completed, 64 of those had internal 

dosimetry records for the evaluated period, and 104 

had external dosimetry records for the evaluated 

period.

The site description, the site is located at 8900 De 

Soto Avenue in Canoga Park, California. There's a 

little cutout of a map showing the Greater Los 

Angeles area. Santa Susana Field Laboratory, SSFL, 

is labeled. And you can see the relative location of 

the De Soto Facility.

Again, the DOE covered period is 1959 through 1995 

with a remediation period in '98. And this is a fairly 

large facility consisting of several buildings. Two of 

these buildings were involved in radiological work. 

Building 001 was used for fuel fabrication, and 

Building 004 was used for research and development 

and also has a facility called the Gamma Irradiation 

Facility and the Helium Mass Spectrometry Lab.

This is a blueprint of the De Soto Facility. You can 

see the two highlighted buildings, Buildings 001 and 

004, along with other buildings that were not 

involved in the DOE contracted radiological work.
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The facility was constructed in 1959 and became the 

headquarters of Atomics International. It was moved 

from the Canoga Avenue Facility which is also a 

related site in the area.

DOE operations from 1959 through 1995 consisted of 

engineering design and construction of operations 

supporting DOE operations at Area IV and De Soto 

Facility, they did nuclear fuel fabrication until 1983. 

They housed the L-77 research reactor until October 

1974 when it was decommissioned and the fuel 

removed in 1976. The Gamma Irradiation Facility 

operated from 1966 through 1994. The Helium Mass 

Spec Lab, they did radiochemistry support for 

operations at De Soto and Area IV and they did fuel 

fabrication for the SNAP program from 1955 through 

1973.

So as operations wound down in the 1980s for most 

of the nuclear activities except Gamma Irradiation 

and Mass Spec Lab, those nuclear areas that 

supported fuel fabrication were decommissioned 

around the 1984 time frame. The Gamma Irradiation 

Facility operated up until '94 and the Mass Spec Lab 

until 1995. These two facilities, the Gamma 

Irradiation Facility and the Mass Spec Lab, were 

decommissioned in 1998. That's what is this one 

year remediation period.

So to evaluate this petition, we looked at our typical 

information researches, the Site Profile, coworkers 

studies. We researched the NIOSH Site Research 

Database where we have accumulated over 3,000 

documents that are related to Santa Susana Field 

Laboratory, Area IV, and all related sites.

We looked at the existing claimant files. We looked 

at the database that contains all of the work force 

that were monitored for radiation. We have those 

scans so we can look at those for information. We 

looked at the documentation provided by the 

petitioner, and we had some interviews that were 
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previously done. And we conducted a few more 

interviews of former workers of the De Soto Avenue 

Facility and Santa Susana Field Laboratory.

So we looked into the two main focus points of this 

petition was americium and thorium. We looked into 

any operation with americium. There are some 

instances of americium storage and shipping 

operations from the vault at the De Soto Facility. The 

facility also had a license to fabricate Americium 

sources. But we found no information or indication 

that the source fabrication or any other operation 

involving americium took place at the site. 

Interviews confirmed that.

We also found no occupational exposure data for 

americium. We would kind of expect to see some 

indication in the documentation if there was handson activity operation with americium that there would 

be some kind of indication of that in the health and 

safety health physics files. The only use of americium 

we found was in commercial products such as in 

smoke detectors.

Now, for the thorium, it's a little different. There's a 

brief campaign in May and June of 1970 where they 

produced a fuel simulant containing thorium oxide. 

This was a simulated fuel. It was not to be used in 

an actual reactor, but they were using it for stress 

testing, what would happen to it if it was basically 

blown up in one of these space reactors -- the SNAP 

reactors.

Now, the testing was not done at De Soto. It was 

done at Sandia. So the only thing that was done at 

De Soto for this campaign was that they produced --

they pressed it into discs. And then after it has been 

tested, they took it back apart and disposed or 

processed the product after the campaign was 

complete.

There was an application for a use of thorium oxide 
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in 1971, but we found no indication that this was 

actually done at the site. There was no -- this was 

something that was apparently planned but didn't 

pan out. And so in 1979 was another campaign 

consisting of machining thorium metal plates. That 

was a much larger operation that was out in the 

open.

I should say that the operation in 1970 was done in 

enclosures in glove boxes and that type of thing. The 

1979 machining operation has same safeguards, but 

it was out in the open.

For both of these campaigns, we have bioassay and 

air data. And both of these were relatively small 

scale processes. They were well documented down 

to the names of the operators that were involved. 

There are logs of who did what when, and we actually 

have these workers' files.

So we looked into the petition concerns. One of the 

petition concerns was that the SRE fuel, the SRE, the 

sodium reactor experiment. That was run at Area IV, 

this reactor used several cores, different core 

configurations. And one of them contained thorium 

in the fuel. They're all indications that this thorium 

fuel was fabricated and stored at Area IV. It was not 

produced or handled at De Soto.

There are some indications that the fuel for the Core 

3 might have been stored or some fuel elements, fuel 

slugs maybe that were for Core 3 for the SRE 

might've passed through De Soto, but those were 

uranium containing.

The SNAP fuel production operations only consisted 

of uranium. There was also no used fuel handling at 

De Soto. This was done at Area IV. The fuel handling 

was done before, it was put in the reactor, essentially 

not after.

This TRUMP-S program, there's no indication this was 
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ever operational. This was some kind of small scale 

research program that tried to investigate the -- it 

was like a waste processing experiment that was not 

actually ever -- that didn't actually take off, neither 

at Area IV or De Soto.

So as for the CEP issues as the primary vendor for 

urine bioassay samples from '92 to '94. That time 

period at the De Soto Facilities, all nuclear facilities 

had been D&D'd except for the Gamma Irradiation 

Facility and the Mass Spec Lab. And as was the 

conclusion for SEC-00235, for Area IV, we found no 

impact on the feasibility to do dose reconstruction 

due to disregarding the CEP associated data from '92 

to '94.

So the internal exposure potential at the De Soto 

Facility was inhalation ingestion of radioactive 

contamination from unsealed materials from fuel 

production and radiochemistry operations. The De 

Soto internal exposure potential is a little different 

from Area IV. It's mostly uranium from fuel 

production. There was this -- they had this facility 

that did the Uranium-Aluminide fuel for the advanced 

test reactor that was run at Area IV.

This is the potentially limiting exposure scenario at 

the De Soto Facility, and it has been realized in the 

past. And NIOSH has developed a special DR 

methodology for these Uranium-Aluminide workers. 

And this is currently in the Technical Basis Document. 

The thorium work again was only episodic in 1970 

and 1979. And there's no indication of americium 

exposure potential.

We have internal monitoring data available for 

radiation workers that worked in high contamination 

areas. Workers that handled unencapsulated 

radiological materials were generally monitored for 

internal exposure.

There was also some called special samples that were 
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typically triggered by high air sample results. So 

these are in vitro and in vivo routine monitoring data 

that are available. They had a radiological controls 

manual in place, and this was an event-condition 

driven special sampling program that was available. 

Again, that was mostly triggered by air sample data.

So how do we propose to reconstruct thorium doses? 

So the 1970 operation was this production and posttest analysis of simulated fuel disks. And the 1979 

machining operation of thorium metal discs, we 

consider as a dose bounding operation. This was an 

operation that was a much larger quantity. It 

involved machining, and it had limited containment. 

It was an eight-day operation.

We have the operational detail and worker rosters. 

The main operator had a baseline and a post-work 

analyses for thorium. We also have lapel air sample 

results. We can take those bioassay data and 

develop a chronic intake for natural thorium using 

this MDA level that is available and assign doses 

based on those intakes.

So in conclusion, the fuel fabrication operations at the 

De Soto Facility present no dose reconstruction 

infeasibility. Bioassay is generally available after 

1965. The coworker model is available for potential 

unmonitored internal exposures. We have identified 

no exposures to americium. And the thorium 

campaigns in 1970 and 1979 have thorium-specific 

personnel and workplace monitoring. And does can 

be bounded. Also, the lack of the CEP data does not 

affect NIOSH's ability to perform sufficiently accurate 

internal dose reconstructions.

So this is our summary slide. And with that, I am 

finished and welcome questions.

Questions on Presentation

Mr. Katz: Thank you, Lara. We do have questions 
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from Board Members in the room. Dave?

Member Kotelchuck: The folks at the Santa Susana 

Field Laboratory, they're covered in an SEC through 

1988. But you're suggesting that in the -- you were 

proposing that in the De Soto Facility, you can 

determine the radiation levels with reasonable 

accuracy. And therefore, you request denying this 

petition.

Tell us a little bit about how the personnel -- how you 

dealt with personnel moving between the different 

facilities, which we've heard about from the folks 

there in the past. How separate were the workers, 

or how much did they go back and forth between the 

two places?

Dr. Hughes: They can go back and forth as they are 

assigned. It's my understanding they are employed 

by the same employer, the De Soto Facility and Area 

IV. So they could assign any worker. I mean, I don't 

know how much input they have. But yes, they could 

assign a worker to the De Soto Facility from Area IV.

Member Kotelchuck: But that's what we've heard. 

But you don't know what kind of exposure they've 

had. We cannot determine what kind of exposure 

they had during this period in the SSFL facility. 

Therefore, people are going back and forth and 

getting exposed in both facilities. And how can you -

- I'm a little confused as to how you feel like that you 

can determine the exposure in the De Soto Facility 

only.

Mr. Hinnefeld: If I could offer something. This is Stu 

Hinnefeld. The SEC determination has to be a sitespecific determination -- covered site specific. And 

so what we've reached -- the conclusion we reached 

on SEC is for the exposures that occurred at the De 

Soto facility, we have sufficient information to do 

sufficiently accurate dose reconstruction.
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We recognize that people would be -- may move back

and forth, but that would be an issue for the 

Department of Labor to verify that they had 250 days 

of employment at Santa Susana. So Department of 

Energy determines where people were and how long 

they spent at the covered facility. So in that case, it 

would be up to them to determine whether a person 

spent 250 days at Santa Susana during this time.

Member Kotelchuck: Oh, so it's the site specificity?

Mr. Hinnefeld: An SEC determination is a sitespecific determination.

Member Kotelchuck: Okay. Thank you.

Member Lockey: So can I follow up on that?

Mr. Katz: Of course.

Member Lockey: So if somebody is at SSFL or 

somebody is at De Soto and went to SSFL for a week 

and then came back to De Soto, they would be --

their exposures at SSFL would not be considered in 

relationship to whether they --

Mr. Hinnefeld: Depending on what their exposures 

were at SSFL. There are certain kinds of exposures 

at SSFL we can't reconstruct.

Member Lockey: That's right.

Mr. Hinnefeld: And so those would not be included 

in the dose reconstruction. If we had that kind of 

granularity in their exposure record, yes.

Member Lockey: But they would not be considered 

as part of the SEC then?

Mr. Hinnefeld: Well, it would be up to the 

Department of Labor to determine whether they 

spent enough time at SSFL to be in the SEC at SSFL. 

They would need 250 days there.
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Member Lockey: Oh, I see. So DOL would have to 

say they spent 250 days at that facility?

Mr. Hinnefeld: Yes.

Member Lockey: Okay. That's what I was asking. 

Okay.

Mr. Hinnefeld: Yes.

Member Roessler: This is Gen. I have a question --

Mr. Katz: Yes, Gen. Go ahead.

Member Roessler: -- with regard to Work Group. Is 

the Work Group for this facility the same as the one 

for Santa Susana?

Mr. Katz: Yes.

Member Roessler: Okay. I thought it was, but I just 

wanted to verify. Thanks. I guess, then, has the 

Work Group met on this --

Mr. Katz: No, this is being newly presented, Gen --

Member Roessler: Okay.

Mr. Katz: -- at this Board meeting.

Member Roessler: Okay.

Member Beach: My question --

Mr. Katz: Go ahead, Josie.

Member Beach: -- is on the badging. How are the 

employees -- I know they're going back and forth 

between the two facilities. How are we tracking the 

badging between the two facilities? Are they badged 

independently or one badge and it can go either 

direction? Do you have any comments on that?

Dr. Hughes: I'm not sure. We focus so much on the 

internal. I believe they don't. They're not 
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individually badged at each site. I have not seen 

concurrent. Like, they don't have one badge at De 

Soto and one at Area IV. I think it's -- I mean, the -

- I'm not sure they go back and forth.

If you have an individual that would go back and forth 

a lot, I would think they would carry their badge with 

them. But that's really something I would have to 

verify. They also work a fair amount with visitor 

badges, so it could very well be that a worker at Area 

IV who was regularly badged would go to De Soto 

temporarily and would receive a visitor badge.

I'm not sure. We have to verify that because we 

haven't looked a whole lot into the badging issue. We 

know it's generally available. We were able to do an 

external coworker model. I mean, there's not really 

been an issue. But it's a good question.

Member Beach: And then bioassay data, is that 

tracked through De Soto or SSFL?

Dr. Hughes: It's all one -- it's one operation. It's one 

corporate entity, so it's all -- it's one. If you pull up 

any given worker's record, you cannot tell necessarily 

where they worked. We only know they were 

monitored, when you see the bioassay data, 

whatever was sent back from the -- whoever was the 

vendor at the time, that sort of thing.

So who worked where when is really -- it's a job for 

DOL to parse out, and it's not an easy one, I 

understand.

Member Richardson: Just to follow up on Josie and 

David's question, so it's not the badge which DOL 

would be able to turn to, to say that that person 

worked 250 days at Area IV?

Dr. Hughes: It's my understanding DOL goes by the 

human resource records they receive from Boeing 

which often are related to where the person stamped 

their timecard which may or may not be the location 
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where they worked. It's been a problem with DOL 

being able to verify for the entire --

Member Richardson: Oh, I can imagine.

Dr. Hughes: Yes.

Mr. Katz: Phil?

Member Schofield: Do you have access to incident 

reports like nasal swipes or smears --

Dr. Hughes: We do have --

Member Schofield: -- and what their analysis was 

and levels?

Dr. Hughes: Yes, we do. We do have incident report 

access. There's a database that contains incident 

reports that were logged. They typically contain the 

names, what happened, what kind of follow up was 

done. We have not specifically looked for nasal swipe 

data. I know we have breathing zone data for this 

particular thorium operation. I'm not sure about the 

nasal swipes.

Member Schofield: Okay.

Member Richardson: Turning to the issues of 

americium and thorium, you described two activities 

that you identified involving thorium, one of them 

fabrication of thorium fuels and the other one 

grinding of substantial quantities. I guess they were 

working with thorium in the late '70s. It's 

somewhere around 200 kilograms of thorium.

Dr. Hughes: Yes, they did this for some -- I think it

was a Japanese entity. So they didn't actually use 

the thorium after it was done which is something they 

did for -- it was a contract operation of some sort.

Member Richardson: And I understood you to say 

that the latter activity -- could you describe again? I 

thought --
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Dr. Hughes: Yes.

Member Richardson: -- you had said it was outdoor, 

open --

Dr. Hughes: No, it was -- well, it was in the lab but 

it was out in the open. It was a machining operation, 

so there was a lathe involved, I guess. And there 

was a higher potential for creating airborne compared 

to this 1970 operation which was done in a glove box 

enclosure.

Member Richardson: Right. And so for 

reconstructing thorium -- a dose from an intake of 

thorium, in the latter situation, you had pointed to a 

roster of people involved in that list. But was there 

control over movement through that area? Or are 

you relying on records which would say that 

somebody spent some time or passed through there?

Dr. Hughes: Yes, it was one room in the facility. And 

so there was a list of this, basically a name -- one 

name. Like, this is the main operator and this is his 

helper. And he did this operation on this-and-this 

date from this-and-this time period, that sort of 

thing.

Member Richardson: And I understand that in terms 

of sort of the primary person who's involved in the 

activity. But what is NIOSH imagining for 

reconstruction of exposures to thorium in that 

situation in terms of other people who may have been 

in the room, who may have moved through the room. 

Was the room completely -- assumed to be 

completely clear after we were done?

Dr. Hughes: It was cleaned up after it was done. As 

for the person passing through, we have really no 

way of --

Member Richardson: But again --

Dr. Hughes: -- determining that.
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Member Richardson: -- what's NIOSH proposing to 

do?

Dr. Hughes: We could bound the dose using the 

operator data.

Member Richardson: For everybody at that site?

Dr. Hughes: No, probably people that would have 

been involved in the thorium operation.

Member Richardson: So you're imagining bounding 

dose for the short list of people who are on the roster 

of specifically conducting the activity but for nobody 

else?

Dr. Hughes: I would think so, unless there's 

indication that they happen to, you know, be in this 

room for some reason.

Member Richardson: And what would that indication 

be? Because we can't even place them in Area IV 

versus De Soto in terms of placing them in that room.

Dr. Hughes: Well, it would come out of the -- like, 

an interview or personal information that somehow 

relate.

Member Richardson: So you're asking them to 

recollect in 1979 whether they were in a room or not?

Dr. Hughes: Well --

Member Richardson: I'm just asking.

Dr. Hughes: Yes, I mean --

Member Richardson: I mean, because the proposal 

is that it is feasible to reconstruct this.

Dr. Hughes: It is feasible.

Dr. Neton: This is Jim. I think this is a situation we 

face all the time where we can't clearly identify who 
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may have been in and about the room. And this is a 

fairly short duration operation?

Dr. Hughes: Eight days.

Dr. Neton: Eight day operation? I don't see why 

wouldn't, at this point, say anybody who had the 

potential to be in that area we would assign the full 

exposure to maybe the 50th percentile. I'm not sure. 

We haven't clearly got all the details worked out. But 

I don't see how we could limit it. I agree with you 

that it's very difficult in these situations to say it's 

only the operators. There are other maintenance 

staff and such that would've been there involved. So 

I think we would expand that list to include certainly 

people that had potential to be in that area, 

operators, that sort of thing.

Member Richardson: But right now, it's -- how this 

is actually going to work isn't quite figured out.

Dr. Neton: I thought we had done that, but I'm not 

recollecting right now.

Dr. Hughes: We've done some dose assessments 

based on the operator data, but we haven't done --

we could certainly provide, like, sample dose 

reconstructions for various --

Dr. Neton: We focus mainly on the bounding issue 

and then how you attribute it to the other classes. 

It's pretty standard procedure, though, in this case 

that anyone who would've, could've been an operator 

working in that area would've been -- received the 

95th percentile, and administrative type folks who 

could've passed through probably would be the 50th 

percentile. It's a fairly standard approach that we 

use for these types of situations.

Member Richardson: Yes, I mean, I get that for the 

people who are conducting the activity. But I was 

just trying to clarify what's going to happen with --

you know, maybe I'm naive. I'm imaging 200 
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kilograms of thorium as being something substantial.

Dr. Neton: It's not as much as you think. Thorium 

is a pretty dense metal, and I think there was some 

limited operations. I think it was trimming these 

plates. I forget. It was --

Dr. Hughes: They grind the corners off.

Dr. Neton: Cut the corners off of these plates. I 

mean, and we have lapel air sample data. It was 

pretty low values. I mean, these were not extreme 

situations.

Member Richardson: And the other activity, the --

the manufacture of fuel?

Dr. Neton: Oh, the fuel in the -- as a glove box 

operation? Lara?

Dr. Hughes: Yes, it was a glove box operation that 

consists of milling some thorium oxide, coating it with 

molybdenum, and then pressing it into these fuel 

plates, I believe.

Mr. Katz: Other questions from Board Members? 

Brad?

Member Clawson: Yes, Lara, we're talking about a 

hot shop down there at De Soto. So they built this 

fuel. They took it up. They ran it, and then they 

brought it back to the hot shop to disassemble it and 

research it?

Dr. Hughes: No, the -- well, the hot cell facility was 

at Area IV. So they did not use -- they didn't take 

spent nuclear fuel from a reactor into the De Soto 

facility. There are no indications. They didn't have 

the facilities to do that.

Member Clawson: Okay. So that was up in Area IV?

Dr. Hughes: Yes.
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Member Clawson: Okay.

Mr. Katz: Do we have questions from any of the 

Board Members on the line?

Member Ziemer: No questions.

Member Field: No questions here.

Member Roessler: No further questions.

Mr. Katz: Thanks. Loretta?

Member Valerio: So if a DeSoto employee was at 

Area IV and involved in an incident, would that --

number one, I would assume that the duration of that 

incident, the follow-up would all be documented in 

the records. Is that going to be in the Area IV records 

or in the De Soto records?

Dr. Hughes: There is no differentiation. If we receive 

a claim and we request the claim data, we get one 

single packet of radiation dose records from Boeing, 

I guess. And there is no differentiation. From solely 

looking at those records, we cannot tell where this 

person worked. It was all one company, one 

oversight, one health physics program.

Member Valerio: But it would document the date of 

the incident if there was an --

Dr. Hughes: Yes.

Member Valerio: -- incident --

Dr. Hughes: Yes, so you can --

Member Valerio: -- situation --

Dr. Hughes: Based on -- yes, you could potentially 

place a worker based on this type of evidence. So if 

they say, well, there was an incident at, you know, 

the SNAP fuel production involving uranium 

aluminide, that would place him at De Soto. If there 
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was an incident at, let's say, the SRE, that would 

clearly place them at Area IV.

So, yes, we can use that type of information that was 

in there. But there's no clear-cut information saying, 

you know, Joe Smith worked at De Soto from thisand-this period to this-and-this period. This is 

something DOL works out or tries to work out with 

Boeing, as I understand.

Mr. Katz: Dave?

Member Kotelchuck: Well, I appreciate that the SEC 

has to be determined at a site. But I am troubled by 

the suggestion here that there seems to be an 

apparent unfairness to individual workers because 

let's talk about the americium and thorium.

A person working for two years, let's say '80 to '82 

for a couple of years, we would be able -- they would 

be -- if we accept the recommendations, they would 

be individually assessed. We have to say we don't 

know what -- we know what their thorium and 

americium exposures are at De Soto. I accept that. 

The De Soto facility, if a person worked full time --

I'll back off.

If the person worked full time at the De Soto Facility, 

we can assess their exposure to thorium or 

americium. But if they worked at both for a couple 

of years, then we can't determine it at one place but 

we can determine it at the other. And we're going to 

make an individual assessment.

So we're going to -- part of their exposure cannot be 

assessed and other part can be. It just seems to me 

that it is a troubling thing if I were a worker and 

trying to -- and for us to make an assessment about 

the worker's exposure.

May I ask, does the -- the Working Group discussed 

this issue of De Soto and --
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Mr. Katz: No, this hasn't been presented to --

(Simultaneous speaking.)

Mr. Katz: -- the Working Group because this is being 

presented newly right now.

Member Kotelchuck: But we have a Working Group.

Mr. Katz: We have a Working Group, right.

Member Schofield: This has not been before us yet.

Member Kotelchuck: Oh, okay. So we're not looking 

to vote on this recommendation today but to consider 

it and then go to the Working Group. And then the 

Working Group will present it.

Mr. Katz: It's entirely up to this Board whether it 

goes to a Working Group or not and whether we do 

any tasking or not and so on.

Member Lockey: So let me make sure I understand 

your question, though. What I understood before is 

that the SSFL is already an SEC. So if somebody 

worked at De Soto and spent more than 250 days at 

SSFL, they're in the SEC?

Member Kotelchuck: That's correct.

Member Lockey: That's the end of it. So you don't 

have to worry about it at that point because if they 

spend 250 days there, they're already in the SEC. 

Because even though they are assigned to De Soto, 

if they spent more than 250 days at SSFL, they're 

automatically in the SEC?

Member Kotelchuck: Right. And if they worked less 

than that, than 250 days --

Member Lockey: Then they wouldn't --

Member Kotelchuck: -- at the SSFL --
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Member Lockey: -- DOL would not qualify them.

Member Kotelchuck: -- then you will make an 

individual assessment of their exposure if we --

Member Lockey: That's correct.

Member Kotelchuck: Yes, to me, that's still troubling. 

But I would think that we -- I would like to hear from 

a Working Group about this and their assessment. Is 

there some way to resolve a potential problem?

Member Schofield: Did you have any -- find any 

indication? Say, a person is badged out of De Soto. 

If they go back and forth, maybe they're spending 

half their time up at Area IV but yet they're badged 

out of De Soto. So it doesn't necessarily -- you said 

it's all under Boeing. How can you determine how 

much time they spent up at Area IV and how much 

time did they spend at De Soto?

I mean, is there -- as far as I know from what we've 

gone through in the past, there is not any way, like, 

a login book or something when people came into 

Area IV. I may be wrong on that, but my 

understanding, if you had a badge that covered both 

areas or allowed you to go back and forth, you 

weren't logged in. You didn't get a visitor badge.

Mr. Katz: Phil, I mean, this is just -- this is well trod 

turf you're talking about now. This has been 

discussed many times, and it is not the provenance 

of the Board or NIOSH to make these determinations 

as to how many days you have at a facility. That 

lands with DOL. It's stuck with DOL. It's not for us.

We may not like the situation there and so on. It 

doesn't really matter. It's not our provenance, and 

we can't resolve it. We can't act on it in any way. 

That's DOL's business. So I know there's been lots 

of communication about issues related to this, of 

course. It's understandable.
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But that's really not something for the Board to spend 

its time on or its Work Groups to spend its time on. 

And frankly, NIOSH can only provide information 

related to that and it does when it has issues with 

that. But that's as far as it goes. It's not for us to 

make any determinations on an individual's basis or 

what have you.

Member Clawson: But that being said, the Work 

Group has not been able to look at this yet.

Member Schofield: No, we have not.

Member Clawson: So we could move to have this 

Work Group evaluate this and then get back to the 

Board.

Mr. Katz: Right. Just not the DOL issue --

Member Clawson: Right.

Mr. Katz: -- because that's not for the Work Group 

to --

(Simultaneous speaking.)

Member Richardson: Can I --

Mr. Katz: Dave?

Member Richardson: -- move from the time issue to 

back to Brad's previous question. The 

characterization of the De Soto Facility, as I 

understood it, Brad posed the question, was fuel 

fabricated, run through a reactor, sent back to De 

Soto. And you said De Soto didn't have the capacity 

to do that work. That was Area IV work. Was that -

-

Dr. Hughes: That is correct. They had the hot 

laboratory that would've had hot cells.

Member Richardson: But the description of the 

activity is there's an internal letter describes 
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disassembly work in De Soto Avenue Hot Shop 

Building 04 involving a Hot Shop Department 789 

with 160 hours of work. So there's quite a detailed 

description of what sounds like the work that Brad 

was asking about happening at the De Soto --

Dr. Hughes: Yes, they had what they call a hot shop, 

but it wasn't a hot cell where they disassembled used 

reactor fuel to my understanding.

Member Richardson: It describes disassembly work 

in the facility.

Dr. Hughes: Yes, they had -- I mean, they had all 

kinds of materials. So there should be --

Member Richardson: Can you help me understand 

the nuance of what was and what was not happening 

there?

Dr. Hughes: We try our best to understand the 

nuances. It's very -- I mean, we've looked 

extensively at the records. And from what we can 

tell is that the fuel that came out of a reactor at Area 

IV was dealt with at the hot laboratory facility that 

was equipped for that purpose.

Member Clawson: I was under the impression that 

there was a hot shop down in De Soto and when I 

was reading that. And that's why -- but guess what? 

This comes down to the Work Group. It's going to 

have to sit down and look at this one. I don't know 

what we need to go through, but I move that we send 

to this to the Work Group to evaluate this or 

whatever.

Mr. Katz: Before we get to moving we want to 

complete questions, and then we want to hear from 

the petitioner. And then we will go back to any kind 

of Board actions that we want. So --

Member Richardson: Could I ask one more question?
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Mr. Katz: Yes, of course you can.

Member Richardson: And this is just a total technical 

question.

Mr. Katz: Ask as many questions as you wish.

Member Richardson: I don't know that much about 

a bioassay program for thorium. Could you describe 

in a little bit of detail about what that involves?

Dr. Hughes: It was urine samples that were analyzed 

by mass. The result was in microgram, and at this 

point I don't recall who the vendor was at the time. 

But I can certainly get back to you with that 

information.

Member Richardson: Thank you.

Member Schofield: Were those urinalysis -- were 

those done on an annual basis, semiannual basis? Do 

you have any data that tells how often they were 

actually had to give urine samples?

Dr. Hughes: I think it depends on the -- for De Soto 

in general, it would depend on the worker and what 

he or she was involved in for the thorium. This 

particular thorium operation, the machining 

operation, they did a sample before the operation 

started and then one afterwards. So we have the 

dates, and they bracket the operation.

Member Richardson: And do you have a sense -- like, 

for thorium oxide where you've got this fuel. And 

urinalysis, is that -- what would the limit of detection 

be there?

Dr. Hughes: It's fairly high. We discussed it with our 

internal dosimetrists, and we're able to come up with 

an intake that's fairly high.

Member Richardson: Yes.

Dr. Hughes: Yes, and the doses are -- like, the lung 
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dose, you look at the considerable amount. But it's 

still bounding. I mean, it's -- but, yes, there's a high 

missed dose component.

Member Richardson: And were there -- I mean, is it 

so high that the bioassay program actually never 

found anything because the limit of detection for 

thorium oxide through urine sampling would be?

Dr. Hughes: I'm not sure. That's why we assign 

missed dose to account for that.

Member Richardson: Or the other way is that the 

bioassay program is basically not informative or in its 

--

Dr. Hughes: I don't know. We ran it past the internal 

dosimetrist, and she felt like this was appropriate.

Member Richardson: Do you remember what the 

lung dose was before you would get a positive 

bioassay?

Dr. Hughes: No, but I have the numbers. I can 

provide it to --

Member Richardson: Yes, I'd be curious.

Dr. Hughes: -- the Work Group. At the time, I don't 

have it with me right now.

Dr. Neton: One thing I would mention is this is not a 

routine sampling program. This was taken directly 

after the end of the operation. So it buys you some 

improvement in the detectability of dose.

Member Richardson: Because the excretion time is 

so short that --

Dr. Neton: Yes, yes. If you take a sample, at the 

very end -- at exactly the end of the excretion time, 

then the amount being excreted in the urine is a 

much larger percentage than if you took a monthly 

or an annual check.
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Member Richardson: Yes, I understand that. But it's 

inhalation thorium oxide and then it's going to --

you're thinking that there's --

Dr. Neton: Yes, thorium has a fairly high detection 

for urine bioassay, we agree with that.

Member Richardson: Yes.

Dr. Neton: But we also had some lapel samples, if 

I'm not mistaken, did we not?

Dr. Hughes: Yes, we do.

Dr. Neton: Yes, and so there's more than just the 

bioassay, the urine samples.

Member Richardson: No, I was just curious about --

Dr. Neton: But you're absolutely right. Thorium --

Member Richardson: -- the utility.

Dr. Neton: -- in general, urine bioassay is fairly 

insensitive. In this case, it's incident -- it's not 

incident, they had a routine sample taken at the 

exact end of operations which does buy you some 

improvement in detectability. And oftentimes, when 

you're doing a thorium calculation, you're talking 

about an annual sample or a monthly sample. And 

the clearance curve is exponential, and it's pretty 

rapid shortly after intake. And so we could certainly 

provide you with the missed dose calculations.

Mr. Katz: Is that something maybe that would get 

dealt with in the sample dose reconstructions 

anyway? So, what? Because we usually -- sample 

dose reconstructions with these anyway. Any other 

questions, Board Members? Loretta?

Member Valerio: The two buildings, the De Soto 

Building 001 and 004 were decontaminated and 

decommissioned, correct?
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Dr. Hughes: That's correct.

Member Valerio: What time frame did that operation 

happen, and who did the work?

Dr. Hughes: So it wasn't so much per building. It 

was more like operation. So the fuel fabrication 

areas were D&D'd in the 1980s to my understanding. 

There were two facilities, the Mass Spec Lab, what 

they referred to as the Mass Spec Lab, and the 

Gamma Irradiation Facility that were 

decommissioned in 1998.

And the work was done by the employees as far as I 

know. I mean, we have no indication that -- there 

was not an outside contractor coming in. This was 

done by the workers who were employed at the site 

at the time.

Mr. Katz: Other questions, Board Members?

Okay then, hearing none, we have D'Lanie here. 

Welcome. She's a petitioner for the facility. D'Lanie 

Blaze.

Ms. Blaze: Thank you. I'd like to thank everyone for 

all their hard work on this and their really good 

questions, too.

I'm D'Lanie Blaze, SEC-246 petitioner. I'm going to 

talk about why it is imperative to pass SEC-246 to act 

in concert with SEC-234 at Santa Susana.

Let's look at what we already know about the 

relationship between Santa Susana and De Soto. 

NIOSH says SECs have to be site specific. We know 

NIOSH considers Santa Susana and De Soto to be the 

same entity, operationally and contractually.

In fact, based on the established relationship 

between these work sites, SECs covering 1955 to '59 

and 1960 to '64 were passed together at both 

facilities because it is understood that Santa Susana 
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and De Soto were intimately intertwined. They 

operated in conjunction with and in support of one 

another.

To be clear, it has been established that Santa 

Susana and De Soto shared the same DOE contractor 

during the same time periods, the same DOE 

projects, radioactive materials. The record keeping 

program was the same. The health physics 

department was the same. They shared 

environmental and worker monitoring practices, 

health and safety staff, and, most importantly, Santa 

Susana and De Soto shared the same employees.

Let's take a look at the situation involving the 

workers. We've established that these employees 

routinely rotated between both locations without 

changes in their administrative affiliation, job title, 

work location assignments, and without changing 

their radiation badges. Many times, they rotated with 

no documentation whatsoever.

In addition, radiation badges were issued at both 

locations. And in some cases, workers wore more 

than one badge at a time. Sometimes, they wore 

badges issued from both sites.

Adding to this complexity, we recently validated a 

visitor badge location code key which confirms that 

the dosimeter badges assigned to De Soto and Santa 

Susana often use the same numbers, making it 

impossible to make a distinction between which 

facilities that particular badge numbers may have 

been issued. And these were badges that were worn 

on monthly to quarterly occasions.

So NIOSH acknowledged that it is not possible to 

accurately or reliably track a worker's movements 

between areas of Santa Susana or between Santa 

Susana and the De Soto facility. NIOSH relies on the 

same Site Profile and the same Technical Basis 

Documents to reconstruct radiation dose for workers 
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at both sites. And given what we know about the 

relationship between these sites and the challenges 

we have in identifying work locations, it's logical that 

the same data limitations are going to apply.

So I question NIOSH's assertion that it can 

reconstruct dose to americium and thorium with 

sufficient accuracy for a De Soto worker but not for a 

Santa Susana worker because these guys are one 

and the same. NIOSH has not demonstrated how it 

makes the distinction between where workers were, 

when they were exposed to americium and thorium, 

nor has NIOSH demonstrated how accuracy and dose

reconstruction is miraculously improved by virtue of 

a mere administrative affiliation.

I'd like to talk about materials at the work sites. The 

ER indicates that the materials were shipped to De 

Soto from outside sources and that they did not 

contain americium or thorium until the materials 

were shipped to Santa Susana and underwent certain 

processes.

And this explanation seems to have been provided to 

support the theory that americium and thorium could 

be present at Santa Susana but not at the De Soto 

Facility. But it also implies that shipping only went in 

one direction, from De Soto to Santa Susana, and 

that De Soto only ever received unprocessed 

materials. But facility records quickly disprove that 

theory.

Here are some of the documents that I supplied. 

Records show that materials containing americium 

and thorium were shipped and stored between the 

sites interchangeably, reused shipping containers 

contaminated with uranium thorium dust presented 

a documented concern of cross-contamination of 

both sites.

Records of fuel inventory show storage of spent fuel 

at the De Soto Facility. Log books from the De Soto 
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Facility clearly document ongoing operations with 

americium, contamination of the work area, and 

inhalation by workers who were present. The log 

books also describe cutting and reprocessing of spent 

uranium thorium fuel from the SRE after 1964 and 

the presence of transuranics like americium.

In its OTIB document, NIOSH identified americium 

and thorium in the stacks at De Soto in 1995. 

Radiological use authorizations do not specify any 

limitation for the use of americium or thorium at De 

Soto facility. These license were relevant to Santa 

Susana, Canoga, and De Soto without exception.

Special nuclear material licenses for De Soto show 

that up to 1,000 pounds of thorium were permitted 

as a Schedule 1 material used for research and 

development while americium-241 was indicated as 

both a Schedule 2 and Schedule 3 material. And that 

referenced sealed sources as well as production and 

fabrication which translates to operations. No 

limitations at De Soto facility were specified in the 

licenses.

Renewal of the broad scope radioactive materials 

licenses included americium and thorium for the 

express purpose of accommodating site remediation 

at Santa Susana. They needed to store and ship the 

materials from Santa Susana to the De Soto and 

Canoga facilities, and they did so until 1995. These 

materials generated at Santa Susana were likely to 

contain americium and thorium. And it should be 

noted that the Site Exposure Matrix, or the SEM, 

identifies a thorium storage warehouse at the De 

Soto facility.

I interviewed a site health physicist who was present 

at Santa Susana and De Soto during the proposed 

SEC period. He confirms that radioactive materials 

containing americium and thorium were routinely 

shipped from Santa Susana to De Soto for further 

processing, storage, or shipment.
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His information is consistent with facility records that 

were supplied in support of this petition. He states 

that the materials were not analyzed to separate 

radioisotopes or to identify americium and thorium 

specifically. There was no time to conduct such a 

detailed analysis.

He and the other HPs were simply instructed to mark 

the materials as mixed fission products in an effort to

be all-inclusive. It was understood that a container 

marked with MFP likely held any number of 

radionuclides that were generated at Santa Susana, 

and there would be no logical reason to assume 

americium or thorium would not be among them. 

This HP is prepared to provide a signed affidavit.

We talked about worker records and radiation data 

yesterday which specifically addressed an employee 

that had transferred and rotated between the Santa 

Susana hot lab to the powder room at De Soto for 45 

years. His radiation data was incomplete.

There's no way we can tell which of his americium or 

thorium exposures occurred at Santa Susana versus 

the powder room at the De Soto facility. And that's 

if we weren't lucky enough to have his records that 

he collected himself because Boeing omitted his 

radiation data from the file.

In the ER, NIOSH appears to have discarded 

historical facility records in favor of conducting an 

interview with Boeing, although Boeing's presence at 

the work site did not begin until 1996, a year after 

the proposed SEC class ends and nearly 50 years 

after facility operations began.

And it was my understanding yesterday that ATL was 

supposed to kind of be a liaison for worker interviews, 

not necessarily the contractor. So I'm kind of 

confused why NIOSH contacted Boeing. But the 

hazards of relying on Boeing's information over easily 

accessible historical records have been well 
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established. There's no shortage of examples where 

relying on Boeing's information over documented site 

history has proven to be catastrophic for workers of 

Santa Susana and its related work sites.

Coming easily to mind is the deficient Site Profile 

that's still missing 50 radiological facilities and all 

associated operations and environmental data which 

were never reported by Boeing. The misleading and 

inaccurate employment verification information that 

is created by Boeing that routinely mischaracterizes 

eligible workers as people who do not qualify for 

EEOICPA.

And employment records responses that are 

consistently incomplete, lacking in personnel records, 

that can identify work locations and radiation data. 

So in asking for Boeing's input on operations at De 

Soto facility, what could possibly go wrong?

Alliance of Nuclear Worker Advocacy Groups sent a 

FOIA for records of communication between NIOSH 

and Boeing on this issue. And in response, NIOSH 

did not provide the questions that were asked of 

Boeing or the answers that Boeing provided to their 

questions. All we can determine from the response 

of documents is that Boeing was provided advance 

notice of the questions that would be asked by NIOSH 

and allowed to choose which employees would be 

interviewed.

We have no indication of whether NIOSH addressed 

specific concerns raised in this SEC petition or 

whether they countered with historical 

documentation that was supplied or whether the 

interviewees had verified knowledge of historical site 

operations. All we know is that based on the NIOSH 

ER, it seems this is another instance where Boeing 

has been allowed to call the shots.

So we've established that Santa Susana and De Soto 

represent the same entity operationally and 
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contractually. NIOSH is aware of this and states as 

much, that the work site shared the same DOE 

programs, radiological materials, practices, and 

workers for nearly 50 years before Boeing ever even 

showed and that based on these shared operations, 

we cannot determine with reliability which workers 

were at De Soto or Santa Susana during various time 

periods.

We've also established the presence and use of 

americium and thorium at De Soto facility. NIOSH 

referenced the presence of these radioisotopes at De 

Soto in 1995.

It's reasonable to acknowledge that shared 

limitations in the data exist, and we have undeniable 

evidence of attempts by the contractor to undermine

eligibility and to omit or even alter employment 

records. And evidence that these efforts have led to 

erroneous disqualification of eligible workers and 

inaccurate or incomplete dose reconstructions. It's 

pretty clear that De Soto facility meets several of the 

established criteria to be considered an SEC facility 

under EEOICPA.

I urge the Board to recognize the importance of this 

SEC. Santa Susana and De Soto operated in concert. 

So too should their SECs. I'll submit a detailed 

written response to the ER with an affidavit from the 

HP.

It's a privilege to address the Board. And thanks 

again, everybody, for your hard work.

Mr. Katz: Thank you, D'Lanie. Do we have any 

questions for D'Lanie before she sits down? Or on 

the phone? Thank you again, D'Lanie.

Ms. Blaze: Thank you, guys.

Mr. Katz: Okay. Back to the Board for discussion as 

to path forward.
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and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 80

Member Clawson: I move that we move it to the 

Work Group to evaluate this.

Member Kotelchuck: Second.

Mr. Katz: Okay. And just to elaborate on that, do 

we want to have SC&A have a look at ER?

(Chorus of yes.)

Mr. Katz: Just to be explicit about that. Very good. 

And is there any focus that you want to be given to 

this ER evaluation?

Member Clawson: Well, everything that's been said 

up here, I understand where NIOSH's point at. But I 

really want to be able to take a look at what their 

feasibility really is. That's what I'd like. But I'm up 

to -- it's the Work Group's decision, the path forward. 

I just want to see -- I don't think it's that feasible, 

but --

Mr. Katz: Okay. So we have a --

Member Anderson: I mean, I would just add I think 

that the point that the workers were one and the 

same in both groups and the determination can't be 

made at Santa Susana but can here. I think we really 

need to look at what is the difference between those 

two evaluations, especially for the americium and the 

other compounds.

Member Schofield: I think Brad's comment about we 

need clarification on whether there actually was some 

form of hot cell or something, even if it was a very 

small one, were any of these targets irradiated and 

then brought back for analysis. I mean, true, they're 

small. But there was a lot of dosage there, even in a 

small target that's been irradiated.

Member Ziemer: Ted, could you clarify? Do we 

actually have a motion before us, and what is the 

motion?
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Mr. Katz: Right. So we have a motion before us and 

a second on it to have Work Group evaluate this ER -

- the petition and the ER with SC&A tasked to do its 

evaluation. And so that's what's before us.

Member Ziemer: And it's safe to assume that we 

haven't put any restrictions on what they would look 

at in this regard. So it seems to me we don't need 

to detail every step that they should take. They have 

broad freedom to address both the ER and whatever 

SC&A comes up with in terms of their evaluation.

Mr. Katz: Sure, sure. I had asked the question as to 

whether they wanted a focused approach to this ER, 

that's all. So that's what I think engendered those 

comments that followed. So I think the answer to 

that question is no, that there's no specific focus on 

this ER evaluation by SC&A.

I would just then also -- so anyway, we have the 

motion on the floor. We have a second. If we don't 

have any other discussion, we don't need to do a 

person-by-person vote. But all in favor of going 

forward with this evaluation by the Work Group and 

SC&A, say aye, please.

(Chorus of aye.)

Mr. Katz: Any opposed?

Okay. The motion passes. That's the course forward. 

I would just also ask considering we're going to go to 

LA in December, I would hope that SC&A would put 

a priority on this and try to get their work done as 

quickly as possible.

Well, we can hear an update in October, just not an 

update of substance but about where you are in the 

process. But it would be great to get this work done 

quickly if it can be done quickly. Obviously, that's 

not putting any restrainers on whatever deep dive 

you may have to do.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 82

Okay. So if there is a -- that's the last item on our 

agenda. I think if there's nothing else for the good 

of the order, have a motion to adjourn.

Adjourn

Member Clawson: Adjourn.

Mr. Katz: And a second?

Member Beach: Second.

Mr. Katz: Okay. So we are adjourned. Thank you, 

everybody. Thank you, everybody on the line, as 

well. And good work these last couple days. Have a 

good trip. Bye-bye.

(Whereupon, the above-entitled matter went off the 

record at 11:16 a.m.)