NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

U.S. Department of Health and Human Services

Centers for Disease Control

National Institute for Occupational

Safety and Health

Advisory Board on Radiation and Worker Health

Joint Meeting of the

Savannah River Site (SRS)

And

Special Exposure Cohort (SEC) Issues

Work Groups

Thursday, November 17, 2020

The Work Groups convened at 10:30 a.m., Eastern 

Standard Time, via video teleconference, Henry Anderson 

and Bradley Clawson, Co-Chairs, presiding. 
2 

Present: 

Henry Anderson, Co-chair

Bradley P. Clawson, Co-chair

Josie Beach, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member 

Phillip Schofield, Member

Paul L. Ziemer, Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Ron Buchanan, SC&A

Zaida Burgos, CDC

Grady Calhoun, NIOSH/ORAU

John Carderelli, NIOSH/ORAU

Joe Fitzgerald, SC&A

Roger Halsey, ORAU

Warren Johnson, on Behalf of Petitioner

Mark Lewis, Subcontractor to DCAS

Mike Mahathy, ORAU

Jenny Naylor, HHS OGC

Chuck Nelson, NIOSH/ORAU

Kathy Robertson-Demers, SC&A

Lavon Rutherford, NIOSH/ORAU

Tim Taulbee, NIOSH/ORAU 
3 

Contents

U.S. Department of Health and Human Services 

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Joint Meeting of the 

Savannah River Site (SRS) And Special Exposure 

Cohort (SEC) Issues Work Groups Thursday, 

November 17, 2020 1

Welcome and roll-call/introductions 4

1. SC&A Review of RPRT-0092 (sub-CTWs 

monitoring practices between 1972 - 1998) 6

a. SC&A recap of its RPRT-0092 

response 6

b. NIOSH Presentation 51

c. Work Group Discussion 81

NIOSH summary of RPRT-0091 (missing or 

incomplete americium exposures between 

1971 and 1999) 117

a. NIOSH Presentation 117

b. Joint SC&A and NIOSH presentation

126

i. SC&A presents its responses 

(issued in January 2020) 126

ii.NIOSH present its responses to 

SC&A comments 127

c. Work Group discussion 131

Petitioner comments 135

Work Group Discussion; Follow-up Actions 135
4 

Proceedings

(10:30 a.m.) 

Welcome and roll-call/introductions

Dr. Roberts: So, this is the Advisory Board on 

Radiation and Worker Health. I'm Rashaun Roberts, 

I'm DFO for the Advisory Board.

And this is day one of a two-day joint meeting of the 

Savannah River Site Work Group and the SEC Issues 

Work Group.

The second meeting session, for those who may not 

be aware, will be on this coming Friday, November 

20th, starting at 10:30 a.m. Eastern, like today's 

session. 

So, I want to let meeting attendees, both on Zoom 

and those who might be participating by telephone 

only, that the agenda and all of the background 

documents and presentations for both days of the 

meeting are on the NIOSH website, under schedule, 

meetings, today's date.

And as you will see, there is a lot of material posted 

there for you to review and read through, as you 

might see fit.

If you have taken a look at the agenda, you will notice 

that today's session is focused primarily on Savannah 

Site Working Group, with the November 20th session 

focused both on Savannah River and the SEC Issues 

Working Group. So, if you didn't notice that, I just 

wanted to highlight that for you.

Before we move into the SRS Work Group business 

for today, let's of course get started with roll call. And 

I would like all Working Group Members and staff to 

address conflict of interest during the roll call.

To simplify things a little bit, I will speak to conflict of 

interest with respect to the Members of the SRS 

Working Group. So, in order for them to serve on this 

Working Group, they can't have any conflicts of 
5

interest.

So, with that, let me move into the roll call for the 

Members of the SRS Working Group. And starting 

with our Chair, Brad Clawson.

(Roll Call.)

Dr. Roberts: Again, welcome to you all. Just a couple 

of items before I give the floor over to Brad Clawson, 

who Chairs the SRS Work Group.

Are you all hearing an echo?

(Pause.)

Dr. Roberts: Okay. Now, I'm not sure what I can do 

to adjust that. But let me go over a couple of 

additional items.

So, in order to keep things moving smoothly, so 

everyone can be clearly understood, please mute on 

Zoom. Again, the mute button is on the lower lefthand corner of the screen. Unless of course you're 

speaking.

If you're --

Mr. Halsey: Excuse me?

Dr. Roberts: Yes.

Mr. Halsey: I'm sorry, I just found my mute button. 

This is Roger Halsey with ORAU, no conflict.

Dr. Roberts: Okay.

Mr. Halsey: Sorry about that.

Dr. Roberts: Okay, anyone else? Okay, great.

So yes, if you're calling by telephone press *6 to 

mute and then *6 to take yourself off mute if you 

need to speak.

If, again, if you didn't hear earlier, the agenda and 

the presentations and background materials that are 
6

relevant to today's meeting, can be found on the 

NIOSH DCAS website. And all of these materials were 

sent to the Board Members prior, and to staff, prior 

to the meeting.

And I do want to note that there is a lot of content to 

cover in these two days, and we have done our best 

to organize the content for you. But please bear with 

us, some things may seem redundant across 

presentations. So just bear with us.

So with that, Brad, I will give the floor over to you. If 

you're able to speak.

Chair Clawson: Yes. It's not connecting to me, it's 

saying I've got a bad passcode and kicked me out of 

the meeting.

So anyway, I'm Brad Clawson, I'm the Work Group 

Chair for the Savannah River Work Group. This has 

been a long time coming.

I am a little bit disappointed though, and I want to 

make this upfront, that we did not get NIOSH's report 

until yesterday, to be able to even review. They have 

an awful a lot to be able to go over on this, and 

timeliness in getting things out is really critical. 

Especially in this kind of stuff.

So, with that being said, we'll go ahead and kick this 

off. I'm going to hand it over to Joe Fitzgerald or 

SC&A for the review of 0092 and go from there.

Joe, I'll turn it over to you. And I'll keep trying to get 

logged in.

1. SC&A Review of RPRT-0092 (sub-CTWs 

monitoring practices between 1972 - 1998)

a. SC&A recap of its RPRT-0092 response

Mr. Fitzgerald: Alright, thank you, Brad. Can 

everybody hear me alright? I would assume so.

Dr. Roberts: Yes.
7 

Mr. Fitzgerald: Okay, good. Okay, good. Now, this is 

in the agenda as a recap, and it is essentially the 

same findings and discussion that we presented last 

December.

We have updated it slightly, so it's in the context of 

NIOSH's August response. So, it's just so it makes 

more sense when Tim and John give their 

presentation based on their most recent review. 

There is some additional information their 

presenting.

So, anyway, I guess --

Dr. Roberts: Joe? Joe, I'm --

Mr. Fitzgerald: Hello?

Dr. Roberts: -- sorry to interrupt.

Mr. Fitzgerald: Yes.

Dr. Roberts: I can hear the echo, I'm wondering if it's 

disruptive enough to try to adjust. Can --

Mr. Fitzgerald: Well, let me --

Dr. Roberts: -- the court reporter --

Mr. Fitzgerald: Yes. Let me see if it's because I have 

a phone connection as well. Hold on.

Dr. Roberts: Okay.

Mr. Calhoun: We can't hear you now, Joe.

Mr. Fitzgerald: Okay, how is that? Is that better?

Mr. Calhoun: We hear you, but with an echo.

Mr. Fitzgerald: Let me, okay.

(Pause.)

Dr. Roberts: So, sorry, Joe, did you want to try to 

start the presentation again?

Mr. Fitzgerald: Can anybody hear me? Hello?
8

Mr. Calhoun: We can now.

Mr. Fitzgerald: Okay. I'm just trying to figure out, I 

have a phone connection as well as a Zoom 

connection so it's --

If I can be heard, I will go ahead and proceed, if that's 

alright, Rashaun?

Dr. Roberts: Yes. Please go ahead.

Mr. Fitzgerald: Okay. Fine. Again, this is a recap of 

something we presented last December, so I'll go 

through, relatively quickly. And if it's too fast, please 

stop me if there is any questions.

But we, in fact, we're tasked to review 0092 over a 

year ago. And it provides the results of NIOSH's 

sampling analysis, '72 to '98.

And the question, the essential question it's designed 

to answer is, and this is right from the sampling plan 

in the report, did unmonitored workers work in the 

same environment as monitored workers at the time? 

We're talking subcontractors.

I'm going to emphasize, at the same time, because I 

noticed in NIOSH's presentation, at the same time is 

left off the objective. And I think for transient 

subcontractors who were in and out often, and it was 

a job-by-job, task-by-task type of activity, the time 

issue is a critical one. It does need to be a review of 

permits and bioassays at the same.

And that can be certainly some difference but not a 

large difference in our view.

At any rate, this review follows our 2017 review. And 

the impetus behind all of it, and this was one of the 

primary findings was that Westinghouse, in a selfassessment of its own bioassay program, found 

almost 80 percent of its job-specific bioassays. Ones 

that were required by RWPs missing in '97. A large 

number.

And the question that that posed was whether that 
9

gap, that incompleteness, might figure in years 

previous to 1996 to '97. And that was a driver behind 

the analyses that the Board requested be done, in 

which it certainly figures in RPRT-0092.

In any case, we reviewed the report that was issued 

and presented the findings last December. We did get 

some initial reactions and feedback from NIOSH in a 

Work Group discussion back then.

But the formal response, the actual written response, 

was provided in August, this past August, in terms of 

0092. In terms of SC&A's review of 0092.

Next page, Bob. Next slide. There we go. I'm not 

going to dwell on this. I know John will probably cover 

this in some detail in terms of the RPRT-0092 

conclusions, but the overall conclusion was that there 

was a large percentage of subcontractors who were 

monitored for potential intakes while under a job 

plans, a special work permit or a RWP.

Next slide please. Okay, so our approach, and we've 

covered this last year, but we wanted to do a pretty 

comprehensive look at how this was done.

If you may, a weight of evidence type review. One 

that looked at both the premise behind the sampling, 

how the sampling was actually executed in terms of 

the actual data that was reviewed.

And to look at the exposure data sets do indicate that 

monitored subcontractors, and unmonitored 

subcontractors, work side-by-side (audio 

interference) in '89. April 1st '89.

So essentially, this is the Westinghouse operating 

error up through the end of the SEC qualification 

period. Not SEC, but petition qualification period of, 

that was under Westinghouse.

So finally, we were looking at this representation 

question. The real question is, the representatives of 

the subcontractor bioassay data were in fact 

bioassays required by, whether it's job plans, SWPs, 
10

or RWPs, were they sufficiently represented in the 

database such that a co-exposure model would 

encompass them and you would have a 

representative database. That was the bottom line.

Okay. Okay, Finding 1. Our biggest concern, as we 

indicated last year, is that we went through the 

DuPont era. SWPs and job plans.

And what we were looking for was the, the first 

evaluation objective of RPRT-0092 was to determine 

the percentage of subcontractors monitored for 

bioassay, and this is right from the report, in the 

context of ascertaining whether gaps existed, as in 

the '96, '97.

So, again, the percentage of subcontractors 

monitored. And it was to be a direct measure of the 

RWP to bioassay relationship.

And we call it linkage in our response. But it's 

basically a relationship of the job-specific bioassays 

to the permit. The RWP that requires the bioassays.

And looking at that evaluation objective we just could 

not find evidence about the relationship. That 

linkage.

No SWPs or job plans that we looked at, and we've 

looked at them all, for '72 to '90, contain any 

requirements for job-specific bioassays. Even where 

under SWPs you had to check off for bioassays. None 

of the ones that we could find had that checked off.

And so our concern was, it brought into question 

whether in fact you could satisfy that first objective 

and demonstrate that in fact you had a bioassay-toRWP relationship upon which you could look at 

completeness.

Now, next one in terms of the NIOSH response. Okay. 

In the August response NIOSH, I think, emphasized 

that they had a ample number of bioassays who 

states can be associated, and this is from the report, 

with those who need permits and job plans, with the 
11

assumption that these bioassays would have been 

obtained. Okay.

And it goes on to point to the Farrell and Findley 

report and some of the DuPont procedure 

requirements as a basis for assuming that bioassays 

would have been done in response to the job plans in 

SWPs.

Next one please. The response -- our concern is that 

we think this really, really retreats from the original 

sampling approach.

This was to examine the job-specific bioassays called 

for in the permits. And in our view, this cannot be 

accomplished for '72 to '90 because, essentially, in 

the DuPont era you did not have accountable RWPs 

being implemented. And there were no site-wide 

requirements for these bioassays to be performed as 

a condition of the SWPs and job plans.

So, if you're directly measuring the relationship of 

RWPs to bioassays at the measure of completeness, 

we just don't think that's feasible. You can't satisfy 

that objective.

Going further, looking at associating, and this is a 

term that's used in the latest response, bioassays for 

permits by roughly, I would say, if not the date, a 

close date, does not account for whether or not the 

specific task was in fact the task that would have 

called for that bioassay.

Again, keep in mind these are transient 

subcontractors who were under specific job plans 

that were doing tasks that would have differed from 

day-to-day perhaps. It wasn't clear what the source 

term or the particular task might be, but you 

definitely would have to look at, as the original 

objective called for, the timeframe, the same 

timeframe, for the jobs involved and be able to 

assess those jobs in terms of the similarity.

And then again, on respiratory protection, I think we 

were clear that those procedures for job-specific 
12

bioassays that were incumbent upon those with 

respiratory protection did not come into being at 

Savannah River in a formal procedure until the 

Westinghouse era.

So, again, you can assume that they would have had 

bioassays. And you can try to link that assumption. 

But it didn't exist in reality so there is no way to know 

how you can peg that.

Can I have the next slide on Finding 2? Okay. In this 

case we were concerned about radionuclides of 

interest, and we questioned how accurate they would 

be and whether in fact they would in fact have been 

referenced adequately in the permits. To the job 

plans and SWPs in that DuPont era before 1990.

And NIOSH, in its response, frankly contended that 

prior to 1990 there were a number of ways that 

DuPont could have done source term 

characterization. And there was a number of 

examples provided in the August report. And I have 

listed them there.

But these were all capabilities. These were, as NIOSH 

put it, some evidence that they in fact had the means 

to characterize source terms in different ways.

Our response, essentially, and I'm going to boil this 

down to one thing. That essentially the DuPont era 

procedures did not provide for a specific or analytic 

based characterization process in general and one 

specifically that would have identified source terms 

for the SWPs and the job plans.

And I think the strongest, if I may, independent 

assessment of that question was the Tiger Team 

review. Where you had a, an independent health 

physicist that reviewed the Savannah River program 

in 1990.

And I went ahead and cited that finding there, but 

what their finding essentially says is that the internal 

dosimetry program does not comply with the DOE 

order. And more specifically, that the radiologically 
13

areas at Savannah River have not been sufficiently 

characterized.

To provide a technical basis for the assignment of 

bioassay sample, types and frequencies. Okay, that 

is very specific to bioassays in terms of the types and 

frequencies that were being mandated for the various 

facilities and operations at Savannah River.

They did find one exception, which was the Naval 

Facility that was co-located at Savannah River. And 

they indicated that there were other discrepancies 

that they felt hampered appropriate site 

characterization.

And I guess our response to NIOSH's response is 

that, and this is not too unusual at DOE sites, just 

simply because they had the technical capability to 

do so doesn't necessarily translate into actual 

practice. That they actually applied it to the work 

permits or the job planning process.

And I would go so far as to say, that actually in 

Westinghouse's response to that Tiger Team finding, 

they agreed that the facility characterization, 

upgraded --

Ms. Burgos: Hello?

Mr. Fitzgerald: -- facility characterization was 

needed. And they in fact went further and developed 

a TBD that included that.

Dr. Roberts: Hello?

Mr. Fitzgerald: And conducted a site-wide 

characterization in 1990. Is somebody --

Dr. Roberts: Hi. Sorry about that, I was hearing some 

speaking in the background.

Ms. Burgos: No.

Mr. Fitzgerald: Oh, okay.

Ms. Burgos: No. No, less, because we just refinanced.
14

Mr. Fitzgerald: I hear it.

Dr. Roberts: It sounds like Zaida.

Mr. Fitzgerald: Okay.

Dr. Roberts: Zaida? Zaida, can you hear? Sorry, Joe. 

I think you can go ahead.

Mr. Fitzgerald: Okay. Well, let me continue. Again, 

I'm just going to keep moving through this because 

we did cover this in some detail last year.

Our Finding 3 was, that the scope of the permit 

sampling for the, again, the DuPont years, essentially 

the '72 to 1992. And we added 1990, even though 

we know what, DuPont left the site April 1st, 1989 

because, again this, I think agreement, that there 

were no RWPs. And I don't believe there were job 

plans for 1990. So there is a gap there. So we intend 

to include 1990 into the '72 to '89 era.

But in terms of the scope of permit sampling during 

that period, as we pointed out, it's essentially limited 

to one facility, 773-A, the laboratory. And again, we 

think this falls short of the sampling objective where 

originally the basis for 0092 was in fact to do 

sampling of various facilities at Savannah River.

And it was actually a Board concern, which lead to, 

one of the key impetuses to doing 0092, the survey 

analysis that was done in 0092 was the fact that 

earlier analyses, and the one that was done for '81 

to '86 for 773, and the one that we did, which was 

only for, essentially the '90s, didn't really answer the 

question from a scoping standpoint of, what were the 

-- was the subcontractor job-specific data complete 

and representative enough based on a site-wide 

review for the years in question.

So, in terms of expanding the assessment to 

characterize the site in terms of the representatives 

of this data, we still are kind of stuck with one facility 

where that can be done in detail for the years in 

question, and that's 773-A, for the earlier years.
15

Now, after 1990, with the 852 boxes of records, very 

clearly there were many more RWPs which does 

provide a much better basis for the latter period 

under Westinghouse, to do this analysis. Although we 

still have some issues, which we'll get into. But 

certainly for the earlier periods, 773-A is essentially 

it.

In our, certainly the NIOSH response for Finding 3 

was that that they were -- that the subcontractors 

were adequately monitored in areas outside 773-A

because the CTWs were monitored based on the 

radionuclides of interest in the similar to the prime 

contractor workers. So in other words, there is a 

statement that the, since the monitoring was the 

same then that would represent adequate monitoring 

all around.

There is a review in coding of plutonium logbooks, 

which enumerates more sampling for plutonium for 

the subcontractors for various facilities.

And there were a number of subcontractors having 

plutonium in fission product urinalyses and wholebody counts based on the RPRT-0094 assessment of 

NOCTS data. So there is several additional sources of 

what would constitute what, I think, NIOSH is 

considering to be ample data available that would 

supplement the review that was done for 773-A and 

bring in additional facilities in the area.

Our response on Finding 3, however, is that no 

matter how you slice it, in terms of the permit review, 

looking at the direct relationship that would answer 

the question in completeness, we're still talking one 

facility, 773-A for the DuPont era. So, what the Board 

had requested as far as an expanded scope just 

wasn't possible.

And again, it wasn't from lack of effort, it's just that 

the availability of the records did not turn out to be 

the case for the earlier years, we still only have pretty 

much the records for the DuPont era in terms of the 

job plans in the SWP.
16

So, certainly (audio interference) --

Member Ziemer: We have lost the sound --

Chair Anderson: Can hear.

Member Ziemer: -- for Joe.

Chair Anderson: We can't hear.

Dr. Taulbee: Joe, your sound just dropped out.

Dr. Roberts: Can you hear us, Joe? It looks like he's 

trying.

Court Reporter: This is the court reporter, I've lost 

him as well.

Dr. Roberts: Joe, can you hear us? He's still talking.

Member Beach: I just gave him a call so hopefully he, 

he did answer.

Member Ziemer: He's moved to Finding 4 --

(Simultaneous speaking.)

Member Ziemer: -- but I don't think we've tried 

Finding 3 yet.

Member Beach: No. I think he's working on it.

Mr. Barton: I lost audio on my phone real quick there. 

I mean, can anybody hear me?

Member Beach: Yes.

Mr. Calhoun: Yes. We can hear you, but we can't hear 

Joe yet.

Mr. Barton: Okay. Yes, I got cutoff my phone line, so 

I just, computer audio. So that probably happened to 

Joe.

Member Beach: Right.

Dr. Taulbee: I think we're still back up on Finding 3 

though.
17

Member Ziemer: We lost him find of in the middle of 

Finding 3.

Dr. Roberts: Okay. It looks like he's trying to connect.

Mr. Fitzgerald: Am I coming through now? Hello?

Dr. Roberts: Yes. I can hear you.

Mr. Fitzgerald: Okay. Somehow I got, my phone line 

cutout. That's kind of odd.

Dr. Roberts: Okay.

Mr. Fitzgerald: Okay.

Dr. Roberts: Joe, we lost you in the middle of Finding 

3.

Mr. Fitzgerald: Okay.

(Laughter.)

Mr. Fitzgerald: Well, you can pretty much read what 

I was saying there.

The major concern is that because of the nature of 

the work that subcontractors may have done in terms 

of being transient, doing day-to-day tasks, we think, 

again, it's particularly important, one, to have a 

handle on the specific nuclides that were involved. In 

some places they were unconventional nuclides.

And also, to have a good handle on the nuclides that 

would have been important. The radiological, the 

radionuclides of concern for the other facilities, not 

just 773-A.

And with all difference to Farrell and Findley, which I 

think is a pretty good analysis, that's 1998 and one 

that was a fairly comprehensive, analytic-based 

review of source terms that in 0092 is proposed to 

back apply to other facilities in earlier times.

And we covered that in our report, but we believe 

that's not substantiated in, more so in the view that, 

in the Tiger Team review, that certainly the 
18

characterization wasn't done properly.

Okay, if there is no questions, I'm going to go to 

Finding 4. And everybody still can hear me, I hope.

Okay. On this one I'm going to --

Member Ziemer: So, Joe, are you taking questions as 

you go or you want to wait till the end?

Mr. Fitzgerald: If it's easier that way I, since this is a 

Work Group I would invite that, just to kind of keep 

continuity.

Member Ziemer: Well, could I ask a clarifying 

question?

I think this is more, this is Ziemer for the court 

reporter. On Finding 2 I just have a question for 

clarity, that I think I know the answer, but I want to 

make sure I clarify it. Because, Joe, as you know, I 

put a lot of stock in that Tiger Team report.

But is it, did DuPont have any requirement that 

bioassay must be carried out if respiratory protection 

was used?

And what I'm getting is, is there an implicit sort of 

built-in requirement that if the work order required 

respiratory protection, then you automatically kick in 

bioassay without having to put it in a check box. I 

think --

Mr. Fitzgerald: Yes.

Member Ziemer: Let me ask you --

Mr. Fitzgerald: Okay.

Member Ziemer: -- to just specifically clarify that.

Mr. Fitzgerald: Yes. Actually, the, in terms of 

respiratory protection, both the job plans and SWPs 

did have a checkoff for respiratory protection.

And unlike --
19

Member Ziemer: Yes, I know that. But what I'm 

saying is, would that have kicked in the site-wide 

requirement for bioassay that didn't have to go into 

the work plan.

Mr. Fitzgerald: Yes. There wasn't a site-wide 

requirement, it would have been a facility manager 

call. The site-wide explicit, and you used the word 

implicit, and I think there was an implicit, good 

practice type of thing where if you're wearing 

respiratory protection an HP would certainly, would 

want to see some bioassay.

But as far as an explicit site-wide procedure, that was 

codified by Westinghouse in its improvement 

program in the early '90s. I think '92, '93, where that 

was included in the, what they call the 5Q1 

procedure. Where one would have to in fact do a 

bioassay if respiratory protection was called for.

So I think, to use your terminology, was more implicit 

then and more up to the facility manager and the 

HPs, whereas it became an explicit requirement in 

the early '90s.

Member Ziemer: So, can you tie that in with the Tiger 

Team finding that you cited. Does that have to do 

with tying those two together or is this simply a 

separate issue on their dosimetry program per se?

Mr. Fitzgerald: This is somewhat separate. We 

focused on the question of source terms because in 

the 0092 report it has a hierarchy of how the 

assumed source terms would be applied in the 

analysis that NIOSH did.

And it went from the nuclide being identified on the 

SWP, or job plan. Of course, we found none that that 

was the case. That didn't come later till the RWPs in 

the '90s.

Or if the procedure, the second level on that 

hierarchy was just the procedure, in the case of 

DuPont, that DPSOL or DIPSOP, required the source 

term to be identified and addressed.
20

And as NIOSH pointed out quite correctly, it's 

obviously, the DPSOLs were pretty general. They 

were not specific in these requirements.

They were more performance-based, if you 

remember that term. And so, that wasn't a claimed 

basis for applying the source terms in NIOSH's 

analysis in 0092 as well.

And the third level in the hierarchy was the Farrell 

and Findley. Which was the 1998 comprehensive 

analytic-based characterization. This is with all the 

bells and whistles. They looked at waystreams, they 

looked at actual operations, and essentially moved 

the sample type and frequency. Actually, they 

discarded the sample type and frequency table as the 

basis for identifying source terms for permits and 

went to what Farrell and Findley provided, which was 

a pretty detailed guidance. And that is, in the RPRT0092, was back-applied from the 1998 document.

The Farrell and Findley document was back-applied. 

And that's the basis for the source terms that were 

used in NIOSH's analysis.

And two things that we point out in that regard is, 

one, the, again, the Tiger Team was very explicit that 

DuPont was not in fact providing a up-to-date 

operational basis for its source terms. That the 

assignment of the bioassay types and frequencies in 

the job plans, the SWPs, and whatever RWPs they 

might have done, which were very few, would not 

have been adequate because they would not have 

been correct.

And that's kind of what Finding 2 basically says, that 

we can debate this but frankly, the procedures were 

general, the SWPs and job plans did not include 

specific citations. And we believe the Farrell and 

Findley, although that's perhaps a Cadillac version of 

site characterization, that came along in 1998. And 

in terms of trying to use that backwards, we don't 

think that's appropriate as far as the backapplication.
21

That in fact, the characterizations were not adequate 

in the DuPont era and there would be no way of being 

able to pin down, allow these very specific source 

terms that the subcontractors may have been 

exposed to doing day-to-day work of specific tasks.

I mean, even, I think Farrell and Findley in one 

passage, made it clear that places like 773-A dealt 

with a whole spectrum of source terms, 

radionuclides, that were unconventional. Would not 

likely be caught by the kind of bioassay type of 

frequency assumptions that were brought forward 

but not updated.

So, finding 2 is just kind of on source term, more 

specifically.

Member Ziemer: Thanks. And I assume when we get 

to the NIOSH response, Tim, your people address 

their --

Dr. Taulbee: Yes.

Member Ziemer: -- point of view on this same 

question, I supposed.

Dr. Taulbee: Yes, that's correct. I just wanted to 

quickly clarify that one of the things that Joe said at 

the beginning is that there was not a formal 

requirement of people who were wearing respiratory 

protection to be on bioassay during the DuPont era.

Our selection of those RWPs in RPRT-0092 was that 

those workers would have a higher potential of 

somebody who would be exposed, and therefore we 

wanted to look at whether they were monitored via 

bioassay.

There are many job plans that did not require 

respiratory protection. And even some of those that 

did require respiratory protection, when we looked at 

contamination surveys that were conducted in 

conjunction with the job, if there was no 

contamination found, that was noted in there and 

there would not be any subsequent follow up 
22

bioassay.

But again, we were trying to single in on a population 

that could have been exposed to airborne 

radioactivity, that could have been a hazard, and 

whether or not those workers were monitored. Thank 

you.

Member Ziemer: Thank you.

Mr. Fitzgerald: Okay, I'm going to jump back to 

Finding 4 if my slide mover can get me there.

Okay. I'm going to be pretty quick with this one 

because our concern here is more basically whether 

the incident-based data that was cited in RPRT-0092. 

And this was the incident-based/special bioassays for 

F and A areas were reviewed, identified and found to 

be, found to have a high measure of completeness 

and no systemic issue.

And our contention was, we're not arguing with that 

finding because it obviously is factual. But it's not --

it wasn't to the point in terms of what we were saying 

in Finding 4.

We're not contending that incident-based/special 

bioassay sampling was not an integral component of 

the SRS bioassay program. Which was one of 

NIOSH's point.

We're not saying that there was in fact a high 

measure or completeness of incident-based/special 

bioassays in F and A areas. And we're not claiming 

that the IG-006, the criteria for evaluation, used 

coworker data sets, did not in fact permits its used 

as a co-exposure modeling input. So we're not 

making any of those claims.

What we are emphasizing though, and if you could 

move the slide one, at the bottom we are saying, and 

I think NIOSH actually agrees, that the inclusion of 

this incident-based data should not be meant to 

complement the completeness of the nonincident/non-special bioassay data.
23

So next slide. What we're concerned about is that if 

we're looking at completeness of bioassay data, next 

slide. Okay. No, the one before that.

What we're basically saying is that the incident data, 

base data, should not be used to complement the 

non-incident/non-special bioassay data. Because of 

course, it's pretty clear that when you're talking 

special bioassays at Savannah River, that the 

procedures were very precise. The accountability was 

very strong.

And management track, as you would expect they 

would track special bioassays, so you're talking about 

a intake driven incident, both times. So if you're 

looking at the degree of completeness of bioassays in 

response to the impetus for taking those bioassays 

by including special bioassays, the incident-based 

bioassays, you're going to inflate the overall 

numbers, the success rates if you want to call it that.

So our caution is that we do a -- we don't believe that 

the incident-based data should be included in that 

assessment because it's going to be misconstrued.

And in NIOSH's response they agree that incidentbased data should not be used to complement the 

data. So really, that's all we were saying. So we have 

no further issue, except the inclusion of that data in 

the report continues, and it's there.

And I think the Work Group should be aware that 

even though the percentages of completion are very 

high, it doesn't necessarily bear on the completeness 

of job-specific assays per se. That's all we're saying 

there.

Okay, Finding 5. Okay, so we were raising a question 

of incompleteness of dose records given the 

acknowledge destruction of those records. And this is 

something that we have raised repeatedly since 

2017. So it's not a new issue.

What has drawn us out more specifically in our 

response is that, and if you can skip over to the 
24

response, Bob, was that there is a statement in 

NIOSH's finding that "only one area," and this is A 

area, "appears to have routinely used SWPs or job 

plans in the 1972 through 1989 DuPont era."

And in our -- I think you're on the wrong slide. May I 

have Slide 19 please? There we go.

And in our response we explicitly call out that one 

finding as being potentially misleading because it's 

not a question of only area appearing to have 

routinely used the SWPs or job plan, it's just the fact 

that is was the availability of records that connotes 

that.

And given the destruction of records, it's just as clear 

that this is likely, and perhaps more likely, that the 

records for the other areas were just not available 

because they were destroyed. So, I don't think there 

is any disagreement that it's not just that the SWPs 

or job plans were only routinely used for one area, 

it's really that they're unavailable for the other areas 

due to likely destruction when DuPont left the site.

Secondarily, we did repeat the concerns that we've 

had before that, based on interviews with workers, 

subcontractors from that time era, there were 

destructions of, and I just wanted to include these 

quotes from the interviews, all kinds of records. 

Including monitoring records and timecards.

And our concern is whether that has any implications 

for the identity and whether the monitoring records, 

writ large, include anything that would be of concern.

I don't want to -- this isn't particularly central to the 

question of the representatives of the data per se, 

but it's a concern that the actual review of what 

specific records were destroyed in 1990 and what 

implications they may have has not been pursued 

except for the acknowledgment that in 2001 that the 

dosimetry records appear to be complete. There has 

been no signs of discrepancies.

And the NOCTS claimant files appears to be 
25

complete. So from an empirical standpoint so far 

there doesn't seem to be any evidence.

So, again, what we're just acknowledging is that so 

far no evidence of records gaps, but certainly a 

number of other records have in fact gone missing.

Skip to Observation 1. Slide 21. 21. Okay. This is an 

observation. I wanted to, certainly it's just one that 

we were concerned about the fact that a lot of the 

analysis in 0092. And a lot of the premises behind the 

analyses seem to borrow from procedures, policies, 

and practices that were clearly ones that were in 

place, but ones that did not actually get implemented 

until the earlier '90s.

And NIOSH disagrees with that and made it clear that 

they felt that the policy, practices, and procedures 

were pretty constant from '72 to '98.

And our, I guess our only response, and this, again, 

this is an observation so we'll leave it as it is, is that 

for the specific, and this is Slide 23, for the specific 

examples that are at the core of the RPRT-0092 

completeness analysis, we want to make it clear that 

we see distinct differences in those practices and 

procedures between DuPont and Westinghouse that 

makes it difficult to do a coherent and complete 

analysis over those 25 years. Because starting in 

about '89 and '90, '91, you had several major 

programmatic changes that altered the way business 

was done in terms of radiological bioassay control. 

And I just provide three specific examples.

And I think that was a contributing factor, a major 

contributing factor, to why what was capable of being 

done for the Westinghouse timeframe, as far as 

looking for a relationship, a direct relationship 

between the RWPs and the job-specific bioassays in 

terms of both representatives and completeness, 

wasn't feasible for the DuPont era because you had 

to make assumptions that even though they made 

sense for Westinghouse wasn't in fact reality for 

DuPont. That these procedures did not exist, 

practices weren't followed, and therefore the 
26

conclusions that you reach are consistent into those 

early years.

So, again, I think that the Observation 1 wanted to 

look at what seems to be a root issue. It seems to 

be, certainly that seems to be one of them.

Okay, that's kind of the first part of this, which deals 

with the premise or the programmatic part. I think 

Bob and Ron are going to look at the execution part.

Mr. Barton: Yes, thanks, Joe. I just let me make sure 

everybody can hear me okay. Can you hear me all?

Member Beach: Yes. Yes.

Mr. Barton: Okay, great. Thank you. Alright. As Joe 

pointed out this analysis in RPRT-0092 is sort of 

separated into two main theories, the DuPont era, 

which, again, ended in April 1st, essentially, 1989.

There is a little gray area in 1990, which Ron 

Buchanan will get into. But what we are going to talk 

about right now is really that earlier DuPont period 

from 1972 up through 1989.

So this gets into Finding 6, and I'll just read this to 

the record. It says "For the period 1980 to 1989 only 

20 percent of the identified subcontractor-job plan 

combination is identified by NIOSH as requiring 

americium sampling had internal monitoring 

performed within an acceptable timeframe."

And this is one issue that we brought up in our review 

of the dataset provided by NIOSH is that, you know, 

sort of direct monitoring is going to be both urinalysis 

and in vivo counts.

However, when you are talking about chest count 

data NIOSH, through its own procedures, state that 

you have to restrict it to within two years for Type M 

material because it clears the lungs very quickly.

So in the actual dose reconstruction procedures, and 

I believe it's 260, internal dose reconstruction, it does 

state that periods longer than two years should be 
27

considered unmonitored.

So basically when we at SC&A went back through the 

analysis presented in RPRT-0092 we didn't consider 

a valid monitoring result after two years for 

americium.

Plutonium also if it was Type M, of course, there is 

probably is some examples of Type F and Type Super 

S, which I know NIOSH will get into in their own 

presentation, but essentially what we did is make 

adjustments where there were matches made for 

americium monitoring associated with the job plan.

And, again, it's restricted only to the F-Wing area of 

773-A. So as Joe mentioned earlier in the 

presentation the job plans available for analysis 

under RPRT-0092 were really restricted to just A area 

and for americium specifically it was restricted only 

to the F-Wing of A area because that's where they 

actually separated americium from other products 

such as plutonium, obviously.

Americium and plutonium are usually joined at the 

hip, but in the F-Wing area they were actually

separating it out, and we're going to get into some of 

the -- there is at least one other area and there might 

be a third area, I'm not quite sure, but we'll get into 

that.

So just to quickly summarize NIOSH's response, I 

know they are going to want to do their own 

presentation, but essentially we see the response as 

this, is that the exposure potential was very limited, 

again, only to those areas where americium was 

separated, because it was generally commingled with 

plutonium.

And so those two areas are the F-Wing, as I just 

mentioned, but also the Multi-Purpose Processing 

Facility, MPPF, which was located in F area, not to be 

confused with the F-Wing of 773-A. This is a 

completely different area.

And, also, NIOSH points out that there are only 15 
28

documented intakes related to separated americium 

and that there were over 80 subCTWs that were 

monitored via the urinalysis program from 1972 to 

1989.

So I guess what we want to sort of point out here is 

that, you know, only the F-Wing was analyzed, so 

they did not have any analysis of the MPPF in the F 

area, which also had separated americium.

And, again, the scope is very limited. There is only 

one job plan that was identified in 1973 and there 

was no associated internal monitoring for that and 

then the remaining job plans were only from 1981 to 

1987.

There were 34 total that were available for analysis 

and no job plans were identified for the Multi-Purpose 

Processing Facility.

Now a third facility that I am not sure about and I 

wasn't able to get a lot of information on, I basically 

pulled what I could from the Technical Basis 

Document and what was available in the SRDB, but 

I'm not sure.

There was another facility called the New Special 

Recovery facility that was basically there to separate 

plutonium to re-use it. So, obviously, if you are 

separating out the plutonium americium is going to 

come out of that separation process.

So we are not sure if that is a third facility that should 

be considered, but, again, all we have is the job plans 

from 1981 to 1987 at 773-A F-Wing.

We appear to agree that only 20 percent of those 

subcontractor and job plan combinations were 

directly monitored, and that includes both in vitro and 

in vivo.

And really I tried to focus in on what we feel is the 

key question is: has adequate evidence been 

established that the job-specific monitoring program 

was sufficient to detect the intakes from separated 
29

americium where it is not commingled with plutonium 

where you might be able to use some sort of ratio to 

get at a dose reconstruction approach for the 

americium component?

What we are really worried about is these facilities 

where they were separating out americium and how 

well did they monitor for that. So that was Finding 6.

As Joe pointed out if there are any questions as I am 

going along please just stop me in my tracks and we 

can discuss any of these points.

Finding 7 gets into the term effectively monitored. 

This was introduced in RPRT-0092 and it's 

essentially, even if you were not monitored on a 

particular job or associated with a particular job, if 

you were on the same job plan with someone who 

was monitored then you could consider it that the coexposure model is representative of that exposure 

because the worker was not monitored but you can 

apply the co-exposure model based on workers who 

were doing the same thing at the same time.

We do have a little bit of a differing of opinion on what 

the entails, but we'll get into that in a second. But 

Finding 7 reads that total effectively monitored 

population, which, again, is those who were directly 

monitored via urinalysis or in vivo, and those who are 

on the same job plan who would be included in the 

co-exposure model essentially covering those 

unmonitored workers. So the effectively monitored 

population for americium during the 1980 to 1989 

period is about 33 percent.

In SC&A's look at the data we had 20 percent who 

were directly monitored and then another 13 percent 

who are essentially covered by someone who was 

monitored via urinalysis and those results would 

hypothetically be used in the co-exposure model.

And, in fact, with americium that's true because I 

believe NIOSH coded all of that data so it's not just a 

sub-sample of NOCTS for americium specifically. For 

some of the other nuclides I believe it's basically the 
30

available NOCTS data, not the full population.

So moving on, just to summarize what we see as 

NIOSH's response, and, again, this is where I guess 

the differing of opinion is, NIOSH believes that the 

effectively monitored population should be 56 

percent, not 33 percent.

And that is based on, again, we agree only 20 percent 

were directly monitored within a given timeframe and 

36 percent were monitored or were covered by a 

worker who was monitored via urinalysis or in vivo. 

This is where the differing of opinion comes from.

SC&A feels that to define an effectively monitored 

population you can only count it if, you know, the 

unmonitored worker is on a job plan with a monitored 

worker whose results are actually used in coexposure modeling.

If those results are not used in a co-exposure model 

they are not represented, and so essentially they 

remain unmonitored, not effectively monitored.

They point out that three of 43 subcontractors had 

the potential for exposure. I do have a little bit of 

questions about how they reached that number, but, 

again, this comes directly out of their review which 

was transmitted in late August.

And, also, subcontractors were monitored for 

incidents, which we do not dispute. I mean it's a 

higher level. They had, obviously, there was a 

contamination found or high air samples or whatever 

it was that triggered the incident investigation and 

we agree those subcontractors in that event were 

monitored.

And then this last bullet here associated with the 

1991 data, we originally pointed that out because the 

1991 data was not used I the co-exposure model, so 

we sort of questioned, well, if you're not using that 

data how can you claim that it's actually 

representative of those unmonitored workers?
31

Again, we'll get into that because it seems like NIOSH 

has agreed and they will be using that data, and it's 

actually just one bioassay sample from 1991, but it 

covered a lot of those workers to get to that 

effectively monitored population.

And, again, SC&A's sort of response to this is if you 

are going to say "effective monitoring" you should 

only include the unmonitored workers if that 

monitored worker on the job plan is actually used in 

the co-exposure model.

For example, I mean if the samples are not used to 

build a co-exposure model and assign intakes, which 

is basically the in vivo monitoring results for 

americium, then the unmonitored worker is not 

represented in the co-exposure model.

And so we don't feel that it should be given credit just 

because they were on a work plan with somebody 

who had an in vivo sample if that sample is not going 

to be used.

I know NIOSH will, based on the presentation sent 

yesterday, I think it sounds like they will be starting 

to use in vivo monitoring for americium, but we'll get 

into that I think during NIOSH's presentation.

And, again, regarding this 1991 bioassay sample, the 

reason we brought that up is because it wasn't used 

in formulating the co-exposure model as it currently 

stands.

But NIOSH in its response from back in 

August/September they are going to add that data 

and consider it in any co-exposure model estimates.

Finding 8 has to do with fission products. We are in a 

pretty good lockstep on here. Seventy to 73 percent 

of the workers who should have been monitored for 

fission products had the appropriate sampling during 

the periods evaluated.

And, again, this is the DuPont period, so it's 1972 to 

1974, 1980 to 1989. Now you'll notice there is a gap 
32

in there. There were no job plans identified for '75 to 

'79 available for analysis for either plutonium fission 

products or, obviously, americium.

Among those 70 to 73 percent almost all of them 

were monitored via urinalysis. However, the coexposure model is based on in vivo counting.

So, again, the question is whether when you start to 

look at that effectively monitored population, that is 

the directly monitored, you have monitoring results 

for that worker, or they were on the same job plan 

as someone who was monitored and that result is 

included in the co-exposure model.

Essentially what happens is is that 70 to 73 percent 

remains the same because they were all monitored 

via urinalysis while the co-exposure model is based 

on in vivo, so they are not represented in the current 

co-exposure model.

A summary again of NIOSH's August response. They 

present essentially figures about how many 

subcontractors were included in the co-exposure 

model.

There is a minimum of no subcontractors in '74 and 

'75 and then it increases substantially to about over 

300 in 1990 who are included in the co-exposure 

model.

Prior to 1982, NIOSH contends that the 

subcontractors were monitored by a special 

urinalysis, so that would essentially be mostly 

incident-based, I believe.

I mean there would be some situation in which a 

subcontractor was identified and sent, you know, 

over to medical to submit their sample.

And that prime construction tradeworkers performed 

similar work to bound exposures to subCTWs, which 

is really essentially the entire question that RPRT0092 is set up to answer.
33

They note that whole body counts were considered 

valid up to three years from the date of the job plan. 

And as I said before based on the internal procedures 

it's two years. It says it right there in TIB-60 that 

periods longer than two years for fission products are 

considered unmonitored.

And we agree that 70 to 73 percent of those workers, 

and, again, this is strictly for fission products, 

underwent the appropriate monitoring to be able to 

bound their intakes. So that's the number for that 

one.

I guess, and our response to this is, again, we want 

to point out that there is no job plans for '75 to '79 

so there is a gap there where we can't say anything 

about it.

In the original sampling plan it was actually stated in 

there that NIOSH would only consider any sort of 

bioassay as being associated with a job plan if it was 

conducted within one year of the job plan. That 

goalpost moved a little bit.

And, again, this two years versus three years, again, 

now we're sort of expanding the approach again. 

Again, we trust in that procedure, internal dose 

reconstruction, which was written by NIOSH and 

governs their program, that two years is the 

acceptable timeframe to be considered monitored 

rather than three years.

And, again, the co-exposure model, formerly the 

coworker model, none of the workers identified in the 

'72 to '74 timeframe were monitored via in vivo. It 

was all in vitro, urinalysis data. Only 4 percent had 

monitoring via in vivo in '80 to '89 and that is how 

you would establish that the unmonitored workers 

are actually represented in the coworker model.

We agree on the percentage of directly monitored 

workers, again you're in that 70 to 73 percent range, 

but we disagree on the effectively monitored workers 

for the reasons I just stated. They are not monitored 

via in vivo and in vivo is what is used to develop the 
34

co-exposure intakes.

So moving on to Finding 9, and this is the big one, I 

guess. SC&A does not find that the data collected as 

part of the RPRT-0092 review support the premise 

that subcontractors on job plans that should have 

required internal monitoring for americium were 

either directly monitored, around 20 percent, NIOSH 

and SC&A agree on this, or alternately appropriately 

represented in the derived coworker models for SRS. 

And, again, coworker is the antiquated term, the 

correct term is co-exposure now, but since that is the 

way it is worded in the original finding we kept it here 

for that.

And as far as those who are represented, the 

unmonitored workers represented in the co-exposure 

models, that's an additional 13 percent which gets 

you up to about 33 percent.

To summarize again what we see as NIOSH's 

response based on the response paper from August, 

most of the americium exposures were commingled 

with plutonium. Additionally, NIOSH provided 11 

examples of incidents involving subcontractor 

workers where there was follow up monitoring. SC&A 

does not dispute that.

And that NIOSH believes that the effectively 

monitored population should be 56 percent, not 33 

percent, and that 56 percent actually comes from 

SC&A's analysis and it includes those workers who 

were monitored via in vivo for americium, which 

again is not currently used in any sort of co-exposure 

calculation.

So when SC&A calculated the 33 percent we didn't 

count an unmonitored worker as effectively 

monitored unless they were on the same job plan as 

a monitored worker via urinalysis, which is used in 

the co-exposure model.

So we acknowledge that the majority of the 

americium exposures would likely also involve 

plutonium that is commingled with it. It's a 
35

parent/daughter relationship there. We also 

acknowledge that the incident-driven bioassay did 

occur.

We point out that the examples provided in the 

August response were limited to the 1980s and I'm 

not sure how much I can say about this because our 

response paper has not yet cleared ADC.

But for those of you who have the "Official Use Only" 

copy you can look at our description of Example 1 

and it points out several issues with the institutional 

controls that were in place at the time.

So, again, I don't think I can really speak to that on 

this public call at this time, but I would point to the 

Work Group Members again to that description of the 

first incident example and hopefully you'll see what I 

am talking about there.

Anyway, even though a lot of the americium was 

commingled with plutonium it doesn't answer the 

question of when you have separated americium, as 

occurred in the F-Wing. And, again, those are the 

only job plans that were analyzed in this evaluation 

and there were none for the Multi-Purpose Processing 

Facility.

And, again, we feel that when you establish the 

effectively monitored population, that's the directly 

monitored, they actually submitted a sample, were 

counted in vivo, plus those unmonitored workers who 

were on the same job plan as somebody who is 

included in the co-exposure model, we believe that 

the correct number is 33 percent effectively 

monitored, at least at this time.

And, again, just perusing through NIOSH's 

presentation sent late yesterday it seems that maybe 

that co-exposure model might be modified, so we'll 

certainly talk about that later today.

Again, our responses, we don't feel that RPRT-0092 

actually accomplished its goal, at least for 

americium-241. Now, again, SC&A believes that for 
36

americium only 33 percent were effectively 

monitored.

NIOSH contends that it is 56 percent, which doesn't 

necessarily strike me as a great number either, but 

this comes down to a policy decision on what is 

acceptable, how complete is complete.

Moving on, Observation 2. For the '72 to '74 period 

we only had one job plan and worker combination for 

americium exposure. We noted that in the original 

RPRT-0092, however, it indicated that two job plans 

were applicable for this period, and this is really an 

easy one.

NIOSH responded that, you know, that second job 

plan really should not have been, or the report should 

not have indicated that the second job plan was to be 

assessed for separated americium monitoring 

because it did not take place in the F-Wing, so it just 

should not have indicated that, and we agree with 

that clarification.

Again, it's an observation. We would recommend that 

it be closed and, again, just to sort of remind the 

Work Groups that there was only one single job plan 

available for evaluation from '72 to '74 and there 

were no job plans available for the evaluation from 

'75 to '81, or '80. There was job plans from '81 to '87 

only.

And this gets back to, again, what is the effectively 

monitored population and what we point out here, 

again, is that a lot of the matches made for the 

effectively monitored population were based on a 

worker who was sampled in 1991.

The worker was in a different area and was involved 

in an incident there. At the time of our review that 

data was not included in any sort of co-exposure 

model so we didn't think that credit should be given 

for that.

But, again, a summary of NIOSH's response is that 

the intent of the report was to just assess if 
37

unmonitored workers worked in the same 

environment as monitored workers.

SC&A feels that, again, the monitored workers have 

to be part of a co-exposure model to consider it 

representative and, again, this is a point of 

contention that will be discussed thoroughly if not 

through this presentation but certainly through 

NIOSH's response presentation.

NIOSH contends that the 1991 sample does reflect 

exposure potential for all the job plans that that 

worker was involved in. We don't dispute that.

NIOSH has agreed that that 1991 sample would be 

incorporated in any future revision of the coexposure model. So that would essentially take care 

of this observation anyway.

Again, just to reiterate, when we are trying to get 

percentages here of the effectively monitored how 

many workers are actually covered by either direct 

monitoring or the co-exposure model that's the point 

of contention.

And, again, SC&A believes that representation is only 

established when your monitored worker is actually 

used in a co-exposure model so that when you have 

the unmonitored worker on that same job plan you 

can say they are represented by the person standing 

next to them, for lack of a better characterization.

Now we agree that '91 sample does reflect the 

exposure potential to any job that person was 

involved in and NIOSH agreed to include that sample 

in any future co-exposure analysis and evaluation, so 

SC&A recommends that that observation also be 

closed by the Work Group.

Okay, that kind of sums up the DuPont era analysis. 

And, again, there is some gray area with 1990 that 

Ron Buchanan will get into.

I guess at this point before turning it over to Ron are 

there any questions at this point or should we just 
38

proceed ahead?

(No audible response.)

Mr. Barton: Well, hearing none, Ron, do we got you 

on the line?

Dr. Buchanan: I think so. I hope so. Can you hear 

me?

Mr. Barton: I can hear you. Alright.

Dr. Buchanan: Okay. This is Ron Buchanan with 

SC&A and I am going to be briefly talking about the 

Westinghouse Era and we will cover Findings 10 and 

11 and then Observations 4 and 5. And so, again, feel 

free to ask questions as we go along if you have any.

So Finding 10 we were concerned that the RWP data 

for 1990 was lacking and, therefore, and as Joe has 

alluded to this previously, that the 1990 should be 

included with the limited data era of '72 to '89 and 

not bundled with the year 1991. Next slide. 

Now we understand NIOSH's response is that they 

believe that 88 percent direct monitoring for 

subcontractors is just not incomplete and the results 

of the NOCTS data indicate that 89 percent of the 

subcontractors who were claimants in 1990 had some 

form of internal monitoring data and that Savannah 

River continued monitoring all site workers during the 

changeover in contractors. Next slide. 

Now our response is that, first of all I would like to 

put in the note that RPRT-0094 was issued just 

before we issued our response to 0099 last year and 

in that report it showed that about 89 percent of the 

subcontractors were bioassayed in 1990 and that 

that was similar to the percentage that was 

bioassayed during the following periods of the '90s.

However, we reviewed RPRT-0094 and we agree with 

that. However, what we are talking about in 1990 

was not the number of bioassays but the RWPs that 

specified what radionuclides should be bioassayed 
39

for, and so the number of bioassays doesn't 

necessarily substitute for the number of RWPs, which 

would give specific radionuclides. Next slide, please. 

And we look at this, NIOSH's response, and we see 

that the 88 percent NIOSH quotes covers the entire 

period of 1990 to 1998, not just the year of concern 

of 1990 to present, and addresses the number of 

bioassays, not the number of RWPs.

And so we feel that bundling that '90 and '91 

indicates that that there is a lack of RWP information 

for 1990 and/or with '91 and it is 1990 that lacks.

There was only one RWP that had one worker on it.

(Off microphone comment.)

Dr. Buchanan: Pardon?

Participant: Okay.

(Off microphone comment.)

Dr. Buchanan: Okay. So that was Finding 10 and this 

is Finding 11. We feel that overall for --

(Simultaneous speaking.)

Dr. Roberts: Hello? I am hearing someone speak in 

the background. Please mute your phone.

Dr. Buchanan: Okay. Okay, we feel that for both 

periods that when you consider whether the 

contractor was monitored or not you have to look at 

all of the radionuclides being monitored.

Now that was the original intent, I understood, of 

RPRT-0092 and then it went to the at least one 

radionuclide monitored.

In other words, if there was an RWP that specified 

you had to have strontium and plutonium then my 

opinion is that you should have to have bioassay 

results for strontium and plutonium, not just for 

strontium or plutonium, because this would not 
40

represent that the person was strictly monitored for 

what was required under the conditions of the RWP.

And so if you analyze the data, Bob Burton analyzed 

the earlier period, I analyzed the later period, and we 

found that the percentage of the directly monitored 

workers we found ranged from 47 to 77, whereas 

RPRT-0092 where they only use at least one 

radionuclide be monitored ranged from 76 to 96, so 

there is quite a bit of difference there, about a 20 

percent different.

And the effective monitor, if you include the coworker 

that might have been with the worker and he was 

monitored then we calculate 55 to 89 percent and 

RPRT-0092 has 85 to 99 percent. Again, quite a bit 

of difference in what appears to be the monitoring 

rate.

Okay, so we understand NIOSH's response says that 

originally that was true, all of them were supposed to 

be monitored, however, RPRT-0092 only used at 

least one.

And so NIOSH believes that the data given in the 

report shows that the subcontractors were monitored 

similar to other workers and that unmonitored 

subcontractors worked in the environment as the 

monitored workers. Next slide.

Dr. Roberts: Sorry, Ron. It sounds like somebody is 

speaking in the background and they are probably 

not going to hear me to mute.

Dr. Taulbee: It's whoever is calling User 1.

Dr. Roberts: Yes. I've written -- Nancy or Zaida, are 

you still on the line?

Ms. Adams: Yes. I'll try to --

Ms. Burgos: Yes, we'll do it.

Dr. Roberts: Okay. Thank you.

(Pause.)
41

Dr. Roberts: Sorry, Ron.

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

be okay to keep going.

Dr. Buchanan: Okay. Okay, we're on Finding 11 now, 

Slide 48. Additionally, SC&A understands that NIOSH 

stand by the results given for the effectively 

monitored workers by using the one bioassay only 

and even without the effective monitoring that they 

have plenty of data to create a coworker model.

Okay, so we can move to Slide 49 now. Okay, so from 

our analysis we, again, we think that using just at 

least one bioassay should not be used to indicate that 

a worker was adequately bioassayed as specified by 

a job plan or RWP. At most it's a crude indication that 

the worker was bioassayed but not necessarily 

specific to the requirements of the job plan and 

because, again, a worker could have been on routine 

uranium analysis but then required by a job plan to 

have plutonium analysis and the uranium wouldn't 

count for the plutonium bioassay.

In addition, when that subcontractor worker's data 

comes up for dose reconstruction that person would 

only be assigned uranium dose and probably not 

plutonium dose unless there was special 

circumstances that indicated that he needed to do 

that because they were not in the worker's file that 

he is monitored for plutonium. Okay, next slide. 

Okay. So we feel that there is a severe limitation to 

using just at least one bioassay when weighing the 

adequacy of the internal monitoring data.

So the Work Group should be aware of that fact and 

that the original intent of RPRT-0092 was to 

determine if subcontractors were monitored similar 

to other workers and not that if they had some 

bioassay but if they had complete bioassay.

So I'll move to the next one. Okay, that was Finding 

11. And so now we have two observations.
42

Observation 4. This was the -- We have been 

debating this a while, and that is that when you do 

use the effective monitored data to say that a worker 

was monitored, a sub was monitored, you have to be 

very careful of what you include because there is a 

lot of criteria that needs to be met.

One of our suggestions was same crafts so it would 

be the same exposure. However, there has been 

some debate over that. Now we all agree that it 

should be the same date and the same time that the 

work was performed and, also, on the same RWP.

Now we understand that NIOSH says that when they 

compare the plutonium bioassay datas for the '90s 

there is no significant difference in the crafts and that 

they consider the following criterias listed there on 

the slide, the RWPs, the working conditions, similar 

times, and not the same crafts, but similar 

environment. Next slide, please. 

And so NIOSH found that they had the same amount 

of bioassays over the crafts, but this doesn't really, 

this just indicates the frequency of bioassay, not 

necessarily that it had similar exposures as an RWP 

would point out.

And so SC&A now when we did look at this effectively 

monitored group we found that if we looked at the 

plutonium data in Table C-3 of RPRT-0092 we found 

about 25 percent of the sign-in dates didn't match for 

the co-exposure method that was used.

So I mainly want to point out that there is some 

fallacies that can take place in there because it's quite 

a detailed process. So, next slide. 

So this observation was mainly to point out the 

caution to the Work Group that you have to very 

careful when matching up coworkers to the subs to 

say that they were effectively monitored.

I think we discussed this, and I don't think there is 

going to be enough data to separate out by the crafts, 

and so what we want to do with this observation is to 
43

make the Work Group aware that the effective 

monitor's percentage has to be taken with a grain of 

caution and that we recommend closure of this 

observation by the Work Group in the SEC Issue 

Work Group at this point. So it was an observation to 

point out a point.

So that brings us to Observation 5 and that is 

probably the crux of the whole 1990 issues is, as Joe 

has alluded to, that the 1990s did see some 

improvement. However, we feel that this wasn't a 

step function when the new contractor took over. It 

wasn't the instantaneous change as you can imagine 

in a huge organization like this. It took a while to get 

it identified and in place and effective.

And so we see that, as I pointed out before, 1990 

only had one RWP with one subcontractor listed in it.

So it took a while to get things in place.

As NIOSH has also agreed that the specific 

radionuclides were not required on the RWP in a 

consistent manner until about the 1990s, about the 

mid-1990s, '94-'95 timeframe. So next slide, please. 

Now we understand NIOSH does not think that any 

of this is consequential to the operation of the 

Routine Bioassay Program or dose reconstruction.

While it is true that radionuclides were not specified 

in the early RWPs until about 1994, however, NIOSH 

has used other information and documentation and 

information on RWPs to give some indication of the 

target radionuclides.

And even though the radionuclide of interest was not 

documented on the RWP this doesn't mean that the 

subcontractor did not have a bioassay taken. Next 

slide, please. 

So we respond to this to say that while the number 

of bioassays is an indication of the data available, 

which is not necessarily an indication that the 

subcontractor was monitored for the correct 

radionuclides while working in the same environment 
44

as the other workers, this, of course, was the issue 

that initiated RPRT-0092's analysis of the job plans 

and the RWPs to begin with. Next slide, please. 

And so now we know that NIOSH assumed basic 

assumptions as outlined on Page 31 of RPRT-0092, 

and that is that they looked at air monitoring 

requirements, bioassay requirements, on similar 

RWPs in the areas, bioassay guidelines and other 

documentation to fill in what they thought was 

needed.

Now I would like to clarify that there is tables in 

RPRT-0092 in the back, the C-1, 2, 3 and 4, et cetera. 

They have assumed and required bioassays for 

certain radionuclides and a lot of when you are even 

talking about directly monitored subcontractors when 

that figure says you have 70 percent were directly 

monitored, 20 percent were effectively monitored, 

NIOSH gave you 90 percent overall.

Well, even on a directly monitored those 

requirements were combined. If a person needed a 

certain radionuclide that was determined by if it was 

specified on the RWP, which it wasn't much in the 

early days, even in the early '90s, and assumed, 

you'll see an R and an A, and R was accurately written 

down and A is assumed, which means that NIOSH 

went back using these criterias and said, yes, 

plutonium should have been a candidate that might 

have needed monitored during this specific instance.

And so you have some judgment call there, but you 

don't have direct linkage between the RWP and the 

isotope that was assumed to be monitored or needed 

monitored, even indirect, and then you supplement 

that with effective monitoring which increases the 

percentage some if you assume that the coworker 

and the sub was exposed to the same intake and then 

that coworker was monitored.

So there is a number of assumptions being made in 

even the direct monitoring. And so we feel that the 

early 1990s is still a question on how accurate some 

of these subs were monitored. Next slide, okay. 
45

And, of course, you couple that, the fact that the 

RWPs weren't specific until the mid-1990s and then 

you get concern also that there were still issues in 

1997 of workers not leaving bioassays, and this was 

more specific to the RWPs overall.

For example, in 1997 where you had the 3200 cases 

and there was only like 160 that didn't leave samples, 

but that was RWP people which could include a lot of 

subs. And so you have that area of concern and you 

have your DOE Occurrence Report in 1998 that 

indicated that there was job-specific bioassay issues 

repetitive back first identified in '95. And so that is a 

reason that we analyzed the 1990 data in some detail 

and while we didn't find some of the big gaps in the 

lack of facility coverage, we had more facility 

coverage and we had information with RWPs, 

especially in the latter part of the '90s, we still have 

some concerns.

So to summarize it, go to the next slide. We have two 

issues still and that is that there is a limitation on 

what the one bioassay concept can cover and that we 

should consider heavily how that weighs in on the 

accuracy of the internal monitoring data and that 

doesn't necessarily satisfy all the internal monitoring 

requirements or indicate adequate internal 

monitoring. Next slide, please. 

And so we have some incomplete RWPs, that's 

probably one of the main cruxes of the 1990s, is that 

there was marked improvements with the 

introduction of RWPs in the early '90s but they did 

not begin to consistently specifying radionuclides 

until around the mid-1990s and that filling in the 

earlier requirements for the RWPs through later 

information has its limitation.

And as we have seen this was done also for the 

DuPont area and we feel that this even for the '90s it 

has its drawbacks because there is not a direct 

linkage between the RWP and the bioassay 

requirements.

Okay, so that concludes my part on the 1990s. If 
46

there is no questions I will turn it over to Joe to sum 

up the 1972 to '90 era.

Mr. Fitzgerald: Any questions for Ron?

(No audible response.)

Mr. Fitzgerald: Okay. Just to wrap things up from our 

standpoint, again, this embodies the NIOSH August 

response in addition to what was said last December.

You know, we split our conclusions for the DuPont 

versus the post-'90 era. For '72 to '90 we continue to 

conclude that NIOSH has been unable to 

demonstrate, and this is using the stated evaluation 

criteria in RPRT-0092, to demonstrate the 

completeness of subcontractor job-specific bioassay 

data and it did not accomplish the objectives for 

determining completeness that was in the sampling 

plan that was the basis for the analysis.

Our second point, and this was covered by Bob, is 

that the limited analysis of the americium by time 

period, for '73, '81 through '87, and for the fact it 

was only one location, F-Wing of 773-A, showed 

limited associated monitoring to conclude that, in 

fact, the co-exposure models are truly representative 

of the workers on the job-specific bioassay program.

And, finally, it remains unknown from our standpoint 

to what extent past job-specific bioassays are 

incomplete. I mean that was the central question 

three years ago.

But it is known that the gap in '97 that was the driver 

behind this review, it was significant, and we believe 

that the weight of evidence that we have provided at 

least invalidates the inclusion of the pre-'91 

subcontractor data as sufficiently complete and 

representative for use in the coworker model, or the 

co-exposure model, I'm sorry. So those are the three 

touchpoints for '72 to '90.

Okay, for '91 to '98 the so-called gray area, which 

Ron just covered, as he noted we conclude that the 
47

subcontractor job-specific bioassay completeness we 

believe can be established. There is certainly enough 

information, whether it's RWPs or bioassays, I mean 

certainly the amount of information becomes much 

greater, a lot of it derived from the fact that 

Westinghouse put in place procedures and programs 

that, you know, provided more accountability and 

required, in fact, more specific bioassays.

However, the big qualification and where we call it 

the gray area is we are not clear still where that step 

function is after 1990 because, again, that was a 

period where new procedures, new practices, even a 

formal RWP program was being stood up at the site, 

so the question is -- and this question goes back to 

the fact that, you know, the whole issue with notice 

of violation and the self-assessment that 

Westinghouse performed was that, you know, a large 

percentage of the job-specific bioassays were 

missing or lacking for 1998 and there was no clear 

idea of whether that condition pre-existed '97, '98 --

or, I'm sorry, '96, '97.

I think the information is much more comprehensive 

now, but we are still not very clear on whether that 

point of completeness and representedness is 1990, 

'91, '92, certainly it suggests that it might be in that 

very early '90 timeframe, but for the reasons that 

Ron covered we are still concerned about that.

I want to conclude by reading into the record 

something that actually is in our executive summary. 

It's the last paragraph of our executive summary.

NIOSH emphasizes in its recent review, and this is 

the August review -- I'm sorry, no, it's the recent 

review of RPRT-0091, which is the report we are 

going to discuss next, but there was a very relevant 

citation in there.

The citation is that "A small amount of missing 

routine or job-specific bioassay samples did not 

invalidate the Radiation Protection Program at 

Savannah River and do not automatically invalidate 

the vast amounts of available monitoring data to 
48

generate a coworker model." That's the very central 

quote from RPRT-0091.

But, you know, from our standpoint, and I think we 

have touched on this today, we think this misses the 

point of the RPRT-0092 analysis.

As pointed out in SC&A's 2017 review, going back 

three years ago, subcontractors are not merely 

another worker category. They were often transient, 

performed a variety of work across the site, and they 

were often assigned the higher exposure jobs making 

it imperative to demonstrate that their internal intake 

data are sufficiently complete and bounded by the coexposure model.

From our standpoint it remains unknown to what 

extent job-specific bioassays are incomplete, but 

what is known is that the gap in 1997 was significant.

SC&A concludes that the weight of evidence provided 

by SC&A's review of RPRT-0092 invalidates the 

inclusion of those data's complete and representation 

in the SRS co-exposure model for at least the 1972 

to 1990 timeframe, the DuPont era.

So that's kind of our bottom line at this point. I would 

add that quite apart from the difficulties with the 

unavailability of records and, you know, permits and 

job-specific bioassays, the design of RPRT-0092, the 

analysis that was designed and the evaluation 

objectives, I thought were very relevant and 

corresponded to the requirements of IG-006 in terms 

of directly establishing the completeness and 

assessing the representativeness.

So no fault with the design, it's just the execution 

because of the lack of records and the assumptions 

that then had to be made I think undercut the results 

that were achieved.

I don't think we still have a valid basis to judge that 

the completeness of job-specific bioassays for 

subcontractors prior to '96, '97, were, in fact, 

dramatically better, and particularly for the '72 to '90 
49

timeframe.

So that's pretty much it from our standpoint. 

Rashaun, do you want to -- well, first let me say since 

we kind of did a wrap up, are there any questions 

from the Work Group for any of us on the response?

Chair Clawson: This is Brad. Joe, I don't have any at 

this time. Does any other Members of the Work 

Group have any questions?

Chair Anderson: No, I do not on my behalf. This is 

Andy.

Mr. Fitzgerald: Okay. And we did cover this in some 

detail last winter.

Chair Anderson: Yes.

Mr. Fitzgerald: So it's a recap.

Chair Anderson: It's a good update, but that's --

Mr. Fitzgerald: It was a year ago, so I guess it was 

worthwhile.

Chair Anderson: Yes.

Mr. Fitzgerald: Rashaun, do you want to take a break 

or what's your direction?

Dr. Roberts: Let me defer. Brad, what is your feeling 

about that? Do you think a comfort break is in order?

Chair Clawson: Yes, that would be nice.

Dr. Roberts: Okay. How long of a break is 

reasonable? It's about, it's just a little bit before 

12:30, so when shall we reconvene?

Chair Clawson: Ten minutes. Ten minutes would be 

fine with me.

Dr. Roberts: Ten minutes. Is that sufficient for 

people?

Chair Clawson: Voice your opinion if it isn't enough.
50

Member Ziemer: Good for me. Ziemer.

Dr. Roberts: Okay. So we will be back at let's call it 

12:40.

Chair Clawson: Okay, sounds good.

Dr. Roberts: All right. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 12:28 p.m. and resumed at 12:40 p.m.)

Dr. Roberts: So, my clock is showing 12:40. So, the 

court reporter is back on the line. And let's do a quick 

roll call to make sure that Working Group Members 

are back.

So, Brad, are you back on the line yet?

Chair Clawson: Yes, I'm back.

Dr. Roberts: Great.

Lockey?

Member Lockey: Yes, I'm back.

Dr. Roberts: And did David Richardson, by chance, 

join us?

(No response.)

Okay. I don't hear anything.

Schofield?

Member Schofield: Yes, I'm back.

Dr. Roberts: Okay. Anderson? Andy, are you back?

(No response.)

Okay. I don't hear anything.

Josie, are you back? I think I see you.

Member Beach: Yes, I'm back.
51

Dr. Roberts: Okay. Gen?

Member Roessler: I'm here.

Dr. Roberts: Good.

And Ziemer, Paul?

Member Ziemer: Yes, I'm back.

Dr. Roberts: Okay. Great.

Chair Anderson: I'm here. I'm sorry, I was on mute.

Dr. Roberts: Great. I thought so. Okay.

Chair Anderson: My screen went black.

(Laughter.)

Dr. Roberts: Okay. Well, it looks like everybody's 

back.

I would just like to send a reminder, though, to just 

make sure. Sometimes the Zoom or your phone can 

come off mute. So, if you could just periodically check 

and make sure that you're completely muted as 

others are speaking. It's been a little bit of a rocky 

morning. So, if you could just make sure that you're 

muted.

Great. So, thank you.

And let me hand it back to you, Brad.

b. NIOSH Presentation

Chair Clawson: Thank you. Okay. Well, we've heard 

from SC&A. And so, the next one is the NIOSH 

presentation. I believe you'll be doing that, John?

Dr. Cardarelli: Yes, I will.

Chair Clawson: Okay.

Dr. Cardarelli: So, I need to share my screen here. 

And bring this one over. Okay. I'm not sure that's the 

right one to be seen. Uh-oh, I'm having difficulty 
52

getting the screen because it just went black. Oh, 

there we go. All right. Can everyone see that now? I 

can't see anybody, but --

Member Ziemer: I'm not seeing it, John. Nothing yet.

Dr. Cardarelli: Okay. It's coming up on my screen. 

Let me try something else. My apologies.

Member Ziemer: Do you have screen-share 

privileges from your computer?

Dr. Cardarelli: I am going to try to start over here 

because I can't seem to get my Zoom to work right.

Dr. Taulbee: John, if you want, I can try to share.

Dr. Cardarelli: Yeah, if you want to do that. For some 

reason, it's gone to all different screens on my 

computer here. And I'm trying to move the screens 

around. Here we go. Share screen and this 

presentation.

Dr. Taulbee: There, you've got it.

Member Ziemer: Now we have it.

Dr. Cardarelli: Great.

I might look off to my right a little bit because my 

monitor is there and that's where I can see, and then, 

I can see the video on my left when I look into the 

camera here, just to orient folks here.

Now you should only see just the whole picture. Is 

that correct?

Dr. Taulbee: Yes.

Dr. Cardarelli: Okay. Perfect.

All right. First of all, I want to thank everyone. This 

is the first time I get to present in front of the SRS 

Workgroup. I joined NIOSH about a year ago, and 

I've been spending the last year getting myself slowly 

brought up to speed in reading many, many years of 

transcripts and reports and trying to get myself to the 
53

point where I can present this information 

competently to you, and I am hoping I am there.

And I, first, want to say something to Mr. Clawson 

and the Workgroup, that the material that I'll be 

presenting here, the actual report was sent to the 

Workgroup on September 2nd of this year. The 

PowerPoint presentation that was mentioned earlier 

was sent to the Workgroup yesterday, and that was 

due to the fact that there are slides in this particular 

presentation that needed to go through classification 

review and there was a delay in getting that back in 

time. So, my apologies on that.

Chair Clawson: I understand, John, and I appreciate 

that.

Dr. Cardarelli: No problem. Thank you very much.

I'd also like to thank SC&A for giving a two-hour 

recap of the material. It came as a little bit of a 

surprise because what they really presented was 

material that we received on November 5th, which is 

great. It's just that we -- the good news is my 

presentation probably will be substantially shorter 

because it's partially been presented. The bad news 

is we may not have all of our responses to have a full 

discussion and may need to take some time to digest 

what we received a few weeks ago. But I think we 

can make some good progress today.

And I especially appreciate the SC&A's 

recommendations to close out Observations 2, 3, and 

4. So, that will certainly cut off some of our discussion 

there.

What I wanted to get started with is the fact that the 

primary authors of this particular work were Mike 

Mahathy, who's the health physics lead at the 

Savannah River Site, and Roger Halsey. I worked 

closely with them over the past several months to 

prepare this, and I may rely on them to speak up, or 

Tim, to correct me if I happen to get a specific detail 

wrong. So, I ask for a little bit of support there as we 

present this information.
54

Let me see. We should go to the next slide. Okay. I'm 

going to redo my images. Okay.

As pointed out earlier, the background of this whole 

work was simply to determine the question of 

unmonitored workers working in the same 

environment as monitored workers, and I'll even add 

the caveat at the same time. That was mentioned in 

the previous presentation.

So, the Workgroup asked NIOSH to obtain more 

information, and we thought at the time that special 

work permits, radiation work permits, and job plans, 

would be able to answer this question with the fidelity 

necessary to address that question.

So, we went after and gathered a whole bunch of 

information. And, you know, if we can actually do 

this, then the ultimate resolution would be the use of 

coworker exposure models would be applicable for 

dose reconstructions. If they aren't, then a different 

approach might be needed.

So, at the out-front, it's our preference that we do 

not stratify subcontractors from the contractor trades 

population. I think that's kind of an underlying 

assumption that we would like to put forward there.

What was discussed is kind of presented in this 

image. It's a timeline from 1950 through 1998, but it 

shows where the SEC Class 103 ranges from 1953 to 

about 1972. The ORAUT-RPRT-0092 starts in 1972 

and progresses through about 1998. And then, I've 

shown in here when there's a change in the major 

contractor, the DuPont era and the Westinghouse 

era. And then, in the report we separate that further 

into Mid DuPont and Late DuPont, as you can see 

there, separating around 1979 to 1980.

So, to save us some time, I put up the finding here, 

and I guess I'll go ahead and read it into the record. 

No SWPs or job plans sampled by NIOSH for 1972 to 

1990 contained any requirements for indications for 

job-specific bioassays, despite respiratory protection 

being required, bringing into question the approach 
55

taken to satisfy RPRT-0092's first evaluation 

objective, which was to determine the fraction of 

subcontractor trade workers identified on RWPs of 

interest who were monitored for internal intakes.

So, what does this get to? It's the finding questions, 

the completeness of the dataset for subcontractor 

trades during the DuPont era.

Well, our response is, basically, summarized earlier, 

that we contend that, even though the bioassay 

choice may neither have been checked nor entered 

in the standard work permits and job plans, there 

was plenty of or an ample number of bioassays taken 

after respiratory work was conducted to verify 

workplaces.

So, RPRT-0092 used the era-specific criteria to 

determine if bioassays should be taken for the '72 

period. And I think that's really important. We're 

basing determinations on what was done at the time 

that a routine bioassay program was in place. We 

should not necessarily be applying what was done 

during the Westinghouse era and expect the same 

level of fidelity in the DuPont era. They were 

absolutely different operating philosophies, different 

management approaches and procedures. That's 

been acknowledged during previous, past Working 

Group meetings. So, I think it's a little bit we have to 

be cautious when we compare these two and try to 

say, well, it's not complete because it didn't meet the 

criteria that Westinghouse met and we like that 

criteria.

I think this was an interesting quote that I found in 

one of the transcripts back in February 9th of 2019, 

and SC&A made this comment. DuPont handled the 

subs pretty similar to how they handled the in-house 

workers.

So, you could go to that particular transcript, read 

the context, but, in essence, the main message here 

is, even folks back then recognized that the 

subcontractors were not treated super special and 

they don't have something radically different or 
56

unique which might require them to be further 

substratified from the construction trade workers.

Going back to an image, I've tried to bring the big 

picture. We've talked about bioassay control 

procedures. We've talked about job plans. We've 

talked about radiation work permits, when certain 

things started and ended. This is just one slide with 

a graphical image that gives of us an idea of when 

the bioassay control procedures took place.

And I think it's really important to note that, during 

the DuPont era, think of this as more of a production 

era, and the Westinghouse era is more of a transition 

from production to environmental cleanup and other 

activities. And that really starts to take off after the 

1998 period.

So, one thing is very stable when you're in production 

and things begin to vary a little bit when you're 

moving away from a normal production era. But 

there's an evolution that also goes on with regard to 

the routine monitoring, why it was done, how it was 

done. And what we'll see throughout this 

presentation, it's remained relatively constant over 

time. And I think that's an important talking point 

that we can discuss later.

So, Finding 2: Radionuclides of interest assumed for 

sample permits in RPRT-0092 are of questionable 

accuracy, given the cited lack of adequate 

radiological source term characterization prior to 

1990.

Well, we believe that, prior to this, the radiological 

source terms at SRS were adequately characterized 

with sufficient accuracy for dose reconstruction 

purposes. And there's significant evidence that SRS 

characterized the radiation work environments in 

multiple ways, and we talked about that. And these 

are just some examples:

The SRS maintained inventories of radioactive 

materials.
57

We have isotope production records with quantities 

and locations.

We have transuranic radionuclides and enriched 

uranium controlled as special nuclear materials.

Monthly technical reports from 1953 through 1989. 

These are very detailed. It tells us exactly where the 

radionuclides are, their amounts, quantities, things 

of this nature, which are necessary to understand 

when you design a health physics radiation protection 

program.

Not only did we do that, or did SRS do that, SRS 

monitored the routine and non-routine work by a 

variety of air monitoring, engineering controls, and 

things that we've mentioned in our report.

I think what you'll see, too, there's an example in 

here where a contamination incident occurred which 

triggered a series of bioassays. And I'll get into that, 

because bioassays are done above and beyond the 

requirement by the site and by the orders, DOE 

orders at the time. They had a policy in place that no 

worker would be exposed. The bioassay is merely the 

last line of defense for which we would try to 

understand, to ensure that all of the other air 

monitoring, surface monitoring, personnel 

monitoring are all being done adequately to protect 

the workers.

One example is this particular table here. And I want 

to bring out that these are not all the buildings and 

facilities, just a handful to fit on the slide. But we 

have four areas or four time periods: 1971, '77, 

1985, and 1998.

And as you go across a particular building, say the 

221-H Canyon, you can see that the radionuclide of 

interest was plutonium, fission products, and 

uranium. And that was what the bioassay routine --

and that's important here, routine bioassay. Keep in 

mind, that doesn't mean they didn't measure for 

other things if it was a special, because, through 

time, if it became a special or if you were involved in 
58

an incident, they would often go back and do alpha 

spec or gamma spec to specifically identify the 

radionuclide that would be the biggest contributor to 

dose in those samples.

The message here, though, is it's generally consistent 

throughout time. And these were based not on some 

large-scale Farrell and Findley operation in the '90s. 

It was based upon knowledge process, where the 

radionuclides were, experience from the 40 years of 

operating the facility. So, people pretty much knew 

what was a stable work environment -- and these are 

the isotopes that contributed at least 90 percent of 

the occupational dose. So, we've captured the 

majority of most workers' exposures just in this 

routine program, again, which was only designed to 

verify that all of the other health physics practices 

were operating properly.

So, Finding 3: the scope of the permit sampling for 

1972 to 1990 at SRS is essentially limited to one 

facility, 773-A, falling short of achieving NIOSH's 

sampling objective and the representativeness called 

for in the NIOSH coworker or co-exposure guideline.

So, again, this finding challenges the completeness 

of the data for subcontractor trade workers, primarily 

between 1972 and 1979, since only special work 

permits or job plans were found for 773-A. Well, we 

believe that the subcontractors were adequately 

monitored in areas outside 773-A between '72 and 

'79. Additional reviews of plutonium logbooks support 

this representativeness called for in the Co-Exposure 

Implementation Guide.

I was part of a coding process with Mike, and we 

reviewed over 10,000 pages of plutonium logbooks 

from 1972 to 1990. And we looked specifically for 

subcontractor trade workers to get a better 

understanding of the areas and the volume, or the 

amount of subcontractor trades that worked at the 

site over time.

What we found was that there was over 11,300 

bioassay samples, over that amount, because we did 
59

not code the same person if they were on a single 

page and had five bioassays. We were merely 

interested that a subcontractor trade worker left a 

bioassay sample on this particular day, and that's 

what we've really captured. If he left five, we 

wouldn't count that as five separate individual 

records because the question of the coding was: do 

we monitor subcontractor trades and where did they 

work? And this was a way of capturing that in the 

most efficient way we could.

So, we identified 7,000 unique subcontractor trades 

and at least 23 areas at the site. One thing I'll point 

out, when Joe was presenting his information, he was 

suggesting that there was over 30 particular areas at 

the site. The data did not support something of that 

large of magnitude of potential areas where 

subcontractor trades would be exposed. The actual 

bioassay monitoring data, we identified up to 23 

sites.

So, here's the data over time. And there's a couple 

of things that I think that we need to look at here.

First, what's this real low number here in the 1972 to 

1978? Well, that's not a period where the 

subcontractor trades were used. That's just a 

cultural, procedural thing. The quote here says, prior 

to 1989, it's still relevant, but, very clearly, you're 

dealing with less subcontractors, fewer 

subcontractors in the DuPont Management System, 

which is a different system. They held themselves 

close, and the operations were pretty coherent. This 

was a quote from one of the transcripts in December 

of 2018 from SC&A.

And the data bears that particular quote out, where 

we do see less subcontractors, especially in the '70s, 

until they started using them more in the '80s.

So, the other thing that you'll notice later -- and I'll 

bring it up -- in 1974 and in 1975, there was some 

discussion in the last presentation that there were 

zero subcontractors monitored that was actually 

using in vivo methods. Okay? But, here, we're seeing 
60

that they are using bioassay. A little bit different, but 

this is number of bioassays recorded by year for 

subcontractors only.

What's even more compelling here is where did they 

work. That's one of the questions: did these people 

get exposed in the same environment as monitored 

workers? Well, here we have monitoring data, the 

11,000 samples from 7,000 subcontractor workers 

by area during that '72-to-1990 period. What you'll 

mainly see is the F and the H areas, where plutonium 

exposures are mainly found, in the canyon areas, and 

this was plutonium data.

The CS areas signifies construction trade workers, 

central shops. And you can see there's a tremendous 

-- that's practically the second or the third largest 

volume of bioassay samples. So, anyone who worked 

through the central shops was being monitored one 

way or another. Now, radioisotopes, other similarities 

and issues, we can talk details there.

But I will point out that the C, the reactor area, has 

932 samples, where the K and the L and the P are 

around 224 up to 620. And why would we have more 

here? And it's simply because this C reactor area, is 

located very near the central shops. So, when 

someone were to leave a bioassay sample, it's very 

easy to put C, thinking central shops, versus just C, 

reactor. That's our understanding. We think that 

that's why we have this much larger number here. 

So, this number is probably larger.

But that's what the data shows and that's what we're 

seeing. So, these workers are being monitored well 

outside 773-A and about 20 other locations.

So, SC&A Finding 4: the SRS incident-based special 

bioassays were provided by workers on a more 

stringent procedural basis and should not be used to 

supplement the evaluation of permit-related, jobspecific bioassays for 1972 to 1989 as a measure of 

historic data completeness.

As I note here, this finding points out the difference 
61

between routine and special bioassay procedures, 

and the latter demanded more attention, and 

therefore, would likely lead to better follow up 

completeness. And SC&A suggests that these data 

will give a false sense of data completeness. And I 

would not necessarily disagree with that, and I think 

that they agreed as well. Special bioassays, they're 

collected for a completely different purpose.

And I think what's interesting in point here -- and this 

is, again, putting the proper context in the NIOSH 

response -- the second bullet, actually, the first part 

of this bullet was in the SC&A presentation. NIOSH 

contends that incident-based special bioassay 

sampling was an integral component of the SRS 

bioassay program for both prime and subs and 

cannot be disconnected from the routine monitoring 

program.

And then, the emphasis put on this was for coexposure modeling completeness -- okay? -- coexposure modeling and completeness. SC&A put a 

period right after routine monitoring. It's the 

application of this data which was really important 

here, and we're using all data for co-exposure 

modeling purposes, and it can be applied for 

completeness in that context.

I think the other thing that's worth noting is that the 

coworkers are considered to be workers at the same 

site whose radiation-monitoring measurements are 

considered to be representative, or -- and the 

emphasis is placed here -- plausibly bounding of 

those received by one or more workers with no 

individual monitoring data.

And what do we mean by that? We simply mean that 

the plausibly bounding part would necessitate the use 

of incident-based or special monitoring because 

those typically occur because an incident occurred or 

you have higher values found in the results. Those 

would tend to bound the workers' co-exposure 

models and give them a higher, a claimant-favorable 

estimate. So, those are some of the reasons I wanted 
62

to bring out.

The evaluation criteria for data in co-exposures I 

think, as stated here, in general, three types of 

monitoring programs have been employed at the site 

covered under this Act. These programs, listed in 

hierarchical order of preference for use in coworker 

models, are the routine, which we've showed data 

on, the routine measurement of workers with the 

highest exposure potential, and the collection of 

samples after the identification of an incident. So, 

hence, we would want to be including these as part 

of our co-exposure modeling efforts.

Member Beach: John, this is Josie.

Dr. Cardarelli: Yes?

Member Beach: Oh, go ahead, Brad.

Chair Clawson: No, I'm trying to figure out, are you 

talking prime subcontractors or are you talking 

construction trades?

Dr. Cardarelli: I'm sorry, I'm talking construction 

trade subcontractors.

Chair Clawson: Okay.

Member Beach: My question is the same. Back on 

slide 15, that was prime contractors with the dose 

you're talking about or --

Dr. Cardarelli: No, this is subcontractor trades only, 

construction trade workers.

Member Beach: So, no prime is included in this slide?

Dr. Cardarelli: No prime is -- yes, that's correct. This 

is not prime. This is only subcontractors, as 

determined by the payroll ID number.

Member Beach: And I'm talking prime 

subcontractors, not the construction.

Dr. Cardarelli: Right. These are only subs.
63

Member Beach: Okay. Thanks.

Dr. Taulbee: Yes, if I can specify, yes, this is just the 

subs, as John stated. This does not contain any prime 

construction trades workers, just the subcontractor 

construction trades workers.

Dr. Cardarelli: Okay?

Chair Clawson: Okay.

Dr. Cardarelli: Okay. I'll get back to where I was.

All right. So, the routine versus incident bioassay. 

The routine bioassay was used, obviously, I 

mentioned earlier, to verify and validate workplace 

controls. Again, the policy of zero exposures was in 

place and this is a validation effort.

As mentioned in the second bullet, incident special 

bioassays include positive results, and they are, I 

mentioned, more bounding, more claimantfavorable.

Rashaun, is this particular Workgroup, is this public? 

Is the public viewing this?

Dr. Roberts: Yes. Yes, they are viewing it.

Dr. Cardarelli: I've got the wrong version of the 

PowerPoint which shows personal identifiers. Let me 

switch out the PowerPoint real quick.

Dr. Roberts: Okay.

Dr. Cardarelli: In fact, while we do that, if there are 

any questions, I'll prepare the next slide, 10, and my 

folks, Roger or Mike, will be happy to address some 

questions.

Mr. Halsey: Are there any questions at this point?

Dr. Taulbee: If I could just elaborate or expand a little 

bit on what John was presenting with those graphs, 

SC&A was making the point that we only had data 

from A area and from '72 to 1990. And that is correct 
64

when you look at it from a job plan and RWP 

standpoint. And so, that's correct. We did not find 

other job plans that we could do this with.

But I don't want people to get the impression the 

workers were -- I'm sorry, this is Tim Taulbee -- but 

I don't want people to get the impression that there 

is no monitoring of subcontractor construction trades 

workers in other areas because there clearly was. 

And that was one of the things that John and Mike 

did as they went through the bioassay logbooks and 

they looked at the plutonium monitoring across, well, 

throughout the logbooks, and which areas did those 

subcontractor construction trades workers leave 

those samples.

And you see the predominance there is F and H area. 

That's where the plutonium was worked with. So, 

that's where you would expect more of the 

subcontractor construction trades workers to be 

leaving plutonium bioassay. And that bears out that 

those workers were, in fact, monitored. Even though 

we don't have the RWPs or job plans to demonstrate 

it, you can clearly see it by the numbers, that there's 

thousands of workers monitored in those two areas 

in that time period.

The third largest is the central shops area. That's the 

area where construction trades workers would come 

in from the union halls, get their assignments, and 

go out to other areas. So, central shops effectively 

covers all the areas from that standpoint.

And then, you've got the C area there. If you looked 

on that graph off to the far left, you'll see how small 

A area is with monitoring for plutonium. Okay? That's 

where we had the job plans in order to compare.

And, John, if you could go to that particular slide, that 

would be awesome.

Dr. Cardarelli: Sure.

Dr. Taulbee: I think it's slide 15.
65

I just wanted to show the scale difference here. We 

only have the snapshot of the RWPs that we can 

match whether somebody was monitored or not 

appropriately for that small area of A area, but the 

vast majority of the bioassay is in other areas where 

plutonium was handled, well, handled more, 

effectively, and where subcontractors would 

potentially be exposed.

Dr. Cardarelli: Okay.

Dr. Taulbee: We can see your screen now, John.

Dr. Cardarelli: You can see it?

Dr. Taulbee: Yes.

Dr. Cardarelli: Okay.

Dr. Taulbee: You're on slide 4.

Dr. Cardarelli: It should be slide 16.

Dr. Taulbee: No.

Dr. Cardarelli: Oh, okay.

Dr. Taulbee: We're seeing your -- it's opened; it's not 

in presentation mode.

Dr. Cardarelli: Okay.

Dr. Taulbee: Okay. Now you're on slide 21.

Dr. Cardarelli: Okay.

Dr. Taulbee: Okay.

Dr. Cardarelli: All right.

Dr. Taulbee: If you could go back up to slide 15, I 

think it was that Josie was asking about, 15 or 16. I 

don't remember which.

Member Beach: It was 15.

Dr. Taulbee: Okay. Actually, I wanted to show 16, 

though. Fifteen is just over time. Sixteen is the 
66

composite there.

And you can see the third column from the left is A 

area. And look at the difference in magnitude 

between F and H area and A area there. It's just that 

we only have those RWPs and job plans in this time 

period for that one single area. But look at the vast 

majority of the samples. They're out at central shops. 

They're at F area and H area.

And so, to imply that we can't say anything about the 

workers being monitored anywhere but the A area I 

just think is not correct. We do know that workers 

were monitored from these other areas in large 

quantities.

Mr. Fitzgerald: Yeah, can I say just one word, 

interject, please? I was going to wait until the end, 

but I wanted to say one thing on this point.

Yes, there are certainly a lot of monitoring data 

points, but in terms of the completeness review that 

is the purpose of 0092, which is matching permits 

and jobs to the bioassays, this doesn't speak to that 

at all. I mean, this is basically a tally of subcontractor 

monitoring data, whether it's permit-indicated or jobspecific. I mean, this is everything. This is routines 

for these particular sites.

Yes, you have data for other locations, but we knew 

that three years ago. The question that 0092 is trying 

to answer is whether, in fact, you can show that the 

bioassays that were indicated by job plans or SWPs 

were, in fact, performed, because in 1996-97 a large 

proportion of those went missing.

So, you know, this is all interesting, but the question 

is, how relevant is it to the 0092 objective that you 

went out to achieve? And again, what you've 

demonstrated is you can look at that complete survey 

from one facility, which is 773-A. That's the 

distinction I think needs to be made.

Dr. Cardarelli: Okay. I think that the next few slides 

might help answer a little bit of that, Joe. I think you 
67

brought up a good point and it's a good segue into 

why I had to change presentations.

I can't see what you're exactly seeing, but I'm 

assuming -- am I in presentation mode?

Member Beach: No.

Dr. Cardarelli: Okay.

Dr. Taulbee: We're seeing slide 21.

Dr. Cardarelli: That's where I want to start.

Dr. Taulbee: Okay.

Dr. Cardarelli: Are you seeing other notes or just the 

slide?

Dr. Taulbee: Other notes. I mean, that is a bunch of 

notes. It's redacted, though. The name is redacted 

and the number is redacted.

Dr. Cardarelli: Yes.

Dr. Taulbee: So, yeah, it's probably the one you 

want.

Dr. Cardarelli: Okay. I wanted to get better fidelity. 

Let me see if I can just do this. For some reason, my 

computer -- I'm trying to go to presentation mode, 

and that's what it does. So, we'll go with this if you 

can read the information. Okay.

This is an example in 1972 of an incident that 

occurred, and we found it in a nasal and skin 

contamination logbook. This is one of those health 

physics protection measures where, if you're involved 

in an incident, you would take a nasal or a skin, or 

whatnot, and it would be sent off for bioassay.

What I want to bring to your attention is, first of all, 

it's 1972. The very beginning part of this question is, 

were subcontractors treated differently or were they 

working in the same environment as primes or 

others?
68

What we have is, this is a construction worker, a 

health physicist, another subcontractor. This is a 

separations officer, and this is another subcontractor. 

All right. The top person up here happens to be 

working with the Wilmington salary group. So, we 

have five people working.

And the description of the incident is working inside 

an air tunnel to 294-H, sand-filler, when the air 

pressure dropped to 90 psig on the manifold that was 

supplying them fresh air to their plastic suits. All 

right?

So, here we have an incident. We have two 

subcontractor trade workers and two normal 

workers, one being Williams. This is the logbook 

entry of their nasal contaminations. As you can see, 

I put their basically identifier of who's the 

subcontractor trade worker and who is the 

separations officer here. And you get to see that they 

have a variety of almost two orders of magnitude 

difference in the nasal contamination.

So, right now, these workers were involved. They 

were all working together. They all had to do a nasal 

swab. And it made it into an entry book in 1972.

This happens to be the plutonium logbook bioassay. 

It's a different logbook now. And I'm only showing 

two of the five workers because the first four that are 

circled in red come from the same person. It happens 

to be the WS contractor who had the 13,959 dpm 

contamination of the nasal area.

And then, the one below that was the separations 

officer, not a subcontractor trade worker. And they 

had 1400 dpm.

You can see the volume for the urine. We codified 

them by the PR number, which has been blacked out; 

the type, which are specials, and then, we have FU, 

which is follow up. And then, we have another special 

down here. The area was the H.

The receipt date you see is 8/2. That's the date of the 
69

actual incident. The bottle date, you can see with the 

follow ups, is 8/2, 3, and 4. And here it's 8/15, but 

the bottle date is 8/3. So, there's always these lags 

in the bioassay protocol, where this person left a 

bioassay sample, but the receipt date for the lab 

wasn't until 8/15.

Moving on in the plutonium logbooks, we start 

looking at examples. And this also conveys good 

information about how difficult it is to interpret these 

logbooks. This is the WS contractor, and they read 

his planchette, a dpm per disk, converted it over to 

dpm per 1.5 liters. What they've reported, which is 

basically an average of these -- .3, .4, .1 and LIP, lost 

in process. And then, they have general remarks.

And of course, this person started out with a nasal 

contamination of 13,595 dpm. And, of course, the 

person below it, the separations officer, who had a 

1400 dpm contamination, got reported less than .1, 

the reporting level at the time.

Now let's look at the subcontractor trade workers 

who were involved in this incident. One had a 3500, 

roughly, dpm nasal contamination, and the other one 

had a 496. So, they had contamination. You can look 

at the volume of their urine at the time. The area was 

the H area, which I copied down from the top of the 

thing. The receipt date was 8/7. And, of course, the 

bottle date was when they left the samples the day 

after here and the day of. They're specials because 

they were involved in an incident. And that's 

approximately the time that they left the samples.

The health physicist, who had 4,000, roughly, dpm 

nasal contamination, you see his volume. He was also 

in the H area. They received his sample, we believe, 

on 8/27. And the bottle date was 8/16, several weeks 

after this incident.

It was a special. So, we're associating this one to that 

incident. It may not have been because there's been 

two weeks that has gone by, but that's the way we're 

interpreting it at this point.
70

So, what were the results of the subcontractor trade 

workers? You can see that it's gone through all of the 

conversions. It's very difficult to read what the report 

was, but I believe this was less than .01 and the other 

one was .2. The one who had 3500 dpm got reported 

less than .1 in the urine, and the one who had the 

lowest nasal contamination actually got a positive 

result of .2. And, of course, the health physicist had 

4,000 nasal contamination and his report came back 

as less than .1.

Now there's a couple of things that I think we need 

to kind of pull back here. The subcontractor trade 

workers were treated exactly the same as the 

operator and the WS contractor with regard to 

providing the bioassay samples. They may have left 

samples weeks after the incident, but it's all covered 

under the special program. The special operator was 

also consistent with the subcontractor trade.

The nasal and surface contamination are not always 

correlated with the bioassay results. That's probably 

understandable because there's lots of different ways 

you can go in and do a smear wipe and do a counting. 

There could be cross-contamination. Many reasons 

could explain that. That's why we would look at the 

bioassay as a gold standard, not the nasal 

contamination level.

Logbooks are difficult to read and interpret, and are 

also prone to errors, as you see in the lost in the 

processing. How would we report that, four individual 

results for that one person, to combine that together?

And then, nonetheless, all of what we've seen here, 

this is good data that can be used to develop a coexposure model. And I think this was probably one of 

the most important aspects of this whole talk, was to 

demonstrate in 1972 how the subcontractor trades 

were being handled. This is long before anything --

RWPs came into place and any other practices that 

would have required a piece of documentation, like 

an RWP, that said, on this particular day, I went to 

leave this and had that. That didn't exist. That was 
71

just a different operating philosophy. But, 

nonetheless, they were covered.

So, I'm ready to move on to Finding 5, which is, the 

incompleteness of the SRS dose records for '72 to '90 

is substantiated by the acknowledgment of 

destruction of subcontractor trade records and 

firsthand worker accounts, coupled with DOE findings 

of missed occupational radiation dose data from 

many SRS personnel files, as well as systematic 

bioassay delinquencies and wide gaps in NIOSH 

capture of permit documentation.

Well, NIOSH respectfully disagrees with that: 

dosimetry records were destroyed or lost. SC&A 

reviewed the RPRT-0092 and they cited inability to 

readily compile radiation exposure data I think prior 

to 1990, as well as any key radiation control records, 

is traceable to a longstanding SRS policy in the 

DuPont era that limited onsite retention of all but 

exposure histories. Records were only retained for 

two years, and then, shipped to the federal 

repository, which retrieval of complete records can 

be difficult, as noted by the DOE assessment team 

and illustrated by NIOSH's survey results for the 852 

boxes that were retrieved.

Someone came off of mute. Did they have a 

comment?No?

So, the DOE Tiger Team, in 1990, assessment of the 

SRS Radiological Safety Program does not mention 

specifically that records were destroyed. The report 

indicated that there was an issue of the availability of 

the dosimetry records, that they weren't easily 

obtainable. So, jumping from not easily obtainable to 

destroyed is a jump without stronger evidence. And 

the one we're pointing to here does not specifically 

say destruction.

So, SC&A reviewed it. Radiation exposure histories 

are maintained in the dosimetry files in Building 735. 

All other records are boxed, inventoried, and sent to 

the federal repository for a storage period of up to 

two years.
72

So, we provided -- SRS provided external monitoring 

data for 74 percent of the subcontractor trade 

workers, claimants, and bioassay monitoring data for 

56 percent of the subcontractor -- sub construction 

trade worker claimants for the period 1972 to 1990.

And Findings 6 and 7, I've combined them. For the 

sake of time, I'm not necessarily going to read what's 

on the slide, but, basically, say the next few slides 

are going to talk about this whole issue of effective 

monitoring and where the numbers come into play, 

and where there's a difference of interpretation, and 

the reason for it.

So, I combined them because they both addressed 

that percent. NIOSH agrees with the SC&A finding 

about 20 percent were monitored in the 1980s. We 

respectfully disagree with their Finding 7, with 33 

percent effectively monitored.

We answered a slightly different question of what 

percentage of the subcontractor's CTWs were 

effectively monitored by either method, which was 

the intent of RPRT-0092. I believe the SC&A 

answered the question, what percentage of the 

subcontractor trade workers were effectively 

monitored that could be used to develop a coexposure model? They stated that chest counts are 

not to be used in a coworker development -- now 

that's the key phrase -- and deleted these data in 

their calculations.

So, NIOSH, we can use chest count data for coexposure modeling if needed. Now I think this chart 

might better explain it more logically, where we have 

our americium analysis in the left column. You have 

urinalysis data, the in vitro, and chest count data in 

vivo. The number of bioassay results from job plans 

-- and by the way, this comes from 151 americium 

bioassay results from 35 job plans reviewed between 

1980 and 1989.

The 20 percent that we agree on is at the bottom, 

where we have combined the number of bioassay 

results from the job bioassay plans that include both 
73

urinalysis and chest count data. So, that's where we 

get our 20 percent that we agree.

Where there's a disagreement is right in here with 

the chest count data being used, as a result, from 

coworker data. So, if you're with a coworker, you did 

not have a chest count, but they did, we would link 

you to that and you would receive -- that would be 

part of that co-exposure model. SC&A excluded this 

particular column or cell in the data, and that's how 

they get their 36 percent, which is the 13 plus the 20 

gets their 36 percent. The 13 percent comes from the 

urinalysis data that was included.

NIOSH includes the in vivo chest count data. So, 13 

percent plus the 23 percent gives us 36 percent. We 

include the 36 plus the 20, gives us 56 percent 

effective monitoring. SC&A basically excludes this 

and they turn around and say 20 percent from the 

bioassay plus 13 from urinalysis only comes to 33. I 

think it's just a minor point, but it's a point to 

understand, when we start seeing all of these 

percentages flying around, where and how they were 

derived. And I think that here it's just the difference 

of application and what we feel is applicable and what 

they felt was not.

Member Beach: So, John, this is Josie.

Dr. Cardarelli: Yep?

Member Beach: So, NIOSH is concluding that 56 

percent, regardless of the 23 percent for the chest 

count, that's adequate for the modeling?

Dr. Cardarelli: I can't say -- well, I don't want to 

speak to what's adequate. I'm giving you what the 

data presents at this point. I think we can have a 

discussion on that.

Member Beach: Okay.

Dr. Taulbee: This is Tim.

It is our interpretation of that, and this is why, Josie. 
74

Remember, this is purely subcontractor construction 

trades workers. We combined subcontractor 

construction trades workers with prime construction 

trades workers into a single co-exposure model. The 

combination of the two we believe would result in a 

bounding co-exposure model. This is just the 

subcontractor construction trades workers. Okay?

Member Beach: Okay, and correct me if I'm wrong, 

but didn't the construction contractor workers 

typically do dirtier jobs? So, combining the two, 

you're still not getting, to me, a good balance of what 

the two different subcontractors did.

Dr. Taulbee: No, I disagree with that statement of 

the subcontractors only did the dirtier jobs. And we'll

talk more about that, actually, when we get into the 

stratification discussion on Friday. We'll get into 

comparing the DuPont construction versus the 

subcontractor construction trades directly. And I 

think that will become more clear. So, I don't agree 

with that statement just now and hope we could 

present that, then, on Friday.

Chair Clawson: So, Tim, this is Brad.

So, what you're telling me is that they did not bring 

subcontractors in there, turn them and burn them, 

correct?

Dr. Taulbee: That's not what I'm saying, either, Brad. 

I'm saying there are times --

Chair Clawson: When we get into this, I want to make 

sure you understand we want to see proof of what 

you're saying, not assumptions, because we know it 

just as well as anybody because we still do it today. 

That's what we use subcontractors for. We can't risk 

our people taking the doses. But we see it on a daily 

basis. So, just make sure when you get into this, I 

want to see some actual proof on this.

Go ahead.

Dr. Taulbee: I plan to show you some data on Friday 
75

with regards to that. Thank you.

Dr. Cardarelli: So, the NIOSH response to the SC&A 

findings, which was presented earlier, some were 

routinely monitored for americium. I won't go 

through and re-read this whole slide to you because 

I think we've already talked about that and I'll save 

us some time. But a key point was why those 

numbers were derived the way they were.

So, Finding 8: many of the workers, around 70-73 

percent, who should have been monitored for fission 

products underwent appropriate internal sampling 

the two periods evaluated prior to 1990. However, 

very few of these monitored workers underwent in 

vivo counting for fission products. Thus, they were 

not included in the coworker model developed for 

SRS and are not considered representative of the 

unmonitored worker.

So, NIOSH, we believe that there are sufficient data 

to reconstruct fission product doses for unmonitored 

subcontractor trade workers. The actual fission 

product urinalysis results reported for individual 

subcontractor trades will be used to reconstruct 

fission product doses.

So, the co-exposure models are stratified to the 

construction trade workers, which is the prime plus 

the subcontractors, combining them all into one. This 

is not a separate; this is total combined. So, the 

prime contractors were routinely monitored during 

the entire period while the subs were monitored by 

special urinalysis up to 1982. And, of course, by 

1976, the whole body counts replaced the fission 

product urinalysis to detect fission product intakes.

So, our co-exposure model may use all applicable 

bioassay data, including results from specials and 

routine bioassay samples if needed. So, the model is 

valid for subs, as the data for all construction trade 

workers are sufficient for dose reconstruction 

purposes.

What does this really mean in this particular table 
76

here? We have from 1972 to '73 and the year all the 

way to 1990. You can see the number of 

subcontractor construction trade workers is very 

minimal in terms of having whole body counts up 

until about '83. Most of it was done by the primes.

Now why are these numbers so low? Because during 

that time period, if we remember back on slide I think 

14, very few, very few subcontractor construction 

trade workers were actually onsite. They used 

predominantly DuPont construction trade workers. 

And that's reflected certainly here, and then we've 

got our total.

So, although the subs are underrepresented in the 

fission product co-exposure model until '83, we 

believe the model is still valid for the subcontractor 

construction trades because the data included for the 

prime are sufficient to reconstruct doses.

Dr. Taulbee: I would --

Dr. Cardarelli: Go ahead.

Dr. Taulbee: I would also like to interject on that. Go 

back to that slide, please, John.

If you look, there's an inverse in the late 1980s where 

the subcontractor construction trades represent a 

larger portion of the co-exposure model than the 

DuPont construction trades workers in that time 

period. So, it's working both ways within the 

combined co-exposure model.

Dr. Cardarelli: That's a good point.

Dr. Taulbee: Thanks, John.

Dr. Cardarelli: Yep.

This is just an example of the TWOPOS models that 

are associated with the co-exposure model. And on 

the left is the model for the non-construction trade 

workers, and the one on the right is the model for the 

construction trade workers, which also includes the 

subs.
77

There's a lot of similarities between these two, and 

one thing that might even be interesting and worth 

noting is that the trend, and almost the annual basis, 

almost supports not doing any stratification at all 

because these are nearly identical with regard to 

their patterns of exposure.

So, is it really necessary to even split between 

construction trade workers and subs or non? That 

could have been used in the argument. But, if we're 

going to split them out by construction trade and non, 

that's fine.

What we've done here is, when you start splitting out 

-- and I think that this was acknowledged in the last 

presentation; this is why we can't do further splitting 

by trade -- the numbers and the statistics begin to 

be the biggest limitation, which leads to great 

uncertainties. So, the larger your cohort population 

that you're trying to model, certainly the better 

statistics are, and that's what you're starting to see 

here. When we separate these out, we're missing 

some years and we had to combine years to get the 

statistics there.

So, Finding 9: SC&A does not find the data collected 

as part of the RPRT-0092 review to support the 

premise that subcontractors on job plans that should 

have been required internal monitoring for americium 

were either directly monitored, around 20 percent, or 

alternatively, appropriately representative in the 

derived worker models for SRS, around 13 percent.

I think this goes right back to this particular slide that 

I showed you earlier. It's just understanding where 

the numbers came from. Again, we respectfully 

disagree with SC&A. The effective monitored 

calculation is the total of the directly monitored, 20 

percent, and the indirectly monitored, 36 percent, 

which gives us our 56.

Again, we reaffirm our position that subcontractor 

construction trade workers performed work and were 

monitored similarly to prime construction trade 

workers. Therefore, the development of the co-
78

exposure model can be used to estimate 

unmonitored subcontractor construction trade 

worker doses. And it was that 20 plus this 36 that 

gives us our 56 percent.

So, moving on to the next slide, Finding 10: data for 

1990 are lacking. Therefore, 1990 should be included 

with the period of limited data and not bundled with 

the year of 1991.

What we see here is NOCTS data indicates that 89 

percent, right here -- by the way, I'm assuming you 

can see my little arrow. Okay? The 89 percent of the 

subcontractor claimants working in 1990 have in 

vitro or in vivo monitoring. So, we believe that that 

88 percent direct monitoring for subs across those 

various radionuclides -- plutonium, strontium, 

uranium, americium, and neptunium -- is not 

demonstrably incomplete. These data can be 

categorized in the 1990-to-1998 timeframe.

Finding 11: for both '72 and '89 and 1990-to-1998 

periods, when considering all radionuclides requiring 

internal monitoring per work permit, as opposed to 

at least one radionuclide requiring monitoring, the 

percentage of monitoring workers dropped 

significantly. Directly monitored workers ranged from 

44 to -- 47 percent to 77 percent in comparison to 

the 76 to 96 percent in the RPRT-0092, and 

effectively monitored workers ranged from 55 

percent to 89 percent in comparison to 85 to 99 

percent in RPRT-0092.

I think Bob did a really good job of kind of describing 

why this occurs, and it just comes down to the 

decision that we made that we looked at the sampling 

plan and considered that, if you had one bioassay, 

then that was sufficient to make the connection.

So, a worker can leave a bioassay based on either 

the routine schedule or the job-specific requirement. 

They would say, if the job-specific requirement said 

uranium and plutonium, and you only left a uranium, 

if they're on a routine plutonium program, they're 

going to leave a plutonium measurement and that's 
79

going to be adequate, even for that job-specific plan. 

That's the physics behind why we would make that 

assumption, and why we also stand by the results 

given for effectively monitored workers. There is 

sufficient data to reconstruct doses using a coexposure model based upon this approach.

Observation 1 I think is the only one that was not 

recommended right now, 1 and 5, by SC&A for 

closing out. So, I'll go over this. The back application 

of assumptions regarding work permits, job-specific 

bioassays, and target radionuclides to conduct a 

completeness review is not plausible, given the 

significant changes in radiological policies, 

procedures, and practices that occurred in the early 

1990s.

As we've said, we do not assume the monitoring 

practices in the '90s regarding the work permits, jobspecific bioassays, and target radionuclides was 

applicable to the 1972-1989 timeframe for 

completeness. Radiological practices were done 

consistent with Department of Energy orders in place 

at the time. So, applying what was done in 

Westinghouse back in the '70s would, frankly, be 

inappropriate when you look at how the routine 

bioassay monitoring requirements were done.

And I've listed two here: DOE 5480.1. They 

monitored workers primarily if they exceeded 10 

percent of the quarterly dose limit for external and 

internal, and that changed to an annual effective 

dose of 100 millirem in the 1989 -to-'90 period with 

DOE 5480.11. And prior to that, it was based on the 

maximum permissible body burden.

Despite all of the criteria of when to do monitoring, 

they always had a zero exposure policy which said no 

workers will be exposed and we will back that up by 

doing routine monitoring. So, the expectation was 

zero. That's the assumed result, unless there's an 

incident. Then, there's special. That would result in 

the dose where we would then begin to apply these 

DOE orders. And that's kind of the big picture on that 
80

Observation 1.

For the sake of time -- and, Tim, I'll let you chime in 

if this is okay -- I'm going to make a suggestion that, 

since SC&A has made the recommendation to close 

Observations 2, 3, and 4, I'll save us the time of 

going through that explanation. So, if no one objects 

to that, I'll move forward and go straight to 

Observation 5.

Dr. Taulbee: This is really a question for Brad, as the 

Chair, as to whether he accepts SC&A's 

recommendation to close those or not, Brad and the 

Workgroup. That's not our call.

Dr. Cardarelli: Yes. Brad?

Chair Clawson: I guess I'll just take comments from 

the other people in the Workgroup. I have no 

problem with closing those. SC&A has already -- our 

contractors said that they could go ahead and close 

it.

So, Phil? And Lockey?

Member Lockey: Brad, I agree with that. Jim Lockey.

Chair Clawson: Okay. We'll go ahead and move on 

then.

Dr. Cardarelli: Okay. The last one I think was 

Observation 5. Bioassay data in the '90s are not 

entirely free of the earlier data issues. The

implementation of methods used to correct for the 

bioassay deficiencies seen in the '70s and '80s did not 

take place immediately, and that's true with the 

change in the contracting company in 1990. It was 

not a step function that took place in '90. Instead, it 

took a number of years to identify, address, and 

effectively implement the changes. For example, 

there was only one RWP for one subcontractor 

construction trade worker listed for 1990 in RPRT0092, and specific radionuclides were not required on 

the RWPs until the mid-1990s.
81

We certainly acknowledge that it took time for 

Westinghouse to fully implement their radiation 

control procedures. While several deficiencies were 

identified by self-assessment and the auditing during 

this era, NIOSH believes that none of these are 

consequential to the operation of the routine 

bioassay program or ability to reconstruct doses with 

sufficient accuracy for compensation purposes.

Then, I have a statement in here from the 1990 Tiger 

Team report where SRS basically responds to DOE. 

And I'll just paraphrase this one sentence that says: 

to conclude that a sound technical basis for the 

existing program does not exist is somewhat 

excessive.

And they were basically challenging that the entire 

program itself was inadequate, and SRS challenged 

that through their documentation. So, we do believe 

that the data can be used for doing dose 

reconstruction purposes.

And that concludes my presentation.

c. Work Group Discussion

Dr. Roberts: Okay. Are there any questions or 

comments?

Member Ziemer: This is Ziemer. I have a question, I 

think probably best to either Joe Fitzgerald or Ron 

Buchanan.

It relates to the 11,000-plus bioassays which appear 

to be mainly from areas other than 773-A. What is 

SC&A's view on the ability to use those bioassays as 

part of a co-exposure model?

Mr. Fitzgerald: Well, let me answer. Certainly that 

data was always out there and it's now being coded. 

But when this was originally started, going back to 

the RPRT-0092 sampling plan, the whole approach 

was looking at completeness.

The issue is not the total amount of data. It's the 
82

question that was raised in 1996 and '97 that 

evidence showed that a large amount -- 79 percent 

was defining in '97 of the job -- the RWP-indicated 

job-specific bioassays were missing. And as you 

recall, that was the impetus to say there's got to be 

a way to look at whether or not that circumstance 

predated '96-97, and if it typified job-specific 

bioassaying of subcontractors in previous years, that 

would cause them to be underrepresented in a 

coworker or co-exposure model.

So, it's not a question of the total amount of data 

available. I mean, certainly, if you combine all of the 

special bioassays, the incident-based bioassays that 

you could find for subcontractors, if you added that 

to all the hundreds, if not thousands, of routine 

bioassays that would be available, and also added in, 

obviously, whatever job-specific bioassays there 

might be -- in other words, the total universe of 

bioassays for subcontractors -- it would be a large 

number, but it wouldn't answer the basic question 

that was the reason that 0092 was written and the 

reason we got into this, which was, how 

representative is the subcontractors on job-specific 

bioassays? Given the fact that so many of the 

bioassays were missing in '97, what confidence level 

do we have that that's not the case in previous years? 

That was the basis for the design and the objectives 

of RPRT-0092.

And now, what we're talking about is reaching out 

and gathering all this additional data. Well, we could 

have done that three years ago. I mean, certainly, 

you could gather a lot of data, not just routines, 

specials, incident-based, and you would have a lot of 

data that would speak to subcontractor exposure. But 

how complete is that in the context of job-specific 

bioassays required by RWPs? That was the going-in 

proposition.

And this is, to me, plan B, which I think John 

mentioned. If you could not answer the question that 

0092 was intended, then a different approach may be 

needed. Certainly, that would be the different 
83

approach, but as far as the objectives that we 

originally got into this in 2017, reaching out and 

gathering all this data in terms of the sheer number 

of data, that's what we're talking about. We have all 

this data, hundreds, if not thousands, 11,000 data 

points, but what does that actually say about the 

completeness of the job-specific bioassays paralleling 

the 1997 question? That's, to me, what's relevant.

Dr. Taulbee: This is Tim. If I could address that a little 

bit and help, hopefully, Paul, answer your question, 

at least from our perspective.

The 1997 bioassay issue that Joe keeps bringing up 

was job-specific bioassay, and that was for people 

who were not necessarily on the routine bioassay for 

that radionuclide when they did that job. And so, it 

comprised a small proportion, and we've shown a 

graph of that. And I think John will be showing that 

later at some point; I'm not sure.

But it's 95 percent of the people were monitored 

through the routine program, and subcontractors 

included in that. And I think RPRT-0092 clearly 

defined -- clearly -- from 1991 for sure through 1997, 

that the subcontractor construction trades workers 

were adequately monitored, or monitored -- I 

shouldn't say adequately -- monitored to the point 

where a co-exposure model would clearly cover their 

exposures.

We went through and we looked at the RWPs in that 

area and we looked at whether those workers were 

monitored on a routine or job-specific. They're still a 

subcontractor. Okay? If they were on a routine 

program, they were monitored; we have their data, 

and we could make a co-exposure model from that.

So, in that time period, I think RPRT-0092 clearly met 

the objectives. Where we didn't meet all of those 

objectives, as SC&A has been pointing out, is that 

1972 to 1990, because we didn't have a large 

sampling of RWPs available for multiple areas. From 

the areas that we did see, and doing the comparison, 

we did not see any discrepancy, any difference. Less 
84

workers were monitored, sure -- that's in the DuPont 

era -- but we're still seeing the same thing of workers 

who were subcontractors were not excluded. They 

were on the routine program, or if there was an 

incident, they were on the special program. And so, 

the co-exposure model would still apply over that 

time period.

I hope that helps.

Member Ziemer: That's helpful to me. I wanted to get 

both views on how you addressed that group of 

bioassay. The large number, as Joe said, and how do 

you address the adequacy of their use? Yeah, thank 

you.

Dr. Taulbee: Are there other questions?

Chair Clawson: So, Tim, you were saying, from '90 to 

'97. What about '72 to '90?

Dr. Taulbee: '70 to 1990, we see we only have data 

from one area to do that RWP job plan comparison. 

Okay. We don't have the job plans from other areas. 

They were using a different method. They were using 

the DPSOLs. And we could not meet that objective in 

RPRT-0092.

But that doesn't mean that those workers weren't 

monitored. They clearly were. And when you look at 

the slide that John's got up right now, slide 15 there, 

you can see from the plutonium bioassay logbooks, 

you know, it ranges here from 56 that appear in 1978 

to 1800 in 1988 workers being monitored, 

subcontractor construction trades workers being 

monitored. Okay. So, this is just the subs. This isn't 

combining all construction trades. This isn't 

combining prime and subcontractors. This is just the 

subcontractors. Okay? And so, there is a lot of 

monitoring amongst these workers.

Mr. Fitzgerald: Yes, and if I can add, there was a lot 

of monitoring of subcontractors in 1997. So, the 

question is not whether subcontractors had a high 

degree of monitoring. The question is whether those 
85

who were on job-specific bioassays actually got 

them.

I have to keep going back to that because three years

ago that was, again, the impetus to look backwards 

and actually come up with a sampling mechanism 

that would look at permits, look at job plans, and 

actually demonstrate that you had follow up and a 

percentage completeness on these bioassays.

Dr. Taulbee: I think if you look at the 1990 data, 

1991 through 1996, you will see that we've 

demonstrated that, that those workers were 

followed; the subcontractors were, in fact, 

monitored.

Mr. Fitzgerald: Yes, and I think we acknowledged 

that, in fact, starting in the early 1990s with the 

Radiological Improvement Program Westinghouse 

put in place and the accountable procedures, and an 

actual RWP program that did not exist before '91 at 

Savannah River, things got better, and it enabled the 

analysis that 0092 was intended to do in terms of 

matching up job-specific bioassays to actual RWPs, 

so that -- and we do say this -- that it certainly makes 

it feasible to do the kind of completeness analysis 

that was intended in the beginning.

The only question we had is, you know, there's a step 

function somewhere in there, '90, '91, '92, where the 

RWPs are sufficient and the job-specific bioassays are 

complete. So, we're not disagreeing in substance; 

we're basically trying to clarify timeframe in that 

case.

I don't think we believe that's the case before 1990. 

And again, it's not any fault of the intended -- the 

objectives of 0092. It's just that the records, the 852 

boxes, didn't produce the job plans and SWPs and 

RWPs, on one hand, which is the scoping issue of 

facilities. And it just turned out that, in terms of 

checkoffs on forms and actual follow up, that one 

could actually have taken this from the job plan, you 

know, it was supposed to be a direct measure of 

RWP-to-bioassay relationship that's right from the 
86

sampling plan. That couldn't be ascertained just 

because, again, it was clear that that linkage did not 

exist, at least in the DuPont era.

So, if you're talking about trying to, as IG-006, the 

guidelines say, you're to determine if there are 

sufficient measurements. That's the key, sufficient 

measurements for this particular category, the 

subcontractors on job-specific bioassays. For '72 to 

'90, I think RPRT-0092 falls short from that 

timeframe, and for the reasons we just discussed.

There may be additional data that one can code. 

There may be more data in NOCTS, et cetera, et 

cetera, but those are sources that could have been 

available before. I mean, that's not pertinent to 

0092, what was trying to be accomplished in 0092. 

It's a plan B, if you may, for adding additional data 

and considering a different way to do it.

But, for 0092, again, I think there isn't a measure, as 

required by the Implementation Guide, as to whether 

there were sufficient measurements for those subs, 

not all subs, just the subs that were, again, on job 

plans and SWPs in that timeframe.

Dr. Taulbee: Again, I would point you back to -- you 

know, I agree that we did not meet all the objectives 

in that early time period in 0092. We could not look 

at more areas other than area A. But, in area A, we 

did not see any significant difference there. We did 

not see that, oh, my gosh, you know, the 

subcontractors weren't monitored or were only, you 

know -- what was it? -- 10 percent were monitored. 

That's not the case, especially for plutonium in that 

time period. Americium there is a decrease, but for 

the plutonium in that area we've got a large number 

of the job plans indicating that they were monitored.

So, yes, it's only one area and we didn't meet all of 

the other areas, but we have no evidence to the 

contrary that, if those records were available, that it 

wouldn't be, that we wouldn't be able to fill in that 

whole time period. We can't do that; I recognize that.
87

Chair Clawson: Tim, this is Brad.

How can you say that when you've only got the 

information for one area? You're saying, well, this 

one area did it, so all the others must have, too. 

Show me the scientific proof of that.

Dr. Taulbee: Well, if you look at slide 16 that John's 

got up there, Brad, in A area where we were able to 

compare, there's only 438 plutonium bioassays. And 

we were showing a high correlation between the job 

plans and those workers being monitored.

Look at F area and look at H area and the Central 

Shops area. They have way more in that time period. 

So, I mean, this is the bulk of the plutonium 

monitoring data, is in the areas where you would 

expect plutonium.

Mr. Fitzgerald: I guess for the Workgroup's benefit, 

I'd take you back to early 2018. The charge, I think, 

that the full Board gave NIOSH, based on the 

discussions that took place in the Workgroup in 2017 

and beyond, was that the original review -- and there 

was an original review; I think it was 0083, if I'm not 

mistaken, maybe it was a different number -- but 

that Tim and his team did at 773-A wasn't enough to 

answer the question about sufficiency of data, the 

completeness of the data.

And Jim Neton -- not Jim Neton -- Jim Melius himself 

specifically brought up two points: that it had to be 

more than one facility and it had to be more than 

1981 to 1986 to properly address that question. So, 

that was the charge to do RPRT-0092 and to address 

more than just 773-A.

So, yes, certainly some observations, additional 

observations, have been made about 773-A, but the 

reality is that 0092 did not accomplish the major 

objective that the Board gave it, which was to be able 

to address what the representativeness of that 

question would be for other facilities and other 

timeframes.
88

And I think it's minimizing the implication of just 

having one data point in order to answer the question 

of whether or not subcontractor completeness is 

sufficient to be represented in the co-exposure 

model. That's been our finding all along since this 

came out.

Now, you know, we appreciate and accept the reason 

that occurred. I mean, it just so happened that -- and 

we had thought the 852 boxes held a lot of promise 

to deliver enough records to do the assessment in 

that early timeframe. It did not. So, there's no way 

to really answer that question of the objectives posed 

in 0092 adequately, given that circumstance. It does 

help a great deal for after '90, and I agree with Tim 

on that.

So, that's where we are. I mean, after three years, 

that's where we are.

Dr. Cardarelli: Joe, I just wanted to add I'm glad that 

you acknowledged the fact that, if the data just isn't 

there, the records aren't there, and we can't achieve 

that objective, that doesn't mean that we failed in 

that objective. It just means that the data wasn't 

there to support doing what we were originally 

charged. And I think that's a good point.

One of the reasons I put this particular example in 

was to demonstrate that I could not find any 

examples where there were subcontractor 

construction trade workers who were involved or left 

a routine that were left out or treated differently. And 

that's why I put this in there, because it was five 

different people, three different types of employers, 

and they were all treated exactly the same. And I 

think that that speaks to the culture and the 

monitoring practices and philosophy, and this is 

1972. I don't think that that would have changed.

We can go and maybe search other skin 

contamination logbooks to see other ones, but this 

was the one that we were able to find. And I would 

certainly be willing to look at any evidence that you 

could produce that says that they were treated 
89

differently. I think that would be --

Chair Clawson: Well, John, that's very good. Show 

me, maybe giving me 500 more examples of these 

that you just put this one up there for. You have not 

met the criteria that was set forth. Show us 

completeness. And this is what we've been trying to 

achieve.

And please forgive me if I seem a little bit frustrated, 

but this is 13 years now with Savannah River, three 

years with 0092. And we still are nowhere, in my 

feelings, any closer than we were.

Dr. Taulbee: One area where I would -- I understand 

your frustration, Brad. I clearly do. The one area 

where I feel we are a little closer on agreement is the 

1990-forward area. And that's where RPRT-0092 did 

meet the objectives in my opinion. We clearly 

demonstrated that the subcontractors were 

monitored and make up a large fraction of the 

monitoring of randomly pulled RWPs.

And we've demonstrated that they were monitored 

appropriately from those RWPs; that there is 

sufficient numbers that we can demonstrate or we 

can develop a co-exposure model, and that there's 

that issue from 1997; it does not back-extrapolate 

for the job -- the job-specific bioassay program was 

a small fraction of the overall bioassay program, as I 

demonstrated back in 2018.

That RPRT-0092 is done. So, I feel like we have 

demonstrated that aspect of it. Clearly, yes, you're 

right, Brad, we need to -- the pre-1990 time period, 

we did not meet the objective of demonstrating 

across all areas and all time periods because we just 

don't have that data. So, that aspect, you are right, 

we are not any closer than we were then. But I do 

feel the 1990-forward we've met the objective.

Chair Clawson: I agree that we've met quite a bit of 

it. I think we still have some work to do on it, though. 

Well, '97 really is interesting to me because, yes, 

they went and they pulled everybody; they got 
90

everything up to 100 percent. But 78 percent was 

missing in that. I think that we still have some things 

to do. But I'll tell you, from '72 to '90, I do not think 

that you have met it.

Member Lockey: Hey Brad, Jim Lockey. If I can, I'd 

like to ask a question. And this really follows up on 

your concern, Brad, about contractors being brought 

in to do job tasks that primes may not want --

Chair Clawson: Hey, Jim, can you talk up just a little 

bit? I'm sorry, I'm having a hard time hearing you.

Member Lockey: Can you hear me now?

Chair Clawson: A little bit better, yes. Speak up, use 

your big-boy voice.

Member Lockey: I'm doing the best I can now. Okay, 

so I want to follow up on that question that you had 

or the concern you had about subcontractors being 

brought in to handle jobs that don't want to be 

handled by, say, the prime contractors or by 

management on site. This goes both back to NIOSH 

and SC&A. 

If you went back and looked at the subcontractor 

bioassay data and you compare that to the prime 

bioassay data, both routine data but more 

importantly incident data, is there any qualitative or 

quantitative differences in that? For example, if I look 

at incidents data for the subcontractors and I 

compare that to incidents data for the contractors, is 

there a qualitative or a quantitative difference in that 

data?

Dr. Taulbee: We have not compared that, Dr. Lockey. 

That is something that could be done because we do 

have that data broken out from that standpoint. Well, 

we have the data available, I shouldn't say broken 

out because I'm not sure all the incident data's been 

coded.

But with regards to the routine monitoring, or the 

combined actually, routine and special monitoring 
91

between primes and subcontractors, that is some of 

the data that I'll be presenting on Friday during the 

stratification discussion, where we have compared I 

believe five years' worth of data of just the prime 

construction trades workers and the subcontractor 

construction trades workers broken out separately. 

So we do have some quantitative data for a 

comparison from that standpoint.

Member Lockey: Let me follow up on that question 

then. Would that be a way to have some reassurance 

one way or the other regarding Brad's concern, which 

is also my concern, seeing I've been involved with 

workplace situations that subcontractors sometimes 

are brought in to do jobs that nobody wants to do?

And if you found a significant qualitative or 

quantitative difference in the bioassay data, that 

would have some real, some significant implications 

for me, that the subcontractors in fact are different.

Dr. Taulbee: Correct, and we can, I will show that 

comparison. Just a little bit of a spoiler here. We do 

not see much difference between the 90 -- the 50th 

and 95th percentiles of those distributions, and I will 

show that.

Member Lockey: Is that routine or incident data?

Dr. Taulbee: It's the combination of the routine and 

incident data. Now, again, the incident data could be 

broken out, we could do that type of an analysis 

separately, if desired, from that standpoint.

Member Lockey: Would it be -- let me follow up. Joe, 

would that be interesting to you?

Mr. Fitzgerald: Well, it would be interesting, but let 

me throw a qualifier in. If, and we've gone through 

this with other sites, if you're missing 79% of your 

RWP permit-indicated bioassays, then, you know, 

whatever analysis you're doing on the information 

that you do have is not going to be complete.

So you know, the precedence of what we have been 
92

doing is to establish do we have a complete data set. 

And I'd be interested if in fact that it could be, you 

know, shown, you know. Then, you know, are the 

subs that are doing prime work versus the other 

subs, if it's comparable that, you know, that you're 

showing they're not doing the dirty work.

But you're missing up to 80% of the data to begin 

with from the RWPs, then what the heck are you 

actually comparing? You know, that's the problem I 

got. You got to at least show you got all 52 cards in 

the deck before you start comparing things. 

And I don't know if we've actually done that yet. 

Except I think we're closer on the 90s, as Tim has 

suggested. But, you know, again, I don't know how 

we can get to that answer without answering the first 

question on completeness.

Mr. Barton: And this is Bob Barton. Just to add onto 

what Joe said there, as far as qualitative, this whole 

notion that they brought in subcontractors to do the 

dirtier work, that comes from the interviews with 

former workers. In fact, that position actually 

appears in one of NIOSH's reports from back in 2017 

when we looked at stratification for the first time.

And Tim is correct that on Friday we'll be discussing 

whether, if it's deemed acceptable to use a coexposure model, whether we need to break out 

subcontractors from the regular construction trade 

contractors. So I don't want to get too far ahead on 

that. 

But again, the qualitative evidence was statements 

made by the actual workers, that they were brought 

in to do the dirtier jobs to save the exposures from 

the prime construction trade workers. So that's your 

qualitative evidence right there.

And just to comment on, there seems to be a lot of 

emphasis put on plutonium. I think for that earlier 

period, our main concerns were really about 

americium. In fact, when we look at the numbers in 

SC&A's review of '92, I'm looking at them right now, 
93

we were remarkably close on plutonium when we talk 

about this notion of effectively monitored, that is, 

how many were directly monitored or on the same 

job plant as someone who was monitored and had 

their co-exposure result. 

So I mean, for '72 to'74, SC&A came in at about 65%, 

NIOSH came in at about 69%. Whether 69% or 65% 

is acceptable, that's obviously a judgment call. In the 

80s it's much higher in that both SC&A and NIOSH 

came in at about 97%. Again, just for plutonium. But 

our main concerns really centered around americium.

Also there's a lot made of these, the incidents. And I 

would just point out that if there is an incident that, 

you know, requires significant intakes or uptakes or 

high bioassay results, often those workers were 

chelated. And we don't use those in co-exposure 

modeling. 

So I'm -- so those incident-related data is important 

in that it shows that there was follow up surveying, 

but it has nothing to do with co-exposure modeling if 

there was chelation involved, because all those 

samples are removed.

You know, a couple of other comments here. Let's 

see, I was just trying to jot down some stuff as John 

was going through his presentation. Like I said, we're 

basically in agreement on plutonium. Slide 15, a lot 

was made about slide 15 where it showed the number 

of workers, subcontractors, monitored by year. That 

was contained in the plutonium bioassay logbook.

Again, that's not the number of subcontractors that 

were potentially exposed, that's just the data we 

have for them. So, showing that there's a small 

number there in the 70s, and then it grows, that just 

indicates the numbers that were actually monitored. 

But the question we're trying to get at here is how 

complete are those job-specific bio assays, which 

really involve the more transient-type 

subcontractors, which according to former worker 

interviews, were brought in for the hot job. So they 
94

wouldn't be on a routine bioassay program, and if 

there was no incident identified, it's quite possible 

those intakes could be missed.

Also, it was indicated that, let's see, slide 32. This is, 

again, talking about the americium data. And it says 

1980-1989 as the period that was evaluated. That's, 

it's actually 1981-1987, because those are the only 

years where we had those job plans to be able to 

evaluate. 

And again, only for the F-Wing of 773-A, even though 

there was separated americium at at least one other 

location, and possibly a third that we point out in our 

most recent report. 

And NIOSH says that the americium data could be 

used in co-exposure analysis, and I'm a little -- that's 

certainly something that would bring up that number 

to the 56% quoted on this slide. I'm curious how that 

would work, how you would mix in vivo and in vitro 

data to come up with one coworker model.

But again, I mean, is 56% really a good number 

either? And that's obviously a judgment call and a 

policy decision for the Work Group and the Board as 

a whole. 

Dr. Taulbee: With regards -- go ahead, Brad, I'm 

sorry.

Member Schofield: Yeah, this is Phil, I've got a couple 

comments here. One, the statement about the 

subcontractors being brought in to the dirtier jobs, if 

you go back through I don't remember which 

document it is just for this meeting, it is written in 

one of those documents. And I just, right off the top 

of my head I can't remember which one it's in there.

The other thing is, I would find the subcontractors 

more than likely bounding for the prime contractors, 

just because they are doing these dirtier jobs. And 

based on some of the interviews, a lot of these 

contractors, you know, when they got done with the 

job, they were told to leave a urine sample. 
95

Well, they're not coming back. They were here for 

maybe three days, five days, and they leave without 

leaving a sample. So we're going to be missing a lot 

of data there too.

Chair Clawson: Thanks, Phil. You know, one of the 

things -- this is Brad speaking. One of the things that 

is really hard with this is we are -- we also have a lot 

of data being dumped on us. We're looking at the 

years from '72 all the way up into '97/'98. I kind of 

want to, and tell me if I'm being wrong or whatever, 

I want to just look, for this discussion, I want to look 

at just from '72 to '90. And in that area, I do not 

believe that we have met the criteria was set forth 

with this.

One of the things, if you start reading in the CATI 

reports and stuff like this, this is where most of this 

comes out. These guys were coming in, some were 

here for a week, two weeks, they were gone for 

months. Come back the next year, get burned out 

again, and they're gone and they're off on the road 

and stuff like that.

I don't think that we have achieved what we needed 

to do on this. And I -- you know, I'm just looking at 

this time period right now. I know that we go up into 

the '97 because this is also the thing that bothers me 

about it is when we get to the '97 time period, that 

we're missing 78%. And this is after Westinghouse 

has been in there for a few years. 

But I think that is a section for another day. I want 

us to really look at from '72 to'90, have we 

accomplished what we set out to do with '92. And my 

personal opinion is that we have not. We have not 

demonstrated that.

I know that when we go into '91 and everything else, 

there's going to be some other stuff. But I want all of 

us as a Work Group to be able to look at that right 

now and look at what there is. Because we're going 

to be in -- there's a lot data out there, I'm not saying 

that there isn't. But we have not met what the met 

what the criteria was set forth for us.
96

Dr. Cardarelli: Hey, Brad, this is John Cardarelli. With 

that period of '90 -- '72 to 1990, obviously we don't 

have the RWPs that were really implemented by 

Westinghouse. So to achieve kind of what you're 

looking for, we were looking at all other alternatives, 

and we have it take a different approach, which is 

what we've done. 

Is there another approach that you would like for us 

to do or see or look at that might be able to answer 

that, given the fact that they just operated differently 

and collected different types of data, which make it 

very difficult for us to link to answer the question that 

we thought we could answer when we first started 

this, not knowing that we would not have that critical 

data for the pre-'90 area. What other options would 

-- could we look at?

Chair Clawson: The SECs, just like what the program 

was set up for. When you have insufficient data and 

you'll not be able to do completeness of data, you do 

an SEC.

Dr. Cardarelli: I would argue maybe -- I think that 

we would argue that there's reasonable 

completeness of data. We think we can do dose 

reconstructions using the co-exposure data that we 

have in place. So setting a standard based upon the 

Westinghouse and applying it to the DuPont and then 

say you don't need what Westinghouse did, so 

therefore SEC is kind of illogical, we need the data. 

You know, if we didn't have any data, I would be 

100% behind you. But right now we've got a plethora 

of data, you've said that. And I'm just trying to figure 

out a way to show completeness to meet your 

satisfaction.

Chair Clawson: We don't have the time anymore, 

John.

Dr. Cardarelli: Okay.

Chair Clawson: Thirteen years, 13 years. Do you 

know that the original people that filed this are all 
97

dead? Do you know what it's like for me to have to 

answer to these people's families that, yeah, Mike, 

he died five years ago, two years ago, and we still 

have not solved this. 

I understand about the data, and we get into this all 

the time. We can look at Fernald, we can look at all 

of these. And we have a lot of data out there, but we 

couldn't meet what the criteria set forth for us. 

And as a Work Group, this is where it comes down to 

us. I am not saying in any way, shape, or form that 

you guys have not done a great job. But if the data 

is not there, if there information is not there, it's not 

there.

I've -- Tim and Joe can both testify to this. I don't 

know how many trips I've made to Savannah River 

down there. We've been through this whole thing, 

and one of the biggest things, and the people have 

told us this from the very day one, well, it's going to 

be hard for you to get the information because I 

never left anything there. I was a transient worker, I 

went there, I'm gone, I'm this, I'm that. It just isn't 

there.

I understand that there's a lot of number-swapping 

and everything else that we can come down to, but 

we've also got to come down to accountability for 

this. And I really think, and I'm going to throw this 

out to the Work Group right now, I think that we have 

an SEC here from '72 to '90. Now, I'm not saying for 

the primes or anything else like that. I am saying just 

for the subcontractor workers.

Dr. Taulbee: Brad.

Chair Clawson: This -- yeah?

Dr. Taulbee: I would -- I guess one of the things that 

we haven't discussed as a Work Group or you haven't 

addressed or discussed is if you look at RPRT-0094 

that we put out back just before the last, before the 

December Work Group meeting last year, we really 

haven't discussed that. 
98

And this is what's causing me some concern here, is 

that we have monitoring data for a large fraction of 

subcontractor construction trades workers that are 

claimants. And these are people who have filed 

claims, and it's well above what the monitoring -- the 

percentage of people being monitored is in the 80s, 

80 percentiles, as I recall, for the 1980s for sure. And 

--

Chair Clawson: You mean in the NOCTS system.

Dr. Taulbee: These are in the NOCTS system. These 

are subcontractors in NOCTS. So these are people 

who filed claims. And so we have a high percentage 

of them being monitored over time, and we've 

documented that in RPRT-0094. And I'd really 

encourage the Work Group Members to review that. 

And I don't know that SC&A has reviewed it and made 

comments on it, I really can't remember. Bob, do you 

-- Bob, Joe, do you remember if you've reviewed that 

report and made comments on it?

Mr. Barton: I believe we were just tasked with that a 

few weeks ago, to take a look at that. But again, I 

mean, that's looking at the totality. And I think one 

thing that sort of got glossed over in this whole 

discussion is the statement of whatever percentage 

it is that the workers were monitored. 

But monitored for what? Were they monitored for the 

correct radionuclide based on what job-specific 

things they were doing? I think a blanket statement 

of saying, well, they were monitored for something 

loses the connection between the work they were 

actually doing and whether they should have been 

submitting those job-specific bioassays. 

And that's the whole question here. It's not the 

totality of data that we have, it's whether there's a 

group out there, mainly the workers who should have 

been monitored via some sort of job-specific 

mechanism, and whether -- what we can look at, 

which is very limited in my opinion, prior to 1991. I'm 

not sure that's borne out, that there was a 
99

relationship between what should have happened 

and what did happen.

John mentioned that, you know, we can't hold the 

DuPont era to the same standard as Westinghouse, 

and that's entirely a fair comment. But the question 

is is did the monitoring process that was in place 

adequately capture the potential for intake to some 

of these transient subcontractors that should have 

been monitored via job-specific, and were they or 

were they not? 

And the data is severely limited, and what we see, 

particularly with americium, is concerning from 

SC&A's viewpoint.

Member Schofield: This is Phil again, I'd like to make 

a comment on that. We have given SECs to different 

facilities based on the fact that maybe they were only 

-- we were only seeing monitoring for uranium or 

plutonium, you know, fission products, americium, 

strontium, whatever else it might have been, they 

weren't being monitored for. 

And on that basis, we have actually granted SECs. 

And since a lot of these subcontract people, some of 

them came back and forth with several different 

contractors. It just depended on who they were with 

that week or month. And we know we can't even, I 

mean, it's been stated we have not been able to 

identify all the subcontractors who have ever come 

in and out of Savannah River. That's all I got to say.

Mr. Fitzgerald: If I could ask -- can I ask a question 

of Tim, just from what he was saying about the '94?

Chair Clawson: Sure.

Mr. Fitzgerald: Yeah, this is interesting to me because 

this goes back discussions that you and I and the 

Work Group had back in 2017. 

Because after we got some interviews from Savannah 

River that alluded to the subcontractor records being 

kept in a separate file and the original completeness 
100

question started coming into place, you know, where 

were those records, were they complete, whatever, I 

remember you had examined a couple different 

courses of action before you arrived at the, you know, 

the 773-A review and the RPRT-0092 review.

And you looked at the Center to Protect Workers' 

Rights, that database, to see if you could do a 

completeness review of that. You also looked at 

NOCTS, you looked at NOCTS back there. And in both 

cases you decided that neither data source was 

adequate to answer the question on completeness.

I guess I'd be curious, what's happened with the 

NOCTS database as reflected in '94 that's different 

than what it was a few years ago? Because clearly 

you believe there's data that you can use in '94, and 

you pretty much discarded that option three years 

ago.

Dr. Taulbee: I wouldn't say I completely discarded it 

three years ago. I felt at that time that doing this 

direct comparison with RWPs would be a better 

source to directly answer the question. So --

Mr. Fitzgerald: Okay.

Dr. Taulbee: That's my interpretation of that.

Mr. Fitzgerald: Okay, like I said, I remember NOCTS 

coming up back then, but it wasn't selected as the 

way to go, so thank you.

Dr. Taulbee: And what '94 gives -- or, and I 

understand what Bob is saying about, because we did 

categorize it by actinides or tritium and whole-body 

count, that type of thing. So it is more general than 

perhaps what the Work Group is looking for here.

But one of the things that comes out from RPRT-0094 

is just the large number of current claimants that 

have personal monitoring data. And so if only a small 

fraction of them who worked on these RWPs were 

monitored, then that would bear out from the 

subcontractor's standpoint, and it doesn't, in my 
101

opinion, okay. 

There is a large fraction of them that have plutonium 

bioassay year after year after year. And americium I 

can't speak to directly, Bob, I don't recall if we ever 

looked at that, broke that out separately or not, along 

those lines. So I mean, that is another potential 

approach, but I understand, you know, what Brad is 

saying of, you know, we have been working on this a 

long time.

But I do think the RPRT-0094 should be considered 

by the Work Group as a whole, at least discussed 

potentially as an avenue, or you know, maybe it 

doesn't meet your needs from this standpoint. But I 

don't believe that is something that we have 

addressed.

With regards to what Bob has been saying about 

americium is where we seem to be having the 

disagreements with regards, or that's where you're 

finding a potential issue. That's the next topic on our 

discussion here today. 

And so I would actually ask that we go through that. 

We've got a couple of presentations with regards to 

that, and I believe it feeds into this discussion for 

RPRT-0092, but that's just my suggestion to you, 

Brad.

Chair Clawson: Well, that's fine. We want to make 

sure that we get the best data for all of this and the 

best information and everything else like that. But 

you remember what I told you almost two and a half 

years ago, this is -- we're done, we're it. So one of 

the things I'd say is let's go ahead, launch into the 

americium and let's -- if I didn't see that on our 

agenda, so I was wondering --

Mr. Fitzgerald: Brad?

Chair Clawson: Yeah?

Mr. Fitzgerald: Yeah, they're related because it 

involves americium and there's some overlap. But I 
102

don't think the 0091, RPRT-0091 discussion is going 

to solve the 0092 issue that we're talking about with 

the americium. It's a question of enrollments versus 

completeness. 

And I don't think we have tied up 0092. I think it 

sounds like there's some kind of coalescing around 

the fact that '72 to '90 didn't meet the objectives of 

RPRT-0092. And, but I'm not sure we have closed out 

the implications of that. You know, where's that leave 

us. 

All I've heard is that, well, you know, there's a 

certainly a, you know, a rework on the NOCTS, and 

that's in '94. And there's an acknowledgment that 

the, a lot of the ample data that NIOSH has cited 

would not necessarily answer the specific questions 

that we want answered. But you know, we've been 

at it for three years. 

So I guess the question is, you know, 0094, I mean, 

RPRT-0092 was the culmination of that, all that effort 

to look at the completeness. And you know, I know 

Tim's team, John's team, and our team has put a lot 

of work into this. 

And I guess the question is, you know, where's the 

Work Group see this as far as a conclusion. Is there 

any other issues or questions we can give you, any 

information that would enable you to reach a 

conclusion?

Mr. Mahathy: This is Mike Mahathy, if I could add one 

detail about 0094 is that we plot -- we chart it out by 

month. And you can go in and see how a large 

majority of these subs were not there for a day or 

two, they were at SRS for weeks, months, some of 

them for years. So we found that very few of these 

workers actually went in and were there two or three 

days and gone.

Chair Clawson: Mike, can you separate from the 

subcontractor to the prime contractors? Can you 

separate all of those out?
103

Mr. Mahathy: These were --

Participant: Yes, we can.

Mr. Mahathy: Ninety-four only is only subcontractors, 

not prime contractors.

Chair Clawson: Right.

Mr. Mahathy: It's a higher level, it doesn't go down 

by radionuclide. 

Chair Clawson: Right. 

Mr. Mahathy: But it does show they were consistently 

monitored over the period of years for most years. I 

just wanted to add that one little detail.

Chair Clawson: Well, and all that comes back to were 

they monitored for the right details too. That's what 

this whole thing was supposed to come back to. And 

this is why -- this is why we set up the sampling plan 

the way that we did. What were we going to need to 

be able to accomplish completeness for this.

And I will be right honest, and I've already made 

myself clear, I do not think that we've met it. I guess 

I'll throw this out to the other Work Group Members 

that are with us here. Are there anything else that 

you guys need? Because right now, I'm pressing for 

an SEC from '72 to '90 for the subcontractors, not for 

the prime, for the subcontractors. Because this where 

we're at on it. And --

Member Ziemer: Brad, this is --

Chair Clawson: Go ahead, Ziemer.

Member Ziemer: Brad, I'm not actually on the 

Savannah River Workgroup, so. But the SEC 

Workgroup is sort of looking at whether we meet SEC 

requirements. 

But one of the questions I had, and maybe Tim can 

answer this, has the DCAS staff ever gone back and 

looked at the claims that have already occurred, 
104

particularly for that period up to 1990, to determine 

to what extent have we had claims where you found 

that you didn't have bioassay data or it was not for 

the right thing? 

Do you know what the history of it is? That might tell 

us the extent to which we don't have enough 

representative data.

Dr. Taulbee: Yes.

Member Ziemer: I know we're looking for a coworker 

model possibly, but we've had an awful lot of claims 

that have been handled already based on individual 

information.

Dr. Taulbee: That's correct, Dr. Ziemer. We have a 

lot of bioassay data for the individual subcontractor 

construction trades worker claims that have enabled 

us to complete those reconstructions for those 

workers.

With regards to what they were monitored for and, 

you know, whether they were adequately monitored 

from that standpoint, plutonium is obviously the 

clearest that we have the data for. When a worker is 

indicating that they were working in F area or H area 

and we have the plutonium monitoring for the 

subcontractors construction trades worker, we can 

estimate the dose there.

What RPRT-0094 does is it looks at it from a global 

standpoint if we'd looked at all actinide monitoring 

together, so that would be americium, plutonium --

americium, curium, californium, and plutonium type 

of bioassay. And what we have found is that the vast 

majority of the subcontractor construction trades 

workers, especially in the 19080s, have monitoring 

data.

They both have typically plutonium and fission 

product monitoring bioassay, which is the two 

dominant exposures at the Savannah River site. And 

so that's the bulk of the subcontractor monitoring 

data that we have within the claimant files. There are 
105

those who were monitored for americium, curium, 

californium. But it's not as prevalent, let's put it that 

way.

When we do dose reconstruction, the areas where 

americium would potentially become a potential issue 

is the 773-F, the 773-A area and the F-Wing, and the 

MPPF, the multipurpose processing facility. 

Everywhere else, the americium is tied to the 

plutonium, and we assign currently americium doses 

to these workers, to these subcontractor construction 

trades workers when we're doing dose 

reconstruction.

So those are currently being done. I hope I answered 

your question. If I missed something, please let me 

know and I'll try and fill that blank in.

Member Ziemer: No, I was trying to get a feel for the 

extent to which we could determine from claims that 

have already occurred the extent to which there are 

big chunks of missing data.

Dr. Taulbee: There's really not, to a large -- oh, I 

shouldn't. I can't -- that's something we could 

certainly look at. But I am afraid I could speak out of 

turn here. 

In my recollection of looking at a few in RPRT-0094 

going through is that there was routine monitoring 

almost on a per-year basis for plutonium, or you 

know, every three years at least, like on the bioassay 

frequency. So there isn't this big gap that a coexposure model would be needed for. Does that help?

Member Ziemer: Yes, thank you.

Chair Clawson: Okay, I'll get back to what I've got 

going on. I don't feel 0092 met what it was set out to 

do. I don't think that it's there. I move that we push 

for an SEC from 1972 to 1990 for construction trades 

subcontractors. And this is to the Work Group, not to 

anybody else. I've got Jim and Phil. Do I have a 

second?
106

Member Schofield: You got a second. I mean, I think 

we need to call it at some point. It's, like he says, 13 

years, we need to call it.

Chair Clawson: Well, this -- everything's been leading 

up to this, everything's been leading up to 0092. And 

it is where it's at. I don't think that we've got it. I 

think it's something that we need to take care of now. 

So I move that we take this to the full Board.

Member Schofield: Second. 

Member Lockey: Hey, Brad, this is Jim Lockey, how 

are you?

Chair Clawson: What's that? I can't hear you, Jim.

Member Lockey: Hi -- Jim, this is Jim Lockey. You 

know, I think, you know, this is a very, very difficult 

subject, and I think there's a lot of value judgment 

that has to go back in making a decision one way or 

the other. 

But I think what concerns me most is that it has been 

13 years. I don't think we're going to resolve it by 

going through additional data going forward in the 

future. And I think under those circumstances, I 

would agree with you.

Chair Clawson: Understand. So Rashaun, we need to 

-- the SRS Workgroup is moving to make this an SEC 

from 1972. I'll have to sit down and write up the 

paperwork on this of what it's going to come down 

to. But I'm looking at just the subcontractors 

construction trade workers from 1972 to 1990. 

I think it'd be January 1 that I've got to the 

December. And we'll take a look at the '90 to '97, 

what I call the Westinghouse years. We will take a 

look at that later, but I think that we need to take 

this to the full Board at this time.

Dr. Taulbee: Brad, if I may, may I ask a question or 

a clarification?

Chair Clawson: Sure.
107

Dr. Taulbee: Is this the dose reconstruction is not 

feasible for all radionuclides from 1972 through 1990 

for all internal radionuclides, or is there a specific?

Chair Clawson: I think more towards americium is 

what I was looking at.

Member Lockey: Yeah, I would agree with that.

Mr. Fitzgerald: I guess the only, I don't like to slow 

any momentum on this, the only question is the 

Finding Two, where the specific source term is 

indeterminate in a lot of cases. How would you 

differentiate those subcontractors that in fact, you 

know, did or did not get americium? 

I mean, how would you know if in fact the source 

terms were not specified, nor could you predict? I'm 

just throwing that out because that was Finding Two.

Chair Clawson: So Joe, how would we -- how would 

we word this? This is, you know, you guys have been 

the ones that have been working on this too.

Mr. Fitzgerald: Well, I don't think you can distinguish 

because you're lacking that information. I think for 

that earlier time period, the job plans and the SWPs 

did not specify a particular target nuclide. Much of 

the effort that NIOSH undertook was to find a way to 

assume what that would have been using, you know, 

Farrell and Findley and looking at the facility. 

You know, it's not something that is self-evident from 

looking at the permits. So I don't think you can in 

fact decide that this particular sub was on americium 

and this was one was not. There's certainly a chance 

that you would have those that lacked bioassays that 

were on -- did get exposed to americium. 

But you would have no way to determine that 

because their job plans and their SWPs did not say, 

didn't stipulate. So it's really any subcontractors who 

had potential exposures, basically.

Member Lockey: Joe, I thought they were curious, 
108

they separated americium. Is that not correct?

Chair Clawson: What's that?

Mr. Fitzgerald: There was separated americium. But 

I'm just saying that there would be no easy way to 

distinguish those that might have been exposed 

doing whatever specific tasks they were doing to, 

say, americium or fission products or anything, 

because none of those job plans or SWPs stipulated 

any nuclides per se. 

And much of the work we've been doing is just to 

basically come up with assumptions on what the 

source terms would have been for workers at certain 

locations. But that's not anything specific.

Chair Clawson: So I guess it would be for all internal.

Mr. Fitzgerald: Yeah, it'd be all internal. And you 

know, just to go back to a comment that John made 

in his presentation, you know, he was saying that 

well, in response to the Tiger Team, I think 

Westinghouse pointed out, this is in the 90s, that, 

you know, that the workers were relying on their 

familiarity and expertise to decide, you know, what 

nuclides would be, you know, of concern. 

It was an expert-based system. It didn't go into a 

analysis-based system until the mid-90s with the, 

and we're going to be talking about that next, with 

the recognition that the expert-based system and the 

tables they were using weren't reliable and weren't 

being kept up to date. There was an over-reliance on 

them and they were static.

So this whole question of who was exposed to what I 

think is a legitimate question before that upgrade. 

And certainly that was the problem that DOE 

headquarters identified prior to 1990. There wasn't a 

clear idea in terms of the bioassay types and 

frequency on what people were actually exposed to 

in actual operations.

Chair Clawson: Okay, is there anything else that we 
109

need?

Dr. Roberts: Okay, so this is Rashaun, Brad. So just 

to be clear, what you're recommending is that we 

bring the recommendation to the Board to add, you 

know, this SEC, to this as an SEC Class.

Chair Clawson: Correct. We as a Work Group have 

done this, but it's got to go to the full Board for their 

vote. And there'll be the usual verbiage of the 250 

days and everything else like that.

Member Beach: Brad, this is Josie that the -- what 

you bring to the Board, you can work that out and 

send it around to the Work Group.

Chair Clawson: Right.

Member Beach: Is that correct?

Chair Clawson: Yes, I'll -- I'm trying to think of, 

because we're going to have to exclude the primes, 

and I've got to spend a little time and look at that. 

Maybe I can get Joe or Bob to help me with that.

Member Ziemer: Keep in mind also, this is Ziemer, 

keep in mind that you're going to have to specific 

what can be reconstructed during that period. 

Because you may have individuals who don't meet 

the 250-day limit for whom doses may, partial doses 

may have to be reconstructed. 

And for example, we're going to have to address 

medical dose, external dose. And if there are some 

internals that can be reconstructed, you have to 

specify those so that you're being fair to those who 

don't meet the, or don't have the proper cancer for 

the SEC.

Chair Clawson: I understand, thank you, Paul. Yeah, 

I --

Member Ziemer: NIOSH is going to have to help with 

that, I think.

Chair Clawson: Yup, I think they can, so.
110

Dr. Roberts: Okay, so then this will go, we have a full 

Board meeting the 8th and 9th, so this will go on for 

potential vote.

Chair Clawson: Correct.

Dr. Roberts: Okay.

Chair Clawson: There'll be a presentation for us, and 

be able to give the full Board the opportunity to ask 

questions and understand this better. 

Joe, if I could ask of your help to be able to help put 

this together, make sure that we make this the best 

we can. We can send it to NIOSH and Rashaun and -

-

Mr. Fitzgerald: Yeah, I think it has to be vetted pretty 

carefully. This complicated, as we found out at 

Hanford, subcontractors, if you're carving them out, 

that's difficult. So it has to be --

Chair Clawson: Yes, that's right. And --

Member Ziemer: One other thing, Brad, Ziemer 

again, if I could suggest. I know there's a big 

frustration with the time element. But in essence, we 

have not really based SECs on how long it's taken to 

resolve an issue. So --

Chair Clawson: No, Paul, and I understand, I 

understand that.

Member Ziemer: I think to take this to the Board, 

that it's not simply the fact that a lot of time has gone 

by. We need to make sure that it, I think what you're 

saying, or I understand that, and again I'm not part 

of the Work Group, but from the SEC other Work 

Group point of view, we have to have a good rationale 

for why additional work won't resolve the problem. 

Know what I'm saying?

Chair Clawson: Yes, I do, and I understand that. But 

at some point, time does play into it.

Member Ziemer: I understand that too. But we've 
111

never used that as a sole criteria for an SEC.

Chair Clawson: Right, but we --

Member Ziemer: I mean, it's always been -- it's 

always kind of been the background, but we also 

have to say, yeah, we've reached a point where we 

don't think further studies are going to resolve the 

problem, something to that effect.

Chair Clawson: Right.

Chair Anderson: I would agree. This is Andy, I would 

agree with that. I think we just, or you have to put 

into this that exhaustive searches have been for 

additional data and what data you hoped for didn't 

come out of those boxes. And therefore we don't 

think that additional searching is going to resolve the 

issue to make the coworker model issues come up to 

what our expectations were. So it's --

Chair Clawson: Yeah.

Chair Anderson: -- The availability of data, yeah.

Member Beach: So I have a comment.

Chair Clawson: I understand that.

Member Beach: Brad, I have a comment for you.

Chair Clawson: What?

Member Beach: I have a comment for you and/or 

maybe Rashaun. I think you have one more member 

of the Work Group that's not online. Would it be 

feasible to get his opinion so you can go forward with 

the full Work Group recommendation? Or does that 

matter at this point? I'm just curious.

Chair Clawson: Well, if he decided not to, it'd be three 

to one anyway, so I don't know that it would be that 

much. I think that he should be involved in it and let 

him know what's going on. But he'll have the same 

opportunity when it comes to the full Board to be able 

to discuss and review what we've got to put forth. 
112

And I'll need your help, Joe, on putting this together, 

because I think it's going to be you're right and I'm 

on the Hanford Workgroup so it's, I know what we're 

going to get into this. But we need to both put 

something together to be able to push around to the 

SRS Workgroup, and then we'll put it out and go from 

there. I'll get Rashaun to be able to help us with that, 

go from there.

Member Roessler: Brad?

Chair Clawson: Yes.

Member Roessler: This is Gen, I'm on the SEC 

Workgroup.

Chair Clawson: Right.

Member Roessler: And I've been sitting for several 

hours listening to all of this, and this is a really 

complex site. And I was looking forward to hearing 

the rest of discussion on this before coming to any 

kind of conclusion myself. And I think maybe other 

Board Members who haven't been involved in even 

that much will find this very difficult to understand 

and to vote on.

And I guess I would make one suggestion that as you 

put something together, and certainly Paul and Henry 

have made some good comments, but as you put it 

together, maybe you want to not only present your 

draft to the SRS Workgroup, but also the SEC 

Workgroup to get comments.

The Board might feel you're rushing things a bit, in 

spite of the fact that we identify with your frustration 

for this having been a long time.

Chair Clawson: Well, you know, and look at this too, 

you know, let's say we -- it's a year turnaround every 

time. And there is no more information. We have beat 

this to pieces. 

But Gen, I take it under advisement, I'll see what we 

can do to be able to put this together, be able to bring 
113

it into a rational situation. Maybe give a little bit of a 

background of where we're at and why we feel where 

are at now and why we're pushing for an SEC.

And then I think that because I understand this is just 

like any of the other SECs or not passing SECs 

coming forth from every Work Group there's -- we 

will not be able to cover everything, but we will give 

it the best opportunity we can to be able to explain 

why we are where we're at and why we feel that this 

is the best path forward.

Member Roessler: Are you actually suggesting that 

the rest of the agenda for today and Friday would not 

be completed?

Chair Clawson: No, because I don't think that 0091's 

really going to add anything into it. It's going to be 

good information, we're going to get a lot more in 

there. But it is still not going to come to terms with 

completeness. If you've read 0091 and stuff it's, I 

don't think that it -- I don't think it will.

Member Ziemer: What about the Friday materials?

Mr. Barton: This is Bob Barton. I think I can comment 

on that a little bit. There's really I think, well, there's 

four items really. There's some mop-up activities 

based on the coworkers models, sort of bringing 

those to close. There are two issues, one is global for 

the entire program, one of them applies to all the 

workers at SRS. 

And then the fourth one is the question of 

stratification for subcontractors, which may be moot 

at this point if the Board chooses to go forward with 

an SEC. Then you know, we're not going really be 

stratifying coworker models for subcontractors 

because they're already a cohort. So I don't think the 

Friday material necessarily impinges on any 

recommendations made about RPRT-0092 here.

Dr. Taulbee: This is Tim. I somewhat agree with what 

Bob is saying. I think the speaking to the observed 

differences, the quantitative comparisons of the 
114

DuPont construction trades to the subcontractor 

construction trades actually does speak to this too a 

bit with regards to when we combine them and that 

we don't see any difference there. 

And here you're designating an -- or proposing to 

designate an SEC, actually I think you already have 

recommended coming out of the Work Group, to 

designate and SEC for the subcontractor construction 

trades workers. And so I do feel that that data is 

relevant. But that's just my opinion. It's your call, 

Brad.

Chair Clawson: So what you're saying, Tim, is that 

this SEC could involve more people that just if we find 

the data with the subcontractors and if we stratified 

this? Is it going to change -- is it going to change 

what we've come up with on 0092?

Dr. Taulbee: From the standpoint of completeness, 

no, it's not going to change that. From the standpoint 

of are the subcontractor construction trades worker 

different, are exposures and how we model them in 

co-exposure models different from the prime 

construction trades workers? Yes.

Chair Clawson: Well, and I'm not saying that we 

won't have the other meeting and stuff like that. But, 

maybe by that time we can have something brought 

together to be able to bring a little bit more clearance 

to this. But the bottom line is it still comes back to 

the completeness. Now, the other part of it that 

comes into the dose reconstruction, yeah, I 

understand that.

Mr. Barton: This is Bob Barton. I guess what I would 

say to that is if the underlying premise is that we 

don't have complete data for subcontractors and 

that's the impetus for the SEC, comparing the data 

we do have, I mean, what does that really get us? I 

mean, if we're saying that the data set is incomplete, 

any comparisons would seemingly be of somewhat 

limited value, I think. 

Again, if the premise is accepted that we don't have 
115

complete data and thus we're missing workers that 

should have been monitored. Well, now you're 

comparing just the data you have, which if it's 

incomplete, I mean, again, what can we really draw 

as far as conclusions on that?

Chair Clawson: Thanks, Bob.

Dr. Roberts: Okay, so what again are we doing for 

the rest of the agenda today and the agenda set up 

for Friday?

Mr. Fitzgerald: I think RPRT-0091 will go, and I 

hesitate to say this, relatively quick. So maybe if we 

can finish it within the hour, I think our presentation 

will take about 10-15 minutes.

Chair Clawson: Okay, so what do we want to do? I 

think I'm -- personally I think that we still need to be 

able to, you know, there's some overarching stuff in 

there. What about -- what about the next meeting on 

the 20th? Is that going to buy us -- do we still have 

-- this is all pertaining to SRS.

Mr. Barton: I think a lot of the, and this is Bob again, 

I think a lot of the items on the docket for the 20th 

are sort of separate from this. One discusses 

americium again, but that would be applicable to the 

entire site. One of them discusses a method called 

multiple imputation, which is how you deal with 

censored datasets and co-exposure analysis. 

Again, there's a couple of very quick mop-up items 

related to discussions about the co-exposure model 

that from back in last December. The only one that 

may not be applicable is the stratification issue, if in 

fact the Work Group's going to recommend an SEC 

for subcontractors. 

Because, again, if we're going to say doses are not -

- dose reconstruction is not feasible for 

subcontractors, then you're not going to stratify any 

sort of coworker model because it's already been 

determined to be infeasible.
116

Chair Clawson: I understand. So let's go ahead and 

we'll --

Member Beach: This is Josie, sorry -- this is Josie, 

sorry for interrupting. What about the later years? 

Because you're just talking through '90, correct?

Chair Clawson: Correct. We'll have to address that as 

a Work Group. I think that we've been -- we've got 

to take this in little bit smaller bites. But that being 

said, let's go on to NIOSH, they've got the Report 

0091 but --

Member Beach: Could we -- could I ask for a break? 

We've been at this for about three hours another --

Chair Clawson: No, what the heck do you think's 

going on, Josie, this is -- yes, that'd be fine if we want 

to take a comfort break.

Dr. Roberts: And how long are we going to have that 

break for?

Chair Clawson: Ten minutes should be good.

Dr. Roberts: Okay --

Chair Clawson: I thought for 60 seconds.

Dr. Roberts: Okay, so back here at 3:20.

(Whereupon, the above-entitled matter went off the 

record at 3:09 p.m. and resumed at 3:20 p.m.)

Dr. Roberts: Okay, I have 3:20, so again I'll do a 

quick roll call. One minute.

Okay, so Brad, are you back?

Chair Clawson: Yes, I am.

Dr. Roberts: Okay. Jim Lockey. Jim Lockey, are you 

back?

Member Lockey: I'm back. I'm Jim Lockey. I'm back.

Dr. Roberts: Okay, fabulous. And Phil, are you back?
117

Member Schofield: I'm back.

Dr. Roberts: And Anderson.

Chair Anderson: Yes, I'm here.

Dr. Roberts: Beach?

Member Beach: Yes, I'm here.

Dr. Roberts: Gen?

Member Roessler: I'm here.

Dr. Roberts: And Paul.

Member Ziemer: Yes, I'm back.

Dr. Roberts: Okay, great. It looks like we've got 

everybody. And so Brad, I believe we're moving on 

to the second part of the agenda at this point.

Chair Clawson: Okay. Sounds good. Thank you. I 

would like to welcome everybody back. We're going 

to proceed on. NIOSH is going to give their present 

on 0091. And I'll turn it over to you, John.

NIOSH summary of RPRT-0091 (missing or 

incomplete americium exposures between 1971 and 

1999)

a. NIOSH Presentation

Dr. Cardarelli: Thank you, Mr. Clawson. I'll just try to 

make this quick, given what we just went through. 

And I know it's been a long day, so I'll get straight 

into it. 

This is a summary of the report that has not yet been 

presented to the Work Group, but the documentation 

has been shared on the evaluation of the Savannah 

River site americium-241 source terms between 

1971 and '99, particularly using the bioassay 

frequency tables.

Again, I'd like to acknowledge the primary authors, 

Mike Mahathy and Roger Halsey, who are also on the 
118

phone. So if we do get into detailed questions, I will 

probably lean on them to help provide it.

The report itself is broken up into a brief background 

and then six sections. Near the end of this particular 

presentation, there's five questions that have kind of 

evolved over the last iterations between NIOSH and 

SEC, and we ask and answer questions and I believe 

that Mr. Fitzgerald will come in with another response 

to our response on those types of questions, and then 

we should have this covered.

Also, I point out the time line again. The SEC Class 

103 goes from '53 to about '72 or '71-ish. I think it 

was March or something. And ORAUT-RPRT-0091 

starts around 1971 and goes through '99.

To the background. November 14, 2017, SRS Work 

Group meeting, SC&A stated concerns that workers 

were enrolled in incorrect bioassay programs before 

1999 and that some of those workers were exposed 

to unrecognized americium-241 sources.

In January 2018, their memo, Missing or Incomplete 

Radiological Source Terms, included the five 

questions that I mentioned earlier, and we'll get to 

those. 

About a little over a year and a half later, Report 0091 

comes out to address this and it addresses the issues 

raised in that January 2018 memo and then about 

eight months after that, January 23rd, SC&A came 

out with a review of our report. They didn't really 

have any observations or findings or new concerns, 

but they did add responses to our five questions and 

that put us in a situation where we weren't quite sure 

how to handle these as are they findings? Are they 

observations, and what weight do we give them? So 

we treated them as if they were findings and just 

tried to provide responses to them in that context.

October of this year, we sent out a memo which was 

our responses to those five questions. The 

introductions probably, what was the driver for the 

report which was underlined here in this particular 
119

statement. I won't read the whole thing, I'll just read 

the underlying section. Lack of proper specification of 

radionuclides of significance for internal dosimetry 

may have led to unmonitored exposures for which 

dose reconstruction with sufficient accuracy may not 

be feasible. And then obviously, we should further 

investigate that.

Part of the big picture is to kind of understand the 

operating contractors, and this is kind of a big picture 

slide showing that when the reactors R, P, K, L, and 

C came on board, it pretty much stopped operating 

in the late '80s, predominantly production-type error 

and you have the F Canyon and the H Canyon. The F 

Canyon stopped, started. 

There was somewhat of a start up effort in the '90s 

during the Westinghouse era, but I'm just giving you 

a big picture view of kind of the work activities over 

these several decades.

Again, another background slide to help better 

understand what was going on with regard to the 

regulations, operating philosophies, how they did 

monitoring. So we put it in the context of what was 

required at the time. Of course, it starts with the 

Atomic Energy Commission in charge up through 

1974, based a lot of monitoring based upon 

maximum permissible body burden. 

And then NRC and ERDA came in '74 to '77. 

Department of Energy became a player in 1977, 

which replaced ERDA. And then a few years after 

that, DOE 5480 was like the first order that came in 

which starts setting monitoring requirements based 

upon a dose. And that was further refined in 1989-

1990 period with 5480.11 coming in. Of course in '95, 

10 CFR 835 takes over.

So a lot of dynamic changes with regard to the 

requirements that they had to meet under the 

regulations or the orders or the expectations. The 

drivers for that were all different over this time 

period. 
120

This is just a slide showing what were the basic 

drivers for the monitoring requirements -- 10 percent 

of the quarterly limits all the way down the 100 

millirem per year combined, and that is followed 

through also with 10 CFR 835.

You saw this particular slide in the previous 

presentation. I won't go over it, but again it just how 

the bioassay control procedures were in place and all 

work was done by mostly DuPont construction trade 

workers under job plans up through about '74-'75. 

Lots of chest counts and whole body counts began to 

replace the fission products, but we're here to talk 

about americium.

The Defense in Depth operating philosophy, I wanted 

to point out with Westinghouse Era, that same 

operating philosophy was applied in the DuPont era. 

It just wasn't called Defense in Depth, and that is in 

essence where they used engineering controls, 

administrative controls, policies like the zero 

exposure policy, things of that nature. Basically, the 

same with regard to protecting workers.

So the internal dosimetry section, the selfassessment, this covers the DOE Office of 

Enforcement, where they issued 31 general 

deficiencies in July 1999 and asked all contractors to 

review their programs.

Not all 31 of these deficiencies was associated with 

the site. I think only 18 basically were and the one 

that is really pertinent to this discussion is Item B.8, 

workers enrolled in incorrect routine bioassay 

program.

So the SRS provided a response for this, and they 

previously identified some workers potentially 

exposed to americium that were not included on the 

RWPs. They recommended changes and the memo, 

Specification of Urine Bioassay Requirements on 

Radiological Work Permits, was submitted. 

So the key here partly is to understand there's also 

an ingrowth of americium-241 to the plutonium 
121

mixture, so when you're in a production phase like 

the DuPont era, you're dealing largely with fresh 

plutonium with very little to no americium ingrowth. 

As that plutonium ages and you're no longer in 

production and now you get into storage, the 

americium will begin to grow in and become a 

potential dosimetry radionuclide of concern. So we do 

address that in our dose reconstructions, as you can 

see here. We make assumptions that it's fuel grade, 

usually after 10 years, and it gets at least 10 percent 

of the committed effective dose.

So there's a true account for this already in a 

claimant favorable dose reconstruction effort for 

individuals. That's built into the whole dose 

reconstruction process.

Separated americium, a little bit different from 

plutonium, existed in a few areas we talked about, 

the MPPF and the 773-A, where plutonium is not the 

primary dosimetry of concern, just the americium is.

So we summarize that, Section 3, we talk about the 

whole body counting and the bioassay monitoring, 

and here is just a big picture timeline of the types of 

technology that were used to conduct whole body 

monitoring. It started with a Phoswich chest counter, 

predominantly looking for americium, but it could 

pick up -- I can't say it -- californium and curium. And 

then in about mid-'82, '83 period, they started 

germanium counters, but kept the Phoswich active as 

a backup to that, and then they improved the 

germanium counter system in the '90s.

The other thing I wanted to point out here is that the 

bioassays in around 1986 or '87 period, anything that 

had a significant detection, or if there was an incident 

where americium was found to be positive, they 

would do an isotopic analysis to verify and validate 

that. That basically answers a question: how do we 

know that there aren't already radionuclides that 

could have been potentially exposed, that they 

weren't monitored for? Because that would have 

been captured in that context of an isotopic analysis.
122

Prior to that, it was predominantly just either gross 

gamma or gross alpha type analyses to my 

understanding, so if I missed any of that, I would ask 

that Tim speak up, but I think I've captured that 

right. 

Another concept that they started was called the 

Fastscan Whole Body Counter for fission products. It 

came in about '89, and then you'll see a big jump in 

some of the data at that time period. But chest and 

whole body counts, what we see here from 1972 to 

1985, this is combined together. The data did not 

exist in a separate format, so I can't split these out, 

but these are the folks who have gone through it. 

Quite a substantial amount of data exists.

Then we go from '86 because the previous ones stop 

at '85. Now I'm picking up from 1986 to 1992. We 

have whole body count data and then chest count 

data. So you can see that the numbers start at 5,000 

here and go up to 30,000, and then the slide before 

it just went up to 3,000. So there's an explosion in 

one respect of -- probably a bad term, but there was 

a significant increase in the number of whole body 

count and then chest count data that began to occur 

in the mid-'80s, especially starting in the '90s.

So what's the purpose of the SRS Routine Bioassay 

Programs? Again, I said before, it's not used to assign 

dose. It's used to monitor program effectiveness. The 

program included the items listed here: engineering 

controls, air monitoring, surface contamination, 

personnel monitoring, all of this is pictured in this 

phrase called the Defense of Depth concept that is 

kind of in quotes with regard to the Westinghouse 

era. This also applied during the DuPont.

So any positive result triggered special bioassay. 

That's what would be used for dosimetry analyses.

The bioassay frequency tables were the method used 

to identify the locations, analytes, how frequent we 

must monitor these workers and the participants who 

need to do it. Typically, they're annually and you'll 

notice that the tritium, plutonium, strontium, 
123

neptunium, uranium, enriched uranium, fission 

products, and americium, curium, and californium 

are together. Those seven or eight radionuclides of 

interest, I'll call them, basically account for 90 

percent of the dosimetry issues at the site. So those 

-- and there's monitoring across the site for all of 

these. Anything not on that particular list was 

considered not to be dosimetry -- of dosimetric 

importance with regard to regulatory measures.

So whole-body counts, chest counts, category. They 

did a category-based program which I'll talk about in 

the next slide, and then RWPs which Westinghouse 

started in '92. That's where the workers' 

responsibility is to follow through and some workers 

simply didn't, and that's part of the challenge is you 

can't force a worker always to leave the samples that 

they're supposed to leave. That was a challenge.

So here are the categories. I will not go through all 

of them. I will just point out Category III --

Categories I, II, and III. And Category III is the 

personnel who were not required to routinely enter 

radiation control areas where protective clothing was

required, and who were not performing tasks 

requiring work in contamination or airborne 

radioactivity areas. 

So Category I is the person who wore the respirators. 

And Category III was pretty much the general folks 

who wouldn't go into these areas. And you were 

selected based upon a frequency of your risk of 

exposure or potential of exposure.

So the purpose of the special bioassay is to assign 

the dose, triggered by routine bioassay results or air 

sample results, or as we saw in the previous 

presentation, surface contamination, nasal 

contamination, or any incident that might occur.

They're designed to assess the inadvertent intakes. 

They require an investigation to establish the source 

term and you can see after 1986, they did isotopic 

analysis to verify the specific isotope that was 

contributing to the contamination. They did not use 
124

the bioassay frequency tables for these types of 

monitoring. 

Section 4 is the americium, curium, californium 

source terms from bioassay frequency tables. On the 

left, you see the year, 1971 all the way through 1999. 

And it shows examples where americium-241 only 

was a routine, required on the routine urine bioassay 

requirements. 

As you can see as we talked before, 773-A is listed 

just about everywhere. And you can see in the '90s, 

I'll point out here, you get a lot more different waste 

streams and things that have been characterized as 

a result of the Farrell and Findley document, and also 

a change in the actions at the site from mostly 

production to waste characterization, environmental 

cleanup. So there's a fundamental shift in kind of 

what the entire site was doing at the time. That's 

where you see this change in the '90s.

Dose reconstruction considerations. Americium-241 

is a decay product of 241, monitoring one, either 

americium or plutonium. You monitor them both, 

assuming the key point here is americium has not 

been chemically separated from the mixture.

So the 1999 memo listed three sources where 

americium was listed as a routine bioassay, and 

plutonium did not contribute more than 10 percent of 

the dose in those areas. And that was the californium 

waste stream, the F wing boot waste stream, and 

MMPF in 221. So that's just kind of pointing out where 

americium alone itself could have been potentially 

present. 

For the MPPF, the multi-purpose processing facility, 

which was in Building 221-F, no americium 

requirements in the bioassay frequency tables 

between 1989 and 1999. Why? Because it simply 

wasn't used. It was there, but not used.

It was used in 1995 for demonstration of a 

vitrification project, but it really did not have large 

quantities where exposures were going to be 
125

significant or potentially significant. So we reviewed 

eight RWPs for the MPPF for the work in 1996 and 

'98. Everyone on those RWPs had americium, 

plutonium, and strontium listed on their routine 

bioassay requirements. This is the era where RWPs 

started to really list the radionuclides of interest. 

Thirty-four individuals signed in, and 29 had 

americium routine bioassays within four and a half 

years of the RWP. Five had no bioassays for 

americium. But each of the five had coworkers on the 

same date, the same RWP, with an americium 

bioassay result which effectively would mean 100 

percent coverage.

Other parts of the dose reconstruction program. The 

air sampling which could trigger special urine 

bioassay, plutonium was the controlling limit for most 

radionuclides or for the radionuclides for dose. In the 

'70s and '80s, Radiation Concentration Guidelines 

were used to determine whether or not you've got to 

give us a special urine analysis. In the '90s, Derived 

Air Concentrations took over. So again, we have a 

change in the types of criteria by which would trigger 

a special. 

NOCTS Chest data is available if we need it. It was 

used and can be used to reconstruct doses for 

americium. We have more than 1,000 chest counts 

of americium of 469 workers just for the decade of 

1990 to 2000.

So routine or special urine bioassays, we have over 

14,000 urine bioassay results from '71 to '90. The 

majority of them are routine --- 5,000 are routine 

from '91 to 1999 alone, and about 1,500 are special 

in that same decade of the '90s.

The routine bioassay is not required in a bioassay 

procedure. Areas with the americium contamination, 

but not listed in bioassay procedures were covered

by the RWPs.

(Audio interference.)

So on to conclusions. So the SC&A statement, lack of 
126

proper specification of radionuclides of significance 

for internal dosimetry may have led to unmonitored 

workers for which dose reconstruction with sufficient 

accuracy may not be feasible.

So our report focused on the potential americium, a 

decay product of plutonium for the time period '71 to 

'99. Both radionuclides were detected by various 

methods: air, surface, skin, nasal contamination, 

routine or special urinalyses, and in vivo counting.

Dose reconstruction, we believe, is feasible with 

sufficient accuracy for compensation purposes due to 

the availability of these data.

b. Joint SC&A and NIOSH presentation

Now we are going to get to the point in the 

presentation where there's questions that have been 

by SC&A. I'll present our answer and then I'll zip over 

to the slide for Joe to provide his response to NIOSH's 

response. Is that okay, Joe?

Mr. Fitzgerald: That's fine.

i. SC&A presents its responses (issued in January 

2020)

Dr. Cardarelli: Sounds good. Okay, the five questions 

were: what are the ramifications to dose 

reconstruction? What's the completeness of the preMarch 1999 bioassays? Third question is worker 

enrollment in bioassay programs. The fourth question 

is the facility source term characterization and 

adequate internal dose. And the final one is 

ramification of missed dose radionuclides.

So what does this all mean with the big picture with 

regard to our ability to reconstruct doses? I won't 

read the question, but I will read the answer. So on 

the ramifications to dose reconstructions, our 

response is basically the relevant radionuclides were 

included in the bioassay program. There were 

relatively few changes in the bioassay program by 

area from 1971 through '99 with the exception of 
127

americium as discussed in Section 4 of this report, 

those two areas. NIOSH believes that dose 

reconstruction can be done with sufficient accuracy 

for compensation purposes.

At this point, I can turn it over to you, Joe, and you 

can provide a response to that, we can move on, or 

I'll zip on through the other four --

Mr. Fitzgerald: No. Let's just do the questions real 

quick. That would be more expedient.

First off, these weren't findings.

Dr. Cardarelli: I can't hear you.

ii.NIOSH present its responses to SC&A comments

Mr. Fitzgerald: Oh. Can you hear me? Hello. All right, 

good. These were suggested lines of inquiry. Very 

simply put -- what's that? Hello?

Let me continue real quick. Yes, these were 

suggested lines of inquiry that came from a question. 

We raised a very simple question during a Work 

Group meeting that in the course of our Report 0092 

review, we came across a Westinghouse selfassessment where they identified americium as being 

---

Dr. Cardarelli: I understand that everyone can hear 

you, Joe, except for me.

Mr. Fitzgerald: Okay. 

Dr. Cardarelli: For some reason, I'll work on that, but 

give me thumbs up if we want to go to Joe's answer 

to that. Okay.

Mr. Fitzgerald: This will be interesting. Yes, so 

frankly, it was a question that we raised ---

(Simultaneous speaking.)

Dr. Cardarelli: I have to find out why I cannot hear.

Mr. Fitzgerald: I can hear you, John. It was a 
128

question we raised about a self-assessment 

Westinghouse had performed where it identified 

americium as not showing up for a couple of facilities 

and therefore the potential for workers not to be 

enrolled in the correct -- for the correct nuclides in 

their RWPs. We flagged that to the Work Group and 

said this may have implications. The Work Group just 

simply said, you know, well NIOSH wanted the 

references. We provided those. And then the Work 

Group suggested that we write down the concerns 

and we did that in a memo. We weren't asked to 

investigate, just to identify the concerns. 

(Simultaneous speaking.)

Mr. Fitzgerald: And these questions are simply 

suggested lines of inquiry -- all right, suggested lines 

of inquiry that NIOSH could follow in the course of 

doing the investigation that they were going to 

pursue. So these weren't findings per se. They sort 

of came back that way, so -- and we had a dialogue.

But I'm going to tell you in general that really the 

fundamental question was whether one could dose 

reconstruct with sufficient accuracy if, in fact, you 

had these specific americium issues. NIOSH satisfied 

us from the standpoint of demonstrating that that 

would not be an issue for the two facilities in question 

that were flagged in the self-assessment.

So that removed the fundamental question that we 

had relative to dose reconstructability. What was left 

is these questions -- they were kind of programmatic 

questions that we posed as lines of inquiry. The first 

question was ramification of dose reconstruction. We 

suggested that that would be one implication that 

ought to be addressed. And the response was that 

NIOSH felt that there would be no ramifications to 

dose reconstruction from '71 to '99. 

Well I'm not going to reiterate everything we covered 

in the '92 discussion, but we felt that clearly that 

source terms were not necessarily identified 

adequately in the DuPont years, and I think we did 

discuss that under finding two, and that's kind of our 
129

position on that question. And that's where we left it 

on question one.

But I think what you're going to hear is the response 

on almost all of these -- there's five questions. 

They're going to be about the same, that you know, 

in terms of the implications, I think NIOSH's position 

is that there are no implications for dose 

reconstruction or completeness analysis, and we feel 

otherwise primarily for the '72 to 1990 time period. 

So we can go through this, but I think I want to put 

this in perspective that these programmatic lines of 

inquiry that would be guiding an investigation, I think 

have been -- have been pursued. We've agreed to 

disagree that on the implications for the DuPont era. 

And I think we've touched on most of those 

considerations in the previous discussion. I would not 

want to drag you through that again. 

So I'll just leave it there, and like I said it was a 

question that came up in our review on a 

Westinghouse self-assessment. It wasn't one that we 

raised independently. And we felt the fundamental 

question was settled by NIOSH for the two facilities 

in question.

The programmatic questions or the lines of inquiry 

are pretty much the same as the ones we just 

discussed in the Report-0092 dialogue. So that's my 

capsule for the whole thing. And we did generate a 

response and NIOSH generated a response, but I 

don't think there's any fundamental disagreement on 

the outcome and where we have differences, I think 

we have laid those out in the response to 0092, 

particularly in finding 2.

Dr. Cardarelli: So I'm back now. I can hear. I can 

hear you, Joe.

Mr. Fitzgerald: Okay, good. I kind of touched on how 

we dealt with the questions and the bigger picture, 

John. I don't know if you caught much of that.

Dr. Cardarelli: No, I did not. So should we go through 
130

them, is it worth ---

Mr. Fitzgerald: Okay. Just for your benefit, I just 

wanted to emphasize that the fundamental question 

which was the dose reconstruction with sufficient 

accuracy for the two facilities that were flagged by 

the Westinghouse self-assessment, I think NIOSH's 

response in '91 was more than adequate about the 

fact that, you know, for one facility, I can't remember 

which one it was, but it wasn't really in operation until 

later, 2004 I think it was. And for the other you could, 

in fact, rely on plutonium in vivo bioassay as a means 

to ascertain what the exposure would have been. So 

that was essentially a work-around that provided 

sufficient data.

So the specific question that we had which was the 

implications for dose reconstruction per se, I think 

went away. The lines of inquiry or questions that we 

provided to help to guide NIOSH on the investigation, 

we really weren't making findings, but since they 

came back with responses, we expressed some 

differences on the conclusions, the programmatic 

conclusions, but they're not that much different than 

what we just discussed in the RPRT-0092 dialogue. 

So I guess I would propose that unless you want to 

touch on anything specific, I don't see any real 

benefit to walking through things like Farrell and 

Findley, walking through the source term 

identification for job plans and SWPs. The ---

Dr. Cardarelli: I think we've covered everything in 

the big picture, as I'm looking at the responses to 

some of our questions. At this point, I will leave it to 

Tim because he's heard everything, or to my 

colleagues at Oak Ridge to see if I should go through 

the rest of the questions.

Mr. Fitzgerald: Yeah, the key thing to understand is 

that the Work Group had asked us to identify our 

concerns because I think the understanding was 

NIOSH was going to follow up, and the questions --

you know, we don't usually do questions, as you 

know, weren't meant as findings, but were lines of 
131

inquiry that we felt were important in any 

investigation of that particular issue. So that's the 

context by which we identified these questions.

Dr. Taulbee: I don't have anything else to add from 

that standpoint. It's up to Brad as to whether you 

want to go through all of them or whether this is 

sufficient, up to Brad and the Work Group.

Chair Clawson: I don't see any added to it, but I want 

to make sure that anybody that has any questions 

will have the opportunity to be able to ask.

c. Work Group discussion

Member Ziemer: This is Ziemer. It's not really a 

question more than a comment. I think at the Full 

Board meeting, the Full Board will have the right to 

hear NIOSH's reasons why they think they can 

reconstruct dose. So all of these responses may have 

to be provided for the Full Board because I believe 

that for the Full Board to make a decision on this, 

they're going to have to hear both sides of these 

arguments.

Mr. Calhoun: This is Grady. Can you hear me? This is 

Grady, can you hear me?

Member Ziemer: I can hear you, Grady.

Mr. Calhoun: I have something to add here too, and 

it kind of goes along with what Paul was saying. Just 

so it's easier for the Secretary to administer this if it 

comes to that, to writing up something to help advise 

the Board or inform the Board. I think what you have 

to include in that is obviously a technical basis and 

specifically what, why do you recommended an SEC, 

and then if it's for americium, for example, or any 

reason, remember any reason that's used to 

establish an SEC to not be used to assign dose to 

anybody else of that Class. So anybody with a nonSEC cancer or anybody with less than 250 days, they 

-- you can apply that to them. 

And then you said for '90, so it would be important 
132

to come up with an actual date. If it's December 31, 

1990 what changed, and what made you end it at 

that point? Who is covered? Clearly this whole 

discussion seems to follow construction 

subcontractors and not the general workforce. And so 

if you decide that that's what you want to be the 

population including the SEC, you need to define 

that. What are construction subcontractors?

And then it's also going to be important to somehow 

make sure that the Department of Labor can 

administer the proposed Class. So that will just make

it easier I think for you guys to get this through, so I 

just wanted to point that out and let you know. 

Chair Clawson: I appreciate that, Grady. And Paul, 

we'll something put together there and we'll discuss 

it between the Work Group, and then we'll send it out 

and get you guys' input on it, to be able to implement 

this and be able to forth with it. So appreciate that.

Member Beach: Brad, this is Josie. Do you think you 

might have that by our call on Friday or ahead of 

Friday?

Chair Clawson: You know, we'll sure give it a shot. 

But I'm going to have to get SC&A to be able to help 

me with this. Because I'm thinking in the '90 time 

period we get into some different primes in there at 

the beginning of Westinghouse and stuff, so I'll work 

with Joe and Bob and we'll go from there if that's all 

right, and we'll see what we can get before the Board.

Ms. Naylor: Brad, this is Jenny. I think it would be 

helpful for you to take a look at some of the 

definitions, SEC Class Definition packages that go up 

to the Secretary. And those are all publicly available 

on the website. And just take a look at the technical 

content that actually goes into the Secretary's report, 

and I think that would be a good basis for you guys 

to work on. 

So that said, it's a pretty heavy and very dense 

document, so do take your time so we have a good 

product from the Board to the Secretary.
133 

Chair Clawson: I appreciate that, and we'll take that 

into consideration. I was just thinking of all the 

different ones that we have put together and how 

each one of them has got their unique aspects to it. 

So I appreciate that, Jenny, and we'll go from there.

That being said, is there anything that we need to --

does anybody have any questions on 0091 that we've 

just gone over? Any questions for Joe or John?

Chair Anderson: No questions.

Chair Clawson: Okay, appreciate that. With that 

being said, we've got -- is there anything -- we've got 

petitioners down here. Is there any petitioners that 

wanted to say anything to the Work Group?

Mr. Johnson: Yes, sir. This is Warren Johnson. First, 

I'd like to thank you all for your efforts, and I 

certainly thank you for moving ahead with this 

portion of the SEC. And I assume the remaining 

portions of the petition will still be worked through in 

the future.

With that in mind, I also would add that there's been 

a lot of reference to the time and I guess a difference 

of opinion on what the meaning of whether the time 

frame of 13 years is relevant. Let me point out that 

Congress did say that the SEC should be granted if 

it's not feasible to bind the dose with sufficient 

accuracy. And feasibility certainly includes both 

resources, money, but also time. 

The very purpose of the Act is to provide relief to the 

very people that supported our efforts in the Cold 

War, and they certainly -- the provision of healthcare 

as well as compensation, all of this obviously time 

matters. And so you can't view this solely in a 

vacuum. You have to consider the fact that it's taken 

13 years and some great efforts by both the SC&A as 

well as NIOSH to attempt to bind the dose and 

confirm that you can do dose reconstructions and be 

sure that they're claimant-favorable.

Thirteen years and today we just had the 
134 

acknowledgment. It can't be done, at least as to the 

subcontractors. I would I guess respectfully request 

that you continue that consideration as it relates to 

all workers during the '72 to 1990 time frame and 

quite frankly on forward throughout the petition, but 

we've heard from NIOSH that the subcontractors and 

the other workers were treated the same. 

The records don't exist. The point of '92 was to 

compare the radiation work permits to and what was 

required of monitoring to whether that monitoring 

actually happened and whether it was for the 

appropriate radionuclides and that information 

doesn't exist. We just heard NIOSH say that. We're 

missing critical information. You can't go back and 

create that information right now.

In addition to that, we've done -- as it relates to the 

other workers, we have numerous reports of 

deficiencies throughout the monitoring program. And 

instead of acknowledging that, we're just arguing 

around how there's other ways to find this 

information. The information just doesn't exist. And 

quite frankly, on behalf of the workers, I find the 

assertion somewhat offensive that we can't trust the 

anecdotal evidence or the witness statements from 

former workers that these records were destroyed. 

And that that must just not be true. Well that's simply 

-- there are many, many people who have provided 

that information.

But the second part is it really doesn't matter 

whether it was destroyed or whether you just can't 

find it. I've been in litigation at the Savannah River 

site for eight years now, and I deposed many people 

at the site. And the records custodian has told me 

that in many cases, she will not commit that the 

records are complete. Instead she'll say I think they 

are. And when we go through that, ultimately the 

answer and her quote was, they're not lost, I just 

don't know where to find them.

Well it doesn't matter. If you can't find them, you 

can't use them. And that's part of the problem is the 
135

records aren't complete and again, I think we heard 

today from NIOSH confirming that the records aren't 

complete. That was the mission of 0092, and they 

conceded that it's failed. 

So again, I appreciate what you all have done, and I 

just ask you to continue and consider expanding the 

SEC even further. Thank you for your time.

Chair Clawson: Thank you, Warren. I want to make 

sure you understand too. Both sides on this, they 

may not agree on paths forward and stuff, but both 

sides do take this serious, and the people at 

Savannah River are important to us. We're trying to 

get best product we can out to them, and to make 

sure that they are represented the best that they can. 

I know this from years of spending time here. And we 

will continue to keep going on this. This isn't the end 

of it. It's just sometimes we have to take certain 

sections so we can digest what we're actually dealing 

with. 

Mr. Johnson: Yes, I certainly understand that, and I 

appreciate all you are doing.

Petitioner comments

Chair Clawson: Okay, anybody else here that's 

petitioners or anything that would like to make a 

comment at this Work Group meeting?

Work Group Discussion; Follow-up Actions

With not hearing any, we've got some follow up, but 

what I've got to help provide, and I'll need SC&A's 

help and probably NIOSH's too to be able to write up 

a bounding document to be able to bring forth. We'll 

try the best we can to be able to get it before this 

Friday, but there's a lot to digest into this, and I want 

to make sure we have the best product that we can 

get out to them.

With that being said, is there any other discussion 

that needs to come forth for the Work Group?
136 

Member Lockey: Hey, Brad, Jim Lockey. I think this 

is going to be a complicated letter to write. I think it 

really needs to be very precise. So I wouldn't hurry 

on it, okay? 

Chair Clawson: I understand that, Jim. And I won't 

write it, so you guys will be able to understand it 

because I'd hate a dangling participle put forward, or 

something like that in there, so we'll run this by all of 

you. This isn't just my thing. This is going to be all of 

us and a product that we're all good for, but we may 

have something rough that we'll be able to look at, 

okay?

Member Lockey: Okay.

Chair Clawson: Okay. With that being said, Rashaun, 

I think that we're good for the day if we want to 

adjourn.

Dr. Roberts: I think so. I think the path forward on 

the SEC issue is clear on the work that needs to be 

done in order to prepare the case, so with making 

that recommendation to the Board, some 

recommendations have been provided. 

I think I will need to touch base with you and to see 

about the agenda for Friday. I'm not sure. So we 

probably just need to talk about what we want to 

cover on that agenda, along with you, Andy, as well. 

So I'll be in touch.

Chair Clawson: I've still got to get a hold of the IT 

center to try to get my computer fixed that died. So 

just give me a call, and we'll work through that. We'll 

just go from there. 

With that being said, as always it's a pleasure to be 

able to talk with all of you, and until we can meet 

again, I look forward to it. This meeting is adjourned.

(Whereupon, the above-entitled matter went off the 

record at 4:08 p.m.)