THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


FERNALD
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Cincinnati, Ohio on November 


13, 2007. 


STEVEN RAY GREEN AND ASSOCIATES 

NATIONALLY CERTIFIED COURT REPORTERS 

404/733-6070 
2 

 6 

C O N T E N T S
 

November 13, 2007 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


INTRODUCTION BY CHAIR 11 


MATRIX DISCUSSION: 


FINDING 4.3-1 12 


FINDING 4.3-4 82 


FINDING 4.3-6 88 


FINDING 4.3-7 97 


FINDING 4.3-8 108 


FINDING 4.3-9 132 


FINDING 4.3-10 144 


FINDINGS 4.4-1, 4.4-2 189 


FINDINGS 4.4-3, 4.4-4 200 


FINDING 4.4-5 208 


FINDING 4.5-1 214 


FINDING 4.5-2 242 


FINDING 4.5-3 264 


FINDING 4.5-4 299 


FINDING 4.5-5 306 


COURT REPORTER’S CERTIFICATE 332 

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TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


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


an unintentional or purposeful interruption of a 


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


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


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


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


"uh-uh" represents a negative response. 


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


without reference available. 


-- (inaudible)/ (unintelligible) signifies speaker 


failure, usually failure to use a microphone. 

 

 

 

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


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

ZIEMER, Paul L., Ph.D. 


Professor Emeritus 


School of Health Sciences 


Purdue University 


Lafayette, Indiana 


EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

CLAWSON, Bradley 


Senior Operator, Nuclear Fuel Handling 


Idaho National Engineering & Environmental Laboratory 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 


SCHOFIELD, Phillip 


Los Alamos Project on Worker Safety 


Los Alamos, New Mexico 

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IDENTIFIED PARTICIPANTS
 

BALDRIDGE, SANDRA, PETITIONER 


BEATTY, EVERETT RAY, SR., SEC CO-PETITIONER 


BEHLING, HANS, SC&A 


BEHLING, KATHY, SC&A 


BRACKETT, LIZ, ORAU 


CHANG, CHIA-CHIA, NIOSH 


CHEW, MELTON, CAI 


ELLIOTT, LARRY, NIOSH 


FAUST, LEO, ORAU 


HINNEFELD, STUART, NIOSH 


HOFF, JENNIFER, ORAU 


HOWELL, EMILY, HHS 


KENT, KAREN, ORAU 


KISPERT, BOB 


KOTSCH, JEFF, DOL 


LEWIS, MARK, ATL 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MORRIS, ROBERT, CAI 


POTTER, GENE, ORAU 


RICH, BRYCE L., CAI 


ROLFES, MARK, NIOSH 


SHARFI, MUTTY, ORAU 


WOOLS, JESSIE, SEN. VOINOVICH 

 

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P R O C E E D I N G S


 (9:00 a.m.) 

WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO
 

DR. WADE: Can you hear me out there? Is 


Mark Griffon with us? 


MR. GRIFFON (by Telephone): Yeah, Lew, I’m 


here. 


 DR. WADE: And Robert Presley? 


MR. PRESLEY (by Telephone): I’m here, Lew. 


 DR. WADE: Let’s begin. This is the work 


group on the Fernald site profile and SEC 


petition. It’s ably chaired by Brad Clawson, 


members: Griffon, Ziemer, Presley and 


Schofield. Clawson, Ziemer and Schofield are 


here in the room, and Griffon and Presley are 


on the telephone. So let’s begin. 


Again, this is Lew Wade. I have the 


privilege of serving as the Designated Federal 


Official for the Advisory Board. Before we do 


our normal introductions and have our little 


talk about telephone etiquette, I’ll remind 


everyone that we are talking from a matrix 


that hasn’t been necessarily scrubbed for 

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Privacy Act information. So we should talk; 


we should be guarded in our comments when we 


come to the potential of sharing personal 


identifiers. But I think everyone around the 


table is well schooled in that etiquette. 


We’ll begin by going around the table 


here for three purposes, introduction, if you 


have any conflicts, please so state, we’ll 


also give people on the phone a chance to 


establish they can hear everyone around the 


table. So if during an introduction someone 


out there in telephone land has difficulty 


hearing, just shout out, and we’ll make the 


necessary adjustments either in volume or in 


positioning of equipment. 


This is Lew Wade, and I have the 


privilege of the Advisory Board, and I work 


for NIOSH. 


MS. HOWELL: This is Emily Howell with HHS. 


DR. ZIEMER: This is Paul Ziemer, member of 


the work group and no conflicts at Fernald. 


DR. MAKHIJANI: Arjun Makhijani, SC&A and 


CDS -- CBCS said I have a conflict at Fernald. 


MR. SCHOFIELD: Phillip Schofield, a Board 


member and no conflicts. 

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MR. ROLFES: Mark Rolfes, NIOSH, Health 


Physicist, no conflicts. 


MR. CHEW: Mel Chew from the O-R-A-U team, 


no conflict. 


MR. RICH: Bryce Rich from the O-R-A-U team, 


no conflicts. 


MR. MORRIS: Robert Morris, O-R-A-U team, no 


conflict. 


 MR. CLAWSON: Brad Clawson, work group 


chair, no conflict. 


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


conflict. 


MS. BALDRIDGE: Sandra Baldridge, 


petitioner. 


MR. BEATTY: Ray Beatty, former Fernald 


worker. 


MS. KENT: Karen Kent, O-R-A-U, no 


conflicts. 


MR. HINNEFELD: Stu Hinnefeld from 


NIOSH/OCAS, and I am conflicted having worked 


in management and salaried positions in 


Radiation Safety and Health and Safety 


departments at Fernald. 


MS. HOFF: Jennifer Hoff, ORAU team, no 


conflicts. 

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MR. LEWIS: Mark Lewis, ATL International 


Outreach Specialist, no conflicts. 


 DR. WADE: Okay, let’s go out to the 


telephone and start with members of the NIOSH 


and ORAU team. Please identify yourselves. 


MR. FAUST (by Telephone): Leo Faust, ORAU 


team, no conflict. 


MR. POTTER (by Telephone): Gene Potter, 


ORAU team, no conflict. 


MS. BRACKETT (by Telephone): Liz Brackett, 


ORAU team, no conflicts. 


 DR. WADE: Other NIOSH/ORAU team members? 


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


NIOSH Director’s Office, no conflicts. 


 DR. WADE: SC&A team? 


MS. BEHLING (by Telephone): Kathy Behling, 


SC&A, no conflict. 


 DR. WADE: Any other SC&A team members out 


on the phone? 


 (no response) 


 DR. WADE: How about other federal employees 


who are working on this call? 


MR. WOOLS (ph): Jessie Wools, Senator 


Voinovich’s office. 


 DR. WADE: Welcome. 

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MR. KOTSCH (by Telephone): Jeff Kotsch, 


Department of Labor. 


 DR. WADE: Welcome, Jeff, as always. 


MS. HOMOKI-TITUS (by Telephone): Liz 


Homoki-Titus, HHS. 


 DR. WADE: Good morning, Liz. 


Other feds working on this call? 


 (no response) 


 DR. WADE: Are there any other 


representatives of members of Congress on the 


call? 


 (no response) 


 DR. WADE: Workers, petitioners, their 


representatives? 


 (no response) 


 DR. WADE: Is there anyone else on the call 


who would like to be identified? 


 (no response) 


 DR. WADE: Okay, just a little bit about 


phone etiquette. We were doing real well, but 


we slipped on a call recently. So please 


again, mute if you’re not actively engaged in 


a discussion. If you are engaged in a 


discussion, try and use the hand set if at all 


possible. It cuts down on background noise. 

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And be very mindful of your environment and 


what happens if you put a call on hold. We 


were inundated with background music the last 


time. 


And please be aware of the fact that 


what might be commonplace noise to you can be 


very disruptive to the work group in trying to 


do its business. I think it’s good that we 


open these calls up to any and all and give 


them telephone access, but please ensure that 


we can continue to do that by exercising due 


caution in terms of how you monitor the 


environment around you. 


Let me ask if there are any other 


Board members on the call aside from Mark and 


Robert Presley. 


(no response) 


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


the Board, and that’s appropriate for us to 


conduct the business of the work group. 


I guess, Brad, it’s yours. 


INTRODUCTION BY CHAIR
 

DR. MAURO (by Telephone): Brad, this is 


John Mauro. I just joined you late. I’m 


sorry for being a few minutes late, but I just 

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want to let you know I’m on the line also. 


 MR. CLAWSON: Thank you, John, we appreciate 


that. 


At the last meeting I believe that we 


finished up with 4.3, at 4.3. So we’re going 


to start off in the matrix at 4.3-1, and I’ll 


turn it over to Hans. 


FINDING 4.3-1
 

DR. BEHLING: Let me ask Mark, since you’re 


on the phone, if you had anything that you 


wanted to discuss prior to starting with 4.3. 


I know we’ve indicated on a couple issues, and 


I just wanted to be sure before we start 


whether or not you had some outstanding 


issues, action items that you wanted to 


discuss prior to starting at 4.3, Mark. 


 (no response) 


DR. BEHLING: Mark Griffon, are you on the 


phone? 


 (no response) 


 DR. WADE: Might be muted. 


DR. BEHLING: Hello? 


 (no response) 


DR. BEHLING: Well, okay, let me just 


perhaps speak in his behalf. I think last 

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time we talked about something that involved 


the very last finding, 4.2-3, which involved 


the radon release model for the K-65 silos. 


And I’m not sure whether or not we had asked 


NIOSH to revisit that issue looking at 


basically the disequilibrium between Radium226 and the two daughter products and perhaps 


come up with a revised estimate about annual 


releases. And I’m not sure whether you’ve had 


a chance to look at that at this point. 


MR. GRIFFON (by Telephone): Hey, Hans, this 


is Mark Griffon. I’m sorry. I went to pick 


up the handset and lost the call accidentally. 


You were asking me something. 


DR. BEHLING: You and I had discussed a 


couple items in preparation for this meeting, 


and I wasn’t sure whether you wanted to 


perhaps discuss some of those, a couple of 


those items before we get started at 4.3 


because that’s --


MR. GRIFFON (by Telephone): Well, my, I 


mentioned it to Brad, I talked to Brad earlier 


this morning, and my sense was why don’t we go 


through the rest of the matrix and get through 


it one time, and then maybe come back if we 

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have time at the end, if that would be all 


right, Hans. 


DR. BEHLING: That’s fine. That’s fine. 


MR. GRIFFON (by Telephone): Just so we have 


one pass through the entire matrix. 


DR. BEHLING: Okay then, I guess we’ll start 


at 4.3 which in the report that I submitted 


starts at page 49. And the issue there is one 


of the model that assigns a maximized internal 


exposure of 1,050 MAC hours for thorium as a 


default value. Now I’m not sure, and I’m 


talking now to Mark Rolfes, whether or not 


that has been also changed. 


MR. ROLFES: Well, that certainly is in the 


process of being changed. That was what we 


believed the claimant favorable default at the 


time when we had a push to get the technical 


basis document out to use for dose 


reconstructions. We now have a much more 


comprehensive dataset process knowledge of the 


thorium processes, the time periods that it 


was processed, the areas and the air 


concentrations associated with that. 


So we are going to be using a more 


detailed approach to assigning thorium 

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exposures to individuals rather than a default 


1,050 MAC hours. So our approach that we will 


be using now for the early time period will be 


based on air monitoring data associated with 


the processes. And in the more recent time 


periods the mobile in vivo results will be 


used as well. 


DR. BEHLING: And when will that revision, 


or in what form will that revision take place, 


that will be part of a revised TBD? 


MR. ROLFES: I believe we can separate that 


out in a white paper. I believe that’s what 


we’ve agreed to do. So we will --


MR. RICH: The TBD is in revision now. 


MR. ROLFES: The TBD is, in fact, in 


revision as well as we speak. So I believe we 


had agreed to pull the thorium portion out as 


a white paper for the Advisory Board members. 


DR. MAKHIJANI: Can you describe the 


conceptual approach at least that you’re 


taking? How are you taking into account the 


high episodic air concentrations of thorium 


like half a gram per cubic meter that has been 


documented? 


MR. ROLFES: Well, we have because we do 

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have data for that. We will be giving credit 


to those high airborne concentrations. We 


have a distribution of thorium air 


concentrations for the early time period. I 


believe, is it about 3,000 air monitoring 


results that we have for the early time 


period. And so we have quite a bit of data 


that we feel is going to provide a good 


distribution of the air concentrations to 


which people were exposed. 


Now, furthermore, when we do have 


these higher concentrations, we are not 


assuming any credit for respiratory 


protection. We are not reducing air 


concentrations based on particle size 


distributions because many of the particles 


which were airborne were not respirable size. 


And plus, we are also assigning a 2,000 hour 


per year exposure to thorium for an entire 


year as a chronic exposure. So we feel that 


what we are doing is certainly very claimant 


favorable and will be a bounding analysis of a 


person’s exposures to thorium. 


DR. MAKHIJANI: I guess I didn’t address my 


question well. How does a distribution of 

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3,000 air samples take care of an episodic 


exposure to an individual? 


MR. ROLFES: Well, we could look at that 


specific air sample, but we wouldn’t assume 


that that person was exposed to that high air 


concentration for 2,000 hours per year. 


DR. MAKHIJANI: Yeah, no, no. That’s 


exactly the problem that I’m talking about. 


The distribution doesn’t take care of that, 


and we don’t know the names of the individuals 


who were involved. We should just wait for 


the --


DR. BEHLING: I think that’s going to come 


up in the next finding essentially because it 


does raise questions that you are addressing 


here. 


DR. MAKHIJANI: Okay. 


DR. ZIEMER: One other question, this is 


Ziemer. What years are covered by this set of 


samples? 


MR. ROLFES: This would be from, I believe, 


beginning in 1953 through -- well, for the air 


monitoring data? Is that what you’re 


referring to specifically? 


DR. ZIEMER: Well, this thorium data that 

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you’re talking about. 


MR. ROLFES: The thorium air monitoring 


data, the majority of it is in the early time 


period because that’s what we had focused on 


because that was prior to the time period 


where we had the mobile in vivo radiation 


monitoring lab results in ’68. So we focused 


our initial data gathering on the time period 


from, I believe, ’53 through ’68. And we are 


revisiting those records to make sure that 


we’ve captured all the thorium air monitoring 


data that we can. We are also looking for the 


more recent time period as well. 


 MR. CLAWSON: Well, this thorium data that 


you’ve got, this is Brad, is this general area 


or is this personnel or where was this sample 


on the O drive? I’m just questioning some of 


the, how were they being taken? 


MR. ROLFES: There’s a sampling of both 


breathing zone samples as well as general area 


air monitoring results. So there’s a wide 


distribution of air monitoring results that 


are taken associated with the individual’s 


breathing zone while he was working with the 


materials. And there are also general area 

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plant monitors distributed throughout the 


plants and processing areas. 


MR. MORRIS: This is Bob Morris. There’s a 


third set of data that we didn’t use which is 


the process sampling where the intent was to 


get inside the (unintelligible) or right at 


the point of generation to actually capture 


the worst concentration that existed. And so 


that the plant had three sampling protocols, 


general area, breathing zone where the sample 


was held near the person’s face, and then the 


process samples. We used the, we excluded the 


process samples from these calculations and 


used the general area and the breathing zone 


samples to represent the intake rates. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro. Quick question. When you provide 


the white paper, will there also be these 


datasets, the 3,000 air sampling measurements, 


put on the O drive as supporting material? 


MR. ROLFES: They’ve already been provided. 


DR. ZIEMER: They’re there, John. 


DR. MAURO (by Telephone): Thank you. 


MR. RICH: This is Bryce Rich. We might 


just mention again that, I think Mark 

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mentioned at the last meeting, that we have 


become aware through additional research that 


there were a number of careful attempts to 


look at intake or deposition through a thoron 


breath analysis and through accounting by 


Hirsch and others throughout this early 


period. And the results of those studies 


indicated that the body depositions of the 


highest exposed people were less than maximum 


permissible lung burdens at that time. 


MR. ROLFES: Correct, thank you, Bryce. I 


did forget about that. I wanted to point that 


out, I guess, as we moved through the matrix. 


I figured we’d be discussing thorium for quite 


awhile, and it is very important to note that 


several individuals from Fernald who had been 


previously exposed or currently exposed to 


thorium in the process at Fernald were sent 


offsite because the Health and Safety Division 


or the Industrial Hygiene and Radiation 


Department wanted to characterize who had been 


exposed to thorium and how much thorium the 


body was retaining. 


So I believe beginning in 1961 there 


were a couple of individuals that were sent to 

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the University of Rochester to Dr. John 


Hirsch, I believe was his name. And he had 


done in vivo counts, lung counts, of the two 


individuals and was unable to detect any 


thorium in the individuals’ bodies at that 


time. 


So he had also requested thoron breath 


samples from the individuals, and he was able 


to detect some thorium progeny, some thoron. 


And the amount he interpreted was about I 


believe, let’s see, was about 1.6 picocuries 


per liter of thoron which was the higher 


result. From that he said that that was 


approximately a ten percent of maximum 


permissible lung burden. 


So that was the first of a series of 


studies where individuals from Fernald who had 


previously not been monitored in vivo for 


thorium exposures were, in fact, being 


monitored. Now the second was I believe a 


couple years later, and I’d have to take a 


look back at my notes, but another handful of 


individuals was sent to Wright Patterson Air 


Force Base who had an in vivo set up, and I 


believe those same individuals also gave urine 

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samples to determine whether they could detect 


thorium in urine using neutron activation 


analysis of their urine. They were able to 


detect some thorium in one individual’s urine. 


I believe a handful of people were 


also sent to Y-12, and I believe some of the 


same individuals that had gone to Wright 


Patterson Air Force Base also were sent to Y12. Those individuals at Y-12 were given lung 


counts as well, and I’d have to take a look 


back at the data, but I do believe they may 


have detected some thorium in the one 


individual, but it was still less than the 


maximum permissible lung burden. 


MS. BALDRIDGE: Question, Mark. Did the 


Hirsch report say what means they used to try 


to determine whether there was thorium? 


MR. ROLFES: Yes. 


MS. BALDRIDGE: And are there other methods 


available today that would have been more 


precise? Is it possible that there was 


thorium present, that the means that they used 


to try to detect it didn’t work? 


MR. ROLFES: Sure. The NIOSH approach that 


would be taken if there was a sample result 

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that didn’t have a detectable amount of 


thorium, NIOSH would assume that there was a 


missed intake that would have been incurred 


but not detectable by the equipment at the 


time. So it is very possible. We’re not 


saying that there was no thorium exposure. 


What we would interpret this as is that there 


could have been exposure, but it was less than 


the detection limit. 


MR. RICH: Mark, you probably have to say in 


addition that we have a high level of 


confidence as a result of these studies that 


the air sampling default values for intake are 


enormously high. 


MR. ROLFES: Yes. They certainly are. 

DR. ZIEMER: Compared to the in vivo 

results? 

MR. RICH: Yes. 


MR. ROLFES: Correct, yes, probably a couple 


of orders of magnitude higher than the actual 


in vivo data. 


DR. BEHLING: When we talk about the Hirsch 


study that he attempted to actually establish 


the in vivo body burdens of thorium, which 


kind of technique did he use? I mean, it 

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wasn’t until years later I assume that the 


mobile in vivo laboratory analysis was 


conducted, and that’s a fairly sophisticated 


system which leaves me to question whether or 


not this individual, Dr. Hirsch, had the 


capability of doing in vivo studies. 


MR. ROLFES: Well, he was at the University 


of Rochester. I’d have to take a look at the 


data to make a determination on what he did. 


But just given the fact that the workers were 


sent there for counts, and that there were no 


detectable quantities of thorium in the 


workers, he didn’t believe that that was as 


sensitive a measurement as possible. So he 


used another method, the thoron breath 


analysis, and was able to detect a little bit 


of thoron indicative of a thorium exposure. 


DR. BEHLING: But you mentioned that he had 


concluded that the body burden was less than 


ten percent of the maximum permissible lung 


burden. And that means he must have 


understood how to convert thorium, thoron in 


breath to body burden. And again, that 


requires a very detailed understanding of the 


biokinetics, retention and elimination rates 

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and all these things which, again, I don’t 


know if Dr. Hirsch is a medical doctor, and 


not to speak disparagingly of the medical 


profession, but my experience has been that 


they understand very little about these very 


esoteric items and issues that are coming into 


play here. 


MR. ROLFES: Dr. John Hirsch was very 


involved in other radon breath analyses. He 


was very involved at the University of 


Rochester and had quite a detailed knowledge 


of bioassay methodologies. He did discuss 


some of his assumption in the report that I 


have regarding the thoron breath analyses, and 


I’d be happy to provide that. I actually do 


believe I have provided it to the Advisory 


Board members. 


MR. RICH: They did have a major thorium 


study going on. That’s where the genesis of 


this, the bioassay work was started there. 


DR. MAKHIJANI: It might be useful to look 


at the caveats that they put on their own 


measurements. Here’s what they said. I’m 


reading from a document, quote, “Results of 


these tests were interpreted as showing not 

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more than five to ten percent of a permissible 


body concentration of thorium.” That’s what 


we were talking about, right? 


Continuing with the quote, “In 


arriving at these results, certain assumptions 


had to be made concerning the presence of 


radium daughters with the thorium in the lung 


and the percentage of the total thoron 


generated in the lung which is exhaled in the 


breath. The breath thoron technique, if it is 


to be useful, clearly requires some 


refinement.” So they’re quite sure, this 


seems to indicate that they didn’t think this 


was very useful, and that to be useful it 


would require some refinement. At least 


that’s how I read the English. Maybe English 


is a complicated language so probably other 


people may read it differently. 


They put together a pretty cheap 


apparatus for doing this which is described a 


little bit here. So I think it would be 


worthwhile to note, it’s at least worthwhile 


to note that these people were skeptical about 


their own measurements and their utility in 


saying how much thorium was in the body. 

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DR. BEHLING: And am I correct in concluding 


that your assumption was that the source term 


was strictly radium in the lung as the source 


term for the thoron that’s being exhaled? 


DR. MAKHIJANI: I haven’t read the whole 


report. 


DR. BEHLING: And there was no other source 


term in the body? 


MR. ROLFES: I think it’s very important to 


note also that in the same report it does say 


a second question arises as to the precision 


of the thoron measurement. An error here 


would be in the nature of an overestimate. 


DR. MAKHIJANI: Well, clearly, this requires 


some very careful analysis, and it would be 


useful I think to have more details on their 


equipment and their own assessment of their 


accuracy. 


MR. RICH: Could I just say this was a 


quality program at the leading edge of 


research and development in this particular 


area. We’re not indicating that that is going 


to be used for dose reconstruction. It just 


is a valid measurement to indicate that the 


deposition in the lung was not extreme as the 

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air sampling, the use of air sampling results 


will, we’re sure, will give a bounding that 


will probably be in the couple of orders of 


magnitude high. That’s all we’re saying. 


DR. BEHLING: And how would these 


individuals who were assessed by Dr. Hirsch 


selected for this evaluation? Is there, I 


haven’t seen the paper so I’m talking 


basically on a blind level, but how were these 


individuals selected? Were these people who 


were considered at the top end of the exposure 


group? 


MR. ROLFES: Yes, I do believe so. One was 


a chemical operator, and I believe the both of 


them may have been chemical operators. I know 


the one individual was involved in the early 


production runs in 1954 in Plant 9. 


DR. MAKHIJANI: Well, this paper is from 


1965 and to the extent that I’m familiar with 


the thorium air data, and I went through all 


3,000 samples, the highest measurements of 


thorium were in the ’50s and early ‘60s by far 


to my recollection. So it could be easily two 


orders of magnitude higher. 


So you’re talking about, I think we’re 

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comparing apples and oranges. We have two 


individuals from 1965 with a method that was 


regarded as questionable by the people who did 


it themselves that are being talked about 


bounding doses for air concentrations for the 


‘50s and ‘60s that were one or two orders of 


magnitude higher than were measured in the 


mid- to late ‘60s. Well, it might be useful 


to see the white paper and what element of 


temporal analysis there is in the various 


periods within the air monitoring. 


DR. ZIEMER: I agree we should look at the 


paper, but I also would point out that those 


caveats are not any different than almost any 


scientist puts in this kind of a paper because 


you always have those issues. It’s always 


based on what assumptions you’re using so that 


does not imply that these are not useful. I 


think your conclusion, Arjun, may be 


questionable there. It does not imply that 


they did not believe that their method was 


useful. I think it’s the normal caveat 


scientists put in. I would do that. Hans 


would do that. You would do that. 


DR. MAKHIJANI: I don’t think I had a 

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conclusion. I more put a question on the 


table that as to what interpretation of a 


paper in which people had reservations about 


their own measurements. That was point number 


one. 


DR. ZIEMER: No, no, I’m saying that does 


not imply reservations. That’s what I’m 


saying. That’s the usual caveat. 


DR. MAKHIJANI: If it is to be useful, I 


would not put, you said what I would do in a 


paper that was I was writing. If I had made a 


good measurement, I would not put a caveat if 


it is to be useful if I were confident that 


the --


DR. ZIEMER: No, no, I think you would put 


the limitations of that reading. All readings 


have limitations. All readings do. 


DR. MAKHIJANI: Right, but if the limitation 


if it is to be useful, I believe that it 


deserves careful scrutiny (unintelligible) its 


utility. 


DR. ZIEMER: Oh, I don’t disagree with that. 


I’m just saying all measurements have their 


limitations and you need to know what they 


are. And then you can determine whether you 

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can use that for bounding. 


DR. MAKHIJANI: And the more important 


point, conclusion, that I’m putting forward, 


I’m not putting forward a conclusion about the 


utility of this, is that you’ve got people 


from 1965, two individuals, and a claim has 


been made --


MR. ROLFES: Nineteen sixty-two, I wanted to 


correct. 


DR. MAKHIJANI: -- claim has been made that 


they are bounding. And we need to know what 


air concentrations they were exposed to 


because the air concentration variations in 


the ‘50s, from ’54 to ’61 as I remember in 


that period were much, much higher than in 


later periods. Now if we can establish what 


these people were exposed to in the workplace, 


there would be some basis to say that these 


results show that the air concentrations are 


bounding. But I think unless that can be 


done, I would question whether these two 


individual measurements, even if they were 


valid, meant anything. 


DR. BEHLING: I think the issue is one of 


timing, too. The fact that these potentially 

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large exposures may have taken place years 


earlier, to what extent can you assess that 


years later by a exhalation of thoron. 


Obviously, even a highly insoluble material 


will ultimately be purged from the lung; and 


therefore, the question is how do you account 


for the time element here. If their exposures 


took place in the middle ‘50s or early ‘50s, 


what is the validity of a 1961, ’62 


measurement, and how do you account for that 


time gap? 


MR. ROLFES: Was that a question or --


DR. BEHLING: No, it’s just a question that 


again, what is the validity of using that data 


in trying to establish a bounding value? 


MR. ROLFES: Our objective from this is just 


to show that we feel that there was a concern 


in the workplace that these individuals had 


previously been exposed to thorium. And this 


is an attempt, and it was a good attempt in my 


opinion, to determine if there were any 


significant exposures to thorium previously. 


MR. RICH: They did make an effort to choose 


those that had been exposed, before the 


special study, to choose those that had been 

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the highest exposed during the 1952 period. 


DR. MAKHIJANI: ‘Sixty-two. 


MR. RICH: ‘Fifty-two, those that had been 


exposed at the highest levels. The people at 


the plant made the decision to send people, 


operators, chemical operators, for analysis 


that had the highest potential exposure 


stemming back from the early period. 


DR. MAKHIJANI: I didn’t understand the 


reference to ’52. I thought thorium started 


in ’54. 


MR. ROLFES: We’re referring to ’54, ’55 


time period is what we’re referring to. 


MR. RICH: I misspoke, ’54. 


And in addition to that at the very 


early time it was well known that thorium, 


where it was inhaled, it did not, it’s very 


difficult to use urinalysis. It did not 


become systemic to the standpoint of being 


excreted as uranium and other materials were. 


They knew that, and as a consequence they 


knew, Hirsch and others at the university had, 


the front end of the studies in relationship 


to thorium bioassay and other processes. 


That’s where it began. 

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DR. MAKHIJANI: I compiled the air 


concentration data in the review of the 


Fernald TBD that I did. Obviously, you have a 


lot more data, but in the 1950s you had some 


data in Plant 9 that were as low as one times 


MAC, four times MAC and then a hundred, 353, 


3,500 times MAC. It’s all over the map. 


Whereas, the range in the ‘60s was a 


little bit lower. There were some high 


samples in the ‘60s, but as I say, you have to 


know, you can’t just presume that they were 


sending the people who were exposed to the 


highest concentrations because the 


concentrations varied from four to 1,260. You 


have to know which worker it was, and when 


they were exposed. 


MR. RICH: They were a relatively small 


group of workers that were working in the 


thorium processes. 


MR. ROLFES: A very small population of 


workers. 


DR. MAKHIJANI: Do we know who they are from 


the ’54 to ’68 period? 


MR. RICH: We have listings of them that 


identifies them as potential thorium workers. 

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MR. ROLFES: And there was a study that was 


done before the mobile in vivo radiation 


monitoring lab came in at Fernald in 1968. 


There was an attempt to determine who had 


previously been exposed to thorium. And those 


individuals that had been exposed to thorium 


were some of the very first people to be 


counted in the in vivo lab. 


DR. MAKHIJANI: Well, I guess I just have to 


look at the paper. 


MR. SCHOFIELD: What about did they account 


for the crafts that might be in the vicinity 


during these high concentrations? Were they 


also monitored? 


MR. ROLFES: During the time period when the 


mobile in vivo unit did come in, yes, there 


were some individuals from crafts who were 


potentially exposed. They were counted. Not 


as routinely as the chemical operators, but, 


yes, they still were counted. 


There are some notes on some of the 


air monitoring results from the early time 


period that, for example, our general area air 


monitoring results associated with like a 


guard station. And they said that this is a 

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general area air monitoring result for the 


guard, but it’s probably representative of the 


guard’s breathing zone. 


So he wasn’t directly involved in the 


processing but was potentially exposed to 


background, I guess elevated air 


concentrations. They just note that on a lot 


of the air monitoring results. 


MR. MORRIS: Just a second. I’ll give you a 


site research database reference number for 


this document I’m going to refer to. Bob 


Morris, here. 


It’s a letter from R.C. Heatherton to 


all employees. It’s essentially introducing 


the first use of the mobile in vivo lung 


counting system, and he says, “Each employees’ 


potential for inhaling uranium or thorium 


determines if and how often they will be 


counted. For example, a water plant worker’s 


potential for exposure is practically nil, and 


they are not included in the routine in vivo 


counting program. 


Chemical operators who work daily with 


uranium or thorium have the greatest chance of 


accidentally inhaling these materials and are 

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counted at least once each year. Workers with 


only a slight possibility for such exposure 


such as mechanical employees are monitored 


about every other year. 


Of course, any employee regardless of 


classification would be counted if air dust 


data or urine results indicated elevated 


exposure levels. If an employee was involved 


in an incident which might have caused 


significant exposure to uranium, airborne 


uranium or thorium, they would also be 


counted.” 


He goes on to cite the recounting 


protocol, what would prompt a second recount. 


But this was a letter to all employees, 


introducing a new technology into the system. 


So I think you can find more details and for 


the record in just a minute I’ll tell you what 


the site research database number was on that. 


MR. KISPERT: What’s the date of that 


letter? 


MR. MORRIS: It’s not dated specifically, 


but it’s clear that it was early in the 


process, ’67, ’68. 


MR. RICH: It was preliminary to the mobile 

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laboratory, so it would be in the mid- to late 


‘60s. 


MR. ROLFES: Arjun, you can address your 


question about the episodic (unintelligible). 


DR. BEHLING: The episodic issue we can 


address it in Finding 4.3-1, and if we’re 


ready to go on we can discuss Finding 4.3-1 


which is described on page 52 of SC&A’s 


report. And it is basically a discussion that 


is not confined to thorium, but it’s a generic 


issue which at this point obviously has some 


real implications because before the in vivo 


measurements were taken, it is the air 


monitoring that is, in fact, going to be used 


for dose reconstruction. 


And 4.3-1 discusses the generic 


limitations on certainly associated with air 


sampling. And I provide a significant number 


of attachments and examples that define the 


variability of air sampling data as a function 


of time and location, time and space. And 


also the issue of using general air sampling 


as opposed to breathing zone. And on page 52 


of the report I provide some data. These are 


empirical data that were procured at the 

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Nuclear Materials and Equipment Corporation, 


NUMEC, back in that timeframe. 


And what it shows is that the ratio 


between general air and BZ is one that is not 


a static ratio but actually increases as the 


air concentration increases. And that’s 


likely due to the fact that when you have 


discrete source terms, Mark had previously 


mentioned the issue of breathing zone for 


guard shacks. 


Obviously, one could make a reasonable 


assumption that when the source term is at a 


great distance from the people that you’re 


trying to monitor, a general air sample is 


very accurate in defining a breathing zone 


because obviously it’s not going to vary as a 


function of (unintelligible)square or some 


other value which is obviously the case when 


you deal with work location such as a hopper 


and so forth that is a source term for 


breathing zone air sample and having a general 


air sample that’s 20 feet removed. 


We know from empirical studies that 


even five feet can make a several fold 


difference in air concentration. What this 

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whole discussion’s about, and you will see 


some examples that I cite on page 52, 54 and 


in attachments, is how variable these things 


are. And it also touches on episodic events 


such as obviously radiological incidents. 


And I give examples where on page 53, 


for instance, where you have air 


concentrations for various discrete locations 


over a 30-minute time interval. And it goes 


from 355 dpm per cubic meter to 140,000 over a 


half hour timeframe. And these are things 


that you see throughout when you look at the 


air monitoring data. 


And even when you look at BZ samples, 


oftentimes a person will take three 


consecutive measurements at the same location 


for the same individual, and we’ll see a high 


and low for three samples that are orders of 


magnitude apart. And so the question comes 


into play which numbers are accurate and how 


do you apply that to people whose work 


location or job location you’re not even sure. 


We have roving maintenance people. We 


have people who go from one location to the 


other. And how do you assign air sampling 

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data under these circumstances where we have 


already problems associated with even defining 


what the air concentration is in time and 


space, but you don’t even know who these 


people are especially when we’re dealing with 


roving maintenance people and laborers who 


were assigned almost on a daily basis to 


different jobs. 


So the generic question here is how 


well do you define an internal exposure based 


on thorium air sampling data that mixes BZ 


sampling with general air sampling. And over 


time and space you have to somehow or other 


get your hands around a bounding estimate when 


you don’t have a clue as to who these people 


were and where they worked in time and space. 


MR. ROLFES: We certainly feel that our use 


of these air sampling results will provide a 


bounding analysis of the potential exposures 


given the additional process knowledge that 


we’ve obtained based on records retrievals, 


document searches, worker interviews. We also 


know that based on the processes these were 


typically campaign-type processes rather than 


continuous production operations. 

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So by us using these higher 


concentrations for 2,000 hours per year 


without respiratory protection factors being 


credited and without any other adjustments to 


the air sampling data, we feel that we are 


assigning a very claimant favorable intake by 


assuming that this concentration existed for 


2,000 hours per year. Based on information 


some of these operations lasted a day, so by 


us assuming that an individual was exposed to 


2,000 hours per year at a high air 


concentration is very claimant favorable. 


Getting back to what we were 


discussing before about the thorium bioassay 


investigations I have a letter dated November 


2nd, 1965, and this was in regards to the 


people that were chosen for quantifying 


thorium exposures in vivo. It’s titled 


“Thorium Bioassay Investigations”, and it 


says, “During the past year there has been a 


small thorium operation at the pilot plant in 


which about 25 people have been receiving 


exposure to airborne thorium. It’s understood 


that there is a good possibility that there 


will be a larger operation in the refinery...” 

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and there’s some discussion about crushing 


thorium in the plant. 


Let’s see, let me get on to, they had 


chosen two of the foremen who were employed --


that’s the earlier time period. This refers 


back to the earlier total body counting that 


was completed. The two individuals that were 


sent to the University of Rochester, two 


foremen, were employed in Plant 9 thorium 


operations were counted in the whole body 


counter at the University of Rochester on 


November 30th, 1962. At that time Dr. Hirsch 


interpreted the body results to show that 


there was not a permissible concentration of 


thorium in either of the employees. 


It goes on to say if the results show 


that these persons had a detectible quantity 


of thorium in the body, we would want to have 


other persons with thorium exposures counted 


with the possibility that we would eventually 


count all of our employees who are exposed to 


thorium. This would involve a total of about 


30 people, it appears, or 80 I think. But it 


appears to be 80 people. So it does show 


there was some attempt to quantify historical 

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thorium and current thorium exposures. 


MR. BEATTY: May I ask a question, please? 


This is Ray Beatty. You mention in that story 


that this was two supervisors tested. I 


really question why would they send 


administrative personnel when the chemical 


operators and maintenance people would have 


been the most highly likely to be involved in 


an incident at work. 


MR. ROLFES: The one individual I know was 


in Plant 9 and was associated with the thorium 


blender operation, the explosion that occurred 


in Plant 9. He was one of the first 


individuals that had gone back into the area. 


MR. BEATTY: My concern would be that the 


persons that were right there at the incident 


would be the ones that should have been 


tested. And I hear this a lot from claimants 


that supervisory personnel being in an office 


setting most of the time or administration 


areas, well, I just see a little problem with 


it. 


DR. BEHLING: I guess, again, the question 


is obviously in the process of revising the 


TBD and I guess we’re going to be looking to 

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you to tell us when you finalize some of these 


issues in establishing a new database and 


drawing your conclusions from some of that 


data. And can we expect to see the revision 


to the TBD any time in the near future? 


MR. ROLFES: Bryce, do you have a feeling 


for the time period that we’ll be able to 


produce the white paper? 


MR. RICH: The time period, a couple weeks I 


would imagine. We’re in the final phases I 


think even though we’re still developing 


information. That’s the reason I hesitate 


just a little bit. 


MR. ROLFES: But, yes, as soon as it’s 


available we will make it available to the 


Advisory Board work group members. 


DR. MAKHIJANI: Including the whole model 


and all the information. Are you still 


researching information and doing interim 


white paper or --


MR. RICH: The answer is yes. 


DR. MAURO (by Telephone): Mark, this is 


John. I recently reviewed some work dealing 


with Bridgeport Brass. And I was looking at a 


similar situation where you have air sampling 

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data, and you’re going to use that data as 


your primary basis for constructing exposure 


matrix. I bring this up just because I notice 


certain approaches that were taken there have 


raised some questions in my mind, and I 


thought may be valuable to alert you at this 


time some of the things that I and we would be 


looking at. 


And I noticed in the Bridgeport Brass 


there was a lot of pooling of air sampling 


data whereby you may have taken data from 


several years and across operations and from 


that built a distribution and selected the 


upper 95th percentile. 


Now one of the concerns is that when 


you, these datasets that you work with -- and 


it sounds like that, Arjun, you’ve already 


looked at some of this -– to what degree do 


you try to construct some granularity where 


your distributions, the datasets, are grouped 


by time, campaign, location, type of 


operation, and have different distributions 


for these different, I guess, segments whether 


it’s in time and operation. 


And then from there select the 

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percentile that you’re going to treat as being 


your bounding number for different groups of 


workers. Could you give, you may have already 


covered this, but have you broken it down in a 


finer way or used pool data? 


MR. ROLFES: Bob. 


MR. MORRIS: Bob Morris. The data for 


thorium air sampling from in the ‘50s and ‘60s 


is broken down by individual calendar year. 


We could have in some years subdivided two 


different operational locations, but in most 


years the operations were focused at one 


operating location. So I suppose we could 


have subdivided two or potentially three of 


the years into different operating locations, 


but we chose not to. Now that’s a choice that 


could easily be reversed if you think that’s 


necessary, John. 


DR. MAURO (by Telephone): Well, no. I only 


bring it up, I’m not saying it’s necessary, 


but when you pool data, whether it’s, you 


know, for example, in this case it sounds like 


you are breaking it down by time. But if you 


are taking data from a number of different 


operations and you pool it, what happens is 

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that would work if you knew your workers that 


were working were, in fact, being cycling 


through these different operations. 


So therefore, but if it turns out one 


particular operation might be a little bit 


more severe, and this goes without speaking to 


the incident issue. That’s, of course, a 


separate issue. I’m looking at more of a 


chronic situation and you’re going to try to 


place a bound. The degree to which your white 


paper addresses the need for granularity in 


different job locations and job types in a 


given time period, I’m not saying that you 


need to break it up that way, but if you don’t 


break it up that way, a case needs to be made 


that you have, your distribution that you are 


using does, in fact, reflect what would be 


considered the upper end operation that took 


place. 


So I just say that because later on we 


are going to come back to this when we see the 


white paper. I know this is going to be in my 


mind when I look at that data. 


 MR. CLAWSON: I had one question. When 


we’re talking about the TBD is being rewritten 

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and so forth and then the white paper, is this 


what we’re going to receive back from it or is 


this two different --


MR. ROLFES: Can you repeat that one more 


time, please? 


 MR. CLAWSON: Well, we’ve been discussing 


that the TBD’s going to be somewhat rewritten, 


and you’re going to produce that to us in a 


white paper. 


MR. ROLFES: That’s correct. We’re going to 


separate the thorium exposure model 


essentially out from the TBD so that we can 


get it to the Advisory Board members in 


advance of the technical basis document. It’s 


typically a little bit easier to get pieces 


out to the Advisory Board rather than the 


entire document as a whole. 


 MR. CLAWSON: On the sampling of this -- and 


forgive my ignorance and so forth -- but 


whenever we pull air samples and so forth like 


that we have a calibrator that’s telling us 


exactly what the air flow is. That’s a prime 


thing, and we really haven’t had calibrated 


instruments until about ten years ago. And if 


you go back and look at our data, it could be 

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off. We were using a vacuum cleaner. What 


type of system was being set up that we’re 


relying on these air samples to be correct? 


And where did they come up with the number for 


the air? 


MR. RICH: Even in the very early days of 


the, you know, using the vacuum cleaners, we 


used Filter Queens, for example, in the very 


early days, but we did air flow measurements. 


In other words we had, and we were aware that 


the air flow at the beginning of the period 


was considerably less as the filter low. And 


so there was a measurement pre- and post-


sample. And during the early days we 


averaged. We took the average flow. So even 


in these early days there was an awareness and 


a full measurement made on the air sampling 


devices. 


DR. MAKHIJANI: Are you talking about Idaho 


or Fernald? 


MR. RICH: Yes. 


DR. MAKHIJANI: Both? 


MR. RICH: Idaho I know about and Livermore 


and the other places I’ve worked at. 


DR. MAKHIJANI: Well, I certainly recall 

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stack monitors that had not been calibrated at 


Fernald for decades. This is from memory, but 


I would wager that it’s pretty good memory, 


and I would produce the document. 


 MR. CLAWSON: The reason I was wondering is 


I’ve been through the O drive and so forth on 


that, and I was checking. And it seems like 


they used one data point for all the air 


flows. And you can go from one sampling 


process to another and it’s going to be off. 


MR. RICH: Normally what they tried to do, 


for example, for constant air monitors or 


other devices, they tried to set them so that 


they sample at five cubic feet per minute as 


the air sampling rate for general air samples 


or one cubic foot per minute or whatever the 


air flow measurement is, they tried to tune 


the restriction so you get the air flow 


measurement that you desire. It makes the 


calculations easier. 


 MR. CLAWSON: And I understand that. My 


issue and my point that I’m trying to get to 


and especially even on these air samplings, 


breathing zone, whatever and so forth like 


that, you’ve got to assure the data integrity 

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of this. And just with my layman’s brain 


going through it, we’re using a set point 


there. And it seems like to me that it’s an 


over-bounding one. 


I’d like to be able to see where, you 


know, the post- and so forth because I’ve seen 


what you were talking about of checking what 


the air flow was. But I know that in my world 


it was not done that much. I guess I’m just 


looking at I want to make sure that if we’re 


going to be using this air sample data that I 


want to be able to make sure that it is 


correct and how it was done. 


MR. MORRIS: All you’re really talking about 


is an uncertainty analysis. Isn’t that right? 


This is just one of the parameters that goes 


into the final answer. It’s two liters per 


minute plus or minus a half liter a minute or 


five cubic feet per minute plus or minus one 


cubic foot per minute. I mean, fundamentally 


you’ve got a vacuum cleaner that’s got a fixed 


amperage going through it. And you’ve got a 


new filter because these were 30 minute long 


samples. 


So the reproduce-ability of a lot of 

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these systems is in favor of low uncertainty 


because a vacuum cleaner can never pull more 


than a certain amount. And with a new filter 


it’s going to have a certain amount of 


resistance to it. So the uncertainty may be a 


little bit less than you would begin to think 


off the top of your head. 


 MR. CLAWSON: I know you could take one, and 


you could take another one, and you could have 


a totally different sample. 


MR. MORRIS: How different is totally? Is 


it a factor of two or a factor of a hundred or 


a factor of a thousand? 


 MR. CLAWSON: There, now you’ve brought 


exactly what it is. 


MR. MORRIS: The answer is a factor of two. 


The physical hardware constrains that. It’s 


not going to pull like a jet engine if it’s 


got a 12-volt motor on it. 


 MR. CLAWSON: Let’s take and say you use a 


Filter Queen, and you use a shop vac. 


MR. MORRIS: Both pulling through the same 


filter? In fact they didn’t do that though. 


They used the same sampling equipment. You 


have procedures that showed the sampling 

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equipment they used. 


MR. ROLFES: There are procedures 


documented, and there is indication in the 


Industrial Hygiene and the Radiation weekly 


reports in that early time period that the 


various pieces of equipment were tested, 


calibrated, and there were quality control 


procedures in place. Also, on the air sample 


results that we have, we also do have 


documentation of the air sample volume that is 


pooled, the time that the sample was drawn, as 


well as the total counts and the counts per 


minute, and then a conversion to 


(unintelligible) per minute per cubic meter. 


 MR. CLAWSON: So you do have documentation 


showing that these were calibrated so that 


they were checking the air flows. 


MR. ROLFES: Yes. I don’t know if we have 


every report, but there are early reports that 


do indicate that the air samplers and other 


laboratory equipment was, in fact, calibrated. 


 MR. CLAWSON: What timeframe are we talking, 


the early or --


MR. ROLFES: Back in the early ‘50s. I know 


of ’53 off the top of my head so it’s very 

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close to the early time period. 


MR. RICH: Could I add just one other point? 


Hans, you mentioned the uncertainties 


associated with doing intake based on air flow 


our air sampling data. That’s well 


understood. Just as an example I remember we 


did a, we had a little contract to do some 


research and development for NRC. And one of 


the studies involved putting a breathing zone 


sample on both lapels of a welder that was 


doing some Plasmarc welding on a contaminated 


piece of equipment. And we got a factor of 


five difference on between the two lapels. 


So and for that reason there are 


enormous uncertainties associated with doing 


dose reconstruction or determining the intake 


and then the deposition of what stays in the 


body using air sampling data. We recognize 


that that is the least accurate. There’s 


enormous uncertainties. But -- and it’s been 


mentioned here, we’re not assuming taking 


credit for respiratory use. 


If you used any type of a respirator 


that uses a high efficiency filter, you get 


99.97 percent of filtering efficiency which is 

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three times ten to the minus four, not ten. 


And that’s at the low point, 0.3 microns. The 


filtering efficiency is higher on either end. 


And so as a consequence you got four as a 


magnitude conservativism if you’re wearing a 


respirator. I’m not assuming that they wore a 


respirator. 


And in addition to that the respirable 


particles in most operations you get a major 


share of the particulate distribution that’s 


non-respirable. And so as a consequence we 


will default to in vivo measurements where 


measurements are made that’s actually 


deposited in the body or it can be 


reconstructed by urine or fecal analysis which 


is a more direct measurement. 


Now what I would say that in using air 


sampling data to reconstruct intake, you’re 


generally going to come up significantly on 


the conservative side. And that’s the only 


thing that we’re saying here is that we feel 


that in these very early time periods, if we 


have a decent distribution of air sampling 


data, we’re going to err on, in a very 


conservative fashion. And that’s 

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fundamentally all I wanted to mention. 


DR. MAKHIJANI: Well, your conservatism 


about respirators would only be true if they 


were wearing respirators. 


MR. RICH: I said that already. 


DR. MAKHIJANI: Well, let me review, but 


lots of evidence that a lot of people didn’t 


wear respirators. Here’s a document from 


1954. 


MR. RICH: You’re assuming that they all ---


DR. MAKHIJANI: I’m not. This is an SEC 


thing that applies to any worker in the group, 


right? And here’s a document from 1954 that 


deals with respirators and also a particle 


size. It talks about thorium fumes so you 


could have some micron particles there. 


MR. RICH: Go on. 


DR. MAKHIJANI: Quote, “cutting thorium 


derby in half by hacksaw, the operation is 


done dry and releases a considerable amount of 


fume in the area. Saw operator was without 


any type of respirator.” Okay, so there is 


some evidence that respirators were used some 


of the time, and there’s some evidence that 


they were not used some of the time. So that 

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actually assuming no respirator use is not a 


conservatism, it’s simply applied to the 


manner of work of many workers and in many 


periods. 


Moreover, assuming that your applied 


micron particle size would not necessarily be 


conservative for thorium fumes when you’re 


cutting dry by hacksaw, and you could have 0.3 


or 0.4 micron particles. So I think, well, I 


guess I won’t say more. Maybe it’s necessary 


to see the white paper. How general area 


samples are handled. How fumes are handled. 


How particle sizes are --


DR. BEHLING: When respirators were used, 


obviously, I looked at a lot of memoranda that 


talked about the respirator issue, and again, 


I’m comparing it with today’s methodologies 


and protocols for assigning respirators where 


you fit test, where you clean these things to 


specification. 


And repeated memoranda talk about 


respirators that were so filthy that people 


didn’t even bother using them, and they 


clearly were not fit tested. They were not 


monitored for good seals and any of those 

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things. Today when you go into a radiological 


environment, a minor amount of one day or two 


days worth of facial hair is an issue that has 


you sending back to the bathroom for a shave. 


In those days I’m sure none of that existed. 


So you have to be careful about applying 


today’s standards to periods of time when 


people simply didn’t care. 


 DR. WADE: Question. 


MR. GRIFFON (by Telephone): Hey, Brad? 


 DR. WADE: Hold on, Mark. 


MS. BALDRIDGE: One of the documents that I 


read from old documents says since work 


practices are a primary determiner of exposure 


and is not a measurable factor, how are you 


taking into account the different work 


processes of people? I mean, if one man is 


really careful about how he does, you know, 


that he’s conscious that he could get exposure 


and somebody else has been basically told 


there’s no danger, he can just do whatever’s 


necessary, how are you making the distinction 


there, and particularly when the two samplings 


that were evaluated were management? These 


are people who were not in there grinding, 

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cutting, whatever, you know, their inhalation 


rate is going to be significantly different 


than somebody who’s on a grinder. 


MR. RICH: At that point we’re assuming the 


worst in all cases, the maximum --


MS. BALDRIDGE: How can you make that 


assumption based on two people who weren’t in 


there grinding, filing, inhaling the fumes 


that were basically, you know, in, if they 


were on the floor, they were in a mobile 


situation where they were moving, checking 


from one area to another or doing their 


paperwork. 


MR. RICH: Those are just two people who 


were mentioned that were taken, but there were 


others. 


MR. ROLFES: If an individual entered the 


area and was potentially exposed to high air 


concentrations and then left the area, our 


results would certainly be bounding for that 


individual by applying a 2,000 hour per year 


inhalation at that high air concentration. 


So our approach, if a person was only 


casually or based on air monitoring data, if a 


person only casually entered the area without 

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respiratory protection for a short amount of 


time, by us assuming that the individual was 


in there for the 2,000 hours per year without 


respiratory protection, our dose 


reconstruction results would be very claimant 


favorable for that individual. 


MS. BALDRIDGE: Now the data that you have 


now, are there still gaps in that? I mean, 


initially when the technical basis document 


was developed, there were gaps where that was 


reconstructed. Are there still gaps that 


exist that you’re using to reconstruct the 


data for? 


MR. ROLFES: I think it’s important to 


clarify that for a technical basis document 


there’s not supposed to have every piece of 


information in it. There’s always going to be 


things that we’re not aware of. However, 


those pieces of information are frequently 


documented in a person’s dosimetry files, and 


it’s usually those dosimetry files that are 


the most important piece of information for us 


in a dose reconstruction. So if we would look 


into our dosimetry files when we looked at a 


dose reconstruction, if we saw that we had a 

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gap in dosimetry data, for example, we could 


go to the technical basis document to learn 


how to interpret that gap and to assign a 


claimant favorable missed dose or unmonitored 


dose for that. And so we feel we have a very 


comprehensive approach to dose reconstruction 


based on the dosimetry results that we have 


for individuals in combination with our site 


profile documents. 


MS. BALDRIDGE: Weren’t they measuring 


thorium with (inaudible)? 


MR. ROLFES: External exposures from thorium 


would, in fact, have been measured by 


dosimetry. 


MS. BALDRIDGE: When would that have 


started? 


MR. ROLFES: Nineteen fifty-one, if there 


was thorium at the site in 1951 so it 


certainly would have been, it’s much easier to 


detect penetrating exposures from thorium than 


it is uranium. 


 MR. CLAWSON: That brings up a question of, 


I know that I bring up Rocky Flats, but have 


we checked into the information in each 


person’s dosimetry of, didn’t we go back at 

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Rocky Flats, have to kind of check the 


information on that? What’s in each person’s 


file for the reconstruction? 


DR. MAKHIJANI: Brad, we did that when at 


first there was a discussion around the 


completeness of the HIS-20 database, the 


computerized data file. And then that was 


found to have some gaps, and then at that 


point we did, NIOSH stated that they were 


going to rely on the individual dosimetry 


files. And at that point we did an 


investigation of the completeness of the 


individual. But we have not done that. 


 MR. CLAWSON: We have not done that with 


Fernald. 


DR. MAKHIJANI: So far as I know. Hans may 


have -- No, I don’t believe we have done that. 


 MR. CLAWSON: I think to have something, you 


know, as we’re going into this, but we, for 


our own reliability we better be sure that we 


check into that. I don’t want to get down the 


road and have to revisit this issue. So 


that’s something we may want to check into. 


Did you hear that? 


MR. GRIFFON (by Telephone): Yeah, Brad, I 

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agree with that. I just think, you know, the 


last couple meetings I’ve been trying to in my 


mind scope how we would do that, and I’m not 


sure exactly until we see. We don’t have all 


the pieces for NIOSH’s approaches yet. That’s 


what I’ve been trying to piece together in my 


mind. 


And I was just, had a question for 


Mark on the statement he just made. I mean, 


maybe this is something, again, going back to 


the individual files versus the sort of 


database approach here. For thorium we have 


all this air sampling data which I’ve been 


flipping through here while you’ve been 


talking. And your response a few minutes ago 


suggested to me that some of this was in the 


individuals’ files as well, or not the air 


sampling data you were referencing, just broad 


dosimetry data? 


MR. ROLFES: Typically, the air monitoring 


data is not associated with specific 


individuals’ files. 


MR. GRIFFON (by Telephone): So even the BZ 


stuff wouldn’t be --


MR. ROLFES: Correct, even the BZ --

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MR. GRIFFON (by Telephone): No, I just 


wanted to clarify that. Yeah, I agree, Brad, 


in general. I think we need to consider 


having that --


MR. ROLFES: There are some exceptions to 


that, Mark. For incident reports there is 


sometimes some air sampling data associated 


with that. 


MR. GRIFFON (by Telephone): Okay, thank 


you. 


Can I just say one thing on this 


whole, I think, 43.1 through five actually. 


I’ll track these actions again today. I think 


it’s sort of already an action, but this white 


paper everyone seems to be bringing up again 


that we really have to wait to see the white 


paper. I think we can talk in circles on this 


until we have something more specific to react 


to. 


But I would ask that in the, if it 


doesn’t already address it, in the white paper 


I would hope the question of what buildings 


are covered and the one that John brought up 


are you going to break it out by building or 


is it going to be sort of a site, across the 

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site approach where the one model fits all 


areas? But also just the, you know, what 


buildings are considered, quote/unquote, 


thorium buildings for the application of this 


model for assigning internal dose. 


And the second question is, and I 


think it’s already listed sort of in 43-2, or 


I’m sorry, three, the question of how you’re 


going to deal with the different jobs. And I 


think you’ve already probably got that in your 


draft, but I think those things need to be in 


that white paper somewhere so we can 


understand those. 


And the last question I would have and 


then I’ll shut up for a little while because 


it’s a little harder to participate on the 


phone here, but the last question I had, Mark, 


you mentioned again a few minutes ago that you 


have some Health Physics or whatever type of 


weekly or monthly reports from the early 


years? 


MR. ROLFES: Yes. 


MR. GRIFFON (by Telephone): You were 


responding to Brad’s question about the 


calibration of the air samplers. I think we 

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brought this up once before, and I was 


wondering if these, because at one point 


someone indicated there were all these monthly 


reports somewhere. And I think you had said 


that you were still looking for some of them. 


MR. ROLFES: Yes. 


MR. GRIFFON (by Telephone): Are those all 


on the O drive or are those, can those be, or 


even if they’re not specifically put in the AB 


document area, if you can give us like the 


names so we can find them on the site research 


database. 


MR. ROLFES: There’s quite a number of them, 


Mark, but there have been some put on from the 


earlier years beginning in the ‘50s. We have, 


I don’t want to say hundreds of them, but I’ve 


probably seen at least 50. 


MR. GRIFFON (by Telephone): Are they all on 


the site research database? 


MR. ROLFES: Correct. 


MR. GRIFFON (by Telephone): And do they 


have a name that we could search by that would 


help find some of these? Are they Health 


Physics reports? Are they, you know. 


MR. ROLFES: This one in front of me is IH&R 

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Department Monthly Report. So maybe IH&R 


might be the easiest way to find it in the 


site research database. 


MR. RICH: There are several names. 


MR. ROLFES: Yeah, they’re also referred to 


as the Health and Safety Reports, Radiation 


Safety, Fire Safety --


MR. GRIFFON (by Telephone): So a broad 


number of names which always happens at these 


sites. 


MR. RICH: Otherwise we’d have them all in 


front of us. 


MR. ROLFES: It can be tricky locating them 


sometimes in the site research database. 


MR. GRIFFON (by Telephone): And in your --


this is a little off the current discussion, 


but we had talked about some of these early 


reports sometimes have summary statistics that 


are helpful when you’re looking at the 


validation of the electronic databases. Do 


any of these reports have that kind of like 


summary? You know, for this quarter we had 


400 thorium samples taken? 


MR. ROLFES: Yes. I don’t believe I have 


one in front of me, but for example, in the 

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early time period in, say, 1954, one of the 


Industrial Hygiene and Radiation Reports had 


the number of film badges that were assigned, 


the number that were read, the number of 


uranium urinalyses that were collected from 


employees, the number of clinical urinalysis 


results that were collected from employees, 


the number of accidents that occurred, the 


number of visits that were made to the clinic 


onsite for either occupational-related 


diseases or non-occupationally-related 


diseases. And they also had the number of 


radon breath analyses collected. So something 


else that I’m sure I’ve forgotten. 


MR. CHEW: Brad, I want to make sure we 


don’t lose your question because you asked 


about the data gaps here related to the call 


at Rocky Flats. Just to refresh our memory 


that was about the 1969 time period and Arjun 


was talking about the data gap that you were 


discussing that was missing at Rocky Flats was 


external and there were some issues of why 


some badges were not read and some people were 


not wearing badges because (inaudible). I 


want to make sure we don’t mix up what we’re 

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talking about. We’re talking about internal 


versus external data gaps. 


 MR. CLAWSON: Well actually, what I was 


talking about is that we had been halfway 


through Rocky Flats and then we kind of had to 


back track to be able to go back and look at 


the claimants’ individual files for 


completeness, and it kind of seemed like we 


have to back track. It covered everything on 


that if I wasn’t correct. There was large 


gaps and so forth. Now I didn’t want to get 


three-fourths of the way down the road and end 


up having to come back and look at those 


things. I wanted to be able to address that 


right up front for the completeness of the 


individuals’ files. 


MR. CHEW: I think we need to have the 


question exactly posed to searching for what 


you’re looking for. 


 MR. GRIFFON: Yeah, I think the notion here 


should be that we need to have the work group 


and the Board independently need to sort of 


have a sense of, you know, because we’ve 


heard, much like the Rocky Flats scenario, 


that you have a couple coworker models, you 

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just provided the one for uranium. But you’ve 


indicated that there is probably very little 


reliance on that because most individuals have 


sufficient data in their files to be able to 


reconstruct their personal doses from their 


personal records. 


And I think we want to do, we want 


just to verify that, and I would think it 


would be a worthwhile task for SC&A to do, 


again, emphasis on small but statistically 


significant. A small sample to sort of say, 


yes, we agree or, no, we don’t agree that the 


data is there in the individuals’ files to 


allow for internal and external DR. 


MR. RICH: This is Bryce Rich again. Based 


on the record keeping requirements you would 


expect the personnel dosimetry files to be 


(inaudible) gaps. That’ll be good data. All 


of the personnel dosimetry data will be in the 


file. To say that we don’t have gaps in the 


air sampling data is incorrect. The air 


sampling data was not kept with the same 


regularity as the personnel dosimetry data. 


So there are gaps that we’re trying to fill by 


the way. But we do have a large number of air 

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sampling data with a wide distribution and a 


very conservative, I’m convinced, dose 


reconstruction. 


DR. ZIEMER: But those are not associated 


with individual claimants --


MR. RICH: They are not. 


DR. ZIEMER: -- as I understand it. 


MR. ROLFES: They’re not in the dosimetry 


records; however, there are some BZ samples 


listed as, you know, so-and-so was doing this 


operation, and this is a BZ sample from this 


operation for him. 


DR. ZIEMER: For that person. 


MR. RICH: An individual associated with a 


major incident, and then the report would be 


in his file. 


MR. ROLFES: For an incident report that may 


be in the individual’s file, but for, I was 


just making the point that oftentimes the BZ 


air sample results do have an individual’s 


name associated with the sample results. 


 MR. CLAWSON: Well, I just want to make sure 


that, because I know that we’re going to be 


discussed with this several different people 


as their data integrity and so forth for their 

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individual dose. 


DR. ZIEMER: Could you help me recall? Did 


we have SC&A –- did your statistician suggest 


a number of random samples from the Rocky 


database? Or how did we proceed on that? I’m 


trying to remember, or, Mark, do you recall 


that? 


DR. MAKHIJANI: Mark, do you want to --


MR. GRIFFON (by Telephone): Arjun, you can 


describe it. 


DR. MAKHIJANI: We took an initial look at a 


few and found there were periods where workers 


were not monitored, and then we went to our 


statistician to design a sampling program that 


would enable us to say with confidence that 


since we took, I think in all there were 32 


cases, individual dosimetry records we looked 


at, internal and external. 


DR. ZIEMER: In detail. 


DR. MAKHIJANI: In detail. And then since 


there were periods for which some of the 


workers were not monitored, including some 


periods where many or most workers were not 


monitored for, as I remember, external 


(inaudible). Then we had, at Rocky Flats we 

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had the particular situation of a group of 


workers that were retrospectively determined 


to be high exposed workers and were called 


back for review. 


And we picked 20 of them to look for 


completeness of data in their files in order 


to judge whether a coworker model could be 


built from that. And so we did two different 


completeness investigations, one for workers 


that were thought to be highly exposed 


retrospectively looking back from the ‘90s 


cumulatively, and then one random sampling. 


 MR. CLAWSON: Well, I just wanted to bring 


that up. And somehow we’ve got to be able to 


look into that and capture it. I want to get 


this started now instead of halfway --


DR. MAKHIJANI: Is that something that you 


would want us to look into, the uranium paper? 


Because the thorium paper’s obviously not 


complete. 


MR. GRIFFON (by Telephone): Yeah, I think 


the thorium, and it’s also clear that the 


thorium, you know, as far as personal files, 


it’s not a completeness issue. 


DR. MAKHIJANI: Right, true. 

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MR. GRIFFON (by Telephone): I mean, you’ve 


got a separate model going on. But I would 


say you want to do, I think, maybe a task, a 


good task would be to have SC&A come back with 


a sampling plan first before we just go hog 


wild into it. Let’s get a sense of what you 


think, you know, again, Arjun, just like we 


did at Rocky, go back with your statistics 


folks. 


And I would think we would focus on 


internal uranium and external and look at, and 


I would give you, I mean, my feeling is the 


similar factors that we outlined for Rocky 


apply here as well. Like I think we’d want to 


sample the workers from the different decades 


but also maybe workers from different job 


types, you know, operations, supervisory, 


administrative, maintenance. 


But I think that would be a starting 


point as come back to the work group with an 


approach on how we might do that. And then we 


can talk through it more. 


DR. MAKHIJANI: Yeah, Hans and I can 


certainly get together and think up something, 


talk with Harry about it. Now at Rocky Flats 

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we did not do job types or sample by building. 


We did a more crude approach because, as you 


recall, there was a considerable amount of 


discussion and a desire by the working group 


to limit the amount of investigation that we 


did. So as a result the end product did not 


tell us lots of things and did tell us lots of 


things. And because the sample size was not 


defined by building, job type and, it was 


defined by two broad periods basically. 


That’s it. 


DR. ZIEMER: I would think the plan itself 


would address whether we need to do it by job 


titles or by buildings or what. That could be 


part of the plan, could it not? 


DR. MAKHIJANI: We could look at what it 


would take to do it by job types and building. 


DR. ZIEMER: If that’s even needed. 


 MR. CLAWSON: I guess the thing is you need 


to --


DR. ZIEMER: Develop the plan. 


 MR. CLAWSON: -- develop the plan and let’s 


sit down and take a look at it. I guess 


because some of the points of interest to me 


is going through the TBD and so forth there 

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was a lot of interesting information to me 


like the clothing worker, so forth like that 


of all of a sudden coming back. Also, how 


they issued a lot of different clothes. I 


think what I’d like to do is be able to have 


you guys bring us back a plan. We’ll discuss 


that, and then we’ll continue on. We’ll make 


a decision at that time. 


MR. GRIFFON (by Telephone): And I think we 


did -- I’m sorry -- I think we did for Rocky. 


We sort of, like you said, Arjun, we did one 


subset of production workers, but then we 


looked at a larger, and that was just random 


across, you know. And I guess the idea there 


was that, or the issue we were trying to get 


at there was that we wanted to see if the 


production workers certainly were all sampled 


or had complete data. But also we wanted to 


see if sort of all job types so that was the 


random --


DR. MAKHIJANI: And we did have some fine 


grain things show up even in this. We 


discovered that uranium workers were not 


monitored in a certain period whereas 


plutonium workers were more completely 

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monitored. So we were able to tell a lot of 


things and because the sample size was --


MR. GRIFFON (by Telephone): Yeah, and in 


your plan if you can sort of think about the 


purpose of each piece that would be helpful, 


too. For instance, we have to think about how 


we’re doing dose reconstruction for these 


individuals and if you have uranium, you may 


not have -- well, I guess I would leave it up 


to you. 


But in my mind there’s a couple 


questions for if I looked at an individual’s 


file for their uranium samples, one thing I’d 


want to know is, okay, given their job type 


were they on the schedule that they were 


supposed to be. So if they were an operator 


in a certain building, and the procedure said 


they got monthly sampling, were they, in fact, 


getting monthly sampling? 


But the other question is, and 


probably the sort of bottom line question 


would be did they have a uranium urinalysis 


toward the end of their career? Because in 


many ways you could really use that as a 


bounding measurement to bound their dose over 

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their entire career if --


DR. ZIEMER: A close-out sample. 


MR. GRIFFON (by Telephone): -- right, 


right, close-out sample kind of thing. That 


would be essential, and that’s one thing we 


found in Rocky Flats, and they actually had to 


revise the coworker model because during the 


D&D period we did not have that urinalysis 


data for as many people as they did during the 


production years. So we had to extend that 


coworker model. I guess those are the 


questions maybe to incorporate in your plan. 


 DR. WADE: This is an important issue, and 


maybe we could talk about it just for a 


minute, but I think we really need to proceed 


in stages here to get this right. I would 


propose that the first thing that happens is 


that SC&A thinks about this and then comes 


back to the work group and says we’re going to 


develop a plan to include these factors. And 


you sort of lay out the variety that you’re 


going to --


DR. ZIEMER: In your plan, is that --


 DR. WADE: -- then the work group can 


comment upon that. And then based upon the 

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work group comments you develop the plan. If 


we don’t do that, we’re going to do that 


eventually anyway. 


 MR. CLAWSON: I just passed déjà vu or 


whatever. I just wanted to make sure we 


addressed this up front. But, Hans, --


DR. BEHLING: Yeah, I think Mark has already 


touched on it. We have Finding 4.3-2, 4.3-3, 


4.3-4 and they all basically touch on the 


common theme, and that is we’ve come to the 


conclusion here that for thorium internal dose 


reconstruction there’s likely to be very 


little, if any, data in the personal files. 


Mainly, we’re going to have to rely on your 


white paper that will define what is the 


potential upper value that we may have to 


assign to these people in the absence of 


information. 


And I guess I have multiple things 


that I want to discuss here on that issue when 


you develop this plan. One is obviously to 


always make a distinction between what do we 


assign to a person who is likely to be 


compensated, and we have to rely on a best 


estimate. 

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And frequently our approach to doing 


dose reconstruction based on generic 


information may differ significantly from one 


where we have a maximized dose estimate. So I 


would like to ask you to keep that in mind 


when you do a white paper and distinguish 


between best estimates as opposed to maximized 


dose. 


And also, talk about the issues that 


are identified here as the various findings 


here. We’ve already discussed 4.3-2, and from 


what I gather we’re going to dismiss or 


discard the issue of the 1,050 MAC hours as a 


default value for a bounding intake. 


We are also in 4.3-3 I want to again 


make sure that when we talk about the issue of 


identifying a person even though he may have 


some cards in his file that says he was a 


certain process worker or chemical plant 


worker on a job location. If you look at 4.3­

3, we identified problems with that, too, 


because I’ve identified numerous attachments 


that talk about maintenance people, project 


labor pool. 


And so you’re going to deal with a lot 

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of unknowns for a lot of people in terms of 


where were they working, and what were they 


doing. So when you develop a protocol that 


will probably have generic applications for 


all workers regarding the internal exposure to 


thorium, you’re going to have to keep all 


these issues in mind. 


Because as Arjun, and as the 


regulations require, you’re to basically 


identify all individuals for their potential 


exposure. We’re not looking for what is a 


best average exposure, but what is the 


potential maximum exposure because we’re here 


to protect every person, not just the average 


person. 


FINDING 4.3-4
 

And so I think we can probably go 


through the next several issues that go all 


the way including 4.3-4, the inability to 


account for internal exposures associated with 


radiological thorium intakes. And again here 


I had provided a significant amount of 


documentation. I talk about the frequency of 


these events, and they were not infrequent 


when we talk about, for instance, Attachment 

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4.3-4 on page 71 where we talk about fires and 


other incidences that would have given rise to 


significant elevations in exposures. 


So rather than belabor all these 


issues at a time when we don’t have your white 


paper, I would just like to at least make you 


aware that these issues will be looked at in 


the context of your white paper. And we will 


assess your white paper in the context of 


identifying the problems associated with where 


did this worker work. Was he a member of a 


project labor pool, a roving maintenance 


person? Was he potentially exposed to 


incidents that are not documented in the light 


of his personal file, et cetera, et cetera. 


So if everyone agrees, we can probably 


postpone the next several attachments and 


postpone further discussion until we have your 


white paper. And then we will go back again 


and look at these specific issues to be sure 


that we are satisfied with the fact that they 


have been addressed. 


MR. ROLFES: Hans, I did want to clarify 


that we do have thorium exposure information 


associated with individual claims beginning in 

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1968 with the mobile in vivo radiation 


monitoring lab results. 


DR. BEHLING: Well, yes, that’s a new 


threshold, and maybe ‘65’s a little early 


because there were just a handful, but ’68 is 


really, marks a threshold for potentially 


applying a person-specific data that are 


obviously in that person’s file. But up until 


’65, ’68 timeframe, obviously the application 


of the generic thorium air monitoring data may 


have to suffice. 


And we just want to be sure that we’re 


talking about a comprehensive review of all of 


the variables that come into play here and 


assure ourselves that we’re not leaving people 


high and dry who may be very well at the upper 


end of that. We have, for instance, 


documentation as Arjun already pointed out in 


some of the memoranda where people were 


exposed to 1,200 MCGs that translate to more 


than 1,800 MAC hours who were not wearing a 


respirator. 


And when you talk about what is his 


potential exposure for any given year, well, 


it’s going to be pretty high. We have no clue 

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as to what he was exposed to even during that 


evolution. But it’s clear that if we were 


even assured that he was taken to a lower 


exposure environment what that might be. It’s 


likely that he was not transferred to mahogany 


row and taken a desk job. We just don’t know 


what happened to that individual. 


 DR. WADE: Let’s keep our issues straight. 


Hans, took us back to thorium. We want to 


close on the uranium issue in terms of the 


completeness of the data. 


So are you comfortable now that the 


instruction has been given to SC&A that you 


want, Brad? 


 MR. CLAWSON: Yes, I want --


Is it clear to you? 


DR. MAKHIJANI: What I wrote down was what 


Dr. Wade said at the end that you want this 


plan developed in two stages. First -- at 


least that’s what Dr. Wade proposed. I didn’t 


see an assent from --


 DR. WADE: What I’m suggesting is SC&A comes 


back to us and says these are the factors 


we’re going to look at. How we’re dealing 


with uranium internal and external monitoring, 

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the entire period at the facility. 


DR. MAKHIJANI: External (unintelligible) 


and then uranium for internal. 


 DR. WADE: And then we come back and say 


these are the factors we’re going to take into 


account as we develop our plan. The work 


group will modify that, give you instructions, 


then you’ll develop the monitoring --


DR. MAKHIJANI: Then we’ll go to the 


statistician. So the first step will be a 


kind of a technical review. I guess Hans and 


some of us can sit down and talk about what 


factors and work with you in developing that, 


and then we will go to the statistician. 


MR. GRIFFON (by Telephone): Lew, I agree 


with your outline of the approach. The only 


one thing I might ask, and this is a question, 


it’s uranium internal and the external. But 


I’m just listening for the, I also included 


thorium post-1968 because are you relying on 


individual data at that point, Mark? Is that 


correct? 


MR. ROLFES: That’s correct. 


MR. GRIFFON (by Telephone): So I would add 


in thorium post -- and do I have the date 

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right, 1968? 


MR. ROLFES: ‘Sixty-eight. 


MR. GRIFFON (by Telephone): ‘Sixty-eight, 


right. 


DR. MAKHIJANI: I got that. 


 DR. WADE: So, Brad, would you expect to see 


something from SC&A and then you would convene 


a work group meeting to deal with it before 


this goes forward? Is that your --


 MR. CLAWSON: Yes, that’d be my, we’d like 


to be able to sit down and discuss with being 


in the process of being able to look at it and 


make sure it’s covering what --


 DR. WADE: So then John or Hans or Arjun, a 


sense of when we might have that sort of 


preliminary thought piece that the work group 


could then react to before you develop your 


detail plan. You can think about that this 


morning and maybe after lunch --


DR. BEHLING: We need to talk with John and 


Arjun. 


 MR. CLAWSON: While we’re thinking about 


that, more on that, there may be required a 


comfort break here. If we could have a kind 


of a comfort break and convene back in 15 

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minutes. If that’d be all right --


 DR. WADE: We’re not going to break the 


line. We’re just going to mute the phone. 


(Whereupon, the working group took a break 


from 10:45 a.m. until 11:00 a.m.) 


 DR. WADE: We’re back in session. 


 MR. CLAWSON: First of all you wanted to 


read into the minutes the reference document 


that you had used. 


MR. MORRIS: Yeah, this is Bob Morris. I 


referred to a document by Heatherington (ph) 


regarding the mobile in vivo radiation 


monitoring laboratory first use. It’s SRDB 


reference number 2932. 


 MR. CLAWSON: Great. Now several of these 


are going to be covered with the new white 


paper coming out, so we’re going to kind of 


skip over some of these in the matrix. 


DR. BEHLING: Yeah, I think what I’d like to 


do is just again, continue. 


FINDING 4.3-6
 

We talked about 4-3.2, three, four and five, 


and also just briefly touch on 4.2 (sic)-6 


which talks about the need to potentially 


address thorium exposures during post­
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production periods, meaning that there were 


discrete periods of time during which thorium 


was processed at a given plant. 


However, one has to come to a 


realization that residual contamination of 


thorium after the last production takes place 


will remain in that facility and there’ll be 


resuspension and inhalation and to what extent 


one may have to look at that and sort of say 


post-production air monitoring. 


And since you’re really only measuring 


gross alpha, how do you know whether that 


gross alpha is a uranium daughter or uranium 


or is it a thorium, and to what extent during 


this transition period between production of 


thorium and resumption of uranium are there 


potential data points where you may have to be 


careful about assigning that gross alpha as 


strictly uranium as opposed to thorium? And 


that’s really due to the fact that the dose 


conversion values are considerably different 


between thorium and uranium. And that’s just 


a point that I wanted to bring up here. 


DR. MAURO (by Telephone): Brad and Hans, 


this is John. Before we move on, during the 

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break I was thinking a little bit about the 


conversation we just had regarding the white 


paper, and I just had an idea. And I’d like 


to just put it on the table. It seems to me 


that a recurring theme that we always run into 


is the construction of these coworker models 


and their granularity in terms of time and 


space, et cetera, et cetera. 


And it’s not until we get to this 


point in the process where we engage that 


issue whereby we have all these data. And 


then we look at the data and see, okay, how 


well does the data serve us and be able to 


build these coworker models at the level of 


granularity necessary to support some decision 


regarding SEC. 


What I was thinking about was it seems 


to me that recognizing that we’re always going 


to have to deal with this kind of issue, it 


seems to me that when the site profile is 


prepared, and you’re preparing chapter two 


which describes the site, right now there’s a 


ton of information that summarizes activities 


at the site. 


I would suggest that while that 

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section is being prepared it is prepared with 


an eye toward what are the different sub-


compartments of activities, job 


responsibilities, time periods, campaigns, et 


cetera, where you would say these represent 


different cohorts of people. I use the term 


cohort not in the SEC sense, but in just the 


sense of what a cohort is. 


Whereby if you are going to create a 


coworker approach because you don’t have 


complete data, you need to build it around 


these different cohorts because the nature of 


the activities, the nature of the exposures 


were of substantially different -- Now we’re 


dealing with different populations of workers 


in effect. And so it’s almost like we should 


front-end this question and to be dealt with 


before you actually get into the data. 


When you’re at the front end in 


principle you should be able to say, you know, 


we understand the operations and how the high 


level of resolution, and we also understand 


that if you are going to develop some type of 


coworker model, it has to be developed at this 


level of granularity in order for it to be 

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functional for you to do dose reconstruction. 


So I guess I just want to put that on, 


it’s almost as if that issue could be 


addressed in the front end before you actually 


get to the data, then when you get to the data 


you could pose questions to the data. That 


is, are the data of sufficient resolution that 


allows you to build the coworker models at the 


level that you need. 


So I’d like to just put that on the 


table because I think we’re going to run into 


this time and time again, and I realize it 


doesn’t really apply, it applies to everything 


we’re doing. And I wanted to unload that 


because I was thinking about that during the 


break. 

 MR. CLAWSON: I understand and appreciate 

that, John. 

DR. BEHLING: I do want to make a comment, 

John. This is really not a coworker model 


since obviously this applies to just about 


everybody. In the case of the thorium air 


monitoring data, we don’t really have worker 


specific air monitoring data. We have BZ and 


GA air sampling data without necessarily 

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identifying specific worker groups. We may 


have some job locations and plant locations 


but not really individual-specific data. So 


this is really not a coworker model. 


DR. MAURO (by Telephone): Maybe I used the 


wrong term. I guess I was thinking in terms 


of you’ve got a group of workers, and you’re 


going to try to characterize the distribution 


of the exposure in that group of workers. 


Whether it’s bioassay data, air sampling data, 


breathing zone data, external dosimetry 


measurements, film badge readings, all I’m 


really saying is that when you try to 


understand the exposures that any given group 


of people have been exposed to, the idea of 


pooling the data is, you want to avoid that. 


You want to try to create a dataset, 


in this case air sampling data, at a level of 


resolution that you feel confident that the 


distribution you create captures the range for 


a particular group and is not pooled to such 


an extent that it’s diluted to the extent that 


you really don’t know whether you’ve captured 


the high end or not. And I can almost see 


that being done early in the process, you 

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know, not after you’ve gathered the data but 


while you’re actually characterizing the 


operations and preparing the site profile, 


that particular chapter two is prepared with 


that in mind. 


I think right now there’s a lot of 


information of that type, but I don’t think 


that chapter is prepared with that issue in 


mind. Because in the end that’s how you use 


chapter two. It should lead you to how much 


granularity do you need in order to understand 


the differing population groups and activities 


that took place that will need to be 


characterized whether it’s a coworker model or 


whether, as in this case, we’re talking air 


sampling data that’s going to be used from 


which you’ll pick off a distribution. 


Anyway, forgive me. It was sort of in 


my head, and I wanted to get that out. 


 MR. CLAWSON: I understand. So, John, let 


me just try to capture what you just told us. 


You’re talking about when they’re developing 


the site profile, correct? 


DR. MAURO (by Telephone): I think that’s 


the right time to do this because you’re not 

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already immersed in the data. In other words 


you’re basically, it’s almost like a clean way 


to do it. In a perfect world given the site 


we would like to have data at a level of 


resolution, certainly all the individual data 


that’s your perfect world, but you never have 


that. 


And you may have to resort to what 


we’re doing right now, drawing upon air 


sampling data. But then again if you’re going 


to do that, right up from the beginning you 


need to appreciate how much resolution do you 


need in characterizing the workforce? Where 


they were. When they were. What they were 


doing. 


And that should be done before you’re 


looking at the data so that later when you do 


collect your data, you could actually evaluate 


that data from the perspective of will it 


serve our purposes to characterize the 


exposures that workers experienced given the 


granularity that we defined in chapter two. 


DR. ZIEMER: It sounds to me like this is a 


suggestion for NIOSH, maybe two years too late 


or something. 

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MR. ELLIOTT: This is Larry Elliott. I 


appreciate hearing your thoughts, John, and it 


certainly needs to be considered in the 


context of how we have approached our work. 


As Dr. Ziemer points out I think that our 


strategy has been to look at sites where we 


have a large number of claims and datasets to 


apply to those claims and move a technical 


approach into play, into dose reconstruction 


practice as soon as we could so that we could 


use that to the best advantage of a majority 


of the claims. In some cases we would not be 


able to complete a given claim because we 


didn’t have all the information assembled. So 


you could say maybe we put our cart before the 


horse here, but that’s why we’re going through 


this today I think. 


DR. MAURO (by Telephone): Yeah, I think so, 


too. 


MR. ELLIOTT: We’re going through this now, 


and we’re saying, okay, how do we fill these 


holes? How do we fill these gaps? What are 


the questions that our overall strategic, 


general approach didn’t really address for 


each individual claim? The majority of the 

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claims we feel we’re working with a document 


or set of documents that give us the correct 


answer for compensation. 


 MR. CLAWSON: And we appreciate that, John. 


I’m sure NIOSH will take that into 


consideration. 


We’d also like to welcome Larry 


Elliott here. He just arrived. 


So I’m going to turn this back over to 


Hans, and he can proceed on. 


FINDING 4.3-7
 

DR. BEHLING: The next one, 4.3-7 on page 86 


of the report again makes reference to perhaps 


a fairly significant program that involved 


redrumming of thorium. 


MR. GRIFFON (by Telephone): Hey, Hans, 


before you move on to 4.3-7, on 4.3-6 I just 


wanted to clarify in the previous action we 


had said NIOSH would post thorium in vivo 


data, and I underlined here, and associated 


model. 


I’m pretty sure, Mark, that you’ve 


posted the data, but is there any coworker 


model associated with that for people that 


wouldn’t have their own individual data during 

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that time period? 


MR. ROLFES: I don’t believe the final 


version has been put out there. The data has 


been --


MR. GRIFFON (by Telephone): Okay, I just 


don’t want to lose that because your response 


says done, but I think the second part of that 


action isn’t necessarily completed. Is that 


correct? 


MR. ROLFES: The descriptive information I 


believe is probably still being finalized. 


But the white paper that we had completed for 


the in vivo, the assignment of thorium intakes 


based on in vivo data, we’ve put together some 


documentation of the intakes and everything. 


There was a descriptive report I believe for 


that. 


MR. MORRIS: Yeah. 


MR. ROLFES: I do not believe I have put 


that back on or I do not believe that it is on 


the X drive or O drive at this time, but I 


will make sure it is available. 


MR. GRIFFON (by Telephone): Okay. 


MR. MORRIS: And probably as a result of 


this meeting and the comments that we’ve heard 

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you say today that you’d like us to 


specifically consider, we’ll make one more rev 


on it before we give it away. 


MR. ROLFES: Probably a good idea. 


DR. MAKHIJANI: This is the coworker model 


you’re talking about, for thorium? 


MR. ROLFES: For thorium, correct. 


DR. MAKHIJANI: In this 4.3-6? 


MR. ROLFES: Yes, and were we going to 


separate that out from the, are we going to 


put one general white paper for thorium out or 


are we going to divide it into the early time 


period and the more recent time period? Are 


we going to have two separate white papers, 


one for the early time period and one for the 


more recent time --


MR. MORRIS: We’ve got a coworker model for, 


based on in vivo chest counts starting with 


’68 that goes through ’88. And we’ve got an 


air sample-based intake model that uses the 


Battelle TBD-6000 documentation, the equation 


that’s in Battelle’s 6000 which is, I think, 


has been reviewed by SC&A in a Procedures 


working group. So I think the only issues 


that could be left is who would be applied to 

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the operator category versus the laborer 


category versus the --


MR. GRIFFON (by Telephone): I think that 


TIB-6000 is still kind of under review. I 


mean it’s in the resolution phase in the work 


group, Procedures work group. 


MR. MORRIS: Possibly, I know SC&A has 


provided a draft. 


DR. MAURO (by Telephone): Mark, but bear in 


mind that it looks like what’s more applicable 


here is 6001, which is the process. We did 


review 6000 which is metalworking, and that 


certainly is, we completed our draft. It has 


not entered into the issue resolution process, 


but I think that we did not review 6001 which 


has to do with processing with the thorium 


issues come in. 


MR. MORRIS: Well, essentially the model is 


repeated in 6001, John. 


DR. MAURO (by Telephone): Oh, okay, okay, 


then in that regard many of the comments in 


6000 may very well apply to 6001. 


MR. GRIFFON (by Telephone): And as far as 


one white paper or two separate, it sounds 


like you already kind of have two separate --

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MR. MORRIS: We have two separate --


MR. GRIFFON (by Telephone): -- that’s fine. 


MS. BALDRIDGE: I have a question. How do 


you plan to approach the Plant 6 three and a 


half years where we didn’t know that they were 


processing the thorium because you didn’t have 


access to the records? So obviously the 


worker records didn’t show any, there wouldn’t 


be any worker records specific to thorium in 


that timeframe so you would have to rely on 


air sampling. But how do you develop a model 


where a group of people that you really don’t 


know what they were dealing with since they 


were handling raffinates? 


MR. ROLFES: Well, these individuals were 


not handling raffinates. They were handling 


materials that had been through the Plant 9 


process in the 1950s. These were leftover 


scraps, thorium contaminated material such as 


thorium oxide, incomplete fires, incomplete, 


so there was a lot of high volume of 


contaminated scrap. 


It was contaminated with thorium, and 


the idea was to reduce the volume of the 


materials that were contaminated for storage. 

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And so what they did is converted the Plant 6 


sludge furnace over to handle thorium, and 


they essentially reduced the volume of the 


thorium contaminated waste from the earlier 


production time period. And so we’re going to 


use the air sampling data for that time period 


for that operation to assign intakes. 


DR. BEHLING: Let me just briefly introduce 


Finding 4.3-7 and that, as I started to say, 


was an issue that surrounds the redrumming of 


thorium and there were large, large numbers of 


drums that on a repeated basis were decaying 


and corroding, had to be repackaged. 


And one of the things that, or at 


least we were not able to find any BZ air dust 


data or air sampling data on behalf of that 


operation, and we know very well that that is 


likely to be a fairly high airborne 


environment in this whole process. And the 


question is to what extent will that also, 


that particular evolution, be considered as 


part of your white paper in assessing air 


concentration intakes. 


MR. ROLFES: The redrumming operation was 


typically done on every couple of year basis. 

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We do have BZ air sampling data for the three 


individuals that were involved in redrumming 


during one of the redrumming operations. That 


information has been provided to the Advisory 


Board. 


DR. BEHLING: And that was three 


individuals? 


MR. ROLFES: Correct. 


DR. BEHLING: And do you have any idea as to 


how many individuals -- I would assume much of 


that effort was done by people who were 


declared as labor pool members of the labor 


pool. Do we have any understanding as to how 


many people we might be looking at who were 


exposed to airborne environments during this 


redrumming? 


I mean, that’s an awful lot of drums 


when I consider, for instance, the issue of 


the 13,000 drums and the number of years it 


took for the transfer of that material into 


silos one and two. When we’re talking about 


periodic redrumming, I’m sure we’re talking 


about a significant number of people. Do we 


have any idea who they were? 


MR. ROLFES: The 13,000 drums of material 

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were the raffinate wastes that were shipped 


from Mallinckrodt and from Lake Ontario --


DR. BEHLING: I realize that. I’m just 


giving that as --


MR. ROLFES: -- separate operation --


DR. BEHLING: I realize that. 


MR. ROLFES: If you take a look at the 


quantities of thorium that were handled on the 


site, the typical production from the early 


time period was about a metric ton per day. 


So it was a very low quantity of material --


MR. RICH: Less than. 


MR. ROLFES: -- less than a metric ton per 


day. So I do have some inventory data for 


some thorium here, and I’d have to take a look 


at it. But it was typically handled by a 


small number of people and we do have some 


breathing zone air sampling results associated 


with those individuals completing the 


redrumming operations. So that is something 


that we will elaborate on in our white paper 


as well. 


 MR. CLAWSON: So, Mark, let me make sure 


that I’m clear on this. When you’re talking 


about the redrumming process in the white 

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paper coming out, you’re going to kind of 


cover how and what people are covered by that? 


MR. ROLFES: I would suspect if an 


individual was, in fact, involved in a job 


where he was exposed to thorium, I believe he 


would have been one of the individuals that 


would have been counted by the in vivo lab at 


Fernald. In the earlier time periods we’re 


going to have to rely on air sampling data to 


reconstruct exposures from this pathway. 


 MR. CLAWSON: Well, the reason why I’m just 


trying to get my hands around what people were 


involved in this because I do agree, that’s an 


awful lot of drums to be able to... And I’m 


just, I’m trying to just figure out how we can 


(inaudible). 


DR. ZIEMER: How many drums are we talking 


about? 


 MR. CLAWSON: I see here in the 


(unintelligible) materials have been 


redrummed, there’s approximately 2,000 drums 


of material. This is just another report. 


DR. MAKHIJANI: There were a lot of thorium 


drums onsite that involved stored materials 


because Fernald became a storage site, and a 

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lot of the thorium was not processed there, 


but it had to be redrummed because the drums 


corroded. 


MR. ROLFES: That’s true. 


MR. BEATTY: Just from the campaign record 


of 2,000. Silo three was also full of 


thorium. 


 MR. CLAWSON: And I guess I’m looking at 


this a little bit different, Mark, and I 


apologize for my ignorance. But a lot of our 


processes -- we run an awful lot of people 


through, and I’m just wondering how we can get 


our hands around what people were going to be 


covered by this. 


MR. ROLFES: Well, the time period that 


we’re referring to with the Building 64, 65, 


the thorium storage buildings at Fernald. 


Thorium was sent from across the entire DOE 


complex to Fernald beginning in about I think 


it was 1972. And this is the time period that 


the mobile in vivo lab was monitoring people. 


So for an individual that was 


potentially exposed to airborne thorium, had 


intakes of thorium, these individuals were 


likely counted by the mobile in vivo radiation 

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monitoring lab at the site. So there would be 


information in that individual’s file that 


would allow us to reconstruct in a claimant 


favorable manner his thorium exposures 


associated with redrumming. 


But the mobile in vivo results would 


be independent of the actual process because 


we have measurements indicating how much 


thorium is in the body. But really, you know, 


how it got there, we can make assumptions 


about inhalation, ingestion that result in a 


claimant favorable dose estimate. So the fact 


is that the data are in the dosimetry files 


for the individual. 


DR. MAKHIJANI: The thorium in vivo stopped 


in ’78, right? 


MR. ROLFES: No. 


MR. MORRIS: ‘Eighty-eight, mobile in vivo 


monitoring laboratory went through ’88. 


DR. MAKHIJANI: Yeah, but for thorium I 


thought your in vivo only went --


MR. MORRIS: No --

MR. ROLFES: That’s not the way it was 

reported. 

DR. BEHLING: The next issue I think is 

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something that perhaps Arjun is more qualified 


to -– 


FINDING 4.3-8
 

DR. MAKHIJANI: The fugitive emissions. 


This came up last time I did cite the memo 


which is quoted in review and maybe also, in 


the TBD review and maybe also in the 


evaluation report. There were quite large 


fugitive emissions, at least from the 


qualitative description in the memo. I read 


it out last time where trays were left in a 


doorway to dry and then there’s a lot of 


loose, suspended, or suspended thorium in the 


air both inside and outside the plant. And 


the atmosphere is described as very dusty. 


And so not only production workers but 


others would also have been exposed to 


thorium. I wondered whether and how you were 


including them in the model. This doesn’t 


involve just inside the plant. It involves 


also workers who would have been there 


outside. I believe the memorandum is in the 


TBD review. I can try to bring it up. Yeah, 


it’s on page 41 of the TBD review. And it is 


in relation to thorium metal production 

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housekeeping, and it’s from 1970. 


So this is a period where the actual 


production air monitoring data, well, the ones 


that I’ve seen, were not as high as in the 


earlier period. But the processing operations 


were leading a huge –- well, the words 


indicate large fugitive emissions. There were 


no numbers that I’m aware of. 


MR. ROLFES: In what form are they? Arjun, 


are they referring to air dust or are they 


referring to --


DR. MAKHIJANI: No, no, air dust. One is 


probably the worst housekeeping problem in the 


facility, the (unintelligible) mill equipment 


leaks at practically every joint. All 


horizontal surfaces have a thick covering of 


dust, ventilation is inadequate and so on. So 


this --


MR. ROLFES: Is that not referring to 


uranium though? 


DR. MAKHIJANI: No, it is thorium metal 


production housekeeping, Ross 1970. And then 


the same memorandum explicitly talks about 


thorium tetrafluoride. During operation of 


removing calcine thorium tetrachloride and 

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calcium fluoride from the retorts. A stack of 


trays was left standing on a skid near the 


south annex door. The door is left open to 


aid in cooling the trays. The wind coming 


through the doors blows the loose powder from 


the trays and spreads it generously through 


the annex, and so on. So I don’t know which 


door this refers to. I’m assuming it’s a door 


between the building and the outside, but it’s 


not explicit here. 


MR. MORRIS: So it spreads it through the 


annex. That’s not out backwards through the 


door. 


DR. MAKHIJANI: But if the door is to the 


outside, if it’s a door between the inside and 


out, it’s an access door, then it would also, 


it will be on the outside and non-thorium 


workers on the inside would also be at some 


risk. 


MR. MORRIS: There’s no doubt about that. 


DR. MAKHIJANI: So this is the problem of 


fugitive emissions in a period where you’re 


relying on in vivo data, but you may have a 


lot of workers who were exposed to thorium who 


don’t have any in vivo data because they were 

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not considered to be at risk. 


MR. ROLFES: It’s always very possible that 


an individual was exposed to thorium; however, 


because we do have mobile in vivo radiation 


monitoring results for the individuals, we can 


simply assign a missed intake. Because if an 


individual was exposed to thorium, and we have 


indication that he was in a thorium area, we 


could assign a missed intake of thorium based 


on his non-positive or positive mobile in vivo 


results. 


DR. MAKHIJANI: Now these thorium areas are 


the same plants as the uranium areas. You’re 


talking about a lot of workers, but you 


indicated that the thorium workers were 


actually very few. Well, we have to look at 


your in vivo database to see how many workers 


are involved in it, and whether workers who 


were in a particular building were all 


monitored in the in vivo or not. 


But it’s a question as to how workers 


who were not designated as thorium workers 


would be subject to this kind of emission. 


And how are you going to assign the, how are 


you going to know to assign a thorium dose to 

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them? Or are you going to assign a thorium 


dose to everybody? 


MR. ROLFES: We would, based on an 


individual’s mobile in vivo results --


DR. BEHLING: But he wasn’t, that’s the 


point, he was not monitored. 


DR. MAKHIJANI: This gets to another 


question. Fugitive emissions means workers 


who were not designated thorium workers were 


at risk of thorium exposure. If they’re not 


being monitored for thorium because they’re 


not at risk of thorium exposure but are still 


at some risk of considerable thorium exposure, 


how would you know they’re thorium workers, 


and how would you know to assign them a 


thorium dose? 


MR. ROLFES: Everyone that had a mobile in 


vivo radiation monitoring lab result was 


monitored for both uranium and thorium. 


DR. BEHLING: But, Mark, that’s the point 


Arjun’s trying to make, that not everyone was 


monitored by the in vivo system, meaning that 


there will be people who for whom there is no 


record that they were given chest counts for 


either thorium or uranium. 

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It may have been a secretary who was 


obviously considered not at risk who was 


obviously subject to fugitive emissions but 


has no record of ever being monitored. How 


would you know to assign her missed thorium 


dose based on fugitive emissions? That’s 


Arjun’s question. 


MR. ROLFES: That will be documented in the 


thorium coworker model. 


DR. MAKHIJANI: Who are you going to apply 


the coworker model to? Are you going to apply 


it to secretaries? That’s the question. 


MR. ROLFES: A secretary certainly does not 


have the same exposure potential for a 


chemical operator directly involved with the 


thorium processing. 


DR. MAKHIJANI: That’s not the question. 


How are you going to determine who was subject 


to fugitive emissions, and therefore should be 


assigned a thorium dose? I guess we’re not 


talking to each other. 


MR. ELLIOTT: No, you’re not, you’re not. 


You’re coming at it, Mark, from what 


environmental dose is going to be assigned. 


That’s the way we would view it, an 

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environmental dose. And first I’d have to 


understand to even enter into this what is 


considered a considerable thorium fugitive 


emission and whether or not there are enough 


of those that merits risk. 


MR. RICH: That’s the sticking point. 


DR. MAKHIJANI: Well, I agree that that’s 


the key point. I mean we just have, I mean, 


there may be other documentation. I happen to 


know of this one. It’s from 1970, and it 


describes a routine operation. This is not an 


incident. This is a piece of equipment that’s 


leaking and a procedure, there’s two things. 


A piece of equipment is leaking and spraying 


dust. And an operation that was routine that 


was used to dry thorium tetrafluoride. 


So we’re talking about operations that 


were done there as part of their method of 


dealing with thorium. And so I don’t know how 


long these things were done. I don’t know how 


long this equipment was leaking. That’s part 


of the problem is that we don’t have any 


numbers, but obviously it was a pretty big 


concern because the surfaces had a thick 


covering of dust of thorium, that means you’re 

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leaking a lot of thorium. 


DR. BEHLING: And also it parallels the 


issue that identifies those four individuals 


who had an unexpected high uranium intake. 


Had, for instance, on behalf of those 


individuals you’re fortunate enough to give 


annual physicals that included a urinalysis 


that also looked for uranium in the urine. 


In which case I believe those four 


individuals, and we can go back to that 


particular issue, were obviously identified 


and identified as unexpected. The point here 


is that we haven’t monitored for thorium; and 


therefore, we’re questioning whether or not 


they were people who on a parallel level were 


exposed to thorium. But in this case you have 


no chance of capturing them as you did in the 


case of the uranium. 


DR. MAKHIJANI: That’s right. 


 MR. CLAWSON: Was somebody trying to speak 


on the phone? We were getting a lot of static 


there. 


 (no response) 


MR. ROLFES: For the early time period the 


Battelle model does allow us to assign a 

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fraction of the intake or a fraction of the 


air monitoring results to a person based on 


their job category. And if you fold in the 


Battelle model for individuals that were 


potentially exposed to non-processing areas, 


you know, to general background areas or 


occasional entrants into the plant such as a 


secretary or something, we default to one 


percent of the intakes based on air monitoring 


data for the earlier time period. So the 


information for the later time period, the 


more recent time period, can be documented or 


will be documented in our white paper. 


MS. BALDRIDGE: I have a question. In one 


of the documents included in the petition it 


states concerning thorium that there are 


improperly coded items that at times have 


exploded and burned. There were large losses 


into the storm sewer, and that 240,000 pounds 


of residue was sent to Plant 6 for oxidation. 


How are you going to determine who would have 


been exposed during an explosion or a fire 


concerning thorium? Not only the people 


assigned to the area but observers, the fire 


department that may have come to assist in 

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getting this under control. Are these people 


identified? 


MR. ROLFES: Yes, they are. For example, in 


1954 when the thorium processes were starting 


up, there was a very bad incident, an 


explosion, there was a partial reduction of 


the thorium in process. Some calcium metal 


that was used to reduce the thorium was being 


blended, and there was a little bit of 


moisture I believe in the materials being 


blended. The calcium reacted with the 


moisture and caused a large fire and explosion 


involving about -- off the top of my head --


around 100 pounds of thorium I believe it was. 


The individuals involved with that 


incident, two of them died because of the 


incident because of burns. There were other 


individuals that came to the first aid of, to 


give first aid to the individuals that had 


been burned. There is a very detailed 


incident report and investigation of this 


occurrence in Plant 9. 


There are other documented incidents 


where there is indication that some thorium 


sludge or materials contaminated with thorium 

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were burned. And it is documented in 


documents that we have available to us in the 


site research database, both the numbers and 


the names of the individuals that were 


involved. 


MS. BALDRIDGE: Now my point, there have 


been other incidents concerning uranium, other 


locations, where in excess of 20 people have 


been involved in the incident but only five 


people had it accounted for in their records 


because only five people were examined for the 


uranium excretion levels. Now if they didn’t 


have a practice of even recording all the 


individuals involved in an incident, how can 


you be sure that the ones who were recorded 


are the only ones who had been involved? 


MR. ROLFES: Individuals that were involved 


in an incident were required to report to the 


medical office for giving a urine sample. 


That was part of the procedures that were 


documented at the site. 


MS. BALDRIDGE: But they weren’t always all 


tested. 


MR. ROLFES: That’s not true. 


MS. BALDRIDGE: Well, there’s documentation 

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to support my opinion. 


MR. ROLFES: There is, for example, there 


was a large uranium hexafluoride release in 


1966 I believe it was. There is a report 


documenting what happened, what led up to the 


event of the release, the number of urine 


samples collected, the number of urine samples 


tested, et cetera. I believe there were more 


than 1,200 urine samples taken as a result of 


this event from I believe in excess of 200 


people. 


They did slightly change their 


procedure because they did not have the 


capabilities to do as many counts as they 


typically did. They normally count each urine 


sample with the barometer in triplicate. 


However, because of this incident and given 


the large volume of incident urinalyses, they 


reduced it to only duplicate counting of the 


sample. 


So there was a documented change. 


However, it appears that all of the urinalysis 


results were, in fact, counted. All of them 


that were collected were counted. Now there 


could have been some laboratory errors 

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associated with that, just like any other 


operation. There could have been samples that 


were lost, contaminated samples. Those are 


all possibilities. 


MS. BALDRIDGE: I just want to make the 


point that everybody involved in an incident 


isn’t always accounted for. 


MR. ROLFES: It’s very unlikely, but there 


may be an unusual case. However, I haven’t 


seen a case where, now it usually follows that 


if there’s an incident, that an individual had 


to report to Medical and provide a urine 


sample. And also --


MR. ELLIOTT: Was it within the discretion 


of Medical to say you don’t need to give us a 


urine sample? 


MR. ROLFES: I’ve never seen such a 


statement being made or documented. 


MR. RICH: Could I just make a statement? 


Based on a lot of years of experience at a 


number of different plants, when you have an 


incident, that is the time when you actually 


look at the most likely exposed people, those 


that are in the immediate vicinity of what 


happened. You sample those people 

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extensively, and that is (unintelligible). 


Those are the highest exposed people. There 


may be people in the building or in adjacent 


laboratories and if you don’t get significant 


exposures in the initial responders or those 


that were involved in the initial, you don’t 


sample everybody. It’s not necessary. 


MS. BALDRIDGE: I realize that. 


MR. RICH: And so you could have people that 


said I was there. I was in the building, but 


I was not sampled, and there’s a reason why 


they weren’t sampled because the maximum 


exposures were bounded by the sampling that 


was done as a result. 


MS. BALDRIDGE: My point is it’s not, when 


dose reconstructions were done, the 


information that I received even from the 


evaluation that SC&A did on the initial way 


that NIOSH was handling things was that they 


did not attribute that type of dosage 


associated with an incident except to the 


people whose file indicated that they were 


involved in the incident. 


In the case where five people were 


captured and in excess of 20 were involved, 

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only five people’s dose reconstructions 


hypothetically would have included a dose 


attributed to an incident. The other 15, 16, 


whatever, would not have been given that dose 


consideration. 


MR. ROLFES: I think what you may be 


referring to is our approach that we use for 


dose reconstructions based on our Technical 


Information Bulletin 0002. And this is a 


large intake that we assign to an individual 


on the first day of his employment as a 


demonstration of a large and very unlikely 


exposure to that individual. And this is a 


gross overestimate of the potential radiation 


exposures that an individual received, but it 


is done to provide a timely and quick response 


for the claim. 


So typically when we go back and 


revisit those types of dose reconstructions, 


the actual dose that the person could have 


received was typically much lower than what we 


assigned in our efficiency process. And I 


believe that may be what you’re referring to. 


DR. BEHLING: I think I understand very well 


what Sandra is taking about, and I fully 

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understand what Bryce was talking about. If 


you have an incident, and you realize given 


the circumstances investigative people would 


look and say among the 20 people who are the 


five most likely to receive the highest dose. 


You assess them, and that’s fine. 


And let’s assume that for the five 


highest exposed people they each get assigned 


100 MAC hours. But you realize there were 15 


others, and for those five people you will 


have in their personal files an assignment of 


100 MAC hours for that particular incidence. 


But you also realize that there were people 


who were in the periphery whose exposure may 


have been half of that. We know reasonably 


well that their exposure was less than a 


hundred, but for whom you have no data. 


And they’re not going to be covered by 


your TIB-0002 because that’s strictly used for 


the estimation of a person’s exposure who you 


know you’re not going to compensate. So 


that’s not going to cover that particular 


issue that we mentioned with Sandra. TIB-0002 


does not address the issue that Sandra raised 


here. 

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And that is among the 20 people, the 


hypothetical case of 20 people involved in the 


incident, five were assessed. Five people 


have in their personal records information 


that would allow a dose reconstructor to take 


into consideration that radiological incident. 


But the other 15 whose exposures were less 


than those five for whom data is available 


have no data, and therefore, will not have any 


reference or no accounting for that particular 


incident. I think that’s an issue. 


MR. RICH: Could I just add a comment to 


what you said? And that is that typically in 


an incident of this kind you sample people 


until you get results approaching nothing 


detected. In other words if you sample people 


in the immediate vicinity and you get -– and 


normally it’s recorded in (unintelligible) 


recording of CEDE, which is cumulative 


millirem dose, if you get down into the levels 


at which you cannot see them, then you don’t 


sample everybody else. If it’s less than 100 


millirem or something like that. 


DR. BEHLING: I would buy into that, but in 


the case I think that Sandra pointed out, it 

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may involve some things such as uranium 


hexafluoride, a very soluble or relatively --


yeah, hexafluoride, a very soluble material. 


And if when you sample the five maximally 


exposed individuals that you assume were 


maximally exposed, by the time you get the 


data back, you may not have any chance to re-


sample the people who are at the periphery. 


So that you can’t do this on a concurrent 


basis. 


MR. RICH: But you know you can take that 


maximum release of uranium hexafluoride 


whether the visible cloud that went for long 


periods of time, it is sampling (inaudible). 


Everybody in the plant was potentially 


exposed. 


DR. BEHLING: Yes. 


MR. RICH: And so they sampled to the point 


where they were assured that no one else, at 


least the exposures would be below permissible 


or detectable levels. 


DR. BEHLING: But what you’re saying is the 


fifth person that would have been sampled in 


this hypothetical case of 20 individuals, 


would represent a value between not 

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detectable. 


MR. RICH: Yes. 


DR. BEHLING: But you wouldn’t know that 


until you get the sample back, would it? All 


five had very, very high exposures, and now 


it’s days later and you’re looking at it and 


saying, oh my god, those other 15 probably had 


a high dose. It’s kind of late in the day to 


worry about this. 


 MR. MORRIS: There are other indicators, 

too. 

 MR. SHARFI: From the dose perspective, if 

they sample them later all you’re going to end 


up doing is increasing your minimum detectable 


dose. So they did have a routine program so 


even if they didn’t do an instant 


(unintelligible) sample, they do have a 


routine program that if it was a, by extending 


out the bioassay to anything longer, it just 


ends up from our program’s perspective 


assigning larger doses. 


So if their routine would have been 


positive, which would likely be due to the 


incident that is not in the record, you would 


have to, you would do bits which would result 

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in very large doses. So the end people who 


were associated with instant samples would be 


easier to bound on a much smaller dose level 


than the people who are much farther out, and 


you’re relying on their routine samples. So 


this might go more towards your completeness 


of data question of does everybody have 


bioassay data. And if they do, if they 


weren’t captured under the incident main 


(unintelligible), they still have monitoring 


data that we can base the dose on. 


DR. BEHLING: Well, I agree to a certain 


extent that even a year later if you have a 


monitored individual, and there’s evidence of 


an exposure, but then you have to make a 


decision is this chronic exposure or was this 


a year ago during the episodic event. And the 


two are quite different. 


MR. ROLFES: I’d like to read this into the 


record. It’s titled, “Bioassay Aspects of UF6 Fume Release”. And it’s NLCO-986. And this 


is in regards to the incident that I was 


referring to. There are some things that I 


thought were worth mentioning. 


There’s indication that, let’s see, 

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“all employees were instructed that if they 


had noticed any peculiar odor or had any 


reason to believe they may have inhaled some 


of the material, they should report to the 


dispensary. All involved in emergency actions 


were also asked to report to the dispensary. 


Urine samples were collected from all these 


individuals within a few hours of the 


incident. Follow-up urine samples were 


collected at the beginning of the workday for 


several days after the incident.” 


The activities in the bioassay 


laboratory. “There was no need for evacuation 


of the Health and Safety Building since it and 


the site of the UF-6 release are on opposite 


ends of the project. Most of the personnel at 


the bioassay lab continued their routine 


duties during the release. Urine samples 


began arriving soon after the release was 


stopped. 


“During the week following the 


incident, 280 employees and four visitors 


submitted 1,024 urine samples which were 


analyzed for uranium by fluorometric 


technique. In the usual procedure samples are 

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analyzed in triplicate and only (sic) one 


technician can analyze 60 to 80 samples per 


eight-hour day. Because of the large sample 


load and the need for rapid analysis, the 


procedure was changed to duplicate analyses.” 


It goes on to say regarding the 


results, “six employees voided urine samples 


in which the uranium concentration exceeded 


one milligram per liter. Their exposures and 


results are briefly discussed below. No 


albumin was found in any of the samples from 


these employees. There was no clinical 


evidence that any employee suffered damage as 


a result of this uranium exposure. 


Elimination of uranium was rapid. During the 


first few hours after exposure the biological 


half-life for most employees was four-to-six 


hours. After 24 hours most employees were up 


to their pre-incident level.” 


And it goes on to various case studies 


of the highest exposed individuals associated 


with this. So I thought it was important. 


DR. BEHLING: It dramatizes the exact point 


I’m making, and I’m not sure when that 


particular incident took place. But the 

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situation that Sandra discussed may have 


occurred many years earlier. When was that 


particular incident? 


MR. ROLFES: This was from, let’s see, it 


was 1966 is when it occurred. It was on, I 


believe, Valentine’s Day. 


DR. BEHLING: There were certain incidents 


involving a high exposures to uranium 


hexafluoride in the ‘50s. And again, the 


question is if you postponed monitoring people 


that you retrospectively realize should have 


been monitored based on your biological halftime for excretion, you may miss the point in 


time when you have a data point that is really 


something that you want to look at. 


And it addresses her issue saying that 


you may have incidents in early years where 


you only chose to monitor the maximally 


exposed individual who then have records for 


that incident, but not monitored people who 


were more at the periphery but still were 


significant exposures. For them you have no 


data. And I think that’s the central issue. 


MR. RICH: However, Hans, the normal 


sampling procedure was after a weekend off; 

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they normally sampled for long-term deposition 


and excretion as opposed to the initial 


(inaudible). So immediate sampling in 


response to an incident they deliberately 


looked for a maximum credible to have more 


sensitive, but to delay a few days would not 


hamper the total dose reconstruction. 


MR. CHEW: I don’t want to get into a long ­

- your question really kind of poses really a 


generic question if you really think about it. 


And you’ve got to look at the practices. When 


you have an incident where more than just 


indicators (unintelligible) and we know that 


from the practice of just looking at the 


bioassay data. That the monitoring itself, 


the air sampling itself, the contamination 


levels, and so you know as an Operational 


Health Physicist who the right people should 


have been initially monitored. And if you 


have a bioassay result come back or it’s just 


your indicators and you know the extent of the 


incident itself tells you who you should 


really be monitoring. And so there’s a lot 


more than the question, gee, I just monitored 


five people who were closest. 

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MR. RICH: Even the area of contamination 


gives you the boundary. 


MR. CHEW: You have to give some credit to 


the Safety people and the Operational people 


who say, yes, we feel comfortable we have 


adequately monitored all of the right people 


that had potentially a significant exposure 


due to this incident, okay, just a generic 


question. 


MR. ROLFES: There is discussion of the 


urine sampling program that’s well documented. 


I don’t know what site research database 


document number this is, but it does describe 


the sampling frequency and procedures for the 


individuals for different work places. 


FINDING 4.3-9
 

DR. BEHLING: The next finding is 4.3-9 on 


page 92, and it just addresses the issue of 


internal exposures that may have entered the 


body by way of ingestion as opposed to the 


more common pathway of inhalation. And we 


bring this up mainly because of all of the 


documentation that alludes to poor engineering 


designs, poor ventilation systems, high 


airborne concentrations, the lack of training 

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of personnel, the lack of anti-cees and other 


measures that might have mitigated internal 


exposures by way of careless handling. And so 


this particular issue focuses on the ingestion 


of thorium as a potential exposure pathway 


that at this point we’re uncertain as to how 


that will be addressed. 


MR. ROLFES: Ingestion intakes of thorium 


will be based upon information documented in 


the Battelle model. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro. With regard to the Battelle 


ingestion model, that’s one of the areas that 


we did have quite a bit to say. So I guess 


regarding basically the Battelle model recent 


TBD-6000 -- I assume 6001 is similar -- was 


based on a methodology that pre-dated the 


latest protocol that you folks have developed 


and applied for Bethlehem Steel. 


So one of our commentaries on 6000 is 


that that method probably has certain 


deficiencies. Whether or not this issue then 


becomes something that we would transfer over 


to the ingestion model, you know, because that 


is a cross-cutting issue, and I believe what 

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was used in Battelle was the generic approach 


that has been used across the board. But that 


approach has, in fact, been significantly 


modified with the method that was adopted for 


Bethlehem Steel. 


MR. MORRIS: This is Bob Morris. I think 


that that’s true, John. And if I recall your 


comments, you actually analyzed the impact of 


that change very closely, didn’t you? 


DR. MAURO (by Telephone): Yes, we did. 


MR. MORRIS: And my recollection of that is 


that depending on whether the new model 


applies or the older model applies the answer 


is still consistent within a factor of 50 


percent. Is that --


DR. MAURO (by Telephone): I’d have to go 


back and quantitatively, but I remember we did 


have quite a bit of commentary on the Battelle 


model and tested it against the, compared it 


to the Bethlehem Steel. And there was some 


differences, but I guess what I’m saying is 


that we have engaged this issue extensively, 


and it’s really a generic issue that’s crosscutting. 


MR. MORRIS: That’s right, and we have no 

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objection to following the lead that has 


developed on this. My point here is that it 


probably is just a parameter that’s in the 


equation. It’s not the equation itself. And 


also the ingestion pathway provides relatively 


low dose compared to inhalation. 


DR. MAURO (by Telephone): Oh, I agree with 


that completely. 


MR. MORRIS: Okay. 


DR. BEHLING: The next issue of 4.3-10 --


DR. ZIEMER: Where are we leaving this one, 


4.3.9? 


 MR. CLAWSON: Well, I was going to ask a 


question. So have we reviewed this OTIB? 


DR. ZIEMER: Is this covered by the 


independent review of the Battelle model or --


DR. BEHLING: SC&A reviewed the 6000 OTIB. 


MR. MORRIS: It’s the Battelle Technical 


Basis Document 6000. 


DR. BEHLING: And if that’s to be applied 


we’ll have to look at that again to be sure 


that that’s something that’s --


MR. MORRIS: It’s the subject of a 


Procedures working group right now, and SC&A 


has provided comments on it. And I think it’s 

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in the process of being considered. So my 


suggestion is to take it in that form where 


it’s already on the agenda. 


MR. GRIFFON (by Telephone): The only thing 


is this might be the more pressing --


MR. HINNEFELD: I would prefer -- this is 


Stu Hinnefeld. I would propose that Brad talk 


to Wanda, and they decide between them which 


forum to solve it in because I don’t know that 


this work group wants to be held hostage to 


the schedule of the Procedures working group. 


MR. ELLIOTT: Or vice versa. 


DR. ZIEMER: Or vice versa. 


MR. HINNEFELD: I mean, this is a little 


more, this specific for a site and it may be 


better to resolve that one in this forum than 


in a different --


DR. ZIEMER: Than in the Procedures group. 


MR. HINNEFELD: Right. 


 MR. CLAWSON: I guess I’m still kind of at a 


loss what to be able to do on an action on 


this. I guess we need to be able to look at, 


I guess I’d have to talk to SC&A about this. 


How do we want to proceed on this one? 


Because John’s made a comment that this is 

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something that they were --


DR. BEHLING: I would say this. Since we 


have no empirical data such as fecal analysis 


which would give us some handle as to whether 


or not the ingestion pathway was a significant 


contribution to internal exposure, we’re going 


to have to rely on a generic model and the 


Battelle-6000 may be your option for making a 


default model that can be applied here. But 


at this point we haven’t looked at it to be 


sure that that’s the reasonable alternative 


for dealing with the unknown of ingested 


thorium. 


DR. ZIEMER: Well, I’m trying to recall, and 


maybe John will remember, John, does the 


Procedures group have the SC&A comments on --


DR. MAURO (by Telephone): Yes, it does, but 


it was transferred to the, in other words as 


you recall in the Procedures group, whenever 


we came across an ingestion pathway issue such 


as we are doing right now for this case, for 


this site, what we did in the Procedures group 


was transfer it to a global issue. Namely, 


right now the ingestion model is the subject 


of a generic, complex-wide OTIB that’s being 

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in preparation. 


And so designate it as, okay, we’re 


not going to address it in the Procedures. 


It’s being transferred over as a global issue. 


Now this brings up an interesting question. 


That’s certainly appropriate in the Procedures 


group where we have the luxury to do that. 


In this particular case here we have 


an SEC and time is important. Perhaps the 


appropriate thing to do at the next meeting is 


to look at the comments -- well, I guess it’s 


a two-step process. 


One is apparently the TBD-6001 has 


adopted the same methodology in 6000. We’ll 


operate on the premise, TBD-6000. Two, it’s 


probably a good idea to make sure that, okay, 


the comments that were made related to TBD6000 that SC&A made, is there anything about 


this particular circumstance now at Fernald 


that is, you know, the comment also applies 


here and in the same way. 


There may be something about the 


circumstances of exposure at Fernald whereby 


the methodology in 6000 may or may not be 


applicable. But assuming it is, okay, now I’m 

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taking it now the third step would be, okay, 


we all agree then that the comments on TBD6000 have applicability here. Then the 


question becomes let’s resolve that here 


whereby we look at the comments, explore the 


significance of the comments that SC&A made. 


And then at that point, of course, 


NIOSH could either say, yes, we agree with 


those comments, and we will revise the 


methodology in accordance with those comments 


which by and large say we like Bethlehem 


Steel, but we don’t like TBD-6000. Now the 


magnitude of that difference as pointed out 


previously might be relatively small. I’m not 


quite sure. But it seems to me that’s a path 


forward to resolve the issue here in a timely 


fashion. 


DR. BEHLING: John, I haven’t looked at the 


Battelle model but and just a quick question, 


is that model linked to something such as air 


concentration, surface concentration, 


(unintelligible) ingestion? 


DR. MAURO (by Telephone): Yeah, it’s an 


improvement over the old deposition velocity 


approach and then the assumption that ten 

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percent -- I don’t want to get into it. 


There’s a lot of structure to it. There 


really were multiple developments of the 


ingestion model. One was the original method 


which we had some serious concerns about 


because we didn’t think it was scientifically 


valid. Eventually all of those concerns were 


resolved in the Bethlehem Steel site profile. 


And now in this TBD there is another 


method which I would say is some place in 


between the method that originally was 


developed and the method that was developed 


for Bethlehem Steel. So it’s an improvement 


over the original one that we had some serious 


concerns with, but it’s still somewhat 


different and less claimant favorable than the 


Bethlehem Steel method. 


And I believe that NIOSH right now is 


in the process of perhaps formalizing the 


Bethlehem Steel method as an OTIB that would 


have cross-cutting operability everywhere. 


And my sense would be when and if that occurs, 


it would also be applied here to the TBD-6000, 


-6001 documents. 


But again as I mentioned I don’t think 

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we have the luxury to wait for -- I don’t 


know. This is certainly your call -- to wait 


for that or should we try to deal with that at 


this time? That, of course, would be, the 


only problem with that is that we’d be moving 


ahead of the global investigations. 


MR. GRIFFON (by Telephone): Well, my sense 


is -- this is Mark. My sense is let’s have an 


action item that says SC&A to review TIB-6001 


for application to Fernald workers. I can’t ­

- and we can coordinate with Wanda. I mean 


I’m on the Procedures work group also so we 


can coordinate with that group. But I don’t 


think we want to hold up an SEC work group for 


a Procedures, you know. 


MR. ELLIOTT: This is Larry Elliott. If I 


can offer another suggestion. You have Mark’s 


suggestion, Mr. Chairman. It seems to me that 


without Jim Neton here I’m at a disadvantage. 


I don’t know where he’s at on this across the 


complex ingestion model. But I do know that 


we liked the Bethlehem Steel approach. 


I’m a little bit concerned about where 


TBD-6000 leads us and whether or not it’s the 


right one or not. And we need to think 

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through that. I think it needs to be NIOSH 


that comes forward with what we’re going to do 


on Fernald and ingestion and which model we’re 


going for and then you can mac (ph) to that. 


Does that take anything away from you, Mark? 


MR. GRIFFON (by Telephone): No, no, no. I 


thought the decision was made that you were 


going with TIB-6001, so I was starting there. 


But if you --


MR. ELLIOTT: I’m asking Mark Rolfes if it 


helps him or not or it hurts him. 


MR. ROLFES: We have documented right now 


that in the matrix that our approach will be 


to rely on the Battelle model. NIOSH does 


have a separate technical information bulletin 


on ingestion pathways as well. So we haven’t 


finalized the methodology, and our finalized 


methodology will be in our thorium white 


paper. 


So we did not believe that this was an 


SEC issue but rather a dose reconstruction 


issue as to how much we are assuming a person 


ingests rather than inhaled. So typically for 


most organs for which we complete dose 


reconstructions, the inhalation pathway 

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results in a higher dose. 


MR. GRIFFON (by Telephone): And, Mark, I 


was actually going to add on that it may be in 


the course of SC&A reviewing your model, now I 


guess I’ll take back that action because maybe 


it’s SC&A reviews the approach described in 


the white paper. I thought you were saying 


TIB-6001 was one. 


Anyway, it may be that this is a site 


profile issue once they do that review, and we 


don’t have to close on TIB-6001 if that’s the 


model. We could just examine it enough to say 


clearly the data’s there. They have 


sufficient data to bound, and we don’t need to 


know exactly the how’s and particulars for the 


SEC process. And the rest can go back to the 


Procedures work group review, and it becomes a 


site profile issue more than an SEC issue. 


DR. ZIEMER: Well, then it would await the 


white paper still so that you would tell us 


what direction you’re going and then --


MR. ROLFES: That probably would be the 

best. 

DR. ZIEMER: So it becomes a white paper 

issue right at the moment. 

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MR. ELLIOTT: So it’s back in our lap. 


MR. GRIFFON (by Telephone): So it’s back 


with NIOSH with the white paper. 


 MR. ELLIOTT: Tell you which way we’re 


going. It bothers me that I don’t know why we 


would have a variety of ingestion models out 


there unless they’re circumstance driven and 


so we need to look at that. And I don’t know 


if Mark and his folks have talked to Jim Neton 


about this specifically, but I think we need 


to make sure that Jim’s included in this 


discussion so that we can move forward. So 


I’d ask that it be put back on NIOSH’s 


shoulders to deal with here. 


 MR. CLAWSON: Okay, and as soon as we know 


then we can address it and go from there. 


Hans. 


FINDING 4.3-10
 

DR. BEHLING: Yeah, the next one is 4.3-10, 


and I’m not sure with Dr. Wade’s commitment, 


are you, can you stay for a few more minutes 


before we break for lunch? 


 DR. WADE: Sure. 


DR. BEHLING: So let’s maybe try to go 


through 4.3-10, and then hopefully that will 

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bring us into our lunch hour, and we can take 


a break. 


But the issue of an unanswered 


question regarding data integrity, there’s two 


elements to that. In this one, we didn’t go 


through it extensively, but we do have one 


affidavit that was provided by a member of the 


team of hygienists who was there to assess 


obviously the work environments by air 


sampling, and he had some disparaging comments 


to make about some of the protocols and things 


that he felt were inappropriate, and obviously 


you may want to read that. 


That’s provided as an Attachment 4.3­

10. It’s the sworn affidavit by a person, and 


he goes through a whole series of things that 


lead one to question to what extent was the 


program that was designed to protect the 


workers compromised by overzealous management 


who was more concerned about maintaining 


production quantities over worker health. And 


you can draw your own conclusions. 


In addition to this particular one 


which clearly does affect the individual 


workers, there were some other outstanding 

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issues that Arjun had identified in his TBD 


that go beyond the working environment 


necessarily to perhaps other indiscretions 


that involved the use of not counting samples 


that involved stack monitors and elsewhere. 


And I’ll let Arjun talk about those 


separately. 


DR. MAKHIJANI: Well, the stack monitor 


samples that were not counted were I think in 


the ’69 to ’81 period or ’68 to ’81 period. 


We were talking about that at the break. This 


problem is cited in the petition along with 


some documentation if I remember right, Sandy. 


And I believe the person involved who made 


that decision to not count them regularly and 


entered zeros even when they were not counted 


actually has acknowledged that that was done. 


So long as NIOSH is relying on -- this 


is an issue that concerns directly 


environmental dose. So long as NIOSH is 


relying on the national lead environmental 


dose data that was a problem. But I 


understand NIOSH is now relying on the John 


King environmental dose model. 


MR. ROLFES: I’d like to clarify. The most 

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important piece of information is the 


urinalysis data --


DR. MAKHIJANI: I understand that. 


MR. ROLFES: -- in the person’s file. 


DR. MAKHIJANI: But environmental dose is 


assigned to people who don’t have urinalysis. 


MR. ROLFES: For a small fraction, a very 


small fraction of the workers at Fernald may 


not have had urine sampling results. If we 


have reason to believe that they were exposed 


to airborne uranium of significant amounts we 


are going to be using a coworker intake model 


for those individuals. 


DR. MAKHIJANI: Okay. The other question 


that arises, I think maybe, Sandy, you raised 


this so maybe you want to state the issue in 


that regard. 


MS. BALDRIDGE: Concerning the accuracy --


DR. MAKHIJANI: Well, reliance on data and 


documents for use by a particular individual. 


MS. BALDRIDGE: At the last meeting it was 


brought up that the environmental portion of 


the technical basis document was almost 


finished. And my concern is whether they used 


the same references that this individual in 

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question provided for the revised document as 


was for the original, the one that the 


individual acknowledged not looking at certain 


data before they even wrote the report. 


Without mentioning names, do you have any idea 


what I’m talking about? 


MR. ROLFES: I’m not exactly sure what 


you’re referring to. 


 DR. WADE: Is there a reference cited? I 


think you can mention that. 


MS. BALDRIDGE: There were several 


references cited from Mr. Bobeck (ph) that 


were used in the original environmental 


portion of the technical basis document. The 


deposition that he gave at the trial. Before 


the trial he indicated that zeros had been put 


into the data in lieu of actual measurements 


which affects the credibility of the data used 


in the environmental doses based on stack 


releases. 


I’m hoping that anything that would 


have his name attached to it either directly 


or other documents that might have used him as 


a reference would be eliminated from 


consideration for the revised environmental 

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portion of the new technical basis document. 


MR. ROLFES: We will not be eliminating his 


input because it has been very valuable to us. 


We have spoken with him in great detail 


actually in previous meetings to get a better 


picture of workers’ exposures, effluent of the 


site. We do have documented interview notes. 


I haven’t made them available yet to the 


Advisory Board members but documented probably 


-- what, about maybe five hours speaking with 


him? So we have about 30 pages of notes of 


interviews with him. And we can --


MS. BALDRIDGE: Do you have notes of what he 


did while he was there to know where he 


actually applied data and where he didn’t 


apply data? 


MR. ROLFES: I would have to ask Jim --


MS. BALDRIDGE: Or his recall from his 


recollection? 


MR. ROLFES: We can take a look and see what 


it is exactly that’s being referred to, and we 


can consult with him to help in clarification. 


MS. BALDRIDGE: Because Arjun had mentioned 


like from 1968 through ’81, well, that’s, you 


know, 12 years. I would just question unless 

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he actually had notes that he could rely on, 


anybody’s ability to remember, but why they 


put a certain number down at any particular 


time during a 13 year timeframe. 


MR. ELLIOTT: Yeah, but your point is you’re 


questioning how we’re going to handle the 


testimony that Mr. Bobeck (ph) gave at the 


trials in regard to the documentation that his 


name is associated with elsewhere. 


MS. BALDRIDGE: Right. 


MR. ELLIOTT: That’s what your point is, 


okay. It’s something we will look at. 


DR. BEHLING: And let me go back in the 


context with the discussion about this 


individual. I think that the affidavit that I 


included as Attachment 4.3-10, I think we 


briefly touched on it the last time. And, 


Larry, you mentioned that this individual you 


hired yourself. 


MR. ELLIOTT: I did not hire him. 

DR. BEHLING: Or NIOSH hired him. 

MR. ELLIOTT: I worked with him. 

DR. BEHLING: But I think your comment if I 

can recall was that he was a credible 


individual. 

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MR. ELLIOTT: Yes. 


DR. BEHLING: And his comments are very 


strongly worded comments. And a person who 


was there, he’s not a bystander. He’s not 


looking at this from the viewpoint of a 


distant observer. He’s not a person that I 


would define as a person with an axe to grind 


who has malice on his mind. 


I have to look at this and question, 


therefore, to what extent was this whole 


process more pervasive than we’re willing to 


admit, that it may have involved other 


industrial hygienists who should perhaps be 


looked at or contacted to see if they have 


similar stories to talk about or present in a 


sworn affidavit and let’s go back. 


After all, we are going to be using 


air monitoring data exclusively for thorium 


intakes prior to ’65, ’68. And for us to look 


at that data and say it’s credible requires us 


to have some feeling or assurance that we’re 


not looking at data that has been manipulated 


as he implies in his affidavit. 


MR. ROLFES: Well, the affidavit was 


referring to a uranium process area, Plant 5, 

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I believe, which our dose reconstruction 


approach for reconstructing uranium exposures 


would rely primarily on urinalysis data. So 


it really wouldn’t be an issue for a uranium 


exposure. But for thorium it could be if this 


was a pervasive and commonplace practice. 


However, based on interviews with 


industrial hygienists from Fernald this was 


not a pervasive practice. Industrial 


hygienists were told to sample the highest 


areas where a person could potentially be 


exposed. They were trying to collect samples 


that were representative of the individual’s 


breathing zone. They were taught to resample 


high areas. So when there was a high 


exposure, that attracted much more attention. 


There was nothing in the affidavit 


that I saw that indicated that the high air 


sample results were destroyed. It actually 


appears that there were approximately six high 


air samples followed by one low one that was 


taken to satisfy the individual’s supervisor. 


DR. BEHLING: Which one is the sample of 


record? 


MR. ROLFES: All seven. 

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DR. BEHLING: Is that a fact? 


MR. ROLFES: It appears to be. There was no 


indication that the information had been 


altered in any way. 


DR. BEHLING: Well, you may log, or you may 


identify six or seven air samples and then 


decide, well, this one’s the one that we’re 


going to put into the records as the one that 


is credible, perhaps not worry about the other 


six that we didn’t agree on were reasonable 


samples (inaudible) here. 


MR. ROLFES: That’s not accurate. If you 


take a look, they’re all air sampling 


datasheets, industrial hygiene datasheets. It 


has multiple results typically from the same 


operation in various times as you had alluded 


to before. And all those sample results were 


in fact recorded. So all of them would have 


become part of the record. 


DR. BEHLING: It’s hard for me to accept. 


As I said, he doesn’t go into any detail. He 


does not talk about the destruction of sample 


data, but the implication is that perhaps they 


were not documented. 


 MR. CLAWSON: Well, the one statement right 

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here, “on several occasions during the term of 


my employment I got air dust sample results 


that were above the MAC. I was told by my 


supervisors that the results were in error. I 


was told to go back and resample.” 


MR. ROLFES: But it did attract additional 


attention because they didn’t expect the air 


concentrations to be as high as what was 


recorded. So time and time again the 


individual was sent back into the work area to 


resample because they did not believe the air 


samples could have been that high. There’s no 


indication that the high air sample results 


were deleted from the record or ignored. They 


attracted additional attention so that they 


could reduce the exposure in the workplace to 


the people. 


DR. BEHLING: When you have multiple high 


values, you have to start to become a believer 


and not keep sending the guy back. I have a 


very different opinion that is not consistent 


with your opinion. But I would certainly in 


context with what was said previously about 


the air emissions into the off-site or the 


stack monitors, I would certainly want NIOSH 

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to perhaps contact this guy and clarify some 


of these issues. What was done with these 


high sample results? Were they discarded? 


MR. ROLFES: No. 


MR. ELLIOTT: He’s no longer with us. He 


passed away. 


DR. BEHLING: Oh, he’s passed away. I guess 


we forfeit that option. 


 MR. CLAWSON: And for us to be able to say 


what was done with these samples I think would 


be questionable, too. Because there’s only 


one person that can tell us, and 


unfortunately, he’s not with us. 


DR. MAKHIJANI: Brad or Mark or working 


group, I mean, just in terms of what we are 


doing. Do we await, is NIOSH addressing this 


in the white papers and then we look at it or 


we are supposed to -- I’m unclear as to 


whether, who’s doing what at this stage. 


MR. GRIFFON (by Telephone): Yeah, I was 


just going to ask for 43-10, I thought I heard 


Larry offer a response to Sandy for an action 


or follow up, and I might have missed 


something. Do we have an action on this item, 


4.3-10 for NIOSH to follow up on something? 

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MR. ELLIOTT: Well, I committed to Sandy 


that we would consider her comments or 


suggestion that this one individual’s offering 


and reference material may be compromised by 


what he offered in testimony in a trial 


situation. That’s what I committed to. 


On this particular point that we’re 


just discussing, however, I think what I’m 


hearing Mark say is that we feel we have this 


information for consideration in what we do. 


We didn’t lose any data here. We have it. We 


had the testimony prior to it being included 


as part of the documentation in a petition. 


So we have, you’re not the first ones to read 


this information from this one individual. We 


had it before the petition was presented to 


us. 


So, is that correct, Mark? 


MR. ROLFES: Yes, correct. 


MR. ELLIOTT: We feel we do have the data 


that is mentioned in this affidavit that was 


submitted by this one individual. 


MR. ROLFES: He does not document exactly 


what time period and what air sample numbers 


these were that he was referring to. However, 

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we do have air sampling data associated with 


this individual, this industrial hygienist. 


But furthermore, I’d like to reiterate 


that for the process where he was collecting 


the uranium air samples, we would not be 


relying on uranium air sampling data to 


reconstruct an individual’s dose. We would 


rely on their bioassay data. 


MR. ELLIOTT: And I would further that to 


say that we have, I believe we’ve not run 


across information that tells us that there 


was a pervasive set of actions here that need 


to be accounted for in how we go about doing 


dose reconstruction. Yes, we have this one 


source of concern that’s provided, and we’ve 


looked at that. But we don’t see in a broad 


sense of all the information that there’s a 


pervasive problem. 


MR. ROLFES: Correct. 


DR. BEHLING: I do have to, not to beat a 


dead horse, but when I read the statement, 


“when I got the air dust survey results that 


were above the MAC, I was told by my 


supervisor the results were in error.” The 


question is would you record a result that 

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your supervisor said was in error? 


I mean, wouldn’t you accept the fact 


that your supervisor knows more than you do or 


he has authority over you. And when he says 


you did something wrong, would you necessarily 


record something that your supervisor tells 


you is in error? My gut feeling is you would 


not. 


And what he says is that when he 


reversed himself, and his back was to the flow 


of the air, he would get the much, much lower 


air concentration readings on his air sample. 


And that became the correct value. 


Now I have a difficult time in 


accepting the notion that in this case when he 


said five or six times he had high dose and 


then he gets the low dose that all the samples 


for that particular assessment were, in fact, 


documented and are part of the record. If 


someone says to me you made an error here, I 


would say, well, thank you very much. If I 


believe him, I would probably discard those 


data and probably rely on the one data that’s 


obviously acceptable to a supervisor. And 


this is my opinion. 

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MR. GRIFFON (by Telephone): Yeah, my 


opinion, Mark, is I agree with what you said 


about the fact that you’re not relying on the 


air sampling for the uranium. I guess this 


finding speaks more to the overall data 


integrity question. 


And I wondered if as a follow up, you 


know, sometimes these Health and Safety 


reports or Health Physics reports that we 


talked about have summary stats including 


number of samples greater than a MAC value or 


number of, you know. I wonder if some of 


these summary reports would, during that time 


period or if they’re available, would possibly 


shed some light on this. 


In other words if it shows a number of 


values greater than the MAC consistent with 


this guy’s sampling, then actually that 


supports your argument that not only did he go 


in and measure all these high values, they 


were translated into the quarterly report. I 


guess that would corroborate the fact that, 


yeah, it would support that those measurements 


were not just discarded and the low one was 


recorded. 

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I guess that’s the question. It 


speaks to the data integrity. We know that 


you’re going to rely on urinalysis, but this 


speaks to data integrity and just trying to 


think of a way to close it out. And one way 


might be to examine the quarterly report 


during that time period. 


DR. BEHLING: And, Mark, I don’t, I mean, 


I’ve looked at enough data to realize that 


there were plenty of air sampling for uranium 


and for thorium where the air concentrations 


were very high. And so you can look at those 


and say, see, they recorded high air samples. 


But there may be selective incidents, 


and I suspect that in some instances these 


measurements that we’re talking about or that 


this hygienist is referring to may have come 


as a result of modification to the plant. 


There were so many memoranda that I looked at 


where there was a consistent effort to improve 


the engineering controls regarding ventilation 


systems. 


And I’m sure that there have been 


attempts where perhaps some effort was made at 


some significant cost and perhaps slowing 

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production where there were changes made to 


ventilation systems and other things and the 


expectation was, oh my god, yeah, this is 


really going to improve or reduce the air 


concentrations, improve the working 


environment, and it turns out it didn’t quite 


meet their expectation. 


And perhaps this particular effort 


here that we’re talking about here was not so 


much directed against cheating someone out of 


an air dose or intake, but to somehow or other 


to cover your butt with regard to having 


invested a tremendous amount of money, stopped 


work, introduced a lot of things involving 


ventilation systems and changes in work 


practices without no real significant benefit 


after the fact. And I suspect that this might 


be just one of those cases. 


MR. ELLIOTT: Another possible scenario. 


Another possible, I mean, I’m an industrial 


hygienist, and when I’m told to go out and 


take air sampling, I ask, well, what’s the 


purpose. Is this process point sampling or is 


this sampling to determine what potential 


exposure might be to an individual standing at 

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a work station? 


So this particular individual may have 


been sent out on a process point sampling 


effort to try to see if he could sniff out 


something that no one expected to be there. 


And when he found it, he was met with 


resistance. 


DR. BEHLING: Yeah, it may have been a very 


episodic issue, not a pervasive, systemic 


problem, but one that involved the situation 


where significant monies had been spent on 


modifying the plant system engineering 


controls that turned out to be of little use. 


And the people didn’t like it. Who’s to say? 


We don’t know. 


MR. ELLIOTT: Who knows? We could have an 


employee-supervisor issue going. 


MS. BALDRIDGE: I’d like to add something 


here. I have a letter from 1985, Battelle’s 


letterhead, and it’s addressed to the Health 


and Safety Environmental Division at FMTC. 


And it goes on they’re requesting an open 


house for employees and their families. It 


says that the gentleman requesting the open 


house is unaware of the extent of the 

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contamination problems at the site. 


It goes on the last paragraph of the 


letter it says, “There is, however, yet a more 


compelling reason not to invite large numbers 


of people, particularly children, into the 


facility. As we have indicated, once friskers 


are placed in the change room and become 


readily available to workers, they will be 


very likely to learn that they have frequently 


been leaving the plant contaminated.” 


Now to me this shows a mindset that 


they weren’t willing to have an open house for 


the purpose of the employees not finding out 


how contaminated they were. It just looks 


like as Hans said somebody’s trying to cover 


this up. 

 MR. CLAWSON: Where do we want to go with 

4.3-10? 

DR. BEHLING: 4.3-10. It’s just an issue 

that we have occasional an insight as to 


perhaps the mentality of people who were, 


whose charge was to protect the workers who at 


least in this case that the person with 17 


years experience talks about things that are 


somewhat disturbing. And I just have to raise 

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the whole thing. 


MR. GRIFFON (by Telephone): Well, can I 


ask, you know, NIOSH indicated that they 


interviewed many other industrial hygienists 


and didn’t, I mean, I think Larry is correct 


in saying that really our focus should be was 


this a systemic problem. Is this an isolated 


incident? We really have to try to determine 


whether there was some sort of systemic 


problem here. And I don’t know if SC&A has 


looked at those interviews? I’m assuming 


they’re on -- I haven’t looked at all of them. 


DR. MAKHIJANI: I don’t believe they’re 


posted. Are these interviews posted? 


MR. ROLFES: Only, let’s see, I’ve 


documented, let me point to the end of the 


matrix. I did identify a couple of interview 


transcripts, site research database document 


reference ID 26115 and 31023. There will be 


at least two additional ones added. 


DR. MAKHIJANI: They’re on the site research 


database you believe? 


MR. ROLFES: Yeah, I have put a couple on, 


maybe one or two onto the O drive for the 


Advisory Board. 

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MR. GRIFFON (by Telephone): I’m just going 


to capture that as an action, Mark, just as 


reminder for all of us that NIOSH will post 


industrial hygienist interviews on the O 


drives for SC&A to review. 


MR. ROLFES: Mark, we do have that on the 


last page of the matrix. I’m sorry, I didn’t 


MR. GRIFFON (by Telephone): Oh, it is on 


the last page, okay. 


MR. ELLIOTT: Just the two that have been 


posted out of perhaps three more coming or two 


more coming? 


MR. ROLFES: I don’t recall. I know I have 


two with me right now. 


MR. MORRIS: Those two that I sent you in 


the e-mail with reference numbers, then 


there’s two that we provided last week. And 


then one --

MR. ROLFES: One that had been done awhile 

back? 

MR. MORRIS: Right. 

MR. ROLFES: Okay, so there should be a 

total of about five, and there may have been a 


previous one. There’s --

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MR. MORRIS: But only one of those is an 


industrial hygienist interview. 


MR. ROLFES: Yes, correct. 


DR. BEHLING: The reason I do have to 


question whether or not the potential exists 


for a systemic problem is the fact that if 


this had been an individual who was fingered 


by let’s say somebody else who said we know 


this guy doesn’t like to go out there and 


sample so he sticks a sample in there, ends 


it. Then this would obviously be confined to 


a single individual. 


But in this case he’s the individual 


who’s fingering his supervisors as he does on 


bullet seven. And if this supervisor was in 


charge of all of the industrial hygienists, 


then perhaps his corruptive mentality would 


impose certain feelings and directives to not 


just this particular hygienist, but to all. 


And so therefore, I have to question whether 


or not this is an isolated event or if it 


involves the entire group of hygienists whose 


collective job was to protect the worker. 


MR. ROLFES: That’s a good point, and --


MR. HINNEFELD: It’s Stu Hinnefeld, if I 

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could just make one comment because I knew 


some of the people. I didn’t know the person 


who wrote the affidavit in the petition, but I 


knew some of the people who worked out there. 


Arjun a while ago when we were talking 


about thorium and the fugitive emissions from 


the pilot plant, there was a rather 


condemnatory letter written about how terrible 


the conditions were in the pilot plant that he 


read from. That was written by an industrial 


hygienist, wrote that. 


DR. MAKHIJANI: Right. 


MR. HINNEFELD: But before we paint the 


entire department with a (unintelligible) 


brush, I think you should look at the volume 


of the things that were written. They’re read 


a lot more like Keith* read. I mean there are 


plenty of stuff out there, I mean, like Arjun 


read. There are a lot of those correspondence 


like that out there before you want to make 


some sort of judgment about some sort of 


inherent supervisory-imposed brush on that. 


DR. MAKHIJANI: I would support what Stu 


said in terms of the volume of documentation 


that shows high air sampling. Not that, it 

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doesn’t negate what this person said, but I 


think that there is a lot of documentation 


with very high air samples, and some of it’s 


actually higher than anything recorded any 


place that I know of. 


But there’s also this affidavit. I 


mean, it would be useful to see these 


interviews, but there’s only one with an 


industrial hygienist, and I guess is that the 


person you were talking about it? 


MR. ROLFES: Yes. We also have attempted to 


contact the industrial hygienist of whom we 


are speaking. We’ve attempted to contact his 


supervisor, and we have not been able to 


contact him to date. 


DR. ZIEMER: Mark, how about other logbooks? 


Have you done any spot checking? The reason I 


raise the logbooks is I don’t know what their 


practice was at this facility, but my 


experience at Oak Ridge was that the first 


thing you did after you did a survey, it went 


into a logbook long before a supervisor ever 


saw the results. And those logbooks typically 


had the results. You counted an air sample. 


It was in the logbook right then. 

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And so someone telling you that you 


got the wrong results isn’t going to change 


what’s in the logbook unless somebody rips a 


page out. They’re there, and they’re dated 


and signed and numbered. Are there some log, 


you talked about trying to recover some 


logbooks. Do we have some that you could spot 


check and say, yeah, here’s the logbooks, and 


here’s where it’s showing up on the survey 


data? 


MR. ROLFES: We had attempted, we contacted 


DOE to see if we could recover logbooks from 


industrial hygienists. They responded that 


they did not have any logbooks. Based on the 


query that we did it did not appear that there 


were any logbooks at Fernald. However, we do 


DR. ZIEMER: They didn’t keep logbooks or 


they just can’t find them? 


MR. ROLFES: I’m not sure. 


Stu, do you know if the industrial 


hygienists did in fact keep logbooks separate 


from the industrial hygiene datasheets? 


MR. HINNEFELD: From memory I can’t say 


definitively. My recollection is they carried 

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record books around like I do, but I don’t 


recall if they did. 


MR. SCHOFIELD: Could they possibly have 


used survey sheets? I know this was a common 


practice at Los Alamos. Instead of being put 


in logbooks they had survey sheets they did. 


MR. RICH: Did we ever have access to survey 


sheets? 


MR. ROLFES: We do have the survey sheets. 


MR. SCHOFIELD: Maybe that’s what you’re 


looking for to find was the survey sheet where 


they were logged the first thing. 


MR. ROLFES: That’s it. I’m still confused 


about that myself. I do have, I wanted to 


point out some, well, here’s an example of an 


air dust analytical sheet, and this says 


National Lead Company of Ohio Analytical Data 


Sheet. And this has the sample number, the 


sample time, a description of the sample being 


taken, air volume sample time, sampling and 


the results as well. 


And it’s what I initially believed was 


that this air sample result, this would have 


been information that was recorded in a 


logbook. This would have been the raw data 

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here. I’m not sure if that’s true or not, but 


we have requested logbooks to see if there are 


logbooks that exist separate from the 


analytical data sheets. Without going through 


the records again I can’t answer whether there 


were separate logbooks from the analytical 


data sheets. 


 MR. CLAWSON: You know, it basically comes 


back to data integrity, and I think that’s the 


root of the whole issue here. And we’ve got 


conflicting affidavit to what other stuff is. 


I guess I’m at a loss of what we need to look 


into on this, and what we’re going to do with 


this affidavit because --


DR. BEHLING: Well, it adds to the 


collective uncertainty that started out with 


the issue of how good is the air sampling. 


How good is general air sampling relative to 


BZ, and even we heard earlier from Mel that 


you mount the BZ air samplers on the same 


person and may have five different values. 


So you add to the issue to the 


uncertainty as to where a person worked, what 


his job description was and then add to that 


the issue of potential air sampling that 

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raises questions about these select samples, 


and you have to come to the conclusion that 


air sampling’s not a very accurate measure of 


what a person was exposed to and take that 


into consideration when we use it for dose 


reconstruction. 


You cannot look at these data in a 


definitive way and say this is precisely. You 


have to recognize that the uncertainty 


associated with air sampling data is very, 


very large. 


MR. ROLFES: Correct, that’s a good point. 


And all uncertainties go to the benefit of the 


claimant. 


 MR. CLAWSON: Right, and so this basically 


comes back to the person’s personal file on 


their bioassay or whatever and so forth. 


DR. MAKHIJANI: Oh, no, Brad, actually the 


thing that this throws into question is can we 


trust the thorium air sampling data. If you 


have high values recorded and somewhere, I 


think we’re not talking about the uranium 


data. Mark Rolfes is right about that, but if 


you’re using coworker models and bioassay that 


then the specific uranium air data are not in 

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question. I would suggest that maybe --


MR. ELLIOTT: But this affidavit speaks to 


uranium air sampling, correct? 


DR. MAKHIJANI: Yes, and it raises a 


question whether it was a pervasive practice. 


We do have what Stu said is high values were 


clearly recorded so it was not happening all 


the time. We know that. But accepting this 


affidavit means it happened at least once. 


And so where the actual matter is in regard to 


a particular supervisor or particular employee 


or particular period we don’t know. And it 


may be useful to do a couple of independent 


interviews. Maybe the working group wants to 


do it or the industrial hygienists from -- we 


don’t know the period from which this 


happened. 


DR. BEHLING: Yeah, it was a 17-year period. 


Also, and he alleged --


DR. MAKHIJANI: And he alleged that it was a 


routine thing in that period. 


 MR. CLAWSON: And whatever timeframe that we 

had --

DR. BEHLING: And his second bullet here 

identifies the employment period. 

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DR. MAKHIJANI: What was the period? 


DR. BEHLING: It’s blanked out actually. 


It’s just in the ‘50s --


DR. MAKHIJANI: But we have access to that. 


DR. BEHLING: Yes. I have the original so I 

know. 

 MR. CLAWSON: ‘Fifty-three to ’71. Well, I 

guess for an action item I really don’t know 


which way we’re going to go, but we will have 


to look into this. I think at this time we’re 


going to have to break for lunch, and almost 


quarter to one right now, ten to one. We’ll 


probably return at about two o’clock if that’s 


all right. And we’ll go ahead and break the 


phone line. 


MR. PRESLEY (by Telephone): Hey, Brad, this 


is Bob Presley. I’ll see you at two. 


 MR. CLAWSON: Okay, thank you. 


(Whereupon, the work group recessed for 


lunch from 12:50 p.m. until 2:00 p.m.) 


 DR. WADE: We’re back. We’re prepared to be 


back in session once the chairman lowers his 


hand. 


 MR. CLAWSON: First of all Larry Elliott 


would like to make a comment on the record, 

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asked for a moment here, and then we’ll 


proceed back in. 


MR. ELLIOTT: Thank you, Brad. I just 


wanted to react to at the last working group 


meeting for Fernald, Dr. Makhijani asserted 


that NIOSH selectively relies on worker input. 


The implication was that NIOSH listens to 


workers when their input supports positions 


that is taken by NIOSH but ignores workers 


when their input contradicts with NIOSH 


positions. 


And in his assertion Dr. Makhijani 


offered an example that related to the thorium 


strikes that occurred in Rocky Flats and the 


potential for an intake during those thorium 


strikes. Specifically, he said that we relied 


wholesalely (sic) on one individual, a health 


physicist who was involved in that particular 


work, without listening to others. 


It is not clear why Dr. Makhijani 


again raised the issue of these thorium 


strikes and this issue since the Advisory 


Board has already opined upon the subject with 


regard to Rocky Flats. However, in a more 


general context I want to speak specifically 

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to what NIOSH does and how they value, how we 


value worker input. 


A review of the transcript on the June 


12, 2007 Advisory Board meeting reveals this 


question was explicitly raised by David Hiller 


of Senator Salazar’s office. You can find 


that on page 143 of the transcript. And it 


was also answered by Brant Ulsh of NIOSH on 


page 143 to 147 of that same transcript. 


As explained at that time NIOSH 


examined the redacted pages from a classified 


document that mentioned in passing that the 


thorium strikes occurred in Building 771 


rather than Building 881. The subject of this 


investigative report was a later contamination 


incident involving Uranium-233 rather than the 


thorium strikes themselves. 


Furthermore, the report was written by 


an independent committee convened to 


investigate the Uranium-233 contamination 


incident. One of the criteria for selecting 


committee members was that they were not 


directly involved in the project which helped 


assure their independence. Balanced against 


this report we had the explicit and detailed 

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account of the thorium strike operation as 


provided by the health physicist in charge of 


the project. 


He clarified that the Uranium-233 


solution had been received in Building 771 


from offsite and transferred out of the 


shipment container in that building. The 


Uranium-233 was then transferred to Building 


881 for the thorium strike and subsequent 


Uranium-233 metallurgical and machining 


operations. 


The health physicist had direct hands-


on involvement with the thorium strikes, 


provided a list of employees involved in the 


project from memory which was confirmed later 


by the health physics logbook covering the 


project, and provided a detailed sketch of the 


room where the thorium strike occurred. That 


would have been Room 266 in Building 881, from 


memory. 


And we further confirmed that by 


examining that drawing, the sketch, against 


building blueprints. He also provided the 


approximate dates of the operation from memory 


which was later confirmed by his own logbook 

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and the logbook of his supervisor. 


On balance we considered the detailed 


recollection most of which was independently 


confirmed of the health physicist with direct 


involvement in the project to be more reliable 


than an incidental mention in an investigative 


report dealing with a different subject and 


authored by individuals with no involvement in 


the thorium strikes. 


It is noteworthy that this question 


was raised in the larger context of evaluating 


the potential for thorium strikes at Rocky 


Flats. Over the course of this investigation 


NIOSH interviewed 12 workers including one 


site expert currently retained by SC&A and to 


an individual they stated their belief that 


there was no potential for thorium intakes at 


Rocky Flats. 


SC&A was apparently unconvinced by 


this unanimous opinion from the workers and 


repeatedly has asserted that there were 


potential intakes even though they could 


provide no monitoring data, worker statements, 


incident reports or any other documentation 


supporting their contention that such intakes 

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could have occurred during thorium strikes or 


any other thorium operation at Rocky Flats. 


In conclusion, NIOSH stands by its 


position that there were no thorium intakes 


during the thorium strikes or any other 


thorium operation at Rocky Flats for that 


matter. This position is supported not only 


by the information provided by the health 


physicist directly involved in the project but 


also by the testimony from numerous other 


workers, logbooks covering the operation and 


other written documentation. 


So we in essence take full account of 


all of the information that is presented to us 


on a topic, and we take from that a balanced 


opinion as to where we need to go forward and 


what approach we would use specifically in 


that set of circumstances. So I just wanted 


to get that on the record since it came up in 


this working group. 


I know it’s Fernald, and we talk about 


Rocky Flats here in this example, but I do see 


a lot of consternation in the claimant 


community right now about how much value NIOSH 


puts into worker input, worker interviews, 

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worker comments. And I just want it to be 


known that we value a worker’s input as much 


as we do, we consider them to be site experts. 


So we’re reaching out, and we’re 


trying to improve our interactions and the 


ways that we interact with workers. So I just 


wanted to make this comment for your record. 


 MR. CLAWSON: Appreciate that. 


DR. MAKHIJANI: Might I have a chance to 


clarify. I don’t want to get into Rocky Flats 


stuff, but I brought this up not in a Fernald 


meeting but in a Nevada Test Site. 


MR. ELLIOTT: I missed the meeting. 


DR. MAKHIJANI: Yes. 


MR. ELLIOTT: Thanks for correcting me. I’m 


sorry. 


DR. MAKHIJANI: I believe that you were 


there. 


MR. ELLIOTT: I was there. 


DR. MAKHIJANI: It was at the last Nevada 


Test Site working group meeting. I brought it 


up because I felt that there was not a clear 


and full acceptance of the statement that the 


fellow, retired health physicist, made, kind 


of regarding badge practices. I did not bring 

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181 

it up to revise any Rocky Flats issues. I 


realize that the Board has voted on that and 


made a decision on that. 


I did not bring this up in any context 


that involved thorium exposures at Rocky 


Flats. I believe Dr. Ziemer was there. I 


believe the Board actually took some action on 


that, and I have to revisit my notes from the 


Nevada Test Site. Jim Neton was there, and it 


was agreed that some investigation in regard 


to the badges not being worn in the forward 


areas needed to be done. 


And that was as a result of the 


intervention that I made because I thought 


that not only a particular health physicist’s 


statement was at least as much of a site 


expert as any other site expert at least that 


I’d interviewed or any evidence that I’ve seen 


brought forth from any site expert because he 


witnessed more than 900 nuclear weapon tests. 


And that was the context in which I brought it 


up. 


I believe the record of the reports 


that we showed in which I played a significant 


part in preparing SC&A’s, some of SC&A’s Rocky 

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Flats report will not show that we had stated 


that there were significant thorium exposures 


during thorium strikes. But we had repeatedly 


questioned whether NIOSH has properly created 


a bounding dose or not. And we repeatedly 


rejected the use of NUREG-1400 as the approach 


for bounding dose and asked for evidence from 


the site regarding bounding doses. 


It is simply not correct and a 


misrepresentation of things that I said last 


time and a misrepresentation of things that 


are there in the report to have read into the 


record the kinds of things that you have just 


done, and I do object to it. 


MR. ELLIOTT: Well, I apologize for getting 


the wrong working group, but the issue was --


DR. MAKHIJANI: But a considerable portion 


of the other record is also not properly 


stated in that e-mail, and I do object to it. 


I have not fought an exercise about anything 


in three years, but this misrepresentation of 


what’s in our written reports, it’s a matter 


of record what’s in our written reports. 


We did reject NIOSH’s repeated 


statements that NUREG-1400 was bounding dose 

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as improper. And that was done by the whole 


team. It wasn’t done by me. For your 


information every report that I have submitted 


has been reviewed so far as I can recall, has 


been reviewed by John Mauro and signed off by 


John Mauro including, and specially I asked 


him to go over every word in sensitive reports 


to make sure that he knows every detail of 


what’s in them. And if he’s on the line --


John, are you on the line? 


DR. MAURO (by Telephone): Yes, I am, and I 


agree with what --


DR. MAKHIJANI: -- or deny or --


DR. MAURO (by Telephone): -- especially 


NUREG-1400. 


DR. MAKHIJANI: Sorry? 


DR. MAURO (by Telephone): Especially the 


NUREG-1400 work. In fact, that was my 


concern. I mean, just to hearken back I am 


familiar with that particular subject and 


being very much involved in that part of the 


review. 


DR. MAKHIJANI: Thank you. 


MR. ELLIOTT: I was not --


DR. MAKHIJANI: When you make ad hominem 

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characterizations, I would request you to make 


correct ad hominem characterizations. I do 


try to avoid them here, and I am exercised 


that your team has chosen to make incorrect 


characterizations on the record in a way that 


I find objectionable. 


MR. ELLIOTT: Well, I think that’s the pot 


calling the kettle black because I’m sorry, it 


was the NTS --


DR. MAKHIJANI: And there you go again. 


MR. ELLIOTT: -- working group meeting that 


you brought this up. And you brought it up in 


the context that NIOSH does not listen to 


worker input. And I have so many --


DR. MAKHIJANI: You might ask a whole bunch 


of workers about that. We’ve had this 


complaint from workers repeatedly. 


 DR. WADE: We need to go back now to the 


business of this work group. 


 MR. CLAWSON: We appreciate the input, and 


we’ll proceed on with this, Hans. 


DR. BEHLING: The next section deals with 


the in vivo monitoring of workers for uranium 


and thorium that started with the introduction 


in 1965 in mobile in vivo radiation laboratory 

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monitoring unit that was brought onsite, a 


discrete timing of people were assessed for 


lung burdens involving uranium and thorium 


exposures. 


And starting on page 103 of the report 


I talk about some generic aspects, and I 


preface my statement on that page by saying 


not considered a finding by SC&A. A critical 


component of the MIVR lung counting system, 


however, was the radiation detection system 


was perhaps not the one that should have been 


used. 


And I stand not alone in that 


particular criticism because recently I 


reviewed the Portsmouth TBD and some of the 


supporting documents that surround the 


Portsmouth TBD, one of which was a DOE 


document that had some very, very critical 


comments to say about the Y-12 mobile in vivo 


laboratory system. And principally the 


consideration here is the level of sensitivity 


that comes with the very, very large crystals 


that were used, the four-inch thick crystals. 


As we know if you’re looking for lower 


energy photons, you tend to go with the thin 

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crystals in order to avoid the (inaudible) 


background against which you have to discern 


your signal. And if you read that particular 


report from the DOE that relates to the 


Portsmouth, you will see similar statements 


that I make here. Again, they’re not 


findings. It’s just the level of sensitivity 


that says the system was not intended to be 


used for lower energy photons. 


And in the case of uranium you’re 


really looking at U-235, the 186 keV photon, 


and if you look at the conventional gamma 


spectroscopy issue involving the backscatter 


photon, then that particular 186 keV for 


uranium coincides with, if you look at, for 


instance, the 183 backscatter photons for 


cesium or for cobalt, they all lie somewhere 


between 180 to 210 to 120 keV. 


So you have a real problem here when 


you’re potentially dealing with other 


radionuclides. And I realize cesium was not 


one of the major radionuclides, but we all 


have, especially in the early days, cesium 


from atmospheric fallout. And so I just 


brought that up as an issue that the four-inch 

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thick crystal compares very poorly in terms of 


discerning low energy photons for chest 


counting when you compare it to the crystals 


that are conventionally used at other DOE 


facilities that involve four millimeters 


instead of four inches. And so I just brought 


that up. 


DR. ZIEMER: Well, it still is possible to 


use them with proper calibration. 


DR. BEHLING: Of course. 


DR. ZIEMER: And, in fact, and I wouldn’t 


know in this case, but it’s interesting to 


note that sometimes the higher background is 


not an issue. Your sort of coefficient of 


performance goes to sample squared to 


background. So if your sample count gets high 


enough, you can put up a terrific background. 


That’s why Los Alamos for many years 


was able to use those large whole-body liquid 


simulation counters with terrific backgrounds 


because the sample count was so high, the 


sample squared background ratios were good. 


And I don’t know what they would be in this 


case. My guess it’s very inefficient to use a 


thick crystal because the particles only 

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penetrate in the outer surface. So you 


probably don’t have good samples squared to 


background here. And so it’s not optimum. 


And I agree with your point. I think 


it’s not optimum, but it’s usable. 


COURT REPORTER: 4.4-1? 


DR. BEHLING: Yes. We haven’t really gotten 


to 4.4-1 because I’m only talking about a 


generic statement. 


DR. ZIEMER: Right, right. 


DR. BEHLING: And I meant to bring with me ­

-


DR. ZIEMER: That wasn’t a finding but an 


observation. 


DR. BEHLING: No, no, that wasn’t a finding, 


just an observation. 


DR. ZIEMER: Yeah, that’s the best way to do 


it. 


DR. BEHLING: Be careful about how much 


accuracy you assign to these measurements and 


realize that perhaps by design this particular 


counting system was not optimal. 


DR. ZIEMER: It’s not optimum, yes. 


DR. BEHLING: And was clearly not the one of 


choice that, because other DOE facilities used 

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it for millimeter inch thick crystals for 


counting these lower energy photons. But 


having said that --


MR. MORRIS: I don’t think you should say be 


careful of the accuracy. You should say be 


careful of the detection limits. 


DR. BEHLING: Detection limits. 


DR. ZIEMER: Yeah. We can be very accurate, 


but the detection limit is much higher. 


MR. ROLFES: Right, and the net result from 


that I think is important to clarify that a 


higher detection limit will result in a higher 


dose estimate for a claimant. So once again 


this is another example of the uncertainties 


associated with a measurement being credited 


to the claimants in a dose reconstruction. 


FINDINGS 4.4-1, 4.4-2
 

DR. BEHLING: There are a number of other 


findings. In part they were due, and I will 


ask you to look at page 110 of the report 


which is a reproduction of one of the tables 


that were identified in the original TBD. And 


I will say that because initially that is what 


I was working on in making some of my comments 


that relate to finding number 4.4-1. Actually 

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not so much that but the other ones, finding 


4.4-2. 


And if you look at page 110, you will 


see a table that talks about the different 


measurements that were taken on a yearly basis 


as you see on that page for the year 1965. 


They were two Uranium-235 counts, two uranium 


total, and zero thorium although it says there 


were two Lead-212 and two Actinium-228 which 


by default I assume are there for thorium. 


And as you go down the list over the years, it 


isn’t until you get to the time period of 1978 


or really 1979 that you see a large number of 


citations that reflect Lead-212 and Actinium228. 


And prior to 1978 you see an awful lot 


of data that involves thorium. And having 


looked at that I was very much confused. And 


I make all these statements in preface to what 


you’re about to tell me is that this is how 


the data was reported. And I think we can go 


through some discussion and come to terms with 


what the data really represents. But at the 


time when I looked at this, this was the table 


I was making reference to. 

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191 

And quite frankly I could not make 


heads or tails with the notion that up to 1978 


all of the thorium was reported in terms 


milligrams and for Lead-212 and Actinium-229, 


which are your two indicator radionuclides. 


There was no data there. And I think since 


that first discussion you informed me that 


this was an issue of reporting the method by 


which the mobile in vivo data was reported. 


And that brings us to a couple of 


other issues, but having said that, we can 


discard perhaps a couple of the first findings 


here, 4.4-2. At this point I have looked at 


some of the data, and it is clear that the 


thorium data reported in milligrams between 


’68 where you have 310 all the way to ‘78 


where you have 161 are reflections of data 


that involve Thorium-232. 


One of my concerns was what thorium 


are you really referring to, but it’s clear 


these data do reflect Thorium-232 and Thorium228. So I have at this point accepted the 


notion that these data do, in fact, involve 


Thorium-232 as opposed to Thorium-230 or 


something else. 

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But having said that we can now go and 


look at a couple of the other issues that I 


guess I would like some clarification on 


because when you don’t have any data that 


involves a definitive assessment for Lead-210 


-- and I guess for those who may still be 


somewhat unsure as to what these mean, I 


enclosed for the benefit of the reader, 


Exhibit 4.4-2 on page 106. 


And there you have a citation of the 


radionuclides that start with Thorium-232 and 


the intermediate products between 232 and 


Thorium-228 and the two indicator 


radionuclides defined by Actinium-228 and 


Lead-212. And you realize, and I explain here 


briefly what assumptions are reasonable here. 


Obviously, if you were to deal with 


pure thorium material that is just harvested 


for the first time, ore, you can reasonably 


expect every one of these radionuclides --


let’s put it this way. It’s not unreasonable 


not to expect them to be in exact equilibrium. 


However, once you segregate the thorium 


chemically again you may start out at time 


zero with total equilibrium between 232 and 

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228, not equilibrium but equal quantities. 


They won’t be in equilibrium long 


because what you’ve done is essentially 


removed Radium-228 which has a half life of 


6.7 years and in the process if you remove 


Radium-228 you also remove actinium. And of 


course, that’s your indicator for Thorium-232. 


At that point and moment in time when you 


chemically segregate thorium and you isolate 


Thorium-232 and 228, you start to, as a 


function of time, lose Thorium-228 because you 


have a half life of 1.9 years. So if you 


segregate the thorium chemically at 1.9 years, 


your Thorium-228 will be exactly half of the 


Thorium-232. 


And in fact, I think somewhere along 


the line we do have a map that identifies how 


these values coincide over time, and I can 


pass it around here. And you see obviously 


that this equilibrium that occurs with these 


two radionuclides, and I guess the question 


now I have is what happens when you deal with 


data that you no longer have the individual 


measurement. 


Obviously, Actinium-228 is your 

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indicator for Thorium-232, and Lead-212 is 


your indicator for Thorium-228. And now you 


have to make a decision. What is it that I’m 


looking at when it’s reported in thorium 


milligrams? What were the assumptions on the 


basis of which the original data as you see in 


that table on page 110 where you have thorium 


reported in milligram quantities or microgram 


quantities, how do you segregate the two 


thoriums? 


MR. MORRIS: It’s a fair question, but it’s 


obviously a dose reconstruction issue, not an 


SEC issue. 


DR. BEHLING: Well, it’s a dose 


reconstruction because you can certainly --


let’s assume you rely on Lead-212 and say, 


well, they’re in equilibrium. But you can 


certainly have Lead-212 that after a period of 


years has decayed off and it’s going to be, 


you will have an accurate assessment if you 


rely on Lead-212. You have an accurate 


assessment for Thorium-228, but you can also 


realize that Thorium-232 has been grossly 


underestimated if you assume that Lead-212 


provides you with an indicator. Unless you 

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use both, and you have reasonable assumption ­

-


MR. RICH: Again, you’re using daughters of 


both isotopes. 


DR. BEHLING: Yes. 


MR. RICH: And they also were very careful 


to determine the age since separation of the 


material that they were operating from. 


DR. BEHLING: I would care less about the 


age. If you have accurate measurements for 


both Lead-212 --


MR. RICH: Well, it makes a difference, 


Hans, in terms of the ratio that the activity 


of the 232 to 228, depending on the age since 


they’ve been separated. 


DR. BEHLING: Of course, I know that. But 


you could, if you had accurate measurement for 


Lead-212 and Actinium-228, the 212, Lead-212, 


tells you how much Thorium-228 you have. And 


the 228 tells you how much Thorium-232 you 


have. 


MR. RICH: They made assumptions for both in 


order to do the, to come to the conclusion of 


how much Thorium-232. 


DR. BEHLING: Because I have looked at data 

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in subsequent years following 1978. And we do 


have data that tells you how much Lead-212 was 


measured in the chest count and how much 


Actinium-228. And they’re clearly not, 


frequently they’re just a factor of two or 


three higher different meaning that there is 


disequilibrium between the two thoriums. 


Now to what extent was that considered 


or was a larger number or value used to 


account for any uncertainty? I guess I would 


like, I’ll turn to you and tell me how it is 


that you interpret data prior to 1978 when all 


the data was only issued to you in units of 


thorium mass as opposed to subsequent data 


when you may have two values, one for Lead212, one for Actinium-228, and how do you 


assess your lung burden based on these two 


different sets of data, one lead involves just 


thorium measurement, the other one for two 


daughter products but they’re not necessarily 


in equilibrium? 


MR. RICH: The data that’s listed in the 


claimant file prior to when they started to 


simply record the two daughter products. 


Those same two daughter products were used in 

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the analysis to come to the milligram 


quantities prior, and it was just a matter of 


change recording. 


DR. BEHLING: I mean, do we have data that 


says that for let’s say in the years 1972 or 


so prior to the change --


MR. RICH: Yeah, there are some transition 


years where we have both the daughter activity 


and the milligram. 


DR. BEHLING: I’ve seen it. But are we 


comfortable in understanding what it is that 


they did to be sure that they didn’t do things 


that potentially are not claimant favorable? 


MR. RICH: I’m comfortable, yes. 


DR. BEHLING: Are you? 


MR. ROLFES: We’ve also pointed the Advisory 


Board members to a couple of documents that 


discuss the assumptions that went into 


measuring Thorium-232 in the body. And 


there’s a record of, let’s see, one report is 


the evaluation of health physics problems from 


thorium and its daughters in a thorium 


purification and fabrication process. This is 


in the Health Physics Journal, Volume 8, pages 


279 through 297 for 1962. And also we have 

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radioactivity of thorium and the feasibility 


of in vivo thorium measurements from the Oak 


Ridge Y-12 plant, Report Y-1280, 1959. 


DR. BEHLING: Again, I just want to be very 


careful about interpreting some of the data. 


As we know and we’re fully aware because I’m 


preaching to the choir here, that 


disequilibrium is an issue here that you can’t 


avoid. And on page 107 I give an extreme 


case. If you had something that is at this 


point thorium ore that has been just 


separated, what you don’t have at that point 


is Radium-228 or Actinium-228. Meaning that 


you have no indication as to the fact that 


Thorium-232 is there potentially in large 


amounts, but you have no way of verifying that 


because your indicator, Actinium-228, simply 


isn’t there. 


MR. RICH: That was well understood by those 


people who were doing the work. 


DR. BEHLING: I mean I just want to be sure 


that we’re not caught off guard here by people 


who don’t understand the mechanics and the 


biokinetics of all these radionuclides and how 


indicator radionuclides have some limitations 

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regarding the interpretation. 


DR. MAKHIJANI: Bryce, is there a procedure 


for the in vivo counter that shows that this 


was well understood? 


MR. RICH: Those documents that Mark just 


referred to. The documents themselves were 


explanatory. 


DR. MAKHIJANI: I’ve looked at the in vivo 


procedure, but I didn’t see, I’ll have to go 


back and revisit it because I don’t remember. 


MR. RICH: There are a number of documents, 


more than what we have here. 


DR. BEHLING: If we go to, and if everyone’s 


comfortable. As I said there’s no real 


resolution other than to go back and assess 


what were the methods used to interpret 


thorium data prior to ’78 when there 


(unintelligible) not reported for two 


indicators. And if we’re comfortable with 


that then I think we can --


MR. RICH: It was standard industry practice 


and with the best minds that in vivo counting 


for thorium (unintelligible). 


DR. BEHLING: I was just somewhat taken back 


because I did look at a couple memoranda that 

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talked about the early years when the mobile 


unit was brought onsite and was operated by Y12 personnel. And I have to say on a relative 


scale I would trust their ability to, since 


they designed the system, understood its 


limitations. And when they operated it, they 


clearly understood what they needed to do to 


compensate certain deficiency of the system 


and how to interpret data. 


What did cause me some concern, and I 


quote one memoranda, is that the people after 


the first two years at, Fernald took over and 


it’s a question of did they understand the 


nuances? Did they understand what needed to 


be done here? And there were a couple of 


memoranda that I looked at that raised a 


question about the qualifications of people 


who ran the mobile in vivo lab. 


And so again it’s an issue that from 


this point has a limited chance to be 


resolved, but the qualifications of people who 


were not necessarily trained on them to the 


extent that the Y-12 people were, raises some 


questions. 


FINDINGS 4.4-3, 4.4-4
 
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These next two issues relate to the 


worker selection and the frequencies by which 


the in vivo counts were conducted. And I know 


I’ve read enough documents to suggest that on 


average people at the high end of their 


exposure potential were at least counted once 


a year, but there were clearly indications 


that some people were skipped and there may 


have been two years. And, of course, the 


question was there for let’s say two years, 


just after the unit left and the next time it 


showed up obviously he would not have been 


part of the monitoring program. And I assume 


at this point if there’s indication that he 


was subjected to thorium, you’re going to tell 


me that there’s going to be a coworker model, 


is that correct? 


MR. MORRIS: That is correct. 


MR. GRIFFON (by Telephone): Are you on 44­

2, Hans? 


DR. BEHLING: Yeah, 44-3 and 4. 


MR. GRIFFON (by Telephone): And for 4.4-2 


it says NIOSH will provide a coworker model, 


and you indicate you’ve done that. Is that on 


the O drive, that coworker model yet? Or is 

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that --


MR. MORRIS: No, it’s not on the O drive 


right now. It’s in final review right now. 


MR. GRIFFON (by Telephone): Okay, so it’s 

done, but it’s not to us yet. 

MR. MORRIS: Right. 

MR. GRIFFON (by Telephone): Okay. 

 MR. CLAWSON: Pending. 

DR. BEHLING: Again the issue of 4.4-4 on 


page 109, again, raises some questions again 


based on the memorandum that talks about 


worker selection. You know, you use good 


judgments and you rely on your process 


knowledge, your work environment and select 


workers. Again there are certain suggestions 


here in one of the memoranda that are 


(unintelligible). Air monitoring data for 


certain locations within the plant did not 


coincide with the highest empirical exposure 


data as evidenced by the mobile in vivo lab 


data. 


And so the question comes to mind is, 


are there people there that should have been 


monitored (unintelligible) as opposed to 


people who may not have been at the high end 

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but who were monitored. And are we 


potentially finding ourselves in a situation 


where people with potential high exposures 


were simply ignored? And I can’t answer that. 


MR. ROLFES: That’s the opposite of the 


truth. In 1959, I have a letter here dated 


October 21st, 1959, in regards to thorium 


bioassay. It goes on to say “our interest in 


the subject concerning,” excuse me. “Our 


interest in the subject stems from the thorium 


operations we had at the plant a few years 


ago. Although this operation has been shut 


down, many of the thorium workers are still 


employed at this plant, and we are still 


interested in performing tests to determine if 


retention of thorium from exposure to airborne 


material was appreciable. Recent efforts 


along this line have included the analysis of 


urine samples for radium daughter” -- and it 


also, this was one of the precursor letters to 


the individuals being sent outside to the 


University of Rochester. 


So to me this indicates to me that for 


individuals that were potentially exposed to 


thorium, they were interested in determining 

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historical thorium exposures. But --


DR. BEHLING: And that may be fine, but I’m 


also looking at on page 108, and I’ll read it 


for those who may not have access to this 


report. And it’s a direct quote from one of 


the memorandum that I selected and it’s 


phrased as follows: “Recent in vivo 


monitoring (unintelligible) employs utilizing 


the IVRML indicated (unintelligible) of 


currently sustained 70 percent to 100 percent 


of a permissible lung burden of uranium.” And 


then it continues. “A serious question has 


been raised regarding the validity of the job 


(unintelligible) and air dust sampling 


approach used by NLO since that data would not 


suggest lung exposure (unintelligible) at the 


in vivo indicated level.” And again, --


DR. MAKHIJANI: Which page are you one? 


DR. BEHLING: This is on page 108 of the 


report. 


And it goes back to the similar issue 


we observed for uranium. We had people that 


just simply didn’t expect to have had a high 


urinary excretion rate of uranium. Here you 


have people who show high test burdens, lung 

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burdens, who were at 70 to 80 percent of the 


permissible lung burden who were not expected 


based on weighted air dust sampling data to 


have been exposed. 


And then the question is since you 


selected these people on that premise, to what 


extent are there people for whom the in vivo 


data simply doesn’t exist? Now again if there 


is a coworker model that elects to use a 


fairly conservative upper-end value, we can 


accommodate. But the question is what would 


we do for people for whom perhaps data is not 


there or is very, very sparse. 


MR. MORRIS: There is the coworker model in 

final review. 

MR. ROLFES: That’s it. We do have a 

coworker model that will be made available to 


the Advisory Board working group members. 


DR. BEHLING: And the next finding, 4.4-4, 


is something that perhaps you can clarify 


here. I think at one of the meetings that we 


had -- I’m really referring to you, Mark. You 


had mentioned that there was going to be some 


correlation between lung count data with 


thorium air sampling data. And is that still 

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a process that you’re going to look at in 


trying to establish some correlation between 


air monitoring data and in vivo chest 


counting? 


MR. ROLFES: It’s a potential approach, but 


I don’t believe we would be doing that at this 


time. 


MR. RICH: We wouldn’t be applying the ratio 


back to the early times. 


DR. BEHLING: Yeah, my concern was that 


obviously post-’79 we’re not dealing with 


processing of thorium any more; and therefore, 


air monitoring data that correlates during 


that timeframe may be poorly correlated. So I 


just was looking to make sure that we 


understand what the limitations of the intakes 


exist when you compare two time periods that 


may or may not necessarily apply to earlier 


years when thorium was processed. 


MR. RICH: However, we have taken a look at 


the relationship between internal uptake in 


the ’68 period of time when they brought in 


vivo and air samplings. We find the in vivo 


results always significant. 


DR. BEHLING: Now I would hope that if such 

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correlation exists, that we would exclude 


post-’79 data because at that time air 


monitoring data may have very limited value to 


relating to body burdens. 


MR. RICH: And because of the differences in 


operational and circumstances in the very 


early times where you’re not going to tie that 


ratio back to the early time. That’ll be done 


with pure air sampling results. 


DR. ZIEMER: Yeah, you’d have no guarantee 


that that ratio which is sort of a modern day 


ratio held for the earlier days. It may, but 


there’s no guarantee. 


MR. MORRIS: They were totally different 


plants and different processes. 


DR. ZIEMER: The net result is that earlier 


days are going to look like higher exposures. 


MR. RICH: Well, they do have --


DR. ZIEMER: They may or may not be. You 


don’t know, but you have to assume they were. 


MR. RICH: Well, we have some assurance 


because of the experience in the period of 


time when both sets of data are there that the 


air sampling data will give us a very 


conservative result in the earlier time. 

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DR. ZIEMER: It tends to overestimate. 


MR. RICH: Yeah, it tends to overestimate 


for a variety of reasons which are 


(unintelligible). 


FINDING 4.4-5
 

DR. BEHLING: The last finding on that issue 


is Finding 4.4-5 on page 110, and we’ve raised 


it before. Perhaps we need a clarification. 


Based on one of the (unintelligible) on page 


111, at a previous meeting I believe Mark had 


identified certain statistics regarding the 


number of cases that had been completed or 


adjudicated to date at Fernald. 


And I know that in many of these cases 


for efficiency’s sake, ORAU/OTIB-0002, had 


been used to essentially say what kind of 


exposure did you receive from the 12 or 28 


radionuclides defined in TIB-0002 at the first 


day of employment. And would that result in 


if you’re not going to be compensated on that 


premise. Chances are that you’re not going to 


be compensated using your data. 


I have yet to see, for instance, a 


comparison between OTIB-0002 and compare that 


to perhaps someone who had perhaps as many as 

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209 

30 years experience at working at Fernald and 


apprise certain data, some of which you may 


have for uranium exposure from urine bioassay. 


And now that you have perhaps coworker data 


for thorium and others, and I’d like to see a 


comparison to see if that statement is, in 


fact, a true statement. 


I mean, it’s clear that if you had a 


person who worked for one year, but to assume 


that that is, that particular model transcends 


all other options for saying we’re going to 


clear the slate by assuming that we can run 


your dose model using (inaudible) and thereby 


determine whether or not you’re going to reach 


the 50 percent mark is something that I 


haven’t convinced myself truly holds. 


MR. ROLFES: This is not an SEC issue. It 


is how NIOSH does dose reconstruction. That 


is the issue. The TIB-0002 methodology we can 


show you a comparison of TIB-0002 intakes 


versus actual data. 


DR. BEHLING: I would like to see, now that 


we’re in the process of revising the TBD we’re 


developing white papers. We’re developing 


coworker models. I’d like to see someone for 

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whom that TIB-0002 was used to say, okay, 


you’re finished. We’re done with you. 


I’d like to be sure that under the 


most extreme case a long-term employee, a 


worker who is at the forefront of some of the 


exposures and determine whether or not the 


current assumptions as you’re proposing here 


would still hold up in the sense where the 


TIB-0002 data would transcend all other 


exposures that you just pointed to by two 


workers. 


MR. ROLFES: Has SC&A seen, have you looked 


at the data and seen any results where an 


individual’s actual dosimetry records would 


have exceeded TIB-0002 intakes? 


DR. BEHLING: Well, we’ve already concluded 


that dosimeter data for external is one 


parameter, that uranium bioassay, there are 


certain loopholes there. We don’t know what 


thorium data to apply and other things that at 


this point are still part of your ongoing 


revision. 


And so we’re hard pressed to say once 


all of the dust settles, and you tell us that 


you were finished with providing this 

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particular approach and this model, that’s the 


time when we would want to look at and take a 


limiting case, a worker who worked from the 


early ‘50s through the end of his employment 


career, maybe 30, 40 years later and determine 


whether or not the application of TIB-0002 is, 


in fact, a limiting exposure scenario. 


DR. MAKHIJANI: I haven’t checked the 


Fernald situation, and I agree with Hans that 


we have to await your formulation of these 


models. But I did do some back of the 


envelope work in relation to Mallinckrodt, and 


I believe SC&A raised questions about TIB-0002 


in the context of Mallinckrodt not with 


uranium but with the other radionuclides, with 


Actinium-231, the thorium. 


And I wasn’t convinced that the TIB0002 -- at the time I think you’ve since 


revised it somewhat, and I’m not aware 


whether, how many and what numbers have 


changed or how its application has changed. 


But in the context of Mallinckrodt certainly 


there seemed to be situations where TIB-0002 


would not be bounding or would not be a --


MR. ROLFES: For monitored workers? Is that 

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what you’re referring to? 


DR. MAKHIJANI: Well, we --


MR. SHARFI: OTIB-0002 was not allowed to be 


used on every case. It does have limitations 


inside the TIB. It does point out that there 


are cases where you can run into a situation 


that you may see larger doses by assessing 


bioassay than you would have OTIB-0002. So 


you do have to consider before the monitoring 


data whether or not OTIB-0002 would 


(unintelligible). 


DR. MAKHIJANI: Right. 


MR. SHARFI: I don’t want to believe that we 


always say OTIB-0002 is an overestimate, but 


usually we do some analysis and make sure for 


that particular claim the OTIB-0002 would 


result in larger doses than would be if we 


assessed the individual data. 


DR. MAKHIJANI: I was speaking in the 


context where you didn’t have bioassay data 


for those radionuclides, and that’s why there 


was sort of an extended discussion about the 


SEC at Mallinckrodt. And here also we’re 


talking about thorium where you don’t have 


bioassay data for the first 16 years. 

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MR. SHARFI: And that might (unintelligible) 


for OTIB-0002 when we go back and --


DR. MAKHIJANI: And in that context NIOSH 


had applied OTIB-0002 in Mallinckrodt and also 


noted that NIOSH has frequently applied OTIB0002 in Fernald when, in fact, there are no 


thorium bioassay data. And so the fact 


remains to be demonstrated, and in a few cases 


that I, I did review some cases at Fernald 


when I drafted the site profile review for our 


team, and I did not find, you know, I didn’t 


look at every scrap of paper in your dose 


reconstruction files, but I did not find an 


attempt to calculate whether the thorium doses 


are based on air concentration data. Of 


course, the air concentration models you were 


using, were they correct? 


MR. SHARFI: Yeah, you’ve compared that they 


were concerned to the thorium at the 110 MAC. 


There was 1,050 MAC which is different than 


the new proposed. So it may be in the 


revision of the site profile that now it may 


not be applicable, and we may have to then go 


back and redo it, which we’d have to redo 


those cases. (Unintelligible). 

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DR. MAKHIJANI: I agree. 


 MR. SHARFI: So there’s a lot of potential 


where a lot of these cases they might be 


reworked. The thorium they may still be 


bounding. 


MR. ROLFES: That’s correct. We’ll go back 


and look at previously done claims in a formal 


program evaluation report for Fernald based on 


document changes to the site profile. 


DR. MAKHIJANI: Right, I agree. The Fernald 


question is still on the table. I just wanted 


to point out that this issue had been raised 


earlier in the context of radionuclides that 


were not monitored --


 MR. SHARFI: That was never dose per unit. 


DR. MAKHIJANI: Yeah, that was never brought 


to a conclusion because it was rendered moot 


by the decision of the Board. 


FINDING 4.5-1
 

DR. BEHLING: If there are no other 


comments, I guess we can go to the next topic 


starting on page 112, Section 4.5 and we’re 


still with external exposure monitoring at 


Fernald. Finding 4.5-1 states the absence of 


performance standards quality assurance for 

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personal dosimeters, and you see in the write 


up that there were a number of issues here 


that deal with the training of the people who 


processed the film, the certain practices 


involving film dosimeters that were left in 


cars were experiencing heat damage and other 


things. 


And apparently there was very little 


in the way of controlling how these badges 


were used by the individual person to whom the 


dosimeter was assigned to as well as perhaps 


some of the qualifications for the people who 


ran the program in terms of their training 


qualifications in using calibration standards 


appropriate for the energies to which workers 


were exposed and a number of other things. 


And I found very little that would 


give us a warm feeling about the quality 


controls and the QA program that was in place 


especially in the very early years. And 


again, I refer to a couple of attachments that 


make reference to that. Among the other 


things that was missing was obviously 


extremity exposures that were not monitored 


properly. 

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MR. ROLFES: NIOSH has located inter-


comparison studies from Herb Parker, dated in 


1945. It was inter-comparisons of the 


(unintelligible) lab, the Oak Ridge Clinton 


lab and Hanford Works. The three badges were 


inter-compared. The Oak Ridge dosimeter was 


the one that was used at Fernald during start 


up, and we’ve provided that on the site 


research database, reference ID 439. 


DR. MAKHIJANI: And the relevance of a 1945 


study at Fernald? 


MR. ROLFES: It was the same dosimeter. 


DR. MAKHIJANI: The same three badges that 


were compared? 


MR. ROLFES: The inter-comparison study was 


done by Herb Parker in 1945. It was an inter-


comparison of the Oak Ridge dosimeter, the 


Argonne National Laboratory dosimeter and the 


Hanford dosimeters. 


DR. MAKHIJANI: (Unintelligible) dosimeters? 


MR. ROLFES: It was the Oak Ridge dosimeter 


that was used at Fernald. 


DR. BEHLING: I don’t question the validity, 


obviously the key component in the integrity 


of a dosimeter is the people who manufactured 

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the film and how does it respond and how is it 


processed. And when you obviously go through 


the exercise you will find that there’s a fair 


degree of consistency when you have such a 


test as you mention. 


But the question is when these 


dosimeters were, in fact, processed by inhouse people who were perhaps not properly 


trained, who did not or may not have 


understood the need for calibrating these 


dosimeters to energies, photon energies, that 


were applicable to the facility, then these 


are issues that you can’t really assess by 


this inter-comparison that you mention. 


So I still have questions about the 


quality of the program because there’s regular 


documentation that would give you this feeling 


that there was a high degree of emphasis 


placed on the processing of these dosimeters 


and an assurance program that said these 


things are always done by procedure. I didn’t 


see such, especially for the early years. 


MR. ROLFES: The calibration curves for the 


dosimetry that was used at Fernald is in fact 


on the site research database. There are 

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several calibration curves reported. As far 


as procedures I would have to take a look back 


to see what we do have. 


MR. GRIFFON (by Telephone): Hey, Mark, 


these reports, these Health and Safety 


Radiation Safety reports, whatever these are, 


these monthly or quarterly reports, do they 


have any section on quality, assurance quality 


control? Because this issue came up related 


to the bioassay I think related to the 


urinalysis results, too. And you had 


mentioned that you were going to look for QA 


reports but were unable at that point to 


locate any. 


MR. ROLFES: I’m looking through a stack of 


papers on the table in front of me here, 


and... 


DR. BEHLING: The ones I’ve seen are 


obviously later years and clearly again when 


you talk about later years, the question is to 


what extent were similar procedures applicable 


to earlier years. And that’s always an 


unanswered question. Obviously, as we all 


know in the health physics field things were 


fairly questionable early on in the ‘50s. 

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They obviously significantly steadily improved 


over time. And so when you look at something 


that was the health physics people put out in 


the ‘80s, you have to obviously be very 


mindful of the fact that what existed in the 


‘80s may not have existed in the ‘70s, ‘60s 


and ‘50s. 


MR. ROLFES: Let’s see, I believe we had 


spoken with a couple of employees from 


Fernald. We did receive indication that there 


were procedures for some badge calibrations. 


We haven’t located those procedures to this 


date I believe. We’re still looking for 


additional procedures and if Leo Faust is on 


the line I wondered if he could please 


elaborate on what I’ve just stated. 


Leo, are you on the line with us? 


MR. FAUST (by Telephone): Yes, I am. You 


have to remember, Mark, that the first year 


and a half of operation at Fernald, the 


dosimeters were actually read out by HASL. 


And they didn’t start their own read out until 


I would say 1953, about 18 months after start 


up. As far as calibration is concerned they 


used uranium and uranium slab of which the 

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surface dose rate is well known, and they used 


radium as their photon source which everybody 


else did, too. 


That badge, the Oak Ridge badge, or as 


it’s referred to in the Parker study as the 


Clinton Laboratory, that badge was used for a 


long time and any changes that were made at 


Oak Ridge were incorporated in the same 


dosimeter that was employed at Fernald until 


Fernald decided to go with a TLD system which 


was in the ‘80s. 


So we also found some procedures that 


were employed. I did not find any that 


related to the actual calibration itself other 


than the calibration curves and the timing 


that was used to establish a certain number of 


doses to calibration film. 


They also handled their film just like 


everyone else did. They had controls and they 


had backgrounds. And they stored their new 


film in refrigerators which was the standard 


practice. 


DR. BEHLING: Well, I’m going back to page 


112 of our report, and I made a number of 


statements which actually are quotations from 

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the 1981 response to dosimetry assessment fact 


sheet that follows, that’s included in the 


report. And the statement says test 


dosimeters, i.e., control badges, are not 


routinely processed. And these are again 


things that a good quality assurance program 


would do obviously on a routine basis. 


You would obviously zero in your 


densitometer and make sure your densitometer 


is working. You would have various protocols 


that says on measuring things that I can 


reliably assign to an individual as an 


exposure. And there seems to be questionable 


data that would support that this was in fact 


done. 


MR. FAUST (by Telephone): What time period 


was that? 


DR. BEHLING: Well, I don’t know if you have 


access to --


MR. FAUST (by Telephone): No, I do not. 


DR. BEHLING: Okay, then I’m sorry, but in 


my report as Attachment 4.5-1 on page 113 is a 


response to dosimetry assessment fact sheet. 


Apparently the National Lead Company of Ohio 


was asked to perhaps support a reconstruction 

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program. And they went back to historical 


records. 


And so you get some assessment of what 


they felt in 1981 were limitations that would 


allow them to do so. And in that report they 


make certain statements that lead you to 


believe that they didn’t really have a lot of 


faith in some of that historical dosimetry 


data. 


MR. FAUST (by Telephone): Yeah, I’m 


familiar with that report. I don’t have it 


with me. I’m sitting in Branson, Missouri, as 


a matter of fact. But the person that, well, 


we’re intimately familiar with that particular 


report, but from our interviews with at least 


three different individuals, they all claim 


that there are not exact responses to the 


questions that were asked in that particular 


survey. And that’s about all I can say to it 


at this stage. 


We also recognize that during the 


changeover from the film to the TLD that there 


were some discrepancies in the algorithm that 


was used. And those discrepancies were in 


fact taken care of and changes were 

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incorporated into the algorithm. However, we 


haven’t found anything that would discredit 


the film dosimetry program at the site. 


Everything that we have found supported a good 


dosimetry program. And that’s been verified 


by interviews with people that were 


responsible for the program including an 


individual that actually operated it. 


DR. BEHLING: Well, apparently there was, 


but the single individual, I will read to you 


from one of the pages in paragraph G that 


states in this particular report, “There were 


no specific training requirements for the film 


badge technicians when this program began in 


1951. The technicians received on-the-job 


training. The technician now performing all 


film badge processing began this work” -- and 


then it’s been blanked out for Privacy Act 


reasons -- and has been the only technician 


doing this work since whatever. 


So we have but one individual who 


apparently was responsible for the issue of 


assessing personal dosimeters, the film badge 


dosimeters. And apparently, he was not 


necessarily trained, formally trained, in this 

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area. 


MR. MORRIS: I have a question for you. Bob 


Morris. Excuse me, Leo. 


On page 112 your finding, quotes, 


“test dosimeters,” and I assume that’s your 


parenthetical addition, i.e., control badges? 


DR. BEHLING: Yes, yes. 


MR. MORRIS: Are not routinely processed. I 


don’t think that was control badges that 


they’re talking about there. If you go into 


the actual text you quote that from, I think 


you’re out of context. 


DR. BEHLING: I’m not sure, where did you --


MR. MORRIS: Just go down one more page, 


right below there, and you’ll see where you 


quoted that. And it doesn’t say control 


badges. That was your interpretation of it. 


And I think that’s in response to a specific 


question, do you use test badges. And I don’t 


think that was in their vocabulary, but he 


does, whoever replies, goes on to say “test 


dosimeters are not routinely processed; 


however, five or ten gamma and six or seven 


beta and gamma calibration films are 


processed.” So I think that you’re out of 

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context on that. 


DR. ZIEMER: There’s two kinds of 


possibilities here I think. One is where 


you’re giving known doses and you’re 


confirming your calibration. Another would be 


a blind test. Some groups do that where 


somebody gives a dose, but the reader doesn’t 


know which it is which is different from a 


calibration. 


MR. MORRIS: A round robin perhaps. 


DR. ZIEMER: Yeah, it’s something like an 


inner-calibration study where the person 


reading it out does not know the dose that’s 


been given to a, quote, test badge. As I say 


that’s different than a control badge where 


you give it a known dose and confirm that you 


get some density reading on the film. So 


those two --


Hans, I’m wondering if those two 


issues got intertwined here. 


DR. BEHLING: You know, in fact I’m kind of 


trying to search where that statement was 


extracted from. 


MR. MORRIS: Okay, let me get it for you 


exactly. 

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DR. BEHLING: Give me the number. 


MR. MORRIS: In your attachment there’s a 


little page number two at the bottom of it, 


and it’s item D, page 114 at the bottom. 


DR. BEHLING: D, okay, now I see. 


 MR. CLAWSON: This is Brad. We used a 


control badge, and I believe they use that for 


general background. 


MR. MORRIS: That’s right. 


DR. ZIEMER: Yeah, a control badge that 


gives you a background reading. 


MR. FAUST (by Telephone): Correct. 


DR. ZIEMER: Badges which are given known 


doses to establish your calibration curve. 


And then the third thing is many places used a 


blind test badge where somebody has given that 


badge some dose and the reader doesn’t know 


what it is in advance. 


MR. RICH: You express those in your 


sequence so that periodically it just 


validates --


DR. ZIEMER: It looks like another user 


badge and whoever’s reading it out doesn’t 


know that it’s --


 MR. CLAWSON: Checked before that it was --

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DR. ZIEMER: I’m wondering if they didn’t do 


that. 


DR. BEHLING: Well, I guess I don’t really 


understand what a test dosimeter represents. 


MR. MORRIS: Well, I think he, we don’t know 

what the --

DR. ZIEMER: Sort of like a blind review for 

dose reconstruction. 


DR. BEHLING: On the next page, item E 


again, “test dosimeters were not routinely 


evaluated.” I don’t have --


MR. MORRIS: Well, first of all they didn’t 


process them, and then they didn’t evaluate 


them. 


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


They were not processed unless there was some 


mix-up or a question regarding a particular 


result of a particular dosimeter. Then a 


control may have been processed just to answer 


that particular. 


MR. MORRIS: The way I interpret this is, 


are you involved in a round robin where you’re 


trading dosimeters with other groups. 


MR. FAUST (by Telephone): That we would 


terminate, we would call that a test program, 

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and they would be readily identified as a 


separate test from the ordinary day-to-day 


operation of the dosimetry program. 


MR. MORRIS: But I think the important part 


of this quote is where the responder says test 


dosimeters weren’t done, but we did do five of 


these and six of those. 


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


They did a whole bunch. I mean if I remember 


correctly it’s some 15. They also used a so-


called fast dosimeters for the calibration of 


their densitometers. 


DR. BEHLING: We can strike number three 


then. As I said I was not, and I’m still not 


certain I understand what test dosimeters are, 


but I will accept the notion that a certain 


number of badges were processed with this 


badge to establish the fact that a system was 


properly functioning, at least the 


densitometer. 


DR. MAKHIJANI: Number three. 


DR. BEHLING: Three on page --


DR. ZIEMER: In the report. 


DR. MAKHIJANI: Not in the matrix. 


DR. ZIEMER: No. 

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DR. ZIEMER: Could I ask here? I’m not sure 


anybody was using sort of you mention the 


quality factors here. Somewhere I thought I 


saw that. Virtually everyone in the early 


‘50s was using a, well, I’m not sure anybody 


was using the rem even. 


DR. BEHLING: No, they were interchangeably. 


DR. ZIEMER: Well, I think in the early ‘50s 


I’m not sure the rem was even --


MR. RICH: Invented yet. 


DR. ZIEMER: Well, probably invented, but I 


think almost all badges were in Roentgen units 


in those early days. Even the rad probably 


wasn’t, in fact, they were using reps and --


MR. FAUST (by Telephone): And we recognize 


that, and we take the easy route out, and we 


equate them all. 


DR. ZIEMER: Well, I think within the 


accuracy of a film badge, a rep, rad, rem, 


it’s probably the same thing. 


MR. FAUST (by Telephone): It didn’t matter 


all that much. 


MR. RICH: For gammas. 


DR. ZIEMER: For gammas I’m talking. 


MR. FAUST (by Telephone): Yeah, for gammas. 

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A rep was like 94 erds* per gram and a 


Roentgen is give or take a little bit about 


88. 


DR. ZIEMER: Eighty-seven point six. 


MR. FAUST (by Telephone): Yeah, right. So 


for all practical purposes it doesn’t really 


matter whether, you can interchange them 


without worrying too much about it. And they 


finally, everybody did. But as far as I can 


tell the rem didn’t come into play until 


probably early ‘50s, somewhere around ’55 I 


would guess. 


DR. ZIEMER: Well, I don’t think it was that 


early. I’d say ’59 or ’60. 


MR. FAUST (by Telephone): Well, I was 


thinking of ICRP-2 they were using the rem. 


DR. BEHLING: Well, that wasn’t published 


until ’59. 


DR. ZIEMER: Roughly, yeah. 


MR. FAUST (by Telephone): That wouldn’t 


matter here anyway. 


DR. BEHLING: In fact, if you look at 


(unintelligible) 20 in the late ‘80s before 


they converted or revised the NCR 


(unintelligible) standards, the statements say 

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that Roentgen is the rem for gamma and beta. 


That’s the statement. I don’t know what to 


say other than to again mention the fact that 


I didn’t come across any kind of QA of 


procedures or anything that for the early 


years would let you know that there was a 


quality program here that had certain 


procedures that had to be adhered to in 


processing and read out of dosimeters. 


I obviously identified that as a 


finding, but at this point you’re going to 


find anything that would support your 


statement that there was some very, very well 


defined procedures and protocols in place. I 


didn’t see any. And the 1981 document reports 


that statement that there is very little data 


so we really (unintelligible) which film 


dosimeters were used. 


Finding 4.5-2, unaccounted doses to --


MR. GRIFFON (by Telephone): Hans, back to 


4.5-1, I just wanted to say I have one action 


down there which is just that, and this has 


been a kind of ongoing thing, that NIOSH will 


also attempt to identify procedures in their 


QA reports from the early time period related 

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to that topic. So it’s just sort of a follow 


up. If we can find any procedures or QA 


reports from that ’53 to ’85 time period that 


might help close this out. 


The only other thing I wanted to note 


in that in your report page 115 interested me. 


As we were looking through those other areas I 


looked at page 115 on the bottom, and this 


part, I don’t know who added the emphasis with 


the underlining, but it might have been you, 


Hans. 


Under number one there at the bottom 


of the page it says employees have always worn 


badges; however, exposures were not always 


determined for all employees. I think we 


might want to keep this in mind as we look at 


the data completeness question when we look at 


these individual files. I don’t know if it’s 


going to even, are we going to be able to pick 


that up though because I’m not sure what years 


we might have annual summary data as opposed 


to cycle data. 


Can NIOSH respond to this? I mean, 


you’re probably aware of this issue or this 


statement, but does this result in gaps in the 

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external monitoring data or have you examined 


this at all? 


MR. ROLFES: NIOSH is aware that not 


everyone was monitored. 


MR. GRIFFON (by Telephone): This says even 


the people who were wearing their badges, not 


all of them, exposures weren’t determined for 


all of them. 


DR. ZIEMER: This is Ziemer. I’m not sure 


you should interpret that word badges as film 


badges. 


MR. GRIFFON (by Telephone): Security 


badges, I know, yeah. 


DR. ZIEMER: I mean many facilities 


everybody wore badges, but not everybody wore 


film badges. The ones that did those were 


built into the security badges. 


MR. GRIFFON (by Telephone): Since badges 


were always a combination security/dosimeter 


badge is the first line in that paragraph, 


that’s what I was going on. 


DR. ZIEMER: Yes, but if you weren’t 


required to wear a film badge, it wasn’t 


loaded as it were. 


MR. GRIFFON (by Telephone): Right, right, 

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right, so, yeah, I understand. And also, if 


they were in a, they could have made an 


educated determination to not measure, like I 


think at Rocky Flats we found that they made a 


decision; it was in memos, that these people 


that were on quarterlies we weren’t going to 


read the badges in these years because they 


were likely to have very limited exposure 


anyway. And so they made a determination that 


certain people even though they had the badge 


in there, they weren’t going to bother reading 


it. 


DR. ZIEMER: Well, you wouldn’t read it 


unless there was some kind of an incident? 


MR. GRIFFON (by Telephone): Yeah, if 


something came up, then they might, you know, 


so they only, but I just wondered whether 


this, you know, I’m not sure exactly how to, I 


just noticed this statement as I was reading 


through. 


MR. FAUST (by Telephone): This is Leo 


Faust. We have to remember that the dosimeter 


in the security credential weren’t necessarily 


incorporated into a single unit until later 


on. I can’t tell you what Fernald did, but a 

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lot of other sites the security credential and 


the dosimeter were two separate things. And 


finally they were incorporated probably in the 


mid-‘50s for the most part. 


MR. GRIFFON (by Telephone): Yeah, that’s 


what I, we’ve certainly seen that at other 


sites. And this statement in the survey, 


maybe I’m misinterpreting it or it might be 


slightly inaccurate. Who knows? But I just 


think we might want to, but I think this 


question can be further examined in our review 


of the data completeness question really. I 


don’t know that --


DR. ZIEMER: Another piece of that is it 


looks like they had criticality dosimeters 


incorporated into those. So that might be a 


reason why everyone would wear it. 


MR. GRIFFON (by Telephone): Right, right. 


DR. ZIEMER: But you wouldn’t look at any of 


those unless you had a criticality accident. 


MR. HINNEFELD: This is Stu Hinnefeld from 


NIOSH. I’m just reading this note off Brad’s 


screen here, and it sounds to me like they 


describe the people who were not, whose badges 


were not read and were women through two 

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periods of time. And I was told anecdotally 


while I was there that there was a period of 


time when women weren’t allowed to go to the 


process areas so they didn’t wear a dosimeter. 


MR. GRIFFON (by Telephone): Yeah, maybe it 


is just a female. 


MR. HINNEFELD: I believe the people who 


were -- wore a badge who were not monitored 


are depicted right there in the following four 


lines. It’s the two periods when women 


weren’t. 


MR. FAUST (by Telephone): Well, yeah, there 


was two periods in time when females were not, 


did not wear a dosimeter. 


MR. HINNEFELD: I believe that’s the entire 


interpretation of that statement that not 


everybody who wore a badge was monitored. 


MR. FAUST (by Telephone): That could very 


well be, Stu. 


MR. GRIFFON (by Telephone): It could be, 


Stu. You could be right, yeah, yeah. 


MR. SMITH (by Telephone): This is Billy 


Smith. I was the health physicist in charge 


of dosimetry at the Nevada Test Site for 


years, and I processed thousands of film 

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dosimeters. The terminology that I’ve been 


listening to relative to the quality control 


process that may have been in place, at NTS we 


processed film in batches of 100 badges each. 


And in each batch we had two controls 


which were dosimeters, film badges, that had 


no dose on them that we used to determine what 


the background was going to be that we were 


going to subtract from any readings from any 


film that we read. 


Also in that batch we had five 


standards. The five standards were film that 


had been exposed to 30 millirem, 100 millirem, 


500 millirem, 1,000 millirem and 2,000 


millirem. Those were processed prior to 


reading any dosimeters for dose purposes from 


people to determine that the densitometers 


were working properly, and then the individual 


film dosimeters were read. 


Now if the same process that Oak Ridge 


had previously established that Fernald was 


following, then they would process controls 


and what I call standards at the same time. 


And that to me indicates a quality control 


process that’s going on in the reading 

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process. 


MR. FAUST (by Telephone): I think they 


looked at it that way, Billy, because that was 


pretty much the standard practice throughout 


the industry. And there’s no reason to 


believe that Fernald was any different than 


anybody else in my opinion anyway. 


 MR. CLAWSON: Well, we can all project our 


opinions into what they mean, but bottom line 


is we’re trying to get to the bottom of a 


determination if we could find this is 


evidence of this, then it brings this to a 


head. And as Mark stated into this that he’s 


tried to check for a procedure or so forth 


that was being followed to be able to say that 


this is how it was done. 


MR. FAUST (by Telephone): And we’re 


continuing trying to find those procedures. 


We found a lot of different procedures, but we 


haven’t found one for that yet. But that 


doesn’t say it doesn’t exist. 


 MR. CLAWSON: That’s true. 


DR. ZIEMER: So they’re continuing to look 


for that then. Well, who read about the five 


and four? Was that from there? Was that a 

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procedure? 


DR. BEHLING: Yes. 


MR. MORRIS: Well, right here on page -- you 


got your file open? 


DR. ZIEMER: Oh, yeah. 


MR. MORRIS: The SC&A report page 114 at the 


bottom of that page, item D. 


DR. ZIEMER: Now is that a quote from --


DR. BEHLING: You know, the response, from 


the 1981 response report. 


DR. ZIEMER: Okay. 


MR. GRIFFON (by Telephone): And that sort 


of, I mean, Paul, I think that says they’re 


doing calibration films but whether it was 


each batch just like we heard happened in 


Nevada. But if we can get a --


DR. ZIEMER: Well, a formal procedure would 


help. 


MR. GRIFFON (by Telephone): But I think 


that’s as far as we can take it really is to 


try to identify that. 


DR. ZIEMER: They’re doing that which would, 


if they’re doing what would be considered good 


practice at the time, that’s important. 


MR. GRIFFON (by Telephone): Right, but I 

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think this survey, to me anyway, it says they 


were doing calibration runs along but not 


necessarily what people are calling tests or 


round robin tests or whatever. 


MR. FAUST (by Telephone): By the way that 


was recommended in that Parker report that 


continued inter-comparisons between the sites 


was recommended by Herb. Whether or not it 


was practiced I can’t say for certain, but I 


do know that at the Hanford site we did 


exchange dosimeters with various other 


organizations on a cooperative kind of a 


basis. There was nothing required to do that, 


but we just did it as a good practice. 


DR. ZIEMER: Do we know whether later on 


after they got into TLDs and so on, did they 


get involved, would they have been eligible 


for DOELAP? 


MR. HINNEFELD: They were certified by 


DOELAP. 


MR. FAUST (by Telephone): They were the 


very first organization to be DOELAP 


accredited. 


DR. ZIEMER: Okay, well, that’s important to 


know. 

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MR. FAUST (by Telephone): And they’ve kept 


it up or they’ve kept it up through their 


operating time. 


DR. ZIEMER: Well, that doesn’t come out of 


the blue either. There had to be some --


 MR. CLAWSON: Other reason. 


DR. ZIEMER: -- well, some basis for 


achieving that. 


MR. MORRIS: This is Morris. One of the 


things, Hans, that you had mentioned in your 


preliminary remarks was matching the energy 


spectrum of the radionuclides to the challenge 


spectrum that is used for calibration. And 


radium and uranium combination is quite a 


reasonable approach to matching that spectra I 


would think. 


MR. FAUST (by Telephone): Well, they 


couldn’t get any better quite frankly. And 


later on it was DOELAP. DOELAP dictated what 


calibration energies they had to perform by. 


So that kind of took it out of the individual 


site’s hands so to speak. 


 MR. CLAWSON: Well, this is a rousing 


conversation. I do think we’re going to take 


probably a ten-to-15 minute break. We’re just 

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going to mute the phone, but we’re going to 


have a quick comfort break, and then we’ll 


come back. 


(Whereupon, the working group took a break 


from 3:30 p.m. until 3:40 p.m.) 


 DR. WADE: We’re back in session, the last 


leg of a journey. 


FINDING 4.5-2
 

DR. BEHLING: I guess we’re down to the item 


finding 4.5-2 on page 119 and that is the 


exposures to extremities. And I guess there 


were certain studies done, and I quote them in 


the first quotation there on page 119 that 


talked about fairly high ratios. 


And I can only gather that the ratios 


that are defined therein in 1963 where they 


identified 22.9 rem that represents beta and 


gamma versus 4.4 rem penetrating only in 


providing a fairly high ratio was based on a 


whole body dose in the one on the chest. And 


at that point they compared it to earlier data 


in the 1960s when that same ratio was 20.7 to 


1. 


And so it’s clear that there were 


significant skin exposures, and I believe 

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those measurements represent a film badge worn 


at the chest. Now the question that comes to 


mind is what would have been the potential 


exposures to extremities that were not 


monitored. 


And it’s clear that obviously that 


ratio for a whole body dosimeter may have 


significantly underestimated skin exposures 


experienced by your extremities based on 


strictly the geometry and/or distance to 


source term especially when you deal with 


uranium and its radioactive daughters, 


Protactinium-234. So I raised some questions 


about the potential for extremity exposures 


that may not have been properly monitored or 


not monitored at all. 


Because in the next paragraph down 


there we talk about, and I quote, “The results 


of the study showed projected annual forearm 


exposures from about 14,000 to 46,000 


millirems.” And there was a subsequent time 


period during which wrist exposures were used, 


and again, they may or may not necessarily 


reflect hand exposures which were estimated to 


be two-to-three times the wrist exposure. 

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So this whole issue deals with 


extremity exposures to the skin and in 


particular hand exposures that even during the 


time of wrist monitors may not have been 


properly assessed. So I guess I’ll ask Mark 


to, give your opinion as to what you intend to 


do to deal with skin exposures and 


specifically skin exposures involving the 


extremities. 


MR. ROLFES: We at NIOSH typically don’t 


receive many claims for a skin cancer of the 


extremities. I can think of one. We do have 


extremity monitoring for many individuals that 


may not be complete in certain years. 


What we have done typically is used 


recorded results to the time, day, the ratio 


for -- to interpolate between years where the 


individual didn’t have an extremity monitor. 


We can use a ratio of the dose received by the 


whole body badge to assign a ratio to the 


extremities, or assign a dose to the 


extremities, excuse me. 


We don’t consider this to be an SEC 


issue but rather an issue that is how we go 


about doing dose reconstructions. What 

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assumption we make regarding the dose that’s 


being assigned. And once again this is for a 


very, very low number of individuals whose 


dose is being reconstructed. 


DR. BEHLING: I accept the notion that skin 


cancer of the extremities are probably not a 


very common occurrence, and you may not even 


have one. But if you did have one, you would 


have a difficult time in reconstructing 


exposures during a timeframe when skin 


exposures to the extremities was not the 


issue. And so if it’s a contractor would you 


say I’ll reconsider that the potential issue 


that involves (inaudible) because you really 


have no way of properly addressing that 


particular exposure. 


DR. MAKHIJANI: I have a question. 


MR. ROLFES: The approach that we use in 


that case it would be done on a case-by-case 


basis. We would have to take a look at the 


extremity dosimetry results for the employee. 


And if there was a year or two years that the 


individual was not monitored for extremity 


doses to the skin, on skin we could use a 


previously documented ratio of the recorded 

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wrist dosimeter to the whole body badge and 


assign that ratio for the unmonitored periods. 


There are other methodologies that could be 


used. 


DR. MAKHIJANI: Mark, just a question of I 


thought wrist dosimetry started in 1970. Was 


there wrist dosimetry before 1970 at Fernald? 


MR. ROLFES: I don’t believe a routine 


program prior to that. 


DR. BEHLING: No, and, Arjun, what I’ve 


mentioned was the earlier ratios that were 


developed were based on the shallow dose to 


deep dose worn at the chest so we don’t really 


have an understanding other than certain 


measurements that were done, I guess, on an 


experimental level later on that would suggest 


a fairly large ratio. 


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


mean, it’s not a question of a year or two gap 


where somebody was monitored, and then they 


were not monitored so you can interpolate 


something, the whole first 19-year period I 


think. There may have been some experimental 


badging, but I don’t believe there was 


extremity badging until 1970. 

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MS. BALDRIDGE: Mark, I have a question. 


Have you addressed exposure to private 


contractors who came in? Because the petition 


was filed for employees and subcontractors. I 


personally met a gentleman who had skin cancer 


on his arm who was a private contractor. He 


wouldn’t have monitoring. He was allowed to 


work in his street clothes. 


MR. ROLFES: Was he in a radiation area? 


MS. BALDRIDGE: He was cleaning and 


painting. He’s had two types of skin cancer. 


MR. ROLFES: Was he in the process area or 


was he outside of the area? 


MS. BALDRIDGE: I don’t know where he was, 


but the point is subcontractors who didn’t 


have files, they’re not considered employees 


to be monitored the same way someone on 


National Lead’s payroll would be. What type 


of provision is there for them in the 


evaluation of their extremity exposures? 


MR. ROLFES: What time period was the 


individual on site? 


MS. BALDRIDGE: Probably late ‘80s, ‘90s. 


MR. ROLFES: Well, if it’s the ‘90s, we 


haven’t specifically looked outside of the SEC 

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time period. During the ‘90s I haven’t looked 


in detail at the procedures involved for 


individuals that were brought into the site. 


MS. BALDRIDGE: I believe his father was a 


sheet metal worker, and he’s been dead for 


years. So there wouldn’t have been a claim 


filed for him unless he filed for his father 


in addition to himself. 


MR. ROLFES: I would have to take a look at 


the information that we have and separate from 


dose to the extremities for a painter or for 


someone who would have brought in casually 


into the area. It’s very unlikely that those 


individuals would have spent a significant 


amount of time in a position where they were 


directly handling uranium metals. 


MS. BALDRIDGE: Except that they would have 


had to be cleaning and prepping areas that 


would have been contaminated. 


MR. ROLFES: Sure, they may have --


MS. BALDRIDGE: Releasing that as a dust 


factor. If they’re sweaty, then you have an 


adhesive factor there where the perspiration 


just causes the dust to cling to the skin. 


MR. ROLFES: We actually did a little 

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research experiment to bound this scenario. I 


can have Billy if he’s on the line and 


available to discuss what we did, or Bob? 


MR. MORRIS: I don’t have my memory right 


now. 


MR. ROLFES: Okay, Billy, are you available 


to discuss what we did with the experiment 


that was conducted to bound skin 


contamination? 


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


line. I conducted an experiment at ULD using 


Whatman filter paper, both wet and dry filter 


paper, and to see how much contamination could 


actually be deposited, retained on the filter 


paper. 


I used chalk dust, that is the 


construction material that’s used to mark 


chalk lines, and sprinkled it on square pieces 


of paper that were about three centimeters 


square. And then shook it off of the dry and 


the wet and then weighed the individual pieces 


of paper. And there were 20 pieces of paper 


in each category. 


And then after the weighing took 


place, I converted that math to what the 

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uranium, I assumed that that mass was uranium 


and converted it to a uranium number and came 


up with what kind of contamination would be 


retained on a person’s skin. It’s interesting 


to note that it takes a very, very large 


amount of contamination to be seen on a 


person’s skin, on his contamination clothing. 


And right now I’m in the process of 


finishing up a white paper of this experiment 


that will be provided to NIOSH so they’ll be 


able to put it out on the O drive so you can 


get a feel for what the exposures would be. 


But the exposures came up to be very, very low 


from the amount of contamination showing up on 


these particular experimental papers. 


MR. FAUST (by Telephone): This is Leo. In 


addition to that there were some actual 


measurements of contaminated gloves at 


Mallinckrodt. And the maximum dose rate was 


measured, if my memory serves me correctly, 


was 45 mRads per hour. And the smallest or 


the minimum dose rate, and these are now 


contaminated gloves, was like 23 mRads per 


hour. So the people that we interviewed were 


adamant in their insistence on clothing 

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changes at least twice a day and glove changes 


as often as once an hour. So in our 


estimation and in the records if you look at 


the exposure records, there is no one that 


exceeded the administrative levels for skin 


contamination. 


MR. MORRIS: Skin dose. 


MR. FAUST (by Telephone): It’s highly 


improbable that a painter, particularly late 


in the ‘80s or early ‘90s, would have had 


anywhere near that kind of an exposure. 


MR. ROLFES: In addition to what Leo has 


said we also do have some surveys that were 


taken of personnel clothing, coveralls. There 


were several measurements made in various 


areas of several different employees’ 


coveralls and shoe covers. There are results 


MR. FAUST (by Telephone): It’s item 41-36. 


MR. ROLFES: Approximately 15 measurements 


of the chest area on coveralls, the stomach 


area on coveralls, the thigh area and the leg 


area of coveralls, and then also additionally 


there are radiation survey results of the shoe 


covers. The results range from, the highest 

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result that I see here is one and a half 


millirep per hour. 


MR. FAUST (by Telephone): There was also 


the Fernald used the wrist dosimeter prior to 


the advent of reasonable TLDs, and they used a 


wrist-to-extremity ratio. And the ratio that 


was employed was three. So whatever the wrist 


dosimeter results were, the extremities were 


given three times that. And in about 19 -- I 


believe it was, well, I don’t know, ’87 I’m 


going to say, a study was made by an 


independent person. 


And she concluded from the results of 


her study that the ratio, wrist-to-extremity, 


should have been somewhere around 2.1. I 


think it’s actually 2.09 is what she came up 


with. But they accepted that, but they did 


not change any of their doses of records to 


account for the fact that they were very, very 


claimant favorable. 


MR. GRIFFON (by Telephone): But I guess I’m 


having a little trouble following on the phone 


here. I think we just went back to Finding 


4.5-2. We delved into 4.5-3 for awhile there. 


I think for 4.5-3, I don’t know how much 

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further we want to discuss it, you have an 


ongoing action. And it says that in the NIOSH 


response. 


But 4.5-2 I think, I mean in my mind 


my question is similar to what Arjun had 


raised which is this, you know, there’s the 


other question about this wrist ratio is that 


prior to 19 -- I forget the date -- 70 or 


whatever, you didn’t have any wrist monitoring 


at all. So you’re proposing that that ratio 


was consistent through all the early years, 


too, I guess is what you’re saying. 


MR. FAUST (by Telephone): Yeah, and I’m not 


certain I believe that they actually did use 


wrist dosimeters pre-1970. 


MR. GRIFFON (by Telephone): Okay. 


MR. FAUST (by Telephone): They didn’t use 


extremity dosimeters, but they used a wrist 


dosimeter and used that multiplier. 


DR. MAKHIJANI: Well, is there documentation 


on the site research database about wrist and 


finger dosimetry? I think Stu might know. 


MR. HINNEFELD: I don’t know when the --

DR. MAKHIJANI: It’s my recollection. I 

might be wrong. 
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MR. HINNEFELD: I don’t know when the wrist 


dosimetry started. I believe it was in use 


when I got there, but I don’t know when it 


started. The ratio, you know, I remember the 


ratio, the wrist badge being applied to 


generate the hand or the extremity dose. I 


remember there was a ratio used for that. 


DR. MAKHIJANI: I agree. I remember the 

same thing. 

MR. HINNEFELD: But I don’t know what the 

years when wrist monitoring was done. I 


believe there’s a presumption here that wrist 


monitoring didn’t start at the beginning, that 


whatever ratios could be determined from the 


monitoring occurred later on would be 


applicable backward or there may be, you know, 


I don’t know if they’re saying they’re 


universally applicable backward or applicable 


backward with some caveat or some --


MR. GRIFFON (by Telephone): But if you 


don’t have wrist monitoring in the early years 


you have nothing to apply the ratio to. 


MR. HINNEFELD: So what I’m saying, no, I’m 


saying in addition to the hand-to-wrist ratio 


there’s also theoretically a ratio to be 

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developed from a wrist to a whole body. 


MR. GRIFFON (by Telephone): Yeah, right. 


MR. HINNEFELD: So it would be combination 


of those two ratios if, in fact, it was 


extrapolateable, backwards. 


DR. MAKHIJANI: Mark and Brad, one of the 


things we could do since we’re looking at 


external completeness is to look at when the 


wrist dosimetry started. 


MR. GRIFFON (by Telephone): Yeah, okay, 


that can be --


DR. ZIEMER: Well, there’s an additional 


issue. Did they have any operations at 


Fernald where the body was actually shielded 


such as you have in nuclear pharmacy where 


there is reaching around a shield and a whole 


body dosimeter will read essentially zero and 


you can have high doses to the hand? 


That’s very different than working, 


painting and so on where you’re moving your 


arms around and the actual extremity doses are 


not very different from the whole body for a 


person just working around in a general 


radiation field. Their body moves around. 


Their arms move around, and the integrated 

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doses are probably about the same. 


The real times when extremity becomes 


important is when the body itself is shielded 


or if you have something like the fraction 


units where you can stick your finger in a 


beam and that’s very different. 


MR. HINNEFELD: I don’t recall any, but it’s 


been awhile. 


DR. ZIEMER: Because unless they’re doing 


something like that I don’t see extremity 


dosimetry as being important. 


MR. FAUST (by Telephone): I don’t either. 


Well, to answer your question, Paul, they 


didn’t use a whole body shield as a 


radiologist might use. They did use some face 


shields though for eye protection. 


DR. ZIEMER: That’s for lens of the eye. 


MR. FAUST (by Telephone): Yeah, right. 


They did use some rubber matting to cover 


finished product when it was located near a 


place where, well, located near an occupied 


area. They used rubber matting of some kind 


or another to reduce the exposures that might 


be obtained from that stockpile, if you will. 


But other than that I don’t believe they used 

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any protective clothing other than anti-cees. 


MR. GRIFFON (by Telephone): But didn’t 


they, I mean, you’ve got to think about the 


operation itself not necessarily the 


protective gear but the operation itself. 


Didn’t they have furnace operations where they 


would have been reaching into, you know, I’m 


thinking about like cask cleanouts or cask 


cleanout operations, those kind of things. 


That would be the more, where I would expect 


more and where you have --


DR. ZIEMER: That’s similar to a shielding. 


MR. GRIFFON (by Telephone): -- where you 


also have the daughters separating, and you 


have high concentrations of the radionuclides 


of concern. 


MR. FAUST (by Telephone): Well, they 


encountered that. There was no doubt about 


that. 


MR. GRIFFON (by Telephone): Yeah, so that 


would be more the issue. 


MR. FAUST (by Telephone): The slag was the 


concentrator of many of the daughter products. 


MR. GRIFFON (by Telephone): Right. 


MR. FAUST (by Telephone): And contaminants 

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of other kinds, too. 


MR. GRIFFON (by Telephone): And that’s 


where I would be concerned about the whole 


body ratio being representative of what your 


arms, your forearms, would be getting. I 


mean, that’s why the document Hans has in his 


report specifically talks about the forearms, 


and I think that’s probably why they’re 


looking at that. 


MR. FAUST (by Telephone): But my point is 


that the whole body dosimeter would be exposed 


in those kinds of situations, too. 


DR. ZIEMER: It’s reaching in and cleaning 


up something that was heavily beta in there 


you might --


MR. FAUST (by Telephone): Yeah, if it was 


inside of something, yeah. 


DR. ZIEMER: But I think for dose 


reconstruction if you looked at the individual 


case and find out what the person, what kind 


of things they did, you would end up having to 


model that in some way I would think. 


MR. ROLFES: You can certainly learn a lot 


by looking at an individual’s dosimetry 


records, and you can identify those people who 

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would have been in a job where a potential 


extremity dose could have been significant. 


Typically, those individuals weren’t monitored 


especially in the more recent years. 


There were surveys taken in the 


earlier years prior to extremity monitoring. 


That is typically something that is done on a 


case-by-case basis based on the specifics of 


the case. That’s how it’s previously been 


handled. And it’s been handled for a very, 


it’s been a low number of individuals who are 


potentially affected by this issue. 


MS. BALDRIDGE: I have a question. It’s not 


exactly an extremity, but how do you deal with 


the set-up man, the set-up people that worked 


with their heads inside the machinery? 


MR. ROLFES: The head is considered an 


extremity so it’s not the same extremity that 


we’re referring as the hand or a foot, but it 


is once again --


MS. BALDRIDGE: Special consideration for 


that type of exposure? 


DR. ZIEMER: There’s a different dose limit 


for the lens of the eye because that’s a 


critical organ for the head. 

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DR. BEHLING: In those early days they 


didn’t have a 300 milligram dose to worry 


about. 


DR. ZIEMER: They didn’t worry about it, but 


we would worry about it now for dose 


reconstruction. 


DR. BEHLING: Either shallow dose or 1,000 


milligram dose. 


DR. MAURO (by Telephone): This is John. 


Are we talking about concern over skin cancer 


of the extremities? 


DR. BEHLING: Yeah, I guess we’re talking 


about skin cancer not only of the extremities 


but in the next finding, 4.5-3, we talk about 


shallow and deep dose resulting from skin and 


clothing contamination that now extends to the 


whole body skin that may have been 


underestimated by use of a whole body film or 


TLD that may or may not necessarily represent 


the skin exposures received to the head or the 


chest, the trunk or any place else. 


So, yeah, we’re talking about skin 


cancers at large, and then in Section 4.5-2 


we’re talking about potential skin cancers as 


they reflect the areas of the skin associated 

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with the extremities, the hands and the 


forearms. 


DR. MAURO (by Telephone): Now what about 


the, we know what the upper limit is for a 


contact dose with uranium. So in other words 


I think it’s 200 MR per hour in that order. 


Does that have any play here or are we 


basically saying all dose reconstructions, for 


example, related to skin cancer would be based 


on some type of film badge reading either 


wrist or some kind of adjustment factors to a 


ratio of, let’s say, hand-to-wrist or does 


somehow this affect the upper theoretical 


limit, which would be the contact dose, have 


any play here in dose reconstruction? Do you 


believe that the person who was involved in 


actually handling -- in this case I’m using 


pure, natural uranium -- do any of your 


procedures factor that in as opposed to 


depending on the actual film badge reading? 


MR. ROLFES: The first piece of information 


for a dose reconstruction, for example, for a 


skin cancer claim would be the individual’s 


dosimetry records. That was the most 


significant type of exposure that could have 

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been received by an individual especially 


chemical operator working in direct proximity 


to uranium metal, especially aged metal. 


We are aware that high skin dose 


results were recorded for many of the chemical 


operators. We would, in order to have an 


issue with the dose reconstruction for skin 


cancer, we would have to have a skin cancer 


that was a non-compensable claim. At that 


point we could take a look at the specifics of 


the case and determine whether the individual 


was in fact in an area where he was, could 


have been exposed in any abnormal geometrical, 


you know, we would take a look based on the 


location of the individual’s cancer to 


determine if any additional correction factors 


wouldn’t be needed to correct the whole body 


badge result to the area where the skin cancer 


was located. 


I can’t give a more specific answer 


than that because I would need more specific 


information about the cancer location and the 


job duties that the individual was working in 


and also some information about the 


individual’s recorded dose. I’d be happy to 

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explain more details for a specific case 


scenario. 


I’d be happy to answer any questions 


that there are about any specific scenario and 


how we would handle dose reconstructions for 


that specific scenario. So if there are in 


fact a specific case such as --


DR. BEHLING: Let me point back to the 


statement that I quoted on page 119 where we 


had two timeframes, one 1961-1963. And during 


that time the ratio between penetrating dose 


and shallow dose as measured by, I assume, the 


whole body dosimeter mainly worn at the chest, 


and during that three-year time period it had 


changed, the ratio had changed from 


approximately five-to-one to 20-to-one ratio. 


In other words in 1960 if you measured one rem 


to the whole body for penetrating radiation, 


you would have potentially experienced 20 rem 


of shallow dose. That changed to only five-


to-one for 1963. So it was a dynamic process 


and there was no single value, but it depended 


obviously on the material that was handled and 


the quantity of material handled. And so it 


did change over time. And the absence of 

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monitoring really gives you some problem how 


to accommodate these skin doses especially to 


the extremities that were not monitored for 


these select periods of time early on. And as 


I said in the second statement, there was a 


study that said the results of the study 


showed projected annual forearm exposures of 


14,000 to 46,000 millirem. You’re talking 


about a substantial dose to the skin involving 


people who may have handled these materials. 


And as Sandra pointed out we had a person here 


with two skin cancers to the forearm, and this 


person apparently was not monitored. Is that 


correct? 


MS. BALDRIDGE: (Unintelligible) monitored. 


MR. ROLFES: Was that monitored at all or 


monitored for his extremities? This sounds 


more of a contamination issue than it does an 


extremity monitoring issue. I think they’re 


two separate issues that we’re discussing. 


FINDING 4.5-3
 

DR. BEHLING: Well, that brings us to the 


next statement, and that is unmonitored 


shallow and deep dose resulting from skin-


clothing contamination. And we briefly 

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addressed it. I think Leo or somebody else 


had mentioned the issue of having done 


experimental studies with chalk and filter 


paper. 


But I did go through it and obviously 


anti-contamination of clothing was not 


provided for a good number of years during the 


operation, and neither were people monitored 


by using the friskers or portable monitors for 


skin contamination. And, of course, in those 


days early on one can reasonably conclude that 


oftentimes people may have worn the same 


clothing over and over. 


And the assumption that skin 


contamination is something that is confined to 


at most a 24-hour period between showers may 


or may not hold true. Certain skin 


contamination is very persistent, and 


therefore, in the absence of monitoring for 


skin and clothing contamination, you may have 


had a substantial skin dose that resulted from 


persistence of repetitive skin contamination 


that were clearly not monitored. 


And early on Sandra had mentioned the 


issue about families being invited onsite and 

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acknowledged the fact that they might in fact 


be now informed of the issue that they’ve 


carrying contamination home with them. And so 


that particular issue is raised here under 


Finding 4.5-3. 


And I don’t know when it was that you 


finally introduced the issue of frisking out 


people. Certainly it wasn’t done for many 


years early on. In fact, I think it’s the 


1985 site (unintelligible) that identified, 


and I quote -- this is on page 124 -- “there 


are no contamination survey instruments kept 


at the work site for use in checking for skin 


and clothing contamination. Neither are there 


any hand and shoe counters available for use 


either before or after showering.” 


So as late as 1985 you make very 


little effort to assess people for skin and 


clothing contamination that may persist for 


days on end and repetitively expose people to 


fairly high skin doses. 


MR. ROLFES: Thank you, Hans. Well, I’ll 


reiterate what we do have from 1958 is the 


results of a clothing survey. It appears that 


the chest, stomach, thigh and leg area of 15 

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individuals’ coveralls were in fact surveyed. 


The highest contamination result was 1.5 


millirep per hour. Shoe covers were also 


surveyed. 


The highest result there was 0.5 


millirep per hour, an average of 0.24 millirep 


per hour was documented. Individuals that 


were working in the process areas were 


required to shower before they left the area 


for lunch and then again before they left for 


the day. Employees were also encouraged that 


if they had visible contamination on their 


clothes, they were encouraged to shower during 


the day, and they were allowed by management 


to leave the process area to go take a shower 


and change into new clothes. 


Management also encouraged the routine 


exchange of gloves by these individuals. 


There is documentation of the numbers of 


gloves that were sent offsite for laundering. 


These were in the thousands for one month. So 


it does indicate that the individuals were 


changing their gloves very frequently. We 


have documentation of individuals changing 


their clothes and showering very frequently. 

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So it’s very unlikely that a large 


contamination, you know, a large unknown 


contamination problem existed. 


We feel that based on the results of 


surveys that were conducted, information that 


we have in a person’s claim files and various 


other sources, reports. We feel that we can 


bound a skin contamination dose, and also we 


do not feel that this is an SEC issue. 


DR. BEHLING: Well, again, it’s a subjective 


issue whether it’s something -- if you don’t 


monitor, you can’t really assess the exposure. 


Again here there was a, in Attachment 4.1-3-A 


on page 123 is a memorandum issued by the 


senior person who was responsible for the 


Safety and Health or Hygiene program who in 


1953 states that only those men involved in 


the cleaning of the (unintelligible) would be 


required to make a clothing change, again 


indicating that the majority of people were 


not given anti-cees and probably there was 


minimal effort to assess potential skin and 


clothing contamination during the early years 


and possibly as late as the 1980s. 


MR. ROLFES: I can show you pictures of the 

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individuals that worked in the workplace at 


Fernald showing that they all had anti-cees. 


They all wore coveralls. 


MR. MORRIS: And it was hundreds of 


thousands of gloves per month, not thousands. 


MR. ROLFES: There was quite a high number. 


MR. RICH: That’s a lot of thousands. 


MS. BALDRIDGE: We have to watch about 


generalities because this petition covers 40 


years. 


MR. ROLFES: Correct. 


MS. BALDRIDGE: When my father was working 


there, he was never issued gloves. I have his 


clothing issue and gloves was not on it, but 


yet he was an inspector, and he was handling 


the slugs for inspection. So when you say 


there were gloves, there really needs to be a 


timeline. When were there gloves? You know, 


there are periods I know there were no gloves. 


There were periods that people were 


not required to have the monitoring badge. 


There were, you know, there’s so many 


different issues that affect specific groups 


within this petition, but they can’t be 


considered to be broad spectrum over the 

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entire 40 years. They may apply to one part 


and not another part. When you do the 


rationale on this you have to be able to 


differentiate what timeframe, what group was 


given what protection, what provision, and 


what other groups were not. 


MR. ROLFES: The report that we were 


referring to was from 1959, so I haven’t 


completed an exhaustive search for the time 


periods when gloves may or may not have been 


worn and the numbers of gloves that were worn. 


MS. BALDRIDGE: I mean gloves is just an 


example. 


MR. ROLFES: Sure, sure. 


MS. BALDRIDGE: Throughout the discussion, 


two meetings even before, there’s just a lot 


of factors that each group differs --


MR. ROLFES: That’s very true. 


MS. BALDRIDGE: And it has to be sorted out. 


MR. ROLFES: That’s very true. I agree 


completely with that. There are very specific 


issues that we’re discussing today that 


typically only affect a very, very small 


population of the claimants that we have. 


Many of the issues that we are not 

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discussing, well, excuse me, on a broad basis 


we typically have 99 percent or greater than 


99 percent of the information that we use for 


an individual’s dose reconstruction available 


to us within that dosimetry file. The issues 


that we’re talking about today are typically 


the less than one percent of the individual’s 


dose or a very small fraction of the 


individual’s work history that we’re referring 


to. 


It requires a lot of digging, a lot of 


investigation and these issues really, I don’t 


want to say they don’t affect, but we’re 


getting into very specific small populations 


of workers involved in some of these projects 


and in some of these unique scenarios. 


DR. MAURO (by Telephone): Mark, this is 


John. On a related matter we spent close to 


two or three hours last week talking about 


OTIB-0017 which is the OTIB dealing with 


reconstructing shallow doses. And I think a 


lot of what we’re talking about today as 


applied to Fernald also is very much related 


to the discussions we had the other day. I 


think some of the members of this working 

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group are also sit (sic) on the other working 


group. 


And I just want to point out that the 


area that was most contentious with regard to 


OTIB-0017 was the dependence on your open 


window film badge reading worn on the lapel 


for shallow dose measurements and the fact 


that those measurements -- and I know we’re 


talking about this though -- are really going 


to decide contact doses which could occur. 


There’s also the matter of particulate 


deposition. And I think that it sounds like 


that there’s a great reliance on some film 


badge readings in a setting where there could 


be, the film badge readings could, may be very 


non-representative of the exposures to a 


particular location on the body, especially 


beta exposures localized to the skin. 


And so we got into the discussion of 


particle deposition on skin, the ability to 


detect it when a person’s leaving an area from 


a scan or a portable monitor. We got into 


discussions regarding VARSKIN and what type of 


doses could be experienced as these small 


particles are sitting, let’s say pure uranium 

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metal oxide, on your skin for a day before 


it’s washed off. 


Subjects that I guess we haven’t, I 


haven’t heard discussed here with respect to 


Fernald. To what extent do those kinds of 


issues come into play in the dose 


reconstructions, factoring in all these other 


matters that I just mentioned? 


DR. BEHLING: John, I would assume that hot 


particles do not apply to Fernald. 


DR. MAURO (by Telephone): So they don’t 


have any air particulates of uranium 


depositing on people’s skin. 


DR. BEHLING: Well, you mentioned already 


that they did calculations using enriched, up 


to 20 percent or whatever, enrichment of 


uranium and then determined basically on the 


basis of skin contact what the dose would be. 


DR. MAURO (by Telephone): Okay, I 


apologize. I didn’t catch that. So you do 


use those techniques to place an upper bound 


on what some localized dose might have been? 


DR. BEHLING: Yes, and hot particles do not 


apply to Fernald. 


DR. MAURO (by Telephone): Okay, I’m sorry 

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for bringing it up. 


DR. ZIEMER: Well, another issue, it’s not 


clear to me that the surface dose is really 


the limiting factor here. Usually on 


contamination you’re really, the same amount 


of activity, put it in nanocuries or whatever, 


it’s usually pretty low, maybe microcuries in 


this case. 


But you can deliver much more if you 


ingest that than you will ever get to the skin 


I would think. Isn’t the internal dose still 


going to be kind of the limiting or the driver 


on these for personal contamination? Is skin 


dose really the issue? I mean you can get 


cancer. 


DR. BEHLING: (Unintelligible). 


DR. ZIEMER: Yeah, but it takes a lot of 


dose to get an effect on the skin. 


MR. ROLFES: Well, our first piece of 


information if there was a systemic 


contamination problem that typically skin 


contamination is not a large source of dose to 


the skin. 


DR. ZIEMER: That’s what I’m saying. 


MR. ROLFES: Direct contact with uranium 

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metal is in large quantities. And that would 


typically outweigh any potential exposure from 


skin contamination by orders of magnitude. 


That’s the bottom line. We do have approaches 


and methodologies that we can add what we’re 


essentially referring to as a very small 


amount of skin dose based on skin 


contamination in comparison to the large 


amount of dose recorded by the person’s 


dosimeter. It’s something that we have an 


approach for, but it’s not a very significant 


source of skin dose so that’s the bottom line. 


And we can do simple VARSKIN calculations to 


bound skin doses. 


 MR. CLAWSON: I just wanted a clarification. 


This is Brad. You kept bringing up that you 


sent off hundreds of thousands of gloves for 


(unintelligible). Was this to be laundered? 


MR. ROLFES: For laundry, correct. 


 MR. CLAWSON: Well, we’re talking rubber 


gloves and stuff like that. 


MR. ROLFES: They were leather. 


 MR. CLAWSON: Cotton gloves? 


MR. CHEW: Example, one had processed 29,000 


pairs of gloves in one month in August in 

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1959, something like that. 


 MR. CLAWSON: They were surveyed when they 


came back, too? Because I know that right now 


we have a problem with our scrubs coming back 


contaminated with europium and so forth like 


that. 


MR. RICH: (Unintelligible). 


 MR. CLAWSON: I was just sitting there 


wondering if we had this much data on what was 


going out, we’re monitoring what these were 


reading going out, coming back, it’d kind of 


give a better idea of what we had for the kind 


of contamination issues for that. I was just 


wondering what kind of documentation we had of 


that. 


MR. ELLIOTT: I don’t imagine they surveyed 


the activity level on the gloves going to the 


laundry. Do you think? 


 MR. CLAWSON: Ours does before it can leave 


the building. They’ve got to have a --


MR. ROLFES: There are some documents of 


surveys that contaminated gloves, but as far 


as them coming back from the laundry I 


wouldn’t believe that. 


MR. ELLIOTT: No. 

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MR. RICH: They would check and evaluate. 


MR. ROLFES: They did, however, encourage 


employees who were doing hands-on work with 


uranium metal to change gloves, I believe, 


hourly or as soon as visible contamination was 


seen on the gloves. And I think that is 


supported by the number of gloves that were 


sent offsite in 1959 for laundering. 


DR. ZIEMER: But I’ve seen overalls and so 


on come back uncontaminated, but almost always 


it’s like a little spot somewhere. I don’t 


think I’ve ever seen one that was uniformly 


contaminated come back from the laundry, and 


maybe it would read a half an MR per hour, a 


little spot or something. Well, how important 


is that in, if you’re working in a hot area 


it’s usually --


MR. ROLFES: Very trivial. 


MR. SCHOFIELD: I’ve seen them come back 


with chips of uranium in the pocket. 


MR. ROLFES: Sure, it’s very possible. 


MR. SCHOFIELD: Or it’s fairly significant 


how it got out in the first place, shouldn’t 


have been able to get out to the laundry at 


those levels. 

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 MR. CLAWSON: I’m kind of at a loss where --


be able to do an action item on this. 


MR. POTTER (by Telephone): Mark, this is 


Gene Potter. 


MR. ROLFES: Yes, Gene. 


MR. POTTER (by Telephone): I just looked in 


HIS-20 going back to a slightly earlier 


subject, and there are extremity dosimeter 


results in HIS-20 going all the way back to 


1952, only just a few people. I’m only able 


to look at annual totals for those years, but 


right through the ‘50s there are some people 


who are being monitored with an extremity 


dosimeter it would appear up until the 1970s. 


Then they appear to come into much more wider 


use. 


MR. ROLFES: Thank you, Gene. I did 


misspeak. There were some individuals that 


were monitored for extremity exposures earlier 


on back in 1952 as Gene has indicated. 


So thank you, Gene. 


MR. GRIFFON (by Telephone): Well, Gene, is 


it clear whether those were calculated values 


or actual readings? 


 MR. SHARFI: They were actual readings 

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based, they have in HIS-20 a separate results 


when they actually mark them, either 


calculated or they give what hand it occurred 


on. 


MR. GRIFFON (by Telephone): Got you, 


thanks. 


DR. BEHLING: Can we get some kind of an 


assessment as to what the ratio is for 


individuals whose personal dosimetry data 


include whole body exposure, deep dose, 


shallow dose from a chest dosimeter as opposed 


to dosimeter monitoring data from the 


extremities. That would be extremely useful 


for those instances where it might be needed 


and establish a timeline for ratios that may 


have to be applied in the event of a skin 


cancer for whom we have no data. 


 MR. SHARFI: You have to be careful about 


drawing too much conclusion. I’m not sure 


that all these extremities that are listed for 


the entire year, where their external badge 


may cover them for the entire year, their 


extremity may only be from jobs that needed 


extremity dose monitoring. 


DR. BEHLING: Well, so I’m sure that if 

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there are individual wear periods during which 


that data’s available you simply match those 


data sets for that wear period and not make it 


all inclusive for that year. But it would 


give you some kind of an understanding so that 


when you have a person who has no extremity 


monitoring but you have data for someone else 


for that time period that you can potentially 


find something that has more transportability 


than for subsequent years that may have no 


relationship for the time period in question. 


MR. ROLFES: So you’re recommending that we 


put some guidance into the site profile? 


DR. BEHLING: Not necessarily, yeah, put 


some guidance without going through that. You 


may not have one single claim for which this 


is necessary, and there’s no sense in spending 


energy for something that doesn’t have to be 


done until the time comes where you have 


somehow feel compelled to do something that is 


credible. But right now if you say there are 


no claims for which this dose calculation 


needs to be done, there’s no point investing a 


lot of effort and only realize it’s not going 


to be used. But --

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DR. ZIEMER: It’s data that could be used. 


DR. BEHLING: Yeah, could be used, and just 


put it in your back pocket and save it for 


that day when you may have to resort to that. 


MR. RICH: I’m just, to add to what Mutty 


said. A number of different sites we through 


the years did some studies of this very issue. 


And if you look at the whole body through the 


extremity dosimetry, you’ll get a lower value 


than what you can do experimentally. 


If you look at a given job that may go 


on for a month or so we could get ratios as 


high as, depending on the job and the kind of 


material you’re working with, up to a factor 


of seven higher including extremities but not 


generally much higher than a factor of seven, 


extremities to whole body. And again, 


depending on how you’re working. Glove box 


operations are different than working with 


uranium metal pieces and the like. 


DR. ZIEMER: But if you have enough data you 


can at least bound it then. 


MR. RICH: Not to say that this review 


should be fairly easy to do because it’s on a 


different database. 

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MR. GRIFFON (by Telephone): Well, that’s an 


interesting statement though, not much higher 


than seven. You got some skin extremity doses 


in HIS-20 that range up to 36,000 millirem. 


MR. RICH: As I said, the ratio was whole 


body to extremity. And that would be --


DR. ZIEMER: It would be about five rem 


whole body. 


MR. GRIFFON (by Telephone): It would be 


about nine rem, right? Oh, five, five rem, 


right at the limit. 


DR. ZIEMER: Well, in those days the limit 


was 15. 


MR. GRIFFON (by Telephone): Right, right, 


right. 


MR. RICH: And then as (inaudible) the 


reason that the permissible dose for 


extremities higher (unintelligible). 


MR. GRIFFON (by Telephone): Yeah. 


DR. BEHLING: But I will bring you back to 


the statement on page 119 where for the 1960 


timeframe a study suggested that the ratio 


again for the chest dosimeter was the deep-toshallow dose ratio was 20.7-to-1 so that’s 


greater than five. 

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MR. RICH: That’s very conservative. 


DR. BEHLING: Well, this is apparently just 


quoting what was reported here in this study. 


DR. ZIEMER: That might be enough for 

bounding. 

MR. MORRIS: And it could be a scenario that 

Mutty just described which is that if one was, 


that they may not have matched monitoring 


periods. 


 MR. SHARFI: If you don’t compare the data 


well on the --


DR. BEHLING: Yeah, but to answer your 


question if anything you would err on the 


unconservative side. If you monitored whole 


body but failed to monitor extremity, you’re 


going to end up with a dose ratio that is less 


than what it should be, not the other way 


around. 


MR. FAUST (by Telephone): When was that 


particular value, when did it occur? 


DR. ZIEMER: Which one? 


DR. BEHLING: Well, it was, I’ll quote to 


you, and if you have a report -- am I talking 


to Leo here? 


MR. FAUST (by Telephone): Yes. 

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DR. BEHLING: Leo, this was reported on page 


119 of my report, and it identifies Attachment 


4.5-2-A which is also part of the report on 


120. And there it talks about the 1960 


timeframe where they had a ratio of 


approximately 20-to-1, more than 20-to-1 ratio 


between deep dose and shallow dose. 


 MR. SHARFI: This is a ratio of deep-toshallow not extremity. 


DR. BEHLING: But it could be higher yet 


because obviously --


 MR. SHARFI: I’m not disagreeing that you 


could have, we’ve seen very sizeable deep-toshallow ratios. But it doesn’t mean that the 


extremity-to-whole body ratio (inaudible). 


One’s a material property, and one’s a 


geometry issue. Two separate ratios that 


you’re looking at. 


DR. BEHLING: Well, I’m fully aware, but 


would you expect an even greater ratio that 


would have potentially separated the deep dose 


measured by the chest dosimeter to a wrist or 


femur dosimeter at the extremity? It’s 


possible that even that ratio of 20.7-to-1 


could have been even three times higher. It 

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certainly couldn’t be lower than --


DR. ZIEMER: Well, he was saying you might 


have both together. 


 MR. SHARFI: Yes. I think we’re combining 


issues. 


DR. BEHLING: But in this case you have at 


least the assurance that the timeframes were 


identical because the skin, the shallow dose 


and deep dose measured by one common dosimeter 


operate under the same timeframe. There’s no 


discrepancy. But what it doesn’t do is to 


account for the geometry difference which 


could enhance a 20-to-1 ratio to 40-to-1. 


DR. ZIEMER: Well, you may have to look at 


the data to --


 MR. SHARFI: Maybe I’m just not 


understanding your point going from deep to 


40-to-1. What we care about is what the 


shallow level and whole body-to-shallow wrist 


ratio is and whether deep to -- we’re not 


proposing to go from deep-to-shallow-to-wristto-hand. We’re talking about going from 


shallow-to-wrist-to-hand. 


DR. BEHLING: Well, as I said, there’s 


reason to believe that the deep and shallow 

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doses measured by the whole body dosimeter 


worn at the chest provides you with a clue. 


And it’s likely and it’s possible that the 


ratio that is observed in this case to be 20­

to-1 could actually be significantly higher if 


the source term that this badge was measuring 


was right here and it’s measuring here to 


here, but my hands are here. 


Which means that the skin dose to the 


extremities is going to be considerably higher 


than a skin dose monitored by my chest 


dosimeter. And so what was already measured 


as 20-to-1 ratio could easily be a factor of 


two, two times higher. That’s my point, 


depending on the geometry. I mean, look at it 


this way. If there’s a uranium block, and I’m 


wearing my TLD and that’s measuring shallow 


and deep dose, and it’s giving me a 20-to-1 


ratio, but here are my hands that are not 


measured, they’re going to be exposed to a 


higher ratio yet. 


DR. ZIEMER: I think Hans is saying it might 


be the combination of both of these. 


DR. BEHLING: Yes. 


DR. ZIEMER: The deep-to-shallow ratio in 

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the badge may be different than the deep-toshallow ratio as well as the --


DR. BEHLING: The extremity dose is usually 


defined by the seven milligram dose as a skin 


dose. 


MR. HINNEFELD: I think they’re all saying 


the same thing. 


 DR. WADE: It took us a long time to do it. 


DR. BEHLING: You’re the closer. 


MR. HINNEFELD: No one else here seems to 


be. 


DR. BEHLING: Anyway, I think we’ve 


exhausted that one. You say there are data 


that my be used in the event that such dose 


calculations would be done on the basis of 


time, and I trust that you will do that. 


 MR. CLAWSON: Well, I guess I need to just 


make sure that we’re all on the right page on 


this because I think we’re still talking 4.5.3 


of the unmonitored shallow and deep dose. Do 


we have an action that we need to be able to 


look into? I understand that we do have data 


in the HIS-20. 


MR. GRIFFON (by Telephone): Brad, I think 


there’s an outstanding action still there. I 

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mean --


 DR. WADE: That study that was described. 


We’re waiting for the results. 


 MR. CLAWSON: Okay. 


DR. ZIEMER: Well, that covers 4-5.2 and 3? 


DR. BEHLING: Well, the two are different. 


DR. ZIEMER: I know they are. 


DR. BEHLING: One is, as you mentioned the 


external beta component does not have to, is 


likely to be much larger than a skin 


contamination dose. Five point three really 


deals with the issue of residual skin and 


clothing contamination. And we said there are 


some study data to suggest that it’s marginal 


at 1.5 reps per hour or something. On the 


other hand if it’s a persistent one over a 


period of a year can still be a substantial 


dose. 


MR. GRIFFON (by Telephone): Well, I mean I 


think for 4.5-2 if I’m understanding this 


right, NIOSH is saying it’s a very limited 


number of people that would ever, you know, 


they’d run across this for, and they’d do like 


a case-by-case analysis if it came up as a 


best estimate issue. And I guess I would just 

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maybe the action’s in SC&A’s court to say 


reviewing HIS-20. Do they believe there’s 


enough information there to do case-by-case 


all the way back to ’52? 


DR. ZIEMER: Do you mean to get those 


ratios? 


MR. GRIFFON (by Telephone): Well, to get an 


extremity dose, yeah, assuming, you know, if 


you only had whole body data as opposed to 


some people in there clearly have extremity 


data. 


DR. ZIEMER: We have some ratios now, but 


are you asking what do you do if you don’t 


have a person with extremity numbers in their 


record? 


MR. GRIFFON (by Telephone): Right. 


DR. ZIEMER: I thought we were saying, Hans 


was suggesting we establish the ratios as a 


point during the time periods. 


DR. BEHLING: The time from the data that 


existed. 


DR. ZIEMER: And then NIOSH could do that if 


they got such a case, right? 


MR. ROLFES: I think it’s important once 


again to reiterate that this is not an SEC 

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issue, but it’s related to how we would do 


dose reconstruction for a specific claim. 


MR. GRIFFON (by Telephone): It’s not an SEC 


issue. I mean, if you have to have the 


information to be able to do, reconstruct 


doses for all members of the class, right? So 


from that respect it is an SEC issue, isn’t 


it? 


 MR. SHARFI: (Inaudible) is not 


(unintelligible). 


DR. ZIEMER: You might say that louder, 


Mutty. 


MR. GRIFFON (by Telephone): Yeah, I 


couldn’t hear that. 


 MR. SHARFI: Mark, it’s probably more of 


agreeing that the ratio that we choose is, or 


the approach we choose is conservative enough, 


not that it isn’t really doable. There is 


data out there to say we can create one, it’s 


whether or not it’s conservative enough. 


MR. GRIFFON (by Telephone): Yeah, I don’t 


think there’s any more action on NIOSH’s 


behalf here. I’m glancing at this HIS-20 


stuff myself, and there’s some very 


interesting, I mean that one value I just saw 

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with the 36,000 millirem extremity exposure 


has a deep dose for that year of 400 millirem. 


That’s a pretty high whole body-to-extremity 


ratio or pretty low, whatever, vice-versa. 


But I think SC&A should probably examine that 


whether, is there sufficient information 


there. If there is to do those ratios, then I 


would agree it becomes not an SEC issue but a 


DR issue. 


DR. MAKHIJANI: Mark, earlier on we had 


talked about when wrist monitoring began, and 


I suggested maybe we’d look at that as one of 


the criteria of periods in the completeness 


investigation. You seemed to agree, but let 


me, I just want to be clear about that so we 


have a to-do list that’s good. 


MS. BEHLING (by Telephone): This is Kathy 


Behling. Let me ask a question and maybe I 


missed something along the way. Is there any 


OTIBs or procedures or guidance available to 


the dose reconstructor if they were to come 


across a case like this to help to guide them 


as to what to do? Or is this something that 


is either in the Fernald site profile or will 


be put into the Fernald site profile? 

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MR. ROLFES: If there’s a case where this 


information becomes necessary, we can add some 


discussion of it in the site profile. But 


typically --


MS. BEHLING (by Telephone): I guess what 


I’m wondering from a dose reconstructor’s 


point of view if they come across a case like 


this, how will they know how to proceed? 


We’re sitting here talking about these studies 


that have been conducted and these ratios, but 


is that something that the dose reconstructor 


is going to have some guidance on or will he 


be familiar with these types of studies that 


have been done? 


MR. ROLFES: I would say that the dose 


reconstructor would typically be familiar with 


such a situation. 


MS. BEHLING (by Telephone): Okay. 


 MR. SHARFI: I mean, we do have like 


principal external dosimetrists. We can bring 


in additional help on a situation like this. 


I do know of one site -- at Rocky Flats 


actually did publish inside the technical 


basis document whole body-to-wrist ratios. 


No, they had hand-to-wrist ratios. So I mean, 

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there are, we have looked at this issue 


before. 


This isn’t a, extremity doses are not 


a new issue for us, but there’s not, like 


OTIB-0017 is we had talked about before that 


covers skin cancers doesn’t specifically cover 


every extremity situation that you could run 


into or otherwise it would become a 300 page 


document. So I mean some of it is handled on 


a more case-by-case basis. 


MS. BEHLING (by Telephone): Okay, and I 


understand that. I’m just thinking from a 


dose reconstructor’s point of view and 


realizing that they have a lot of cases to 


deal with and there are a lot of guidance 


documents out there. And sometimes even if 


there’s just a generic guidance document that 


points them in the right direction, and I 


realize this might be sort of a unique 


situation that they would come across. But I 


just question whether that dose reconstructor 


would know where to go from here. 


DR. MAURO (by Telephone): Kathy, this is 


John. During the OTIB, the Procedure close 


out meeting last week, I guess a fundamental 

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concept was discussed and that is whether 


we’re talking about a particular OTIB or a 


procedure or a site profile very often there 


are unique circumstances that could arise. 


And one of our commentaries, findings 


for any particular document we happened to 


look at -- it could have been OTIB-0017 -- is 


that particular document only covers a certain 


range of scenarios. And one could conceive of 


numerous other scenarios that could be 


presented to a dose reconstructor that he’s 


going to have to struggle with. And the 


concern we expressed was that the guidance 


regarding these other scenarios was not 


explicitly provided in a given procedure. 


But the position taken by NIOSH, and I 


think was accepted by everyone present during 


the Procedure review, is that you really have 


to look at the collective set of procedures. 


That is, for example, OTIB-0017 may not 


address certain scenarios, but the site 


profile and there are other guidance documents 


that collectively are in place to allow that 


that guidance does in fact exist. 


And I guess I’m just passing this on. 

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This came out of the Procedures discussion 


where it was agreed that we will not as a 


review group expect every procedure to address 


every scenario and that credit could be taken 


for the fact that the knowledge base exists 


collectively within the site profiles and the 


suite of procedures that are available to the 


dose reconstructor. And that the dose 


reconstructor has access to that expertise 


through training and through the other 


resources available to him. 


So I mean it was an important 


precedent that said that, well, every 


procedure does not have to address every 


possible circumstance that might arise. The 


degree to which that same philosophy is 


embraced here is important, but I did want to 


pass on that this did emerge during the 


Procedure meeting, and that’s how it was 


resolved. 


MS. BEHLING (by Telephone): And I do agree 


that I understand that you can’t account for 


every circumstance that the dose reconstructor 


might encounter. I guess I’m not familiar 


personally with any extremity OTIBs or 

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procedures or really even how much it’s ever 


discussed in the site profiles. I’m just 


personally not aware of any guidance document 


whatsoever. 


DR. MAURO (by Telephone): I would agree 


that that is important because the philosophy 


was that the scenarios that we were discussing 


last week, you know, were tractable because 


the know-how was either provided in the site 


profile or in another procedure. And some of 


these procedures were referenced actually 


during the course of our conversations. But 


if the reality is that the particular scenario 


or issues that are being raised here, there 


really is no guidance on it, I think that that 


is an issue. 


DR. BEHLING: On that issue let me also, I 


looked at some of the example dose 


reconstruction that was submitted on behalf of 


the Fernald, and I’m looking at external dash 


three. And I have to be a little cynical here 


in saying does this really answer our question 


with regard to skin contamination because in 


example external three you have a situation 


where you have a contamination report 

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indicating a worker’s hand was contaminated 


with uranium for one hour prior to 


decontamination. 


And you give a precise assessment as 


to what the DPM per 100 square centimeters 


was. And then you say that was there for 


exactly one hour, and then using VARSKIN, and 


it was 100 percent decontaminated and VARSKIN 


calculates 1 millirem. Well, that’s nice and 


fine. It would make for a nice RADCON 101 


quiz exam. 


But in truth you don’t have any data 


where people were monitored, and certainly we 


don’t have a clean-cut situation where we know 


precisely when that contamination took place, 


100 percent successful decontamination 


(unintelligible) VARSKIN. As we said before 


we don’t have any reason to assume that people 


were ever monitored for skin contamination. 


So in terms of this particular example has 


very little value in terms of answering our 


question. 


MR. ROLFES: I’ve read into the record a 


couple of times that individuals were in fact 


monitored for clothing contamination. That 

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would be I think representative of potential 


skin contamination. I don’t want to read it 


into the record, the results of the clothing 


surveys that I just read twice, but it was in 


fact monitored. 


MR. ELLIOTT: I don’t think this example 


he’s talking about was designed to answer this 


particular issue we’ve been discussing. 


 MR. SHARFI: (Unintelligible) white paper on 


dust loading on skin for dose we’ve already 


talked about. 

DR. ZIEMER: Yeah, we talked about it this 

morning. 

 MR. SHARFI: That might be more to the level 

of what Hans is referring to, long-term skin 


contamination, dust associated with that and 


he was doing a wet and dry filter paper. He 


was going to write a white paper. I think 


that will address more of what Hans is asking. 


MR. MORRIS: Well, short term or long term 


it’s still a dozen hours or ten dozen hours, 


it’s still less than 100 millirem, you know. 


It’s not much. 


MR. GRIFFON (by Telephone): Can I propose 


an action for 4.5-2? I think we’ve discussed 

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these two items long enough actually. I was 


going to say that what I have here is that 


SC&A will review data in HIS-20 to consider 


whether sufficient information is available to 


estimate extremity doses for individuals who 


did not have extremity data and who may have 


had significant extremity exposures. And then 


additionally, SC&A will consider whether this 


should be considered in their review of data 


completeness, in other words in that plan. 


And the outline of their plan, should we be 


looking at this issue? If those are okay we 


can move on to the next set of items. 


FINDING 4.5-4
 

DR. BEHLING: Well, the next item is 4.5-4, 


and that’s neutron dose. 


DR. ZIEMER: Well, that was two that you 


did. What about three? 


MR. GRIFFON (by Telephone): Well, three 


there’s an outstanding item, action, Paul, 


that this white paper that Mutty just referred 


to I think, you know. So we’ll just wait on 


that. 


DR. BEHLING: Okay, the next one involves 


the issue of neutron doses. We do know that 

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people were not monitored for neutron doses. 


The TBD identifies a neutron-photon ratio of 


0.23. The last time we met we discussed the 


issue, and I think we resolved it because we 


did a calculation that came up with a higher 


value. But we did, in fact, for deriving such 


a higher value assume that you would have 


multiple drums, three high, three deep and 


three wide. And Stu brought our attention to 


the fact that based on criticality 


considerations that could never happen, and we 


accept that as an explanation. 


Am I correct, Stu? 


MR. ELLIOTT: That’s what he said. 


DR. MAURO (by Telephone): I remember that 


discussion also, and we agree. 


MR. GRIFFON (by Telephone): I’m reading 


from the matrix though, Hans. It indicates 


here NIOSH will provide neutron survey data. 


That was apparently posted, right, 


Mark? 


MR. ROLFES: That’s correct. We provided 


that prior to last meeting and discussed it in 


quite a bit of detail. 


 MR. CLAWSON: That’s also where Stu brought 

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up the configuration --


MR. GRIFFON (by Telephone): Right. So did 


SC&A review that survey data or it was just in 


this last meeting, this discussion? 


MR. ROLFES: It was prior to the last 


meeting we had provided the neutron survey 


information. 


MR. GRIFFON (by Telephone): I guess I’m 


asking SC&A if they looked at the survey data. 


DR. BEHLING: Mark, I did not look at this. 


I haven’t had time to look at that. 


DR. MAURO (by Telephone): This is John. 


MR. GRIFFON (by Telephone): I mean, it 


sounds like we’re okay. I just want to be 


complete that we probably should look at that 


survey data. 


DR. MAURO (by Telephone): There were two 


aspects of that that we looked at, the person 


that did that is Bob Anigstein. He’s not on 


the line. One aspect was the data itself and 


what it reported. And I recall that it did 


support this ratio. But Bob had pointed out 


also that, yes, you’re correct. You’re not 


going to have enriched uranium stacked up that 


way. But he did come up with higher ratios 

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than this for stacked up natural, you know, 


unenriched uranium as being higher than that. 


So the outcome of -- this is my 


recollection. I certainly could confirm this 


by checking with Bob -- was that, yes, the 


data did, in fact, the actual measurements 


taken, did, in fact, support the ratio 


proposed here. However, there were scenarios 


where you did have stored material that was 


not enriched, but it was a large pile of 


material where the neutron-to-photon ratio 


could be greater than was here, but I don’t 


remember how much greater. 


MR. FAUST (by Telephone): This is Leo. 


That report does not support that conclusion. 


It’s just the opposite. It’s much less than 


what we originally used in the TBD. As a 


matter of fact they used some 12,000, well, 


the actual number is 12,773 containers located 


in Building 4B with enrichments between, 


somewhere between 0.711 and two percent. And 


the maximum neutron dose rate measured was 


0.089. And I’m trying to find the gamma dose 


rate. 


MR. ROLFES: The MP ratio, Leo, that you’re 

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referring to. The MP ratio was less than 0.1­

to-1. 


MR. FAUST (by Telephone): Right, and the 


ratio used in the TBD was 0.23. 


MR. ROLFES: Correct, so it is a bit higher. 


MR. FAUST (by Telephone): It is higher. I 


mean it’s much more claimant favorable than 


the actual measurements would conclude. 


MR. ROLFES: Correct. 


MR. GRIFFON (by Telephone): And I think 


John was referencing something that SC&A team 


did as far as --


DR. MAURO (by Telephone): Yeah, as I 


mentioned we looked at the actual measured 


values that you’re making reference to. And 


the empirical data certainly support the 


conclusion that the 0.23 is, in fact, claimant 


favorable. But I recall that we did just a 


theoretical calculation. We ran I believe an 


MCNP calculation to see, okay, if you had 


stored uranium -- well, we did it for both 


natural and also two percent, I believe, 


enriched. 


So we had two cases, and it was a 


white paper that we submitted. It’s in the 

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record somewhere. And it was pointed out at 


the time we discussed this white paper where 


SC&A did these calculations, we withdrew the 


enriched one because the argument was made 


that you would not have for criticality 


reasons that kind of configuration. But I 


believe our calculations for the unenriched 


uranium in storage, and I think they were 


working with uranium tetrafluoride. 


MR. FAUST (by Telephone): That’s what this 


was, too. 


DR. MAURO (by Telephone): Yeah, and the 


calculations -- of course, I could confirm 


this. It’s on the record. I don’t have it in 


front of me, but I seem to recall that for 


that scenario the ratio was somewhat higher 


than 0.23. But I will need to go back and 


check that. 


Now the fact is though that’s a 


theoretical calculation. If you have 


empirical data that you feel represents 


reality that demonstrates that 0.23 is 


claimant favorable, then you’ve got to give 


the amount of importance you give to this 


theoretical calculation. You know, that’s 

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certainly --


MR. GRIFFON (by Telephone): Well, that’s 


what I’m suggesting, John. Why doesn’t SC&A 


just review the neutron survey data provided 


by NIOSH along with revisiting your own white 


paper and come back to us. 


DR. MAURO (by Telephone): Fair enough, and 


we probably could take care of that fairly 


expeditiously because we have looked at. 


Okay, we’ll take that as an action item. 


DR. BEHLING: John, just for your 


information, you may be referring to a 


calculation I asked Bob to do that looked at 


for instance a pile of UF-4 salt just laying 


there in a conical pile. 


DR. MAURO (by Telephone): Yes, that’s 


correct. That’s exactly what he did. 


DR. BEHLING: So it’s something that is 


realistically something that you might have 


encountered. And if I recall, and I don’t 


remember offhand the precise numbers, but 


they’re probably not significantly higher than 


0.23. 


DR. MAURO (by Telephone): And we can 


certainly confirm that. Right now we’re 

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speculating. It’s in the record. We have the 


information. We’ll just have to get back to 


you. 


MR. GRIFFON (by Telephone): That’s fine. 


4.5-5, right? 


 MR. CLAWSON: Yes. 

FINDING 4.5-5 

DR. BEHLING: Let’s see here. Oh, the only 

other thing I want to go back and that is on 


page 127 under the issue of neutron doses 


there was one reference that I saw, and I 


quoted this, that identified a neutron source. 


And I didn’t have a clue what to do with that. 


Apparently a neutron generator or neutron 


source that they talk about in this one, and 


it’s Attachment 4.5-4B that I’m quoting from. 


And they talk about completion of the 


detailed survey of the neutron generator is 


needed for performing adequately Health and 


Safety operational procedures. And I don’t 


know what that’s a reference to, a neutron 


generator. Because no one has made mention of 


this before, and I don’t have any clue as to 


what that neutron generator involved, and what 


potential exposures may have resulted in the 

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use of that neutron generator. I don’t know 


if there’s any comment here from anyone here 


that can shed light on that. 


DR. ZIEMER: You also mention a Cockcroft-


Walton machine and you use that with a deep 


(inaudible) reaction you get 14 meV neutrons. 


I’m wondering if that’s what they had. 


DR. BEHLING: I don’t know. I’m just, you 


know, I came across a memo that identifies the 


assistance of a neutron generator, and I saw 


no other reference. 


DR. ZIEMER: Were they doing activation 

work? 

MR. ROLFES: Yes, there was a CockcroftWalton neutron generator at the site that was 


part of the analytical laboratory. It was 


used for the determination of mass quantities 


of uranium. 


DR. BEHLING: And there’s also a reference 


on the next page, 128, to a Californium-252 


source as a potential source --


DR. ZIEMER: Apparently also for activation. 


MR. ROLFES: I’m not aware of that source. 


I’m not aware of the californium source, but I 


am aware of the Cockcroft-Walton neutron 

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generator. 


MR. FAUST (by Telephone): I never, in 


anything that I’ve seen to date anyway, I 


haven’t seen any reference to a californium 


source. That doesn’t say it doesn’t exist, 


but I haven’t found it. 


 MR. CLAWSON: Well, now this was for 


checking for the -- I know we used to activate 


and find out how much unused uranium we had. 


MR. ROLFES: It could have been the 


determination of mass, uranium mass. 


 MR. CLAWSON: Okay. 


DR. BEHLING: Is there anything that needs 


to be looked at with regards to the use of 


these sources and --


MR. GRIFFON (by Telephone): I mean, I was 


just going to, in your document, Hans, on page 


133, it does describe the californium source, 


153 micrograms. 


DR. BEHLING: Yeah, yeah. 


MR. GRIFFON (by Telephone): Okay. 


DR. BEHLING: Obviously we have no data that 


suggests people who used these facilities were 


ever monitored for neutrons. 


MR. GRIFFON (by Telephone): This neutron 

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activation facility, is there a building 


number associated with that or is it within 


one of the plants? 


MR. ROLFES: I’d have to take a look back 


into my notes, but it was part of the 


analytical laboratory. 


DR. ZIEMER: It does talk about a tritium 


target so they must be using a DT reaction for 


some neutrons. So it would be a little 


surprising if they didn’t have some kind of 


neutron monitoring. 


MR. ROLFES: Yeah, there are neutron 


monitoring results in HIS-20. I haven’t 


looked to see if we have correlated that. 


There is neutron monitoring there. It is 


maybe one non-positive result in HIS-20. I 


don’t recall what time period it was. 


MR. FAUST (by Telephone): It’s 20 millirem. 


MR. ROLFES: Twenty millirem, sure. But 


there was an industrial hygiene and radiation 


survey. Off the top of my head I don’t recall 


when it was, but there was a survey of the 


area of the analytical laboratory where they 


kept the check sources. And there wasn’t very 


much detail in there, but they didn’t note any 

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problems associated with the storage of 


sources or use of sources. 


MR. FAUST (by Telephone): They also, Mark, 


they also had a Snoopy monitoring instrument 


because they used one in that neutron survey 


study. 


MR. ROLFES: Correct, that’s true. 


DR. ZIEMER: Well, Hans, were you asking 


about whether they had neutron monitoring? 


DR. BEHLING: Yes. 


DR. ZIEMER: You’re saying yes. 


MR. FAUST (by Telephone): No, they did not. 


As far as --


DR. ZIEMER: They did not? 


MR. FAUST (by Telephone): -- personnel 


monitoring is concerned they did not. 


DR. ZIEMER: Well, Mark was saying --


I thought you said --


MR. ROLFES: I said we do have neutron 


monitoring results in HIS-20. 


MR. FAUST (by Telephone): We have zeros 


with one positive. 


MR. ROLFES: Well, that would be indicative 


MR. FAUST (by Telephone): But that was late 

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in the game, guys. 


MR. ROLFES: Okay, okay. 


MR. FAUST (by Telephone): It was post-TLD 


so it’s 1977 or ’78 forward. 


DR. BEHLING: These were written, these 


memos come from --


MR. CHEW: This is ’68. 


DR. BEHLING: Well, ’64. 


MR. CHEW: ‘Sixty-four. 


DR. BEHLING: Nineteen sixty-four was the 


first report, and the second one is dated --


MR. CHEW: ‘Seventy-two. 


DR. BEHLING: -- dated ’74. 


MR. FAUST (by Telephone): It doesn’t 


matter. They did not use NTA film at Fernald. 


MR. CHEW: (Inaudible) operational TLD? 


MR. FAUST (by Telephone): The original, the 


TLD system went into place either late ’77 or 


’78. And it was DOELAP-certified by --


MR. CHEW: Here’s what I’m getting, is that 


you may not have used NTA film, but you used a 


combination of TLDs to monitor neutrons. Is 


that what you’re saying, Leo? 


MR. FAUST (by Telephone): Yes, post-19 --


MR. CHEW: (Unintelligible) neutron 

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monitoring. 


MR. FAUST (by Telephone): -- at the time 


that they put it into place. All I’m saying 


is that they had a Snoopy, which is a survey 


instrument. I don’t know when they got it, or 


I don’t know if they ever used it, but they 


did use it during this documentation that was 


or this document that were just referenced. 


And that was done, and I think the actual 


measurements were done in ’98 to tell you the 


truth about it. So they had that instrument 


at that time anyway. When they got it, I 


don’t know. 


DR. ZIEMER: Well, Snoopies weren’t made 


that late. Snoopies were made by Tracer Labs. 


MR. FAUST (by Telephone): Yeah, we had one. 


DR. ZIEMER: And Tracer Lab, they didn’t 


exist after what, 1980? 


MR. FAUST (by Telephone): Yeah, so they 


could have bought it prior to the time they 


went --


DR. ZIEMER: Well, that’s what I’m saying. 


They wouldn’t have bought it as late as ’98 


because --


MR. FAUST (by Telephone): Oh, no, no, huh­
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uh. 


DR. ZIEMER: Or they could buy it on E-bay I 


guess. 


MR. FAUST (by Telephone): Cheaper. No, I 


don’t know when they bought it, but I do know 


they used it for this neutron study that they 


did. 


DR. BEHLING: But there was no personnel 


monitoring. That’s the issue. 


MR. FAUST (by Telephone): They did not do 


any for neutrons. They didn’t have to, and 


they didn’t need to. 


MR. GRIFFON (by Telephone): I guess, I 


mean, I don’t know if it’s hanging out there. 


Maybe as an action item we can just say NIOSH 


will determine whether other neutron exposure 


potentials existed. And, if so, whether the 


current approach would be bounding. In other 


words if these laboratory workers had a 


potential, albeit small, potential neutron 


exposure, does this 0.23 ratio, could that 


still be used and be bounding? 


MR. ROLFES: Well, this is a separate, sort 


of a separate issue because we’re talking 


about rather than a continuous source of 

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potential neutrons, a very intermittent source 


that would only be a source of neutron 


exposure when electricity was applied to it. 


It was not a continuous source of neutron 


exposures. 


MR. MORRIS: That’s not true for the 


californium. 


MR. ROLFES: Well, true, but in speaking for 


the Cockcroft-Walton neutron generator. 


MR. GRIFFON (by Telephone): Right, right. 


DR. ZIEMER: The californium source was only 


there for a few months if this is correct 


here. Well, that was limited. Well, we’ve 


got to know, I guess, but that’s what it says. 


It was planned for four to five months. 


MR. CHEW: You can read in there, I’m not 


sure they actually even used it. 


 MR. CLAWSON: I guess that brings up a 


question, you know, and this is where we need 


to come to a closure on it, too, is what went 


on with it and were the people monitored or 


not. 


MR. MORRIS: That’s a fair question, and we 


should interview the people that we --


DR. ZIEMER: Actually, there’s probably a, 

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this would be a very small number of people 


because Cockcroft-Walton, you’re going to have 


an operator, and that’s probably it. 


MR. MORRIS: Right, and we have contacts 


with analytical laboratory people who could 


make statements about this if we specifically 


ask, I think. 


MR. CHEW: I think we should do a follow up 


on it. 


MR. ROLFES: We’ll take another look. 


MR. GRIFFON (by Telephone): Yeah, that’s 


solved. 


MR. ROLFES: We’ve asked around and, you 


know, I’ve asked around casually with 


individuals, not necessarily the same 


individuals, but --


DR. ZIEMER: Now this is not part of the 


matrix, right? 


 MR. CLAWSON: Now it is. 


MR. CHEW: The neutron monitoring. 


MR. GRIFFON (by Telephone): I’m just 


putting it under 4.5-4. 


DR. BEHLING: Yeah, the second bullet. 


MR. GRIFFON (by Telephone): Just looking at 


other neutron exposure potentials. 

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DR. BEHLING: No, it’s probably not in the 


matrix, Paul. 


MR. GRIFFON (by Telephone): Yeah, it’s not 


really in the matrix, but it’s in the report, 


right? 


 MR. CLAWSON: Right. 


DR. BEHLING: It’s five o’clock, and we’re 


down to the last finding, 4.5-5, unmonitored 


female workers. And the TBD fully 


acknowledges two time periods during which 


females were not monitored for external, but 


then the question comes into play as to 


whether or not 500 millirem may be a bounding 


default value. 


And that also comes into question 


based on the fact that these women in the 


laundry facility were subject to exposures 


that come from dust collector bags and in 


today’s conversation we heard about thousands 


of gloves that were subject to laundering 


which were heavily contaminated in some 


instances. 


And I guess that the discussion that I 


wanted to stimulate here is the external 


exposure of 500 millirem a year, a bounding 

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value. And then does that also address issues 


that may come to, or that may involve internal 


exposures to whatever these dust collectors 


and gloves may have contained in the way of 


uranium, thorium and other radioactive 


materials. 


Here we see in one of the attachments 


on page 135 I highlighted a statement here 


that some of these bags that were subject to 


laundering were reading up to five millirep 


per hour after cleaning. The question is, oh, 


yeah, 30 millirep before cleaning and five 


millirem after cleaning. And to what extent 


this would contribute a dose that might 


significantly exceed the default value of 500. 


Now I assume the millirep here is a contact 


reading involving photon and beta dose. I’m 


not sure. 


MR. CHEW: Is that a question? 


DR. BEHLING: Yeah, the question is is 500 


millirem a year a default value that was a 


bounding value for women who were not 


monitored? 


MR. ROLFES: I don’t see the question how it 


relates to the laundry studies of the dust 

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collector bags which were collecting uranium 


materials and unmonitored women that didn’t 


enter the process area. 


DR. BEHLING: Wait a minute. When you’re in 


receipt of huge quantities of dust collector 


bags, they become your source of radiation 


exposure as was suggested here by these 


measurements. So they didn’t enter a process 


area, but they were certainly exposed to 


external and potentially internal exposures. 


MR. ROLFES: I’m still not clear where it’s 


saying that women received, unmonitored women 


received dust collector bags. 


DR. BEHLING: 4.5-5, laundry studies of dust 


collectors. I mean, who else would have been 


the recipients if not the women who ran the 


laundry? 


MR. CHEW: You’d confine it to women who ran 


the laundry, and they were not monitored. 


MR. ROLFES: So this is implied that the 


women were the individuals that were doing the 


laundry of dust collector bags. 


MR. CHEW: And they were not monitored. 


MR. ROLFES: And they were not monitored. 


So I honestly don’t know if it was the women 

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or men or both that were doing laundry 


studies. I would have to take a look at an 


individual’s records who actually did the 


laundry to determine whether the individual 


was monitored or not monitored. I think it’s 


a leap of faith to say only the women were 


doing the laundry and were not monitored. 


DR. MAKHIJANI: I think the point is not 


that only women were doing laundry. The point 


is that women who were doing laundry, apart 


from any men who might have done it. We know 


according to the TBD no women were monitored 


in two periods at Fernald. 


MR. CHEW: That’s correct. 


DR. MAKHIJANI: Unless you have some, and we 


know that women were doing laundry. Maybe not 


exclusively --


DR. ZIEMER: Do we know that? 


DR. MAKHIJANI: There are pictures of it. 


MR. FAUST (by Telephone): But it’s got to 


be at the right time. 


DR. MAKHIJANI: At the right time. We don’t 


have pictures of it from every period, but we 


do have a picture of a woman in the laundry 


taken in the ‘80s. This would lead presumably 

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to interviews. So I think there’s a kind of, 


the logical set up of the question should be 


correct is all I’m saying. Some women did 


laundry. We have to fix the period and 


perhaps amenable to an interview. But we know 


that they were not monitored in two different 


periods of time. 


MR. FAUST (by Telephone): Yeah, but the 


periods of time that they weren’t monitored 


was males only, 1951 through 1960 or to ’60. 


And again, from 1969 to 1978. 


DR. MAKHIJANI: Correct. 


MR. CHEW: And after that women were 


monitored? 


MR. FAUST (by Telephone): Well, in between 


those times, in between those two times, yes, 


they were. And after ’78 they were. 


DR. ZIEMER: Why did they add them and then 


delete them again? Do we know? 


MR. FAUST (by Telephone): I think it had, 


well, the thing that I read about this whole 


thing, the first time they didn’t have to 


based on the rules and regulations at the 


time. The second time they did it because of 


cost and the fact that they concluded they 

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didn’t have to. Anybody that received the 


less than I think ten percent of the allowable 


limit at the time didn’t have to be monitored. 


MR. CHEW: Your reference in the document is 


from 1958, and I think you mentioned that 


there was a picture of women that was in 1980. 


DR. MAKHIJANI: In the ‘80s. 


MR. FAUST (by Telephone): Well, in 1980 


they were monitored. 


DR. MAKHIJANI: No, no, that’s what I’m 


saying. If we have a picture of it, women 


were doing the laundry but not from the right 


period. 


MR. CHEW: (Unintelligible). 


MR. ROLFES: Now, Leo, during 1958 would 


women have been monitored? 


MR. FAUST (by Telephone): Nineteen fifty-


eight? No. 


MR. ROLFES: Okay. So if we have indication 


that a woman was working with laundry, the 


next question is could she have received in 


excess, working with laundry that was 


contaminated, could she have received in 


excess of the default that we have in our 


technical basis document? And I would like to 

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read into the record again that we do not feel 


that this is an SEC issue. 


Doses to female workers who were not 


monitored during two operating periods can be 


reconstructed by at least three methods. They 


are: if the worker in question is doing the 


same or very similar jobs during periods when 


she is monitored, that dose could be used to 


adjust the missing dose when she wasn’t 


monitored. 


The second methodology is workers who 


were doing the same job and were monitored at 


the time the female wasn’t, could have an 


equivalent dose assigned to the unmonitored 


worker. And three, assignment of the missed 


dose as stated in the TBD, Volume 6, of 500 


millirem per year for the missing time periods 


is known to be very claimant favorable. 


So there are three different 


methodologies that are proposed, and 


therefore, we do not believe this is an SEC 


issue, more of a dose reconstruction issue 


that depends upon the specifics of the case. 


 MR. CLAWSON: Mark, in the back of this you 


kind of had some generic action items, and you 

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had a Gilbert report. 


 (no response) 


 MR. CLAWSON: Did that get put onto the O 


drive? Did we ever get a hold of that Gilbert 


report? 


MR. ROLFES: Oh, I’m sorry. I didn’t know 


if you were talking to Mark Griffon or --


 MR. CLAWSON: Oh, you, I’m sorry. 


MR. ROLFES: Yes, we did have, the Gilbert 


report was made available to the Advisory 


Board members, and I did put that onto the O 


drive. Let’s see. We reviewed the Gilbert 


report, the Tiger Team report and the 


Westinghouse Transition report to assure, we 


did review those, and we did not feel that 


there was any impact on our ability to do a 


dose reconstruction. Those reports are 


available also for the Advisory Board working 


group. 


 MR. CLAWSON: They’re on the O drive? 


MR. ROLFES: Correct. 


MR. GRIFFON (by Telephone): And, Mark, did 


they, parenthetically there it said that this 


includes reviewing the data integrity but I 


forget exactly what I meant. Did this, 

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reviewing those reports, did it shed any light 


on any data integrity issues? 


MR. ROLFES: Gene, are you still with us? 


Gene Potter? 


MR. POTTER (by Telephone): Yes, I am. 


MR. ROLFES: Do you recall if there were any 


discussions? I believe it was you that had 


reviewed the mentioned reports in addition to 


some other individuals. Do you recall any 


data integrity issues from the various reports 


that we were asked to review? 


MR. POTTER (by Telephone): No, I looked at 


the Gilbert report initially specifically for 


issues with the mobile in vivo counter and the 


qualifications of personnel. I believe the 


issue had supposedly been raised in a report. 


The Gilbert report did not contain any such 


information. That’s what I was looking for 


specifically, and I’m not recalling any other 


issues. I also looked at a series of other 


reports that are on that SRDB trying to find 


the appropriate report that may have raised 


issues with the mobile in vivo counter, and I 


was unable to find any information on that. 


MR. ROLFES: Okay, so, Mark, it doesn’t 

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appear that there were any data integrity 


issues within the reports that were reviewed. 


MR. GRIFFON (by Telephone): I think as a 


follow up do we need SC&A, Brad, to look at 


these reports as well? I don’t know if we’ve 


officially asked them to look at these. 


 MR. CLAWSON: No, I don’t think we have. I 


think we need to follow up with that though. 


MS. BALDRIDGE: Brad, my recollection may 


not be accurate, but I thought when you 


suggested getting the Gilbert report, it was 


to review it for the environmental impact, and 


that it really didn’t have anything to do with 


the (inaudible). 


 MR. CLAWSON: Yeah, I brought that up, too, 


because I wanted to correlate it with some of 


the outside environmental ones that were 


brought up, so forth. 


MS. BALDRIDGE: And I think there are 


multiple reports; they may not have gotten a 


hold of the right reports. 


 MR. CLAWSON: Well, we’ll, I guess we could 


have SC&A take an action item to be able to 


look at the Gilbert reports. 


And I guess what I’d throw out there 

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is, I was looking at more from the data 


integrity facts on that. 


DR. MAKHIJANI: Brad, what did you mean by 


data integrity in relation to these reports? 


 MR. CLAWSON: Well, because there was a 


question of a Tiger Team report that went in 


there and really slammed Fernald especially 


from their Health Physics program, their air 


sampling data and so forth. And this was an 


internal one that was done. I just wanted to 


make sure that we weren’t missing anything on 


that. 


DR. BEHLING: What time period was that? 


 MR. CLAWSON: Nineteen eighty-five time era. 


DR. ZIEMER: For which report? 


 MR. CLAWSON: My understanding was, I just 


understood it as a Tiger Team. 


DR. ZIEMER: Tiger Teams didn’t exist in 


’85. 


MR. CHEW: Chuck Gilbert from EH --


DR. ZIEMER: Chuck Gilbert? Not Mark 


Gilbert? 


MR. CHEW: No, Chuck Gilbert from the 


report, and what it was that there was a 


transition from National Lead Ohio to 

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Westinghouse. 


MR. RICH: That’s just prior to. 


MR. CHEW: Yes, just prior to. And it was 


not part of the Tiger Team, Brad. It was 


right before. 


 MR. CLAWSON: Well, yeah, I guess I used the 


terminology that I’m using --


MR. CHEW: No, no, but it was a Tiger Team-


like report. 


 MR. CLAWSON: Right, and I wanted to make 


sure that we had, and I think that’s why we 


hit so many of them, Tiger Team, Gilbert 


report and Westinghouse transition was because 


we wanted to be able to review that. 


MR. CHEW: We also did look at the Tiger 


Team. 


Leo, I think you did that, right? 


MR. FAUST (by Telephone): Yeah, I reviewed 


the Tiger Team report of Health Physics 


aspects of it. They were rather critical of 


the internal dosimetry program. They were 


complimentary of the external program for the 


most part, but the internal program they were 


very critical over. They were super critical 


over the lack of completed SARs. But there 

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was nothing in it that I could find that would 


impact dose reconstructions. 


MR. CHEW: Can you be more specific about 


the issue that they had with the internal 


program, Leo, any more specificity? 


MR. FAUST (by Telephone): Well, I think 


that the time thing that they had with it was 


the fact that they didn’t do enough bioassays 


nor did they do enough full body counting. 


That’s what I recall anyway. 


 MR. CLAWSON: Well, it’s well past five 


o’clock, which I apologize. I think I still 


would like SC&A to be able to look into that 


and just make sure that we’re not missing 


anything. I’d like to look at it from the 


data integrity standpoint of it. 


MR. CHEW: They tell me it was very 


difficult to locate, believe it or not, the 


Fernald Tiger Team report. Headquarters 


didn’t have it. I think it was very, I mean, 


I’m just going to share that with SC&A not to 


look too hard. We’ll get it to you because 


you’ll spend another man-year looking for it, 


Hans. 


 DR. WADE: Brad, you did have this issue of 

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SC&A was going to develop a plan to develop a 


plan in terms of data completeness. Do you 


want to give some thought to timing on that 


now? 


 MR. CLAWSON: Well, I didn’t know if that 


had time to be able to really sit down. 


DR. MAKHIJANI: I tried to call John but 


couldn’t reach him. 


 DR. WADE: Well, maybe then when SC&A gets 


its head together let Brad know, then you can 


decide when you want to reconvene the work 


group. 


 MR. CLAWSON: Maybe what we may be able to 


do is just have a conference call or something 


like that and be able to discuss, we’ll 


evaluate that -- wait with everybody on the 


Board when we get that information when I get 


a time. 


 DR. WADE: Well, if SC&A gives you a sense, 


and even on the call on the 27th you could in 


your time use it to set a time for a work 


group call. 


DR. MAKHIJANI: I guess we can do that. We 


can give a sense of when we’ll produce this 


memo, and it shouldn’t take too long. 

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MR. GRIFFON (by Telephone): Hey, Brad? 

 MR. CLAWSON: Yes, Mark. 

MR. GRIFFON (by Telephone): Since it’s so 

late I won’t go back and read through all 


these actions, but I will, I’ll revise the 


matrix based on what Mark had sent out 


recently. I’ll add in the new actions and 


turn it around in a few days just so it’s 


fresh on our minds still and circulate it if 


that’s okay. 


 MR. CLAWSON: Okay, I appreciate that. I 


appreciate everybody’s continued support on 


this. 


 DR. WADE: Well, thank you very much, all of 


you, for your work. It’s a long day, but it 


needs to be done to do justice to the people 


whose lives we’re reviewing, so thank you very 


much. 


MR. ROLFES: Do we need to schedule another 


meeting before we leave here? 


 DR. WADE: Well, I’m not going to be able to 


do that. SC&A’s going to get back to Mark 


with its timeline on the plan to develop a 


plan. And then maybe on the call on the 27th , 


we’ll look at scheduling a meeting. 

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MR. SCHOFIELD: You’re the only one’s going 


to be back here. The rest of us get to leave. 


MR. ROLFES: I’ll be here. 


 MR. CLAWSON: With that said, we’ll say 


goodbye and thank you. 


(Whereupon, the work group meeting adjourned 


at 5:30 p.m.) 

______________________________ 

332 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of November 13, 


2007; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


3rd day of February, 2008. 


STEVEN RAY GREEN, CCR, CVR-CM 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102