This transcript of the Advisory Board on Radiation and Worker Health, Grand Junction Facilities Work 

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1 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

+ + + + +

GRAND JUNCTION FACILITIES WORK GROUP

+ + + + +

WEDNESDAY

OCTOBER 5, 2016

+ + + + +

The Work Group convened by telephone at 

10:00 a.m., William Field, Chair, presiding.

PRESENT:

R. WILLIAM FIELD, Chair

GENEVIEVE S. ROESSLER, Member

LORETTA R. VALERIO, Member
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2 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
This transcript of the Advisory Board on Radiation and Worker Health, Grand Junction Facilities Work 

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

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

3 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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ALSO PRESENT:

TED KATZ, Designated Federal Official

NANCY ADAMS, NIOSH Contractor

BOB BARTON, SC&A

HANS BEHLING, SC&A

DOUG FARVER, ORAU

JENNY LIN, HHS

JIM NETON, NIOSH

MUTTY SHARFI, ORAU

JOHN STIVER, SC&A

TOM TOMES, DCAS
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4 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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Contents

Welcome and Roll Calls ........................... 5

SC&A Review of NIOSH SEC Evaluation Report and NIOSH 

Response ......................................... 6

Petitioner Comments ............................. 74

Path Forward and or Plans for November Board Session

................................................. 74

Path Forward for Resolution of Site Profile Issues from 

SC&A Review of Program .......................... 75

Adjourn ......................................... 82
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1 P R O C E E D I N G S

2 10:00 a.m.

3 Welcome and Roll Calls 

4 MR. KATZ: The Advisory Board on 

5 Radiation and Worker Health, it's the Grand 

6 Junction Facilities Work Group. Welcome, 

7 everybody.

8 The agenda and most of the materials for 

9 today are posted on the NIOSH website. They're

10 posted under this program's section of the website, 

11 Board Section, Schedule of Meetings, today's date, 

12 and if you go there you can pick up most of them, 

13 the agenda and most of the documents.

14 One of the -- the most recent document 

15 from SC&A has not been posted yet. There are some 

16 posting problems that CDC is having in general that 

17 have afflicted us the last few days in this program, 

18 too.

19 So that one is missing right now, but 

20 when Doug does his review, he'll be covering that 
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1 material orally at least, and it will get posted 

2 when it can.

3 Okay, so roll call. 

4 (Roll call.)

5 MR. KATZ: Okay. Very good. Well 

6 that takes care of preliminaries. Let me just 

7 remind everyone to please mute your phones. If you 

8 don't have a mute button, press *6 to mute your 

9 phone and again *6 to come off of mute if you're 

10 addressing the group, and, Dr. Field, it's your 

11 meeting.

12 CHAIR FIELD: All right, Doug. Would 

13 you mind going over your review?

14 SC&A Review of NIOSH SEC Evaluation Report and NIOSH 

15 Response

16 MR. FARVER: Yes, I'll go over my 

17 review. I don't have it for Live Meeting, but I'm 

18 not sure anyone else is on there.

19 CHAIRMAN FIELD: That's fine. I think 

20 we all have a copy.

21 MR. FARVER: Okay. Do you want me just 
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1 to scroll through and just tell you where I'm at 

2 and proceed through?

3 CHAIRMAN FIELD: All right. I think 

4 so.

5 MR. FARVER: Okay, so this was a review 

6 of the Addendum to Petition SEC 175, and it pretty 

7 much dealt with the period after 1985, and if we 

8 turn to page 3, we'll go through the Table of 

9 Contents real quick, and I start off with just going 

10 through a background of the facility, the SEC, and 

11 then I believe SC&A did a review of PER-47, I 

12 believe. That's what Hans wrote, and then I start 

13 into the addendum and review the external and 

14 internal dosimetry. And move on to page 6, but if 

15 you go to the very bottom of page 6, you see the 

16 purpose for this report is SC&A was asked to look 

17 at the revised SEC time period and also the 

18 appropriateness of the air monitoring of bioassay 

19 data.

20 So after the first ten pages of history, 
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1 then we get into the actual meat of the report.

2 Do you want me to go through the whole 

3 background of the facility and the SEC and so forth?

4 CHAIRMAN FIELD: If you don't mind. I 

5 think it would be helpful. This our first meeting. 

6 It's been awhile since we went through this. It 

7 would be nice to have it on the record.

8 MR. FARVER: Okay. We can go to page 

9 7, and we start with the facility history that they 

10 started back in the '40s under the Manhattan 

11 Engineering District in order to concentrate 

12 uranium.

13 From '74 through '84 it reported the --

14 it supported the National Uranium Resource 

15 Evaluation Program and preparing samples for 

16 analysis, and there were other activities under 

17 clean-up for Uranium Mill Tailings Remedial Action 

18 Program starting in '78, and by 2001, the 

19 remediation had been completed, so we have kind of 

20 an endpoint in 2001.
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1 Now the original SEC, back from 2011, 

2 and well if you skip to page 8, you can see the 

3 summary of the feasibility findings in Table 1-1. 

4 These were the periods that NIOSH broke down, '43 

5 to '75, and '75 to 2010, 2010. And in general, they 

6 thought they could do a reconstruction of the 

7 external dose for most of the time period, but they 

8 didn't feel it was feasible to do the internal dose 

9 for '43 through '75, and then through the period 

10 after is what we're going to be talking about.

11 So that's kind of what they came up 

12 with, and, you'll hear as I go through this that 

13 when we talk about the external dosimetry, yes, it 

14 hasn't changed much. They already thought it was 

15 feasible to do, so I won't spend a lot of time on 

16 that.

17 I'll mainly focus on the air monitoring 

18 and the bioassay data. 

19 Section 1.13 just talks about the SC&A 

20 report when they reviewed PER-47, and I wrote a lot 
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1 of this mainly to bring myself up to speed since 

2 I came in after all this had happened, and I don't 

3 believe SC&A reviewed the original SEC Report, 

4 Evaluation Report, so I believe that's why it was 

5 the purpose of reviewing the PER that came out of 

6 the Evaluation Report.

7 Then on -- we'll probably talk about 

8 this later, they went and reviewed all the data, 

9 and there were a few findings. I think they closed 

10 a couple of findings. There are still a couple 

11 that are open, and I'm not -- I'm going to let him 

12 talk about that, so we can move on to Section 2 on 

13 page 11 where we talk about the SEC addendum.

14 In the original SEC Evaluation Report, 

15 NIOSH concluded that the internal dose 

16 reconstruction was likely feasible for the period 

17 from February of '75 through July of 2010, and that 

18 the external dose was likely -- was likely feasible 

19 for the period of January 1960 through July of 2010, 

20 and they also found it feasible for the medical dose 
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1 from 1940 -- for the period of, the entire period 

2 from '43 through 2010.

3 When they did their initial 

4 presentation of the original SEC Evaluation 

5 Report, they had indicated to the Board or to the 

6 Work Group that they had received additional data 

7 that was pertinent to the post-1975 period, but 

8 they hadn't fully evaluated it, so they kind of held 

9 this in reserve, the period after 1975, and that 

10 was the purpose of this addendum to go over that 

11 data and what they had determined.

12 The addendum came out in March of 2015, 

13 the principal sources of internal radiation dose 

14 for members of the public, natural uranium and 

15 thorium and their decay products.

16 NIOSH determined that there was 

17 insufficient data available to bound intakes of 

18 uranium, thorium and their associated daughter 

19 products from '75 through '85, but they did find 

20 I believe it was feasible to go after '85, well 
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1 1986, beginning there onward, that they could --

2 and it was feasible to determine the internal dose.

3 Based on a lack of internal dose 

4 monitoring data and air monitoring data from 1975 

5 through 1985, it was determined it was not feasible 

6 to do the internal doses.

7 Page 12, Table 2-1, kind of sums up the 

8 period from 1975 all the way through 2010, broken 

9 into two periods of 1975 through 1985, and 1986 

10 through 2010.

11 For the period from 1975 through '85, 

12 NIOSH determined it was not feasible to do the 

13 internal doses except for radon, which they had 

14 already determined was feasible.

15 They did believe it was feasible to do 

16 the doses after 1986, internal and external, and 

17 you'll see this is kind of what we focus on, this 

18 period of 1980 through January of 1986, is this an 

19 appropriate time period to begin is one of the 

20 questions.
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1 2.1, review of the external dosimetry 

2 data. I reviewed what they presented in their 

3 Evaluation Report, and the bottom line is it really 

4 hadn't changed from the original report, so it was 

5 feasible in the original report, and it's still 

6 feasible in the addendum, so I didn't spend a lot 

7 of time. I just reviewed what they had and what 

8 Hans wrote, and SC&A agrees with the feasibility 

9 determination for the external dosimetry.

10 The same thing with the medical dose, 

11 Section 2.1.2. It hasn't changed since the 

12 original SEC Evaluation Report, the same time 

13 period. It was feasible then. It's feasible now, 

14 so -- and that eliminates a lot of it.

15 Onto the internal dosimetry data in 

16 Section 2.2, first up was radon. This is another 

17 situation where it has the same feasibility 

18 determination in the addendum as there was in the 

19 original Evaluation Report, and SC&A had already 

20 reviewed that under PER review, and we concur with 
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1 NIOSH's feasibility determination.

2 Now we're getting down to the good 

3 stuff, the air monitoring data and the bioassay 

4 data. So we began by looking at the air monitoring 

5 data that coincided in the addendum. 

6 As noted in the SC&A report, and Hans 

7 will talk about, prior to '89, air samples generally 

8 lacked information about location. Between 1945 

9 --

10 MEMBER ROESSLER: Doug, Doug. This is 

11 Gen. I've lost track of what page you're on.

12 MR. FARVER: I'm on page 13.

13 MEMBER ROESSLER: Oh, I jumped ahead. 

14 Thank you very much.

15 MR. FARVER: I'm trying to rush through 

16 that because I was trying to get to the more 

17 important information and not --

18 MEMBER ROESSLER: Yes, it got lost in 

19 all those tables. I appreciate that. Thanks. 

20 I'm there.
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1 MR. FARVER: Okay. Between 1945 and 

2 '61 the results for a particular sample interpreted 

3 as uranium. In 1960s only radon and radon daughter 

4 results are available, and then in 1986 there was 

5 some time-weighted exposures for the first quarter 

6 that were calculated in terms of MPC hours for 

7 individuals performing grinding operations of the 

8 uranium mill tailings in the sample prep lab. 

9 I believe this was a memo from someone 

10 to someone else. Beginning in 1989, there are 

11 numerous air sample measurements for on-sight D&D 

12 work, both general area and breathing zone, and then 

13 Table 2-2 just lists all the air sampling data that 

14 was cited, and it goes on and on and on and on and 

15 on for a couple of pages, but you can see that in 

16 the early years, there just wasn't a whole lot of 

17 information, and then we jump to like 1986 on the 

18 top of page 15, and we've got a lot of radon data, 

19 and there appears to be more data for that time 

20 period afterwards.
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1 So afterward, we reviewed the air 

2 monitoring data, SC&A concludes that the lack of 

3 adequate air monitoring data prior to 1961 and the 

4 absence of air monitoring data from '62 to '85 

5 support NIOSH's position that it's not feasible to 

6 reconstruct the internal doses from 1975 through 

7 1985, and '85 is a good breakpoint because that when 

8 there seems to be more data after, beginning in 1986 

9 during D&D operations.

10 Okay. Next section is internal doses 

11 to unmonitored workers. According to the 

12 addendum, there was no comprehensive database and 

13 bioassay results and only a limited number of 

14 results are available for the period of 1945 through 

15 1999, as shown in Table 2.3. 

16 Table 2.3 on Page 17 lists the available 

17 bioassay results, and you can see that it's not too 

18 many, especially in those early years. There just 

19 wasn't much available, and NIOSH found that some 

20 workers do have bioassay measurements included in 
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1 their records, but not enough claimants with 

2 bioassay information are available to indicate 

3 which workers were routinely to be included in the 

4 bioassay program.

5 So we don't really have a good handle on 

6 the bioassay program or the results through 1999. 

7 So we move on. Boy, that's a long 

8 table, but it kind of shows you all the results that 

9 were presented in the addendum, and I thought it was 

10 good to spell them out here so that everybody was 

11 on the same page, and speaking of page, we're going 

12 to get up here to page 22.

13 So we looked at the data. NIOSH 

14 determined the data was not sufficient to 

15 accurately reconstruct the internal doses for the 

16 period of February 1st, '75 through December of '85, 

17 and NIOSH reviewed the data and agreed with them. 

18 It's just not sufficient.

19 So you don't have sufficient bioassay 

20 data, and you don't have sufficient air monitoring 
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1 data, so it's not feasible to reconstruct the doses 

2 from '75 through '85.

3 Okay, how about bounding the doses? 

4 NIOSH believes that there was sufficient data to 

5 support bounding the internal dose from '86 

6 through 2010 based on air monitoring and the 

7 bioassay data that was available.

8 This period of '86 through 2010, you can 

9 break it down into two periods. There's the period 

10 before 1991, so it would be '86 to 1990, and then 

11 the period after '91 which -- you know, '91 to 2010.

12 Sample prep activities occurred from 

13 '86 to '90, and the D&D activities occurred from '88 

14 to 1990. After 1991, that's when DOE Order 5480.11 

15 became effective or was to be implemented. That's 

16 kind of why we have this break period.

17 The DOE Order specifies that bioassays 

18 shall be collected if exposure indicates that a 

19 worker could be exposed to inhalation intake during 

20 the year it exceeded 200 DAC-hours and that a 
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1 monitoring program must be in place for all workers 

2 who could have the potential for 40 DAC-hours.

3 We'll go back to the sample prep period, 

4 so this is going to be the '86 through 1990 on top 

5 of page 23. NIOSH determined that the sample prep 

6 to the highest on-site -- that determined sample 

7 preparation to be the highest on-site exposure 

8 potential scenario in the post-1985 period, from 

9 '85 through '90, and then we quote them from the 

10 addendum: for the period of 1986 through 1990, 

11 bounding daily uranium intake rates for operators 

12 and laborers may be assigned by assuming that the 

13 worker received the MPC hour limit every quarter, 

14 using thorium-230 as the applicable MPC.

15 SC&A looked at this and believed that 

16 that was a reasonable proposal and that it was 

17 adequate for bounding the intakes. NIOSH states 

18 that the method for bounding the uranium intakes 

19 during the time period is also appropriate to bound 

20 thorium intakes from the same period, and the 
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1 rationale for this conclusion is that the controls 

2 used for crushing and grinding uranium ore were the 

3 same controls used for grinding thorium, and both 

4 operations took place in the same facility.

5 NIOSH goes on to state that based on 

6 interviews with former workers, and they have some 

7 information about the crushing and grinding, and 

8 for the purpose of bounding potential intakes of 

9 thorium from these operations, a full calendar 

10 month of exposure to thorium ore is assumed for each 

11 operation.

12 These are based on three personal 

13 communications or interviews, so I went back and I 

14 looked at the three personal communications, and 

15 really it was only between two people. The one 

16 interviewee was -- he appeared to be upper 

17 management, and he didn't seem to remember a lot, 

18 and he referred to this second person, and two 

19 interviews were conducted with the second person 

20 who was also kind of like a supervisor/manager, 
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1 based on his job description. That was kind of my 

2 impression.

3 From the interview with the second 

4 person, they came up with a time estimate for 

5 crushing and grinding, and I believe that's how 

6 NIOSH came up with this month, full month for -- MPC 

7 for a full month.

8 If you look at -- I do have a concern with 

9 it, and Concern 1: both interviewees were kind of 

10 management-level employees and not operators or 

11 laborers who performed the work, and I kind of feel 

12 like you're only getting one side of the story, so 

13 it would be beneficial to obtain some information 

14 from the people who did the work and see if it at 

15 all concurs -- just a concern.

16 During that second period before 1991, 

17 during the D&D period, investigations for site 

18 remediation began in '84. Remedial investigation 

19 study was done in 1989, and the Record of Decision 

20 was approved in 1990, so that kind of puts an 
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1 endpoint on that in 1990.

2 Tailings were removed in '89 through 

3 '94, and a close-out survey site was completed in 

4 1995. The second paragraph: thousands of pages of 

5 health and safety data have been recently captured 

6 for the period of 1991 to 2007 when most of the D&D 

7 activities took place.

8 Later in the paragraph: there's no 

9 database of the results that can readily be used for 

10 co-worker study; however, these data, the ones that 

11 are cited above from 1991 to 2007, it is evident that 

12 the most highly exposed workers were monitored. If 

13 no data are available for a D&D worker, the bounding 

14 dose scenario can be constructed from the health and 

15 safety data.

16 This is all very reasonable and fine. 

17 The only concern, and it's listed down here as 

18 Concern 2, is you have thousands of pages of data. 

19 How is it going to be used by the dose 

20 reconstructers? 
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1 I think this is a similar concern that 

2 Hans had with some air sampling data. There's a lot 

3 of air sampling data, but how is it actually going 

4 to be used by the dose reconstructers? So that was 

5 Concern 2.

6 On to DOE Order 5480.11. There was a 

7 document in 1990, Technical Basis for Bioassay 

8 Sampling for Sample Preparation Plant in Grand 

9 Junction Vicinity Property Workers, written by 

10 Geotech, and it describes their implementation of 

11 the DOE Order 5480.11. 

12 It states that bioassay will be 

13 collected. If exposure indicates the worker could 

14 be exposed to intakes during a year that exceeds 200 

15 DAC-hours and states that a monitoring program must 

16 be in place for all workers who have the potential 

17 for 40 DAC-hours.

18 It regurgitates the requirements of 

19 5480.11. It was issued in early 1990. NIOSH is 

20 assuming that full implementation was not in place 
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1 until the end of 1990. 

2 Okay, so I went back and looked at the 

3 Technical Basis Document, and the executive summary 

4 gives a little quote there. The interim bioassay 

5 program consists of collecting urine samples, which 

6 will be analyzed for radium, allows performance of 

7 standard workplace monitoring for DAC sectional 800 

8 milligrams. 

9 Perspective monitoring or workplace 

10 monitoring will consist of air monitoring and urine 

11 sample collection. Air monitoring will be the 

12 primary method of monitoring the workplace.

13 Urine samples will be collected from 

14 representative workers every six days. This will 

15 be accomplished by rotating the workers on a routine 

16 bioassay program.

17 The next paragraph on the top of Page 26, 

18 retrospective individual worker monitoring will 

19 consist of routine urine sample collections from 

20 individual workers every 26 days.
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1 One of the principles in DOE 5480.11 was 

2 that you have to have your operations people working 

3 with your dosimetry people so you have this 

4 prospective and retrospective so that you can't do 

5 it entirely from bioassay, and you can't do it 

6 entirely from air sampling. They have to work 

7 together so that when you get a high air sample, it 

8 triggers something for bioassay so that you can meet 

9 this performance objective of 200 DAC-hours for the 

10 year.

11 Okay. Section 4 of the Geotech 

12 Technical Basis talks about performance 

13 capabilities. Air monitoring shall be the primary 

14 method. Bioassay measurements may also be used to 

15 support a prospective monitoring program but shall 

16 not provide the primary basis for monitoring for 

17 loss of control in a workplace. Pretty much what 

18 I described.

19 Table 2-4 lists the air monitoring data 

20 that is contained in the Geotech Technical Basis, 
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1 and using the thorium DAC, two of those samples 

2 under the thorium 230 exceed the DAC levels, so I'm 

3 not sure that that's too helpful other than it just 

4 gives you an idea of what the air sample levels were 

5 like in the sample prep lab.

6 At the bottom of the page, Section 7 of 

7 the Bioassay Sampling Technical Basis Document 

8 describes how air monitoring of bioassay programs 

9 are used to determine compliance.

10 The top of page 27, air monitoring data 

11 will be tracked by the use of a database program 

12 presently being developed. It will track all the 

13 derived air concentration values of air samples, 

14 sample location, workers present, reduction due to 

15 the respirator use, and occupancy time, and this 

16 will allow the determination of the need for 

17 follow-up bioassay when a worker is suspected of 

18 having an intake equivalent to .02 ALI, 40 

19 DAC-hours.

20 This is what I was talking about how the 
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1 order was trying to get people to work together and 

2 have workplace samples trigger your bioassay 

3 follow-up, and this is what they wrote that they 

4 were going to have a database and track the air 

5 samples and the -- and trigger the bioassay 

6 sampling.

7 Second paragraph, urine samples will be 

8 collected from a representative worker every six 

9 days, kind of what they cited in the executive 

10 summary. 

11 On to Table 2-5, Table 2-5 contains the 

12 available air monitoring information during and 

13 after the time period when the Technical Basis for 

14 Bioassay Sampling was implemented, with the 

15 exception of the workplace air monitoring results 

16 contained in the Technical Basis, no other 

17 workplace air monitoring results were found. So we 

18 didn't find a lot of air sampling results that were 

19 useful, and that's kind of what Table 2-5 shows.

20 NIOSH goes on to state in their addendum 
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1 that, therefore, starting in 1991, it is assumed 

2 unmonitored radiation workers would not have 

3 exceeded 200 DAC-hours in a given year. If they 

4 had, they would have been placed on a bioassay 

5 program.

6 In addition, it is assumed that 

7 non-radiation workers would not have exceeded 40 

8 DAC-hours in a given year, and the assumption is 

9 that the order was being implemented by 1991, so all 

10 those requirements were being met.

11 Well, I took a look at it, and came up 

12 with the one and only finding. Although the 

13 Technical Basis Document for Bioassay describes how 

14 the program should operate, there was no document 

15 or database that was presented in the addendum that 

16 would contain air monitoring results, sample 

17 location, workers, to demonstrate that the 

18 workplace controls described in the Technical Basis 

19 Document had actually been implemented.

20 SC&A does not believe NIOSH has shown 
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1 sufficient workplace air monitoring data to support 

2 the assertion that unmonitored radiation workers 

3 would not have exceeded 200 DAC-hours or that 

4 non-radiation workers would not have exceeded 40 

5 DAC-hours in a given year, so I just didn't find the 

6 data compelling.

7 We go on to the summary, the summary on 

8 page 30. Two things I was asked to look at was the 

9 appropriateness of the revised SEC time period. I 

10 looked at the time period. The time period looked 

11 like it was adequate and sufficient. 

12 The appropriateness of the air 

13 monitoring of the bioassay data, this is where we 

14 ran into a couple of concerns regarding the 

15 interviewees and how the data would be used, the 

16 workplace data, and also the findings for that 

17 period of after 1991 forward that really just didn't 

18 find sufficient air monitoring data to support 

19 their assertion.

20 So that's kind of the short story of a 
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1 long program.

2 CHAIRMAN FIELD: Okay. I appreciate 

3 that. Gen or Loretta, do you have any questions for 

4 Doug?

5 MEMBER ROESSLER: Yes. This is Gen. 

6 I have -- this is a lot of stuff. I have a lot of 

7 questions. I'll start with maybe a rather simple 

8 one.

9 Doug, on page 26 in Table 2-4, those 

10 numbers look kind of strange to me, and I don't 

11 really understanding air monitoring very well, but 

12 as I just kind of glanced at the table, it seemed 

13 like a lot of numbers were alike.

14 For example, in the first sample there, 

15 Sample 651, you get that 9.3E-7, three times there 

16 for different radionuclides, and then that same 

17 number of tiers in Sample 655 for two different 

18 radionuclides, and that keeps occurring in the 

19 table. 

20 I don't understand why those numbers 
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1 would be the same.

2 MR. FARVER: I can't speak to the 

3 validity of these numbers because they were not 

4 referenced. In other words, I could not see the 

5 actual results. This is just a table that was taken 

6 out of the Geotech Technical Basis Document, so I 

7 cannot speak to even what kind of samples they are, 

8 are they breathing zones, are they general area 

9 samples, are they low volume, high volume. I 

10 really can't speak to that.

11 MEMBER ROESSLER: Well maybe Tom or Jim 

12 would know more about that.

13 MR. TOMES: This is Tom. I basically 

14 agree with what Doug says as far as the information 

15 provided by these tables there. There are some 

16 results reported by the site in assessment of 

17 potential exposures from the sample prep lab, and 

18 I -- it is my opinion that some of these may be an 

19 assumed equilibrium because it's too unusual for 

20 some of these to be exactly the same result for the 
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1 individual radionuclides, but I do not have any 

2 definitive information on exactly how they 

3 determine the various nuclide concentrations.

4 MEMBER ROESSLER: It does kind of bring 

5 out the question about the reliability I guess of 

6 that data, but then I guess another -- I have one 

7 other question, then I'll let other people talk 

8 then.

9 When you talk about interviews, well, 

10 the lack of data and interviews with employees, yes, 

11 I kind of agree. On other sites we often have --

12 make a real point to interview employees in kind of 

13 wide range of them. 

14 It would seem that these 

15 management-level people should be good to 

16 interview, but I'd agree that other interviews 

17 might be necessary.

18 MR. FARVER: And I don't know if they 

19 actually did interview other people. All I know is 

20 this is what they referenced and what was cited in 
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1 the addendum.

2 MR. TOMES: This is Tom. Perhaps Mike 

3 could have information on the interviews, but I 

4 don't recall any more details, but I do recall that 

5 we have some references describing some of the work 

6 that was going in preparation of the models that's 

7 the subject of that work, and so we did consider 

8 other sources of information.

9 CHAIRMAN FIELD: Loretta, do you have 

10 any questions?

11 MEMBER VALERIO: Actually, I do. So on 

12 the, I believe it was the bioassay data, in the 

13 period 1984 through 1986, the number of results is 

14 significantly higher than the other years. Was 

15 that because of the D&D work that was being done?

16 MR. FARVER: I'm trying to find that 

17 table real quick.

18 MEMBER VALERIO: It's on -- I'm looking 

19 at page 18.

20 MR. FARVER: Okay.
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1 MEMBER VALERIO: Which is one, two, 

2 three, four, fifth from the bottom.

3 MR. FARVER: Okay.

4 MEMBER VALERIO: Where under the column 

5 of approximate number of results, you have 1,589, 

6 compared to all the other years.

7 MR. FARVER: Yes, it looks like it's a 

8 summary from '84 through '86, so it would be, '84, 

9 '85, '86, three years of data, and the other ones 

10 look like they are just specific individual data, 

11 so I would say that is when a lot of the work was 

12 going on, during that time period, and I'll check 

13 my timeline. That may have been the D&D period.

14 MEMBER VALERIO: Okay, so then that 

15 raises the next question. Were these just baseline 

16 samples, and were these for -- it says that they were 

17 baseline samples, and most are for off-site 

18 remediation workers, so the people who were working 

19 off-site were being bioassayed I'm guessing based 

20 on this number, and they were strictly doing D&D. 
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1 Am I understanding that correctly?

2 MR. FARVER: I do not know at the 

3 moment.

4 MR. TOMES: This is Tom. I might be 

5 able to help out a little bit there. I've reviewed 

6 a lot of those records and they -- in '85-'86 as Doug 

7 described earlier when he was describing the 

8 program, they made some changes in monitoring 

9 practices, and there are a substantial amount of 

10 baseline samples for off-site D&D activities.

11 At this time at Grand Junction, there 

12 was very little exposure because most of the work 

13 they were supporting had the potential for intakes 

14 were at off-site work, so although the site employed 

15 many people, the majority of those workers were 

16 actually off-site. And we evaluated them before 

17 the D&D work started a few years later, a couple of 

18 years later, that the sample prep lab was the work 

19 that had the highest potential for exposure, and 

20 that was consistent through some records we found 
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1 from the site, including the one that is the subject 

2 of this -- of the air sample results we talked about 

3 a few minutes ago.

4 So in this period, it has been actually 

5 instituted a program, the best I can tell, of 

6 baseline samples and evaluation, specific samples 

7 for evaluation. That's why there's a large number 

8 in that year I believe.

9 MEMBER VALERIO: Okay, so were there 

10 follow-up bioassays after the baseline?

11 MR. TOMES: Well that is hard to get a 

12 handle on, exact frequency, from my perspective. 

13 They instituted this program in '86, and they had 

14 some interim measures, and it wasn't until '91 that 

15 we think they had more of a routine program. 

16 We do know they had throughout this 

17 period, starting in '86 and on through the '90s, 

18 they did have -- there's a lot of records of work. 

19 They had RWPs, job coverages, air samples, special 

20 urines, special bioassays, and the only record I can 
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1 find that they -- actually a routine bioassay 

2 program existed that I can confirm is in '91, '92, 

3 '93. They had some, at least some annual bioassay 

4 programs for people who had access to airborne radon 

5 activity areas, and I know that occurred in the '91, 

6 '92, '93 era. 

7 I do not know if it continued past that 

8 point. The primary means of assessing exposures 

9 was air monitoring, and they used -- they had a 

10 respiratory protection program for respirators and 

11 as I mentioned earlier, most of the activities at 

12 the site other than D&D work did not involve 

13 exposures.

14 But then if you look at the Evaluation 

15 Report's tables of bioassay data, you can see 

16 throughout that whole period, there are numerous 

17 instances of special bioassays being required.

18 MEMBER VALERIO: Right, right, so I 

19 guess that brings me to my next question. So it 

20 says that the samples were for both off-site and 
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1 on-site work; therefore, for a given worker the 

2 samples might not be for work that is covered by 

3 EEOICPA, so how are -- you know, how is NIOSH or DOL 

4 separating who was off-site and on-site for 

5 purposes of a dose reconstruction if someone filed 

6 a claim?

7 MR. TOMES: I'm not familiar with how 

8 DOL does that; however, for NIOSH, if DOL sends out 

9 the claim, and they say they worked on site, we 

10 assume they worked on site, and we access the 

11 exposure accordingly. And we've used the air 

12 sample data for D&D to come up with models for 

13 intakes. We've used the limiting bounding intakes 

14 for other works, such as the sample prep lab, for 

15 a model for those, and so we do not try to -- unless 

16 we have very, very good information in the 

17 claimant's file, we do not attempt to separate out 

18 off-site from on-site because it's difficult to do, 

19 if not impossible.

20 MEMBER VALERIO: All right. Thank 
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1 you.

2 CHAIRMAN FIELD: Okay, so, I guess, 

3 Tom, at this point, could you -- could you give us 

4 what your response was to the one finding? Could 

5 you sort of summarize that?

6 MR. TOMES: Yes, we went back and looked 

7 at the information from Doug's finding, and we did 

8 not find any record of a DAC-hour tracking base, and 

9 so we do not know if it exists. We certainly didn't 

10 find it, but we have gone and looked at the exposure 

11 level that the site controls things to, and their 

12 program is based on 10 percent of the DAC, or in 1986 

13 it would have been the MPC, but by '91 it was 10 

14 percent of the DAC of DOE Order 5480.11, and they 

15 had programs -- they had an extensive air monitoring 

16 program in place.

17 There is a whole lot of air monitoring 

18 data throughout this period, and so we have -- and 

19 they had requirements, as I mentioned a while ago, 

20 for a bioassay at -- a routine bioassay, at least 
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1 in the early '90s they did. And then they had a 

2 program to monitor job coverage from RWPs, and they 

3 had respiratory protection requirements. They had 

4 a full respiratory protection program, and we do 

5 believe that all those, all that information 

6 indicates that the 10 percent DAC with bound intakes 

7 for unmonitored workers, although we did not find 

8 a DAC-hour tracking base that's referenced in that 

9 one document and mentioned by Doug.

10 CHAIRMAN FIELD: Okay, so, Doug, do you 

11 have any response to that?

12 MR. FARVER: Yes. I believe that was 

13 sent out to the Work Group this week, last week --

14 last week, a week ago.

15 The bottom line is, we didn't see any air 

16 sample results for 1991. So if they had a lot of 

17 air sample results, which they should have, that was 

18 not cited in the NIOSH's response as one of the 

19 documents, and I go, in my reply to their response, 

20 I go through each of the documents that they 
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1 referenced and describe what it is and what time 

2 period it covers, and there just wasn't any air 

3 sampling results from 1991, so I go back to the 

4 original.

5 If they had a good program, there should 

6 be some air sample results.

7 CHAIRMAN FIELD: Okay, so I hate to have 

8 you banter back and forth, but, Tom, do you have a 

9 response to that?

10 MR. TOMES: I'll be honest with you, I 

11 did not get -- I was on vacation last week, and I 

12 just briefly went through Doug's response when I got 

13 back to work Monday, and I am not fully prepared to 

14 address any details they're monitoring as far as any 

15 specific year and what's available.

16 Quite frankly, I'm not prepared. I 

17 didn't have enough time to prepare for that;

18 however, there are, I do know there are hundreds and 

19 hundreds of air sample results, but I do not have 

20 a report to tell you how much is in each year and 
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1 what location and all that, and I would have to work 

2 on that to provide a meaningful response I believe. 

3 But there are hundreds of air sample results from 

4 D&D in particular, and I believe that '91, I'm just 

5 not positive about '91.

6 CHAIRMAN FIELD: Mutty, do you have any 

7 indication of that by any chance?

8 MR. SHARFI: One example, for Building 

9 7, the D&D work was in '91, and there is an SRDB 

10 93816, and it's got a ton of air sample data sheets 

11 that are in there, so there's plenty of examples.

12 Even in the RWPs in the 1990s they -- we 

13 captured a lot of the RWPs, not as much -- doesn't 

14 look like the supporting RSDs, we, it doesn't look 

15 like -- we maybe didn't capture, but in a lot of 

16 those, it indicates that air monitoring was 

17 required. There are stop actions for air sampling.

18 There is requirements to notify RadCon 

19 Control for DAC-hour tracking if you exceed certain 

20 levels so they can do DAC-hour tracking. There's 
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1 a lot of indication that they had a, not just a good 

2 air monitoring program, but that they were 

3 conscious of the uses of the air monitoring program.

4 CHAIRMAN FIELD: So, Doug, have you 

5 seen all this data?

6 MR. FARVER: Well I wanted -- well, what 

7 was that document number again?

8 CHAIRMAN FIELD: 9816. It's the 

9 Building 7 D&D Radiological Survey Data.

10 MR. FARVER: Right. I addressed that 

11 in my response, and that was Building 7, D&D 

12 Radiological Survey Data. It includes sampling 

13 data, RWPs, health and safety evaluations. 

14 It contains 124 separate sub-documents 

15 totaling 1369 pages. The document dates range from 

16 1989 to 2001. Seven of the documents only 

17 originated before 1992. It's a petrology request, 

18 a linoleum sample, an asbestos abatement, a ceiling 

19 tile analysis, another asbestos, building summary 

20 log.
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1 There are two airborne 

2 radio-particulate sampling data sheets contained 

3 from 1991. That is it. They are breathing zone 

4 samples taken for 20 minutes. That's it. Out of 

5 1300 pages, there are two sampling data sheets for 

6 two individual samples, and that's why I went and 

7 cited everything in my response so that you can go 

8 look it up. 

9 I give you page numbers, and if there is 

10 additional information, I'd be happy to look at it.

11 CHAIRMAN FIELD: So, Tom, since you 

12 haven't seen the response from Doug, would it be 

13 worthwhile at this point to go review that 

14 information?

15 MR. TOMES: Well, I have read it. I 

16 just haven't had time to try to go into the details 

17 and respond to that specifically, but I'm not sure 

18 that -- from the way that I look at the data, I --

19 from the way that I look at the site, there are two 

20 basically two operations at the site that have the 
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1 potential for airborne exposure that were rather 

2 significant, and that was the D&D work, and the 

3 other was the sample prep lab. 

4 The other activities at the site would 

5 be much less to nil, and as far as the D&D work, I 

6 do not know what D&D work was done in 1991, 

7 specifically that we may not have captured data for 

8 or if there was any going on in 1991, and the other 

9 issue would be, why don't we have any air sample data 

10 from the sample prep lab? And that I don't have an 

11 answer for it right at the present time, but I would 

12 have to look into that a little closer.

13 DR. NETON: This is Jim. It seems to me 

14 that there's a lot of documentation there that we 

15 just talked about for the 1991 timeframe, and I 

16 looked at this yesterday. There is RWP; there's 

17 RWP checklists; there's survey data. I just wonder 

18 if one goes through those in some detail, if you 

19 could get the sense that there wasn't any activity 

20 going on maybe that required air monitoring. 
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1 I mean, so you know, you've got to -- I 

2 think we need to go back and look at the source data 

3 again and look at it for what it's worth, which is, 

4 there's a lot of surveys, a lot of RWP-type things, 

5 and was there really activity ongoing that required 

6 air monitoring?

7 I know, for example, I think in the 

8 sample analysis lab, they did require air 

9 monitoring. They were typically low-level samples 

10 that were taken during D&D work at other sites, and 

11 they didn't rise to the level of needing to have any 

12 air monitoring data.

13 Outside of that, then you would have 

14 this sample prep laboratory, and I don't really know 

15 what went on there after a certain time period. 

16 They quit making those calibration pads that had 

17 high activity where grinding operations were 

18 conducted, so I think we really need to identify a 

19 little better as to what activities were there in 

20 '91 and not speculate that we should find this 
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1 treasure trove of air monitoring data to document 

2 exposures that might have not have occurred.

3 MEMBER ROESSLER: Wouldn't that be 

4 something that would be easy, fairly easy to answer 

5 by going back to one of the interviewees?

6 CHAIRMAN FIELD: Quite possibly.

7 DR. NETON: It might be helpful -- that 

8 would be helpful, I think.

9 MR. FARVER: This is Doug. You could 

10 always ask the internal dosimetrist at the time 

11 about the air sampling data or bioassay data if they 

12 knew anything about that, and I believe they are 

13 still both available. You could probably talk to 

14 them.

15 MEMBER ROESSLER: I was thinking more 

16 in terms of management level. That's not that not 

17 long ago really, and whoever was in management at 

18 that time should have a pretty good recollection of 

19 what activities were going on.

20 DR. BEHLING: This is Hans Behling. I 
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1 have just a generic question to anyone who has the 

2 ability to respond to this question.

3 Of the air sampling data that is 

4 available, or the data that are available, what kind 

5 of information, and I'm saying this in context with 

6 our recent review of the air sampling data 

7 associated with ANL-W, where we had air sampling 

8 data that showed exactly the location. It showed 

9 the exact time of the day when it was taken, the type 

10 of analysis that's done, the amount of air that was 

11 drawn through the sample filter paper that was the 

12 subsequently assessed.

13 What kind of information do we have 

14 available for the air sampling data that you do have 

15 available to yourself for analysis?

16 For instance, when Doug just mentioned 

17 that there were two BZA samples that were operating 

18 for 20 minutes, you know, drawing air samples -- air 

19 through the filter for such a low volume, twenty 

20 minutes is a joke to assess somebody's exposure, and 
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1 so I'm questioning in context of --

2 DR. NETON: They typically were four or 

3 five liters per minute, which -- it's not a joke. 

4 I mean it was a certain percent of the - you could 

5 definitely demonstrate it was less than 40 DAC hours 

6 from that kind of a sample.

7 DR. BEHLING: Well if you're trying to 

8 measure the air concentration at the DAC level, a 

9 few liters is -

10 DR. NETON: You're not trying measure 

11 the air concentration in relation to the DAC. 

12 You're trying to measure an intake, and an air 

13 sample - a breathing zone air sample samples air at 

14 about one-fifth the breathing rate of a human and 

15 so whenever picocuries are on that air sample, you 

16 multiply by five and that's your intake. That's a 

17 pretty good sensitive indicator.

18 You're not trying to measure percentage 

19 of the DAC. You're trying to measure intake.

20 DR. BEHLING: Okay, but when you're 
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1 talking about approximately 1.2 cubic meters per 

2 hour and you're talking about 20 minutes, you're 

3 talking about a little less than half of a cubic 

4 meter and at the concentration that you're trying 

5 to measure, is this a valid sample to assess 

6 somebody's intake?

7 DR. NETON: If the activity lasts 20 

8 minutes, I would say yes.

9 MR. SHARFI: Hello, we're not using the 

10 air samples to actually calculate exposure for this 

11 project. We're using the limit. We're just 

12 showing that they had a program that allowed them 

13 to make sure people didn't exceed the limit.

14 Air samples themselves are not being 

15 used individually to assess exposure. We are 

16 placing people at the limit.

17 DR. NETON: Well, Mutty, I would say if 

18 we had a person's BZ sample in their file, we would 

19 use that. 

20 MR. SHARFI: Yes, that's pretty rare. 
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1 Generally the air sampling data would be used if it 

2 exceeded the limit then to trigger bioassay and 

3 that's when you start to see some of the bioassay, 

4 and then generally these air samples don't trigger 

5 bioassay which means that the limit is probably 

6 their bounding scenario.

7 DR. NETON: Right, but knowing how 

8 breathing samples are taken, I would suspect that 

9 was a 20-minute operation because -

10 MR. SHARFI: Yes, no, I don't -

11 DR. NETON: You don't start a BZ sample 

12 and take it off halfway through a guy's work 

13 activity.

14 MR. SHARFI: Yes, and some of the D&D 

15 air samples are for multiple hours, so those are 

16 personal air samples, and in those cases we have 

17 time on/time off. We have first count, second 

18 count, sometimes third and fourth count results, 

19 description, room locations.

20 MR. TOMES: This is Tom. I'm looking 
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1 at some of the dozens of samples in the spreadsheet 

2 I have open and there are records of start time, stop 

3 time. Some of them are relatively short. Some of 

4 them are several hours, and detailed descriptions 

5 of where the work is going on.

6 MR. FARVER: That's fine, but that 

7 wasn't included in your response, that information. 

8 We're concerning 1991 timeframe because that's when 

9 you're setting your start date.

10 MR. TOMES: I was answering Hans' 

11 question there on the -

12 MR. FARVER: Okay.

13 MR. SHARFI: I mean are we saying like 

14 the air sampling program suddenly changed in 1991? 

15 I guess while I'm a little lost. I'm trying to 

16 answer your question. The question that the - I 

17 mean, the only thing that changes from pre-'91 to 

18 post-'91 is the limit that we're applying. We're 

19 not saying the air monitoring program changed. 

20 We're just saying they changed the limit at which 
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1 they implemented action. They moved from a 540 MAC 

2 hour per quarter to a 200 DAC hour per year limit.

3 That's the only thing that changed. 

4 It's not the air monitoring program itself changed.

5 MR. FARVER: I understand that, but 

6 what I'm saying is I didn't see any air samples from 

7 that time period that match up with what you're 

8 saying, that they actually did control it to these 

9 limits.

10 MR. SHARFI: I'm not going to say the 

11 SRDB -- since we didn't use the air samples to 

12 actually calculate intake rates and we're using 

13 limits. I'm not going to say that we've captured 

14 every air sample that the site ever created or, you 

15 know, analyzed. 

16 I mean, I guess that's possible that we 

17 just didn't capture every 1991 air sample and the 

18 site still has them.

19 MR. FARVER: I found two.

20 MR. SHARFI: I mean we looked at a lot 
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1 of the D&D work when we looked at the air sampling 

2 to help, so we looked at job - those D&D-specific 

3 ones and we captured those and they D&D'ed Building 

4 7 or they D&D'ed other buildings. We got those 

5 detailed reports and those include the air samples 

6 associated with the D&D work, whether it's from '96, 

7 '94 or earlier or later.

8 DR. NETON: This is Jim. We talked 

9 about those 1991 - that report that had all kinds 

10 of thousands of pages in it. 

11 Did you think it - does it appear to be 

12 substantial that it might have included all the RWPs 

13 that were issued in 1991 or all of the work 

14 activities?

15 MR. SHARFI: Is it a - for a D&D 

16 operation, I cannot imagine that 1400 pages is 

17 everything, no.

18 I mean I know when I've been involved in 

19 D&D work, the number of pages of data that just go 

20 to maintain a single building over a course of one 
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1 year and this covers a little bit more than not just 

2 1991. I mean I don't imagine there is thousands of 

3 more pages associated with surveys and -

4 DR. NETON: It sounds like Building 7 

5 was being D&D'ed in 1991. Is that right?

6 MR. SHARFI: I'd have to look at the 

7 start year for Building 7. That might have been 

8 around when they started it.

9 MR. TOMES: I believe there may have 

10 been some investigation. I don't believe it was a 

11 complete -

12 MR. SHARFI: It was in the 1990s when 

13 they started the work in 7 and then I think it took 

14 multiple years before they actually fully - because 

15 I mean I want to say the stuff moved from - the 

16 sampling prep room eventually moved and I think it 

17 was finally closed down in 2000 - and that was for 

18 the Building 7.

19 DR. NETON: I mean I'm looking at the 

20 bioassay logs that we have in the ER on Page 19, so 
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1 it covers 1991 and I didn't add these up, but it 

2 looks to me like there's five or six hundred 

3 bioassay samples taken in 1991 which kind of doesn't 

4 comport with only two air samples. That's what's 

5 sort of interesting here. I'm not sure why - so 

6 clearly they were collecting bioassay samples quite 

7 a bit in 1991. I mean, there's not minimal samples 

8 here, but as I say, I didn't add them up. It looks 

9 like 500 or so.

10 MR. SHARFI: I don't believe that we've 

11 attempted to - since we're not using the air samples 

12 as dose of record, I just don't think we've 

13 attempted to capture every air sample, and I mean 

14 if you look at the way they did air sampling, it 

15 seems that there should be a ton of available data; 

16 we just didn't need it to do this assessment and to 

17 go and capture tens of thousands of pages - I mean 

18 of air samples. I mean every air sample takes 

19 usually multiple page. 

20 I mean there's the - without it being in 
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1 a database form, it can become very cumbersome to 

2 - so that's why the limits were established that -

3 and as you said, there is plenty of bioassay after 

4 that, so it does look like they implemented a DAC 

5 hour tracking program and when people exceeded it, 

6 they initiated bioassays, so for those people that 

7 exceeded it, bioassay would be available to assess 

8 those larger exposures.

9 Anybody under that would receive the 

10 limit.

11 CHAIRMAN FIELD: So, Doug, it sounds 

12 like there's a layer of information, perhaps worker 

13 interview possibilities. What information do you 

14 think is required yet to address your finding?

15 MR. FARVER: Well, the finding - the 

16 specific finding was that the workplace air 

17 monitoring data do not support the assumption that 

18 unmonitored radiation workers could not have 

19 exceeded 200 DAC hours, so that was - the finding 

20 was the workplace air monitoring data does not 
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1 support that, so I think at the time that they would 

2 say, oh, okay, well here's the workplace air 

3 monitoring data that supports that, and they cited 

4 I believe it was ten documents, over 6,000 pages and 

5 still after going through that it did not - there 

6 was no workplace air monitoring data that supported 

7 their assertion, so I mean it still comes back to 

8 the original findings.

9 Now I didn't look at all the bioassay 

10 data and evaluate the bioassay data because that 

11 wasn't the finding.

12 CHAIRMAN FIELD: Okay.

13 MR. FARVER: I mean I would think that 

14 if they've got a good program in place there should 

15 be some air sample results from that time period, 

16 and then that's really what I was looking for is the 

17 air sample results.

18 MEMBER ROESSLER: The question is only 

19 for the year '91. Is that right?

20 MR. FARVER: Well that's when they're 
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1 saying that they were going to use that as their 

2 start point for using a different method to bound 

3 the internal doses.

4 Now I'm making a big point of this 

5 because if you go back to the original SEC and you 

6 look at their dose reconstruction template, I 

7 believe they use a completely different method for 

8 bounding the intakes for this time period, and now 

9 they're - I believe they are proposing that they 

10 change the method they use to bound these intakes.

11 MR. SHARFI: Doug, we're not changing 

12 the method, we're just changing the limit. It's 

13 still based on an air sample concentration or a MAC 

14 hour to a DAC hour and then they just changed the 

15 terminology, but it's a MAC hour limit versus a DAC 

16 hour limit, but the approach is still the identical 

17 approach. It's just a different limit. 

18 The method is no different between 

19 pre-'91 and post-'91.

20 MR. FARVER: See, this is part of the 
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1 problem because there is not a technical basis. I 

2 cannot see how you're going to implement this in 

3 your DR template.

4 DR. NETON: The DR template is 

5 available in the dose reconstructions, and it uses 

6 the ten percent of the MPC basically, 4200 DAC 

7 hours. That's what's in there, and it assumes 

8 5480.11 compliance after 1990. But 1991 and 

9 beyond.

10 MR. FARVER: And I believe that is 

11 different than what is in the current DR template.

12 DR. NETON: No, I just looked at the 

13 current DR template an hour ago and that's what it 

14 says.

15 MR. FARVER: Is that the same template 

16 that Hans reviewed back for PER 47?

17 DR. NETON: I don't know.

18 MR. FARVER: Okay. 

19 DR. NETON: The template that I looked 

20 at was issued, I think, in 2015.
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1 MR. SHARFI: It would have been issued 

2 with the ER, the revised ER.

3 DR. NETON: Right, so it was in 

4 September of 2015 which is written after the revised 

5 - the addendum came out in March - or May of 2016.

6 MR. FARVER: It came out in May.

7 DR. NETON: The addendum came out I 

8 think in March.

9 MR. FARVER: March, March of 2015.

10 DR. NETON: March in 2015, and the 

11 template was revised in September of 2015, and it 

12 comports with what we're saying here after 1991, so 

13 it's the same logic.

14 MR. FARVER: It is, but it's different 

15 than the previous one.

16 DR. NETON: Well, yes, because we 

17 changed - we realized after looking at the data and 

18 the ER that we were making it to conform with the 

19 ER.

20 MR. FARVER: Right, and you say looking 
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1 at the data, and that's what I'm asking for the data 

2 and the air sampling data and the workplace data and 

3 for 1991 when you want to make this change and I did 

4 not find it.

5 CHAIRMAN FIELD: So, Tom, you were 

6 saying before that there is a bunch of air 

7 monitoring data for that time period. Is that 

8 correct?

9 MR. TOMES: Well, I think maybe 

10 specifically Doug is referring to 1991, and I do 

11 know that overall, over a period of the D&D period 

12 through the '90s we have hundreds of air samples, 

13 so I think Doug was saying that he did not find any 

14 for specifically for 1991.

15 MR. FARVER: l990, '91, something in 

16 that timeframe that would support that date because 

17 you are changing your method from the previous DR 

18 template, and my point is that, unless you can 

19 support that, then you probably shouldn't be 

20 changing your method from your previous template 
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1 until you can get to a time point like maybe '95, 

2 '96 when you have the data to support going to the 

3 ten percent of a DAC.

4 MR. TOMES: So you're questioning where 

5 they implemented a control to dose levels?

6 MR. FARVER: I'm questioning whether 

7 you have the data to support that they did it for 

8 that time period as a justification for changing the 

9 method that you found would bound your intake.

10 MR. SHARFI: Are we asking if we can 

11 prove they implemented their TBD that they issued 

12 in '91?

13 MR. FARVER: Yes, if there's data to 

14 support that they implemented their air sampling 

15 program and that's what the air sampling results 

16 would do, I believe.

17 MR. TOMES: If I understand correctly, 

18 what you're saying is that you're not necessarily 

19 questioning whether they implemented, you're 

20 questioning that we have not provided evidence that 
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1 in 1991 they were air - they were monitoring workers 

2 that needed to be monitored. Is that correct?

3 MR. FARVER: Yes. They may have 

4 implemented it but I don't believe you provided 

5 evidence to support that, or they may not have 

6 implemented it.

7 MR. SHARFI: Are we saying they didn't 

8 do air sampling or that they didn't control a limit 

9 at what they said they were going to do? Is it the 

10 limit or is it the actual fact that they did air 

11 sampling? Which one are you talking about, Doug?

12 MR. FARVER: Well, if we assume that 

13 they followed the 5480.11 limits, then they would 

14 have air samples and some kind of programmatic other 

15 than their TBD documentation to show that, yes, this 

16 is what they did. Maybe there would be some report 

17 that says these samples were greater than, you know, 

18 ten percent of a DAC and therefore we monitored 

19 these people. Anything like that.

20 DR. BEHLING: This is Hans. Again, I'm 
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1 going back to the ANL-W, and that's exactly what 

2 happened there where we have actual data, air 

3 monitoring data, from general area air sampling 

4 data and they assess the air for gross output and 

5 they establish the ten percent MPC level and showed 

6 that for, a given location, that these were the 

7 values that would allow you to conclude that a 

8 person did not exceed ten percent of MPC values, and 

9 I guess this is what Doug is hopefully looking to 

10 obtain to verify that the 200 DAC hours could have 

11 been implemented based on the available air 

12 monitoring data that would suggest that it was in 

13 fact done.

14 MR. TOMES: This is Tom. I think for me 

15 I cannot provide an answer on 1991 without going 

16 back and trying to find more information to see what 

17 was being done specifically in 1991, why we don't 

18 have air sample data to show they were monitoring 

19 areas in 1991 which Dr. Neton referred to a while 

20 ago. 
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1 I - we may find there was very little 

2 work going on in '91 or we may find that we don't 

3 have all the samples. I don't know which that is.

4 CHAIRMAN FIELD: I think at this point 

5 either would be helpful and probably go a long way 

6 to answering Doug's questions. Am I speaking 

7 accurately for you, Doug?

8 MR. FARVER: Yes. I'm just looking for 

9 something from the time period because the RWPs that 

10 were cited were from, I think, 2001, and years that 

11 really weren't applicable, so all I'm looking for 

12 is some kind of data from that time period that goes 

13 to show that, yes, they had a good program in place, 

14 and I'm saying if they can't provide that, then 

15 maybe they need to change their time period to 

16 accommodate the data that they do have.

17 MR. TOMES: Well, I have one more - this 

18 is Tom. I'd like to add one thing to that, Doug.

19 I pulled open a spreadsheet a while ago, 

20 and it's just a summary of some of the results, and 
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1 I do know there are a lot of air sample data in '94, 

2 '95, '96, so there are a lot of air samples before 

3 2001 where every year you said there's a lot of 

4 those, but I did not - in the one sheet I opened, 

5 I did not find anything except two results for '91 

6 which is what you mentioned, however, this is just 

7 one spreadsheet I had, but there are lots of results 

8 for the '90s in general.

9 MR. FARVER: And it may be that they did 

10 not get it fully implemented until '94. I don't 

11 know. I know there are other sites across the 

12 complex that claimed exemptions for technological 

13 shortfalls because they could not implement it 

14 before a certain time, so there was technological 

15 problems. There were money issues during that time 

16 period. If you need to get a bunch of fixed head 

17 air samplers in, well that costs a lot of money on 

18 a budget. Who's going to pay for it? So there were 

19 a lot of issues in place going on to try and 

20 implement this new DOE order. This was a change to 
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1 how DOE had been doing business before, and that's 

2 why I'm saying. They may not have implemented it 

3 at the beginning of 1991 or they may have but 

4 something should be provided to show that, if they 

5 did.

6 Now is you have lots of documentation 

7 from 1994, well, maybe that's the date you should 

8 go with.

9 MR. STIVER: Doug, this is Stiver. 

10 Something else that's kind of interesting is 1994 

11 is when 10 CFR 835 was implemented, so there could 

12 very well be a period from '91 to '94 in those few 

13 years when, you know, you say across the complex 

14 you see this that there's programs being 

15 proceduralized and then the implementation takes a 

16 bit longer sometimes.

17 MR. FARVER: I know there was a lot of 

18 difficulties with thorium air monitoring.

19 DR. NETON: So this is thorium-230 

20 which is a little different than thorium-232.
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1 MR. FARVER: Okay. What would - can 

2 Mutty tell me what the number of that SRDB number 

3 that he was talking about that had some 1991 

4 information? 

5 MR. SHARFI: 93816, I believe?

6 MR. TOMES: Yes.

7 MR. FARVER: That sounds right.

8 DR. NETON: Because I looked through 

9 some of these things and I recall - I don't disagree 

10 that, you know, we need to flesh this out better on 

11 our end. I'll state that, but I recall going 

12 through this and there's a lot of information such 

13 as there were requests for sample - follow-up 

14 samples because you entered - a person entered an 

15 airborne activity area and there were tracking logs 

16 and sample receipt dates, sample ship date, all that 

17 kind of good stuff, so - I don't know. 

18 It just seems like there's such a lot of 

19 information and why - it is puzzling. I will agree 

20 - why there's only two air samples in 1991. 
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1 But I'd be surprised if it took them four 

2 years to implement this, but I agree. I think we 

3 need to go back and flesh this out a little better.

4 MR. FARVER: And if there are specific 

5 sub-documents in that document, I'd be happy to look 

6 at them. I just - I looked through it as best I 

7 could, and a lot of the dates were from the mid-'90s 

8 up through 2001, it looks like.

9 MR. SHARFI: During the D&D period, 

10 yes, and that's the prime D&D period.

11 MR. FARVER: Right.

12 MR. SHARFI: Which is what we were -

13 when we look for air sampling data, we looked for 

14 air sampling data associated with the D&D effort not 

15 across the entire site for every year, and like I 

16 said, that to me is likely where it is.

17 The TBD didn't indicate that we will in 

18 the future implement this. It was - the TBD said 

19 we are implementing it, and I don't - I can't see 

20 a site ever putting in a TBD implement now but don't
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1 actually follow the procedure.

2 MR. FARVER: I think you better go back 

3 and look at the TBD. It says we shall, we will.

4 MR. SHARFI: Shall is pretty straight 

5 up. I mean shall is you have to do it.

6 MR. FARVER: Shall is just a quote from 

7 the DOE order.

8 DR. NETON: We'll go back and revisit 

9 this and flesh it out to the extent we can and if 

10 we need to get more information, we'll have to make 

11 a determination whether it's worth how many extra 

12 man-hours and resources to capture this versus not 

13 doing it.

14 MR. FARVER: I mean when you look at the 

15 Geotech Technical Basis it says air monitoring 

16 shall be the primary method for monitoring the 

17 workplace in 1990, so, okay.

18 DR. NETON: When there's a potential 

19 for airborne activity, that's true.

20 MR. FARVER: Okay. 
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1 DR. NETON: You don't monitor clean 

2 areas or areas where there's not much 

3 contamination. We'll look at it. I hear what's 

4 being said here.

5 CHAIRMAN FIELD: So Loretta or Gen, it 

6 sound like we're going to move forward and NIOSH is 

7 going to look at this in more detail. Did you have 

8 any other questions?

9 MEMBER ROESSLER: I don't have any 

10 other questions. I guess we leave the whole - there 

11 seemed like there were two areas to discuss for the 

12 Work Group, the appropriateness of the revised SEC 

13 time period and then the appropriateness of the air 

14 monitoring and bioassay data. We're going to just 

15 leave everything until the next meeting then?

16 CHAIRMAN FIELD: I think that makes 

17 sense. I think there's still possibly both up in 

18 the air a little bit.

19 MEMBER ROESSLER: Okay.

20 DR. NETON: Well, the appropriateness 
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1 of adding a Class to '85 is already a done deal. I 

2 mean that's already been added.

3 MEMBER ROESSLER: Okay. Okay.

4 DR. NETON: This is not open for 

5 discussion at this point.

6 MEMBER ROESSLER: Okay.

7 DR. NETON: I believe both those 

8 Classes have been added already. The idea was we 

9 suggested adding up to '85. The Board agreed. It 

10 was added, and then the Board recommended that SC&A 

11 look and see if '85 was the right stopping point, 

12 and that's what we're discussing now.

13 MR. KATZ: That's right.

14 DR. NETON: So it's good to hear that 

15 SC&A agrees that what we've added makes sense, and 

16 what the Board added, but it shouldn't be open for 

17 discussion anymore at this point.

18 MEMBER ROESSLER: Right. I have no 

19 further comment.

20 CHAIRMAN FIELD: Okay.
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1 MEMBER VALERIO: I don't have any other 

2 questions or comments.

3 CHAIRMAN FIELD: So I think that wraps 

4 up that aspect of what we wanted to discuss. So, 

5 Ted, at this point, do we ask for petitioner 

6 comments or - I don't think there is anyone on the 

7 line, but just in case?

8 Petitioner Comments

9 MR. KATZ: Yes, I think - do we have the 

10 petitioner the phone? We're not expecting the 

11 petitioner because Josh reached out and that's what 

12 he indicated to me; we didn't expect them. Is the 

13 petitioner on the line? Okay, so anyway, we just 

14 want to leave that out in the open, but, yes.

15 So, Jim, what are you thinking, Jim, 

16 Tom, about a timeline for getting back that maybe 

17 we can reconvene and discuss further?

18 Path Forward and or Plans for November Board Session

19 DR. NETON: This is Jim. I don't think 

20 it's going to be before the Board meeting in 
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1 November to be honest. This could take a while, 

2 especially if it would require going back to 

3 interview a few people and maybe trying to find out 

4 if we really need to collect more samples, but I 

5 think - we're in, what, early October now? It's 

6 possible, maybe before the Board meeting, but not 

7 much before. That's my thought.

8 CHAIRMAN FIELD: Okay, so at this point 

9 do we have any other things to discuss, any other 

10 items? It seems like we're sort of on hold for 

11 getting that information at this point.

12 MR. KATZ: Right. I agree, Bill. So 

13 we can just report out at the November Board 

14 meeting, assuming that things don't get done sooner 

15 unexpectedly, that this is in progress, and that's 

16 it. You can do that during the work session.

17 CHAIRMAN FIELD: That sounds good.

18 MR. KATZ: We won't need a session for 

19 this SEC specifically.

20 Path Forward for Resolution of Site Profile Issues from 

21 SC&A Review of Program
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1 DR. BEHLING: This is Hans Behling, and 

2 I'm wondering if I'm a little out of line here, but 

3 with regard to PER-47, Finding Number 3 was left 

4 open during the discussion that took place back in 

5 April 28, 2015, at which time I went through the 

6 transcript and Jim Neton was going to look at the 

7 issue involving the 569 data - air sample data 

8 values that were potentially available for use in 

9 dose reconstruction as stated in the template. 

10 If Jim is still on the line, can you 

11 comment on where we are, if that was ever resolved. 

12 That is Item - Finding Number 3.

13 DR. NETON: No, that's not been - it's 

14 not been formally resolved. That would be handled 

15 through the Procedures Subcommittee process, and my 

16 - I just saw some email traffic this morning that's 

17 on the agenda. It's going to be put on the agenda 

18 for the upcoming Procedures Subcommittee meeting. 

19 I think that may convene sometime in November.

20 DR. BEHLING: Okay.
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1 DR. NETON: But we're really talking 

2 about this, these 569 air samples are exactly the 

3 air samples we were just talking about.

4 DR. BEHLING: Yes.

5 CHAIRMAN FIELD: Those are the D&D air 

6 samples.

7 DR. BEHLING: Exactly, and that's why I 

8 was wondering if there was any available 

9 information to clear that finding off the record.

10 DR. NETON: Well, I have to talk to Dave 

11 Allen about this, but we will be prepared to discuss 

12 this at the Procedures Subcommittee meeting.

13 DR. BEHLING: Okay.

14 DR. NETON: I mean the air samples have 

15 been put in a database. They have been categorized 

16 using a log-normal distribution.

17 I think the finding was - it's my 

18 recollection that the nature of that finding was not 

19 that the 569 air samples were in question; it was 

20 that it was sort of inferred in the template that 
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1 the dosimetrist would go back and look at the 569 

2 and come up with an intake.

3 DR. BEHLING: Yes, exactly, Jim. I 

4 didn't question the validity or existence of these 

5 except that I was questioning the need for dose 

6 reconstructor to analyze data for himself, and I 

7 believe they were located in very different SRDB 

8 documents that would make it very, very difficult 

9 for a dose reconstructor to take it upon himself to 

10 do this.

11 DR. NETON: That's right, and I don't 

12 know that the template I looked at this morning 

13 addresses that, but the resolution of that finding 

14 is to be more specific and use the - prescribe the 

15 values that are based out of those - that air sample 

16 database whether it be the 50th or the 95th 

17 percentiles.

18 DR. BEHLING: Exactly, exactly.

19 DR. NETON: I honestly don't remember 

20 if that's in there or not, but that could be resolved 
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1 pretty easily at the November Subcommittee meeting 

2 by just going through that and either committing to 

3 change the template or that we already have. I'm 

4 not sure that we haven't.

5 MR. TOMES: This is Tom. I believe our 

6 template has those values in there.

7 DR. NETON: Okay. If the template has 

8 those values in there, then we can offer that as the 

9 closure of that finding and it can be reviewed and 

10 evaluated. People can look at it and see if they 

11 agree with us.

12 MR. KATZ: Can you just lead Hans then 

13 to look at that template so that that will be - he'll 

14 be prepared to -

15 DR. NETON: Sure.

16 MR. KATZ: Thanks.

17 DR. NETON: That will come out when -

18 we'll put that in the Board tracking system.

19 MR. KATZ: Right, right. Board 

20 Review System. Thanks.
This transcript of the Advisory Board on Radiation and Worker Health, Grand Junction Facilities Work 

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1 DR. NETON: Yes, and that template will 

2 be put out there and that will be part of the closure 

3 process.

4 MR. KATZ: That sounds good.

5 DR. NETON: Very good. Yes, thanks for 

6 reminding me of that, Hans. I had forgotten 

7 completely about that, but I knew we had done 

8 something on it.

9 DR. BEHLING: Yes, the only reason I was 

10 even made aware of it was in preparation of today's 

11 meeting where I went back and looked at what we did 

12 under PER-47. I realized that was still an 

13 outstanding issue.

14 DR. NETON: Right. Of course, how we 

15 end up using these 569 air samples is still sort of 

16 subject to some discussion here, but if that 

17 changed, then of course we would revise the template 

18 again and the PER would be issued. Hopefully that 

19 won't - well, we'll see what happens.

20 DR. BEHLING: Okay.
This transcript of the Advisory Board on Radiation and Worker Health, Grand Junction Facilities Work 

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

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1 CHAIRMAN FIELD: So, Ted, as far as I 

2 think our items for today, I think we have them 

3 pretty much covered. I mean there were two 

4 concerns, but I think we can keep those concerns in 

5 mind as we move toward our next meeting and 

6 discussions for our next meeting and hopefully wrap 

7 things up at that time.

8 MR. KATZ: Yes, I agree, so I'll - we 

9 can't reschedule another meeting until we have a 

10 sense of when the NIOSH folks will be ready, but 

11 we'll do that online by email.

12 CHAIRMAN FIELD: At least we made 

13 progress on this. It was good to have our first 

14 meeting on this issue and we have a plan forward, 

15 so I think that's all good.

16 MR. KATZ: Yes, I think that's good, 

17 too.

18 DR. NETON: Sounds good.

19 MR. KATZ: Okay then. Well, Bill, I 

20 think then we can adjourn, right?
This transcript of the Advisory Board on Radiation and Worker Health, Grand Junction Facilities Work 

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

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1 CHAIRMAN FIELD: Sounds good.

2 MR. KATZ: And thanks, everybody, for 

3 your work and have a good rest of your week.

4 CHAIRMAN FIELD: You too.

5 MR. KATZ: Take care.

6 Adjourn

7 (Whereupon, the above-entitled matter 

8 was concluded at 11:27 a.m.)

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