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 

DAY THREE 

The verbatim transcript of the Meeting of the 

Advisory Board on Radiation and Worker Health held 

at the NIOSH, Cincinnati, Ohio, on June 2, 2005. 
 

2 

C O N T E N T S 

June 2, 2005 

TASK 1, MALLINCKRODT SITE PROFILE REVIEW

NIOSH/ORAU

ARJUN MAKHIJANI, SC&A

HANS BEHLING, SC&A 
3 

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. 

In the following transcript (off microphone) 

refers to microphone malfunction or speaker's neglect 

to depress "on" button. 
 

4

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

ABRWH MEMBER: 

GRIFFON, Mark A.

President 

Creative Pollution Solutions, Inc.

Salem, New Hampshire 

OTHER ATTENDEES: 

DR. HANS BEHLING, SC&A

MS. CINDY BLOOM, ORAU

MR. GREG MACIEVIC, NIOSH

DR. ARJUN MAKHIJANI, SC&A

DR. JIM NETON, NIOSH 

STAFF/VENDORS 

STEVEN RAY GREEN, Certified Merit Court Reporter 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

5

 P R O C E E D I N G S

 (9:00 a.m.) 

DR. NETON: Okay. We're ready to start. Oh, let me 

bring Mark Griffon -- I just hung up on Mark. Hang 

on. 

(Pause) 

DR. NETON: Okay. We're ready to go then. Mark 

Griffon is -- is participating via -- via telephone 

connection and today we've got Cindy Bloom and Hans, 

Arjun, myself, and -- and Greg Macievic. Where we 

left off yesterday was we were now going to get into 

the external dosimetry questions that SC&A had, so I 

guess I'll turn it over to Arjun and he can start 

the questioning. 

DR. MAKHIJANI: Yeah. Hans, should I -- should I 

just go through the questions --

DR. BEHLING: Yeah, yeah, yeah. 

DR. MAKHIJANI: -- and then maybe you take over the 

discussion --

DR. BEHLING: Well, we'll -- we'll -- yeah, I have 

some questions here. I haven't even looked at the 

questions you submitted but --

DR. MAKHIJANI: Okay. Should I run through my 

questions first --

DR. BEHLING: Yeah. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

6 

DR. MAKHIJANI: -- and then you can run through 

yours? Should we do it that way --

DR. BEHLING: Yeah. 

DR. MAKHIJANI: -- since they -- they have it in 

writing already? Okay. I'll just read the question 

so it's in the record. 

What proportion of employees have no external 

monitoring data? 

DR. NETON: Right. This is -- this is similar to 

what we discussed yesterday for the internal. We 

don't have the answer at this point but we'll 

certainly try to get that fleshed out soon, 

hopefully well advance of the board meeting. 

DR. BEHLING: Is there any indication to whether or 

not people were cohort badged or badged on the basis 

of likely to be exposed? And there's a difference 

obviously. 

DR. NETON: It's -- it's -- exactly. It's our --

the indications that I have from looking at the 

files are that people were individually badged. And 

in fact I think there's a memo we can point to in 

'49 that indicated that the badge was actually part 

-- that the film badge was part of the security 

credentials. 

DR. BEHLING: Okay. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

7 

DR. NETON: And I guess I -- we do know a little 

more than what I just indicated about percentages 

that were monitored. If one looks at the SEC 

evaluation report, there is a table on page 17 -- I 

don't have copies to distribute -- that indicates by 

year the approximate total number of employees at 

the site during that year, and this is based on the 

-- the epi study that was done by the Center for 

Epidemiological Research, which -- in traditional 

epi style they -- they only looked at white males. 

But we believe that's it's a good indication of the 

magnitude of the workforce at that time. 

And then we have a listing of the number of 

employees who were monitored during that year. And 

for external monitoring after '49, the numbers 

appear to be well over the majority. In 1949 we 

have 506 employees monitored out of an estimated 

workforce of 676 and it appears that the percentages 

go up from there. And in the last year, you have 

virtually -- well, 90-plus percent of the workers 

being monitored, so a very large -- large percentage 

of the workers had film badges --

DR. BEHLING: So you --

DR. NETON: -- after 1948. 

DR. BEHLING: Yeah, the majority of people were 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

8 

likely to have some radiation dosimetry records. 

Now --

DR. NETON: Now -- now the other question which is 

more relevant, do we have the --

DR. BEHLING: The records. That's true. 

DR. NETON: -- records. Now I have looked through a 

sampling of the records and it seems to be that the 

majority of the people have some records, but I 

don't know if that tracks with this table. Now I'm 

assuming -- and we need to do a little homework here 

-- that this information came from somewhere and 

presumably it has to do with the records that we 

have. But again, I have not, you know, followed 

this thread all the way through. But a very, very 

large percentage of the workers have monitors --

were monitored in those time -- in that time period. 

DR. MAKHIJANI: Now, Jim, when you say 90 percent do 

you mean 90 percent of all the workers in the AEC 

area or 90 percent of the production workers? 

DR. NETON: Oh, I would assume it's AEC area. I 

mean is that -- Mallinckrodt of course was a 

chemical factory and I -- there'd be no reason to 

monitor workers who were working with chemicals. 

DR. MAKHIJANI: I misstated my question. I meant 90 

percent of the production workers in the AEC area or 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

9 

90 percent of all workers in the AEC area? 

DR. NETON: This -- well, I would say this is 90 

percent of all white male workers in the AEC area, 

not just production workers. Those other ten 

percent then would presumably be people such as 

clerical folks and --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- and such. 

DR. MAKHIJANI: Of course a lot of the clerical 

folks were women. 

DR. NETON: Right. 

DR. MAKHIJANI: So that would not fall in this 90 

percent. 

DR. NETON: That's correct. In fact, those women 

would not be represented in this total number of 

employees value because, again, this was a -- this 

was taken from an epi study and they typically only 

-- for statistics purposes pick all white male 

workers at the facility to get the large bulk of the 

population. But, you know, we will -- we will go 

through and look at the individual cases that we 

have, because as I indicated before, I believe we 

only have about a 130 or so cases that -- that 

initiated employment between 1949 and 1957 currently 

in our possession. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

10 

DR. MAKHIJANI: Yeah. In -- in the context of this 

men/women thing, I -- I interviewed a -- a woman 

employee in whose records I found two urinalysis 

samples. And she was a clerical employee, so I kind 

of found that a little odd because I did not find --

they were low, in the two micrograms per liter 

range, so they --

DR. NETON: (Unintelligible) limit of detection --

DR. MAKHIJANI: -- not within the detection limits, 

so one doesn't know what to make of that. But I 

wondered why there would be urinalysis samples in a 

clerical worker's --

 MS. BLOOM: We found at some sites that 

stenographers frequently followed people into areas 

to take dictation while somebody was doing a report. 

That was in the records at Windy* we saw that. 

DR. NETON: And I -- I don't --

 MS. BLOOM: They also might have taken them as 

blanks if they wanted to see, you know, what -- what 

are other people looking like. It's hard to say. 

DR. NETON: And also, I don't know what time frame 

this was or what, but I know for instance at the 

Fernald site not all workers were monitored, but 

everyone when they started a new hire, 

(unintelligible) that's part of the physical, have a 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

11 

urine sample. And actually every year part of the 

annual physical was a urine sample, whether you 

worked in the plant or not. 

 MS. BLOOM: And that could have been true, the 

initial and termination samples there. 

DR. NETON: I -- I don't know. We do have to look 

at the specific case --

DR. MAKHIJANI: Yeah. 

 MS. BLOOM: (Unintelligible) 

DR. NETON: -- and if you've got a number I'd be 

interested in --

DR. MAKHIJANI: I'll try to bring it up later. I 

think I have it in my notes. Maybe not. The -- I 

looked at the medical records sections in some of 

those large DOE files, and there wasn't a column for 

-- so they have routine medical type of urinalysis, 

whatever they do in the medical side --

DR. NETON: Right. 

DR. MAKHIJANI: -- but there wasn't a column in the 

form for uranium. 

DR. NETON: That -- that would not normally show up 

in the medical form itself. 

DR. MAKHIJANI: It would not show up --

DR. NETON: It would be -- like I know at Fernald, I 

don't know that this holds true at Weldon Springs, 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

12 

but -- or Mallinckrodt, but they would just split 

the sample and half would go down to the bioassay 

laboratory and, you know, we would analyze it and 

then keep it in the dosimetry record file. Now 

early on, though, some of the medical files had 

dosimetry records but they weren't typically on the 

same form. 

DR. MAKHIJANI: Okay. 

DR. NETON: Physicians -- physicians really didn't 

know what to do with it. 

 MS. BLOOM: I would say they might not even be the 

sample at some of these sites --

DR. NETON: Yeah. 

 MS. BLOOM: -- that you'd collect the urine during a 

physical --

DR. BEHLING: I mean (unintelligible) --

 MS. BLOOM: -- (unintelligible) you'd take the --

DR. NETON: (Unintelligible) 

DR. BEHLING: -- pre-employment requisite which 

obviously would preclude the need for doing 

urinalysis for isotopes, so it's not likely to be a 

split sample. 

 MS. BLOOM: Uh-huh. 

DR. BEHLING: I mean it's -- as part of your 

employment that you submit to a physical, that 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

13 

includes a urinalysis but there would be no reason 

to at this point assess you for internal exposure --

 MS. BLOOM: Sometimes they did baselines --

DR. NETON: Oh, yeah. Baseline --

DR. BEHLING: Baseline? 

 MS. BLOOM: Yeah. 

DR. NETON: -- workers coming in, sure. I mean 

there's -- there's issues -- and I don't know how up 

these people were back then, but -- but people 

coming in who have well water that has high uranium 

values or for whatever reason would show positive, 

you'd like to know that up front. 

DR. BEHLING: Yeah, well, I know in contemporary 

times you use baseline --

DR. NETON: And I don't know exactly what --

DR. BEHLING: -- but in those days I'm sure they 

were concerned --

DR. NETON: And I don't know that this is even part 

of the medical. We -- I'd like to look at the file. 

DR. MAKHIJANI: Yeah. I -- I'll -- I'll -- during a 

break I'll just come up with a name. Maybe we can 

pull up the (unintelligible). 

DR. NETON: That's fine. 

DR. MAKHIJANI: Okay. Hans, any other follow-up on 

the number of records question? Okay. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

14 

Next question is are there claims where zeroes were 

entered into the records but no monitoring was done 

and no back records exist? 

DR. NETON: I guess I'd like to get a little more 

clarity on this. We've talked among ourselves about 

this and there is a -- and I know Mark I think has 

brought this up, where zeroes were entered in lieu 

of no monitoring. I -- I'm not that familiar with 

this issue. Mark, can you --

MR. GRIFFON: Oh, I don't -- I -- I'm trying to 

remember exactly how -- it -- it was actually 

brought up by one of the -- the petitioners, I 

believe, initially. 

DR. NETON: Right. That's true. That was in the 

evaluation report. 

MR. GRIFFON: Yeah. And I -- I've just been 

following up on it as to whether we've resolved 

anything on that because I think they're going to 

raise it again. But the question of -- of, you 

know, sort of putting zeroes in for entries that --

DR. NETON: Right. See --

MR. GRIFFON: -- there was actually some question of 

whether they were actually putting zeroes in for 

values that -- that were a positive value. 

DR. NETON: Well, see that's what I was going to 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

15 

raise is I don't know that we have any indication 

that that happened. 

MR. GRIFFON: Right, right. 

DR. NETON: I think they're -- you're right. Now 

you refreshed my memory, there were assertions by 

petitioners that if a person weren't monitored, they 

would put zeroes in there. And I -- we've discussed 

this with Janet and she's not, as far as I can 

recall, aware of this happening. But we don't have 

any more to answer. This is sort of proving a 

negative-type situation. 

MR. GRIFFON: Right. I don't know how -- yeah, how 

do you prove it, that's --

DR. NETON: Right. 

MR. GRIFFON: -- the problem I think. 

DR. NETON: And I guess the worst case I could --if 

-- if we -- accept the fact that that happened and 

they -- and we can -- we can hopefully get 

comfortable that they didn't take high values and 

make them zeroes, and maybe that's part of this 

validation thing I'm trying to do. But if they 

entered zeroes where there was no monitoring, what 

could conceivably happen is we would --

DR. BEHLING: Assign dose --

DR. NETON: -- compute missed dose --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

16 

DR. BEHLING: Yeah, because there was no dose. 

DR. NETON: -- well, but -- but worse I think --

MR. GRIFFON: Well, they were unmonitored --

DR. NETON: If they were unmonitored we would assign 

missed dose versus unmonitored dose, and that --

MR. GRIFFON: Right. 

DR. NETON: -- that would -- I suspect could make a 

difference, albeit this would be on the low end of 

the -- of the dose reconstruction spectrum, but --

and honestly I'm not sure how we would deal with 

that. If -- if we could find evidence that it 

happened, we'd have to deal with it somehow. This I 

guess is not unlike the situation where people are 

saying well, I had a badge but I never wore it, 

because then that's, you know, monitored dose --

unmonitored dose when we're assigning zero missed 

dose. 

MR. GRIFFON: But I don't know if there's any kind 

of -- of record that you have that show who was 

assigned dosimetry. I don't think you've seen those 

kind of records, have you? I mean you just have the 

cards with their film data --

DR. NETON: Right. 

 MR. GRIFFON: -- you don't have -- yeah. 

DR. NETON: Yeah, and if there's a zero in there --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

17 

MR. GRIFFON: Right. 

DR. NETON: -- it would normally be concluded by us 

that, well --

MR. GRIFFON: That they (unintelligible) --

DR. NETON: -- that particular person wore the 

badge. 

MR. GRIFFON: -- dosimeter. Yeah. 

DR. NETON: So... 

MR. GRIFFON: Yeah. 

DR. BEHLING: Couldn't you, on the basis of job 

description, determine whether the person should 

have been monitored and -- and realize that the job 

description itself would almost mandate the issue of 

monitoring. If he worked in -- in --

DR. NETON: Right. 

DR. BEHLING: -- Building 6 and he was a certain 

assigned job and there's no records, you can clearly 

understand that either the records are missing or he 

was not monitored but should have been monitored. 

DR. NETON: Right. I -- I think that's a good 

point. We -- based on the job description, I would 

-- I would guess that if a person was not monitored 

and our professional opinion was they did not need 

to be monitored, then -- and they had zeroes, the 

missed dose would be larger than the ambient dose 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

18 

that we would have assigned them. So --

MR. GRIFFON: Right. 

DR. NETON: -- in -- in most situations, that would 

end up giving them a little more dose than we 

otherwise would have. But the -- the worst 

situation, though, is if we made the judgment that 

they were monitored -- or should have -- did not 

need to be monitored and should have been. 

DR. BEHLING: Yes. 

DR. NETON: But then that's an area where -- I don't 

know. You know, there's --

MR. GRIFFON: I -- I think -- Jim, I think what 

you're saying is, you know, you don't have evidence 

that this happened but, you know, if -- if, you 

know, the worst case would be that you could 

consider individual claims or verify on a case by 

case basis maybe, I don't know. Because it seems to 

me that you're right, that if their -- there were 

zeroes but they say I never was monitored and you 

look at them and -- and it turns out that they were, 

you know, administrative or whatever --

DR. NETON: Right. 

MR. GRIFFON: -- then -- then you probably are --

are going to give them the higher of the two doses, 

coworker versus -- versus a missed dose and the 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

19 

missed dose is likely to be higher anyway, so... 

DR. NETON: Right. 

DR. BEHLING: Just a quick question of the 

approximately -- I think yesterday you said there 

was about 120 claims that have yet to be processed, 

is that correct? 

DR. NETON: For this time period. 

DR. BEHLING: For this '49 to '57 time period. Of 

those 120 claims, any idea how many of those 

individuals are alive or being -- claims being 

submitted by survivors, which allows you at least to 

interrogate the claimant himself and sort of assess 

whether or not he worked where and under what 

circumstances and what the probability was that 

these uncertainties can be resolved by a direct 

interview. 

MR. MACIEVIC: Well, see, I think a 

misinterpretation comes to people from -- I mean 

over time you have a person -- and I noticed this in 

several files of different sites, and that a person 

would be assigned a gamma dose and -- this is not 

exactly what's happening here, but they'll be 

assigned or have a dosimeter that they're checking 

for gamma. They never had neutron dosimetry, but a 

zero will go into that value --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

20 

DR. BEHLING: Okay. 

MR. MACIEVIC: -- but it -- so technically they were 

never monitored for neutrons, but they throw a zero 

in there for the record-keeping purposes. Now that 

you can see by, you know, looking at different files 

and how it's laid out. But yeah, this -- this 

question is --

MR. GRIFFON: A little different, yeah. 

MR. MACIEVIC: -- yeah, different than what that is, 

yes. 

DR. NETON: To answer to Hans's original question, I 

think -- I don't know exactly, but if -- if it holds 

true for the rest of the sites, it's about 50 

percent of the cases are --

DR. BEHLING: Are survivors? 

DR. NETON: -- survivors. 

DR. BEHLING: Yes. How about also --

 MS. BLOOM: I think we also find, if you look at the 

interviews, that somebody will say I didn't wear a 

badge. And you go to the records and you go yes, 

you did. 

DR. NETON: Now see, this is when it's part of 

security credential, they don't know. 

 MS. BLOOM: Yeah. 

UNIDENTIFIED: Right. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

21 

DR. NETON: I mean they might not know, but --

DR. BEHLING: The other thing I was just thinking of 

as a cross-reference would be looking at if there 

are -- and again I don't know because I haven't 

looked at the records, but are there occupational 

medical exposure records and would you have given a 

person who's not a radiation worker an occupational 

medical. Is that the criteria? In other words, 

were people given occupational medical exposures who 

were not radiation workers? And if that's the case, 

then any time you see an occupational medical 

exposure with no dosimetry records, you say chances 

are you're missing records. 

 MS. BLOOM: I think it changed over time and at a 

lot of the sites there was a pre-employment physical 

that included routine X-rays, I think. 

DR. BEHLING: So that's not a distinguishing factor. 

 MS. BLOOM: I -- I think it changes and --

DR. NETON: I don't think we can hang our hat on 

that, no. 

 MS. BLOOM: -- finding documentation of the exact 

criteria is really tough. 

UNIDENTIFIED: (unintelligible) 

 MS. BLOOM: The other thing that I -- I did find in 

the records when I was looking at one claim 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

22 

yesterday, some letters that said oh, by the way, 

you haven't turned in your badge, we've sent these 

in. And so there is some indication that they were 

tracking badges, they were following up and you 

might be able to go back to records and see what was 

entered for that time period, did it come in later, 

did it come in at all, was it a zero between two, 

you know, large numbers. 

MR. GRIFFON: Hey, Jim --

DR. NETON: Yeah. 

MR. GRIFFON: -- the other thing I'm trying to 

remember is I'm not sure that this claim wasn't 

partly based on -- on some Mont Mason memos that 

they were referring to. I'm --

DR. NETON: I think you're right, Mark, that there 

was some issue about --

MR. GRIFFON: There was some kind of claim in one of 

those memos that there could have been, you know, 

and -- and I think the -- the petitioners picked up 

on that, so --

DR. NETON: Yeah, I need to maybe go back --

MR. GRIFFON: -- so I think we need to track that 

back, too -- yeah, and I forget what the issue was. 

DR. NETON: Right. I -- I think that I agree with 

your -- your -- your statement earlier, though, 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

23 

Mark, that, you know, if -- if we can't find any 

evidence that it did happen, we do have zeroes in 

the record and we do a case by case evaluation of 

the -- of the job title and either could make a 

determination to assign either -- well, missed dose, 

which would -- would probably -- we would probably 

assign missed dose at a minimum since they --

MR. GRIFFON: Yeah. 

DR. NETON: -- were monitored. 

MR. GRIFFON: And I think you -- you -- I mean I 

don't know. It's your decision, but you might offer 

that, you know, if -- if there's a claim made by an 

individual and in that particular case -- I mean I 

can -- I can foresee a situation where -- it doesn't 

seem like it because you've got 90 percent of the 

(unintelligible) monitored here, but I can foresee -

- on some sites I've been on there's been situations 

where maintenance people kind of fell through the 

cracks because they were assigned to a maintenance 

building, but they would go in other areas where 

they -- they should have had a badge but they just 

kind of fell through the cracks and they did work in 

those areas and -- and never were monitored. So if 

you saw a case like that, then you could say well, 

in those cases we'll give the higher of the two, 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

24 

coworker or missed dose, you know --

DR. NETON: Right. 

MR. GRIFFON: -- if there's a claim made by -- and 

we'll -- we'll handle that on a case by case basis. 

So we don't have any evidence, but we will be 

claimant-favorable in -- in those situations if --

if people make those allegations. 

DR. NETON: Then maybe --

MR. GRIFFON: I don't know. 

DR. NETON: You know, Mark, I'm -- I'm looking at 

this -- the SEC evaluation report and it looks like 

-- I can't tell exactly, but it looks like they're 

referring to the zero recorded for site breath radon 

results. 

MR. GRIFFON: Oh. 

DR. NETON: The TBD indicates technique 

(unintelligible) for internal exposures for other 

isotopes based on uranium. Site breath radon 

results indicate a 0.000 will not affect the ability 

to reconstruct doses to individuals because 

surrogate information is available. At least that's 

what we've said, so unless there -- it appears 

somewhere else in here -- I'll -- I'll -- I'll go --

I've got to go through and -- and address this. 

MR. GRIFFON: We should check back on that because I 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

25 

recall them saying about the film, as well, that 

maybe -- maybe that was more of a --

DR. NETON: Yeah --

MR. GRIFFON: -- a personal --

DR. NETON: -- you're probably right. 

MR. GRIFFON: Yeah. I don't know. 

DR. NETON: I'll -- I'll look through it and, you 

know, I think the approach we were talking about 

here is as best we're going to do and -- and in 

fact, if it was a person such as like a chemical 

operator and they were assigned zeroes -- well, see, 

I -- I find it hard to believe with that many people 

monitored that --

MR. GRIFFON: Right. 

DR. NETON: -- someone like a chemical operator 

would not have -- have a badge result. 

MR. GRIFFON: But -- but -- yeah. It -- it does --

it's a little tricker than that 'cause your 

percentage of people monitored is based on all those 

zeroes counting as real -- real monitoring, right? 

So anyway... 

DR. NETON: Well -- well, you've got a point there 

if -- if that is indeed true. 

MR. GRIFFON: But I -- I tend to think you're right. 

I mean it's like the majority of these people were 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

monitored, so... 

DR. NETON: I -- I think if we go through and pull 

out the ones that weren't monitored, sort of a 

sampling, and get a feel for the -- the job titles, 

you know --

MR. GRIFFON: I think that would be --

DR. NETON: -- I'm envisioning something like a 

little histogram or something. Yeah. Okay, I -- I 

think we've -- we've got the thread here. 

DR. MAKHIJANI: A couple -- couple -- couple other 

things in this area is I think -- from my worker 

interviews, it seems that guards were not monitored. 

DR. BEHLING: Well, I think they were --

DR. MAKHIJANI: And guards may have --

DR. BEHLING: -- in -- in some instances. 

DR. MAKHIJANI: -- some of the guards may have 

fallen through the cracks, but that -- I don't know 

whether that's true or not. 

DR. NETON: (Unintelligible) 

DR. MAKHIJANI: (Unintelligible) the guards were 

monitored? I mean this is just --

 MS. BLOOM: I believe guards were monitored. 

MR. MACIEVIC: And I just read that this morning in 

here --

DR. MAKHIJANI: Okay. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

27 

MR. MACIEVIC: -- somewhere and I can't quite find 

it. 

DR. MAKHIJANI: All right. And I -- it's in the 

TBD. I'll check it. 

MR. MACIEVIC: Yes. 

DR. MAKHIJANI: I will check it. The other thing is 

that, you know, as you said earlier, Jim, that 90 --

that 90 percent of the white male workers were 

monitored --

DR. NETON: Well, at the very least. 

DR. MAKHIJANI: -- but you may not have -- you may 

not -- in the recent -- in the last years --

DR. NETON: Yeah. 

DR. MAKHIJANI: -- but you may not have all the 

records. 

DR. NETON: Right. 

DR. MAKHIJANI: And so I think in a way the zeroes 

question and the lost records question is sort of 

tied up with, you know, your ability to -- to define 

a job category and make an assessment of what that 

situation is. And so this raises sort of -- one of 

the questions that we brought up in our review is, 

in the case of the survivor claimants sometimes you 

have a tougher time with the job history if you 

don't have the records because they may know only 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

28 

the last one. I've -- I've looked at lots of 

interviews and really it's --

 MS. BLOOM: Uh-huh. 

DR. MAKHIJANI: -- it's a lot of don't knows, and 

you can -- you can understand that. And so in -- in 

those cases I think -- I think it's kind of 

important to know what -- what fraction of the --

what portion of the universe you're dealing with 

here in terms of unavailable records as well as 

records that we think where the data might not be --

DR. NETON: Right. 

DR. MAKHIJANI: -- of the integrity --

 MS. BLOOM: I think when you're talking about job 

title and it -- I don't think it matters whether you 

have the employee's recollection or the survivor's 

recollection, you should take it with a grain of 

salt. And I -- I think one of the claims you were 

talking about yesterday, I went back and looked at 

that. There was a strike in 1963. That person who 

became an administrative worker went back and in 

1963 during the strike was the foreman in 

maintenance again and that's in the record. 

DR. NETON: Interesting. 

 MS. BLOOM: I've got a page number for you so you 

can take a look at that. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

29 

DR. NETON: Excellent. 

 MS. BLOOM: So I think as you pull the threads and 

you find data, what you realize is that you can 

probably figure out how to put your arms around 

things, but you should never think that your data is 

all, you know, that -- that you know everything you 

need to know, because I think every time I pull on 

those threads, I find out I missed something. Also 

although that sounds really good, the dates are off. 

And they're off in a way that makes that not exactly 

the answer, but just a compounding factor to the 

information so... 

DR. MAKHIJANI: Okay. Yeah -- no, I mean I -- I 

raised the question --

 MS. BLOOM: Uh-huh. 

DR. MAKHIJANI: -- yesterday about I think Mr. B it 

was --

 MS. BLOOM: No, I think it's a good -- I think it's 

a good question and a good example. 

DR. MAKHIJANI: -- purely, truly, as I don't know 

what's going on here --

 MS. BLOOM: Uh-huh, yeah. 

DR. MAKHIJANI: -- because we know -- well, you 

know, if you take Fernald -- which is a facility 

that I know perhaps best of all the ones that we 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

30 

talk about because I've studied it for the longest -

- in 1955 they had enormous emissions of 

radioactivity. And if you -- if you were across the 

street from Fernald rather than, you know, two miles 

away, you could have gotten pretty big doses. 

 MS. BLOOM: Uh-huh. 

DR. MAKHIJANI: If you were in an office building on 

the Fernald site, you could have gotten pretty big 

doses. And so not to prejudge what goes in Fernald, 

but just from the -- the stack records and the 

scrubber records and so on, you can say quite a lot. 

So I just raised that as a question without knowing 

the answer because we don't -- we haven't done a 

source term evaluation for Mallinckrodt. I don't 

even know whether it's possible to do such a thing 

in terms of what went up the stacks. I haven't 

looked at any of the records so I -- I'm not 

prejudging that answer. So this is actually very 

useful information --

 MS. BLOOM: Uh-huh. 

DR. MAKHIJANI: -- because people forget after --

it's true, people do forget after so many years. 

 MS. BLOOM: And it was an odd situation but I think, 

you know, that's certainly something that you 

probably wouldn't necessarily remember. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 -- 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

31 

DR. NETON: Right. 

DR. MAKHIJANI: Yeah. 

DR. NETON: I forgot where we were going here 

(unintelligible). 

DR. MAKHIJANI: Okay. So is there a kind of -- how 

do -- is there -- are you going to come back to us 

with some kind of information about the proportion 

of records -- roughly? You know, I realize that you 

cannot --

DR. NETON: It's just like with the internal 

monitoring, we're going to come back with some type 

of a -- of a distribution. I mean with 120 claims 

it's, you know, it would be some -- worth of work, 

but it would not be that hard to go through each one 

DR. MAKHIJANI: Right. 

DR. NETON: -- and -- and just check a box. You 

know, it's going to be a little harder so it's going 

to be a rough cut. We're going to say some or none 

because, you know, just because there's some does 

not necessarily mean that it's complete monitoring 

history but at least it's an indication you've got 

something on the guy and the monitoring status 

(unintelligible). It may be instructive to 

determine what percentage of those are zeroes, yeah. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

32 

DR. MAKHIJANI: Right. But if in that same thing 

you could give us an idea of --

(Whereupon, an unrelated discussion ensued off 

the record.) 

DR. MAKHIJANI: If in that same thing you could give 

us an idea of job titles, you know, whether you have 

-- not what the job title was, whether you have the 

job title information. 

DR. NETON: Right. 

DR. MAKHIJANI: Because I think then your ability to 

assign missed is obviously improved --

DR. NETON: Right. 

DR. MAKHIJANI: -- a great deal. 

DR. NETON: Sure. Now again, you know, we have to 

be careful in generalizing this for all cases. If 

you don't have a job title and as -- as we went over 

that case yesterday where the lady -- I think it was 

a uterine cancer -- we assigned her the highest --

average of the highest ten doses at the facility for 

each year without knowing anything about her job and 

demonstrating that it was not likely that her 

uterine cancer was caused by her exposure at work. 

So, you know, these things -- yeah, I -- I'm very 

reluctant to generalize and say if we don't have job 

titles, this is how we're going to do it. It's --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

33 

it depends on the case. I think that was an 

instance of a short latency period possibly 

(unintelligible) -- there' s other factors that come 

into play. 

MR. MACIEVIC: And when you're talking about missing 

data, too, I mean it depends if you're talking a 

person who worked ten years and you're missing eight 

of those years or a person who missed a few months 

out of those years and you can interpolate in 

between. So I mean missing data is --

DR. NETON: Yeah. Well, this will be a little rough 

and we're going to -- we're going to provide an idea 

of are there bioassay, are there external results 

(unintelligible) -- I know there's some with none. 

I mean clearly we had one yesterday, but I don't 

think we knew the job title of that person. We just 

knew she worked here. I'm sure by -- by all 

accounts -- I mean she could have been a secretary; 

she could have been a chemical operator. 

DR. MAKHIJANI: Okay. I think that --

DR. NETON: Okay. 

DR. MAKHIJANI: -- the next question is how is NIOSH 

addressing the issue of organ versus badge location 

geometry for workers such as those who scoop 

residue, shovel pitchblende into digesters, stamped 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

34 

ID numbers on ingots. I think here the stamped ID 

numbers on ingots -- I wrote this before I went to 

St. Louis, I think -- may not be as big an issue as 

maybe at Fernald because I don't think they were 

doing it in the same way. But -- but the others do 

appear to be somewhat -- I don't know how you 

address the geometry problem. It was -- it was 

there at Iowa, we brought it up where the pits were 

in front -- in the pelvic area and we all estimated 

a factor of 2.5 or something like that. But I don't 

know how you would do that, approach that here, what 

the magnitude of the problem is. 

DR. NETON: Well, we -- you know, we -- we've looked 

-- we've looked at this issue some since you raised 

it and we need to do some analysis. I mean we can't 

just out of hand reject it and say that it's not 

important, but it's our opinion that for area -- for 

functions like shoveling, it's not going to be a 

huge difference. I don't think we're talking as 

large a difference as the pits holding up at the 

abdomen. But, you know, it may be -- you know, I'm 

speculating here but, you know, something that's a 

25 percent or something of that magnitude. So we're 

not -- I don't -- I don't think it's going to be as 

large an issue. But it was not addressed in the TBD 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

35 

and is something that we have to answer. 

DR. MAKHIJANI: And is there kind of an approach 

that you've thought of -- thought of to developing 

an answer to --

MR. MACIEVIC: Well, one of the things that I'm 

going to be looking into is we have a new software. 

It's a transport -- radiation transport software 

called Attila that -- it's a deterministic model as 

opposed to the probabilistic like the MCNP, and 

we're going to try to do some calculations using 

that for different scenarios for body position with 

the band badge and organ position with respect to 

the source to get -- see what kind of limits there 

are. And you probably will see that as a person is 

moving off from that source by a certain percentage, 

as long as that distance between the badge and 

whatever organ are, you know, pretty much the same, 

there's not going to be that much difference. It's 

going to be in the cases where -- you know, like 

you're saying, where the person's definitely got it 

close to one place and the badge is now distinctly 

different that you'll see it. But this, hopefully 

will be able to generate some numbers for that and 

get a good feel for the kinds of distributions 

(unintelligible). 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

36 

DR. NETON: Right. 

DR. MAKHIJANI: One -- one of the things -- I have a 

picture that I'll show you at the break from 

Fernald. But one of the things that seems to be an 

issue -- and Hans, correct me if I'm not on the mark 

here. But the -- the -- the angle -- the geometry 

of the radiation source where sometimes the badge is 

kind of dangling down and when the source is beneath 

you, you know, you -- you don't have a perpendicular 

incidence of -- of the radiation on the badge. 

DR. BEHLING: The issue of angular, angular 

sensitivity. 

DR. MAKHIJANI: Angular -- so the angular -- this 

question came up in my mind reading the TBD and 

trying to study the operations actually first from 

an angular dependent point of view, because you've 

obviously got the work beneath you --

MR. MACIEVIC: Right. 

DR. MAKHIJANI: -- and you're -- whenever you're 

bending down, as you'll see in the picture that I 

show you, the badge is dangling vertically and 

you've kind of lost your near-perpendicular 

incidence. 

MR. MACIEVIC: Well, yes, and I think that's part of 

the thing because some people wore badges like that 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

37 

where you had a strap and the dosimeter was on this, 

and as you move forward that would also swing out as 

opposed to having it attached to the clothing at the 

chest level. So --

DR. BEHLING: Right. 

MR. MACIEVIC: But that kind of thing I think you 

could model up relatively easy with the Attila. I 

say relatively easy, but I think to -- to get some 

different types of scenarios, and if the -- the --

the effects of geometry get even more important with 

-- as the energy or the beta -- like with the beta 

particle and the -- the mean free path across. If 

you've got photons and that which have a high enough 

energy, the -- it will interact with the film on the 

-- the angularity effect is a lot less for something 

like that as opposed to a -- a beta particle which 

now you're hitting it at different angles so that 

penetration through or not hitting the filters is 

different. So you can mock that kind of scenario up 

a little bit better with -- using this Attila 

software and try to come up with some kind of 

factors in -- now as far as what you make as an 

assumption as to how many people wore straps where 

the dosimeter hung -- swung free versus how many 

would have kept it to their chest, I don't know. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

38 

DR. BEHLING: Well, it's not even the swing. I mean 

angular dependence is something that you have to 

worry about if you deal --

MR. MACIEVIC: Sure. 

DR. BEHLING: -- with an isotropic source because 

you're getting simultaneous radiation from all 

angles other than normal. 

MR. MACIEVIC: Sure. 

DR. BEHLING: And of course, especially the deep 

dose where you go through 1,000 milligram of fill 

dirt material, whether it's cadmium or silver, the -

- the thickness obviously is a function of -- of 

deviation from normality in terms of deviance in 

radiation. So you know -- and I've gone through --

I think in some of my write-ups regarding -- was it 

Iowa? -- as well as the discussion in -- under task 

3, I provided some data that comes straight out of 

the classic textbook (unintelligible) that measured 

the angular dependence of early film dosimeters. 

And it's clear that any deviation from normality is 

-- is going to affect the -- the response of the 

film, so --

MR. MACIEVIC: There's also an energy 

(unintelligible) --

DR. BEHLING: Oh, yeah --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

39 

DR. NETON: Yes. 

DR. BEHLING: -- of course there is, but in fact in 

some instances if you're actually at 90 degree 

angle, your -- your film dosimeter will -- will not 

even be -- I think if -- if -- and it's an unusual 

case which would never happen, but I think in the 

early day they actually had the little lead marker 

that says if it didn't show up then that exposure 

wouldn't even be registered because they would 

assume that it's a false positive at 90 degrees. It 

would give you a high dose because you're obviously 

avoiding the actual shield or the cadmium shield, 

but that would also be indicated to the reader 

because the -- the -- the lead marker wouldn't be 

seen on the film and therefore he would say ah, this 

is -- this is an artifact and it would essentially 

be recorded as zero when in fact it was a positive 

dose. Those are all issues that are obviously 

limitations when you talk about film dosimeters, 

angular dependence. 

DR. MAKHIJANI: Is it -- is it -- Hans, is it -- is 

it sort of more with the two-element thing, twoelement dosimeter as opposed to the other ones where 

you might have --

DR. BEHLING: Well, it's -- it's -- it's -- all --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 -- 

17 

18 

19 

20 

21 

22 

23 

24 

25 

40 

all dosimeters have that problem. Think of this as 

-- as the filter that overlies your -- your -- your 

deep dose portion of the badge. If you go at right 

angles, it goes through basically one millimeter of 

silver or cadmium, whatever it has. If it goes 

through at an angle, you realize that --

DR. MAKHIJANI: Yeah. 

DR. BEHLING: -- the path is considerably thicker 

and -- and so therefore you -- you see some 

attenuation effect. And there are some data in the 

early measurements that were done, empirical 

measurements (unintelligible), that tell you exactly 

at -- you know, at angle of 45 or 30 degrees, 90 

degrees, et cetera, what -- what the reduced 

response for a -- for a mono-energetic beam would be 

MR. MACIEVIC: But you would also have to look at --

I mean for that kind of thing -- and that's true if 

you were under a certain condition all the time --

DR. BEHLING: Yes. 

MR. MACIEVIC: -- it will do that. But the 

assumption is -- I mean you're moving around 

continuously (unintelligible) --

DR. BEHLING: Yeah. You're basically dealing with 

one --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

41

 MR. MACIEVIC: -- (unintelligible) geometry --

DR. BEHLING: -- isotropic source -- 

MR. MACIEVIC: -- at -- at all times. 

DR. BEHLING: Either the source is truly isotropic 

or your body motion makes it an isotropic. If you 

spin on your own axis, even a point source 

essentially appears to the dosimeter as an isotropic 

source. 

DR. MAKHIJANI: So some idea of an approach may be 

with an illustrative calculation or two? 

DR. BEHLING: Well, I think it's part of the 

uncertainty that's normally introduced, although I 

think from the uncertainty -- and this is one of the 

things that I've always taken exception to because 

I've been in the utilities where you -- you do your 

uncertainty by taking obviously several dozen badges 

and you put it in -- in a circular fashion. You 

rotate about a point source and then you essentially 

determine what the average value is and you find 

your sigma value. But in most instances you're 

dealing with a controlled exposure. It's acute 

exposure, it's mono-energetic exposure, and all 

badges are always normal to the incident radiation. 

So you get a sigma value that is an artificially low 

value. It doesn't, for instance, take into 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

42 

consideration many of the other issues, including 

the -- you know, the -- and if you remember this --

the -- and I wrote up about this, the National 

Research Council report on film dosimetry and 

atmospheric testing, and they go through all of the 

different types of contributions due to laboratory, 

radiological and environmental as being contributors 

to the uncertainty. And in most instances there, 

you only deal with one uncertainty as opposed to the 

environmental and -- and laborat-- not laboratory, 

the radiological uncertainty that includes, for 

instance, angular dependence, which is never 

captured when you do that sigma value under 

controlled conditions because you don't rotate the 

badge or you don't necessarily subject it to high 

temperatures. In fact in some -- one of statements 

here involved a very high false positive read that 

was ultimately interpreted as being temperatureinduced. And, you know, for -- for TLDs you have so 

many factors, everything from chemiluminescence, 

(unintelligible) luminescence, you name it, they can 

all contribute, which is usually not captured when 

we deal with badges under controlled exposures. You 

know -- you know, in a field you -- you put people 

into environment that are hot, humid --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

43 

MR. MACIEVIC: The -- the thing is -- is -- I mean 

the assumption there is that you're not backing it 

up by some kind of --

DR. BEHLING: Yeah. 

MR. MACIEVIC: -- dose investigation because many of 

these cases that you're talking about, like with the 

film and my working at Landauer for about five or --

five years over there and doing research on 

different types of dosimetry, film, TLD, track etch 

types of things and all that, you can define what 

you -- you are -- the one nice thing about film is 

that you do have a picture and you can determine 

that there's something wrong when you're monitoring 

it. And several of these places, if there's 

something wrong with the badge, they'll put it in a 

code that there was something wrong with the badge. 

So in a case like that, you would have some kind of 

estimate or there'd be something to state that there 

is a problem here out of the ordinary. So I don't 

think you would -- you could say that all these offconditions were a routine practice that it would 

account for some huge variation in the badge. I 

mean there's the -- the motion of the person and 

things like that which will cause some variation in 

the badge, but some of these things -- like in 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

44 

chemiluminescence and that on a dosime-- on the TLD, 

one of the things that you do in having a heating 

ramp is that you basically burn off all the crap 

that might do that when before the photomultiplier 

even starts reading the number. If you read out a 

dosimeter and you anneal it -- because when you read 

it, you anneal it -- if that still has another read 

and what your process should be and has -- is, in 

reading several of these documents on rereading a 

dosimeter, if there's a residual of a certain 

percent left in the thermoluminescence, that again 

indicates that there's a problem with this badge and 

then you would go back. And having done that kind 

of thing at Fernald, too, is that you see people 

will take their dosimetry through the shower and get 

soap into the material --

DR. BEHLING: They put it in microwave ovens --

MR. MACIEVIC: That's right. 

DR. BEHLING: -- all kinds of things. 

MR. MACIEVIC: -- and it will -- but it will show 

that that kind of duplication comes up each time. 

You'll see a dose for a person one month; they get 

the next dosimeter, there's zero; then the next 

month they're getting a reading again. And when you 

go investigate you find out that dosimeter is messed 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

45 

up so you have to go back and do an investigation on 

those. So I -- the assumption is is that -- or in 

what you're saying is that when a reading has gotten 

on a badge that no one would have gone back and 

looked if something stood out as strange on it. And 

I think in many cases if the badge is operating 

normally, you're not going to have the 

investigation. But if something were -- if -- if 

you can see it --

DR. BEHLING: Yeah, of course. No, I -- I'm fully 

aware of it, but invariably it would -- would never 

been identified as an artifact or a -- a critical 

problem, it's still an issue of underresponse due to 

such things as angular dependence. 

DR. NETON: All right. I -- I think we're getting 

far afield from the film badges at Mallinckrodt 

here, and let's focus on that I think. And I think 

what Greg is saying is true that, you know, you -- I 

don't know that we've got such an exaggerated 

sequence as you're suggesting where a guy is at 90 

degrees to the source --

DR. BEHLING: No, no --

DR. NETON: -- and you've got a worker who's 

shoveling. And I think our -- our contention here 

is that we can do some bounding estimates using 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

46 

Attila to demonstrate that when a person is three 

feet away with a shovel from a -- from a vat of 

something, that the -- the response of that film is 

going to be probably -- I'm -- I'm guessing here, 

but plus or minus 25 percent or something of that 

nature. And so I don't -- I don't think we have a 

huge issue here that is unsolvable. We need --

DR. BEHLING: In fact --

DR. NETON: -- to do some sort of demonstration that 

we believe it's probably within the uncertainty of 

the whole process, so... 

DR. BEHLING: But if there's an uncertainty, it's 

probably in favor of the claimant, and that is film 

badge contamination. That turned out to be a major 

problem in --

DR. NETON: Sure. 

DR. BEHLING: -- specific testing place because of 

fallout. You know, people do things, they touch 

things, and they place their hands on it, and that 

contamination is going to contribute to dose until 

the moment you read out the film. And so you 

realize --

DR. NETON: Right. 

DR. BEHLING: -- badge contamination is a major 

problem. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 -- 

47

 MS. BLOOM: In the -- in our program for the other 

sites, we've started moving towards assigning 100 

percent AP exposures. That's been our assumption. 

I'm not sure that that's what we're doing on 

Mallinckrodt right now. I know just for the AWEs in 

general, though, that's the direction we've headed. 

Does that change any of your concerns? 

DR. BEHLING: Well, I have problems with the -- the 

whole issue of the DCF because one of the things 

that I believe all of the Appendix B and others are 

-- are wrong because they make assumptions that I 

think start out as an air dose and then they convert 

it into tissue doses, which is not correct. For 

instance, you know, you can tell in Appendix B that 

for low energy photons if you have the PA geometry 

exposure, the DCFs are virtually the same as in AP. 

The problem is you're always wearing a badge up 

front --

 MS. BLOOM: On your --

DR. BEHLING: -- and so you realize those numbers 

are off the wall. They don't -- they're not 

correct. 

DR. NETON: And that's -- that's an issue we need to 

address in that document itself. I don't know that 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

48 

DR. BEHLING: No, no, I'm not saying it is here. 

DR. NETON: It's captured in another review 

(unintelligible). 

DR. BEHLING: But -- but when -- when -- when the 

dose -- the doses are calculated that are not organspecific and you convert a recorded dose into an 

organ dose, you still have to defer to the -- the 

Appendix B DCFs. And for instance, I -- I look at 

the numbers and -- and for all of them -- if you 

look at, for instance, the eye or the thyroid and 

you have a PA geometry, well, you know, you realize 

that all those tissues have to have a DCF greater 

than one because you're dealing with an exit dose. 

 MS. BLOOM: Uh-huh. 

DR. BEHLING: The dose is here. Okay? And if the -

- the source is behind you, what you're measuring on 

your -- on your TLD or film is an exit dose, which 

means that --

 MS. BLOOM: Right. 

DR. BEHLING: -- any tissue that is in between the 

source -- and that's starting on your back, the skin 

on your back throughout your torso -- is going to 

have a higher exposure than what's recorded on that 

film --

 MS. BLOOM: Right. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

49 

DR. BEHLING: -- badge by definition. So --

DR. NETON: We're aware of that --

DR. BEHLING: -- when I look at those DCFs I know 

for a fact --

DR. NETON: We have that comment and we will address 

that comment. That's in procedures review and I'm 

aware of that. I don't want to get off on -- on 

that issue here. 

DR. MAKHIJANI: And so basically, just for my 

clarity, what -- what's in the procedures review 

pipeline automatically get reflected in the dose 

reconstructions --

DR. NETON: Everything, across the board --

DR. MAKHIJANI: (Unintelligible) 

DR. NETON: -- those will all be reworked 100 

percent. 

DR. MAKHIJANI: Okay. 

DR. NETON: Any -- anything that is of a broad, 

sweeping -- such as that, we would go back and redo 

every single dose reconstruction that used that 

concept. 

DR. MAKHIJANI: Okay. So that's not an issue in 

terms of reconstructability --

DR. NETON: Right. 

DR. MAKHIJANI: -- it's just a procedures thing that 
1 -- 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

50 

DR. NETON: It's a matter of interpretation of the 

existing data. 

DR. MAKHIJANI: But what I can expect in terms of my 

producing a draft on this particular question is 

that Greg will do a little exploration and then --

MR. MACIEVIC: Yes, right. 

DR. MAKHIJANI: -- you'll -- you'll send us 

something? 

MR. MACIEVIC: Yes. 

DR. MAKHIJANI: So I can look at it and I could call 

you. Presumably you'd have some (unintelligible). 

MR. MACIEVIC: (Unintelligible) have the right 

number, but yes, you can call me. 

DR. MAKHIJANI: Okay. 

MR. MACIEVIC: Yes, I'll (unintelligible). 

DR. MAKHIJANI: Thank you. My -- my aim is to 

produce a rough draft at least by the 15th and 

closer to a final by the 20th so we can have our 

internal --

DR. NETON: Need to get something. Can you do 

something like that fairly quickly, do you know, 

Greg? I mean --

MR. MACIEVIC: Yeah, I'm already talking with the 

people who do the software about ginning-up some 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

51 

scenarios like this. I'll -- I'll call them and 

talk today --

DR. NETON: The software is very nice, actually 

provides -- one of the features of it provides some 

very nice graphics. I mean, you know, images that 

you can show, you know, the source strength and all 

this stuff in relation to the -- you know, magnitude 

of the exposure at different positions relative to 

the person and badge and things so --

DR. MAKHIJANI: So, Hans, do you -- do you have --

are you familiar with this? 

MR. MACIEVIC: It's pretty much brand new. I mean 

this is -- they've used this transport software. 

What this does is you model up -- whatever your 

universe is that you're going to create, if you have 

the person, the source, you'll model an area. It 

meshes this area and you calculate the radiation 

transpoint (sic) at all points within the entire 

area that you have. So what it's going to do is 

give you isoflux lines; it'll give you dose lines 

and all that through different materials and through 

all the particles. It's a -- it's a very -- it's 

quicker and more -- it's not -- it's just as 

accurate as Monte Carlo. But with Monte Carlo you 

end up picking a few points and do the calculation. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

52 

This will compute for the entire area and you'll get 

doses at all points, which is why this will be nice 

and you get nice graphics to show. If you have 

something here, it'll show you the dose and the flux 

distributions through the entire body at different 

organs, and if you placed a dosimeter here, you'll 

get to see what the lines are that pass through this 

point and all that. It's a really neat software for 

-- for doing this, and it's a -- I think people are 

just starting to use it. I mean it's been around a 

lot. I mean radiation transport using this method 

has been around a long time, but the computer 

capacity -- it's had to have so much to crank these 

numbers to follow every photon through that, it just 

took too much. Now it's starting to come into its 

own light so... 

DR. MAKHIJANI: Greg, could I make a request that 

the -- the -- that we get the assumptions that 

you're going to put into this in very simple 

language that I can understand --

MR. MACIEVIC: Sure. 

DR. MAKHIJANI: -- so that we can do some back of 

the envelope checks? Because whenever there is a 

new complex model that's in the computer, it makes 

me very nervous and I like back of the envelope 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

53 

checks because it makes it sense. And of course, 

Hans is our point person on this and --

MR. MACIEVIC: Well, Bob Anigstein would probably be 

the person that looked at the computer. 

DR. MAKHIJANI: -- and Bob, Bob Anigstein. And I 

will call Bob also and convey this to him and get 

him ready for, you know, whatever you have to say 

because this is an area, you know, in which in -- in 

our team basically it's Hans and Bob who look at the 

issues (unintelligible). 

Mark, shall we move on to the next or did you have 

something? 

MR. GRIFFON: No, that's fine. 

DR. MAKHIJANI: Okay. Next question, external dose 

data did not provide job categories for -- in the 

five -- six boxes did not provide job categories for 

personnel whose badges had doses below 200 m-rem and 

in some cases below 300 m-rem, hence external dose 

data do not appear amenable to being grouped into 

job categories in ways that will enable the 

construction of external dose distributions for 

various job categories. How is NIOSH going to 

construct surrogate worker cohorts given the lack of 

job categories for data applying to majority of 

workers? 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

54 

DR. NETON: This is just of course, referring to the 

five or six boxes. I think if you look through the 

list of the 12,000 TLDs or whatever, most people 

have a job title or category associated with them. 

So I think -- I'm not -- and I don't know what --

I'm not familiar with what you're talking about in 

the five or six boxes, but I -- I do know that 

people have individual badge readings with job 

categories -- in the CER database, at least. 

DR. MAKHIJANI: Right. So -- so I guess what you're 

saying is that you're going to construct the -- this 

may be a more straightforward -- the question was 

long and maybe the answer is more straightforward, 

is that when I looked at these records the way they 

were, was -- they were simply identifying the most 

exposed --

DR. NETON: Right. 

DR. MAKHIJANI: -- personnel, and they were calling 

them out by job category. And for most of the 

people -- the vast majority, 90-plus percent of the 

people -- there was no job category. But I don't 

know why they were collected in that way, but -- so 

I didn't -- I don't think that that data can be used 

for --

DR. NETON: Right. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

55 

DR. MAKHIJANI: -- coworker analysis. 

 MS. BLOOM: I would say that that's probably just a 

partial set of data, and as you go through records 

you find you've got lots of partial sets that you 

need to pull together and make sure they match and 

that they -- you know, you've got an issue of 

zeroes, sometimes you find out the worker wasn't 

here and that's what the zero means when you -- but 

you find it in another record. And so that would be 

similar with that, that that's just supplemental 

data that we need to pull all together to make the 

big set of coworker data. 

DR. MAKHIJANI: Yeah. So -- but my -- my -- my 

feeling is, looking at that data in, you know, more 

detail than were able to do before the Iowa meeting, 

it seems to me that -- that pretty much when -- when 

you're constructing coworker data you have to do it 

from the individual records. 

DR. NETON: Right. 

DR. MAKHIJANI: It would not be possible to use 

those aggregate -- at least the aggregate record 

that are in --

 MS. BLOOM: You -- you cannot --

DR. MAKHIJANI: -- those boxes. 

 MS. BLOOM: What I've found is you cannot use any 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

56 

set of records by itself, whether it's the original 

or the summary or anything else. And part of the --

one of the main reasons is illegibility. You can't 

read names or numbers or dates, and sometimes you 

can find that in the summary when you can't read it 

on the card. Sometimes you find it in the card and 

you -- you know, so you need to look at it all and 

pull it together. That's why some of this takes 

time. 

DR. MAKHIJANI: Yeah. Okay. I -- I think -- I 

think that's fair because -- because I've looked at 

a fair number of individual dose records and I do 

know that -- actually as -- as we said yesterday, 

the job title information at Mallinckrodt is pretty 

good. 

DR. NETON: Yeah, it is. It's actually -- I -- I --

it's not in the exact dosimetry file, now that I'm 

looking at this, but there are work history 

information tied to all of the film badge records, 

and that was what I was going to end up sending 

Mark. Yeah, we do have a lot of job -- job titles, 

categories for Mallinckrodt workers, and that's --

that's clearly what we'd use. 

DR. MAKHIJANI: Okay. I think that -- that 

(unintelligible) can consider it taken care of. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 -- 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

57 

Table 33 has only scattered data for external dose. 

How is NIOSH going to construct claimant-favorable 

and scientifically-defensible values for surrogate 

worker cohort external dose? I guess this is a 

different -- different incarnation of the same 

question. 

DR. NETON: Yeah, I think so. I was going to look 

at Table --

 MS. BLOOM: Table 33 is the workplace exposure rates 

DR. BEHLING: Yes. 

 MS. BLOOM: -- and that's -- that's to provide 

people information on the kind of exposure rates 

that did exist at Mallinckrodt. It's not 

necessarily to reconstruct any specific job. It's 

not meant at this time to reconstruct doses but it's 

a supplemental information table to orient you to 

the site. You know, on a case by case basis it's 

possible that it might be useful for somebody to 

say, you know, look at these dose rates and look at 

the badges, and this makes sense or it doesn't make 

sense --

DR. NETON: Right. 

 MS. BLOOM: -- but it -- it's not meant to be a 

stand-alone, we're going to assign doses from this 
1 

2 

3 

4 

5 

6 

7 

8 

9 -- 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

58 

table. 

DR. BEHLING: Yeah, that was my question, how will 

this table be used --

DR. NETON: Right. 

DR. BEHLING: -- if at all. 

 MS. BLOOM: It's informationally and a case by case 

basis. 

MR. MACIEVIC: And it does help to fill in the holes 

 MS. BLOOM: Yeah. 

MR. MACIEVIC: -- where you've got data over here 

and now you have some pieces here and see that it --

it makes sense what you --

DR. BEHLING: Any idea what instrument was used to 

measure these dose rates? 

DR. NETON: That's a good question. I was just 

looking --

DR. BEHLING: Something like an R02 or something? 

DR. NETON: Yeah, I'm sure --

 MS. BLOOM: I don't -- did the R02 exist at that 

point? 

DR. BEHLING: Probably not. 

 MS. BLOOM: Junos were very common at that point. I 

-- I'd have to go back to the records and find the 

individual information. A lot of times you will 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

59 

find some information, but typically it was an 

ionization chamber. 

DR. BEHLING: (Unintelligible) unit or something, 

ANPDR --

 MS. BLOOM: Sometimes --

DR. BEHLING: -- 37. 

 MS. BLOOM: I have not heard that instrument model 

number. 

DR. BEHLING: I used it in the field a lot, the 

ANPDR-37. 

 MS. BLOOM: I've not seen that in the older records. 

It might be there. Juno was the typical one, 

Victoreen, Nuclear -- Nuclear Chicago was another 

common instrument --

DR. BEHLING: Yeah. 

 MS. BLOOM: -- the 20 -- I can't remember if the 

2650 was both a exposure rate measurement instrument 

as -- I think it may have been. Sometimes 

(unintelligible) detectors were used. 

DR. MAKHIJANI: The -- I think there's an 

intersection there between Table 33 and the data in 

the five, six boxes. And of course, you know, it's 

not possible for me to go and check through, but in 

terms of dose rates it may be -- I think there's 

kind of quite valuable information in those boxes 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 -- 

23 

24 

25 

60 

that may be useful in modifying Table 33 and 

updating it because I think some of the dose rates 

indicates in -- in that collection of data may be 

higher or may be more useful as a guide for job 

titles because Table 33 is organized by job titles 

and areas, if I remember it correctly. 

DR. NETON: Right. You know, my -- my thought on 

this table --

DR. MAKHIJANI: No, so I -- I just -- the data 

seemed very, very sketchy in terms of years and --

even as a guide. and it seemed to me that -- that 

what there is in terms of the -- not -- it's not a 

criticism of what's there, obviously --

DR. NETON: No, sure. 

DR. MAKHIJANI: -- you know, a very -- Janet did a 

monumental job of compiling all of that. We've said 

that I think a number of times, but -- but I think 

there is some information in those boxes that could 

be used as a complement to that data in particular. 

But that may not be so because I made a -- SC&A made 

a partial compilation of the data in those boxes and 

DR. NETON: Right. 

DR. MAKHIJANI: -- if you take a look at it, it 

might be useful. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 -- 

22 

23 

24 

25 

61

 MS. BLOOM: And I think that's -- because this is 

supplemental at this point, I think that's still 

something to look at and we should look at it, but -

-

DR. NETON: All right. You know, I'd like to point 

out --

 MS. BLOOM: -- I don't see this as a primary --

DR. MAKHIJANI: Okay. 

DR. NETON: Right. You -- you need to look at the -

- you know, the hierarchy of data usage. And 

clearly in cases where we have all these film badges 

and we can validate them, then we would 

preferentially use that, then followed by these area 

results which are supplemental. And in the case 

where you have zero information, these of course 

would become very valuable. But I -- I think that 

the second level, though, would like -- more likely 

be coworker dose distributions rather than these 

area badges. 

 MS. BLOOM: That seems unlikely that you'd use this 

DR. NETON: Right, but they do --

 MS. BLOOM: -- unless you saw an incident or 

something --

DR. NETON: I -- I think they do sort of provide 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

62 

some kind of a sanity check, though. If you have a 

worker who spent like all year in one of these 

places where you're seeing 50 mr per hour and his 

CATI says I -- I held these boxes, you know, for 

hours on end and -- and you're showing zero result, 

you might question that and do a sanity check on 

what you're -- what you're proceeding with. 

DR. BEHLING: There are a couple of good ones here 

at the feinc filter and that you talk about some of 

those people who spent a lot of time handling these 

filters --

DR. NETON: Right. 

DR. BEHLING: -- and on page --

DR. NETON: Right. 

DR. BEHLING: -- 232 you'll see some values here in 

terms of what the dose rates would have been --

DR. NETON: Right. 

DR. BEHLING: -- in front of the filter -- at one 

foot, 210 milli-r. 

DR. NETON: Right. 210? 

DR. BEHLING: No, I'm sorry. I'm sorry. No, no. 

It's -- it's expressed in percent tolerance. 

DR. NETON: Okay. 

DR. BEHLING: So it's 210 percent, meaning that what 

the tolerance dose was defined here as what -- 100 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

63 

mr per eight-hour day. 

DR. NETON: Right. 

DR. BEHLING: That would have been then -- yeah, 210 

mr for an eight-hour day, right? 

DR. NETON: Yeah. So matter of fact, that crossed 

my mind when we were talking about these raffinate 

workers. If you had a person with almost no 

recorded dose --

DR. BEHLING: Yeah. 

DR. NETON: -- you've got a fairly good feeling that 

this person was not working with these raffinate 

streams where there are, you know, 50 mr per hour 

fields. So that, in -- in my mind, is one approach 

that we may take in this and to defining -- defining 

some of these people at Plant 6 that we talked about 

yesterday. I used the external to help bracket the 

internal potential for exposure. 

DR. MAKHIJANI: Well, I -- I -- I'm not sure that 

you can actually go there, because the main issue 

with the raffinates, apart from that -- for that 

small group of workers I think you could do that, 

but the main issue with the raffinates that came up 

yesterday was on the reprocessing of the raffinates, 

which is a bigger issue --

DR. NETON: Right, right. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

64 

DR. MAKHIJANI: -- at Plant 6. 

DR. NETON: Right. 

DR. MAKHIJANI: It's not an issue --

DR. NETON: Right. 

DR. MAKHIJANI: -- just where those filters, so --

 MS. BLOOM: But -- but you'd still have those high -

- much higher dose rates --

DR. NETON: I mean the radium is still --

 MS. BLOOM: -- from handling the --

DR. NETON: -- there, right? I mean --

 MS. BLOOM: The radium and the progeny. 

DR. NETON: -- it depends on which -- which stream. 

DR. MAKHIJANI: Yeah. I -- I'm not -- yeah, you 

know, if you're talking about the digesters, you 

know, the -- the external dose (unintelligible) 

shielded by all the acid in the tanks and very --

pretty far, so --

DR. NETON: Right, but that means that you're not 

having much particulate exposure if it's in a tank. 

See, in my mind, these raffinate workers -- the --

the highest potential for exposure is the people 

that are scraping the filters and drumming the 

material. 

DR. MAKHIJANI: Yes, I agree. 

DR. NETON: At that point it's completely 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

65 

unshielded, or almost unshielded, and you've got a 

very large source term sitting right in front of 

you, concentrated material. So I don't know where 

I'm going with this, but it just -- it just --

thought crossed my mind that we could use that to 

our advantage to bracket these things. 

DR. MAKHIJANI: Okay. I think we're done with that 

question. Hans, do you have anything more on that 

question? 

DR. BEHLING: No. 

DR. MAKHIJANI: Okay. Okay. Now here's -- here's 

your question, Hans. Hans/NIOSH addressing the 

nonlinearity and the optical density and dose at low 

exposures. Specifically it appeared that this could 

lead to systematic underestimates of dose. Is NIOSH 

developing a correction factor to address this 

problem? Do you want to clarify that question? I'm 

not sure --

DR. BEHLING: Yeah --

DR. MAKHIJANI: -- I got it exactly right. 

DR. BEHLING: On page 116 -- and this is commonly 

done here and I'm not sure to what extent that error 

is -- is going to amount to a -- a value that is 

significant, but bullet number 7 -- and I think it's 

stated elsewhere here on I guess page -- let's see, 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

66 

where are we here. 

 MS. BLOOM: Is that page 92, the --

DR. BEHLING: Yeah, page 92 is the -- the use of 

simple subtraction to segregate out beta from gamma 

components. And it's not something you can just 

look at and say okay, the open window is obviously a 

shallow dose or that it was responding to both 

photons and -- low energy photons and betas, and the 

shielded portion is obviously likely to be a 

response to higher energy photons only, and simply 

subtracting the two gives you an understanding of 

the beta components. And -- and that issue is 

discussed very -- in detail in the National Research 

Council, the 1989 report of atmospheric testing and 

film badge dosimetry. And they were very adamant in 

those days to try to identify what part of that 

exposure in the open window was due to betas as 

opposed to photons, and you will read in that 

description the difficulties -- and they finally 

quit in trying to make that distinction. And the 

reason being is that the film is not a linear 

response (unintelligible) in terms of optical 

density. When you plot net optical density as a 

function of exposure usually it's a sigmoid curve 

and -- and in essence simply subtracting optical 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

67 

density from the shielded portion from the open 

window is not necessarily the approach. In fact it 

gives you a false reading. And what they tell you 

do is -- and it has to be calibrated properly -- is 

to convert each value first into a dose, and then 

subtract the dose as opposed to the optical density. 

And that apparently is exactly what is done here and 

this is something that's -- at least in -- in that 

report -- was identified as a difficulty that was 

not easily overcome. You have to go back to the 

report and -- and again here, I -- they used 

basically the same film badges here, the Dupont 502 

and the Dupont 510 for the low dose/high dose so 

that you could capture even doses in the, you know, 

in the tens of rads or even hundreds of rads. And I 

realized the same problem would probably prevail 

here in trying to assess the component, the beta 

component from the -- from the gamma component. 

MR. MACIEVIC: Well -- well, you're absolutely 

right. I mean if you have a two-filter badge you've 

got the -- the -- the thick shield, the -- that'll -

- the -- that'll --

DR. BEHLING: Yeah. 

MR. MACIEVIC: -- wipe out all the low energy 

photons. You're not going to have that overresponse 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

68 

under that particular filter. But yes, in the open 

window, if you've got beta and you have low energy 

photons, trying to pull out which is the low energy 

photon and which is the beta when all you have is 

one other filter -- that's why the multi-filter 

badges do much better because you can get that 

intermediate energies in there to go and see ratios 

between different filters. But I believe what we do 

on there -- I mean that is addressed in the OCAS 

Imp. guide as far as how to deal with these kind of 

-- you -- you're going to make -- what is it, 

calculation based on -- I believe that it's a photon 

exposure as opposed to the beta because the photon 

is going to give you the most conservative --

DR. BEHLING: Yeah. 

MR. MACIEVIC: -- number. So when you're in the 

state of not knowing, you're going to go with the 

most conservative and say it's a photon exposure and 

that the overresponse is in there and you're going 

to compute that number. I think I'm going in the 

right (unintelligible). 

DR. BEHLING: But I'm -- I'm not sure that necessary 

is the issue here. This is basically the -- the 

methodology of subtracting the optical density under 

the shielded portion of the film from the net 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

69 

optical density on the open window. And according 

to that study -- as I mentioned, this is Frank 

Massey's* report -- that is something you should not 

be doing. You should first convert each of those 

portions of the -- if you have a two-element film 

badge -- into dose and then subtract the dose from 

each other rather than subtracting that optical 

density from -- one from the other. 

MR. MACIEVIC: I -- oh, I (unintelligible) --

DR. BEHLING: You have to go back --

MR. MACIEVIC: -- in there. I think what -- see, 

what you -- what you would do and -- and how I 

computed the doses in working with film is that you 

-- you're going to subtract off from all of them a 

blank which is a control --

DR. BEHLING: (Unintelligible) 

MR. MACIEVIC: from that film. Now there -- then 

you're right, you convert it to dose and then you do 

your analysis between ratios and that between dose, 

not with densities, because you work with the dose 

numbers. Because yes, you don't -- don't work with 

the density values. I don't recall them doing that 

kind of thing where they're -- they're working in 

density units and then the end result is where they 

convert it. I think they are working with -- you 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

70 

are -- you're subtracting off a blank in the 

calibration. You have dose numbers under the filter 

and in the open window and then you're doing the 

subtraction there. 

DR. BEHLING: Does anybody have a copy of that 

report? The --

DR. MAKHIJANI: NPPR? 

DR. BEHLING: Yeah. 

UNIDENTIFIED: (Unintelligible) 

DR. BEHLING: I think it's online. I have a hard 

copy but I --

MR. MACIEVIC: Yes, that's --

DR. BEHLING: -- can point to you the exact page 

number --

DR. NETON: I have the quote in our --

DR. BEHLING: Yes. 

DR. NETON: -- you know, but what Greg -- Greg, it 

does say in our profile, and I mean looking at it 

here, that Mallinckrodt did subtract the optical 

densities. 

DR. BEHLING: Yes, and that's --

DR. NETON: So the relevant question then is --

DR. BEHLING: -- something they don't want you to 

do. 

DR. NETON: Right. Now this of course would only be 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

71 

relevant to skin dose. 

DR. BEHLING: Yes. 

MR. MACIEVIC: That's right. 

DR. NETON: This does not have anything to do with 

full body. 

DR. BEHLING: Yes. 

DR. NETON: And that's -- that wasn't clear from the 

way the question was phrased, so --

DR. MAKHIJANI: Yeah. 

DR. NETON: And that's fine but --

DR. MAKHIJANI: I didn't --

DR. NETON: -- I just want to make clear that this 

is really a skin dose issue --

DR. BEHLING: Yes, yes. 

DR. NETON: -- not a deep dose. 

DR. MAKHIJANI: And a -- it's a little more than a 

skin dose issue. Right, Hans? 

DR. BEHLING: Well --

DR. MAKHIJANI: It would be --

 MS. BLOOM: Shallow or --

DR. BEHLING: -- if you also convert that into the 

breast and the testes, then it becomes -- and -- and 

on that issue I even wondered to what extent -- why 

-- for instance, under the DC9 code you do have the 

eye as one of the potentials -- organs of -- of 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

72 

concern, and also the thyroid. If you're going to 

consider testes and breasts as being part of that 

problem with a potential low energy photon or 

energetic beta, clearly the thyroid also would 

qualify. For -- for one, it's not covered by 

additional shielding such as clothing, as you would 

in terms of testes and the female breast. The 

thyroid is in fact an unprotected area. And 

especially for -- for females and -- and thin 

females, the overlying tissue of the thyroid is 

about 300 milligrams of -- of tissue, so an 

energetic beta could contribute to at least part of 

the thyroid dose. But anyway --

MR. MACIEVIC: I'd like to check into -- I mean I 

know that's what it says, but in my -- in the six 

months I've been here and reading Technical Basis 

Documents which are -- turn out to be mostly in 

seven different languages and you have to interpret 

what's being said in those documents -- I have a 

feeling they are not -- they do not mean that they 

are actually subtracting, 'cause that is not a 

process that I have seen in any of the other 

facilities where -- at -- at other sites and that in 

doing that process where they work straight with the 

densities. The only part where they're working with 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

73 

the densities is you're subtracting off a blank, do 

a dose conversion for filters, and then work with 

the numbers. 

DR. BEHLING: That's not --

DR. NETON: Okay. Then what --

DR. BEHLING: -- if that's the case --

MR. MACIEVIC: -- that has to be checked into. I --

I have a feeling that's -- they're saying it, but 

that's not what they're doing. I think I -- I can 

check into that and try to check some background --

DR. NETON: Yeah, let's --

MR. MACIEVIC: -- documents --

DR. NETON: -- let's get it --

MR. MACIEVIC: -- because yeah, I agree. That would 

-- that -- that just doesn't seem -- as a process 

that I've seen any other places. I've never done 

that and I --

DR. NETON: I believe early on these were done by EM 

-- HASL, right, or --

DR. BEHLING: It was an in-house processing. 

MR. MACIEVIC: Well, they started outside and then 

they went in-house. 

DR. NETON: Yeah, I thought they did, also, but we -

-

MR. MACIEVIC: Right. 
1 

2 

3 

4 

5 

6 

7 -- 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

74 

DR. NETON: -- we need to check into that --

MR. MACIEVIC: Let me check in that because --

DR. BEHLING: And as I said, it may not be a major 

issue but I -- I noticed -- I mean it jumped out on 

me when -- and I'm quite familiar with the film 

dosimetry because of my work in the Marshall Islands 

DR. NETON: Sure. 

DR. BEHLING: -- and of course that was a -- a 

direct report that corresponded to dose 

reconstruction involving the Pacific testing period. 

And -- and I remember distinctly that as a major 

issue because there was so much interest in 

understanding the different radiation components in 

the badges and they -- they apparently gave up and 

say we really don't have the means to do it. 

MR. MACIEVIC: And when you're working with -- yes, 

you're right. The process should work with the dose 

and if you're working with -- it -- it's not good --

two -- two-filter badges leave a lot open. 

DR. BEHLING: Yes. 

MR. MACIEVIC: And using those when you have a very 

good handle on the photon distributions and what 

you've got, you can use that film and know what the 

overresponse is and work with it. But if you're 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

75 

working under conditions where other things are 

happening, two-filter badges don't cut it as well --

DR. BEHLING: Yeah, yeah. 

MR. MACIEVIC: -- and that's why there is --

DR. BEHLING: Yeah. 

MR. MACIEVIC: -- but we do the --

DR. BEHLING: On -- on -- on that issue and -- and 

it's only peripherally similar to -- to the concerns 

here, what will happen in terms of assigning --

obviously IREP demands us to identify the type of 

radiation that is potentially recorded under the 

shallow dose or open window as either being a beta 

component or less than 30 keV. And yet it certainly 

makes a big difference to -- to -- to distinguish 

between the two of them. One has a choice in saying 

it's either very low energy photon radiation that 

separates the deep dose from the shallow dose, or 

it's a beta component that separates the deep dose 

from shallow dose. And yet for IREP input it's a 

significant difference in terms of the relative 

effectiveness factor because when you look at, for 

instance, electrons greater than 15 keV which would 

correspond to beta particles -- and as I said, I --

I've done a calculation that compares the two in 

terms of POC versus the less than 30 keV photons --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

76 

the POC goes from 14.81 percent to 37 for skin. And 

so it's important to know how will this be treated, 

because for -- for skin exposures -- and you will 

probably encounter some squamous cell carcinomas --

the -- the interpretation of the shallow dose is 

going to be heavily affected by -- or the -- the POC 

will be heavily affected by your assignment of a 

shallow dose based on either less than 30 keV 

photons versus greater than 15 keV betas. 

 MS. BLOOM: Were you saying that the less than 30 

keV photons are giving you the higher POC? 

DR. BEHLING: Much higher. 

DR. NETON: Oh, yeah. 

DR. BEHLING: Much higher. And it's up like at two 

and a half (unintelligible) --

MR. MACIEVIC: That's why I thought we --

DR. BEHLING: -- higher. 

MR. MACIEVIC: -- defaulted to that as if there's 

not a known... 

 MS. BLOOM: I think we've actually gone the other 

way. 

DR. NETON: It depends -- it depends on -- on the 

facility. I mean --

UNIDENTIFIED: (Unintelligible) 

DR. NETON: -- we know for -- for plutonium 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

77 

facilities it's going to -- you know, the low energy 

dose is going -- it's going to be less than 30 keV 

photon. 

 MS. BLOOM: For uranium we've --

DR. NETON: At a uranium facility --

 MS. BLOOM: -- typically gone the other way. 

DR. NETON: -- you need -- yeah, you need to look at 

the -- the relative magnitude of the contributions 

of the different spectra and the protactinium 234 

admittedly is --

DR. BEHLING: That's true. 

DR. NETON: -- going to dominate -- dominate the 

shallow dose. 

DR. BEHLING: Yes, yes. 

DR. NETON: In fact it's not unusual in uranium 

facilities to get ten to one ratios of skin to deep 

dose. I've seen that at -- consistently at Fernald 

and we've seen that in the Mallinckrodt records --

DR. BEHLING: And I think there's --

DR. NETON: -- but most of that dose is going to be 

due to the beta. 

DR. BEHLING: Yeah. 

DR. NETON: I -- I think you'd be very hard-pressed 

to demonstrate that the predominance of those 

shallow dose is from less than 30 keV photons. I 
1 

2 

3 

4 

5 

6 

7 

8 

9 -- 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

78 

don't think we would --

DR. BEHLING: But there should be some guidance so 

that we don't have different people selecting one as 

opposed to the other --

 MS. BLOOM: We have been putting --

DR. BEHLING: -- because I think it's important --

 MS. BLOOM: -- that in the site profiles. I'm not 

sure if it's in this one, but we have been selecting 

DR. NETON: It's a replay of the first comment, that 

we need to make sure that people don't arbitrarily -

-

 MS. BLOOM: Verify that. 

DR. BEHLING: Use one or the other. 

DR. NETON: -- use one or the other because then you 

get into consistency problems. 

DR. BEHLING: Yeah, it's a two-and-a-half-fold 

difference. 

DR. NETON: I -- I think we've been doing these at 

many uranium facilities, though, and maybe we've 

just sort of gotten loose in our -- our write-ups. 

But in uranium facilities -- I think it's -- it's in 

general going to be the beta dose. 

DR. BEHLING: Yeah. 

DR. MAKHIJANI: Would you agree with that Hans? 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

79 

DR. BEHLING: Yeah. 

DR. MAKHIJANI: Okay. 

DR. NETON: So -- yeah. I don't know if we have a 

problem but I think you're right, for consistency 

purposes we should -- we should point that out and 

make sure that we do it that way. 

MR. MACIEVIC: Look and see what I (unintelligible). 

DR. MAKHIJANI: So that -- so that if -- well, I'm 

just trying to make the issues clear in my head so I 

don't get off in the wrong direction. So Greg, you 

-- you agree that if -- you don't think that they 

actually were subtracting optical densities --

MR. MACIEVIC: No, I don't. 

DR. MAKHIJANI: -- in reading the -- because we 

don't have the film badges. 

MR. MACIEVIC: Right. 

DR. MAKHIJANI: Right? So it's very important to 

determine -- Cindy, do -- do we have the film 

badges? 

 MS. BLOOM: I -- I don't believe we have the film 

badges. I don't know that we don't have the optical 

density readings. We may have that --

DR. NETON: It may be possible to go back --

 MS. BLOOM: -- on some of them. 

DR. NETON: -- and look at this but --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

80

 MS. BLOOM: I don't -- I don't think we have them 

all. 

MR. MACIEVIC: Look at some of them and see a 

general case --

DR. NETON: Finding them and -- and doing it in a 

systematic manner but --

DR. MAKHIJANI: Well, it would be useful to check 

just a few if you have them because it seems --

DR. NETON: Yeah. 

DR. MAKHIJANI: -- to me that this is a critical 

issue --

DR. NETON: Well --

DR. MAKHIJANI: -- because we agree that if they did 

-- if they did do it as it says in the TBD, this 

would be a problem. 

DR. NETON: Well, it's a critical issue for skin 

dose. 

DR. MAKHIJANI: Skin dose for these --

DR. NETON: For the shallow organs. 

DR. MAKHIJANI: -- for the shallow dose or --

DR. NETON: (Unintelligible) certain organs, right. 

DR. MAKHIJANI: -- no, I got that. Okay. So for --

for the shallow dose organs it's important to know 

what they did, and you don't think they did that --

MR. MACIEVIC: No, I --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

81 

DR. MAKHIJANI: -- but some -- it would be useful to 

have some verification, either from this site or the 

(unintelligible) what was the general practice at 

the time at least. 

DR. NETON: Right. 

DR. MAKHIJANI: If there could be evidence from the 

time about that, that would be very useful. 

DR. NETON: Some of the language --

MR. MACIEVIC: Because I have a feeling -- yeah, now 

whether I can get it from Mallinckrodt or not, but I 

know practice was not done that way at several other 

sites. I mean that approach --

DR. NETON: Most of these people did not make up 

their approaches. They all --

MR. MACIEVIC: That's right. They took it from one 

place where they knew where they were working with 

it and they took it, so --

 MS. BLOOM: (Unintelligible) we have the densities 

there because I know I --

DR. NETON: What are those two pages that you cited 

earlier? Was it 92 --

DR. BEHLING: Yeah, 92 --

DR. NETON: Down at the bottom --

DR. BEHLING: -- bottom of page 92. 

DR. NETON: And there was another one. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

82 

DR. BEHLING: And then on page 2-- 116 at bullet 7. 

DR. NETON: That's what I was looking for. So what 

bothers me --

THE COURT REPORTER: Excuse me one minute, 

please. 

DR. NETON: I'm sorry. 

THE COURT REPORTER: I'm sorry. 

(Pause) 

DR. BEHLING: Okay. On page 92 you'll see the 

second full paragraph starting with "There was a 

series of meetings", et cetera, where you talk about 

the beta shield and so forth. And then again on the 

very bottom of that page, "Net window density from 

beta exposure alone is equal to actual net window 

density minus net window density from the gamma 

exposure alone. 

DR. NETON: Right. 

DR. BEHLING: And so -- and then again on page 116 

repeats that under 7 --

DR. NETON: Right, and it --

DR. BEHLING: -- and so it tends to --

DR. NETON: Well --

DR. BEHLING: -- you know, multiple -- at multiple 

points in --

DR. NETON: Sure. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

83 

DR. BEHLING: -- in the --

MR. MACIEVIC: No, I --

DR. NETON: What I was going to --

MR. MACIEVIC: No, I agree --

DR. NETON: Greg, if you look at --

MR. MACIEVIC: -- what I'm saying is you're right. 

DR. NETON: -- but if you do look at page 116 I mean 

it gives you the exact references that you need to 

look at. 

MR. MACIEVIC: Yes. 

DR. MAKHIJANI: On page 92 also it has a 

Mallinckrodt reference from the time. 

DR. NETON: Right. 

DR. MAKHIJANI: So I -- I presume it is on the O 

drive (unintelligible) --

DR. NETON: There are three references --

DR. MAKHIJANI: -- I looked at that also. 

DR. NETON: There are three references in here and 

then what -- what kind of looks suspicious is for 

Mallinckrodt it is assumed that the beta readings 

are subtracted so, you know, I don't know if these 

memos were -- were bandying about the issue and --

and thinking about it and how the effects are, so if 

you look into those it'll probably give you --

MR. MACIEVIC: Yes. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

84 

DR. NETON: -- a better feeling for what was 

actually done. 

DR. BEHLING: On that subject, can I make a comment, 

and I -- I don't know who -- who writes these TBDs 

but, you know, I did a -- I was curious. I did a 

word search on this TBD and the word "assume" --

"assumes" comes up 21 times. The word assumed, past 

tense, 175 times, and the word "suppose" comes up 14 

times. Which leads you to question how much is 

there that is really of substance. In fact it -- if 

I point to the page 43, there were -- just in one 

paragraph -- the word "was supposed to be worn", 

"was supposed to be vacuumed", "was supposed to be 

installed", et cetera, and it's --

MR. MACIEVIC: I think you're --

DR. NETON: Well, you know --

 MS. BLOOM: I think we want to represent --

DR. BEHLING: No, I understand. 

 MS. BLOOM: -- what we know and what we don't know -

-

DR. BEHLING: I understand. 

 MS. BLOOM: -- and I think that you'd all have our 

heads if we put it in black and white and --

DR. NETON: We're trying to do reasonable estimates 

of doses here. A reasonable man would take those 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

85 

things and say --

DR. BEHLING: Yeah. No, I understand but --

DR. NETON: So I mean to be fair to the -- to the 

writer, you've got to put that kind of language in 

there, otherwise our lawyers would have our heads. 

DR. BEHLING: The stakeholders will read some of 

that data and -- and sort of wince every time they 

hear the words "were supposed to". 

MR. MACIEVIC: It's equivalent to when you see on 

the news when they say "the alleged killer" does 

this, "the alleged" --

DR. BEHLING: Well --

MR. MACIEVIC: -- I mean you -- you're not going to 

go and commit to saying -- because there is a 

possibility there's more data on other things --

DR. NETON: The bigger -- the bigger issue is with 

"assumed", and I've gotten called to task on this at 

several -- several meetings, public meetings --

DR. BEHLING: So I'm not the first to --

DR. NETON: No, no. The claimants will get up there 

and say this thing is fraught with assumptions. 

DR. BEHLING: Yeah. 

DR. NETON: They assume my exposure was this and 

this. And they're really looking at it from a 

different perspective, which is -- may be correct 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

86 

because they're the claimants. But when we make 

these assumptions in general, we will insert 

assumptions that we believe are generous --

DR. BEHLING: Yeah. 

DR. NETON: -- and claimant-favorable. I hate to 

use that word so much anymore but -- so they are 

assumptions, but that's what science does. I mean 

science makes certain assumptions that bracket the 

truth and reality. You -- you never know anything 

with 100 percent certainty so -- I hear what you're 

saying. I'm sensitive to it, but I'm not sure --

DR. BEHLING: It struck me odd to see that many 

words that assume, assume, assume --

DR. NETON: I think there are some cases --

DR. BEHLING: -- were supposed to --

 MS. BLOOM: That's less than one per page though. 

That's not too bad. 

DR. NETON: Although --

UNIDENTIFIED: Cindy --

DR. NETON: -- I would -- I would say that in 

certain cases like this last one I just read, you 

could probably get by with different language. 

DR. BEHLING: Yes. 

DR. NETON: You know, it's not -- it is assumed, but 

based on the evidence provided, we will use this, 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

87 

you know, that sort of -- but yeah, I -- I agree 

that, you know, it's difficult when you have these 

words, these -- these --

DR. MAKHIJANI: And sometimes there is a disconnect 

between how would you use the word "assumption" in a 

scientific --

DR. NETON: Yes. 

DR. MAKHIJANI: -- tract and in a scientific context 

as opposed to a general sort of literary context in 

which --

DR. NETON: Right, exactly. 

DR. MAKHIJANI: -- you imagine that when you don't 

know anything you make that unfounded assumption. 

There -- there might be some kind of --

DR. NETON: Right. 

DR. MAKHIJANI: -- implication that you're making an 

assumption because you don't know anything --

DR. NETON: Well, exactly --

DR. MAKHIJANI: -- as opposed to making an 

assumption in a scientific context. 

 MS. BLOOM: Based on data. 

DR. NETON: So --

 MS. BLOOM: And I think we do both, and we get 

called to task when we leave it with that very open, 

you know, what I -- this is my best guess. And 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

88 

that's one kind of assumption and that's a very wide 

open one. And then you have your assumption where 

you say okay, they said this and they said this and 

they said that --

DR. NETON: Well, right --

 MS. BLOOM: -- so we have to go somewhere with it. 

DR. NETON: I mean, you know, oftentimes you'll read 

-- I don't -- we assume Class Y, Type Y solubility. 

Well, that's a great assumption for the claimant. I 

mean --

 MS. BLOOM: Uh-huh. 

DR. NETON: -- but they -- they read that, like you 

say, in -- in the general parlance and say geez, 

they had to assume all these things. 

 MS. BLOOM: They didn't know what it was, so --

DR. NETON: They didn't know. 

 MS. BLOOM: Yeah, but we gave you ten times the 

dose. 

DR. MAKHIJANI: Mark, I think --

DR. NETON: Mark, did you have something to say? 

MR. GRIFFON: No, I'm -- I'm assuming we're done 

with this topic. 

DR. NETON: I think we are. We've gone off and... 

Okay. We just have a couple more questions --

 MS. BLOOM: Which -- which --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

89 

DR. NETON: -- and then we're going to get into 

other issues. Do we need to take a break yet or 

should we finish up with these two? I -- I think 

that we'll just take a ten-minute break, if that's 

okay --

DR. MAKHIJANI: That's fine. 

DR. NETON: -- for comfort and --

MR. GRIFFON: What is left, Jim, because I may have 

to bail out at this point. 

DR. NETON: Okay. 

MR. GRIFFON: What topic --

DR. MAKHIJANI: What is left, has NIOSH -- the two 

questions on my list, Mark, are has NIOSH evaluated 

importance of issue of highly variable response of 

films for photons at energies less than 100 keV for 

uranium facilities. It's a kind of a continuation 

of this --

MR. GRIFFON: Yeah. 

DR. MAKHIJANI: -- film badge thing, and then the 

last question, is NIOSH using the open window dose 

as shallow dose for skin testing in breast dose 

estimation. So both of them are kind of 

elaborations of what we've been talking about. 

MR. GRIFFON: Okay. All right. I -- I think -- if 

it's okay, I think I probably won't -- won't come 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

90 

back on. 

DR. NETON: Okay. 

MR. GRIFFON: You guys have got it covered and --

DR. NETON: All right. Then we'll --

MR. GRIFFON: -- I've got work to do. 

DR. NETON: Yeah, well --

MR. GRIFFON: Okay. 

DR. NETON: All right, Mark. 

MR. GRIFFON: All right. Thanks. 

DR. MAKHIJANI: Thank you, Mark. 

DR. NETON: We'll take a -- we'll take a short break 

here. 

(Whereupon, a recess was taken from 10:25 a.m. 

to 10:45 a.m.) 

DR. NETON: We're back from our break and we're 

continuing on. I think we have questions 7 and 8 to 

complete --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- at least on my list --

DR. MAKHIJANI: Right. 

DR. NETON: -- external (unintelligible). 

DR. MAKHIJANI: Okay. Question 7, has NIOSH 

evaluated the importance of the issue of the highly 

variable response of the film to photons at energies 

of less than 100 keV for uranium facilities? So 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

91 

this is kind of a continuation of how you read these 

film badges. Hans, did I --

DR. BEHLING: Yeah, because there is -- there are 

two portions of it. For very, very low energy, the 

film badges underrespond; for somewhat higher, they 

overrespond due to the photoelectric effect that 

obviously for -- for silver bromide and you realize 

that obviously is an issue here. And I think in 

other instances NIOSH has basically generously said 

no, we'll -- we'll -- we won't make a correction. 

We will accept the overresponse and deal with the --

the dose as-is. Is that correct? 

MS. BLOOM: Uh-huh. 

MR. MACIEVIC: Uh-huh. Yeah --

DR. NETON: Yeah. I think it's not -- it's not 

unlike what we've done in other facilities. 

MR. MACIEVIC: Exactly. Yes, it's -- it's true. 

DR. BEHLING: Okay. 

DR. NETON: Yeah, that was -- well, when I saw this, 

I -- my -- my original impression was well, yeah, 

we're going to be overestimating because of the 

overresponse --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- you know, of low energies and --

yeah. It's -- that's what we're doing. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

92 

DR. MAKHIJANI: Okay. Well, that takes care of 

that. 

DR. BEHLING: And -- and the next one is basically 

what we've already touched on and --

DR. NETON: Right. 

DR. BEHLING: -- but for instance if -- if -- I want 

to draw attention to page 48 of the TBD. It does 

make some statements here that again goes to this 

issue of the shallow dose. And -- and -- and I 

guess sort of --

DR. NETON: Where on 48, Hans? 

DR. BEHLING: Top of the first paragraph but middle 

of that paragraph that starts out with "Dose rates 

measured with instruments were combined with time 

measurements", and it says that the gamma doses were 

said to agree well with film badge reading, but not 

the beta doses. And -- and I guess this is -- goes 

all back to the issue of how do we deal with beta 

components. 

DR. NETON: Right. 

DR. MAKHIJANI: Which -- which paragraph are you in, 

Hans? 

DR. BEHLING: I'm at the first --

DR. NETON: First major paragraph. 

DR. BEHLING: -- paragraph on page 48 that starts 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 -- 

24 

25 

93 

out with "As a result". 

DR. MAKHIJANI: Okay. 

DR. BEHLING: And middle of that paragraph it starts 

a sentence, "Dose rates were measured with 

instruments" --

DR. MAKHIJANI: Okay. 

DR. NETON: So --

DR. BEHLING: -- and it just --

DR. NETON: -- you're saying that the instrument 

readings for beta did not measure -- do not agree 

well with film badge readings. 

DR. BEHLING: Film badge data and -- and it goes 

back to the same issue that we've been discussing. 

DR. NETON: Yeah, I think we need to go back and 

Greg needs to review the protocol for --

MR. MACIEVIC: I will, yes. 

DR. NETON: -- looking at the beta doses --

DR. BEHLING: Yeah, yeah. 

DR. NETON: -- and seeing what -- what we have. 

DR. BEHLING: I mean maybe due to the way the -- the 

film was processed that we discussed earlier, maybe 

due to other factors, I don't know and I -- I -- get 

DR. NETON: Well, it's not surprising that if 

instruments -- survey instruments for beta would --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 -- 

18 

19 

20 

21 

22 

23 

24 

25 

94

 DR. BEHLING: Yeah. 

DR. NETON: -- not agree with a -- a badge that may 

have been calibrated theoretically properly --

DR. BEHLING: With uranium slag or something. 

DR. NETON: -- uranium slag, which is what I think 

they've used here. 

MR. MACIEVIC: Yes. Uranium slag is what's used for 

the (unintelligible). 

DR. NETON: Standard uranium slag, so --

MS. BLOOM: Uh-huh. 

MR. MACIEVIC: And I mean yes, the pics and other 

things, too, don't agree well with the dosimeters 

and it's --

DR. NETON: Particularly for these high energy betas 

that we're talking about from -- from uranium, so... 

DR. MAKHIJANI: So we'll get something on two issues 

MR. MACIEVIC: I will --

DR. NETON: Right. 

DR. MAKHIJANI: -- I think. If I might summarize, 

though --

DR. NETON: Sure. 

DR. MAKHIJANI: -- we dealt with question 8, for the 

record. One will be this geometry question using 

this Attila. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

95 

MR. MACIEVIC: Yes, number 3. 

DR. MAKHIJANI: Sort of like Attila the Hun? 

MR. MACIEVIC: Yes. 

DR. MAKHIJANI: As in the Hun? 

MR. MACIEVIC: Yes. 

DR. MAKHIJANI: Because I want to tell Bob 

Anigstein, you know, to maybe look into it. And the 

other will be the shallow dose, this complex of 

questions with --

DR. NETON: Right. 

DR. MAKHIJANI: -- with the shallow dose, how it was 

done, optical density --

DR. NETON: Right. 

DR. MAKHIJANI: -- and so forth. Right, Hans? 

DR. BEHLING: Yeah, yeah. 

DR. MAKHIJANI: Do you have other --

DR. BEHLING: Yeah, I just have a couple of other 

probably insignificant issues, but on page 51 there 

is reference to 100 millirem radium beryllium source 

that might have been the source of neutron exposure 

which I'm not sure are a -- a significant issue here 

if it's, you know, a source that was used in the 

radium and it -- on the bottom of page 51 it talks 

about in the early years --

DR. NETON: Oh, in the Shotgun Laboratory --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

96 

DR. BEHLING: -- Shotgun Laboratory. I don't know 

if that's something that needs to be looked at. 

It's probably something that was used by maybe one 

or two people maybe and has no significance to the 

workforce at large. 

DR. NETON: Well, it -- it talks about that it ended 

by September 1944. 

DR. BEHLING: Okay. In that case it's obviously 

academic anyway. 

DR. NETON: In that case it's not relevant for --

DR. BEHLING: Yeah, yeah. 

DR. NETON: -- this time period. 

DR. BEHLING: I guess in internal exposures, we're 

almost exclusively focusing on inhalation exposures 

as opposed to ingestion. 

DR. NETON: Correct. 

DR. BEHLING: Given -- but given -- yeah, I know. I 

wasn't there yesterday afternoon so I may be 

redundant in some of my questions, but with regard 

to the possibility that people were using their 

hands to shovel stuff and touching stuff and 

obviously there was a significant amount of 

contamination all over the place that people might 

have transferred to their mouth inadvertently when 

they touched their lips or took a cigarette break or 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

97 

a lunch break, whatever it is. The issue is one of 

solubility. It's generally assumed that most metal 

oxides are relatively insoluble but that's usually 

as a result of tests that are done in a neutral 

aqueous solution. When you ingest it obviously 

these materials would encounter the acidity of the 

stomach, which is basically one normal hydrochloric 

acid which considerably changes solubility. Is that 

an issue that needs to be looked at? It wouldn't 

matter if we're dealing with urinalysis which 

obviously doesn't care (unintelligible). 

DR. NETON: Well, that's exactly right. We talked 

about urinalysis --

DR. BEHLING: Yes. 

DR. NETON: -- being okay but --

DR. BEHLING: If -- if it's --

DR. NETON: But the models that are in the ICRP 

default for insoluble at .002 F1 and .02 for the 

moderately soluble material. And I don't think that 

those were done in aqueous media. Those were done 

based on a number of studies, including human 

ingestion studies. 

DR. BEHLING: Yes. I -- I remember doing a lot of 

work in the Marshall Islands where the issue of 

fallout and ingestion of fallout became an issue and 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

98 

when you look at for instance some of the fission 

products that are metal oxides in --

DR. NETON: Right. 

DR. BEHLING: -- in fallout, there is a quantum leap 

between the -- the solubility based on the pH of the 

-- of the solution in which they are being 

dissolved, and of course --

DR. NETON: Oh, sure. Yeah, but I don't -- I think 

that the physiologic models in the ICRP for the GI 

tract, though, are not -- are --

DR. BEHLING: They account for --

DR. NETON: -- we believe them to be representative 

of -- of the absorption (unintelligible) -- I mean 

these were done in animal studies. Now whether the 

pH of a -- of a, you know --

DR. BEHLING: As I said, it's academic if we're 

talking about urinalysis because it doesn't really 

matter how it came -- was transferred from the bowel 

or the gut into the bloodstream, et cetera. Okay. 

DR. MAKHIJANI: Yeah, yesterday -- if I remember 

correctly -- we agreed that ingestion is an issue 

only when you don't have bioassay (unintelligible). 

DR. NETON: Yeah, (unintelligible) urine data we 

will assume it's all inhalation, which provides a 

higher estimate than ingestion pathway. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

99 

DR. MAKHIJANI: Right. And so -- and the issue of 

ingestion in -- when you don't have data sort of 

belongs in how many -- this question of how many do 

you have actually that don't have --

DR. NETON: Correct. 

DR. MAKHIJANI: -- data for Mallinckrodt, and then 

generally you're addressing it in some broader way. 

Right? 

DR. NETON: Correct. 

 MS. BLOOM: Uh-huh, with -- with --

DR. MAKHIJANI: Is that right? 

 MS. BLOOM: -- TIB-9. 

DR. MAKHIJANI: Okay. Hans, ready for more? 

DR. BEHLING: No, I'm through here. No, I -- I'm 

sure we covered the other issues yesterday so --

DR. MAKHIJANI: Make a very, very quick check of my 

-- of our review --

DR. NETON: Uh-huh. 

DR. MAKHIJANI: -- and that table just to see that 

I've gone through it. I think we've gone through 

everything. 

(Pause) 

DR. MAKHIJANI: Oh, yeah. This -- Revision 01 of 

the TBD says external dose calculations on hold. I 

think you addressed this at the meeting. Right? 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

100 

DR. NETON: Yeah, yeah. We talked about that. 

DR. MAKHIJANI: About coworker. 

DR. NETON: Right. It's only on hold for people who 

we don't have monitoring data for. So again, we get 

back to this relevant issue --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- how many people do we have data --

DR. MAKHIJANI: Right. 

DR. NETON: -- and for those who don't, we -- the 

coworker distributions are tended to be applied. 

DR. MAKHIJANI: Right, so we've covered that. 

DR. NETON: I believe so. 

DR. MAKHIJANI: I think that we are -- we are done. 

We -- is there a -- okay, here -- one -- one maybe 

last thing is, is there a difference between how we 

might handle infrequent incidents like uranium fires 

compared to the more frequent ones that we kind of 

agreed probably we've taken care of? 

DR. NETON: With urine monitoring data available? I 

don't think so. I think it's -- it's -- as the 

incidents become more and more frequent, it becomes 

a closer and closer approximation to a chronic 

exposure. 

DR. MAKHIJANI: Oh, yeah. That I agree. 

DR. NETON: But for -- but for very infrequent 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

101 

incidents, it's -- it's equally as valid that this 

chronic exposure scenario brackets the --

DR. MAKHIJANI: The way you -- the way you model it 

with the highest point --

DR. NETON: Right. 

DR. MAKHIJANI: -- is that how you normally do it? 

DR. NETON: Yeah. 

 MS. BLOOM: If -- if there was information that 

showed that you had a peak in your data somewhere, 

you would model that. And we've been looking at 

that both in terms of the coworker studies --

generally it's a small chronic that you use to model 

an incident because there's -- there's a cleanup 

period and there's a -- there's higher exposures 

associated with a number of things, but the -- the -

- I don't know about Mallinckrodt but I think 

probably my sense is that the urinalysis data is --

one of the significant exposure scenarios is from 

fires and they tended to be fairly routine in the 

early days. I think that it -- it was part of the 

ambient atmosphere in the workplace. 

DR. MAKHIJANI: Yeah, there were uranium fires. I 

know the -- we have some idea of what the frequency 

was. 

 MS. BLOOM: I mean you had some bigger ones --
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

102 

DR. MAKHIJANI: So very frequent --

 MS. BLOOM: -- but I think you have some small sort 

of routine --

DR. MAKHIJANI: Yeah. 

 MS. BLOOM: -- incidents at a number of facilities. 

DR. MAKHIJANI: Yeah. The -- the -- the reason I 

raise it, in looking at my list here, is that I -- I 

think by now we know that -- that blowouts were 

pretty -- frequent enough that they would fall into 

this umbrella, you know, that it will be covered by 

a routine exposure assumption. But I don't have an 

idea about the -- I've not seen any documentation or 

worker evidence about the frequency of fires, which 

is why I raise that question. It may not be an 

issue. 

DR. NETON: But again, I think if you go the other 

extreme where you have very infrequent incidents, 

then it's an even stronger case that the chronic 

exposure will bracket that because you have a very 

short spike in an exposure for a period of -- of a 

day. Yeah, we're giving this chronic that brackets 

the entire, you know --

 MS. BLOOM: I've done a lot of modeling --

DR. MAKHIJANI: I -- I think that that's --

 MS. BLOOM: -- where they have that coworker data 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

103 

and I've got this chronic; I've got an incident here 

and I've got some more data out here, and if I model 

that as a chronic exposure, it pulls it up to this 

later, more acute type of data. It pulls up my 

curve. If I drop out that incident data and model 

my low level chronic and then add my short term on 

it, you can see that the area under the curve is 

much lower and that gives me much lower intakes. 

DR. MAKHIJANI: Yeah. Well, Dave said that he was 

going to send --

 MS. BLOOM: Yeah. He's --

DR. MAKHIJANI: -- me something along those lines --

 MS. BLOOM: -- working on that. 

DR. MAKHIJANI: -- actually if there were a couple 

of examples -- or specifically an example --

 MS. BLOOM: Well, actually --

DR. MAKHIJANI: -- with one incident --

 MS. BLOOM: -- the Simonds data --

DR. MAKHIJANI: -- that would actually be very 

useful. 

 MS. BLOOM: -- or not the Simonds, the -- the 

Bridgeport Brass data that's not out yet, but the 

graphs on that in the draft site profile show that. 

DR. NETON: Right. We -- we run into this -- and 

this is going to be valuable to do for several 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

104 

reasons. We've run into this with comments on 

Chapman Valve. There was a fire at Chapman Valve. 

We don't know exactly when the fire occurred --

 MS. BLOOM: Actually that's in there, too. 

DR. NETON: -- but -- but we have a lot -- we have 

monitoring data well after the fire. But if you --

you take these chronic intake scenarios, it -- it 

does account for the fact that there may have been a 

fire, and we believe that we had bracketed the 

exposure -- because you need to look at the 

integration of the curve in microcurie days, coming 

out as microcurie per liter days. And a chronic 

intake scenario will -- will, at the end of the day, 

be equivalent, if not more claimant-favorable. 

DR. BEHLING: Is there any evidence from your review 

of the bioassay data that bioassays were conducted 

in response to specific incidents as opposed to 

routine? I mean does a bioassay tell you that this 

is a routine versus in response to a radiological 

incident? 

DR. NETON: I think there are codes, yeah. But I 

think -- yes. I think that's true but, you know --

 MS. BLOOM: Frequently you can see the frequency 

change --

DR. NETON: Right. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

105

 MS. BLOOM: -- or you see (unintelligible). 

DR. NETON: But that really doesn't matter too much 

for our purposes, whether it was a routine or an 

incident. We're going to have a curve that goes 

through all the data points. In fact, if it were a 

response to an incident, we would be more generous -

-

DR. BEHLING: You would be -- (unintelligible). 

DR. NETON: -- because we would be assuming that --

DR. BEHLING: Yes. 

DR. NETON: -- it was all --

DR. BEHLING: Yes. 

DR. MAKHIJANI: No, I -- I tend to agree, it's just 

that it would be nice to have the actual example --

DR. NETON: We'll try --

DR. MAKHIJANI: -- (unintelligible) cite that. 

DR. NETON: -- and we -- I'm hoping Dave got the 

message. We're going to try to tie it to a -- a 

real case --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- so that we're not doing a 

hypothetical anymore. 

 MS. BLOOM: Uh-huh. 

DR. NETON: Yeah. 

DR. MAKHIJANI: A real case. Okay. 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

106 

DR. NETON: Okay. Well, that's great. 

DR. MAKHIJANI: I think we are done. Thank you. 

DR. NETON: I think this was a very good discussion, 

worked out much better than I thought given that I 

didn't think we were quite ready. But I think we --

we did get through a number of issues and I think --

DR. MAKHIJANI: Yeah. 

DR. NETON: -- worked out well. 

DR. MAKHIJANI: Thank you. 

DR. NETON: Okay. 

(Whereupon, the meeting concluded at 11:00 a.m.) 
_____________________ 

107 

C E R T I F I C A T E 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 June 2, 2005; 

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 

20th day of July, 2005. 

STEVEN RAY GREEN, CCR 

CERTIFIED MERIT COURT REPORTER 

CERTIFICATE NUMBER: A-2102