CENTERS FOR DISEASE CONTROL AND PREVENTION

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH

ADVISORY BOARD ON RADIATION AND WORKER HEALTH

SAVANNAH RIVER SITE (SRS) MEETING

WEDNESDAY, MARCH 22, 2023

The meeting convened at 11:00 A.M.

EDT via video teleconference,

Brad Clawson, Chair, presiding.

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Members Present:

Brad Clawson, Chair

Lockey, James, Member

Pompa, David, Member

Ziemer, Paul, Member

Registered Participants:

Roberts, Rashaun, DFO

Adams, Nancy, NIOSH contractor

Barton, Bob, SC&A

Buchanan, Ron, SC&A

Calhoun, Grady, DCAS

Cardarelli, John, NIOSH

Chalmers, Nancy, ORAU TEAM

Fitzgerald, Joe, SC&A

Gogliotti, Rose, SC&A

Habighurst, Ashton, HHS

Nelson, Chuck, DCAS

Robinson, Sallie

Sharfi, Mutty, ORAU

Taulbee, Tim, DCAS
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TABLE OF CONTENTS

Advisory Board on Radiation and Worker Health Savannah River Site (SRS) Meeting 

Wednesday, March 22, 2023............................................................................................................. 1

Proceedings.......................................................................................................................................... 4

Welcome and Roll Call ................................................................................................................. 4

Background................................................................................................................................... 6

NIOSH Presentation: Response to SC&A’s Focused Review........................................ 7

SC&A Presentation: Focused Review of ORAUT-RPRT-0092, Revision 00, and 

Remaining Petition SEC-00103 Evaluation Report Period 1971-2007....................79

Discussion.......................................................................................................................................99

Open Issues and Paths Forward ..........................................................................................126

April 2023 ABRWH Meeting ...................................................................................................132
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PROCEEDINGS

(11:00 a.m.)

Welcome and Roll Call

DR. ROBERTS: Good morning, everyone. Welcome to the Advisory 

Board on Radiation and Worker Health's meeting of the Savannah River Site 

Work Group. My name's Rashaun Roberts, and I'm the DFO for the Board. 

The agenda, presentations, and other materials and information for 

today can be found on the NIOSH website under scheduled meetings for 

March of 2023. 

So, with that brief welcome and orientation, I'll go ahead and move 

into our roll call. Since Board Members who have conflicts with regard to 

this site can't sit on this work group, there are no conflicts of interest for the 

work group members; however, as I go through the roll call, other staff do 

need to state any relevant conflicts. 

So let's go ahead and start with the work group chair, Clawson. 

CHAIR CLAWSON: Sorry, had to unmute there. I had the sun in my 

eyes. Yes, I'm here.

DR. ROBERTS: Okay, great. Lockey?

MEMBER LOCKEY: Yes, I'm here. 

DR. ROBERTS: Pompa? Okay, is Ziemer here? 

MEMBER ZIEMER: Yes. 

DR. ROBERTS: Let's go on to NIOSH/DCAS and ORAUT.

MR. CALHOUN: Hi, this is Grady Calhoun. I have no conflicts here.

DR. TAULBEE: This is Tim Taulbee. I have no conflicts at Savannah 
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River.

MR. NELSON: This is Chuck Nelson. I have no conflict at Savannah 

River. 

DR. ROBERTS: Anyone else for DCAS/ORAUT?

DR. CARDARELLI: Yes, I'm sorry, I was on mute, and I have no 

conflicts. 

DR. CHALMERS: Nancy Chalmers, ORAU Team, no conflicts at 

Savannah River.

DR. ROBERTS: Anyone else, D -- 

MR. MAHATHY: Mike Mahathy -- Mike Mahathy, ORAU Team, no 

conflicts Savannah River. 

DR. ROBERTS: Thank you. Okay. Hearing no more from 

NIOSH/ORAUT, let's move on to SC&A. 

MR. BARTON: Bob Barton, SC&A, no conflicts. 

DR. BUCHANAN: Ron Buchanan, no conflicts.

MR. FITZGERALD: Joe Fitzgerald, SC&A, no conflicts.

MS. GOGLIOTTI: Rose Gogliotti, SC&A, no conflict. 

DR. ROBERTS: Anyone else from SC&A? Hearing none, let's move on 

to HHS and contractors.

MS. HABIGHURST: Ashton Habighurst, HHS, no conflict. 

MS. ADAMS: Nancy Adams, NIOSH contractor, no conflict. 

DR. ROBERTS: Okay. Is there anyone here from DOL or DOE? 

Hearing none, let me ask if there any members of the public who would like 

to register their attendance of this meeting. 

Well, thank you, and again, welcome to you all. I need to go over a 
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couple of items before I give the floor over to Brad Clawson who chairs this 

group. In order to keep everything running smoothly and so that everyone 

speaking can be clearly understood, please, everyone mute your Zoom or 

your phone when you're not muting -- when you're not speaking. The mute 

button for Zoom is in the lower left-hand side of your screen. If you're 

attending this meeting via telephone, press star six to mute if you don't 

have a mute button. If you need to take yourself off mute, press star six 

again. 

Again, the agenda, presentations, and background documents that are 

relevant to today's meeting can be found on the NIOSH and DCAS website 

and all of the materials were sent to Board Members and to staff prior to this 

meeting. 

Before I turn over to you, Brad, let me check one more time and see if 

Pompa has joined us. I don't hear him, but we do have a quorum so we can 

go ahead and proceed. Brad, over to you. 

CHAIR CLAWSON: Thank you, Rashaun. Good to see everybody or at 

least hear their voices and everything else. It's been a long time since we 

did this. 

Background

CHAIR CLAWSON: Rashaun wanted me to give a little bit of a 

background on Savannah River and how we've gotten to where we're at and 

everything else. Tim, you'll probably have to help me on this, but I think 

this whole thing with Savannah River almost started almost 14 or 15 years 

ago. Is that -- is that not correct, or has it been even longer? 

DR. TAULBEE: We received the petition in December of 2007 and 
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really got -- I don't think we qualified it until 2008, so yeah, it's been about -

- about 14 years, 13-14 years, somewhere in there. 

CHAIR CLAWSON: Okay. So, we've been -- we've been working on --

thank you, by the way. We've been working on this for a long time, and 

we've -- we've come to a point where we're getting near the end of these 

parts. So on July 12, 2001, the Board recommended an SEC for 

subcontractors from '72 to '90. This was October 12, 2021, it was registered 

on the federal registry for that date.

Also, on April 22, 2022, SC&A issued a focused review of ORAUT-0092, 

Rev. 0 and the remaining petition of the SEC-103 evaluation report for 

'91 -- 1991 to 2007. It was kind of my understanding what we're looking at, 

at this point is where does the data completeness come and where can we 

make the cutoff in these later years. We've tried to make it as easy as 

possible in the early -- to -- to have a defined cutoff, but there was several 

other things, so that's why we went with 1990.

On November 22, 2022 -- on June 5th we received NIOSH's response 

to SC&A's focused review of 0092, and this is where we're at to date. And 

we're going to review this now and go on. Is there any questions of, kind of, 

how we got here and what -- any questions that anybody has? 

Okay, with that being said, we're going to let NIOSH start out, Mr. 

Cardarelli, John, to start into their presentation and explain their review to 

us. And with that, I'll turn it over to you, John.

NIOSH Presentation: Response to SC&A’s Focused Review

DR. CARDARELLI: Okay, thank you Mr. Clawson. I'm going to share 
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my screen. I'll pull that off screen. I'm kind of -- I think, everyone, I'm 

going to be working from the PDF file that was downloadable off of the 

internet off of our website. So before we get started on this, this a little 

unusual, because I'm actually going to be presenting our response to SC&A's 

focused review, which has yet to be presented to the workforce -- or to the 

work group. But so I'm going to ask that SC&A be prepared to provide 

additional background or context if there's any confusion associated with the 

material I'm presenting here because I -- we drafted this presentation, kind 

of to be a situation where we're responding, so we didn't include all the 

details in the background as we would have done had we known we'd gone 

first. But that said, I think we're going to be fine. 

This is a co-presentation with myself and Dr. Chalmers, who's the 

ORAUT statistician who did a lot of the statistical work in the sampling plan 

that we're going to be talking about, with regard to our responses to their 

review.

MEMBER ZIEMER: Brad, this is Paul. Could I ask a question before 

John continues? Is there a reason -- 

CHAIR CLAWSON: Sure. 

MEMBER ZIEMER: -- we're not having SC&A's presentation first? 

CHAIR CLAWSON: No, I -- I -- I -- I kind of felt that, because SC&A 

had not got their final revision put in, they're still in evaluation mode, so I 

thought that it was better that NIOSH goes first on this, because -- so this 

was kind of my thing, and I'm sorry if this created a problem, John, or 

whatever. But my -- so I had Rashaun update the agenda, and that should 

have been sent out yesterday. 
9 

But I do have a question for you, John. So, do you want us to stop 

you, or do you want us to allow you to go through the presentation and then 

come back and review these things? 

DR. CARDARELLI: Well, I'm open. I think that if we have an open 

exchange, stop when there's clarification or questions, because there may 

be those times as we go through this. So I'm very comfortable if -- if folks 

have questions to stop during the talk. 

CHAIR CLAWSON: Okay. Because, you know, I was going to suggest 

that we can do that because I believe there's 38 or 40 pages on this and 

then to be able to come back and review, go back through it all, I think it'd 

probably be better to be able to step through these, go from there, if that's 

all right with you, but I also don't want to put you off path either. 

DR. CARDARELLI: No, no, it's good. Thanks, Mr. Clawson, I 

appreciate that.

MEMBER LOCKEY: Hey, John and Brad, Jim -- Jim Lockey. I agree. I 

-- I have a -- I went through with questions on each page or every other 

page or so that I just need some clarification for my own edification. So, I --

I think it'd be -- I agree, better to go through it as -- questions as the 

presentation is being made. I think that to be more educational, particularly 

to new Board Members in may be listening about how this process works. 

DR. CARDARELLI: Excellent, thank you Dr. Lockey. Okay. All right. 

So, the presentation is going to be a brief introduction. I think Mr. Clawson 

did a good job of summarizing that, and then we will also get into the five 

conclusions that were derived from the SC&A's focused review of our report 

92, and then our overall conclusion, which is a single slide. 
10

So the introduction is really based upon the report 19 -- 92, which is 

entitled "The Evaluation of Bioassay Data for Subcontractor Construction 

Trade Workers at the Savannah River Site." The original purpose was to use 

the radiation work permits sampling plan, a sampling plan for those -- to 

determine whether or not subcontractor construction trade workers were 

sufficiently monitored by bioassay such that their radiation doses could be 

reconstructed with sufficient accuracy. That was the purpose of the site 

focused on subcontractor construction trade workers. 

I won't go through this in great detail, but it just gives a 

demonstration of the time line. This is a multi-year effort. It started in 

2018, of which NIOSH worked with SC&A, and we had many technical calls 

to come up with what we call a final sampling plan, which was to look at 

radiation work permits that were available on site. We executed that plan in 

mid-2018. And we eventually received that data near the end of 2018. 

Shortly after that, in 2019, NIOSH produced a report, that was report 

92, of which the first round of comments were received later that year. And 

then we had a response paper to SC&A at that point, and then they had 

another review around -- a review on that particular response paper. And 

then between that and now, the Board added the SEC class up through 

1990, from 1990 -- 1972 to 1990 for subcontractor construction trade 

workers for all radionuclides. So we're really going to start focusing now on 

the period after 1990, which is kind of what their focused review is looking 

at, that time period, post 1990. And then this presentation is our response 

to that focused review. 

So, in summary, really, the SC&A conclusions were, basically, five. 
11

The first one was they concluded that the sampling premise was not 

sufficiently grounded in historical Savannah River site practices. The second 

one was results for direct and effective monitoring may be overstated. The 

third was the generalized matching is not sufficient. And the fourth was 

radiation work permits specified job-specific bioassay data are incomplete. 

And the fifth conclusion was the feasibility of a coexposure model needs to 

balance radiation work permit implementation with completeness of 

coworker data. And I really want to stress here that the focus has shifted 

from the feasibility of developing -- or feasibility of dose reconstruction to 

whether or not there's feasibility for developing a coexposure model, okay? 

CHAIR CLAWSON: Hey, John. John, let me -- let me -- let me 

interrupt you on -- on that one. 

DR. CARDARELLI: Sure. 

CHAIR CLAWSON: I want you to -- I want you to explain that a little 

bit more to me because I -- I -- 

DR. CARDARELLI: Okay. 

CHAIR CLAWSON: I -- I have not -- I -- I have not seen anything that 

we're changing from completeness and everything else going to a feasibility 

of a coexposure model. That's -- that kind of got me lost a little bit there, so 

if you could explain that a little bit more in detail, l'd appreciate it. 

DR. CARDARELLI: No problem. Obviously, in the past, we've 

concluded in our presentations that we could do dose reconstruction for 

subcontractor construction trade workers. The Advisory Board voted to 

make it an SEC class. Part of a dose reconstruction effort is developing what 

we call coexposure models, and they help us fill in doses to workers who 
12

may not have been monitored but were exposed or believed to be exposed. 

So, part of a dose reconstruction is -- and to be claimant favorable, we 

want to develop these coexposure models to provide dose estimates to 

workers who may have been exposed but were unmonitored. If it is 

determined that a coexposure model cannot be developed, then we would 

not be able to add doses to those workers, which would lead to less claimant 

favorable adjudication process because we couldn't add those doses to a 

worker potentially exposed who may have not been monitored. 

And the big picture of the dose reconstruction is we want to estimate 

what their potential doses are in a claimant favorable manner. So, we need 

to make sure that we do our due diligence to create coexposure models to 

be claimant favorable as part of the overall dose reconstruction process.

Does that answer your question, Brad? 

CHAIR CLAWSON: Not -- not really, because I -- I really haven't run 

into this before because I -- I think before you can even do this coexposure 

modeling, we still have to answer the question of the data according to IGO -- IG-006, we still have to do a completeness. And this is why -- this is 

why this one really kind of put me aside here. 

I'm trying to figure out -- because we -- I don't think that we've ever 

really got into this coexposure stuff before with any of these SECs. This is --

this is the first time that this has really came to us, and this is why I was --

I'm kind of baffled by this. 

So, I see Bob that you're -- you're there, so I'll -- I'll let you ask the 

pertinent questions, I guess. 

MR. BARTON: Yeah, thanks, Brad. I -- I -- I guess, maybe our 
13

question is what's the distinction between feasibility of dose reconstruction 

and feasibility of coexposure modeling if you can't fill in the gaps for exposed 

-- exposed workers who are unmonitored. But, I guess, what's the 

difference between these two? I -- I don't -- I don't get how the focus has 

shifted or how these are how these two aren't actually tied at the hip. 

DR. CARDARELLI: Well, in essence, they are tied very closely 

together. If a worker -- by the way, we believe that there is plenty of data 

to develop a coexposure model to provide a dose estimate to a worker who 

may have been exposed but was unmonitored, okay. That's the whole 

purpose of the coexposure model. That helps us in our dose reconstruction 

effort, and it's also very much claimant favorable. 

So, when you shift the focus away from doing a dose reconstruction 

because you think that the data is incomplete, does that prevent us from 

developing a coexposure model? The answer is no; we can still develop a 

coexposure model because data completeness is a different issue for dose 

reconstruction than it is for coexposure modeling. Oftentimes we use a little 

bits of data. Sometimes it could be source data, air monitoring data, it could 

be production data, all to give us an indication of what the potential 

exposures might be. 

So, completeness of a bioassay program, it would be one part of a 

dose reconstruction process, but we could develop a coexposure model to 

estimate intakes using air monitoring data or source data. So coexposure 

models can be developed using a variety of different data to help us with a 

dose reconstruction effort. So, completeness is a separate issue on 

coexposure models. 
14

MEMBER LOCKEY: So, John, this -- 

CHAIR CLAWSON: Brad. The -- oh, I'm sorry, Jim, go ahead. 

MEMBER LOCKEY: Thanks, Brad. 

So, if I -- I hear what you're saying -- correct me if I'm wrong -- you 

can do a -- you can look at whether you have a coexposure modeling, and if 

you can't do coexposure modeling, then you probably could not do dose 

reconstruction, correct? 

DR. CARDARELLI: Likely, yes. 

MEMBER LOCKEY: Okay, but you could -- you could have -- you could 

-- it's feasible to do coexposure modeling, but you still may not have enough 

to do -- to determine if it's feasible to do dose reconstruction. That's also

then correct, right? 

DR. CARDARELLI: Yeah, for individuals, correct. 

MEMBER LOCKEY: Okay. So I think I understand what you're saying. 

Okay.

CHAIR CLAWSON: Okay. Now, I need to get a little bit of clarification 

here. Because you're telling me that feasibility of coworker exposure model 

has nothing to do -- that just has to do with dose reconstruction, that does 

not have to do with completeness of the data and the ability to be able to, 

basically, do dose reconstruction. This is where I'm lost in this, because we 

still have not concluded of when we have sufficient data and completeness. 

And so this is why now you're throwing in this feasibility of a coexposure 

model when we haven't even completed that. Now -- now, if this is 

something you guys do in your dose reconstruction part of it, that's all well 

and fine. But as the work group here, we still haven't -- we still haven't 
15

done the completeness. 

DR. CARDARELLI: Well, -- 

CHAIR CLAWSON: If we don't have completeness, we can't do dose 

reconstruction. That's where an SEC comes in on this. 

DR. CARDARELLI: In it's simple -- 

CHAIR CLAWSON: And so -- 

DR. CARDARELLI: Sorry. Sorry, go ahead. 

CHAIR CLAWSON: I'm sorry. I -- I -- I'm trying to grasp -- my head 

around what you've been saying. 

DR. CARDARELLI: And we will talk a little bit about this later in the 

presentation, but I would say, as an extreme example, extreme example 

here, if we knew that we had the most highly exposed person who was 

exposed at that site at that time, and we only had one bioassay sample from 

them because we know that they were the most highly exposed -- that's one 

person, one example -- it's just a very extreme example -- but that could be 

a bounding source if we knew that that person was the truly most highly 

exposed person. We could use that one person's exposure to represent 

potential exposures for everyone else at the site and have it be bounding. 

In other words, it's -- no one else is going to have a higher exposure 

than that one individual. So in essence, that could be a coexposure model 

where we've taken it from one individual and applied it to everyone else at 

the site knowing that that one individual was the highest exposed person. 

So that's what we mean by coexposure model as opposed to being 

able to apply completeness to the entire site. And we do this already with 

some of our other sites where we apply generic correction factors. Those 
16

are, in essence, a coexposure model by applying a fixed factor to a potential 

intake. 

Here we're using bioassay data because there's so much of it that we 

can develop a better exposure model, one that is more accurate, more 

sufficiently accurate, than relying on a single number or a single air sample. 

Most of the ambient air sampling that we do, where we provide doses 

to workers, that's simply a coexposure model based upon ambient air 

samples at the site where workers work. So here, we just want to develop a 

coexposure model to subcontractor constraint work -- subcontractor 

construction trade workers who have been monitored for various 

radionuclides, and the data's there, and we can produce that. 

CHAIR CLAWSON: But that's -- that's not what IG-00 (audio 

interruption) -- this is where this is throwing me off, because (audio 

interruption) is even before your time when we started to pull in the 

information for this, your -- NIOSH's whole sole case was that they had all of 

the RWPs, they had every -- we went -- they went on such a -- we're getting 

all of this data, we have 300 boxes over here, we have 200 boxes over here. 

We -- we went on a data capture for years, because the process -- and I'm 

just going to -- John, understand, I'm trying to wrap my head around this. 

So if I say something that isn't -- it seems like to me that we've been 

going off RWPs and everything else like that and the data collection and 

complying OG -- OGC -- this -- this is totally shifting from what we were 

doing to something different now is what it appears to me. 

DR. CARDARELLI: This -- 

CHAIR CLAWSON: Now I can be wrong. I'm just telling you that this 
17

whole thing is -- is -- we've been -- we've been going this way, and now all 

of a sudden, we want to go this way. 

DR. CARDARELLI: I -- 

CHAIR CLAWSON: That's what I -- 

DR. CARDARELLI: Mr. Clawson, I would agree with you. And I think 

that, really, our interpretation -- again, this is from the SC&A's review where 

they have shifted this focus, not NIOSH. So, what we're responding to it -- 

CHAIR CLAWSON: No, no, no, no. 

DR. CARDARELLI: -- in that context. 

CHAIR CLAWSON: I -- where -- where does that -- where does that 

come in? Where -- where do you -- 

DR. CARDARELLI: I'll have to bring up their document and -- and 

show you, but I think if we ask SC&A to define that, that would be fine. But 

that was our response to them is we believe that you are shifting the focus 

from dose reconstruction to whether or not we could even create a 

coexposure model. We believe we can create a coexposure model. And 

using the IG, the Implementation Guide, for dose reconstruction and 

applying the coexposure model may not be appropriate or adequate. But I 

see that Dr. Taulbee just came on board here. Tim? 

DR. TAULBEE: Yeah. Brad, if I can kind of paraphrase some of this of 

where we see -- how we felt that there was a shift here is that there's a lot 

of focus on the completeness of the coexposure model. In the example that 

John gave of just one person if you know that they're the highest exposed 

could be used to bound the dose reconstructions is that shift that we are --

that we seem to be seeing here. And, you know, the data completeness 
18

associated with IG-6 is something that, you know, has been asked by the 

Board for us to clarify, and we're working on a white paper from that 

standpoint that goes through some of these examples. And John, later in his 

presentation, will be giving more details about that, give examples of where 

this completeness focus isn't really as critical as SC&A seems to have 

portrayed it in this most recent focused review. 

So, if I could make a recommendation here. If we get -- if you could -

- if we could move on from this one and move to later on, there's another 

slide that I believe John has that will go into three different examples about 

this completeness that will, hopefully -- hopefully, explain this a little better 

to you. Does that make sense, sir? 

CHAIR CLAWSON: Yes, it does. I -- I have no problem with this 

because we can always come back, and we can go to this. And this is one of 

the things I was worried about was -- because I'll tell you what, I do have a 

lot of questions throughout your whole presentation. 

But we'll -- I'll let you continue on there but -- but I -- I do want to 

ask SC&A, because I will be honest with you on this, I have gone back I've 

pulled the transcripts from our last three meetings on this, and I have never 

ever come up with at any point that we ever questioned into this coexposure 

model. 

Now, there's been things that have popped up where we have talked

that we couldn't -- coexposure models are great, but we could not do 

anything with them until we got the completeness done. So, that -- that's --

because I will be honest, since I've got your -- I have be combing through a 

lot of transcripts, and I haven't run across anything. 
19

So SC&A, maybe I'm wrong on that. Maybe you can just keep in the 

back of your mind. We'll -- we'll let John continue on, and we'll -- we'll raise 

other issues that come up. But I would like to be able to have that 

addressed because I can't -- I could not find anything in my searches for 

that. But -- but that doesn't mean it isn't out there. There's awful lot of 

data out there that I went through. 

So, you have any problems with that, Bob? 

MR. BARTON: No, I have -- I actually agree with Dr. Taulbee that we 

might be getting ahead of ourselves here and we need to move on. 

MEMBER ZIEMER: And Brad, could -- Brad, this is Paul. Could I add 

one other comment? Perhaps -- 

CHAIR CLAWSON: Sure. 

MEMBER ZIEMER: Perhaps the use of the word "shifted" is unfortunate 

because ultimately, we still are doing dose reconstructions. That's the whole 

point. And, you know, if you had complete data from one -- on a claimant, 

you can do a dose reconstruction. If you lack data on that claimant, then 

you look at whether or not you can do it -- do dose reconstruction through 

the coexposure model. But ultimately, we're not moving away -- I don't 

think we're moving away from dose reconstruction; we're just right now 

having to focus on whether we have an adequate coexposure model that will 

allow dose reconstruction in those cases where the data is not sufficient. 

CHAIR CLAWSON: Well, you know what, Paul, I greatly appreciate 

that. That's, as usual, you're -- you're very well versed, and I appreciate 

that input. So, John, I apologize. Maybe we got sidetracked there. I'll let 

you continue on with this and -- and -- maybe things will become a little 
20

clearer -- 

DR. CARDARELLI: Okay. All right. 

CHAIR CLAWSON: -- to me. Thank you. 

DR. CARDARELLI: Thanks. And, you know, I'm glad we're having 

these -- this discussion. I think it will make for further slides to be a little bit 

more efficient -- or further discussions on those, so. 

All right. I wanted to jump right into the -- our response to their 

conclusion number one, which was based on the sampling premise was not 

sufficiently grounded in historical SRS practices. So, what -- what is --

exactly is being said here. And this particular table shows the monitoring 

percentages from the years 1991 through 1998, which is that sub area of 

focus that the SC&A did their review on, and it's for five radionuclides, the 

plutonium, the strontium fission, americium, uranium, and neptunium. 

And they're -- for plutonium, you can see it's 0 percent were 

monitored that were based upon on a review of 16 radiation work permits 

that were collected through that statistical sampling plan that was discussed 

in 2018.

So we want to understand why 0 percent would show in 1991 and then 

eventually rise to 78 percent in 1994 and 100 percent in 1995. And as you 

can see, for all five these radionuclides, the number of radiation work 

permits that are associated with estimating these monitoring percentages. 

So I will focus on plutonium because it's where we have a lot of data, and it 

kind of demonstrates how the conclusion came about. 

So, for the 78 percent of plutonium that was monitored in 1994, that 

came from 32 radiation work permits, or 25 of them, they were sampled 
21

from 1994 and they have plutonium marked -- this is the key thing. 

Plutonium was marked on the radiation work permit by which we could make 

that determination. We're assuming that the other 22 percent, or the seven 

remaining that couldn't find any information on, required plutonium 

bioassay. So, this rise or a perceived trend in the monitoring percentages 

from 0 percent in 1991 to 78 percent 1994 to 100 percent in 1995 really is 

driven by a procedure of the bioassay program, not by the radiation work 

permit because the radiation permits were substantially different in those 

time periods. 

So, it's not a reflection of monitoring percentages; it's a reflection that 

the actual radiation work permits were different. In the early '90s, those 

forms did not indicate which radionuclides should be included in the 

bioassay. By the middle to late 1990s, those forms did have that 

information. 

And that is kind of shown here on this particular slide where I provide 

examples of radiation work permits. And the one on the left is a radiation 

work permit in 1992. It talks about the time and exposures, but you'll 

notice the one on the right, which is a radiation or permit in 1997, it 

specifically has boxes, checkmarks, associated with what they've called jobspecific bioassay requirements. So, in 1992, there was no indication of 

which radionuclides would be needed because by procedure they knew the 

location. And by the procedures at the time, they would be on a routine 

monitoring program and that area that they're working in would have 

identified which radionuclide be done. But the RWP doesn't contain that 

specifics. The specifics are in the procedures. 1997, the procedures get 
22

modified slightly and now they include very specific radionuclides. So, 0 

percent is understandable in 1992 because there's nothing on the RWP to 

suggest it. In 1997, 78 percent or 1998, 100 percent when they have that 

information. 

So that's -- that's really what we're trying to point out here is this rise 

and trend is really driven by RWP format not by the practices at the site. 

And that's pointed out in this slide here. So, the purpose of the radiation 

sampling plan, or radiation worker permit sampling plan, we were targeting 

to estimate the percentage of the monitored subcontractor construction 

trade workers to within 5 percent with a 95 percent confidence. So it was 

a -- it was a very complex statistical sampling model that Dr. Chalmers had 

to develop in combination with reviews with SC&A before we implemented 

that strategy. 

So the uncertainty in the percentages of monitored subcontractor 

construction trade workers, we wanted to calculate that. So uncertainty in 

anything else, we cannot because we didn't collect the data and we didn't 

design the sampling plan to do that. What we did was the year in which 

things were inventoried, but we didn't look specifically and design a 

sampling plan by the specific radionuclide. So, the uncertainties in the SC&A 

table two, which was presented a few slides earlier, frankly are unknowable 

because it wasn't designed to answer that question. The sampling plan 

wasn't designed to answer that question. 

So our conclusion in response to SC&A's conclusion, which was the 

sampling premise is not sufficiently grounded in historical SRS practices, 

well, it's based upon change from the procedure or a change in the different 
23

types of RWPs versus a monitoring practice. Any conclusion drawn from 

comparing the statistics with unknowables -- uncertainties is certainly 

suspect. And the presence of bioassay requirements on all the RWPs is not 

necessary for coexposure modeling. 

And what's really interesting, and it's worth noting at this point is, if 

we did not have a single RWP, if the site would have destroyed them, if they 

would have been lost in a fire, I'm talking about RWPs, we could still do a 

dose reconstruction because we have the bioassay data. And a RWP is not 

required to do a coexposure model. An RWP is not required to do a proper 

dose reconstruction with sufficient accuracy. The bioassay data would be 

helpful in developing a coexposure model, and individual bioassay data is 

certainly necessary to do a dose reconstruction. So, we're putting a lot of 

weight on the availability of the RWPs as if -- if there's any incompleteness 

or concern with them, we couldn't move forward. I think the message is you 

don't need a single RWP; we can still do dose reconstruction.

CHAIR CLAWSON: Well, how -- and John, how do you explain in -- in 

1997 -- this -- this is when -- this is when –- I understand what you're 

saying in that, but guess what, you could not have all the RWPs, that's all 

wonderful, but then you only have so much data. And what is to tell me that 

you really have the most exposed person. 

DR. CARDARELLI: That would have to -- 

CHAIR CLAWSON: That's -- that's a shot in the dark. We've got into 

this before. They had 79 -- 79 percent was missing in 1997. 

DR. CARDARELLI: I will address that when we get to that particular 

point. 
24

CHAIR CLAWSON: Okay. Because -- because you keep throwing out 

this coexposure model and everything else like this, and this is what's really 

throwing me in the whole process. Because to me, it kind of seems like 

you're trying to rewrite IG-006. And I -- 

DR. CARDARELLI: No. 

CHAIR CLAWSON: I -- I've got issues there, so. Because -- because 

completeness has always been -- that was one of the biggest issues in this 

whole process when we even started to write this. So, I'll -- I'll sit back. 

But what I -- I -- I understand what you're saying, but you're leaving the 

whole door of do you really have the information or not wide open. So I'll 

just -- I'll let -- I'll let you go on from there unless there's somebody else 

that has something else that they wanted to bring up. 

MEMBER LOCKEY: Yeah. Hi, Jim Lockey. Can you go back to your 

slide number eight table, please? So, my -- my question is, after reading 

through this a number of times, if I looked at the 19 -- say, 1992 data, there 

were 23 RWPs, and none of those RWPs indicated that a bioassay should be 

done for, say, plutonium, right? But am I -- am I to assume that -- 

DR. CARDARELLI: No, no, I would not say that those RWPs that you 

do not have to do it for plutonium. I think the -- what needs to be said 

there is that there's no indication on the RWP that plutonium had to be 

monitored because there's no -- 

MEMBER LOCKEY: -- indicate -- 

DR. CARDARELLI: -- indication of it. They may have been monitored 

for plutonium because of the other procedures in place.

MEMBER LOCKEY: That was -- that was my next question. All right. 
25

So, of those 23 RWPs, is -- does -- is there -- data exist that, in fact, they 

were monitored in some manner? 

DR. CARDARELLI: Yes, they would have been monitored through the 

routine practices at the time, which the procedures would have called for 

workers most likely exposed would have been monitored through the routine 

monitoring practice. So, workers aren't -- it's just not willy-nilly. They had 

to identify areas where the potential for exposure was highest and identify 

those workers, and then they would be put on a routine monitoring program. 

And that's how they were monitored at the time. 

MEMBER LOCKEY: Right, and your -- and your slides in the future, 

you address that by your direct -- direct data; is that correct? 

DR. CARDARELLI: Correct. The direct monitoring versus effective 

monitoring. 

MEMBER LOCKEY: Right. So, what we're saying is that there was a --

there was a procedural change from '91 to '98, where they instituted the 

RWPs and then started to stipulate which bioassays had to be included in 

those RWPs where prior to that, presumably they recovered through other 

ways of monitoring on an ongoing basis. Am I -- is that what -- is -- 

DR. CARDARELLI: That's correct. 

MEMBER LOCKEY: Okay. All right. 

CHAIR CLAWSON: But John, this is also what opened up the whole 

mess. 

MEMBER LOCKEY: Zero -- excuse me, Brad. So the 0 percent doesn't 

mean they weren't monitored; it just means they were monitored, most 

likely by another methodology? 
26

DR. CARDARELLI: Correct. We're putting too much emphasis on -- on 

an RWP, and there are different RWPs, which result in the different 

monitoring percentages that we see here. It's not an indication of a trend of 

monitoring practices. 

CHAIR CLAWSON: And if I asked you for the numbers of the 16, how 

many were monitored for plutonium, you could give me that? 

DR. CARDARELLI: I could. I don't have that handy. I don't have that 

right now prepared, but I will -- I will look for that information. 

CHAIR CLAWSON: Well, do you think it was nearly one to one or was 

it 50 percent? What was that data? 

DR. CARDARELLI: I -- I can't speak to that -- that detail at this point. 

I don't know if Dr. Taulbee or Nancy could -- could chime in to answer that 

question. 

DR. CHALMERS: John, I'll chime in for a second. Those 16 RWPs, so 

that could be 16 workers, it could be 100 workers. So it'd be worker by 

worker were they monitored or not directly or effectively or -- or whatever, 

however you have it there. And so just speaking for the analysis that I did, 

ultimately when we came up with the confidence interval for monitoring 

percentage, I would not have broken it down by nuclide. It was just one 

overall number for the 600 and however many sub CTWs we looked at in 

total, because, as John mentioned before, we did not inventory nuclides and 

so we could break it down by nuclide. But in terms of putting an uncertainty 

on that monitoring percentage, there's no way to do that given the way 

things were inventoried. But we could get you that number, the point 

estimate. 
27

MEMBER LOCKEY: I mean, that's -- that point estimate to me is 

important because it gives me an idea of okay, there were -- the RWPs 

didn't stipulate plutonium had to be monitored, but, in fact, how many 

workers in those RWPs, in fact, were monitored. That gives me -- 

DR. CHALMERS: And I think it may actually be in report 92 in one of 

those tables. I'm not -- 

DR. TAULBEE: Yes. 

DR. CHALMERS: -- sure. 

DR. TAULBEE: This is Tim Taulbee. This is Tim. If I could interject, 

it's in table 4-6 of report 92, and that's on page 40. And if you look for 1991 

in that table, there's a -- it says that there were 17 RWPs, there were 82 

bioassays required for plutonium, meaning that there was a total of 82 

workers. 72 -- or 78 of the subcontractor construction trades workers were 

monitored for plutonium. And so, the direct monitoring percentage for that 

1991 is 95 percent, -- 

MEMBER LOCKEY: Okay. 

DR. TAULBEE: -- if that gives some context. It's all there in, again, 

table 4-6 on page 40. 

MEMBER LOCKEY: Thank you. I appreciate that. 

DR. CARDARELLI: Okay. Are we okay to move forward? Any other 

follow-up questions? 

CHAIR CLAWSON: Well, we -- we do, but you're going to get into the 

crutch of this whole issue here coming up with the important -- 

DR. CARDARELLI: Sure. 

CHAIR CLAWSON: -- because that's -- that's where the crutch of this 
28

whole thing kind of came into my -- myself. I think it's personally being 

skated past, but go ahead and we'll -- we'll continue on and address it when 

we get there. 

DR. CARDARELLI: Okay. And -- and just so folks know, I actually 

have that report up and could show those -- those tables from report 92, if 

necessary. That's what I was looking off to the right for. All right. Let's 

start -- 

DR. TAULBEE: Well, that might be helpful for -- just so Dr. Lockey can 

see what it is it he's looking at or -- 

DR. CARDARELLI: Okay. Here's -- 

DR. TAULBEE: -- looking for at that point. 

DR. CARDARELLI: -- page 40 of 188 on report 92. I'll go ahead and 

maximize this table 4.6, 1991 number of bioassays were required, the 

number of RWPs at the time was 17. Subcontractors monitored by bioassay 

was 78, and they had 95 percent were bioassayed. Three of them were 

subcontractor that were matched to coworker. 

So, Tim, I'll let you explain this table further if -- if there's any 

questions. 

DR. TAULBEE: I guess I'll just open it up. Does anybody have any 

questions on this? This is -- this is where we're trying to emphasize that 

just, you know, the RWP is not mentioning plutonium or not having 

plutonium for those first few years. It was done by procedure. And here 

when you go and you look at those RWPs and you look at subcontractors on 

those RWPs, were they monitor for plutonium based upon the area; yes, 

they were, and here's the monitoring data that we were able to find on those 
29

RWPs or identify who was monitored, and then we went and looked at their 

bioassay. 

Does that answer your question Dr. Lockey? 

MEMBER LOCKEY: Yes, Tim. Thank you very much. Appreciate it. 

DR. CARDARELLI: Okay. I'll move that off. If there's other points 

that we need to bring that report back up, I'll have it ready.

Okay. So, for SC&A conclusion number two with the results for direct 

and effective monitoring may be overstated, I think this one is not going to 

be too much of a controversy here. SC&A stated in their focused review that 

we did not address all the radionuclides listed in the RWPs. The final draft 

sampling plan that was drafted in 2018 did call for all radionuclides be listed 

on the RWP other than tritium. In report 92, however, there's confusion 

because section 2.1 and section 4.2 have different statements, and I've 

underlined them here. 

Section 2.1 calls for all radionuclides listed on the RWP other than 

tritium, and then section 4.2, it's changed to at least one required bioassay. 

SC&A correctly identified that -- that confusion, and we went back and 

reevaluated the data to account for all radionuclides, which is now going to 

be the next slide.

The monitoring types are whether or not your directly monitored. You 

worked in a location and you left your own bioassay sample, and that is 

associated with you as an individual. Effectively monitored would be you 

went into the location with another worker. It doesn't have to be the same 

job title as you -- as you and were signed in on the exact same RWP, you 

went to those locations, and you performed your -- your individual work. By 
30

essence, or by definition, the assumption is that you're in the environment 

with a similar exposure potential. That's one of the key criterions for 

developing a coexposure model. So, NIOSH -- we recalculated the direct 

effective monitoring percentages where the monitored means all required 

nuclides on the RWP, not just one.

Remember the RWP sampling plan was to estimate the percentage of 

the monitored subcontractor construction trade workers within 5 percent 

with that 95 percent confidence. So, it's a very specific question that we're 

trying to answer. So, when we look at uncertainty percentages, we can talk 

about that with regard to the monitored subcontractor -- sub construction 

trade workers -- subcontractor construction trade workers. All right. 

Uncertainty and anything else cannot be calculated because we didn't 

design the sampling plan to answer those other questions, unless it was 

truly inventoried in March of 2018 and the areas that we did inventory was 

year and area. So, we can calculate things for the year and the area in 

which these workers worked. And we did that. The results really didn't 

show a significant difference for the effective monitoring. 

This table here on the left column shows the monitoring type, whether 

you're a direct monitored or if you have been effectively monitored. In other 

words, you've been assigned a dose or a bioassay result consistent with your 

coworker or someone who was in the same exposure potential environment 

because you were on the same RWP as them at the time the work was 

required, and the bioassay sample was collected. 

The middle column is the weighted point estimate that was 

determined. And the direct method, we had 95 percent that were properly 
31

monitored -- or monitored. The 95 percent confidence level was very high, 

87 to about 99 percent. So, most of the people on the RWPs were directly 

monitored with at least one radionuclide. 

Now, we changed it to all. Did you -- were you -- did you have a 

bioassay result for all three radionuclides if the radiation work permit called 

for that? That number naturally dropped from 95 percent to 75 percent with 

the confidence interval from about 68 to about 81 percent. But if you were 

effectively monitored, in other words, you're going to be in the same group 

as someone who was monitored with at least one radionuclide, that was 98 -

- 97 1/2 percent with a very high confidence interval of 88 to about 100 

percent. 

But now, if we incorporate all radionuclides, that last row, it doesn't 

drop significantly. It only dropped to about 88 percent would have been 

monitored effectively using all radionuclides with a confidence interval of 80 

to about 94 percent. 

So, the effective intervals overlap. What I mean by when I say they 

overlap, the 88 percent confidence interval is 80 to 93.74, and that overlaps 

with the 97.5. The direct do not necessarily overlap. But the change here is 

insignificant statistically speaking because of the way that we did the 

sampling. 

So, they're correct. We should have maybe looked at it that way, and 

it was confusing. We've run -- rerun the analysis, and we asked ourselves 

effectively is there any difference; the answer is no. 

So, the SC&A section 5.4 in their 2002 focused review suggested that 

a monitoring threshold be established to determine completeness or imply 
32

completeness not to determine. So, they make the statement SC&A's 

selection of compliance values less than, say, 80 percent was arbitrary, but 

it was a reasonable value below which the rate of compliance certainly would 

be questionable. Compliance and completeness are two separate issues. 

We'll get into those later. 

But our argument would be any suggestion of a monitoring threshold 

is -- is completely arbitrary, of which examples will be provided in a minute. 

Every interval on the previous slide is above or contains the arbitrary SC&A 

value of 80 percent. And what I mean by that is, you look at the upper 95 

percent confidence interval, every one of these is above 80 percent. So, 

using that arbitrary value, even with these changes, with the confidence 

intervals, we would meet that arbitrary value. 

However, again, there are alternatives to the monitoring threshold that 

is worth discussion. We need to -- 

CHAIR CLAWSON: John, let me go -- let me go back to slide 18 there, 

because I think -- I think I'm not really agreeing with that because NIOSH 

and SC&A agree that these are merely benchmarks. Such values for 

comparison only have been continuously used for the past six years. I 

would point out that NIOSH -- and I think it was Tim -- because in looking at 

the transcripts, that suggested value of, I believe, was 50 percent 

acceptable, and this is on page 80 through 83 in December 6, 2019, work 

group procedures. These -- these are just benchmarks that we were using 

and stuff like this. I think -- I -- I think that you're misusing what that was 

really for. 

DR. TAULBEE: This is Tim. I understand what you're saying there 
33

Brad, that these were initial thoughts, and you want to call them 

benchmarks, okay, but what John is going to be presenting here shortly is 

where some of these numbers begin to play a role from that standpoint. We 

shouldn't be looking at a single value from that standpoint. We certainly 

shouldn't be looking at the single value without the uncertainty associated 

with it. Those are the two takeaways that, you know, we're trying to get to 

at this point. But I'll -- I really want John to get on to the next -- I think it's 

a next slide, isn't it, John? The -- of where you give the examples? 

DR. CARDARELLI: Yes. 

DR. TAULBEE: I think this one might help, Brad. 

DR. CARDARELLI: Thanks, Tim.

So, instead of looking at a particular metric of 80 percent or 50 

percent, it's not just that metric with regard to completeness. You have to 

understand the exposure potential and the data that's been collected under 

that exposure potential and especially for unmonitored workers. 

Here's one example. If an unmonitored subcontractor construction 

trade worker represents a small fraction of the highest exposed group, then 

we could still construct a coexposure model and do dose reconstructions. 

Okay. 

On -- on the other side of this is 90 percent of the subcontractor 

construction trade workers were not monitored, 90 percent of them, but a 

large fraction of the highest exposed workers within the entire population, 

that would be everybody, and if they were monitored, then we could use the 

highest exposed population as a bounding coexposure model and assign it to 

those 90 percent of subcontractor construction trade workers who were not 
34

monitored. So, the question then becomes -- is were those 90 percent 

among the most highest exposed and not monitored. And that would be not 

likely given the protocols and procedures that were put in place for the 

bioassay monitoring throughout the history of the site. There would be no 

reason to purposely exclude someone who is perceived to be the highest 

exposed. 

So, and the -- and if we had to take this to the extreme, if -- again, if 

we have one person who we knew to be the highest exposed, we could use 

that highest exposed as a bounding for everybody else at the site. And 

that's -- that's kind of -- it's a very claimant favorable approach. We've 

applied it to other sites, and it allows us to sufficiently -- with sufficient 

accuracy to calculate dose estimates for people who are not monitored. 

CHAIR CLAWSON: And I under -- I understand what you're saying 

there. So, how are you going to tell me and how are you going to assure 

that I have the highest exposed person. 

DR. CARDARELLI: Well, the good thing that we have -- 

CHAIR CLAWSON: That's -- that's -- that's where -- that's where data 

completeness comes in. That's where all of this -- and this is what the 

whole I thing we've been dealing with on this -- to me, it's appearing to me 

that you are trying to say well, we've got -- we've got this many people that 

have been out here. We do -- don't have all of the data. We don't have all 

the bioassays either, because they are lacking too. 

You are not going to be able to prove to us that you have the highest 

exposed person. You really can't because you have no -- you have no -- the 

whole thing of data completeness. This is -- this is why we have 006. This 
35

was one of the criteria. 

It looks like to me that you're trying to sidestep the issue of data 

completeness and just say well, yeah, out of these 1000 people, this 

person's the highest one, so we're going to give it to everybody, and that's -

- that's -- that's not right. And I just want to let you know that I do not 

agree with that, but I will allow you to continue on. 

But this is what it is appearing to me, and I do not agree with it. And I 

think that you've missed what the whole thing was all about. I -- I think 

your whole -- you're shifting the whole premises to be able to go away from 

data completeness to -- because it is too difficult for you to be able to do. 

So, now we're coming back to this coexposure, and this is -- this is -- I -- I -

- I really have a hard time with it. 

But I just wanted to mention this. Because you're telling me this. 

You're telling me you're going to get the highest exposed person and

everything else like that, and I can tell you right now I can shoot holes 

through it all day long, because you cannot guarantee me that because the 

data is not complete. You do not really know you have the highest person. 

You've got the highest monitored one, but you do not know that you have 

data for -- 

MEMBER ZIEMER: Now, could I add a comment here, Brad? 

CHAIR CLAWSON: Sure. 

MEMBER ZIEMER: Sorry, my grandfather clock behind me is chiming, 

so I hope it doesn't interfere. So, you know, but we never know for certain 

that we have the highest exposed person on any site, and that's the reason 

we have modeling where we -- we develop a model and then we -- we don't 
36

really use the average exposure or even the highest exposure number that 

we have, we use a distribution, which takes it out to the high end tail that --

that confidence level at the high end tail, which always -- you -- you could 

always argue that there could be one person or two or a few that are beyond 

that highest tail. But that's -- that's the nature of the modeling in every 

case. 

I know that by using the data that we have, which includes a large 

fraction of the people with a distribution of exposures, and then statistically 

taking that up to the high-end tail, we -- we have -- we -- we kind of meet 

the criteria that says most of the time we'll get it right. Occasionally we 

might not get it right. We're always -- we're always dealing with this 

statistics on it. And even where we have full information on a single person, 

we -- that -- that distribution always -- the uncertainty, we always take the 

high end of the uncertainty and use that number when we calculate 

probability and causation. 

So, I -- I -- I assume, John, that you're using the example of a single 

high dose bounding, yeah, conceptually, that would work, but we never do 

know that, so that's why we use uncertainty and use that -- that 

distribution, typically a log normal and the tail goes way on out there. But I 

-- I -- I don't think anybody's trying to say that we -- we really know that 

most of those persons on any site. 

CHAIR CLAWSON: Oh, and -- and well, Paul, I agree with you to a 

point, but we're sitting here with 79 percent is missing, and we have no 

idea. This is what the whole problem came into. You have no idea what was 

missing out there. Now, you've got the highest exposed person of the 
37

information that you do have, but not the 79 percent that was missing in 

'97. And I'm going to -- 

DR. TAULBEE: Brad, I mean, if we could go back. I mean, you keep 

bringing up the 79 percent missing. It's actually not missing, sir. If you go 

through, the site went back and resampled everyone in that time period, 

okay. And so they found that no one received an intake in that 1997 where 

you're talking about 79 percent missing. They were not missing, sir, okay. 

So, -- 

CHAIR CLAWSON: No, no, they were. That's why they were fined. 

Now, they were given an opportunity to be able to come back. Now, would 

they have done that if they would not have been fined? No, they would not. 

So,

yes, -- 

DR. TAULBEE: Yeah, but from a coexposure -- 

CHAIR CLAWSON: This is -- this is becoming a coexposure. 

DR. TAULBEE: From a coexposure standpoint, sir, we have all the 

data, 100 percent because they went back and resampled in 1979 -- or 

1997, I'm sorry, okay. So, from a coexposure standpoint, there is no 

missing data in that particular year. They looked at 1996. And they did an 

evaluation in that time period and found that the people who did not leave 

the samples in that time period did not need to be monitored, meaning their 

exposures were less than 100 millirem in a year. 

CHAIR CLAWSON: So, you're telling me before '97, we had 100 

percent; it was just that one year -- 

DR. TAULBEE: No, sir. No, sir, I'm not saying that. What I'm saying 
38

is, is that when you look at all of the data we looked at, in doing this RWP 

sampling, and we found direct monitoring for the vast majority of the 

subcontractor construction trades workers. And these subcontractor 

construction trades workers that were not monitored, were working 

alongside workers who were monitored, thus, a coexposure model would be 

applicable to them. That is what we're trying to say here, okay. We 

recognize that not everybody was monitored. But if you look at the 

sampling of RWPs that we looked at, and you look at who was monitored 

and who wasn't, we see that there is sufficient data to develop this 

coexposure model, because a large number of the subcontractors were, in 

fact, monitored on this random sample of RWPs. 

One of the things that was -- has been glossed over -- I shouldn't say 

glossed, that's the wrong term, I apologize -- is that we focused this review 

and report 92 on the actinide exposures that delivered large dose. We 

discarded or did not look at any of the tritium doses. Okay. And that's from 

the sampling plan. That was agreed to with the work group here, that we 

were not going to look at the tritium side, we're going to focus on the 

actinides, because that's where the larger doses would be. Tritium doesn't 

deliver much dose. Some of that -- that 79 percent that keeps getting 

brought up and so forth is coming from some of those tritium facilities. 

When you look at these actinide facilities, and you look at what we did 

in report 92, you'll see that the vast majority of these people were, in fact, 

monitored. That's what I'm saying, sir. 

CHAIR CLAWSON: Well, and here's what you're telling me is that none 

of the data for '97, because they were punished and they went back per the 
39

requirements of DOE, and they had to sample everybody -- but you cannot 

tell me what the previous years were, because they -- you couldn't have 

because they weren't monitoring right. 

DR. TAULBEE: We looked at these RWPs. 

CHAIR CLAWSON: You know, let me tell you something about what --

what you've been telling me here and let me -- let me go back into my life. 

You're telling me that a person that was on the RWP that was going in and, 

say, pulling film bags in that area is going to be getting the same data as 

the pipefitter that spent two weeks in that same area. You have a whole 

different draft of people that are going to be able to go in there. 

But I -- I guess -- I guess maybe what I need to -- what do you see 

0092 as actually what it was requested to do. I guess that's -- I guess that's 

my biggest question, John. Because to me, this has become a coexposure 

model. This is -- this to say that we don't have to -- we don't have to worry 

about data completeness, because we've got these coexposures that we can 

do, and so we don't need to worry about -- 

DR. TAULBEE: As I recall -- as I recall, report 92, from the discussions 

that initiated this report, and we started talking about the sampling plan and 

going forward was that SC&A was questioning whether the subcontractors 

who were not monitored were working alongside workers -- subcontractors 

who were monitored. That was the initial goal of this report 92 was could 

we demonstrate that were they working alongside and if that was the case, 

then the coexposure model would be valid. 

And Bob, I saw you that your hand's up, and I'm hoping you will chime 

in on this particular point.
40

MR. BARTON: Well, I agree with your characterization there. It would 

be the same exposure environment, call it. But I wanted to -- I rose my 

hand because I wanted to go back. You know, the -- the 79 percent in 

1997, yeah, they went back and resampled all those folks. That's -- but you 

also mentioned that they resampled the 1996 folks. That was sort of a --

caught me off guard. 

DR. TAULBEE: No, they did not. They evaluated everybody who was 

not monitored in 1996. And they determined that none of them needed to 

be monitored. 

MR. BARTON: I see. 

DR. TAULBEE: And that's in the records, in the filings with DOE.

DR. CARDARELLI: I do discuss a little bit of this in the following slides. 

MR. BARTON: Well, then let's John, get back to it. I don't know. 

MEMBER LOCKEY: John, before you do that, let me -- I'm going to 

follow up on one -- one of the Brad's questions, which I have a little 

heartache about also is that, in the -- in the coexposure model looking at 

subcontractors, how can you reassure me that in that particular situation 

you have a craft person, an electrician, doing their work and on the other 

side of the room there's a plumber doing their work and that your exposure 

modeling takes that under advisement, either by -- 

DR. CARDARELLI: That -- yeah, that will certainly come into play, too, 

later in this, but that's a great question. And I would say that the --

remember these folks who signed in on these RWPs -- I don't care if it's 

'90s, '80s, or even the late '90s, they're under a routine monitoring 

program, which means that if you signed the RWP, you have to go leave a 
41

routine bioassay sample. So that -- and what -- what really are these 

bioassay samples intended to do? They're basically there as a last resort to 

verify that the engineering controls and the personal protective equipment 

that is required before they even go into the potentially exposed 

environment are adequately working, that the workers are being properly 

protected. 

So if any of those things fail, we're still going to do a routine 

monitoring as a last resort because something might go undetected, maybe 

there might be an issue with the PPE. So, we want to monitor you as a 

routine. Now, if -- that's -- that's what we call the routine monitoring. 

Say, for example, you have a subcontractor or someone else who's 

temporary who might come in who isn't always employed there, and they 

have to go into the same work environment. Well, they're not read into that 

routine program. They -- they fall under what they call a job specific. 

They're going in as if -- they're going in the same environment to do a 

specific job, and they're going to have to leave a bioassay just like a routine 

person would to verify that the engineering controls and the personal 

protective equipment all did their jobs. So that's the multiple layers of 

protection that we provide in that kind of procedural bioassay program. 

Now here's how I could give you better confidence that the coexposure 

model will work, and it's going to come up later in this talk. Say, for 

example, something fails. An alarm goes off, a pipe breaks, someone cuts 

their PPE and -- or their respirator falls off and then they get inhalation, that 

then becomes what we call a special bioassay. It's because the person has 

been believed to have been involved in something that would have resulted 
42

in an intake. All the other bioassays are done because there's no evidence 

that you had any intake whatsoever. It's a routine or you're in there for that 

specific job. We don't expect anything. But if something fails, now you are 

a specific case that's a special sample that can then verify did you really get 

exposed. Those results are also included in the coexposure model. 

So we have these people who are truly believed -- because of some 

other failing in the protection process, they're going -- their results will be 

included in this coexposure model, which makes it closer towards bounding 

model that we have no evidence to suggest that exposures could ever be 

higher than this because the environment was monitored, the engineering 

controls were in place, the PPE was properly used, and we followed up with 

routine just in case any of those failed and we -- we missed. But if any of 

those did fail, we're going to collect a special, and then we're going to verify 

was there any intake even though a pipe burst or your PPE failed. All of that 

information, those highest exposed people, the people with specials, are 

going to be in this coexposure model. 

MEMBER LOCKEY: From my simplistic way of asking -- asking this 

question again, let me go back to my concern and perhaps Brad has this -- if 

I have a pipefitter and electrician and they're in the same work environment, 

by nature their jobs are going to a create a situation whether it's a 

difference in potential exposures, but you'll pick -- that'll be picked up 

through when they leave the bioassay surveys. Is that what you're talking 

about? 

DR. CARDARELLI: In a routine situation, there would have been no 

indication that anything abnormal occurred, they leave a routine sample, 
43

even though you're an electrician, even though you're a pipefitter, nothing 

occurred which would have resulted in substantial potential for an intake 

that would have resulted in this special, so yes. I'm trying to explain that

here. 

MEMBER LOCKEY: They're going to be covered. Well, I'm not saying 

that the plumber would under -- I mean the pipefitter would understand that 

he had an accidental exposure. I'm just saying that unknowingly, they're 

both going to get bioassays; is that correct? 

DR. CARDARELLI: That's correct. 

MEMBER LOCKEY: And if the pipefitter has an externally high bioassay 

level, then you will use that data in your coexposure model?

DR. CARDARELLI: Correct, because they were in the same work 

environment with the same potential. One happened to have been exposed 

through their routine bioassays, the other did not. And that would be -- all 

of that go together in a coexposure model to be applied to people who didn't 

leave routine but went into the same environment.

MEMBER POMPA: This is David Pompa. Do you mind if I ask a 

question? 

DR. CARDARELLI: Please do. 

MEMBER POMPA: We -- just a couple of them. Is the amount of 

plutonium taken in effect on the data without an exposure bioassay? We 

talk a lot about plutonium but is the amount -- one gram of plutonium is 

different from a 10 grams of plutonium when it comes to exposure. Is that 

taken in effect? 

DR. CARDARELLI: Yes, it is. I think through the dose reconstruction 
44

process and our technical basis documents, we use claimant favorable 

assumptions that the plutonium itself is like 10 or 12 years aged, so you 

have a higher americium build up into that. So, we do try to account for not 

only the age of the plutonium but also the isotope if it's specific to 238 

versus 239-type situations. 

MEMBER POMPA: Okay. And the bioassay, how -- when the potential 

exposure happens, how soon after that exposure -- because your body will 

excrete whatever potential you might have inhaled. Your body will excrete it 

normally. So how often or how soon do you do the bioassay? 

DR. CARDARELLI: Well, typically it would be very soon after, but 

because plutonium typically at this site would remain in the body for years if 

not decades, whether or not you do it 24 hours or two months or two years 

afterwards, you would still be capturing that potential intake because it 

would reside in the body longer. Now in our process, we make claimant 

favorable assumptions that not only is that type of plutonium, what we call, 

a super S, which would stay in very long time which results in a higher dose 

to particular organs when it may, in fact, be a type M which would maybe 

stay in the body for months or type S for years versus decades. So, we try 

to account for all of these, what we call, clearance rates for the different 

isotopes that these workers are being exposed to. 

We're talking plutonium because that happens to be the example 

that's most likely where we do a lot of bioassays at the site. But you've got 

uranium, neptunium, americium. They all clear from the body at different 

rates, and we try to account for that in how quickly they do the monitoring, 

so. 
45

MEMBER POMPA: Okay. One more, the -- we talk a lot about a 

coexposure model. Does the coexposure modeling reflective time factor at 

the source by the employee or the closeness to the source, because the 

(indiscernible) or even the time factor will reflect on the data?

DR. CARDARELLI: Yeah, I wouldn't call something a source, because 

that kind of implies that it's like a point source or it's like in a particular part 

of the room. A lot of this could be the -- you're going into a building or a 

large area where the source is the product that's going through pipes and 

things of that nature. So, the RWP would be trying to characterize that 

overall environment, and if you say you go into this environment, you need 

this level PPE and upon exit, at some point shortly after that, you'll need to 

leave a routine bioassay sample, and it could be days to weeks after they 

made that entry because maybe they made multiple entries, that doesn't 

mean they need to leave multiple bioassays every time they go into the 

RWP. And that's really driven by how quickly that radioisotope would clear 

from the body. 

Tritium would clear very quickly, so it's more frequent. Plutonium 

doesn't clear very quickly, so once a month, once a quarter, maybe once 

every two years would be driven by kind of like the environment that they 

go in and the type of work that they do. 

MEMBER POMPA: You know, I work with RWPs. I just -- my mind was 

clicking when you mentioned a respirator when the employee or the worker 

removes their respirator and potentially the respirator could be 

contaminated, are they cleaning the respirator before they doff so that --

DR. CARDARELLI: I would -- well, I would imagine that through the 
46

radiation worker training and that they're properly trained don and doff, or 

take on put -- put on and take off, the respirator, the PPE equipment. And 

yes, you know, they would not necessarily recycle something that's been 

used and known to be contaminated. I'm sure that they probably went 

through some level of decontamination prior to recycling that respirator. 

MEMBER POMPA: Okay. That's all my questions at this time. Thank you. 

DR. CARDARELLI: Okay. Thank you. 

CHAIR CLAWSON: I do have a clarification I want to take, because 

John, you're telling me about an RWP. We have -- we have 12 RWPs for 

Savannah River. That's pretty big site. When they write these RWPs, and 

I'm talking about the general RWPs because this is what you're using, that 

could cover all of, like, 825 -- what -- what -- any of the facilities. You take 

one RWP. A hundred people can sign on to that RWP, so they can go in and 

work in normal conditions. 

Now you're saying if the pipe broke or anything else like that, that 

then they'd have a special one and everything else like that. In my life no, 

that is not true. That's -- that's part of their normal to be able to do basic 

work. But inside that RWP and inside that facility, there are areas that you 

do not go into that are not normally entered. So, when you have to do that, 

you have to have a special RWP, which you are going to be monitoring for 

different isotopes and different things. That to me is a special RWP.

And you come down onto a normal, you may have a bioassay that is 

once a year with a normal routine. It just depends. 

DR. CARDARELLI: Well, I -- 

CHAIR CLAWSON: You're getting -- you're generalizing this RWP, and 
47

it's a lot more in depth. 

DR. CARDARELLI: Mr. Clawson, you bring up good point and then 

Tim, I'll -- let me -- I'll just add something here. One thing that I wanted to 

be clear about with report 92 is we focused on RWPs specific for 

subcontractor construction trade workers, not the general. There are 

multiple types of RWPs, which you've correctly noted. Ones that they would 

call standing or -- standing RWPs, which would cover that routine type of 

activity you just mentioned. We did not focus on those because we knew 

that that would not be focusing on the people doing these very specific jobs 

with perhaps a different exposure potential. Report 92 focused on those 

special RWPs that you're talking about. So, we did exclude standing RWPs 

and focused on those that had specific jobs associated with it. 

So, Tim, did you want to add any clarity to that? 

DR. TAULBEE: No. That's exactly what I was going to say. I mean, I 

understand what -- what Mr. Clawson was saying. 

DR. CARDARELLI: Yeah, I did too. Yeah. 

DR. TAULBEE: The general RWPs. In report 92, we specifically 

excluded those, and so that we were not evaluating those. We are only 

evaluating the special, the specific job-task RWPs, yes. 

CHAIR CLAWSON: Well, and -- but -- and see, this is -- this is where 

I'm having a problem because you're telling me that everybody's going in 

and working under these RWPs. No, that -- 

DR. TAULBEE: Not everybody, sir. We focused on the subcontractor 

construction trades workers. If we -- 

CHAIR CLAWSON: Okay. 
48

DR. TAULBEE: -- opened up one of these specific RWPs and we did 

not see any subcontractor construction trades, we threw it back into the pile, 

if you will, and resampled. We were only looking for RWPs that had 

subcontractor construction trades workers doing specific tasks. That's what 

the focus of report 92 is. 

CHAIR CLAWSON: Okay. Because the way it was being spoken about, 

it was that this was general stuff and that is -- that is not -- I'm glad that 

you clarified that, because there -- there's a lot more into it than this, and 

there's a lot more into the RWPs that is a lot more important. That's --

that's -- that -- that's why DOE has written a lot of their procedures and so 

forth to be able to govern so that the people are monitored correctly. So go 

ahead, John. 

DR. CARDARELLI: Okay. Well, yeah, I'm glad we're having these 

discussions, and it's good to get the -- 

MEMBER LOCKEY: John, I'm sorry. John, Jim Lockey. 

DR. CARDARELLI: Oh, sure. 

MEMBER LOCKEY: Brad forgot to tell me to charge my computer this 

morning, so I -- I was able to get it back online. 

DR. CARDARELLI: Did you have a question? 

MEMBER LOCKEY: No, I just -- I got -- we cut out a moment. 

DR. CARDARELLI: Okay. 

MEMBER LOCKEY: My computer went -- went when you were 

answering my question. 

DR. CARDARELLI: Well, I -- 

CHAIR CLAWSON: I -- I'm sorry, Jim. I -- I've taken to babysitting 
49

you for so long, I totally forgot. I apologize. 

MEMBER LOCKEY: You know, it wasn't -- 

CHAIR CLAWSON: -- try to get the sheets written up so I can cover all 

these things when we do this. 

MEMBER LOCKEY: I was waiting all night for you to send me a note to 

charge my computer. 

CHAIR CLAWSON: I -- I -- I forgot. Sorry. 

MEMBER LOCKEY: Anyway, could you repeat the answer to my 

question for me? I'm sorry. I don't know if you can -- able to do that or not 

or maybe we just move on. 

DR. CARDARELLI: It's been a while. Do you want to repeat the 

question? 

MEMBER LOCKEY: That's all right, go on. I think my question was if 

you had a pipefitter and an electrician, you would -- and they both get 

bioassays performed, you would, of course, take the highest level in your --

in your dose reconstruction modeling, correct? 

DR. CARDARELLI: We would use them all, yes. 

MEMBER LOCKEY: Yeah, that's right. All right. Thank you. 

DR. CARDARELLI: Okay. So, to wrap up the response, our response 

to SC&A's conclusion number two for the direct and effective monitoring 

that -- the fact that they may be overstated, we agree that we did not 

address all the radionuclides when tallying the results. We updated them 

here, and we conclude that really there's no significant change and that we 

can still create a coexposure model using the data that we have. 

Now moving on to response to SC&A's conclusion number three, which 
50

talked about the generalized matching is not sufficient. So, really, what 

does that mean? It constitutes what is a coworker. And I know that we've 

talked about this before, and it's mentioned in the slide. So, for effective 

monitoring, what constitutes a coworker. Is it the same person in the same 

position, or is it the same people working in the same environment but with 

different job titles? 

The final draft sampling plan in 2018, the term coworker was used that 

was on the same RWP, which we had discussions, and it can be implied that 

a coworker is two electricians working together, not an electrician and a 

pipefitter. In effect, what we're really saying is you're in the same exposure 

potential environment, maybe doing slightly different work, but you signed 

in on that RWP which described that exposure potential. So, there's a 

coexposure potential that's being applied. Subcontractor construction trade 

worker is implied since that was the sole focus of that particular statistical 

analysis and review of these, and I'll call them now, special RWPs, not the 

standing RWPs. 

So, the report 92 in 2019 really looked at subcontractor construction 

trade workers who were on the same RWP on the same date and the same 

time with no more than 15 minutes derivation. So, remember, some of 

these RWPs might last for a week or two, but we were interested in people 

who went in within the 15-minute time window for it. Because, frankly, over 

the course of that week, maybe those environmental conditions changed in 

there. So, we really wanted to nail down the specific time, date, and the 

same environment that they were in within about 15 minutes. Very specific. 

And any job type but laborer could be used for another craft. 
51

So, SC&A suggested in their focused review for -- the focused review, 

again, being anything after 1990 to 1998-ish time period, that's the focus --

they were implying that the same craft also needed to be part of that 

coexposure development. Here we would argue rarely do you have two of 

the exact same craft going in. What we're interested in is they're going into 

the same exposure potential environment, they're all are being monitored or 

should be monitored, and they're all leaving bioassay samples, and if they're 

not, the bioassay samples that were collected of the people who were in the 

same environment are going to be applied in a coexposure model to give it 

to those people who either didn't leave a bioassay or were unmonitored. So, 

we're going to still give them exposure based upon the work environment 

that they went in with, what we've called, coworkers back then, it's a 

coexposure today. 

So, we believe that the criteria for coworker matching are more 

restrictive than necessary for developing coexposure models. So, coworker 

versus coexposure is a misconception. I kind of discuss that briefly here. It 

was discussed in great detail in 2019. And as a result of those two 

meetings, the SRS and the SES issues, work group meetings, and the 

Advisory Board, I think everyone came to an agreement that the term 

"coexposure" would be more appropriate and less confusing than using 

terms "coworker." So, we have moved our narrative to be coexposures and 

coexposure modeling versus coworker model. And, again, all based upon 

the similar exposure potentials, not necessarily the exact same craft that 

worked right alongside them. 

So, the matching criteria for coexposure models, there's no 
52

requirement that the monitored person worked closely with the unmonitored 

person. What I mean by "closely" is right next to him. Remember the 

radiation work permit could be for a larger area, and they're doing a variety 

of activities of different things for different purposes because they have 

different jobs to do. But they're in that environment at the same time. The 

model's representative was bounding, which is very claimant favorable for 

unmonitored workers if they had the same or higher potential for exposure. 

And then the sampling plan focused on these subs again. But if any 

monitored worker, that could have been a primary construction trade 

worker, another subcontractor construction trade worker, a nonconstruction 

trade worker with the same or higher potential was monitored, that model 

would be representing or bounding. 

So, this gets to Dr. Lockey's previous concept of if anybody's in there 

and they use monitoring data from that, is that going to go into the 

coexposure model? The answer is yes, and it would be representative or 

bounding. So, our conclusion to that is generalized matching -- or actually, 

SC&A's conclusion was that generalized matching is not sufficient. We would 

challenge that and argue that coexposure modeling coworkers used for 

effective monitoring matches need only have the same or higher exposure 

potential. So, SC&A's criteria for the same radiation work permit on the 

same date, the same time, and having the same exact craft are far too 

restrictive for us developing a coexposure model. And I would also argue if 

you get down to that level of -- it may not be as claimant favorable because 

then we would be excluding potential exposures for people more highly 

exposed who may have had a different craft. 
53

I'm on to conclusion number four of -- 

CHAIR CLAWSON: John, John, -- 

DR. CARDARELLI: -- SC&A's if there's any comments. 

CHAIR CLAWSON: John, just before you go on. 

DR. CARDARELLI: Sure. 

CHAIR CLAWSON: These 19 RWPs that you have, how long did these 

RWPs run for? 

DR. CARDARELLI: I would -- I don't know the particular answers for 

those 19 or 20 or 30 that were selected, but they would vary, I would 

imagine, by their job. Tim, I see that you came online, so can you answer 

that? 

DR. TAULBEE: Which 19 RWPs are you talking about, -- 

CHAIR CLAWSON: You -- your -- 

DR. TAULBEE: -- Mr. Clawson? 

CHAIR CLAWSON: Well, let's just -- let's just take '96. 

DR. CARDARELLI: It'd be a few days, I would imagine. 

CHAIR CLAWSON: You what? 

DR. CARDARELLI: Some could last for a few days. 

CHAIR CLAWSON: Okay, I -- 

DR. TAULBEE: Well, -- go ahead. 

CHAIR CLAWSON: What I'm trying to get to on this is how many in 

'96 or '97 or whatever, how many RWPs did you -- did you have, because 

there was the chart just a little bit before, okay. So, let's take -- let's take 

'94. You have 32 RWPs. What was the time that those RWPs ran for? Was 

it a week? Was it a year? What was it? 
54

DR. TAULBEE: No, we -- 

CHAIR CLAWSON: Do you have any idea? 

DR. TAULBEE: It was a -- I don't recall any that ran for a year. I 

don't recall many that ran more than a week or a month. Most of them were 

very short term, as I recall, when we were doing the sampling. 

Perhaps others could chime in on that. But when we were doing the 

matching, and -- and I think Mike Mahathy can correct me if I'm wrong on 

this -- we were live looking, as John pointed out, within that time window of 

two people signing in, in that same time period. So, if the RWP went for a 

week, it wasn't somebody went in on a Monday and we matched him with 

somebody on a Friday; it was both of them had to be on a Monday type of 

scenario. They had to be there at the same time. 

So the RWP may have gone longer, but when we were doing the 

matching, we were looking at the exposure potential at that particular time. 

And what we were doing was we were looking at all the subcontractor 

construction trades workers. So, we were going through the RWP and 

identifying all of the subcontractor CTWs. 

CHAIR CLAWSON: Okay. Because I want -- I want to get the -- the --

what I was trying to get to. Because some of the RWPs that I looked at 

when I was at Savannah River there were for the project for the subcontract 

workers coming in and working on the waste transfer system that they had 

to go into. That RWP ran for over seven months. And it had electricians, it 

had pipefitters, it had everything else like that. Matter of fact, I believe that 

it had over 85 to 100 people signed in on that. And see, that ran for a long 

time, but under that, that was not classified as a normal RWP. 
55

And -- and I've dealt with the special ones my entire life, because each 

one of our fuels is a special RWP. But we had our generals that we signed 

on for a year. The other ones we signed on to -- and we only had to sign 

once for it -- is for an extended period too. 

I would like to know that some of these -- you know, a better 

understanding of how this RWP was run. But I just -- I just wanted to just 

ask that off the top of my head right there. I'll -- I'll -- we'll bring this up at 

a later time or whatever, but I was just wondering if you had that. So, I'll 

just turn it back to you, John, and we'll -- we'll address this a little bit later 

and go from there. 

DR. CARDARELLI: Okay. All right. Let's get down to conclusion four. 

Getting close to the end. This one was: RWP-specified, job-specific 

bioassay data are incomplete. This gets to the discussion we had earlier 

about completeness. 

And here are two slides that come from the SC&A focused review 

response, and, again, it's for the period 1991 to -- through 1998. And we've 

split this -- or SC&A split this -- into two categories, '91 to '94 and '95 to 

1998 in looking at what they considered to be noncompliant monitoring. 

Again, the noncompliant was perceived because something might have 

and 0 percent when, in fact, the RWP didn't even mention it. So, on the lefthand column here, it's the fraction of compliance, so a high number here 

would be a bad thing. That would show a lot of noncompliance. So, for put 

-- this is for five radionuclides that we talked about earlier; the plutonium, 

the uranium, the americium, strontium and fission products, and neptunium. 

So the 1991 to '94 noncompliance was around 25 percent for plutonium. 
56

And then in the later years, it was understood to being something less than 

that, like around 18 or 19 percent. 

One thing that will come into play later, you'll notice there's no 

uncertainty bars around this to determine whether or not these are 

significant or have a real problem with them. Uranium had the same trend 

where in the later years the noncompliance factor drops, which implies that 

things were being more compliant. And then, of course, americium has a 

higher noncompliance rate, but it certainly reduces in the latter part of the 

'90s. 

For the right column, these are strontium and fission products, and 

they have a reverse kind of a trend where the noncompliance is actually 

lower in the earlier time periods than in the later time periods in the 1990s. 

So, they're just demonstrating the two. I will point out that americium and 

neptunium were not as voluminous in how many -- how often they were 

done because they weren't always on that routine bioassay. They would 

have been what we call job specific or something of this nature. 

So, these could be higher because the numbers are lower. For 

example, I will say the neptunium, although that looks very scary and bad, I 

believe this was based on three radiation work permits on 11 workers. So, 

the numbers here are very small. And when you have very small numbers 

you can have great levels of uncertainty, but nonetheless it gives a 

perception that there's a real problem here; when you look at it in total, it 

may not be. But americium and neptunium are really kind of different. The 

plutonium, uranium, and fission products were certainly part of a more 

routine bioassay program, more numbers. We don't have the numbers 
57

associated precisely with these -- on these particular graphs because I 

pulled them straight from the -- SC&A's report. 

So that's where we get to the uncertainties. So, you know, if we 

inventory by year, we did not inventory again by nuclide. So, if you don't 

design the study, which is what we did, and we excluded nuclide, we can't 

really identify the uncertainty associated with the bars in these charts. So, 

we don't have an up and down here. So, it's very difficult to make a 

comment about whether or not something is statistically higher or 

statistically significant or they -- are they essentially the same. Without 

knowing those uncertainties, without understanding how this bar and 

uncertainty would be, these may very much overlap. These certainly might 

overlap. These could. So, we just need to be careful about how we 

interpret a particular metric without knowing its uncertainty. 

But one -- 

CHAIR CLAWSON: John. 

DR. CARDARELLI: Yeah? 

CHAIR CLAWSON: Let's go back. Let's go back to that. 

DR. CARDARELLI: Sure. 

CHAIR CLAWSON: Because that -- I just want to point out something. 

You know, you're saying SC&A's uses these phrase -- phrases. You do 

realize that that was for data completeness, and we did get that from your 

report 92 because you guys used this same one. So, to tell them by using 

this -- you guys are using the same ones. I just wanted to point that out to 

you, because that kind of struck me a little bit odd. So, go ahead and go on. 

DR. CARDARELLI: Okay. 
58

MEMBER LOCKEY: John, this is Dr. Lockey. When I -- when I was 

looking at this table the last couple of days, you know, maybe it's because of 

the background I come from and I deal with databases, this type of table 

wasn't helpful for me. If you don't have numbers and (indiscernible) in the 

rows, you can't -- it -- it -- it is very difficult to interpret. So, why would a 

table, I guess, be -- why would you present me this table without the data, 

that information? 

DR. CARDARELLI: I think that might be a question you might want to 

ask SC&A, because this is -- we're simply responding into a table that they 

presented to us. 

MEMBER LOCKEY: Oh, this an SC&A table. I'm sorry. I shouldn't 

have asked that question, maybe. Okay. Just in a general overall, I mean, 

when I see a table like this, you need (indiscernible) and rows. You need 

the numbers to interpret the data or it -- it's uninterpretable. It really is. 

DR. CARDARELLI: And that -- that was part of our statement here. 

So, and that that answers part of that conclusion in our response in 

conclusion four. 

Now we're going to get into what we spent a lot of time talking about, 

this 79 percent issue with -- with compliance and completeness that was 

brought up. And I think that the key measure or the key statement is --

really the topic of this slide, is noncompliance with a program does not 

prevent us from developing a coexposure model and doing dose 

reconstructions. So, what we call the other half of conclusion four deals 

with, what we call, the job-specific sampling, which are routine samples but 

are specific to a particular job. They're not specials because nothing 
59

happened in the environment which would have caused a special event 

where we think you have been exposed. But so, we looked at job specifics, 

the audits, the 1990 Tiger Team finding, and then the 1997 and 1998 

Westinghouse Savannah River Company actions as a result of the Tiger 

Team finding, which we discussed earlier. And it was discussed in previous 

Board Meetings and work group meetings, I believe. 

So, in report 102, and report 102 is not with the Savannah River site. 

Report 102 is an analysis of the plutonium bioassay program at the Los 

Alamos National Lab. And in that report, it states clearly that compliance 

with the regulations in place at the time of the radiological work was 

performed is not required in order to perform dose reconstructions or 

develop a coexposure model. So that's kind of the key message. We're 

applying the same logic to Savannah River that has been applied at Los 

Alamos. Dr. Ziemer made a very similar statement to this during an 

Advisory Board meeting in April of 2021. So, the audits, the Tiger Team 

findings, all the company actions to address this -- this perceived 

noncompliance -- or not perceived -- the noncompliance on a procedural 

violation does not affect our ability to create a coexposure model that's 

claimant favorable to give doses to people who were potentially exposed but 

not monitored. 

Getting a little bit more detailed in what is a job-specific sample 

definition and why there's been some confusion. Totally understandable, 

because in the SRS procedures, the 5Q1.1-506 -- I won't read this slide to 

you, but I will point out the two areas that I have underlined in these two 

different definitions at different points where they talk about routine 
60

program and the quote/unquote, underlined, nonroutine, job-specific 

program. 

So when you follow it up with the way that is, it certainly implies that 

a job-specific bioassay would not be part of the routine program. That's 

frankly just poor writing, and it's not how it was practiced in the field. The 

second paragraph says something very similar, nonroutine job-specific 

bioassay programs. In effect, they were all part of a routine program. It 

just determined whether or not something was specific to a job and you 

were not on an already routine program. So, the key point here is jobspecific samples are not special samples. Those are the samples when you 

have a failure in PPE or the engineering controls where an intake is likely 

suspected. The specials are going to be the most highly -- the highest likely 

bioassay results. And we want those in this coexposure model to make it 

more bounding and claimant favorable. 

So, yes, this contradicts a 2017 interview with a former site internal 

dosimetrist where job-specific bioassay is a program prescribed in response 

to a specific event, but it's not a special bioassay. So, we're mixing up 

different meanings, and -- and even the site protocols give the wrong 

impression. 

This gets down to the DOE notice of violation that Mr. Clawson has 

brought up. And I just wanted to point out that the notice of violation was 

changed from a health and safety violation to one of a procedure because 

DOE agreed that job-specific samples or routine samples were not the same 

as special samples, which was implied that they were not doing proper 

bioassay samples. And so it became -- and it's a big difference whether or 
61

not you have a health and safety violation or a simple procedural violation.

I will say that the special bioassays, the ones where workers were 

likely involved with a potential intake of greater than 100 millirem because 

something unusual happened, they are prescribed by RadCon prior to 1991, 

but the areas after 1991, we would get a phone call and the internal 

dosimetrist would be asked this happened in the environment, should this 

worker leave a bioassay sample, and what should they leave it for. And that 

information was tracked, which is something that we've recently learned. 

And I'll get to that at the end -- 

CHAIR CLAWSON: Yeah, but John, -- 

DR. CARDARELLI: -- of the slide. 

CHAIR CLAWSON: John, I -- I just want to -- you are correct. A 

health and safety violation is different than a procedure. Do not ever say 

that a procedure violation is small. The world I come from, you violate 

procedure, I see many people go down the road because of it. It is 

mandatory, DOE compliance is, period. 

And for this comment, despite what the procedure said, job-specific 

samples were part of a routine program and were not specific samples 

according to the site procedure. You're stating to me right there that -- and 

this is why they were fined -- that they were not complying to DOE 

procedures, period. There's -- there's no question of that. 

DR. CARDARELLI: Well, yeah, there's no -- 

CHAIR CLAWSON: And -- and this is -- 

DR. CARDARELLI: -- question. 

CHAIR CLAWSON: And this is the same thing -- this is the same thing 
62

that this individual went to DOE, and he fought the same way and 

everything else, and they told him that they had a good -- they had a good 

normal routine bioassay program, but they were not complying to their 

procedures. And that's why they were fined. And they found people that 

had fallen through the cracks. 

DR. CARDARELLI: Correct. 

CHAIR CLAWSON: That's the issue. 

DR. CARDARELLI: Yep, my apologies. I don't mean to imply that any 

violation of anything is less. Certainly, if the procedures called for it, it 

hadn't happened, they did get fined for that. So, thank you for that 

clarification. 

So, coexposure models that we are planning to develop or are 

developing, they will include these specials, which is -- makes it a bounding 

coexposure model because the most highly exposed workers are part of the 

data set. And why are they the most highly exposed workers? Because 

they have been called out because they've been involved in an incident 

where the engineering or personal protective equipment and controls have 

failed, and we feel that they have been exposed outside the routine 

environment. Their bioassay datas will be included. So, if the samples 

collected were suspected intakes, which they are because their specials, are 

part of the data set, a bounding coexposure model can be constructed 

regardless of what the job-specific sampling and radiation work permit 

states. 

So, we did a follow-up question on the internal -- from the internal 

dosimetrist recently, in October of 2022, to get some clarification because 
63

we wanted to verify whether or not these special examples -- or special 

bioassays can be included. And we've learned that during the time period 

starting around in 1991, anytime someone had a special that the internal 

dosimetrist had to approve a request, that went into a separate database. A 

database that is just called TRACK. 

So, they were tracking people who had this highest potential exposure. 

Okay. So, the response on conclusion number four, which was the RWP 

specified job-specific bioassay data are incomplete. That would be an SC&A 

conclusion. Our response is if the samples prescribed by the site internal 

dosimetrist when a suspected intake occurred, the samples that are in this 

new TRACK database are part of NIOSH's coexposure database, this is 

evidence that a bounding model could be constructed despite what this 

conclusion shows. 

I can say that we have already made a request, a formal request, to 

the site to get a copy of this TRACK database. The most recent feedback 

that we received is we are expected to receive this TRACK database 

sometime in May. Obviously, after we receive it, we will verify whether or 

not the information in that TRACK database is included in our coexposure 

models to validate and verify this conclusion. 

Any comments on that one? 

CHAIR CLAWSON: Well, it -- it's interesting because that individual 

has been a part of your program for so long and that now we're just hearing 

about this. I do have a problem with that. 

But I do just -- you know, going back to this procedure violation, I 

want to make sure that everybody is clear on what that procedure violation 
64

was for. It was for not -- not collecting required bioassays. That's what the 

procedure violation was for. These people did not collect those. 

Now, I -- I -- I -- I'm -- it'll be interesting to see this TRACKs. I can't 

talk to that. It's interesting that we've gone this far and now all of a 

sudden, we find this. But it'll be interesting to see, because how do you --

how do you track something that the information really got into that? So, 

we'll -- we'll see what comes up with that. 

And I'm good with -- and we can just continue on. 

DR. CARDARELLI: Okay. Just one -- one point -- 

CHAIR CLAWSON: All right. All right. 

MEMBER LOCKEY: Brad, I -- hold on a second. Brad, I didn't 

understand your -- your last statement. I -- about -- 

CHAIR CLAWSON: What part of it? 

MEMBER LOCKEY: Just the very last piece, Brad. 

CHAIR CLAWSON: You talked -- have you heard of TRACKs? Have 

you heard of TRACKs yet? 

MEMBER LOCKEY: I've heard of TRACK, what they're talking about 

here. So, what I was trying to say is that if they -- if there is TRACK data 

available, they can run an analysis to see if their current database contains 

that or not. If it doesn't, then that's a problem. If it does, that's reassuring, 

I guess. That's how I interpret that. I wasn't sure where you're going with 

it. That's all. 

CHAIR CLAWSON: What I looked at is what they are -- to me, what 

they are saying is that all these special RWP requests were done by 

contacting the health physicist and him evaluating if they needed to be 
65

sampled or not. So, how do you know -- are you -- is this TRACK, is it 

saying was contacted on June 1, that this person has this kind of a RWP, but 

I don't feel that they need to be on a special bioassay? 

Is it -- is it set up in that way or is it saying that each one of them has 

gone through there and that each one of there, you know, the -- the whole 

thing is -- is -- you know, it's just -- it comes back to a computer, Jim. 

Garbage in, garbage out. If you don't have a way of being able to track the 

information that went into this and what was accepted and what was not, 

how -- how do you say that was good? 

That -- but -- but I can't really speak about that, Jim, because I -- I'm 

-- until I see it, until I evaluate it, I really can't. I can just speculate at this 

time, and that's -- that's why I was kind of big on it, and I apologize. Next 

time I'll try to bring better crayons for you. 

MEMBER LOCKEY: No, Brad, this -- this -- you know, dose 

reconstruction and looking at databases this size is not an easy task. It's 

not easy. Anybody says it's easy hasn't done it. But what I was trying to 

understand -- maybe John can answer this -- when you talked about TRACK 

data, you're talking about samples that were special samples, meaning that 

it wasn't unusual, or it was something that happened. Is that what a TRACK 

sample is? 

DR. CARDARELLI: Yeah, my understanding of the TRACK database is 

it doesn't contain any of the routine or job-specific results; those are more 

routine. The TRACK is really a separate database that keeps a counting of 

all of the specials, and the specials are representative of something that 

went abnormal in the environment or a known potential intake. So, these 
66

would be the highest potentially exposed people as a result of some 

abnormality in the work environment. 

MEMBER LOCKEY: Okay. So, I guess, what I'm asking then, John, is 

if I was an independent investigator and I wanted to look at my database 

and I found out that these were available, I would look at those results and 

compare them to my current results and see, if fact, I do have the highest 

exposures in my database. Is that what you're...? 

DR. CARDARELLI: Yes. You broke up a little bit, but I believe that's 

exactly our next step is to get a copy of the database and then compare it to 

our existing coexposure models to verify the all the data in TRACK is 

included in the models. 

MEMBER LOCKEY: And would your hypothesis be that TRACK data 

most represents the highest quartile? 

DR. CARDARELLI: That would be -- yes, that would be expected, 

because there was something unusual which caused them to have a special 

bioassay taken. 

MEMBER LOCKEY: And if you don't -- if you don't control your 

hypothesis, then that's going to make you think double about your current 

database, I take it, right? 

DR. CARDARELLI: You want to repeat that? You want to say that

again, Dr. -- 

CHAIR CLAWSON: (Indiscernible.) 

MEMBER LOCKEY: I'm saying -- what I'm saying is if you look at this 

TRACK -- you have a hypothesis that in theory the TRACK special exposures, 

and by nature that's accidental exposures or unanticipated exposures, I 
67

would expect that that data from an exposure perspective should be in your 

top quartile, okay? 

DR. CARDARELLI: Yes. 

MEMBER LOCKEY: Okay. So, if that's -- perhaps that's your 

hypothesis, and now you're going to test your hypothesis, correct? 

DR. CARDARELLI: Yes, but I will put this little qualifier. These are 

taken because of the suspected uptake because of something abnormal. It 

doesn't mean that they're all going to be high. You could have a zero or 

nondetect in the specials because the person didn't have an intake, but they 

were involved in an incident that potentially resulted in an intake. 

MEMBER LOCKEY: And I -- and so that's an uncertainty, but I just --

from a logic perspective, you would think at least some of these would 

represent the highest exposure levels. 

DR. CARDARELLI: Yes, that's a fair assessment. 

MEMBER LOCKEY: Oh, okay. 

CHAIR CLAWSON: You know, I guess, part of your terminology of a 

special RWP and so forth like that, we -- we dealt with them when we went 

into any area that was a nonroutine area that had different radionuclides 

than what was on our normal RWP that we were being monitored for. But 

also, too, when we were doing a job and all of a sudden an air sample went 

wrong and we were getting something that we did not expect, then we were 

given a special -- they had to provide a special RWP, but it also put us in the 

process of if we have to, you know -- if we had nasal smears or whatever 

and we showed up something, then all of a sudden we had a special 

bioassay that we had to do. 
68

Some of the terminology -- and I'll be quite honest with you, John --

on special RWPs and so forth like that is -- is a little bit different than -- than 

what I -- I've dealt with. So, sometimes if -- if I'm questioning things, it's 

because it's -- it's different than what I've dealt with in DOE, and I know 

DOE's compliance of two procedures, and I thought they were all kind of the 

same. But I think we're talking past each other a little bit on some of these 

special RWPs. 

DR. CARDARELLI: Yeah, yeah, a little bit, but I agree with you that 

the terminology, while important, can be confusing. And here I'm talking 

about special bioassay samples versus RWPs, just for clarity. And Dr. 

Lockey and Mr. Clawson, you guys bring up excellent points. We would be --

I would certainly be interested once we do get this TRACK database, it has 

the date, we could be looking at additional information to get a better 

understanding of why it was called a special. Because, as we have seen in 

the past, workers do get nasal swabs or there's a surface contamination 

measurement or there's an air sample that's also available that could be part 

of an incident report that would help give us a better understanding. And a 

worker may have a very large nasal smear, but the bioassay be 

nondetectable. Those are types of situations that can occur, and that goes 

to a little bit of what Mr. Pompa talked about was, when you take that 

sample, because it may take time from the time they inhale it for it to 

actually show up in the -- in the urine, and that could be weeks, months, or 

much later than the actual day of the exposure. So that's -- we -- we put all 

of this information together to try to understand the workers' potential 

exposure, so... 
69

CHAIR CLAWSON: Now I've got a question for you. So, my 

understanding in this and -- and in reading the enforcement action on this, I 

never read anything about TRACK in that. And so, I -- I'm sure that being 

the health physicists at this facility that DOE had already looked at this 

TRACKs before issuing the procedure noncompliance. So, I -- I -- I want us 

to keep that in mind too, that this -- this -- this has already been seen by 

DOE. 

MEMBER LOCKEY: Brad, can I ask you -- 

CHAIR CLAWSON: (Indiscernible.) 

MEMBER LOCKEY: Brad, can I ask, maybe, you or Paul a question or 

both of you? I'm not knowledgeable on -- I'm certainly knowledgeable in 

health and safety issues and procedures involving railroads, and it's very 

clear cut. There are certain violations at a railroad you lose your job and 

other violations, you're -- you're -- you're given a warning. 

What's -- what's root -- what is the difference between health and 

safety violation and a procedure violation? What -- what is that? What's the 

difference? Is there an administrative difference? Is there a definition that 

breaks those two out? 

CHAIR CLAWSON: Well, I'll let -- Paul was part of DOE and in that 

section, I'll let him answer it better. But my understanding, if it's a health 

and safety one and an individual can be actually hurt like this, it is very, 

very serious. And one of the reasons why DOE in their report as they put 

this -- of the notice of violation, they did say that Savannah River did have a 

normal -- they did a good job on their normal routine bioassay, but they 

were not in compliance with their procedure where there was 79 percent 
70

that were not collected. In the procedure, it says that you will collect these 

bioassays. That is why afterwards, they had to go back and do 100 percent 

checking. 

Now, in my world, when I have a procedure violation, it is different 

than a RadCon, because mine are tied to criticality, to national security, and 

to a lot of different things like that. And those are usually -- we usually -- if 

you willingly violate a procedure, you're fired, period. No ifs, ands, or buts. 

But --

MEMBER LOCKEY: They shifted you -- your -- your procedures are 

more of a national security issue, I take it, right? 

CHAIR CLAWSON: Well, criticality, too. 

MEMBER LOCKEY: Gotcha. 

CHAIR CLAWSON: Or -- or it actually comes into a health and safety 

issue because if we violate a criticality control, we can actually endanger the 

life and safety of other people around us and the surrounding community. 

MEMBER LOCKEY: Gotcha. 

CHAIR CLAWSON: So, but -- but, Paul -- Paul was in the situation 

where -- where he was actually in the health and safety of DOE, so I'd let 

him, if he's online, address that if I've done it correctly or not. 

MEMBER ZIEMER: Yes, I'll -- I'll answer that in part and indicate this 

would be true of DOE and also of the regulatory commission, that some --

there are some procedural things that don't rise to the level of having to 

report them up the line that are taken care of internally. These would be 

rather minor things that you would take care of with the administration of a 

particular site. But there are other things that I -- in the type that Brad's 
71

talking about that are serious enough that they go all the way up to the top 

of the pyramid, as it -- as it were. 

And, for example, for a Nuclear Regulatory Commission facility, there 

are things that it's mandatory to report to the commission because they 

violate certain requirements of a license or of a regulation. And same is true 

in DOE where facilities have to report things up to the -- the DOE. The other 

part of this and the -- the issue of whether it's a violation or whether -- well, 

let's say a violation precludes dose reconstruction, you could have a 

violation, and we have, where a bioassays weren't being done, and, in fact, 

that's one of the reasons why you go to a coexposure model, because you 

have those -- those violations that cause a lapse in the data available for a 

worker. So, you can do dose reconstruction, regardless of the violation is --

is one of the points. But, yeah, if you're working with critic -- a critical --

potentially critical mass materials, you got some very strict -- some very 

strict procedures that would automatically up -- up the chain if they were 

violated.

MEMBER LOCKEY: Jim Lockey again. When I read this bullet point, 

1997 NOV was changed from health and safety violation to procedure 

violations because the DOE agreed that the job-specific samples are not -- 

MEMBER ZIEMER: Because what? 

MEMBER LOCKEY: Just reading that bullet point on page 32. The 

middle bullet point. I guess I just don't understand why did -- why did DOE 

change to a procedure violation? 

MEMBER ZIEMER: Well, 1997, I wasn't around the DOE at that time. 

So, I can't -- I can't speak to that specifically. 
72

CHAIR CLAWSON: But well, it -- it calls it out in the notice of 

violation, and correct me if I'm wrong, Tim or John, but the reason why they 

changed it from a health and safety -- because that is a much higher issue. 

When you have one of those violations, that is a lot more serious -- to a 

procedural one because they still did have a normal bioassay routine process 

that they were doing, but they were not complying with the collection of the 

samples. I believe that's the way that it was state -- stated in the notice of 

violation, and that's why they dropped it down. And -- and that was actually 

at the request of Savannah River because a health and safety violation is a 

very serious one, because they're saying that you've actually put people's 

lives in jeopardy. But they also said because of the normal bioassay process 

that Savannah River had, their normal bioassay routines -- routine sampling, 

they did drop it down to a procedure violation because that -- that was not -

- it is not as serious in DOE's world. 

MEMBER LOCKEY: Okay, thanks, Brad. I just -- I mean, I kept 

reading that and I -- I can relate to my own environment where I work, and 

I understand what it meant, but I didn't -- did not know what it meant at a 

DOE facility. Okay. 

CHAIR CLAWSON: And am I correct in that assumption, John? 

DR. CARDARELLI: I believe so. Tim? 

CHAIR CLAWSON: Right. 

DR. TAULBEE: Yes. 

CHAIR CLAWSON: Because -- because it call -- it calls it right out in 

the notice of violation. And I believe it even states in there that at the 

request of Savannah River that da-da-da-da, and they justify why they 
73

dropped it down because of the normal bioassay program that they had in 

place. The violation came from -- from noncompliance to the procedure, 

DOE's CFR -- I can't -- can't remember what the whole thing was on that. 

DR. TAULBEE: I believe -- 

CHAIR CLAWSON: -- and that's -- that's why they dropped it down.

MEMBER LOCKEY: Appreciate it. Thank you. 

DR. CARDARELLI: Okay. I just wanted to kind of summarize that up, 

that Dr. Ziemer mentioned, that just because something was not compliant 

doesn't mean we can't do a coexposure model. In fact, that's why we want 

to do coexposure models that -- so we can give exposure to people who may 

have been unmonitored but should have been. So, that part's good. 

The other thing that you will see in the next presentation -- because 

I'm coming close to the end of mine -- is this 79 percent compliance factor, 

and that's very -- frankly, that's a very misleading number. It gives the 

perception that there's 79 percent noncompliance. What that really 

represents is a 5 percent of the total. So, it's 79 percent of the 5 percent 

that were not compliant. And then of those, everyone was retested, and not 

a single one of them came back with an intake with exception of two people 

who had left the site. So that's where you get the 100 percent were not 

exposed. So, when you see 79 percent, think of it being -- it's 79 percent of 

5 percent of the people monitored. So, that would be a more accurate or 

complete definition for that. 

CHAIR CLAWSON: Okay. And John -- and I understand what you're 

saying on that. That being said, that 5 percent -- now, you're talking the 

whole total overall, the 79 percent were special RWPs, basically, correct? 
74

DR. CARDARELLI: No, I think that they were special bioassay, not 

special -- 

CHAIR CLAWSON: They are -- 

DR. CARDARELLI: -- RWPs. 

CHAIR CLAWSON: -- special bioassays. Now -- 

DR. TAULBEE: They were the job-specific bioassays. They were the 

job-specific bioassays. 

DR. CARDARELLI: Job specific. 

CHAIR CLAWSON: (Indiscernible.) 

DR. CARDARELLI: I'm sorry. You're right. Job specific. 

CHAIR CLAWSON: Which -- which you're -- we're using terminology 

that are kind of crossing over one another. Now, if when they did that 100 

percent -- and this comes out in the notice, too -- if when they did that 100 

percent violate -- or the monitoring over the next year, and if they would 

have found one person that had had an update, they wouldn't have been 

able to drop that from a health and safety down to a procedure. 

DR. TAULBEE: That is correct. 

CHAIR CLAWSON: But so, that's where luck was on their side. It's --

it's -- it's -- I want people to realize that that was very fortunate. 

DR. TAULBEE: Well, it's also, I think -- there's another slight -- a 

different interpretation from that standpoint in that the site was potentially 

over monitoring the number of people that they needed to be monitoring, 

and so, the overall population that was being monitored was larger than the 

potential that had to -- of people that had a potential for exposure to exceed 

100 millirem is another interpretation of that, not that they necessarily got 
75

lucky, that they had a larger coverage -- 

CHAIR CLAWSON: Well, and -- 

DR. CARDARELLI: -- than was necessary. 

CHAIR CLAWSON: And I understand what you're saying, but, you 

know, even in today's world in DOE, we -- we still have the problem because 

we are at this -- this '91-'97 time period here, this is when we're changing. 

Before, when this was all DuPont, they were paid X amount of dollars for 

doing the process. Now all of a sudden the monitoring of the workforce, the 

monitoring of everything, comes under the contractor that is having to foot 

the bill for it. 

So, that 100 millirem, that was a thing that they kind of came to if 

you're -- if you don't have the exposure or ability to be able to go over 100 

millirem, you don't have to be monitored. And this is still a battle that 

they're fighting today because of the term "potential." Now, I deal with 

items that far outweigh the potential for 100 millirem, in a heartbeat I could 

be done. But because of my safety factors and everything else like that, the 

company still can say well, nope, he's not going to get that. They monitor 

me up to 100 millirem. I have to get a special letter to go past it, so forth, 

everything else like that. 

This -- this isn't a time change here. This '90 time period is when the 

CFR is starting to come out and things are starting to change. And also, the 

contracts are starting to change. So this was -- this is part of the issues of 

where these changes start to happen a little bit different, and they're still 

dealing with them today. 

DR. CARDARELLI: Okay. I think this is my final slide. Conclusion 
76

number five -- or actually, it's not. It's the second to final. It's the -- the 

conclusion -- SC&A's conclusion was that the feasibility of a coexposure 

model needs to balance an RWP implementation with completeness and 

coworker data. And go -- bring us back -- back to early on in our discussion, 

this is where the concept of feasibility of developing a coexposure model 

became part of our narrative with regard to the shift in the focus because of 

this particular conclusion. SC&A's conclusion, where they're using the words 

feasibility of needs to balance. So, that might explain how that -- how we 

came to that interpretation.

But I wrote an email to get clarity of exactly what they meant by that 

particular statement and asked if we address all of the concerns that they've 

mentioned in conclusions one through four, would SC&A consider our 

conclusion valid that would support the development of a coexposure model, 

and they wrote back and said yes, our interpretation is correct on that 

generalized statement. So, we don't believe that there's any detailed 

response necessary other than the fact that we have asked, they have 

answered, and we believe that we've met their expectations. 

So to wrap this up, there were five conclusions or five responses to 

SC&A's conclusions. The first one is absence of a bioassay requirements on 

RWPs in the early '90s is irrelevant because bioassay programs were 

prescribed by procedure. If you're exposed, you go on a routine program. 

The RWP in the early '90s did not specify which radionuclide. It was done by 

procedure. That was later changed in the mid '90s where they included it on 

the RWPs. 

Number two: Changing the definition of "monitored" had the expected 
77

effect, but the new summary statistics do not prevent creating a coexposure 

model.

Number three: SC&A's coworker matching criteria are far too 

restrictive because coexposure -- for coexposure models, the only necessary 

criteria is that the monitored worker has the same or higher exposure 

potential than the unmonitored worker, and we went so far as to look at 

them who signed in on the same date, same time, within a 15-minute time 

period.

Number four: Regardless of the issues that SC&A pointed out, if the 

samples from the most highly exposed workers -- and these would now be 

considered the people in the TRACK database -- if they're part of the 

coexposure database, this is evidence that a coexposure model could be 

constructed, be representative, and probably bounded. 

And the final one is NIOSH has addressed all of the SC&A previous 

issues from a focused review, and we maintain that coexposure models can 

be developed for subcontractor construction trade workers, that we can 

apply those numbers to unmonitored workers for dose reconstruction 

purposes. So, that concludes my presentation. It didn't -- I didn't expect it 

to take almost two hours -- two and a half, but we had good discussions. 

CHAIR CLAWSON: That being said, is anybody willing to have a 10-

minute comfort break? Rashaun? 

DR. ROBERTS: I think that's probably in order. So, do people want to 

come back -- could we say 1:35 Eastern? 

CHAIR CLAWSON: Yeah, that'd be fine with me. Lockey, are you 

going to be able to take care of that? Will that be okay for you, or do you 
78

need more time? 

MEMBER LOCKEY: Well, I was going to take a break and go skiing if 

that's okay with you, but I'll stay around. 

CHAIR CLAWSON: Okay, sounds good. Okay, we'll see you guys in 10 

minutes.

(Whereupon, a break was taken from 1:22 p.m. until 1:35 p.m.) 

DR. ROBERTS: I'm going to do a quick roll. Clawson? 

CHAIR CLAWSON: Here. 

DR. ROBERTS: Lockey? 

MEMBER LOCKEY: Here. 

DR. ROBERTS: Pompa? 

MEMBER POMPA: Yes, ma'am. 

DR. ROBERTS: And Ziemer? Okay. I don't hear Ziemer, but Brad, I'll 

defer to you. We do have the quorum. Do you want to go ahead and get 

started or see if Paul signs on in a couple of minutes? 

CHAIR CLAWSON: Let's go ahead. We can -- we can start into this. 

It'll take us a few minutes to be able to get started anyway. So, I -- we did 

-- if it's all right, Rashaun, go ahead and proceed then. 

DR. ROBERTS: Sure. 

CHAIR CLAWSON: Okay. Well, I'd like to thank John for his 

presentation and so forth like that. I would like to ask if there's any Board 

Members that had any more questions for John. I know that we kind of 

came to an end. But with the discussion, I thought that a comfort break was 

a lot more important at that time. So, I'll open it up to any other Board 

Members that have any questions. If not, then you're off the hook, John. 
79

Boy, that's -- that's pretty doggone easy. I think we took advantage of it on 

the way through, so. 

DR. CARDARELLI: Thank you, Brad. 

SC&A Presentation: Focused Review of ORAUT-RPRT-0092, Revision 00, and

Remaining Petition SEC-00103 Evaluation Report Period 1971-2007

CHAIR CLAWSON: I'm going to turn it over to SC&A with their 

presentation now, and we'll go from there. 

MR. FITZGERALD: Yeah, thank -- thank you, Brad. This is a Joe 

Fitzgerald, and I am looking to you, Bob, to -- I think Bob's about ready to 

share the screen. Thanks. 

I have -- I can report I have 18 slides. So, this is definitely going to 

be a little shorter, I think. And I'm going to just walk through these, sort of, 

introductory ones pretty quickly. Next slide, Bob.

Yeah, just -- just a little bit of milestones here. The reason we're, you 

know -- we're kind of giving you an initial reaction or response to NIOSH's 

report is -- we did get this in January, and we've been going through 

references and actually looking at some of the data. Again, we will be 

preparing a report, but we're not quite ready to give any formal -- you 

know, formal responses. And, John, thank you. I think this was actually 

very helpful to us as we're trying to interpret and understand the NIOSH 

response. So, I think this was very a helpful -- you know, has been a very 

helpful discussion.

Next one, please.

Okay. I'm not going to go through this, but just to, again, reflect on 
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the milestone that the Advisory Board did provide a recommendation for the 

SEC for '72 through '90 for subcontractor construction trade employees. 

And this is certainly a continuation of the review that led to that particular 

SEC. And what I want to do is provide some context for the tasking that we 

received. And our tasking, basically, was to continue the review for the 

work group for the successive years, you know, '91 to 2007, review report 

92, which was, of course, the -- the basis for the discussion that has taken 

place over the last several years. So we -- this is a continuation -- from our 

standpoint, it's a continuation of that review. 

Next slide please. 

And this is more specific on the basis for the -- the SEC class that was 

defined and recommended. And, basically, subcontractor construction trade 

workers, CTWs, conducting a broad range of work activities. And I want to 

emphasize that this class is a relatively special class in that they may have 

worked in high contamination, high airborne reactivity areas, and the work 

is -- was typical -- and Savannah River is not that much different from other 

sites -- it's typically intermittent, often short-term high exposure work tasks.

And particularly in the early '90s, subcontractors at Savannah River 

were relatively transient given the restart activities on the reactor, and also 

with the cleanup in DND that was going on. So a lot of subcontractor 

workers coming and going, intermittently tasked, moving from facility to 

facility, often doing the hot jobs, that the -- you know, the permanent 

employees were not used for. And -- and often, because they were 

intermittent, did not receive termination bioassays. 

So, you know, certainly the -- the problem is one of trying to capture 
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any intakes that they may have received. And I want to emphasize this 

particular work category, this worker category, because I think, in John's 

presentation we were talking about, you know, that one could, I wouldn't 

say overlook, but one could still proceed perhaps to coexposure model even 

with this kind of data missing if you judge that the routinely monitored 

worker population was large enough or perhaps you judge that because of 

radiological controls and management that the most highly exposed 

individuals are somehow reflected in that population. 

And I think you just -- and again, this is from our review -- can't 

assume that this particular subset, the subcontractor construction trade 

workers, and the type of work they did and the type of exposures they were 

exposed to can necessarily be a subset like that and judged not significant 

enough to be -- to be treated that way. So, I just wanted to make sure that 

was clear. 

Next slide, please. 

And, again, on the -- this is the final, sort of, backdrop, in terms of the 

SEC, finding. The Board found in their -- in its recommendation -- and this 

was the basis for the designation for the prior SEC class for subcontractors 

that there was insufficient information, including a lack of job-specific 

bioassay monitoring data for subcontractor construction trade workers. And 

also, insufficient assurance that the workplace monitoring and source term 

data was being collected. So, it was -- it was a combination of -- of -- of 

incomplete data, lack of data, and inadequate assurance that the -- that the 

bioassay or the data itself was being collected. 

And this is essentially our starting point in terms of, what I would call, 
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our focus, since that word is being used a lot. Our focus for '91 to 2007 is 

squarely on these issues, the completeness of job-specific bioassay data and 

whether that can be tied to some demonstrable evidence of program 

insurance -- assurance, and implementation to collect those bioassays. So, 

sort of a two-way thing. And no, we have not shifted from that focus. That 

is our focus, it has been our focus for the last three or four years. 

Next one, please. Yeah. 

And so, the question that guided us is when did the information 

become sufficient, since that's the key word that was used in the SEC basis, 

to enabled dose construction with sufficient accuracy? And, again, our 

context is report 92. That's the scope of what we're operating with and the -

- essentially the understanding and the data that we're working with. So, 

we did not shift from that focus or that context. 

And quite frankly, we're not -- we're not privy -- and I've been 

listening very intently to John's presentation. It's been very helpful to me, 

because I was a little confused with the response, the written response, that 

we received. We're not privy to NIOSH's -- and I think this was mentioned 

by Tim -- you know, privy to NIOSH's emerging -- I don't know, what is it, 

new policy or new approach on coexposure model development. But, you 

know, we, given tasking and given the history on this review, are pretty 

much confined to reviewing report 92 as the means to sample for 

completeness, and to extend that into these successive years to see whether 

those conditions may have shifted for the positive or in terms of more 

completeness and more program ensures -- assurance to enable dose 

reconstruction with sufficient accuracy. 
83

So that's kind of where -- that is the context and the focus of what 

we're doing. And in that review -- and I think John's covered this fairly well, 

but let me just, kind of, stop on this a bit -- is from a programmatic 

standpoint, you know, we're looking at the WRP (sic) and the job-specific 

bioassays policies, procedures, and practices, and more importantly, to what 

extent there's evidence that they were implemented in the workplace at 

Savannah River. And we're -- and we're linking that with another review 

and, of course, we had conducted something very similar in the last three or 

four years in that -- in our review of Savannah River to look at the data that 

has come out of report 92 on RWPs and the extent to which one can match 

those with corresponding bioassays and to see what we can see for the early 

'90s in terms of data completeness and to the degree which those bioassays 

were submitted.

Now, generally -- and we've said this in the past -- the -- certainly, the 

perspective of RWP implementation and job-specific bioassays much -- were 

much different in the Westinghouse era than in the preceding DuPont era. 

In the DuPont era, as report 92 and that review and follow up found, you 

know, we had job plans. We didn't have RWPs so much. And those job 

plans did not have any firm linkage to job-specific bioassay. So, trying to 

arrive at, you know, good conclusions facility by facility or site-wide just 

didn't prove to be feasible. I think it was only one facility, if I remember, for 

which RWPs had been done, you know, for any length of time. 

So, with RWP implementation during the Westinghouse era, certainly 

report 92 does provide some (indiscernible) for review, and that's how we 

focused on it, to take what data we had in report 92 and to kind of focus on 
84

how one could apply that data. And, again, I guess, I have a little bit of an 

issue with trying to dress it up in terms of a lot of statistical precision 

because, again, I think given the way the data is collected -- I mean, it was 

all available RWPs, and if people recall, we had a -- we had some good 

fortune to uncover, I guess, it was 40 or 80 boxes of RWPs at the eleventh 

hour which added to the complement. But it's proven to be -- it had proven 

to be a much bigger issue to actually come up with what was available, and 

it wasn't necessarily complete by time or facilities in a lot of cases. So, we 

always appreciated that in doing this sampling, it would be probability more 

of an indicator basis in terms of -- of a -- an opportunity to look at what 

completeness -- what one could conclude on completeness but realizing that 

it would probably fall short of what would be useful in a coexposure model. 

So, this, again, and it's strictly in the context of data completeness, and 

strictly from the standpoint of looking for some indication of completeness 

that we could use to illuminate the question of when did the circumstances 

at Savannah River change for the better in terms of data completeness such 

-- such that a coexposure model would be feasible later.

MEMBER LOCKEY: Hey, Joe, this is -- 

MR. FITZGERALD: Next slide, please. 

MEMBER LOCKEY: -- Dr. Lockey. Now I'm going to interrupt you -- 

MR. FITZGERALD: Yeah. 

MEMBER LOCKEY: Back in the '40s, '50s, '60s, maybe '70s, you know, 

when I was initially involved with looking at K-25 and Y-12 in relationship to 

whether they could reconstruct exposures back in the early '90s, we 

determined they couldn't, especially back in the '50s and '60s. Our 
85

databases now are much more comprehensive, much more complete, more 

extensive. And I really have trouble with you when you use the term "dress 

it up in statistics." I know you're knowledgeable in statistics. I know you 

come from a great background. You can't possibly look at this type of 

database with this many samples, with this redundancy, and not do a 

(indiscernible) statistical analysis to see if it's about a database. I mean, 

(indiscernible) statistics -- I mean, to me that's an offensive remark. 

MR. FITZGERALD: Well, I'm sorry that you took it that way. I think 

my perspective was the original sampling plan that was developed was --

was applied to what was available in terms of the RWPs that could be found. 

And I think it was discovered early on that the RWPs that could be found 

were quite desperate, were -- were not as complete or nearly as -- perhaps 

as useful as was envisioned. 

And -- and the number of RWPs for the specific facility in years are 

essentially your -- your denominator if you're looking at the fraction of those 

RWPs that were, -- in fact, could be linked to required bioassays. So, when 

we were looking at the, you know, completeness, we recognize that, you 

know, that's is the source of the information that we're -- we're starting with 

and the -- you know, maybe the best we could hope for is to get some 

indication of, you know, relative completeness from the standpoint of the 

RWPs we have for the specific facilities and times and workers. The -- this 

would be the fraction that happened to show that bioassays were collected. 

So, we recognize that was more of an indicator, one that -- for which 

we certainly did not know the completeness of the RWPs that we even 

started with. And when we were -- I think NIOSH was finding boxes at the 
86

very end that were quickly added to the complement that was being 

evaluated. So, I think the -- from the -- from the very beginning, we 

recognize that from a standpoint of doing a completeness review, this would 

be one that would give us a good indication but one that may not necessarily 

be as statistically sound as we would like to have it, just simply because of 

the information that we're dealing with. 

We just -- you know, if you think of it as a deck of cards, it would be 

great and statistically sound if we had all 52 cards in the deck, but we are 

operating with maybe half a deck at any given time in terms of the analysis. 

So, I -- I just wanted to make sure that certainly that perspective of how we 

were trying to do matching and how matching was done in a lot -- you 

know, certainly in parts of '92 that, you know, we always recognized that 

this was the best one could do with the information that was available. 

MEMBER LOCKEY: I appreciate that, Joe, and I appreciate all the time 

and effort you guys put on this. I just -- I don't know. I guess I had to go 

back to where do you -- when you analyze it, it was my impression SC&A 

and NIOSH were working on the statistical approaches to look at -- look at 

this database to see if it's complete or not complete and can answer the 

pertinent questions. Are you agreeing with that approach, or do you think 

that's not proper approach? 

MR. FITZGERALD: No. We actually -- and I think you were very much 

involved. We very much reviewed the sampling plan that was developed 

based on -- which -- from which 92 was developed from. And that sampling 

plan, I think, walked through the whole -- you know, the whole process of 

how one would match -- what would be considered a match of a -- of 
87

bioassay being done for an RWP. And I think it was recognized at that point 

that that was just a one-for-one simple matching exercise. 

I think there was definitely some statistical analysis that was done, 

and that was around the -- some of the uncertainties for some of the 

coworker or coexposure matches. And I don't think we had any problems 

with that either. So, I think there's aspects of this that were treated in 

terms a statistical analysis. I think -- I don't have any dispute on the 

uncertainties that were worked. I think in a more overall sense, we also 

recognized, and I have to believe NIOSH recognized, that we weren't dealing 

with a complete set of information or data in terms of the RWPs and missing 

those for -- you know, for certain facilities, certain dates, you know, --

clearly, you know, it's a completeness view with a bit of an asterisk. But it 

was the best that one could do with the information that was available. So, 

I -- we agreed with the sampling plan, and we agreed that report 92, even 

though we've had some -- have had some issues and interpretation with it, 

was the best product or best assessment of the question that was raised 

back in 2017 in terms of would this data gap that was identified in 1997, 

what can one say about the completeness of job-specific bioassays for the 

preceding years. And this is going back to '72, but now we're talking going 

back to '91. What can -- what can one say, and is there any way to 

demonstrate completeness in the face of that information.

And I'd like to add that, you know, much has been made that this is 

simply a compliance issue and therefore should not factor into a 

consideration of whether a coexposure model was -- is feasible or not. You 

know, I'd like to, you know, again, remind the work group it is the 
88

implication of missing 79 percent of job-specific bioassays for subcontractors 

that drove this issue originally and raised the question of, you know, can 

you, in fact, establish completeness such that a coexposure model would be 

-- would be feasible according to your own guidelines, which is I -- you 

know, we've said IG-O6, and -- and -- and that's what we've been working 

at now for several years. So, this is just an extension of that same question 

and saying that okay, is there any way we can establish a point, a time 

frame, where we can feel confident that between looking at data 

completeness, ala report 92, and looking at the program assurance provided 

by procedures and policies and the Westinghouse Radiological Improvement 

Program, which was put in place when they became the contractor, is there 

any way we can actually establish a time frame when that was -- that that 

had -- that changed? And that -- that -- that, you know, we get into this 

question of how conclusion five was worded. And that's exactly where that 

comes from. It's taking data completeness and also these programmatic 

assurance measures and deciding as a weight of evidence -- call it what you 

want, balancing, weight of evidence --- when the combination of that gives 

you, you know, the confidence that -- you know, that, in fact, you had 

completeness and job-specific bioassays such that that information can 

represent subcontractor exposures in a coexposure model. If you don't have 

representativeness reflected in the coexposure model for a whole category of 

workers, I would contend that you don't have a -- an acceptable coexposure 

model according to the NIOSH's own procedures in IG-O6. That's been the 

impetus for the last four or five years for the work group's pursuit of -- of 

looking at this completeness issue. 
89

So, anyway, sorry about that. I think I got carried away there. 

Anything else on that? Okay. 

MEMBER LOCKEY: Hey, Joe. I'm sorry, I was on mute. I appreciate 

your -- your insight and I appreciate what you're doing. I just -- I just think 

that it -- it -- okay, you said 79 percent of 5 percent. And I think I heard 

John say -- or you said 79 percent. I think John said 79 percent of 5 

percent. I mean, maybe you too can reconcile that for me, so I understand 

the difference. 

MR. FITZGERALD: Oh, no, no it's 79 percent of subcontractors on 

RWP required job-specific bioassays. That's 5 percent of the entire 

Savannah River, I think it was the, bioassay program that came to -- I don't 

remember the number. Maybe John does. 

It was like 290 workers, something in that ballpark. And it's true that 

under the -- you know, with the concern over what intakes could have taken 

place, Westinghouse did the responsible thing. They went back and actually 

resampled every one of those workers and did not find any -- any 

measurable intakes, which I think is -- it -- it -- it was good and it was a 

diligent thing to do. 

And as Tim also commented, the -- we're thinking about '96 and did 

examine those workers and it was not necessary to go back and monitor 

those. So, again, whether it's 300 -- whether it's 300 workers or, I guess, a 

grand total of 3000, the question is whether this cohort of workers 

represents a class of workers for which high -- you know, of which the 

higher exposed workers, the most highly exposed workers, may reside and 

can you be sure. And -- and -- and I think given the class of workers, and I 
90

think it's defined in the previous SEC, subcontractor CTWs who, because of 

their -- the nature of their work and intermittent style of their work and the 

fact that, again, they came and went and did some of the hot work, I think 

given this particular category of workers, I don't think one can conclude that 

the most highly exposed individuals would not necessarily be in that 

category. And I think one has to be careful about moving to a judgment call 

to make that -- make a decision on the size of the worker category, numbers 

of the workers in that worker category, to decide if -- you know, if one 

wants to go ahead and include the workers in the broader coexposure model 

or not. 

But, again, I am not familiar with -- I think what Tim was commenting 

on earlier, which seems to be a new or emerging NIOSH policy or approach 

on coexposure models, which may exercise such judgment. I -- you know, 

so that's something for the Advisory Board to address when the time comes. 

But for -- for SC&A, we can only focus on report 92 and the techniques and 

the approaches that the work group and NIOSH agreed to several years ago. 

And that's the context of how we're looking at this issue right now. So 

anyway. 

MEMBER LOCKEY: Thanks, Joe. 

MR. FITZGERALD: Yeah. If I can go to conclusion one. Okay. Our 

first conclusion is sampling premise is not sufficiently grounded in historical 

SRS practices. And what we mean by that is that there were certainly many 

policy changes and practices that were shifting in the -- in the '91-'98-time 

frame. 

I -- I -- I, you know, just looking at the documentation in history, I 
91

can't imagine -- and this probably isn't exclusive of the Savannah River. It 

probably was the case at most DOE sites. But you couldn't imagine a more, 

you know, changing time, frantic time -- time frame as 1989 to about the 

mid '90s at Savannah River. 

Again, you had a change of contractors. You had a major Radiological 

Improvement Program which introduced new policies, procedures, and 

practices in rad protection. You -- you had a major influx of subcontractor 

workers to support the DND program, to support the restart of the K reactor, 

and to do many other things on-site. This was much different than DuPont. 

And you definitely had the advent of the DOE enforcement program in 

the mid '90s, which prompted even more re-examinations and what have 

you. So, and this is not even all of it. You had a facility evaluation board, 

that was actually the first entity -- institutional entity that identified a 

number of these issues in terms of submission of bioassays and even the 

local DOE Savannah River office was identifying this particular issue in 1995. 

So, and to answer an earlier question, you know, one of the reasons, 

certainly, that Savannah River was cited or Westinghouse was cited under 

Price Anderson for a 830 violation rather than 835 was the fact that the -- 

you know, the nonsubmission of bioassay samples was identified quite early, 

actually back in '95. And a number of corrective actions were -- were 

supposedly taken, but effectively, none of them seemed to be effective and 

the actual performance was declining by the time that the self-assessment 

showed 79 percent nonsubmittal. So, it was a recognition both that there 

was a procedural noncompliance but also that corrective actions that were 

taken were not effective and not -- not showing any improvement. So, at 
92

any rate.

Let me go through conclusion one. So measured against this review 

criteria we felt that the -- again, the sampling premise was not sufficiently 

grounded in national policy, procedures, and practices. NIOSH's response 

was -- and I think John covered this already -- was that there was a 

transition between the operating contractors, as I indicated, that led to 

increasing RWP job-specific bioassays more due, in NIOSH's view, to the 

reliance on procedures versus the actual RWP forms and that the use of the 

RWP forms, of course, lagged the procedure-based bioassay collections. 

Now, this is certainly different than what was addressed in report 92. 

This wasn't something that we -- that had been surfaced or discussed. So, 

we certainly are looking at that particular issue de novo. And, of course, the 

other conclusion was even quite apart from RWPs, it -- if -- if the bioassay 

requirements don't show up on the RWPs, that's not even relevant to the 

discussion that we're having. 

Okay. Next one please. 

Okay. So, in -- you know, certainly in our original response, we -- we 

indicated that -- that, you know, RWPs at the -- in terms of Westinghouse's 

procedures weren't implemented till '92. Now, what I would also add to this 

is that -- that the 1990 Tiger Team assessment had -- you know, had 

already found that, you know, there was a DuPont procedure on the books. 

It was the dipsal (ph) procedure for RWPs, but they weren't implementing it, 

okay. So, and they -- and -- and -- and DOE made a finding. One of their 

key findings was that, not only were RWPs not being implemented at 

Savannah River, but they had a specific procedure on the books that was 
93

being ignored by DuPont and then following DuPont, Westinghouse. So, 

Westinghouse had had an action plan for the Tiger Team, as they all did, 

that required that RWPs would be implemented in all Savannah River 

facilities by 1991, by the first quarter of 1991. 

So, beyond the fact that, you know, there was sort of a procedural 

motivation to perhaps doing RWPs, there was actually a mandate that RWPs 

would be fully implemented in all Savannah River facilities as a response to 

the Tiger Team finding by the first quarter of '91. It would be a facility-byfacility rollout. And, of course, that would be verified by the DOE local office 

as well as DOE headquarters. So, I just want to add that I know it may not 

change the status of the RWP form itself -- I think John had put some of 

those up on the screen -- but it might give some more perspective of -- of 

the implementation of the RWP program at Savannah River in that early '90s 

standpoint. So, there was another driver that was taking place at that time 

to certainly make sure that RWPs were, in fact, being implemented across 

the board. 

And, I guess, my perspective on -- on -- on this question of -- of RWPs 

is it's a continuum of development. I mean, it's not that you had a complete 

or perfect RWP by year one. Certainly, the -- the expectations and the 

requirements themselves, the forms, it was a -- an evolution over that time 

frame. And in terms of the -- and that includes the specification job-specific 

bioassays. I mean, as late as 1999 there's documentation that shows that -

- that Westinghouse Savannah River was going back and reviewing the 

implementation of these processes and implements in the procedures and 

still finding deficiencies that needed correction. So, you know, certainly, I 
94

don't want to leave the perspective that, you know, we think RWPs sort of 

became the product they needed to be at any specific time, but certainly, 

they were shifting and being improved by experience over that length of 

time. So, however -- 

DR. TAULBEE: Joe, could I -- 

MR. FITZGERALD: -- you know, again -- I'm sorry? 

DR. TAULBEE: Joe, this is Tim. I'm sorry, if -- if I could just make a 

point along with what you're saying there. You know, when you mentioned 

about the implementation in 1991 from -- you know, that Westinghouse was 

supposed to do that, if you go to report 92, table 2-2, this is the inventory 

that we conducted, and this is excluding the standing radiation work 

permits. This is just the kind of job-specific RWPs. You see a massive jump 

in 1991 across the facilities. You know, looking at F area, for example, 

there's, you know, roughly 15 pages in 1990, and there were over 3000 in 

1991. In H area there were -- we didn't find any because they hadn't 

implemented them yet, but in 1991 there were 751 pages of RWPs. So, 

there was a very massive jump when they did this implementation and yes, 

it improved over time. But there was a very definitive jump there 1990 to 

1991, and I just wanted to make the Board Members or work group 

members aware of that, if you look at tables one 2-1, 2-2, and 2-3 in report 

92. Thank you, sir. 

MR. FITZGERALD: Yeah, thank you, Tim. And actually, that that kind 

of was my point. Because of the action plan -- if you look at the action plan, 

it was pretty clear they were going to roll it out facility by facility and be 

done with it by '91. So, from that standpoint, I agree. I think you're looking 
95

at a step function in terms of the number of RWPs that would -- would have 

been implemented by that time frame. 

At the same time -- and I suspect this was also NIOSH's point in its 

presentation -- you know, the -- the forms that were being used and the --

the tie in of job-specific bioassays, that -- that was in transition almost 

throughout the '90s. It -- it -- certainly, you know, improvements were 

made and the form got better, the follow up got better. 

The only fly in the ointment is, you know, clearly the -- the 

accountability and process to ensure submission of bioassays was a big 

problem. And that was a problem with the tritium program in the earlier 

'90s. It was a problem in just job specifics starting in '90 -- well, certainly, 

first identified by the Savannah River field office in '95. The facility 

evaluation board made a finding in '96, and all that led to self-assessments 

which -- which certainly uncovered the -- the famous 79 percent finding in 

'97. 

So, you know, the -- the -- the RWP program and the process of that 

program was definitely put in place and jumpstarted by Westinghouse if -- if 

only because it was identified as a procedure that was being ignored by --

this was from the Tiger Team review -- and so they made a very deliberate 

decision, you know, that they would certainly impose -- implement it site 

wide within a year, and they did, by '91. So I think Tim is quite correct that 

we're looking at a lot of RWPs, but we're still left with the question whether 

the process to -- you know, to do the -- submit the job specifics, when did 

that become more effective? So, that's kind of the essence of what we're 

looking for. 
96

And just to finish this slide, yeah, we were looking for -- for ways to 

evaluate this question of completeness for job specifics. I mean, and yes, 

we -- we kind of looked at 92, and that was the sampling and the data that 

we have. And -- and that's pretty much the -- the reasoning for why we did 

do the samples and did do the fractional rates. I think it's an indicator, but 

it's one of the few objective indicators of that particular question. And, of 

course, that's why the original sampling regime was agreed to, because if 

you're looking for a sampling regime that illuminates this question that was 

raised in this 1997 finding of inadequate submissions of bioassays, I think 

report 92 is as close as you're going to get. 

Okay. Conclusion two: I'm going to have Ron Buchanan -- Ron, are 

you there? I think -- 

DR. BUCHANAN: Yes. 

MR. FITZGERALD: -- the next two, conclusion two and three, Ron did 

quite a bit of work on, and I think -- I think he can cover those well. 

DR. BUCHANAN: Okay. Can you hear me okay? Can you hear me?

UNIDENTIFIED SPEAKER: Yes, we can. 

DR. BUCHANAN: Okay. This is Ron Buchanan with SC&A, and as Joe 

said, I'll be covering conclusion two and three. And NIOSH already done a 

pretty good job of summarizing it and, of course, we just received this 

response short time ago, so I'll just kind of go over where we stand at this 

time. And conclusion two was results were direct and affective monitoring 

may be overstated. And in our 2022 review, we found that NIOSH did not 

address all the nuclides -- radionuclides on the RWPs and that if you 

addressed all of them, it would change, of course, your percentage indicator. 
97

And NIOSH responded that they agreed that that was true and that they 

went ahead and re-tallied and came in -- as they discussed earlier in this 

meeting. 

So, next slide. 

So, our initial response to that is that NIOSH's 2022 response provided 

a summary of their analysis of their updated tallies and weighted point 

estimates and summarized in table 5. Now, if you compare table 5 with our 

table 3 and 4 percentages as indicators, you'll see that they're very close. 

They're within about 1 or 2 percentage points in agreement. And so, of 

course, we haven't seen their re-tally update entirely, just the results of 

them, but we don't really have any qualms with that. 

Now, conclusion three more was concerned with whether -- it's mainly 

concerned whether -- the coworker matching and that's generalized 

matching is not sufficient. Now, when we investigated report 99 or 92, we 

went in to look at the granular details, such as a -- a sub construction trade 

worker and whether they was monitored, which was obvious (indiscernible) 

bioassayed or not, and then if they weren't, then why was the coworker 

substitution for them that you could apply. And so, we went in to each as 

NIOSH did in report 92 and such as table C3 through 37 that covered the 

different isotopes and looked at each individual worker -- I think there was 

like over 600 over them -- and see if they matched on an RWP and included 

reasonable criteria such as being on the same RWP, if they were there the 

same day, same time, and same craft. Now, we looked at the craft because 

we wanted to see if they matched up to potential exposure. Now, this has 

been the biggest debate is on the craft. 
98

Now, we did find some discrepancy on the date and time, and that is, 

again, not as clear as you might sound because some RWPs do increase. 

And so on one entry, they might match up on time, on the next entry, they 

didn't match up on time, so how do you categorize that? Or some might be 

on the same date and a few were not on the same date, but the first RWP 

they were, second wasn't, or vice versa. And so, it isn't quite as clear as it 

looks, but the percentages were indicators not to be used in some coworker 

model or something just to indicate of where we stood. And so, you if you 

don't use craft, then you get a higher percent of compliance, such as like 66 

percent instead of 45 percent. And so NIOSH's recent response was that it 

does not have to be the same craft, just the same exposure and so that our 

criteria was too restrictive. 

And so, the next slide.

Okay. Now, when we did review the report 92 as it now stands, or as 

it was printed, we did find some dates and times criterions not met and that 

laborers were used as coexposure in some cases. And so, that aside, NIOSH 

quality assurance review may have corrected some of these conditions. Like 

I said, we haven't seen the details of it. And to -- we agree that if you use 

coworker data that has potentially the same and higher exposure, then that 

can be his coworker instead of -- for an unmonitored worker. However, in 

this case, it does open up some subjectivity. Because if you say an 

electrician went in and another electrician went in and wasn't monitored, 

then you have just about as fine as you can cut it, to find out if they had 

potentially the same exposure. And then when you -- but if you go and say, 

okay, electrician went in and sheet-metal worker went in, and worked the 
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same time, did they have the same exposure? Well, maybe so. You would 

have to look at the details. And this becomes subjective and a -- the -- a 

value judgment, whether they would have the same. 

And so, in our analysis, we wanted to look at the hard numbers and 

just look at the RWP date, time, and craft. And so, if you don't want the 

crafts to be the same, like I said, you left that out, and you come up with 

like 60 or 70 percent instead of 45 percent. It's in our report. It's broken 

down. It's the same with RWP, the same, the same time, and same craft. 

So, don't really have an argument against that, other than it can lead to

problems if you're not sure if the potential was high or the same.

Now, I would like to mention here that when we was looking at report 

92, we was looking at the granularity of individual workers. When you do a 

coworker model, which was part of our -- our 92 charter, then yes, you can't 

look and make sure everybody's the same craft, same time, same date, and 

we know that in all the coworker models. And so when you're setting up a 

coworker model, completely different than what we was trying to do and 

what NIOSH was trying to do in report 92. So, that concludes my summary 

of conclusion two and three. 

Any questions?

Discussion

MEMBER LOCKEY: Hi, Jim Lockey. I have a couple of questions. One 

is that NIOSH used -- I thought -- and John or Tim, you can correct me. Did 

you-all say you used 15 minutes arrived at this work site were the same --

within the same fit man -- 15-minute time frame or not? 
100

DR. CARDARELLI: Yeah, that's my -- yes. 

DR. TAULBEE: Yes, I believe that is correct. Mike Mahathy, can you 

verify that, if you're online? Okay. Mike may not -- 

MR. MAHATHY: Yeah, yeah, sorry I was on mute. 

DR. TAULBEE: Okay. So, then that was a general criteria. And when 

you look at these RWPs, Dr. Lockey, what you'll see is that nobody really has 

the exact same time because they're all signing in as they're dressing out. 

MEMBER LOCKEY: Right. I understand. 

DR. TAULBEE: And so there is a time window typically. 

MEMBER LOCKEY: Did SC&A -- did you use this 15-minute time 

window, because I didn't see that mentioned? 

DR. BUCHANAN: No. We -- this wasn't in the -- I don't believe this is 

in report 92. We looked at overlapping times, so we gave a little more 

leeway. If they signed in -- obviously, the date was obvious unless they 

signed in two different RWPs, two different dates. One might match up and 

others might not, which like I say, that's so hard to judge then. What do 

you put down, yes or no? But the time frame we looked at maybe was --

especially if it was morning or afternoon, we figured that was -- or if the 

times didn't overlap, at least half time overlapping. We didn't stick to 15 

minutes, which I think is more restrictive than probably what we looked at. 

MEMBER LOCKEY: All right. That -- the other question I wanted to 

address, previously I asked a question about the pipefitter and an 

electrician, and what I heard NIOSH saying is that it didn't -- either one 

when they had bio -- bioassay analysis, the highest value would have been 

taken no matter what the craft. Is that -- am I -- is that correct -- my 
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correct interpretation of I heard this morning? 

DR. CARDARELLI: That is not a -- yes, it is true that the -- the highest 

examples would be in the coexposure model, okay. When we were doing 

this evaluation, we were simply looking to see whether they were monitored, 

yes or no. We weren't looking at the results as to whether one was higher 

or the other from that standpoint. We were -- we were simply looking at 

who was monitored, who wasn't, from this RWP. 

MEMBER LOCKEY: Okay. And so -- 

DR. BUCHANAN: That's the way we did it, too. 

MEMBER LOCKEY: My question is, if you had a pipefitter and 

electrician on an RWP, do you have an example where two different trades 

came out and one had a higher bioassay sample than another or the -- or 

they -- were they -- were -- and/or were they both monitored, and we have 

the results? 

DR. TAULBEE: We have multiple instances where they were both 

monitored. We have instances where there -- only one of them was 

monitored, but the vast majority of this data is nondetect. About the only 

way I think we could answer the question that you're asking is if there was 

an upset condition or an incident from that standpoint that then you could 

compare. But as Ron was mentioning a minute ago of, you know, an 

electrician working in an area and then a sheet-metal worker, you know, 

these are generally -- generally these are fairly small areas that they would 

be working in but, you know, which one has the higher exposure potential, it 

really depends upon the job. If the electrician is working, you know, on the 

-- right around the -- the gloves of a glove box and the sheet-metal worker 
102

is working on, you know, a different area, they're you know replacing a vent 

type of thing, to me, the electrician probably has the higher exposure 

potential. So this varies. But the bottom line is, in the coexposure model, 

what we're looking at is all of the -- all of the doses, all of the intakes across 

all time -- well, not all time, but one year, effectively, and what we look at 

then is we got somebody who's not monitored in the case of one of the 

subcontractor construction trades, we would typically assign the 95th 

percentile of that distribution of all of the monitored workers. So that's 

where we feel that this is bounding from that standpoint. Does that help Dr 

Lockey?

MEMBER LOCKEY: Yeah, I just -- I was just trying to figure out why 

SC&A -- do they think the electrician -- electrician coexposure monitoring is 

more valid than -- than electrician and pipefitter? It sounds like the end 

result is whatever the data is, it's entered into the database. 

DR. TAULBEE: That is correct, sir. 

MEMBER LOCKEY: All right. 

MR. CLAWSON: But -- but -- 

MR. MAHATHY: Yes, -- 

CHAIR CLAWSON: I got yes -- so but that being said -- go ahead 

Mike. Let you -- this is Brad. Go ahead Mike. I'll let you go ahead.

MR. MAHATHY: I just wanted to add that when we -- the RWPs in the 

latter years were broken down by path, so when we compared an electrician 

to a pipefitter, for instance, we would look to take that we're doing the same 

task. If they were doing two discrete (sic) different tasks, then will not be 

matched. And -- and the last thing is we did not do a random -- we did not 
103

base sample on crafts, so, you know, there's not uniformity in the -- in the 

craft, so it's all (indiscernible) now. 

MEMBER LOCKEY: Okay, thank you. 

CHAIR CLAWSON: And that -- and that being said, Jim, this is one of 

my issues that I come up with, because you understand the same way that I 

do on this, you know, we're just -- we're just taking people that possibly 

were in there and -- and you know as well as I do that each -- every --

every person has a (indiscernible) potential for exposure. And this is where 

I -- I feel that I -- I see flaws in this from this aspect, but to me it still 

comes back to is -- if you don't have the data, if you don't have the 

sufficient data, and that you can categorize it as sufficient, I still don't see 

how you can really do it. But this will be for us to be able to address and go 

down because this is a much larger picture. But I do have -- I do have a 

problem with just the fact of what you were saying Jim, so I'll turn it back to 

SC&A. 

DR. BUCHANAN: Okay, Joe, you going to take it? 

MR. FITZGERALD: Yeah, if there's no more questions for Ron, yeah let 

me -- let me continue with conclusion four. Let me -- let me explain this a 

little bit, because I think this is easy to misinterpret. What we're saying 

here is that given the findings in '97 in terms of the large incompleteness of 

job-specific bioassays and evidence from facility evaluation reviews and DOE 

Savannah River's review in late '95, not to mention, you know, Tiger Team 

findings earlier, you know, the -- the lack of submission of bioassays were in 

large, and more specifically the lack of submission of job-specific bioassays, 

you know, we -- it -- it -- it -- without a controvert on evidence, we have to 
104

assume it's incomplete. Now, incomplete in the early '90s unless one can 

demonstrate that this information's collected otherwise. 

And I was listening with -- with interest in terms of some of the data, 

this -- discussions on data that's being collected quite apart from RWPs, but 

I think, you know, the fact that there was 100 percent resampling of -- of 

the data in '97 and that data is available for a coexposure model, for 

example, doesn't address the issue that we're after, which is a question of 

data completeness from the standpoint of whether job-specific gaps existed 

in that early '90s time frame. So, again, our process is to look for the 

means to establish that, in fact, that information was collected and there 

was a -- programs and procedures in place that would have entailed that --

that that would happen. And I think NIOSH's response -- 

CHAIR CLAWSON: Well, Joe -- 

MR. FITZGERALD: NIOSH's response was to disagree that the -- that 

the self-assessment in '98 indicated that the monitoring was incomplete 

from a statistical standpoint or that, you know, somehow this kind of a -- a 

bioassay program inadequacy was relevant to a coexposure model. Well, 

again, the context of our review isn't addressing the fees -- you know, 

addressing the -- the construct of a coexposure model. We're looking at 

data completeness as we have for report 92 all along. And, again, we think 

the -- the original finding of this substantial incompleteness of 79 percent in 

-- of 5 percent, if you want to go that way, but it's about several hundred 

workers back in -- in the 1997 standpoint is significant, and that needs to be 

addressed in terms of whether the data is going to be complete and 

representative enough that the subcontractors can be subsumed into a 
105

coexposure model for the routine exposed workers at Savannah River. 

The second bullet of NIOSH's response -- and I -- I know we've 

summarized this, and I think we got most of it -- was this question of a 

TRACK database and whether that information could be constructed and 

used and would certainly obviate the need for job-specific bioassay data to 

be included. I guess, again, our response is this is not a new question. 

Actually, in the report 92 review and discussions, this has come up before 

about the inclusion of special bioassays and how they could be used. And I 

think there was agreement within the work group that from the standpoint 

of data completeness, the -- the procedures and process by which a forcause bioassay -- in other words, an incident- or exposure-based bioassay, 

was much more driven by procedure, protocol, and management attention. 

So, you know, using that as a basis for looking at data completeness of job 

specifics was deemed as -- it -- it -- it just wasn't consistent to be used that 

way. Now, granted, we also said that if you're looking at strictly a 

coexposure model, special bioassays have a role, have a place to provide 

more data. So, again, I think it's important to make the distinction between 

how you're using the bioassay information. Is it to establish data 

completeness, or is to inform and to add to a coexposure model 

construction, because those are two different things in terms of how one 

uses information like that. 

And in that context if you go to the next slide of the response, -- 

MEMBER LOCKEY: Well, Joe, -- 

MR. FITZGERALD: Yeah? 

MEMBER LOCKEY: -- Jim Lockey. I'm sorry, I just want to ask 
106

questions as you go along. I think you were very precise and very right on 

just what you said. I -- I think that -- that really what we're down to here is 

not -- I think we can do dose reconstruction. I think the database is great, 

but is -- is data completeness there, is there data missing? 

We looked at the '97 data. There was a lot of data missing. 79 

percent of 5 percent is, what, 300 people. When they went back and 

looked, they didn't find anything. No bioassays were -- were (indiscernible), 

so it probably didn't represent a health hazard. But certain data was not 

complete. So, I think you are very correct in what you're -- what you're 

saying here. This is really now at a point that it's not so much that we're 

looking at are we missing the exposure information or is our point estimates 

at exposures incorrect. They probably are correct. It really comes down to 

is -- is the data incompleteness even though it may not be any significant 

bioassay results that are significant and the data that's missing, are we just 

going to look at the data completeness? I think that's what you're saying. I 

-- I just -- 

MR. FITZGERALD: Yes, but I don't think it's -- 

MEMBER LOCKEY: I suspect an estimate's when this data 

reconstruction are great and if -- and as -- as a researcher, I would look at 

NIOSH's database they put together, I would look to TRACK data, and I 

would put a hypothesis together and say this is my hypothesis. It doesn't 

fit, there's something wrong with my database, and then I would reconsider. 

But I disagree with you in the latter aspect. I think that TRACK 

database is very, very important because it's going to either confirm or not 

confirm the -- the robustness of what NIOSH has done. And they're great at 
107

what they do. That's what they do. They do dose reconstructions for 

multiple states across multiple industries, and they know how to do it. And 

so I would use it as a test. 

But the question for this board is, is the data complete based on the 

'97 review? Probably not. The data is not complete. It may be negative 

data, but it's not complete. 

MR. FITZGERALD: Yeah, I -- 

CHAIR CLAWSON: Yeah, so Jim, this -- this is -- this is Brad. So, I 

understand what you're saying. You know what, it's never been a question if 

NIOSH can -- does a good job at dose reconstruction or whatever, but if you 

have insufficient data, you have insufficient co-models. You -- everything is 

off. It all depends -- this is what we said so many times is -- 

MEMBER ZIEMER: Brad? Brad, can I make a comment? 

CHAIR CLAWSON: Sure. 

MEMBER ZIEMER: Yeah. Real quick because I have to leave the -- the 

call here, which I mentioned to Rashaun that I have to -- I have another 

commitment. But and I will say that I look forward to getting the TRACK 

data so that we can have a look at that. But you're never going to have a 

hundred percent complete data, so the issue always come down to what's 

sufficient data. It doesn't have to be a hundred percent. In fact, it'd be 

surprising if it ever was. That's why we have coworker data. 

So, but I have to leave the call. I assume we're going to give SC&A to 

look in more detail since they just got the report from -- from NIOSH and 

also we need to have a look at that TRACK data and see what that shows us. 

CHAIR CLAWSON: Yep. Yep, you're -- 
108

MEMBER ZIEMER: With that I'll -- I'll sign off at this point. Thanks. 

CHAIR CLAWSON: Take care, Paul. I appreciate that Paul, and I 

agree with you a hundred percent. We're never going to have a hundred 

percent, but also, too, there comes a turning point one way or the other of 

do you have sufficient data. That's -- that's always been the question. This 

has always been the question from the very get-go of this. 

And -- and -- and Jim, I understand what you're saying from a 

statistical point of view but remember what the statistics are doing for you. 

I have no problem with throwing numbers to be able to grab this and 

everything else, but bottom line is, this is a compensation program, too. 

And you've got to look at that in your statistics too. This is not just to -- to 

be able to see how much they went here or went there. And that's -- I --

we're -- we -- and without the TRACK data, you know what, we're just --

we're just going at windmills right now. So, we're going to have to be able 

to look at that, be able to evaluate it, and once we have everything down in 

writing of where everybody is -- stands at, it'll be able to be able to -- be 

easier to distinguish this. 

So, I'll turn it back to you, Joe. 

MR. FITZGERALD: Thanks, again. I think, actually, in that discussion 

we pretty much covered most of what I have in the response piece. Again, I 

think we -- I don't disagree. I think the TRACK database will be useful, as I 

say, and relevant to the coexposure model and -- and -- and certainly 

demonstrating it's either robust or one could add that information to the 

database. But in terms of this -- of this prerequisite question of 

completeness, it's not going to do anything -- it's not going to be relevant 
109

for that. And, again, I think we have dealt with the special bioassays in that 

context that, yes, they are valuable for coworker models, but they don't help 

us on the completeness issue.

And going back to '91-'96, we are trying our best to find any markers, 

any measures of -- of data completeness from a programmatic standpoint or 

from a comparison standpoint with RWPs. Just to -- just to establish prior to 

'96, say, where it's pretty clear that Westinghouse understood and was 

responding to the deficiency, you know, whether or not that circumstance 

pre-existed that time frame, it would be a problem from a completeness 

standpoint. So, we're looking for any evidence and -- and, again, we'll work 

through some of the data that -- that NIOSH has discussed today. Because, 

again, we're trying to be very open about looking at that time period and 

trying to figure out despite 1997, is there any evidence that job-specific 

bioassay information or data suitable to be used for dose reconstruction was, 

in fact, being collected or not. And that would certainly inform the work 

group's decision that it has to make in terms of where one might draw that 

line. 

So anyway, conclusion five. Okay. This one -- I'll take responsibility 

for this one. All I wanted to say there was basically from a SC&A standpoint, 

we have three findings essentially on data completeness -- that relate to 

data completeness or measures, metrics. And we have one finding that 

addresses the programmatic aspect of it. And perhaps I should have used 

weight of evidence. 

But taking those four issue areas, if one could satisfy the concerns 

raised, whether it's data completeness or the -- whether it's where the 
110

program stood in terms of ensuring job-specific bioassays were being 

performed -- required, performed, and implemented, then I think a -- a 

coexposure model would be feasible. You, in fact, could construct one and 

be confident that the data was complete and representative of 

subcontractors. And I don't think we're at that point yet. I think we're 

looking for that time frame in the '90s where, you know, that comes 

together. But certainly -- maybe I've said this too many times, but it 

doesn't represent at all a shift in our focus as far as what the issue is relative 

to data completeness and our understanding of the coexposure model 

guidelines where data completeness and representativeness are 

prerequisites before one constructs a coexposure model. So, we don't see 

any inconsistency. In fact, we -- we -- we believe this is consistent with how 

we have looked at this issue starting in 2018. So, I'll just reiterate that. 

Next page, please. Next slide.

And we -- we basically say that. Again, those are considerations that 

have to be addressed and satisfied. And, again, we don't think a coexposure 

model under the current guidelines -- I can't speak to anything that's, you 

know, being considered, a new approach or a different interpretation -- but 

under the current guidelines, we don't believe a coexposure model for 

subcontractor CTWs can be shown to feasible unless and until the data 

completeness and representativeness are demonstrated. And we feel that 

the two -- two aspects of that demonstration are the RWP-related bioassay 

performance and the -- you know, the programmatic aspect, which is the 

procedural implementation. And, again, as we -- we introduced --

introduced earlier, both of those were explicitly cited in the Advisory Board's 
111

recommendation for the SEC for '72 to '90 for the subcontractors, so there's 

a consistency in doing it that way.

Next slide, please.

This is -- this is a -- a -- a formative time line. You know, again, we're 

developing our formal response, but we wanted to share this because, again, 

we're looking at this time frame from '91 up to '96, and I think even '96, 

as -- as Tim alluded to, that's even debatable given the fact -- and I don't 

disagree -- that Westinghouse did take a look at '96 and looked at the 

subcontractor bioassays and felt they were not likely to exceed 100 

millirems, so they decided it wasn't worth the cost to go through and 

resample those. So certainly, there's some confidence from that standpoint. 

But, again, looking at the programmatic as well as the data completeness 

indicators, and I'll again emphasize indicators, we see these time frames 

that come up. 

And I wanted to keep an open mind on the TRACK system, although 

from what little I know of it, it does sound like special bioassays, which 

probably would not be as relevant for this particular milestone in 1991. But 

I know also at the same time agree -- and I think Tim and I agree on this --

that '91 was a step function in a number of RWPs that were implemented at 

west -- at Savannah River by Westinghouse, whether it was driven by 

procedures or driven by an action plan for the Tiger Team, certainly the 

RWPs became much more plentiful starting in '91. Now, the question is 

when the job-specific bioassays were, in fact, collected and became 

complete enough. And that's why -- and that's the -- that's the central issue 

to all this. 
112

And, again, one could make an argument -- and really the decision is, 

obviously, the working group's decision as to what evidence points to what 

time frame. We can ease -- we can easily accept the bookends to this -- to 

this time line, but as far as in between, I think there's an -- there's 

arguments both ways. And I think that's probably the fruit of all these 

discussions and the work that we have, maybe, ahead is just to try to 

illuminate as much as possible, you know, what was happening and to what 

extent there's confidence this information is complete. 

But I -- I would quickly add though, unfortunately, on this thing is that 

the one statistical certainly is there was 79 percent incomplete of the 

subcontractors that had job-specific bioassays in '97. Everything else is a 

derivative metric, but that one is a 100 percent sampling by the operating 

contractor at that time, so that's a high confidence level of the -- of that 

value. So that's the one we have to work back from and decide if there's 

any evidence that would over -- overrule that finding in order to set a date 

that would be earlier than, say, '96 or '97. So that -- that's kind of the --

the broad perspective, you know, of what we know and what we don't know. 

Next slide.

Yeah, our -- our review is maybe midway. You know, there's a fair 

number of references that we're interested in, and we certainly would like 

additional information on the basis for the LaBone and Headlock interview 

statements, because I think that's pretty important. The 5Q1.1 

Westinghouse procedure, we felt was pretty explicit, and actually, there's 

several other Westinghouse documents that basically state the very same in 

terms of the characterization of the nonroutine job-specific bioassays and 
113

how the implementation would be done in the field. So we're going to be 

very interested in anything else that perhaps John and his staff can provide 

in the way of corroborating those statements because we have several data 

points that support exactly what the procedure states. So I -- I -- I want to 

be careful about disputing the written procedure unless we have, you know, 

sort of a very good basis for doing so. And also, certainly, any other 

additional information on the TRACK database and some of the other pieces 

of perspective and information that was in the NIOSH response we'd be 

interested in hearing more about that so we can respond.

In any case, we -- I've said this before, but, you know, we're looking 

at this from a weight of evidence standpoint, meaning that the latter years, 

we think, need to be from a -- from a standpoint of dose reconstructability 

needs to be defined based on the sufficiency of the -- of the bioassays in 

terms of completeness and also in terms of program adequacy. And we 

provide some perspectives in our review and I think NIOSH has as well. And 

I think we need to equip the work group with as much information and data 

as we can to inform their judgment on this. It's going to be a weight of 

evidence judgment in my view, whether there's any -- any compelling 

information that would permit you to pick a year, for example, prior to '96 or 

'97 despite those findings in those particular years on data completeness. 

So, I think that's where we're at.

That's all I have. Does anyone have any questions for any of us? 

Again, this is sort of a midway -- midway status review of where we are, and 

I'll be the first to admit, we've learned a lot from John's presentation, and 

it'll, perhaps, make our response, again, more comprehensive and -- and to 
114

the point. So anyway. 

CHAIR CLAWSON: Anybody have any questions for SC&A? 

MEMBER LOCKEY: Yeah, Brad, I do. Sorry, about that. 

CHAIR CLAWSON: No problem. 

MEMBER LOCKEY: Joe, Jim Lockey. So, in relationship to '97, data 

certainly was incomplete for that 5 percent of whatever, but when 

Westinghouse went back and looked, there was no -- none of the bioassays 

samples were of significance. What I'd like to have you do, if you can, is go 

back to previous years and demonstrate data that would indicate to me that 

the Westinghouse findings from 1996 won't be applicable in previous years. 

In other words, do you have any objective monitoring data in 

subcontractors, either project oriented or for unusual circumstances that 

indicate that the point estimates established by NIOSH aren't encompassed -

- don't encompass that addition -- additional data. I understand the lack of 

data, but we've demonstrated in '96 that that would -- the lack of those 

bioassays was not a significant factor, at least in ninety -- '97, and most 

likely in '96 under 100 millirem, there's no biological plausibility whether 

they would be significant. 

So, from '95 on back, do you have any objective data that indicates 

that there's something there that is going to throw off the point estimates 

that NIOSH has? That's what I'm looking for from you guys. And I 

understand you -- you list administrative prerogatives and things along 

those lines, but what I'm looking at here is modern-time exposures, 

relatively modern time, biological plausibilities. Is there anything here that 

indicates that NIOSH doesn't have the proper point estimates objectively, 
115

not -- not lack of -- you know, what happened in '97. I want to know from 

'94, '93, '92, is there any data that indicates that NIOSH is off base? That's 

all I'm looking for. 

MR. FITZGERALD: And from, you say, point estimates, I guess, I 

would -- I would throw it to Tim. Is this your bounding coexposure value or 

something? I don't know what the point estimate would mean in this 

context. 

DR. TAULBEE: I believe that what Dr. Lockey's referring to would be a 

coexposure model. I would point out that we have not finalized that 

development yet, but we could do so relatively quickly -- well, I believe 

relatively quickly, or at least get something on paper. 

MEMBER LOCKEY: That's what I'm referring to. I mean, I -- I -- I'm 

referring to that and indicate that I would -- I would be looking at is there 

something that we're missing from '94, '93, '92 in the existing data that 

indicates that we can't trust the Westinghouse eval -- evaluation for previous 

years that was found in 1997? Is there something there? That's what I'm 

looking for. 

DR. TAULBEE: Yeah, I -- 

CHAIR CLAWSON: Well, Jim -- Jim, maybe I can ask. Maybe I -- let 

me -- I'm trying to understand what you're trying to get to here. So, one of 

the things that I have an issue with is -- so they were not doing procedure 

compliance in '97. What evidence do we have that they were doing 

procedure compliance before that? 

Now, it's already been told to us by the subject-matter expert that 

they don't agree with that procedure. So, what evidence do we have that 
116

they were complying to it before that year? Maybe that matter -- maybe 

that ought to be the question that you ask. 

MEMBER LOCKEY: Well, what surrogate data were they using to 

indicate that they were complying? 

CHAIR CLAWSON: Well, yeah, that -- that's -- that's -- that's part of 

the issue that I -- I'm getting to. What are you using to be able to measure 

this where they were not doing procedure compliance in '97. I really doubt 

that they were doing procedure compliance in '96 or '94 or '95, especially 

when the subject-matter expert is saying they don't agree with that 

procedure. 

MEMBER LOCKEY: Brad, what I hear is the -- the -- based on the '97 

data, they probably weren't doing it based on what the procedure said, but 

they might have been covering it through other mechanisms, okay. And 

they -- their coverage through other mechanisms was so good that when 

they went back and looked at the 1997 cohort where they didn't have 

analysis, when they went back and looked at it, there was nothing there. So 

that would indicate to me that their prior -- prior monitoring was good 

monitoring -- it was a good monitoring program. I guess what I'm asking 

SC&A is, is there any indication in the previous years that that is not, 

indeed, the case, not just based on the lack of data recording, but other 

objective data. That's what I'm looking for. Actual measurements, actual 

bios -- bioassay measurements, etc. 

CHAIR CLAWSON: Well, if you -- if you read in the notice of violation, 

if I'm correct on this, the reason why they were still fined on this was 

because they did find an individual that was missed by their normal bioassay 
117

monitoring system. 

MEMBER LOCKEY: Right, right, but in '97 -- 

CHAIR CLAWSON: So, that -- that's telling me that it was not -- they 

weren't catching everything with their normal routine. 

DR. TAULBEE: Actually, that's not completely factual there, sir. 

CHAIR CLAWSON: Okay. What -- what was it then? 

DR. TAULBEE: Okay. In the previous years, there wasn't a -- a -- an 

incident that occurred that was not caught -- and the individual was 

identified via the routine bioassay program, so it's actually the inverse right 

then. That was an operations worker, that was not a subcontractor 

construction trades worker. But the person was caught on the routine 

bioassay. That was, I believe, a 1995 incident. 

CHAIR CLAWSON: So, your -- you -- what -- what you're saying, Jim, 

is that the program was so good that they didn't need any of these other -- 

MEMBER LOCKEY: No, I'm not saying -- 

CHAIR CLAWSON: That -- that's kind of -- it's kind of hard for me to 

understand how you would do this, because you're -- you're asking them to 

prove a negative with -- with -- without the sufficient information. 

MEMBER LOCKEY: I'm not saying the program was so good. I guess, 

what I'm -- or not good. I'm not qualifying about the comment on that one 

way or the other. I guess what I'm saying is that -- is, Brad, in -- in 1997, 

they recognized they were missing ninety -- 79 percent. When they went 

back and resampled those people, there was nothing there. There was 

nothing there, Brad. So, is there any indication that wouldn't have been the 

same back in '95, '96, '94', '93, '92, '91? Is there any indication that that 
118

wouldn't have been the same back then, because they did have in place a 

bioassay program? People were monitored in the bioassay program, and 

they had this TRACK program, which remains to be looked at, to hopefully 

take outsiders from accidental or unusual exposures.

What I'm just trying to get a handle on, why isn't the '97 data 

representative of previous data? Why isn't it? 

CHAIR CLAWSON: Well, I'll -- 

MEMBER LOCKEY: I don't know the answer. 

CHAIR CLAWSON: I'll be honest with you, Jim, what you're expecting 

them to be able to prove is an unknown. 

MEMBER LOCKEY: Right. 

CHAIR CLAWSON: That -- that -- that's our issue. That's our issue 

right there. You're expecting them to take the information that we have and 

prove an unknown. 

MEMBER LOCKEY: I agree with you, Brad, and that's why -- 

CHAIR CLAWSON: Well, that's -- that's where I'm -- 

MEMBER LOCKEY: -- getting back to my original comment is -- that's 

why I get back to my comment I made a few minutes ago. I really think 

that the dose reconstruction here is very rigorous, but if our decision is 

going to made purely based on bio -- data completeness, I don't think we 

can go any further. That's what I'm saying. 

CHAIR CLAWSON: I understand, but, you know, we need to IG-006 

and because our requirement's on that, too. And one of the big things in 

there is data completeness, period. This -- this is where the whole thing 

comes into. 
119

But I -- I do have a question for Tim or Joe because it's been ringing in 

the back of my head, and I bet you there won't -- I don't think there'll be 

any debate on this. When was DOE allowed access to DuPont's Savannah 

River site? I remember a plaque at the DOE site, an agreement between 

Savannah River and DuPont to be able to have DOE access to that site. 

What year was that? 

Because if you remember, before DOE really had no position in there. 

They -- DuPont was a contractor that built so many widgets for DOE, but 

they had no oversight. What year was it that DOE gained the access to 

Savannah River?

DR. TAULBEE: I believe DOE's had access since the beginning. I'm 

not exactly sure what you're asking. 

CHAIR CLAWSON: No, there -- there -- 

DR. TAULBEE: They -- 

CHAIR CLAWSON: There was -- DOE -- there's a big -- there's a big 

plaque there on Savannah River of a -- an agreement between DuPont and 

DOE because at the very beginning of DuPont, DuPont had a contract with 

the DOE to build so many widgets, but they had no oversight really over 

them. And then when the compliances started coming in and the reactor 

compliance and everything else started, this changed. And I was just trying 

to remember the year that that actually took effect, because before that, 

DOE really never had oversight. They -- they had oversight over a contract, 

but not over a facility. And I was just wondering if -- it just stuck in the 

back of my head, and I was trying to remember what year that was. 

DR. TAULBEE: I'd have to refer to Paul or Joe on that. I have no idea, 
120

sir. 

MR. FITZGERALD: Yeah. I -- you know, the only comment I would 

make, Brad, is that the local field office, the DOE local office, certainly had 

access going back quite a ways, I would think, into the '70s at least. I think 

very clearly DOE headquarters didn't have that kind of access until the early 

'80s. So, you know, I think there was this distinction then. But no, I don't 

remember the plaque, and I can't tell you specifically -- 

CHAIR CLAWSON: I'll -- I'll see -- 

MR. FITZGERALD: -- what they considered the date. 

CHAIR CLAWSON: I appreciate that. I'll see if I can find that, because 

that was kind of something interesting to me that I've never understood. 

And this is one of the reasons why Savannah River is such a different site of 

the way that it was -- 

MR. FITZGERALD: Yeah, I -- 

CHAIR CLAWSON: -- original years. 

MR. FITZGERALD: I -- I have a comment, I guess, on Dr. Lockey's 

request and, you know, certainly we can -- we can look at that. But I would 

comment that, you know, given the existing guidelines, and I'm talking IG006, and it kind of puts that on its head, meaning that we're sort of starting 

with the coexposure model and then, you know, using that to contrast a 

specific worker category as to whether or not it would be below that level. 

And certainly, the guidelines as they now exist to, you know, ensure a 

representative coexposure model that accommodates that particular worker 

category, you want the -- you want those exposures to be reflected. 

Now, your comment is that for the resampling, they -- you know, they 
121

happen to have shown no -- no intakes. And for the previous years, if we 

again assume that -- that -- that situation, meaning that they weren't 

collecting bioassays, that existed, there would be missing data that we 

would not be able to characterize at all. I mean, it's missing. So, in terms 

of, you know, whether or not there were exposures that could have 

approached or exceeded whatever the coexposure value is, and I'm sure, 

you know, one could derive value, it would be unknowing. We would not 

know if anything did or not. 

What we could do is we could programmatically look at subcontractors 

in terms of, you know, what -- you know, what exposures did take place and 

what the history has been and all that. But that would be sort of a 

qualitative characterization. That wouldn't be a specific, you know, one for 

one, you know, here's the data or for, you know -- for those years, and 

here's the coexposure model. So I'm just cautioning, I guess, that I'm not 

sure we would be able to give you, I think, specifically what you're looking 

for because the -- the -- the potentially high exposures, most highly exposed 

individuals that may have been in that class, may be missing, may just not 

have been collected, they may have left the site because their 

subcontractors never left a termination bioassay and couldn't have a, you 

know, intake that represents an internal dose that nobody's going to know 

about, because they -- you know, they weren't -- they weren't bioassayed, 

either during the operation or when they left the site. So, I think 

subcontractors as a category is a difficult category because they're 

intermittent. They don't, you know, often the termination bioassays and 

they often do these hot jobs. 
122

And the other thing is, Savannah River did not control access to 

facilities. Meaning that in those -- in that time frame, there was no way to 

place a worker in a particular facility at a particular time. So, you know, in 

terms of even tracking those kinds of things, you don't have that. So, we 

can certainly size it up, but I'm afraid we're not going to be able to answer 

the specific question of would there have been a likely high exposure that 

would exceed whatever coexposure model value that Tim can come up with 

at some point, and work backwards and see whether or not the -- the 

subcontractors fit under it. I don't -- I don't know if that's going to really be 

responsive. I think I appreciate where you're coming from because of the --

the fact that the resampling did show no intakes, but I don't -- I don't think 

that's going to -- to help on the preceding years, because we don't know the 

circumstances and the actual exposures of those that are missing from that 

database. Just a comment. 

MEMBER LOCKEY: I appreciate the comment. Sorry. I was on mute. 

I mean, from my own simplistic way of looking at this, what you're -- what 

you're suggesting or maybe throwing out there is that how would I approach 

it. Maybe I would go back and look at subcontractors, short-term 

subcontractors by duration of work and year where there is bioassay data 

available and compare that to the overall cohort and see how it differs. If it 

sort of falls in the same range, or it's in the confidence intervals, then I'm 

reassured. If it represents the most highest exposed, then that becomes a 

little more problematic for me. But look at the subcontractors where you 

have data short-term and do it by time, short term and by year and 

compare it to the overall database and see -- and see where they fall. I 
123

think you've probably already done that, and I missed it, but. 

MR. FITZGERALD: Well, I think there's been some data collected, but 

certainly, we'll go back. If the work group wants us to, we'll go back and 

include that data in our review. Now, I guess the only question is the 

second comparison, I guess, you could do that sequentially, meaning that 

we don't need a coexposure metric from Tim, from NIOSH, to start 

crunching that information. That could be something that the work group 

could consider later. So, you know, with those qualifications, yeah, I'll 

certainly be glad to take a look at that and see what we come up with. 

CHAIR CLAWSON: Well, you know, Joe, I under -- I understand what 

Lockey is getting to, but I -- I -- I -- I think that we really need to take a 

look and let's take a look at tasking and what we need to be able to 

accomplish here, especially with this TRACKs coming into it, and maybe we 

could look at doing this down the road. Because to me, this is looking like 

there's a lot more -- a lot more to it than what really meets the eye. It's not 

as easy -- and I -- and I where -- I have a hard time with where we have all 

of these subcontractors that have left the site and never did a bioassay, 

they're not going to be in the -- we're not going to be able to track them in 

any way. This is where I come up with that we're -- we're trying to prove a 

negative here that we have no information on. 

MR. FITZGERALD: But my -- that's the -- that -- that -- that's the 

point I was trying to raise, is that, you know, given the nature of this 

particular worker category, you're going to be, by definition, missing most of 

the data. They're intermittent. They leave the site without giving 

termination bioassays. They do hot jobs, but there's not a good record of 
124

what jobs they do. They move from facility to facility, there's no records of 

what facility they work in. So, you know, trying to establish exactly what 

the bounds of their exposure is, is extremely difficult. And I don't know in 

the end, whether it would -- it would be useful for any kind of a comparison 

because the qualifications that you would make, the qualifiers you would 

have to, you know, indicate would be pretty significant. So -- 

MEMBER LOCKEY: Hey, Joe -- Joe -- 

MR. FITZGERALD: -- that's -- that's the only comment I would make. 

MEMBER LOCKEY: Joe, Jim Lockey. I mean, I don't think that's true. 

When I did -- when I did -- when I do fertility studies, my -- I start out -- I 

don't -- I don't look at sperm count or -- or number of ovum present, well, 

we can't do that. But I don't do sperm count doing fertility (indiscernible). 

The first thing I do is -- is -- is -- is birth outcomes, family birth outcomes. 

That's what I look for first. That's the first indication. And if there's a 

problem with that, then I go back and do fertility -- then look at specific 

indicators of fertility, sperm count, whatever, aging, conception, etc., as an 

example.

But the first thing I look at is -- is a live birth or pregnancies, okay, 

and then I work my way backwards. 

Here, I guess, what I'm suggesting is roughly -- simple, I think. Look 

at those subcontractors that were -- where we have bioassays data, how 

long -- time frame, how long -- are they short term, long term, and their 

work, and look at their bioassay data and compare that to the whole 

population and see where it falls. If it falls in the middle, that's reassuring 

to me that, you know, more likely than not they represent the population. If 
125

they fall into the top 5 percent, then that's a problem for me, okay, because 

that indicates that more likely that, as you say, these were the highest 

exposures, we probably are missing people and there may be exposures 

even higher who never got bioassay data. 

So, your end point here is the bioassay data. I don't care if they're 

electricians or pipefitters or whatever. I just want to know what their 

bioassay data was as a short-term subcontractor. And I think we do have 

some of that data. 

MR. FITZGERALD: Yeah. Yeah. And I -- I guess I'll defer to the work 

group as a whole as to how you want to task us on that. We can also 

develop a proposal to send back to the work group, and the work group can 

either modify, approve, you know, or turn down, I mean, whatever you want 

to do. So, we could also do that just to frame this, perhaps, a little better. 

MEMBER LOCKEY: Or if it costs money, have NIOSH do it, and you 

guys do it together. I don't care. I don't either way. 

MR. FITZGERALD: All right. Well, you know, again, why don't we give 

you a proposal and if that's -- if that works, and it's acceptable, you know, 

we'll have to look at the data that would be needed and maybe, in fact, we 

would need NIOSH to do something, but maybe we ought to frame that up 

and provide that to the work group, and you all can decide, you know, 

decide if that's what you're looking for. 

MEMBER LOCKEY: Frame it up with Tim, and present it as a joint -- 

CHAIR CLAWSON: Actually, no, Jim, this comes down to us. That's 

doesn't come down to Tim. This comes down to us as a work group. I think 

what we really ought to do is have SC&A look at this, maybe Ron with --
126

with his calculations or whatever, and kind of framework this, what Joe was 

saying, and if it is going to satisfy what you as the work group member 

needs, and what it is going to take because, I think, it's just like a lot of the 

rest of this, when we get into it, there's a -- it's a lot more difficult than what 

we think. Would that be -- would that be all right? 

MEMBER LOCKEY: That be all right me as long as there --

(indiscernible) TRACK data, and that would be very useful to me, I think. 

CHAIR CLAWSON: Yeah, we're going to -- we're going to go into the 

TRACK data, and I guess -- I guess we're kind of get into the end of where 

we're trying to firm up everything on this, and so Rashaun, it's okay with 

me. I guess, what I'd like to be able to do is make sure that we have a clear 

reference on each side of what we are requesting them to be able to do. 

Would that be all right to do at this time, or is there other Members of the 

Board that would like to ask some questions before we get into that? 

Without -- without -- without hearing any other -- other Board 

Members, Rashaun, would it be all right to be able to go and kind of lay our 

path forward with NIOSH and SC&A? 

DR. ROBERTS: Yes. 

Open Issues and Paths Forward

CHAIR CLAWSON: Okay. Well, that -- that being said, so NIOSH, my 

understanding is we -- we have SC&A owes you a written compliant -- or 

reply to 0092. This was kind of a brief form here. But from what you owe 

us is we need to be able to gain access to this TRACK data. Is this -- is this 

your understanding, too, John? 
127

DR. CARDARELLI: Yes. And we are expected to get that sometime in 

May. 

CHAIR CLAWSON: Okay. Is there any other thing we owe you as 

SC&A or as a work group? 

DR. CARDARELLI: Not that -- not that I have on the --

CHAIR CLAWSON: (Indiscernible.) 

DR. CARDARELLI: -- tip of my mind right now. 

MR. FITZGERALD: Brad, I just -- 

CHAIR CLAWSON: Okay. Something's going to -- 

MR. FITZGERALD: -- (indiscernible) -- 

CHAIR CLAWSON: Joe, you're -- 

MR. FITZGERALD: Just -- just -- 

CHAIR CLAWSON: -- breaking up. 

MR. FITZGERALD: Oh. Can you hear me now? Hello? 

CHAIR CLAWSON: We can hear you now. 

MR. FITZGERALD: Okay. Again, on the -- that one slide and one 

bullet that refers to the commentary on 5Q1.1, you know, some of those 

clarifications and corroborations by John and his staff would be helpful to us, 

because, again, it was, I think, as I recall, an interview comment by Dr. 

LaBone or an interview comment by Dennis Headlock. And, you know, we 

have documentation which says otherwise. So, it would be useful to get 

maybe additional corroboration or review by -- by NIOSH just to establish 

the -- the comment or the finding that was made on that. Because that's --

to us that's pretty substantial because we certainly have had that as a -- you 

know, as a basis of our review for quite a while now, so. 
128

CHAIR CLAWSON: So did you understand that, John, that -- it’s in 

their conclusion, in the very last slide there, seeking further corroboration 

for the Labone's interview statements? 

DR. CARDARELLI: Yes, we can interview a few other people to 

corroborate that statement. 

CHAIR CLAWSON: Okay. 

MR. FITZGERALD: Thank you. 

CHAIR CLAWSON: Well, let's -- not -- not just interview people, but 

let's have some proof that this was actually the case. You know, it -- I 

learned a long time ago, and Grady helped me with this one, was that 

people can say everything they want, but if you don't have any 

corroborating evidence to be able to back it up, it's -- it's just hearsay. So, 

please, get the information that we need to be able to have that to 

corroborate -- corroborate with that. So, that being tasked with NIOSH, I 

guess, I'll -- I'll turn to SC&A and you owe NIOSH a response to 0092, a 

written response. 

And we're going to frame work up something for Dr. Lockey and the 

work group to be able to look at as far as for the earlier years. And I -- I'm 

really worried that this is going to get into a heck of a lot more than what it 

really is going to buy us, so -- 

MEMBER LOCKEY: Brad, I -- Brad, Jim. I don't think -- the data 

should be there. That's why I suggested that SC&A and NIOSH work 

together and make sure they can retrieve that database. All we're asking 

for is, you know, what their bioassay samples are, and -- and the years they 

were collected and if there's a way to put a time frame on them. I don't 
129

think that's a lot to ask. I think their databases already have that. 

CHAIR CLAWSON: Okay, well, we'll evaluate it. Bob, your face just 

popped up. Go ahead. 

MR. BARTON: Yeah, I want to reiterate what Joe said that we can 

certainly try to come up with something, but -- and I understand what 

you're looking for Dr. Lockey, but I'm not sure we will ever be able to deliver 

what you're asking for. And any attempt to tease out what the missing data 

might have told us -- and it's not missing data, it's data that was never 

actually collected. It's -- 

MEMBER LOCKEY: No, that --

MR. BARTON: -- and I'm not sure it gets us closer or gives you the 

information that you'd need to be able to say either way. 

MEMBER LOCKEY: I'm not looking for data that's missing. I'm looking

for the short-term worker data that exists in the database. It's already 

there. That's what I'm looking for. 

MR. BARTON: Which is incomplete to an unknown extent, though. I 

mean...

MEMBER LOCKEY: I understand that. That's not the point. The point

is, I don't know if there's 100 data points in the base. I don't know if there's 

1000. I don't know there's 2000. It may be 90 percent incomplete, but I 

want to look at the actual short-term worker database that exists in 

relationship to bioassay data and see where that falls. What kind of 

distribution does it have? I'm not looking for missing data. I'm looking for 

data already -- it's in the database, as far as I know. Isn't that right, Tim? 

Tim?
130

DR. TAULBEE: Yes. Yeah, yes, it's in the Hapara database. 

MEMBER LOCKEY: Okay, that's what I'm looking for. 

DR. TAULBEE: Or I'm sorry, Pro Rad (sic). I'm mixing up the 

databases, but yes. 

MEMBER LOCKEY: I am not looking for missing data. And I agree 

with you, looking for missing data is not going to be helpful. But looking for 

the existing data of short-term workers that's already in a database should 

not be problematic unless the database is not user friendly or you don't have 

the people on board, the programmers that are able to pull that out. 

CHAIR CLAWSON: So -- so, Jim, if they do this, what -- I guess I'm 

trying to understand what -- what you want to be able to see, of how many 

points we have? 

MEMBER LOCKEY: No, Brad. Let me -- suppose you look at the 

bioassay data of these short-term workers where data does exist. And the -

- and the point estimate and distribution is way out of hand of what the 

overall cohort is. That tells me something. If it falls right in the middle, that 

also tells me something. The question is -- that Joe keeps raising, which I 

completely understand -- that short-term workers could have been brought 

in to do the most hazardous jobs, the most abysmal -- under the most 

abysmal working situations, and they were never -- never monitored. I 

can't be sure that the ones that were monitored reflect that worst-case 

situation, but at least I can look at the data, the bioassay data, and see 

where it falls, how representative it is of the cohort as a whole. 

CHAIR CLAWSON: Okay, well, Bob and Joe and Rose and all you guys, 

I guess, what -- we'll look into that, but -- but and Jim, tell me if this is 
131

okay. I would like them to be able to take a look at what -- what is available 

and -- and to make sure that we're getting what you need, I guess. And I'd 

like this to come to the whole work group, be able to see what, you know, 

the path forward may -- because I -- I -- I'm still a little bit confused on it, 

but they'll -- they can -- they can do this and go from there. 

Bob, do you -- do you have a -- do you understand what he's -- what 

he's requesting? 

MR. BARTON: I absolutely understand the question. I'm just not sure 

there's a way to sufficiently answer it, I guess, is... 

CHAIR CLAWSON: Right. Well, so am I, but we'll -- let's take a look

at that. We need to be able to provide them with a written response to 

0092. Is there -- is there anything else that SC&A or NIOSH needs from 

either side that we haven't covered? 

MR. BARTON: Well, that may come up as we look into Dr. Lockey's 

question and how best to approach it, so there may be -- 

CHAIR CLAWSON: Well, I --

MR. BARTON: -- a call needed. 

MEMBER LOCKEY: Bob? Hey, Bob, Jim Lockey, you know, I was just -

- I would -- you and Tim sit down and say is -- is the database -- is the 

database structured in a way that this question can be answered. If he says 

no or it's going to take days and days and months of work, then -- you 

know, then we need to know about that. But if it's a rather simple process, 

then that's a different -- different perspective. I have a different perspective 

on it.

MR. BARTON: And I simply don't know at this point. 
132

MEMBER LOCKEY: Yeah, I don't either. And I think that's a 

conversation you and Tim can have. 

CHAIR CLAWSON: Well, Bob you'll -- you'll get back with the work 

group on this and give us a layout of what -- what it looks like for you with 

the assistance of NIOSH and stuff, because I also don't know because of the 

security issues that we're having and everything else like that, to be right 

honest, I think it may be a little bit harder than what we know. But does 

that sound okay, John, with -- with -- with you? Have we met the 

requirements of both sides need and what is responsible? 

DR. CARDARELLI: Yes, sir. 

CHAIR CLAWSON: Okay. I think that really wraps up this work group 

to this point. Is there any other Board Members or any members of SC&A or 

NIOSH that want to have any last words? 

April 2023 ABRWH Meeting

DR. ROBERTS: Brad, I had a question for you. We have a -- 

CHAIR CLAWSON: Sure. 

DR. ROBERTS: -- full Board Meeting coming up in April, and a report 

on this work group was tentatively put on that agenda. Is that something 

that we want to keep on the agenda and if so, how long? 

CHAIR CLAWSON: John, -- yeah. I'm going to -- I'm going to tell you, 

I'm going to have to refer to SC&A on -- on the white paper. We may -- we 

may -- we may just have to give a brief update of what our path forward is 

as this work group and discuss some of the issues that we're having and --

and how we're trying to settle them. So I'd still leave it on there, but we 
133

may not be able to give the full update that -- that we were hoping. Would 

that -- is that okay, Rashaun? How much time do we have allocated for us?

DR. ROBERTS: I think it's a -- it's a fair bit, but -- but what would be 

appropriate? You said brief. Maybe -- 

CHAIR CLAWSON: Well, -- 

DR. ROBERTS: -- an hour? half hour -- 

CHAIR CLAWSON: I'm going to -- 

DR. ROBERTS: -- to an hour? 

CHAIR CLAWSON: To me personally and SC&A or NIOSH, you can --

you can correct me on this, to me, it's looking like if -- if -- I think we're just 

getting (indiscernible) able to do an update (indiscernible) NIOSH, and they 

won't have an opportunity to have really evaluated it. So, I think an hour 

time period would be enough for us to be able to give a brief (indiscernible) 

this is where we're at with this period. 

DR. ROBERTS: Okay. Did you -- 

CHAIR CLAWSON: Do you agree with Bob? 

DR. TAULBEE: Did you say an hour or a half an hour, Brad? 

CHAIR CLAWSON: Well, I -- I'm just wondering if some of the other 

Board Members have any other questions. I was giving a little bit of extra 

time. I think that we can bring them up to date and a half an hour, but I 

was giving the other Board Members that are not on this work group an 

opportunity to maybe have some of their questions answered. 

MEMBER LOCKEY: I think an hour is a good time, Bob. 

CHAIR CLAWSON: Okay. 

DR. ROBERTS: Okay. There's one -- 
134

MEMBER LOCKEY: I think Brad and I are in agreement that we're not 

going to let this one go 10 years out, right, Brad? 

CHAIR CLAWSON: I haven't wanted to go down this long as it is, 

buddy. So go ahead, Rashaun, I'm sorry, he was just digging me. 

DR. ROBERTS: This is the consideration perhaps for the next meeting. 

But, you know, perhaps the work group wants to discuss the prime 

contractor employees, perhaps, on the next work group agenda somewhere. 

You know, and discuss whether or not dose construct -- dose reconstruction 

is feasible, etc. So I just -- that's something that's sort of a topic that had --

I don't think we've closed the loop on. 

CHAIR CLAWSON: Right. Rashaun, you know, I will be brutally 

honest with you, I -- the whole reason that we took and separated out the 

subcontractors like this -- because this was the low hanging fruit. This was 

(indiscernible) we saw issue with, we saw everything (indiscernible) help. 

And you are truly correct in that standpoint. I -- I really don't think that we 

can go on to the prime contractor until we get this one taken care of 

because there's still so many questions of -- of -- of the path forward that 

we could go with this. Yes, we do have to look at the prime contractor for 

the exact same reasons because if they weren't being monitored, the same 

as what the subcontractors were, you know, we have an issue there. I think 

-- I think this is something we need to bring up, but I was -- I was trying to 

get to an end with -- with this small piece of it. 

DR. ROBERTS: Okay. Yeah, I just -- 

CHAIR CLAWSON: But we have -- we have to -- 

DR. ROBERTS: -- make sure we didn't forget. That's all. 
135

CHAIR CLAWSON: And I appreciate that, and no, I haven't forgotten 

about that. 

DR. ROBERTS: Okay. 

CHAIR CLAWSON: I just -- I will be honest, I thought that we were 

going to come to a lot better consensus on where we're at right now. 

DR. ROBERTS: Okay. 

CHAIR CLAWSON: What were you going to say, Lockey? 

MEMBER LOCKEY: Rashaun? Hey, Rashaun, I wasn't at the last phone 

conference because of another conflict. We're not meeting in person, right? 

Is that right? Is that correct? 

DR. ROBERTS: For April, it's going to be virtual. 

MEMBER LOCKEY: Why is that? Can I ask I just for my own...? 

DR. ROBERTS: Yeah, we weren't able to find conference space for the 

meeting. 

CHAIR CLAWSON: It's called the -- it's called The Masters. That's 

exactly it.

MEMBER LOCKEY: I understand. 

DR. ROBERTS: All right. 

CHAIR CLAWSON: I tried to bring that up. I -- I want you guys to 

always know that you're always welcome in Idaho. We're a very friendly 

group out here. 

But thank you, Rashaun, and no, I haven't forgot about it. I just --

I've tried to separate this out because this is a very difficult and complex 

site, and we have had these issues and these dealings for a long time. We 

are going to have to, and I have not forgot about the prime contractors. 
136

We've got to make these evaluations and -- and -- and go from there. But a 

lot of -- kind of bring this to an end and, but I do appreciate you bringing 

that up to me. 

DR. ROBERTS: Sure. 

CHAIR CLAWSON: With -- with Bob, do you have any questions of 

your path forward in your tasking? 

MR. BARTON: Just specifically to the Board Meeting, are we doing an 

SC&A presentation only or SC&A and NIOSH presentation, or how do you 

want to work that just so -- what I -- what I'd envision is basically a 

modified version of what Joe and Ron had presented with the updates from 

the discussion in this meeting and the updates and as far as path forward. 

And we can certainly do that. It is a quick turnaround time, but we can 

certainly do that.

CHAIR CLAWSON: I --

MR. BARTON: -- if NIOSH desires to also present the material that 

John put forth today also. 

CHAIR CLAWSON: Well, that's -- that's 40 slides. If they could do it 

in six slides or less, yeah, we could probably do that. What -- what's your 

feelings on that, John? I want to make sure that NIOSH has their due 

diligence. 

DR. CARDARELLI: Well, we can certainly reduce the number of slides 

and probably, you know, stick with our conclusions. So yes, we -- 

CHAIR CLAWSON: Well, you don't -- I'm not looking -- I'm not looking 

at so much the conclusions or anything else like this. What I would like to --

what I envision from -- from this is that we kind of just give a brief synopsis 
137

of where we're at on this. These are the issues just boom, boom, boom, 

these are what we're trying to address. I -- I -- I would like to be able to try 

to have some information for Lockey of our path forward, if we're going to 

be able to do it or not. And maybe if -- if why -- why we couldn't. What --

does that sound right? I -- I -- I think that SC&A and NIOSH needs an 

opportunity to be able to just give a quick this -- you know, these are the 

things that we're looking at, this is what we're doing. We don't need to get 

into the -- the nitty gritty part of it that the work group has to go into, but 

just to give people an idea of where they're at now. Now -- now, it may 

come up that we have other Board Members that want to dig a little bit 

deeper into why this is an issue or whatever, and we just need to be able to 

address it from there.

Tim, you popped up, so...

DR. TAULBEE: I agree with you 100 percent there Brad. I think a 

short synopsis that you just went through and the path forward is really all 

that's needed. And so to me, one presentation would cover it. 

CHAIR CLAWSON: Okay. Okay, when you say one presentation, one 

presentation from NIOSH and SC&A or just one presentation? 

DR. TAULBEE: I would think one total, and if SC&A wants to give it, 

that's fine, you know, from our standpoint, or if you want us to, we can, 

either way.

CHAIR CLAWSON: Okay, I -- yeah, where -- it's kind of a response 

back from SC&A on this 0092. I think, Bob, if we could just have you kind of 

go a path forward of this as far as what we're looking at, these are kind of 

the issues, and we'll just -- we'll just go with yours and go from there. 
138

There may come up some stuff that NIOSH may have to address, but I think 

we can deal with it from there. 

MR. BARTON: Very good. 

CHAIR CLAWSON: Okay. Anything else that needs to be taken care of 

at this time? 

MEMBER LOCKEY: I have one request. 

CHAIR CLAWSON: Oh, no. 

MEMBER LOCKEY: Yeah, I do. I had -- 

CHAIR CLAWSON: (Indiscernible) -- 

MEMBER LOCKEY: I have four feet of snow on my roof, and I need 

volunteers to come out here and shovel it off. 

CHAIR CLAWSON: I'm not going to show you guys my front yard, so -

- 

UNIDENTIFIED SPEAKER: That's incredible. 

CHAIR CLAWSON: -- so that -- that's the way it is. You're going to 

have to take that broken hip of yours, get up there, and get stuff taken care 

of. 

MEMBER LOCKEY: I'm sending my -- 

CHAIR CLAWSON: In other words, -- 

MEMBER LOCKEY: I'm sending my wife. 

CHAIR CLAWSON: Okay, in other words, cowboy up. 

So, Rashaun, that being said, I believe that we're done with this -- this 

work group. I will -- I will turn it over to you to be able to end, but I also 

want to make sure that you have the information you need to be able to 

proceed forward. 
139

DR. ROBERTS: Brad, I'm all set. Do you want to make -- go ahead 

and have and -- and have the work group make a motion and to -- to -- 

CHAIR CLAWSON: Yeah. Let's -- let's -- 

DR. ROBERTS: -- adjourn? 

CHAIR CLAWSON: If -- if you have everything. I know that we've 

kind of cut you out of this. I apologize. I just want to make sure as the 

DFO that -- that -- that it's clear for you what -- what our path forward was. 

MEMBER LOCKEY: I move we -- we adjourn. 

CHAIR CLAWSON: I second it. It's been moved and seconded. The 

we can adjourn. I appreciate everybody's input. I know that we have a long 

road ahead of us, but I appreciate everything that everybody does. 

Lockey, get up and start shoveling. 

Thank you, everybody. We'll see you later.

(Whereupon, the meeting was adjourned at 3:45 p.m. EST.)