THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

PUBLIC HEALTH SERVICE 

CENTERS FOR DISEASE CONTROL AND PREVENTION 

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 

convenes the 

WORKGROUP MEETING 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

The verbatim transcript of the Meeting of the 

Advisory Board on Radiation and Worker Health 

Workgroup held in Cincinnati, Ohio, on Aug. 4, 2005. 
 

2 

 

C O N T E N T S 

Aug. 4, 2005 

WELCOME AND OPENING COMMENTS 6 

DR. LEW WADE, EXECUTIVE SECRETARY 

WORKGROUP DISCUSSION 11 

COURT REPORTER’S CERTIFICATE 189 
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TRANSCRIPT LEGEND 

The following transcript contains quoted material. 

Such material is reproduced as read or spoken. 

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

an unintentional or purposeful interruption of a 

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

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

word(s) when reading written material. 

-- (sic) denotes an incorrect usage or pronunciation 

of a word which is transcribed in its original form as 

reported. 

-- (phonetically) indicates a phonetic spelling of 

the word if no confirmation of the correct spelling is 

available. 

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

"uh-uh" represents a negative response. 

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

without reference available. 

-- (inaudible)/ (unintelligible) signifies speaker 

failure, usually failure to use a microphone. 

In the following transcript (off microphone) 

refers to microphone malfunction or speaker's neglect 

to depress "on" button. 
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 P A R T I C I P A N T S 

(In Alphabetical Order) 

BOARD MEMBERS 

EXECUTIVE SECRETARY 

WADE, Lewis, Ph.D.

Senior Science Advisor 

National Institute for Occupational Safety and Health

Centers for Disease Control and Prevention 

Washington, DC 

MEMBERSHIP 

GIBSON, Michael H.

President 

Paper, Allied-Industrial, Chemical, and Energy Union

Local 5-4200 

Miamisburg, Ohio

GRIFFON, Mark A.

President 

Creative Pollution Solutions, Inc.

Salem, New Hampshire

MELIUS, James Malcom, M.D., Ph.D.

Director 

New York State Laborers' Health and Safety Trust Fund

Albany, New York

MUNN, Wanda I.

Senior Nuclear Engineer (Retired)

Richland, Washington 

OTHERS: 

ALLEN, DAVID, NIOSH

BEHLING, HANS, SC&A

BLOOM, CINDY, MJW

BROCK, DENISE, UNWW

CASE, DIANE, DOL

ELLIOTT, LARRY, NIOSH/OCAS

GUIDO, JOSEPH, MJW

HOMOKI-TITUS, LIZ, HHS/OGC

HOWELL, EMILY, HHS/OGC

KATZ, TED, NIOSH 
 

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KOTSCH, JEFF, DOL

LIPSZTEIN, JOYCE, SC&A

MAKHIJANI, ARJUN, SC&A

MAURO, JOHN, SC&A

MILLER, RICHARD, GAP

NETON, JIM, NIOSH

SAMSON, BOB, GAO

SHEFFITS, SANDRA, GAO

TAULBEE, TIM, NIOSH 

STAFF/VENDORS

LASHAWN SHIELDS, Committee Management Specialist, NIOSH

STEVEN RAY GREEN, Certified Merit Court Reporter

JONICA MUELLER, Certified Court Reporter 
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 P R O C E E D I N G S

 (9:30 a.m.) 

 (Technical difficulties occasionally rendered 

portions of comments made by a speaker 

unintelligible. Those portions are noted as 

such.) 

 DR. WADE: With apologies for the lateness of 

the hour in terms of getting started, but we 

had technical difficulties, this is Lew Wade. 

I work for NIOSH. I also serve as the 

Designated Federal Official of the Advisory 

Board on Radiation and Worker Health. 

This is a working group meeting of the Advisory 

Board. This working group meeting specifically 

is looking at issues related to the 

Mallinckrodt site profile and the review of 

that site profile by the Board and the Board's 

contractor, SC&A. 

I would also remind all of you that there is 

also an SEC petition before the Board that 

relates to workers at Mallinckrodt. This 

working group is looking specifically at the 

site profile, but clearly there are 

interactions between the two processes as they 

go on. 
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The Board asked this working group to get 

together and it also asked that we conduct the 

working group meeting as a public meeting, so 

we've noticed this working group meeting. The 

public has been invited. There will be no 

public comment period scheduled during this 

working group meeting. The public is allowed 

to listen to these deliberations. 

The Board did make it a point to say that the 

petitioners involved in the Mallinckrodt SEC 

petition be invited to participate fully in 

this working group, and I see that Denise Brock 

is with us. Denise, you only need to let us 

know of your interest to speak at any point and 

you can speak. You're also welcome at the 

table, but I think you're more comfortable -- 

at least you identified you're more comfortable 

where you are. 

The working group that has been put together 

for this consists of Dr. Melius, Mark Griffon, 

Wanda and Mike Gibson, who is not here. 

 MR. GIBSON: I'm on the phone. 

 DR. WADE: Oh, Mark -- Mike is with us. 

Welcome. 

It is important that in the conduct of this 
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business there not be a quorum of the Board 

present, so I would certainly ask when we go 

around that all Board members identify 

themselves so that we can police this action 

relative to there being a quorum. A quorum 

would be six or more Board members. I'm 

operating on the assumption that we will not 

have that quorum. 

Now Ray Green could not be with us to -- to 

transcribe and produce minutes of this, but his 

colleague, Jonica Mueller, is with us and will 

ably fill in for Ray. 

I don't think there's anything else other than 

for us to go around and identify ourselves. I 

would certainly ask that any Board member, any 

representative of SC&A, any representative of 

the Federal government identify themselves. 

Members of the public are free to identify 

themselves or not, as they see fit. But again, 

it is terribly important that any Board member 

identify themself, so let's go around this 

table. Then we'll do the people in this room, 

then we'll do the people on the telephone. 

Again, my name is Lew Wade. I work for NIOSH 

and serve the Advisory Board. 
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 MR. GRIFFON: Mark Griffon, member of the 

Advisory Board. 

 MS. MUNN: Wanda Munn, Advisory Board member. 

 DR. MAKHIJANI: Arjun Makhijani, SC&A. 

DR. NETON: Jim Neton, NIOSH. 

MR. GUIDO: Joe Guido, MJW. 

MS. BLOOM: Cindy Bloom with the ORAU team, 

also MJW. 

MR. ALLEN: Dave Allen with NIOSH. 

DR. MAURO: John Mauro with Sanford Cohen & 

Associates. 

 DR. MELIUS: Jim Melius, Board member. 

 DR. WADE: Anyone in the audience who would 

like to identify themselves? Denise, would you 

please? I believe you have to do -- okay, 

thank you. 

Now on the telephone, in no particular order, 

let's start with any Board members present. 

 MR. GIBSON: Mike Gibson, member of the 

Advisory Board. 

 DR. WADE: Thank you, Mike. Any other Board 

members present? 

 (No responses) 

 Representatives of SC&A? 

 DR. BEHLING: Hans Behling, SC&A. 
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 DR. WADE: Anyone else from SC&A? 

 DR. BEHLING: I believe Joyce Lipsztein was 

going to phone in and she'll join us later. 

She must have disconnected, but she said that 

she will be calling back in a matter of 

minutes. She was on the phone around 9:30. 

 DR. WADE: Thank you. NIOSH or its 

contractors? 

 MR. TAULBEE: This is Tim Taulbee with NIOSH. 

 DR. WADE: Anyone else, NIOSH or its 

contractors? 

 (No responses) 

Any other employees of the Federal government. 

 MR. KOTSCH: This is Jeff Kotsch with the 

Department of Labor back in Washington. 

 DR. WADE: Thank you. 

 MS. CASE: And Diane Case, as well, Department 

of Labor. 

 DR. WADE: Thank you. 

 MR. SAMSON: This is Bob Samson from GAO, also 

in Washington. 

 DR. WADE: Welcome, Bob. 

 MS. SHEFFITS*: And Sandra Sheffits with the 

GAO in Chicago. 

 DR. WADE: Any other representatives of the 
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Federal government? 

 (No responses) 

Anyone else who would like to identify 

themselves? 

 MR. MILLER: Richard Miller of the Government 

Accountability Project. 

 DR. WADE: Welcome, Richard. Anyone else? 

 (No responses) 

Okay, before I turn it over to Mark, just to 

sort of put this in context, the Board had laid 

out a very specific procedure for this working 

group to follow. It included the working group 

meeting sometime between July 31st and August 

8th. This is that meeting. 

There is the expectation that SC&A would review 

the NIOSH materials presented at this meeting 

and would prepare a response to the Board by 

August the 16th in anticipation of the Board 

meeting scheduled for the end of August. 

Mark, those are all the introductory comments I 

have. Please... 

 MR. GRIFFON: My -- my piece here'll be pretty 

short, Jim. I -- I think we should -- we 

passed around -- I don't know if you got a copy 

of this, Denise, but it's the document 
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generated at the last Board meeting -- the 

priority issues for demonstrating feasibility 

of dose reconstruction for Mallinckrodt. And 

there's a list of tasks, and I thought that 

probably the best way to work through this is 

to start on this list of tasks and have NIOSH 

present their materials for each item. And 

maybe, if it's okay with -- with -- with NIOSH, 

with Jim, I think we'd like to keep it fairly 

informal so that we can break in with questions 

during your presentation instead of holding 

them off until the end or something. I think 

it'd be better -- I think it would, you know, 

be more workable if we could just interact 

while you're presenting. So if that's okay, 

I'll turn it over to Jim and let you start with 

number one. 

DR. NETON: Okay, thanks -- thanks, Mark. I --

I really -- since this was in the format of a 

working group, I really did not prepare any 

official Power Point type presentations, but 

I'd just like to continue on the conversation 

we had at the last working group meeting which 

was held by telephone. I think it was -- time 

-- time flies. I think it was last week, some 
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-- somewhere thereabouts. 

Since that -- that meeting, we have distributed 

a number of what we're calling our -- our inprocess work products and, you know, we -- we 

sent them to the Board and other interested 

parties as -- as they were available, so 

hopefully folks have had a chance to look at 

those documents and formulate some -- some 

rough opinion as to whether they're in 

agreement or disagreement with -- with where 

we're headed. 

The first -- the first issue on the table is 

under item 1(a), the handling of raffinate 

exposures where NIOSH has specified the 

radionuclide ratios for ore processing, 

including non-pitchblende ores. That was 

substantially covered, to a large extent, in 

the document that was distributed entitled -- 

let me see if I can -- yeah, it was a 23-page 

document. It was entitled "Dose Reconstruction 

Approach for Mallinckrodt Uranium Process 

Residues". 

 DR. WADE: And we have copies of all these 

documents if anyone requires them. 

DR. NETON: Yeah, there are copies at the back 
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table available for members of the public and I 

have brought extra copies of everything for 

people at the -- at the working group table if 

they don't have them with them. 

Let me just see -- I also have it on my laptop 

here. I can bring it up if we get to any 

specific sections that people want to discuss. 

What was the title of that again, Wanda, "Dose 

Reconstruction Approach" -- I made -- okay, I 

made a PDF file out of it, that's where it is. 

Okay, I'll just bring that up and -- there is a 

slightly revised version of this that you don't 

have, but -- but in essence it was just 

corrections of some typographical errors and 

that sort of thing, which did not change any of 

the -- substantially any of the technical 

content. 

But in that document I think you would have 

seen that our approach at -- at this time is to 

rely on the radon breath data for workers to 

establish the radium intakes for workers. And 

then subsequent to radium in the decay series, 

we would apply the ratios that were observed in 

the K-65 material stored in Silo One at the 

Fernald site. There is some -- some discussion 
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in the document that we distributed that -- 

that leads us to believe that that material is 

-- is representative -- it is the material that 

was collected at Mallinckrodt, whether it came 

from Mallinckrodt directly to Fernald or via a 

temporary storage at the Lake Ontario Ordnance 

Works, they are actually the K-65 materials 

that were collected. You know, we're not 

stating that the absolute concentrations are to 

be used, but really we're relying on the ratios 

of the progeny in those -- in those materials, 

in the K-65. 

But to take a step backwards again, we are -- 

rather than using the ratio that was proposed 

of 100 to one in the profile to bracket the 

radium to uranium ratio for workers with K-65 

material, we have gone through -- evaluated the 

data and we believe that the radium breath data 

provide more realistic bounding values for 

intakes of radium at the site than applying a 

ratio of 100 to one. There's a couple of 

reasons for this, and I'll just throw this out 

here and we can open it up for discussion, I 

suppose. 

But the -- it became obvious in looking at many 
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of these dose reconstructions -- not many, you 

know, looking at the dose reconstructions that 

the workers themselves were not only exposed to 

K-65 material. So you know, it would be 

inappropriate, for instance, to have a worker 

who -- who worked with uranium -- pure uranium 

materials and then K-65, to apply this 100 to 

one ratio because many workers were rotated 

throughout the plant in the attempt to keep the 

-- their exposures below certain standards, and 

the K-65 material had very high -- high dose 

rates so the workers were rotated through. So 

we -- we believe that just taking the uranium 

intake for a worker and then multiplying it 

times 100 results in fairly -- fairly 

substantial intakes that are actually not borne 

out by looking at the air monitoring data 

themselves. 

For example, if you look at an intake of a 

worker using bioassay data, in the first one -- 

and Joe Guido will talk about this later -- his 

intake in picocuries per day actually about 

equals what the intake was predicted based on 

air sample data, within -- within the realm of 

what I showed at the last Board meeting, that -
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- you know, the air sample data somewhat 

indicates that possibly the person had no K-65 

exposure at all. So to take that intake, which 

is -- which is equivalent to the K-6-- which is 

equivalent to the air monitoring data and then 

increase it by a factor of 100 for the radium 

progeny puts it above where you would expect 

any intakes from U in the in-plant air 

monitoring data. So that's one reason. 

The second reason, more importantly I think, is 

that the K-65 -- the radon breath data are more 

-- we believe to be more representative of 

reality. It's a -- it's a bioassay measurement 

taken on an individual. It's not reliant upon 

air concentration data. So that's where we're 

at with that. 

Now we would propose, however, once you get the 

radium intakes based on the K-6-- based on the 

radium breath, then we still need to apply the 

dose fractions from the progeny below radium. 

And those fractions would be based on the ratio 

of radium to progeny in the K-65 material at 

Fernald. So that's where we're at. 

It's open to discussion, I suppose. 

DR. MAURO: This is John Mauro. First of all, 
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I really appreciate all the material that you 

provided to us prior to this meeting, and Arjun 

and I and the other folks on the line, Joyce 

and Hans, have all had an opportunity to fairly 

quickly run through the material within the 

context of all the material that came before. 

It's been extremely helpful and I really 

appreciate the incredible amount of work that 

went in. 

What -- what we have been doing is caucusing 

over the past several days and formulating, 

certainly just as (unintelligible) in a 

situation where they're still formulating and 

finalizing (unintelligible) and we're doing the 

same. And there are a number of areas where I 

think that, for the purpose of this meeting, it 

would be helpful to make a distinction between 

those areas where you have laid out a strategy 

for coming to grips with what I would call site 

profile type questions. Here we have certain 

data -- in fact, here we have lots of data, and 

here's how we plan on prioritizing or combining 

and using and -- these data in order to do the 

dose reconstruction for a particular worker 

where you may have some missing data. 
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 My initial impression -- and I'm going to work 

through -- I'm -- these are really by way of 

introductory remarks and (unintelligible) to 

Arjun, who's really been our point man, to help 

in an appropriate way to start to engage some 

of these issues as we move through them. So I 

thought it'd be worthwhile, if it's acceptable 

to the Board, that as we move through the 

processes we could (unintelligible) -- could 

communicate our initial impressions and the 

things that we've been thinking about, with the 

objective of forwarding the process so we're as 

mature down the road as we can as we approach 

the end of August. 

One of the things that I think might be very 

helpful today is as we go over some of our 

observations and thoughts on some of the 

matters, such as the ones you just described, 

it might be important -- to the degree we can -

- to parse between those areas where our 

concern is with the data itself and its 

adequacy, because we recognize that the data 

itself and its ability to completely 

characterize or to be useful as a surrogate or 

as a cohort data for the purpose of dose 
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reconstruction, that goes toward issues that 

are of concern from an SEC point of view -- we 

recognize that's part of what's on the table 

here -- and those items that lean more toward 

what I call site profile issues where you might 

-- where you may have lots of data, but we may 

have certain questions as to how you would use 

that data in the -- in the most claimantfavorable optimal way. 

So what we would like to do, and I'm going to I 

guess leave it to everyone around the table, 

when would it be appropriate for SC&A to say 

okay (unintelligible) -- for example, put 

forward certain ideas and strategies where we 

sort of come out right now and our thinking on 

it so that is a -- that is a prerequisite. I'm 

going to ask Arjun, and certainly the folks 

that are on the phone, which I believe is Joyce 

and Hans, Joyce looking mainly at the internal 

dosimetry issue, the radon issue, the raffinate 

issues and the strategies that you are engaging 

in, and Hans looking more toward some of the 

external dosimetry issues as being the areas 

where (unintelligible) us communicating to you 

our initial impressions so that we can move on 
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from there. 

So with that said, I guess -- Arjun, at this 

point if there's anything that you want to 

bring in or -- or I didn't want to interfere -- 

 MR. GRIFFON: No, no, no. 

DR. MAURO: When I get this dialogue, I 

(unintelligible). 

 MR. GRIFFON: Yeah, I mean I -- I expect this 

to be pretty informal, so as you have comments 

I think just bring them in and bring your 

general opinion of a certain issue any time -- 

you know, any time it comes up. I mean let's 

just have a form-- informal discussion. I mean 

I -- I was going to ask, you know, Jim, that -- 

that covers number one. But if we start to go 

down 1(a), (b), (c) --

DR. NETON: Right. 

 MR. GRIFFON: -- I think we'll -- we'll pull 

out some of these details that -- that we know 

are in this report. And I think most -- mostly 

what we discuss in this report, you know -- 

DR. NETON: Yeah, sure. 

 MR. GRIFFON: -- go down these questions, so 

Denise has a comment, though. 

MS. BROCK: (Off microphone) I have a question 
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already and I don't want to bog everybody down. 

I feel funny asking questions but sometimes I 

just don't understand (unintelligible) and I 

can't tell (unintelligible) that's why I'm 

confused (unintelligible) daily weighted 

averages (unintelligible) going to use the 

daily weighted averages (unintelligible) radon 

(unintelligible) things right. 

DR. NETON: Right, the daily weighted average 

values are the air sample data that were 

collected in the campaigns on a yearly basis, 

usually over a couple of month period. We 

believe that the radon breath data are a better 

indicator of the intake of radium for the 

worker than relying solely on the daily 

weighted average. 

MS. BROCK: Isn't that a little bit different 

than what you had previously thought at the 

last meeting? 

DR. NETON: That's true. That's true that we -

- we had proposed, as a -- as a bracketing 

measure, we would rely on the daily weighted 

averages. Those still are there. We don't 

believe them to be totally unreliable. We just 

believe that this approach is -- is a better -- 
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a bit more refined estimate. 

MS. BROCK: Then I guess I'm -- I wanted to ask 

about the SEC evaluation then. Is that a 

living document as well as the site profile? 

mean can it be --

DR. NETON: I believe Larry or Lew could -- 

MS. BROCK: -- altered and changed like this? 

DR. NETON: That's more of a --

 DR. WADE: (Unintelligible) speak to that? 

 MR. GRIFFON: Larry. 

 MR. ELLIOTT: The -- as -- as you know, Denise, 

we have provided supplements in response to 

issues raised during Board deliberations on the 

evaluation report. And I would see that in 

this case we will add another supplement 

responding to, again, another set of issues 

that have been raised. So is it a living 

document? This is a deliberation process that 

the Board is engaged in. And as we proceed 

through that, the evaluation report will have 

to be reflective of that process. I don't know 

that we have envisioned evaluation reports to 

be living documents, as we speak about site 

profiles being living documents, because as we 

work through dose reconstruction we identify 
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improvements to methodologies, data 

information, the site profiles do change. The 

evaluation reports are different in that as 

soon as a determination is made about a 

petition, then that establishes the conclusion 

of the evaluation. Does that help you 

understand? 

MS. BROCK: I -- I understand what you are 

saying, but I'm perplexed because I -- my 

thought, and I believe the claimants' thought 

at the last meeting, was that NIOSH was going 

to use the daily weighted average and basically 

the proof is in the pudding, you can use the 

daily weighted average. And then I'm wondering 

what caused you to eliminate that. I know you 

feel the breath radon is more reliable, but 

isn't there only a minimal amount of claimants 

that actually had breath radon? I mean how 

reliable is that? 

DR. NETON: Well, we -- we estimate around 20 

percent of the cases that we have in our 

possession where people worked during the 

raffinate period have radon breath data. We've 

looked at the files, and each -- each person 

who has radon breath data, and we have radon 
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breath data for 2,500 individual measurements, 

each -- each measurement is -- not all of them, 

but almost all of them are labeled with the job 

category, title, some indications of what the 

process was that the worker was involved -- 

what the worker was involved in. They are 

almost exclusively -- not exclusively, but to a 

large extent related to raffinate type workers, 

people who worked in Plant 6 with radiumbearing materials. But we believe that the 

samples that were taken were taken on the 

target population that were potentially 

exposed. I've looked personally through the 

files of the cases we have that are not -- do 

not have radon breath data. Many of them are 

workers such as administrative folks, security 

folks, forklift operators. One could argue 

whether that should have been monitored or not, 

but it makes some sense to us, looking at the 

files, of who was monitored for radon breath 

and why. And there are actually internal HASL 

-- letters to HASL back and forth discussing, 

you know, which -- which types of workers would 

be monitored and put on the monitoring program. 

 MR. ELLIOTT: I think it's important for us all 
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to recall, if your question comes from the 

perspective of your petition, that the class 

that you have petitioned for here is -- the 

petition is evaluated under our -- our rule, 

the SEC petitioning process rule. And in that 

rule we are required to demonstrate where we 

can do dose reconstruction by capping the dose. 

And the particular question at hand with regard 

to how we go about doing that, whether it's 

using breath radon or whether it's using timeweighted average air concentration data really 

goes to dose reconstruction. We've -- we have 

demonstrated, we feel, in our evaluation 

reports and the supplements to that original 

evaluation report we've been consistent in our 

commentary saying we feel we can reconstruct 

dose. And I think as we would have proceeded 

in doing dose reconstructions, we would have 

achieved some of these recognitions that Jim is 

bringing forward now as part of this 

deliberative process of the Board. 

DR. NETON: I think this gets down to what John 

Mauro was talking about earlier, which is -- 

which is related to -- in an SEC evaluation one 

is -- one is trying to make the determination 
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can you bound the doses using -- you have 

sufficient data available to bound doses, and -

- and that's one analysis. 

Now when we get down into actually doing dose 

reconstructions where we are now, that's a 

slightly different issue as to how best to use 

the available data to make a more realistic 

determination of what the -- you know, what the 

individual doses are to work with. So that 

they're actually separate analyses. They 

really are. 

 MR. GRIFFON: Yes, but -- but -- but it is also 

important to note that -- I mean we went down 

this line of questioning for you to demonstrate 

that you could do it with your method at hand 

from the daily weighted averages. You were --

you were questioned by the Board to go back and 

look and give us specifics of how you were 

going to deal with the raffinate in terms of 

the daily weighted averages and -- and 

demonstrate to the Board that you could -- 

could cap the dose, bound the dose. And what -

- the answer you came back with was a little 

bit --

DR. NETON: Right. 
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 MR. GRIFFON: -- on the other side, so that -- 

that -- I think that's (unintelligible) -- 

DR. NETON: Yeah, I understand the 

(unintelligible) --

MS. BROCK: That's --

 MR. GRIFFON: -- it seems like a -- I mean 

maybe you can still answer that first question, 

can you bound the dose with the air sampling. 

I think you're saying maybe -- 

MS. BLOOM: And maybe --

 MR. GRIFFON: -- (unintelligible) we can, this 

is a better estimating technique I think is 

where you're going. 

DR. NETON: I think that's what I'm saying 

is... 

MS. BROCK: And that's exactly where I was 

going with that. It was my understanding, just 

as a lay person and somebody that petitioned 

this, that it was my understanding that you 

were going in front of the Board to show them 

that you could do it with a daily weighted 

average. And I personally don't really know -- 

I don't understand completely the difference 

between that, but I was curious what -- what 

specifically will not allow you to use that 
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daily weighted average. And as a petitioner 

I'm thinking to myself, since you haven't been 

able to do that and now you're switching gears 

-- at least in my mind that's what it looks 

like -- and you're trying something else, has 

this been validated? I mean how do we know 

that this is going to work and how do we know 

exactly if this is going to work or not. How 

do we -- how do we tell the difference and -- 

and I thought that we would be held to the 

daily weighted average, or you would be. 

MS. BLOOM: Maybe -- maybe I could answer 

that. I was -- I'm Cindy Bloom and I was 

brought in at the last minute to answer that 

question. 

Can you hear me if I turn my head? 

 (Off microphone) And when I started from the 

list of priority items to answer, and 

(unintelligible) the list that I read down and 

the first thing it said is can you tell me 

what's in the residue. And I'm going to call 

it the residue, the K-65 (unintelligible) not 

as raffinate but as K-65 or residue. And 

that's so (unintelligible). So first they 

answered that question. And as you look down 
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that list of questions you'll see that it says 

how are you going to do a dose reconstruction. 

And so I looked at all the data and I did look 

at the air data, and I did both a -- a fit of 

the tabulated data in the CER database and 

looked at the daily weighted averages there and 

I determined a geometric mean to those. I also 

looked at the maximum number or the maximum 

time-weighted average exposure in that dataset 

and I compared that to other (unintelligible) 

data. And some of that's in the -- in the 

report that we pulled together. Some of it may 

have been updated (unintelligible), but I did 

look at that part of the picture. 

But then it (unintelligible) here's the breath 

radon and I looked at that, and we have a lot 

of breath radon data, and so I went that route 

and I said you know what, this number is making 

more sense. 

I also looked at some of the workplace samples, 

which we don't have many, but we have one set 

of data from Mallinckrodt. We have data from 

another similar operation at (unintelligible) 

it's not a factor. Depends on (unintelligible) 

the radium measurement in air versus the 
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uranium measurement in air for the 

(unintelligible) cake operation at Mallinckrodt 

where they (unintelligible) residue sampling 

and where they were doing (unintelligible) and 

I looked at that and I looked at the ratios 

there, and they were more consistent -- the air 

sampling was more consistent with the breath 

radon ratios that we looked at -- the breath 

radon (unintelligible) radium 95th percentile, 

so it gets hard 'cause you're talking about 

these huge groups of data so I hope I'm making 

sense, but that fit with the air data that fit 

with what we were looking at in terms of that 

maximum daily weighted average. But if you 

applied the K-65 fraction itself from the 

(unintelligible) to -- let's see, we were 

actually doing it backwards to start to see if 

that was all radium. It doesn't make sense 

when you look at the workplace data and the 

other information, but you could do that and 

we've put some information together on that, as 

well. So we've looked at it all, but we're 

really trying to answer two questions. Can we 

bound the dose? I think so. Can we -- how are 

we going to do dose reconstruction? I think 
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that after looking at all the data that 

(unintelligible) clear to me that you would use 

the bioassay data and (unintelligible) 42 CFR 

(unintelligible) --

DR. NETON: 42. 

MS. BLOOM: -- 42 -- 42. So it -- that says 

you'll use bioassay data as -- as your first 

piece of information, but you also look at 

everything else. So we've really taken the 

opportunity to look at all the data and 

(unintelligible) really tired (unintelligible). 

 MR. GRIFFON: Let me ask John to comment 

(unintelligible). 

DR. MAURO: One of the impressions I got, and I 

would ask Arjun to develop it in a finer point, 

but it's a conceptual problem that we have. I 

understand -- you've created a series of what I 

call boxes whereby you have labels for job 

categories. You have labels for locations in 

buildings and facilities within buildings. And 

according to each of these designations, you 

have a fairly good idea of the types of 

activities that took place in each of these 

locations as a function of time. And on the 

basis of that, you could start to get a feel 
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for what datasets and information might be most 

useful for reconstructing doses -- I'll say 

internal doses in this case -- to workers who 

were in that location at that time. It's a 

very structured process and it's a -- it's very 

engineered and it's a -- it's almost -- it's 

almost like an assembly line. But when I read 

the documents I say that the lines -- when it 

comes to a real person now, and this is -- this 

is more of a conceptual problem -- I say okay, 

well, let's say we have a real person and we're 

trying to do a dose reconstruction for him. 

The problem is that that real person doesn't 

really fall into a given box. Not always, and 

maybe not often. That is, where he worked 

when, and certainly the feedback is not all 

that apparent. And so all of a sudden -- and -

- and it's -- it's almost like a fuzzy view I'd 

have right now. I say to myself okay, I've got 

this person. I -- I know he did these kinds of 

jobs and might have been over here sometime and 

might have been over there, and then I layer in 

that fact that -- and I think of this in terms 

of bands. You have people that worked at 

certain times with the ore, maybe. And then 
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you have people that worked with different 

kinds of ore. Then you worked with the -- I 

guess the -- the first dissolution process. 

That is another band where you produce the K65. Then there's another band of activities 

where maybe some different facility or a 

different time where the product that comes out 

is more of the short-lived progeny coming off 

the uranium. And then another band is where 

you're actually processing the recycled 

residue. So what I'm getting at is all of 

these are a flow that placing them in time and 

location and -- and marrying it back to a 

person. Then on top of that you have an array 

of data, lots of data, which is -- it's great, 

whereby you've got urine analysis with 

fluorometrics for uranium, you've got ratios 

that you have a handle on, at least for the 

radium to uranium that comes from the K-65. 

But then you've got these other ratios where 

you have these other short-lived radionuclides 

that come out of different bands in the 

process. What I'm getting at is -- and this is 

an impression initially obtaining and looking 

at the data. 
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(The reader should be aware that in addition to 

technical malfunctions in the telephone 

connections, there were other conversations 

taking place on the line at the same time the 

speaker was making his statement, which may 

have distorted the reporter's perception of 

what was being said.) 

It's not -- it's going to be difficult to place 

a person (unintelligible) this person at this 

place and this time, and this is the situation. 

And on that basis, we think the radon breath 

analysis is the best way to get a handle on 

what his radium body burden may be, as opposed 

to going with his urine analysis and using some 

ratio, whether it's 100 to one or 400 to one, 

as we -- so what I'm getting at is that we have 

-- what I -- and this again -- stepping back 

and I would look to others in our group who've 

been looking at this a lot closer -- that the 

boundaries are not that clear, so that in 

practice, when you really have a real person 

that you want to do a real dose reconstruction 

for, you're going to run into the blurry lines 

between the different operations and activities 

that you're going to have a hard time coming to 
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grips with. 

MS. BLOOM: John, I think we've looked at that 

and we've got some real cases to show you later 

to see how that plays out. I think that 

because of the way we do dose reconstruction on 

this project, the results are interesting. I 

think in general the coworker approach bounds 

things -- bounds doses, but we have individual 

data, we would use individual data first to 

address those kind of issues, and we'd use the 

other data to supplement it. But I think 

later, as we get into those cases, that would 

be a better time to -- to discuss that part of 

the process. 

DR. NETON: Yeah, I think we're getting ahead a 

little bit on the issue. But if you look at 

the -- what was broken down for the internal 

dosimetry geometry calculations, 30 percent of 

-- 37 percent of the cases we have have job 

occupation listed as "operator". It's pretty 

easy to agree, I think, that those operators, 

if they worked in Plant 6, are covered with 

this K-65 raffinate exposure methodology. 

You've got another 20 percent that are trades 

and crafts, so about 57 percent of the workers, 
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in our minds, fall very easily into these 

categories where if -- lacking any specific 

evidence that they -- that they weren't 

exposed, that they would fall under the 

umbrella of this K-65 raffinate exposure 

approach. 

That said, remember we have a large percentage 

UNIDENTIFIED: (On telephone) Hello? 

DR. NETON: -- of workers have bioassay data. 

Hello? Is that Joyce? 

 DR. LIPSZTEIN: Hello? 

DR. NETON: Yeah. Joyce, this is Jim Neton. 

How are you? I don't think she can hear us. 

 Well, anyway, I was just going to say -- and 

so, you know, we propose -- and we'll get into 

this -- that we're going to apply this to a 

fairly large percentage of the workers and use 

a more -- a broader brush than -- than you 

would think because, again, if we don't have 

the specific details, operators and trades and 

crafts are going to fall under this umbrella. 

We also believe the K-65 material intake 

calculations are bounding for the other residue 

streams in Plant 6. That would be in the 
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Sperry cake and the -- the barium sulfate -- 

and also the airport cake. There's some fairly 

large doses per unit intake that we'll get into 

that we -- we can talk about. 

 MR. GRIFFON: If it's okay, I was going to -- I 

was going to suggest why don't we get to some 

of those specifics now. We've got some general 

issues on the table and discussion items, but 

maybe we can start on a --

DR. NETON: Sure. 

 MR. GRIFFON: -- on -- and you can point to 

your report -- step us through it a little bit. 

We've all -- we've all reviewed this, but it's 

been kind of in a quick fashion, so it may be 

useful for everyone to hear. This is just the 

ratios that you --

MR. ALLEN: (Off microphone) (Unintelligible) 

 MR. GRIFFON: Uh-huh. 

MR. ALLEN: (Off microphone) (Unintelligible) 

DR. NETON: You need a microphone. Well, in 

specifics of handling --

 DR. WADE: Let's just do a check. Can people 

on the phone hear me? 

UNIDENTIFIED: Now, yes. 

 DR. WADE: Okay. So I mean I think it's 
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important that each of us put the mike very 

close and speak directly into it. Okay? Jim. 

DR. NETON: Yeah. Okay --

 DR. WADE: Closer. I think you need to be 

closer. 

DR. NETON: Sorry. If -- if you look at table 

one on page 5 of the document that we -- you 

know, that we -- oh, I'm sorry, I'm working off 

the original -- page 4, yeah -- it specifies 

the ratios, and Cindy can correct me if I'm 

wrong, but I believe those things came -- those 

doc-- values came out of the K-65 silo 

material. Is that right? Yeah. 

MS. BLOOM: They're based on that. 

DR. NETON: They're based on the silo material. 

MS. BLOOM: They're a little bit higher than 

those ratios. It's just sort of eyeballing 

things. 

DR. NETON: Right. So --

MS. BLOOM: (Off microphone) (Unintelligible) 

at the ratios. 

DR. NETON: So this would be the ratio that one 

would use, whether you -- whether you went as a 

multiplier of the radium to the uranium in the 

urine or whether we applied the radon breath 
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analyses and came up with our own independent 

radium intake value. Then the progeny below 

radium 226 then would be apportioned relative 

to the radium value. 

 That's what we propose to use. That was an 

issue on the table at the last Board meeting. 

I think SC&A, and correctly, identified that we 

did not specify in the profile exactly what 

ratios of the progeny -- it was clearly our 

intent to put progeny in there, it just wasn't 

specified. When we talked about the 100 to 

one, we were not just going to put radium in 

there. We understood that there were other -- 

other progeny to include. This -- this 

outlines in more detail what our proposal is. 

UNIDENTIFIED: (Off microphone) May I? 

DR. NETON: Yeah. 

 DR. MAKHIJANI: This is Arjun. I'd like to ask 

you a question about table one. I looked at 

the original Silo One data, the averages, which 

may be the -- arguably the more -- most 

appropriate values. And because these numbers 

-- I don't know how they have been rounded or 

adjusted upward, but I think it will make a 

significant difference because in the original 
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data the -- the radium was 264 nanocuries per 

gram in Silo One, and thorium was 40, so the 

ratio is about 6.5, so thorium to rad-- thorium 

to radium is bigger, one to 6.5, than what you 

have here, one to eight. 

And -- and similarly, the protactinium and 

actinium are bigger ratios to radium than what 

you have here, which is one to 80 and, as I 

have them, they're also like one to -- one to 

65. And the reason I bring that up, although 

it appears to be a minor problem, is that -- at 

least by my back-of-the-envelope calculations, 

just reviewing your document -- the dose to the 

systemic organs will be dominated by thorium, 

protactinium and actinium. And so small 

differences in these ratios will make a pretty 

big difference, so you have to have some 

demonstrable way to show that the ratios are 

claimant-favorable in terms of maximizing the 

thorium, actinium and protactinium. 

MS. BLOOM: There -- there was no intention 

that these numbers be taken as the final 

numbers. We were working really, really 

quickly to get something out that you could all 

look at --
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DR. NETON: Right. 

MS. BLOOM: -- and to try and just make the 

numbers simple. But I think that's a good 

comment, that -- that you want to look at 

exactly what is in that source term. We looked 

at other -- you know, this is the K-65 

information. Barium sulfate that they -- they 

didn't always process Q-11, the African 

pitchblende ores, there. They processed a lot 

of other things. So these -- these relative to 

uranium are going to be inflated anyway. A lot 

of the other material that was processed were 

concentrates, which would not have had the 

radium in it, and probably would have less of 

the other progeny in it, as well. So --

DR. NETON: Right. 

MS. BLOOM: -- this is just... 

DR. NETON: Yeah. 

MS. BLOOM: The details, certainly we'll take 

comments on those and -- and by the time we 

turn this out as a final product, it will 

hopefully be --

DR. NETON: I'd like to take a step backwards, 

though, and explore the -- the issue of using 

the Fernald data. I mean that -- that, to me, 
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was not a foregone conclusion. It was 

discussed in some detail, maybe a little detail 

at the Board meeting and -- and we indicated 

that -- I mean I think Arjun even supported the 

fact that we'd go down that path. Now that 

we've done that, I guess I'd just like to get 

the sense from the working group at least, does 

that seem to be a reasonable approach -- and in 

SC&A's opinion, as well -- that -- is this -- 

is this, you know, something that -- that this 

is reasonable? 

 MR. GRIFFON: (Off microphone) Arjun's got... 

 DR. MAKHIJANI: Yeah, this is Arjun. I think 

the Fernald K-65 data are a very good starting 

point. And then you've taken them in a -- one 

direction by doing radon breath data, but I 

think -- I think one of the really good things 

about this document that you sent us is the -- 

is the flow sheets. And it's clear that most 

of the radium goes away in the first step, so 

most of the radium winds up in -- in the K-65, 

and so the ratios of thorium to radium are 

lower in the K-65 than they are in the steps 

where most of the thorium was precipitated out 

-- or protactinium or actinium. So I -- I 
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think this problem that I was mentioning is 

actually going to be accentuated since you're 

using radon breath to determine radium and then 

applying the K-65 ratios to that. Whereas in 

other areas of the plant where you have the 

radium mostly gone, you would have bigger 

ratios of thorium, protactinium and actinium to 

radium. And there doesn't seem to be a good 

way to determine those ratios based on the K-65 

silos. There may be other measurements, and I 

haven't -- you know, there -- I know there are 

some other ratios in here, but I haven't had 

time to actually figure out whether -- you 

know, how they've been done and whether they 

are appropriately claimant-favorable or what 

data they're based on and so on. But I think 

it'll make a big difference. 

DR. MAURO: I'm sorry to interrupt -- this is 

John again. I do have a question, which is a 

simpler question which I wasn't quite sure of. 

As I understand it, the ra-- in order to 

determine the body burden of radium, sounds 

like the emphasis is going to be placed on the 

data that you have from the radon breath 

analysis. But at the same time, I look at this 
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table one and I see that you have this 400 to 

one ratio of uranium to radium -- or radium to 

uranium, and it seems to me that what we have 

here is two different strategies for coming up 

with what might be the radium intake -- 

DR. NETON: Right. 

DR. MAURO: -- that a person experienced. And 

I'm not quite sure which one you've decided on 

using and under what circumstances, and which 

one might be more limited. Could you help me 

out a little bit with that? 

DR. NETON: I think -- I think it depends on 

the individual case, but certainly if one takes 

-- well, in looking at the workers, we have 

come to the conclusion that very few workers 

inhaled pure residue material. So if one takes 

their uranium intake and multiplies it times 

400 to get the radium, that will give you a 

much higher intake of radium than we believe to 

be the case. And that's when -- I think I even 

mentioned at the Board meeting that we would 

use the radium -- radon breath to do some 

bounding, sort of sanity checks on doing so. 

Because one has to remember that this was a wet 

process, for the most part, going through. And 
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even when the residues were created, they were 

wet -- within the plants. So you know, the 

potential for airborne is -- is somewhat 

minimal. 

 We believe that -- and so if one takes the 

uranium intake, multiplies it times whatever 

number -- 400 -- you will start ending up 

getting intakes that exceed the air 

concentration data that we're seeing in the 

plant. And if you look at Table 29 in the site 

profile, you'll see anywhere from ten to the 

5th, ten to the 6th picocurie per year intakes. 

I think there's one or two incidences of ten to 

the 7th. If one comes up with an intake of 

uranium for a worker that is already ten to the 

6th, now you multiply that times 400, you end 

up with a couple order of magnitude higher than 

what would be supported by the actual air 

monitoring data. That's doable, and that -- 

that is a calculation that can be done to 

certainly bound the dose. 

DR. MAURO: That's very helpful. I did not 

understand that. 

DR. NETON: But we believe that the better 

approach is to use the radon, as I indicated at 
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the Board meeting, to -- to use that to bound 

the intakes because we believe -- and almost 

any way you look at the radon breath data, it's 

going to be biased high. There are problems 

with radon breath. There was variability. The 

radon background in the air adds to it. The 

time of day when you take it, the fact that 

workers were not off work for a long period of 

time and could have been breathing radon gas 

that would be indicating radium body burdens is 

going to -- all it's going to work is creating 

a slightly larger body burden than you may have 

otherwise. 

DR. MAURO: On -- on that matter -- 

 DR. WADE: Denise, use the microphone, please. 

MS. BROCK: Sorry, John. I just want to make 

sure I understand. If you're talking about the 

air, would you give the claimant the benefit of 

the doubt, would you count that all as uptake? 

Or... 

DR. NETON: I'm not sure what you're asking. 

If -- if --

MS. BROCK: When they exhale -- if I understand 

this correctly, when they exhale, you're 

counting up that there's possibly that in the 
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air, as well. Correct? So are you --

DR. NETON: That would actually add to the -- 

MS. BROCK: So you will not subtract that from 

them. Correct? You will go ahead and count 

that all as uptake. 

DR. NETON: Right, there's no way we would be 

able to subtract that. 

MS. BROCK: Okay. 

DR. NETON: So we would just assume that it was 

all -- all -- all related to radium -- 

MS. BROCK: Thanks. 

DR. NETON: -- acquisition within the body. 

The other thing is when -- Cindy -- Cindy 

mentioned this earlier, when you take the 

uranium intake calculations and then use the 

radon breath, you end up not too far off from 

what the air data are telling us anyways. I 

mean you'll -- you'll end up in the same ball 

park and it -- given the uncertainties of the 

data, it's not -- it's not that -- it's not 

that we're suggesting that these intakes are an 

order of magnitude lower than what the air data 

suggests. It's that the approach that we've 

proposed provides a more consistent indication. 

When one looks at the totality of the radon 
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breath, the uranium intakes and the air data, 

using the radon breath in combination with the 

uranium data in urine, gives you in the same 

ball park as what the air data is telling us. 

And that gives us some comfort that that -- 

that seems to make some sense. Applying these 

400 to one ratios tends to take you out of the 

realm of reasonableness. 

MS. BLOOM: Well, and the other thing that I 

would say on the 400 to one -- 

DR. NETON: Speak into the... 

MS. BLOOM: -- is that -- the other thing I 

would say on the 400 to one ratio is that if 

you're going to start with air data, you 

shouldn't be multiplying that times 400 -- 

DR. NETON: Right. 

MS. BLOOM: -- and calling it all radium. You 

should be going the other way, and so that's 

actually going to bring numbers down, I think. 

DR. NETON: Right, that would be my -- my 

proposal. We use the air data -- we would take 

the uranium data in urine and use that to 

estimate intake, and then assume that the 

entire air data were some fractionated values 

of the alpha in the -- in the radium stream. 
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But we -- we believe that -- that -- we believe 

that use the radium -- the radon breath data is 

-- is the more defensible scientific approach. 

 DR. MELIUS: Can we just go back one second to 

Arjun's original comment on the ratios 'cause I 

just want to make sure I understand your 

response. I think we sort of got off-track 

there. And you're saying that those -- you're 

going to adjust these now, and then -- that's 

all I've heard is you're going to -- there's 

some adjustment going to be made. This is just 

a --

MS. BLOOM: This is a --

 DR. MELIUS: -- preliminary (unintelligible). 

MS. BLOOM: Yeah, this is a -- this is a work 

in progress. I've collected a lot of different 

numbers on -- it sounds like -- I haven't heard 

anybody say that we should use the Silo One K65 numbers, but if that's -- those are the 

numbers we're going to use, then I'll put lots 

of significant digits on there, and this was 

just to make it easy to say if I multiply by 

two I can get 800 rather than 1.578 -- 

something, so it's for my convenience. 

 DR. MAKHIJANI: Yeah, I'm not focused on the 
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specific numbers of the K-65. Generally -- you 

know, I think if -- there is a -- and I haven't 

looked at the radon breath raw data so I'm not 

commenting on the quality of it and questions 

about the minimum detectable limit and so on, 

but for the moment just accepting the radon 

breath data, certainly we've looked at the 

method. And for the record, we would agree 

that the radon breath method is well 

established for estimating radium body burden. 

And we had two different SC&A experts examine 

this question. They both agreed on this 

question, the question of the validity of the 

data, the detection limits and so on. 

My question isn't about -- isn't about the -- 

the actual numbers of nanocuries per gram in 

the K-65 silos. My question is how are you 

going to come up with the thorium 230, 

protactinium 231 and actinium 227 numbers? And 

since those arise out of your radium 

measurement and you're applying a fixed ratio 

derived from the K-65 silos, you're saying I -- 

I know the radium burden in the body because I 

can measure it. Just consider one worker for 

whom you have bioassay data and radon breath 
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data, and you've got all good data. And then 

you're saying you're going to apply the ratios 

from the K-65 silos. Thorium is eight times 

less and actinium is 80 times less. And so my 

first point is it makes a big difference 

whether you say thorium is eight times less or 

6.5 times less because it makes a big 

difference to the dose. So being precise about 

that number is very important -- about that 

ratio, not the actual value. So I wasn't 

taking issue with the specific -- 

MS. BLOOM: (Off microphone) No 

(unintelligible). 

 DR. MAKHIJANI: -- numbers, just the ratios. 

The second point, which I think is 

methodologically more complicated, is that once 

you leave the first step in the Plant 6 

processing of the uranium, you wind up in 

places where the relative amount of radium is 

much lower and the relative amount of thorium, 

actinium and protactinium is much higher. So 

for -- for instance, in the residues coming out 

of the sodium carbonate bicarbonate process, in 

the AJ-4, AM-7, in all of those areas, I think 

there is a big problem in applying the K-65 
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ratios because there the relative amount of 

thorium is much bigger and it will make a 

tremendous difference in the dose because the 

dose conversion factors for thorium are so much 

bigger than radium. 

Rad-- I did some back-of-the-envelope 

calculations, just applying the -- just taking 

455 by -- just as a back-of-the-envelope thing 

-- to calculate percentages. And radium and 

uranium make almost no contribution to the 

total dose. The contri-- 95 -- if you omit 

lead and polonium and just take those four -- 

or even if you include them, lead and polonium 

make 10 percent -- uranium -- uranium and 

radium make less than a couple of percent, and 

the rest of it is all -- those three 

radionuclides. So my -- where I am, 

tentatively at least, from -- from a very 

tentative evaluation, is this whole method has 

to be geared to ensuring that the values you 

come up with ultimately for thorium, actinium 

and protactinium have to be the maximum 

plausible values, not the values for uranium 

and radium. 

DR. NETON: I think we -- we totally agree with 
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that, and -- and I think -- we've stated in 

here that we believe that the -- applying the 

K-65 ratios -- because it's not that there's 

zero thorium or zero protactinium or zero all 

the other daughters in the K-65; there are -- 

and I think we've looked at the airport cake 

material. I think Cindy's looked at some of 

the thorium contents of the airport cake, which 

by far and away is the largest amount of 

material. I mean there's 20 -- 25-foot high 3-

acre piles out there at the St. Louis Airport 

site, so this -- this is the biggest potential 

source of exposure. And if we look at that and 

we know that the thorium 230 is in the airport 

cake, which is the largest potential source of 

intake, and we -- we can demonstrate that 

applying the K-65 doses are bounding compared 

to -- admittedly, there's more thorium there, 

but I think, Arjun, in some cases you're maybe 

not totally correct. I think you'll -- you'll 

-- I was surprised to see when Joe discusses 

these things, polonium 210 is a very 

significant contributor to the internal doses 

to some of these people. 

 DR. MAKHIJANI: (Off microphone) I just 
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(unintelligible). 

DR. NETON: Well, right -- I mean but you've 

got to be careful when you generalize across 

the board, but -- and when you use 50-year 

doses versus annual doses because thorium's got 

a short half-life, there's other -- there's 

other considerations. But I think it would be 

our intent to demonstrate that even under those 

circumstances the K-65 residue dose conversion 

factors will bound the doses to people working 

with airport case and possibly even Sperry 

cake. Those are the only other sources you've 

got out there is the barium sulfate cakes. 

Those are smaller residue streams by far 

compared to the airport cake and the K-65. 

So... 

 DR. MAKHIJANI: I don't think I -- I'm not sure 

that I got a response to the question I asked, 

which is -- and -- and I just want to be clear 

in -- in that I -- I don't think -- okay, let 

me make a statement and try to get a response, 

agreement, rebuttal, something. Is I don't 

think that the K-65 ratios for thorium to 

radium -- because we've gone away now from the 

ratios to uranium, which is the bioassay data, 
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and we're fixing everything on the ratios of 

thorium to the radon breath data. So now 

instead of bioassay data being the central 

anchor for dose reconstruction, you've got the 

radon breath data, which is available only for 

20 percent of the workers, as being the central 

anchor for dose reconstruction because you -- 

you've constructed the amounts of thorium, 

actinium and protactinium out of the radon 

breath data and not from the bioassay data 

anymore. And -- at least as I read it. 

Therefore, those ratios are extremely critical. 

And as I read these flow sheets, the ratios in 

the areas where you've got these AJ-4s, Sperry 

cake, AM-7 of thorium and perhaps protactinium, 

actinium in different parts are going to be 

bigger than they are for the -- you should 

expect them to be bigger because most of the 

radium is gone in the first part of the process 

-- or almost all of it is gone. 

So my question is, for those sets of workers 

where you know that their intake of thorium 

relative to radium is bigger -- is actually may 

be bigger than one to one -- how are you going 

to determine those ratios 'cause I don't think 
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the K-65 ratios are -- are reasonable or 

claimant-favorable? I'm just making that as a 

statement to --

MS. BLOOM: No --

 DR. MAKHIJANI: -- get a response --

MS. BLOOM: -- and I --

 DR. MAKHIJANI: -- and not a conclusion. 

MS. BLOOM: -- and I think we agree with what 

you're saying. I was just looking at some 

numbers now. I do have uranium and thorium 

ratios in the AM-7, and certainly we could go 

back to the uranium data and apply those 

fractions to the uranium data. I think that 

would be a reasonable way to go. I need to 

look at it a little bit more. 

Like one concern I have, I think the SEC 

question is can we bound it easily. The dose 

reconstruction question is then does the answer 

make sense or can we get a better answer. And 

I think we can use the ratios in the AM-7 to 

bound it. I think, based on what we were 

seeing from the uranium to radium ratios, I 

think that we can get a better number on the 

thorium to uranium ratios by considering that 

the fact that you've got a uranium background 
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in all these areas and so those ratios really 

aren't that high. 

We've also taken it a little bit farther since 

we've written this up and looked at -- we had a 

small set of thorium bioassay data and we 

looked at that for the Plant 7E workers. They 

also had some uranium data, so we've sort of 

looked at that comparison, as well. And 

there's some arguments to be made there to -- 

to come up with those numbers. I don't think 

we've finalized that yet except to say that I 

think the SEC question is answered. We can 

come up with a big number. You know, we can 

come up with our --

 MR. GRIFFON: Well, we -- we have no doubts 

about that, but I -- I think item (c) in one is 

where we're -- I mean that's one question we 

had in mind before was -- 

DR. NETON: Right. 

 MR. GRIFFON: -- are there going to be -- and 

this is what Arjun's getting at, are there 

going to be job-specific ratios or -- or areaspecific ratios. And -- and it seems like -- I 

mean I -- I think the Silo One data is probably 

bounding in man-- in most circumstances. Now 
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if you have -- are there other areas where this 

-- this actinium, protactinium and thorium 

concentrates more and would there likely be 

workers that were dedicated to those areas, I 

don't know those answers, you know, if you -- 

DR. NETON: No, I understand that. But I think 

 MR. GRIFFON: And also, you know, you -- you're 

-- when you have the Silo One waste, it -- it 

is -- we're all talking about this is a 

bounding sort of concentration and ratios that 

we're establishing from that, but -- but it is 

all the waste coming together, I guess, so 

you're -- it's sort of an average, you're 

blending it. Right. It might be a higher 

average. 

DR. NETON: I think it's higher --

 MR. GRIFFON: Right, right. 

DR. NETON: -- K-65 material, which was not all 

the material that was processed. We're 

assuming that these workers were inhaling K-65 

ratios the entire work time not, you know, when 

there were lower amounts of radium. We're not 

accounting for that at all. 

 DR. WADE: Denise had a comment or question. 
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 MR. GRIFFON: Right, yeah, Denise. 

MS. BROCK: My question -- I actually have two, 

and then maybe I'll ask them both and you can 

answer them separately. Number one, I was just 

curious, if the K-65 residue that's in Silo One 

at Fernald, does that ratio or chemical makeup, does that change after all of those years? 

I -- I'm not sure. I have no idea. That was a 

question I had. 

And the other question I had is to Cindy and I 

-- I partially remember this. I was on the 

telephone call we had previously, and I'm not 

sure where this fits in at, but did I hear you 

correctly when you said it's 120th of the -- 

was it the dose or the -- it lowers their dose, 

is that -- do you know what I'm talking about? 

MS. BLOOM: (Off microphone) Not yet. 

 MR. GRIFFON: Factor of 20 lower I think you -- 

MS. BROCK: Is that what it was? 

 MR. GRIFFON: -- said, based on the radium 

from the breath data. It might affect the 

overall doses by a factor of 20 -- 

MS. BROCK: That's it. 

 MR. GRIFFON: -- was the statement --

MS. BLOOM: Rather than --
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 MR. GRIFFON: -- (unintelligible) recall. 

MS. BLOOM: -- directly using the K-65. 

 MR. GRIFFON: I think so, right. 

MS. BLOOM: Right, right. 

 MR. GRIFFON: I think that was your statement. 

MS. BROCK: So does that lower their dose? 

MS. BLOOM: If -- if you look at using the K-65 

ratios themselves versus the uraniu-- the 

radium -- the -- the radium intake to the 

uranium intake, and this was for an unmonitored 

worker who -- our sense right now is that an 

unmonitored worker is likely to be a less 

exposed worker, and I know that's, you know, 

over -- over -- you know, we're applying these 

numbers for the whole work period. I don't say 

that there's not unmonitored workers here and 

there. I think there are. I've worked in 

health physics long enough not to be that 

naive, but I think -- overall I think we're 

applying these numbers very generously, and it 

will -- if you use the radon breath data, the 

numbers will be lowered if -- if you start from 

the air data and multiply by 400 -- or the 

uranium data and multiply by 400, yes, that 

will be --
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MS. BROCK: So it won't be as claimant friendly 

to do it that way. 

MS. BLOOM: But it's not supportable when you 

look at the rest of the data. 

 MR. GRIFFON: I think that's what they're 

saying is this is now a better estimate -- 

MS. BROCK: This is better. 

 MR. GRIFFON: -- in their view, right --

MS. BROCK: Okay. 

 MR. GRIFFON: -- and the other one was -- was 

reaching over reali--

DR. NETON: (Off microphone) Over 

(unintelligible) bounding -- 

 MR. GRIFFON: -- right, it was --

DR. NETON: It was borderline --

 MR. GRIFFON: At least that's the position -- 

DR. NETON: -- reasonable. 

 MR. GRIFFON: -- that's the position they're 

taking on it, yeah. 

MS. BROCK: And does the silo -- does the K-65 

-- does that make-up change at all? 

 MR. GRIFFON: (Off microphone) (Unintelligible) 

second question. 

DR. NETON: Well, that second question is -- 

that's what -- we need to talk about that, but 
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I think, you know, there's -- there's evidence 

that this material was stored in drums over 

time. It was placed in drums and it was put 

inside a concrete silo. It was not subject, at 

least totally, to leeching of -- of rainfall 

and that sort of thing, so I think we have some 

confidence that these ratios are not -- not 

significantly different than the original 

ratios that were, you know, present at the time 

the material was made. 

 The concentrations will certainly be different. 

They've been diluted with different types of 

material, bentonite clay and that sort of 

thing, but -- but the ratios themselves, I 

don't believe there's any good reason to 

believe they're substantially different. 

MR. GUIDO: Yeah, I had a comment. From a dose 

reconstruction perspective, one thing to keep 

in mind -- reality in doing this and I really 

understand what you're -- where you're coming 

from when you say how do you -- how do you know 

that Worker A, you know, where they were in the 

plant in all time, and -- and looking at a lot 

of other site cases and specifically a lot of 

Mallinckrodt cases and a lot of data, I agree, 
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it's very difficult to place a worker. 

A lot -- there's a lot of data within the files 

which is even inconsistent with each other, 

like you -- you know, where -- you don't 

whether the person was bouncing back and forth 

between areas or whether they changed 

assignments. So in the reality of doing the 

dose reconstruction, the way it has to be 

applied is you have to come up with a bounding 

scenario and apply it. And that ends up being 

claimant-favorable for a couple of different 

reasons. 

One, because you're picking a bounding scenario 

to give them, and another because you don't 

generally turn off the intakes when they really 

maybe should have. And in an example we'll 

maybe get to later if we look at one of the 

cases I did, you know, you might have an 

individual who has radon breath data for the 

first two or three years of their career, and 

then for the last two of three year-- you know, 

that -- that data goes away, they never get any 

more monitoring for radon breath, but they 

might pick up like thorium monitoring. 

 Well, some sense would say well, that worker 
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probably changed locations. But in doing the 

dose reconstruction, in the methods we use to 

be claimant-favorable, what we would do is they 

would get the intake from that radon stream for 

the entire work period, and then it'd also pick 

up the other intake from the thorium and you 

wouldn't turn off the radium 'cause you really 

don't have data to say that it really ended. 

So you know, I know it's important to 

understand where people worked and what the 

ratios are in different areas, but -- to build 

the ratio set to understand what's bounding. 

But when you actually do the dose 

reconstruction, you -- that data is not as 

important. You know what I mean? It's -- it's 

more important to make sure you have the 

bounding set, because we'll never know where 

all these folks worked at all times. All we'll 

know is the possible datasets and then we can 

assure that we're being bounding, we're being 

claimant-favorable. 

 MR. GRIFFON: Yeah, and -- and we -- and we --

and that's -- and we can see why you would want 

to go with radon breath data for that reason, 

you know --
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DR. NETON: (Off microphone) Cindy 

(unintelligible). 

 MR. GRIFFON: -- instead of air sampling area 

data or -- yeah. 

DR. NETON: Cindy, you said you have the data 

for the airport cake for thorium 230. Do you 

have that handy? I'm just curious about the 

disparity between the two. 

MS. BLOOM: I do have some -- I do have some 

numbers. I was just looking up my calculations 

and my numbers in my comparison spreadsheet are 

in the wrong rows right now so I need to adjust 

those, but I can give you those this afternoon. 

DR. NETON: You don't have a number for the 

concentration of thorium 230 in the airport 

cake handy right now then? 

MS. BLOOM: I do in odd units. 

DR. NETON: Okay. Well, we -- we --

 MR. GRIFFON: I guess -- I guess -- 

DR. NETON: -- can probably talk about that 

later. 

 MR. GRIFFON: Yeah. 

MS. BLOOM: (Unintelligible) per meter or parts 

per million, which would you like? 

DR. NETON: I'd like picocuries per gram, but -
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MS. BLOOM: Yeah, that's what I thought. Then 

give me a minute. 

DR. NETON: That's what I -- I think -- I think 

we can -- we can --

 MR. GRIFFON: Yeah, I guess -- I guess --

DR. NETON: -- talk about that --

 MR. GRIFFON: -- I guess there's general 

agreement here that -- that applying the 

fractions if -- if -- if we can get to that 

point where we're happy with the bounding -- 

DR. NETON: Right, and then we can get to the 

(unintelligible) --

 MR. GRIFFON: -- that -- that -- that approach 

is reasonable, I think. 

DR. NETON: Right. See, now I --

 MR. GRIFFON: But the -- the -- I said the 

general position is that if we can establish 

these fractions and agree that they're 

maximizing or bounding -- 

DR. NETON: Right. 

 MR. GRIFFON: -- then the approach to use them 

is -- is reasonable, you know. 

 DR. MAKHIJANI: Yeah, I'd just like to be clear 

what "these fractions" mean, because I think in 
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most situations we're going to find that -- 

it's just my hunch from back-of-the-envelope 

calculations that the thorium, actinium and 

protactinium are going to be important. And my 

concern simply is that those are the 

radionuclides for which there is the least 

information. There are no direct measurements, 

there are no air concentration data, there are 

no bioassay data and there are no radon breath 

equivalent data, so they're all derivative 

numbers. And how -- I think -- 

 MR. GRIFFON: Even in -- even in the -- 

 DR. MAKHIJANI: -- there has to be some 

assessment on how good those values are and how 

confident we are that they'll be maximum 

plausible because --

 MR. GRIFFON: Right. 

 DR. MAKHIJANI: -- I -- I don't -- I haven't 

seen something that allows me to say that we 

know that to be confident as yet. 

DR. MAURO: John Mauro. I'd like to just add 

one point. Joe Guido's point that you just 

made was exactly the question I asked much 

earlier about the creation of these boxes and 

the boundaries for real people. And the fact 
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that your plan is to give the benefit of the 

doubt where the person was and to carry over 

the -- let's say the continuation of exposure 

on that basis resolves that concern that I 

raised much earlier today. Thank you. 

 MR. GRIFFON: All right, I think we -- are we 

on to 1(b)? Moving right along. 

DR. NETON: I think -- yeah, I think we're -- 

we can -- we can resolve this issue with the 

amount of thorium 230. I --

 MR. GRIFFON: Oh, yeah. 

DR. NETON: -- I thought we'd looked -- we have 

looked at the airport cake and we know the 

amount of protactinium that was in the -- in 

the Sperry cake that we shipped to Fernald -- 

or shipped to Mound, so I think between those 

two we're able to get some consensus maybe as 

to what the bracketing values should be for the 

thorium 230 and --

 MR. GRIFFON: Okay. 

DR. NETON: -- I think that's good. Okay, 1(b) 

 MR. GRIFFON: Actually I think 1(c), yeah. 

DR. NETON: -- 1(c) --

 MR. GRIFFON: 1(c). 
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DR. NETON: I think we've talked about that a 

little bit. We feel that it's going to be very 

difficult, as Joe just indicated, to apportion 

these to individuals every single step of the 

way. I mean it's -- it's just a practical 

limitation on -- on doing so and -- in fact we 

don't have that for everybody, so our -- our 

approach is that if we could come up with this 

bounding calculation, these -- these ratios, 

and if we could use the radon breath data, that 

we would assume that most categories of workers 

that at least worked in Plant 6 -- so we're 

talking about operators, building trades, all 

those types of categories -- we would assume 

that they were exposed to this bounding value 

of -- of the residue material, the raffinate 

material (unintelligible). 

 MR. GRIFFON: When you bounding value of raf-- 

can you point me to... 

DR. NETON: Okay, well, let me -- let me -- 

 MR. GRIFFON: Okay. 

DR. NETON: Okay. The approach would be you 

take the urine data, if it's available, and 

come up with the uranium intake. Now that's --

that's a given. Now you've -- you determine 
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what the uranium intake is. Now if you have 

radon breath, you do the radium intake and 

you've got radium intake, and then we can apply 

whatever ratios we decide is appropriate. 

 MR. GRIFFON: And in the absence of radon 

breath, you use --

DR. NETON: In the absence of radon breath we 

would propose to use the 95th percentile of the 

radon breath intakes that were calculated from 

the 2,500 samples. And likewise, in the 

absence of any uranium bioassay we would use 

the 95th percentile of the uranium intakes for 

that population of workers. So you've got a 

situation -- now that would be for workers who 

were potentially exposed working with raffinate 

just like anybody else, a chemical operator, 

building trades or someone of that nature. 

If you have a worker who did not work in Plant 

6 but could have frequented it doing certain 

jobs, we propose that we would use the 

distribution, the -- the distribution of values 

for radon breath and uranium bioassay and apply 

that to those --

 MR. GRIFFON: The full distribution, you're 

saying --
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DR. NETON: The full distribution rather than 

picking the 95th percentile. So I think if we 

can come up with this -- these fractions, these 

activity fractions, I think we've got an 

approach here that is workable for -- 

 MR. GRIFFON: And do --

DR. NETON: -- almost anyone in Plant 6, and in 

Plant Y, for that matter. If someone -- if we 

can demonstrate someone only worked in Plant 4, 

which may or may not be possible, we would not 

apply that ratio. 

 MR. GRIFFON: And -- and just to be clear, the 

use of the air sampling data now would be to -- 

as a reality check, as a --

DR. NETON: Yes, that's exactly right. It 

would be -- it would be used to make sure that 

we're in the right ball park here. And I think 

in our preliminary calculations that's the 

case. 

 MR. GRIFFON: And that your overall -- like you 

were saying earlier, that your overall alpha 

intake doesn't exceed the plausible with the 

highest air samples in --

DR. NETON: And actually I think it would be -- 

 MR. GRIFFON: -- in the plant or... 
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DR. NETON: -- it could exceed it. We're not 

saying that the air sample data are the 

ultimate --

 MR. GRIFFON: Right. 

DR. NETON: -- cap, but are they in the right 

ball park. 

 MR. GRIFFON: In the right ball park, okay. 

DR. NETON: And if you're three or four orders 

of magnitude higher with your intakes, you 

might want to wonder. But then as we -- as has 

been pointed out in the past, the air samples 

are not perfect, either. They might not have 

been job (unintelligible) -- 

 MR. GRIFFON: So there's no situation where you 

see those being used for dose reconstruction. 

DR. NETON: At this point I think we would 

prefer to stick with the bioassay monitoring 

data as our -- our approach and use the air 

sample data as -- as --

 MR. GRIFFON: Reality (unintelligible). 

DR. NETON: -- reality checks on what we're 

doing. 

MS. BLOOM: It also might give you an indicator 

of what was happening over time, you know, and 

-- and how to help fit data and things like 
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that. 

DR. NETON: It's amazing how these all kind of 

come --

MS. BLOOM: On a case by case basis, it could 

be... 

DR. NETON: In the first few dose 

reconstructions Joe's done I was very pleased 

to see that the -- the estimates -- and we 

didn't presume this, you know -- came out 

fairly close to what the air data -- the air 

data are showing. Of course within an order of 

magnitude -- ten to the 5th, ten to the 6th 

picocuries per year -- but very similar to what 

I showed at the last Board meeting where I had 

these 95th percentile bounds on the intakes and 

the air data kind of -- kind of fit that in 

there. 

Okay. So I think --

 MR. GRIFFON: Any -- any questions on that one 

anybody have? 

 (No responses) 

I think we can go to 1(d), yeah. 

DR. NETON: And I think 1(d) we've also 

actually covered that. I mean the approach for 

when -- combination of urine sampling and 
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breath data, we would use urine and breath, as 

available, to do intakes. We would use the -- 

what we call coworker data, which is really the 

worker distribution data that we have for urine 

and breath, and pick the 95th percentile for 

exposed workers and the full distribution for 

what we believe to be lesser exposed workers. 

 MR. GRIFFON: I think the second part of (d) -- 

I mean we didn't really discuss too much -- 

DR. NETON: Okay, reliability of radon breath 

data, we could talk about that somewhat. I --

I'm encouraged that SC&A does agree that -- 

that radon breath is an appropriate technique. 

It was in fact the -- the intake estimates that 

were used to establish the body burdens for the 

radium dial painters, which everyone knows is a 

fairly famous historical exposure cohort from 

the early 1900s. The radon breath data we've 

looked at. We actually have very similar data 

to what we had for the urine analysis. In fact 

we have the HASL analytical data sheets. 

There's four -- I would not -- don't quote me 

on this number, but I think there's about 487 

individual pages of radon breath measurements 

that were reported by HASL to Mallinckrodt. 
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These data sheets contain -- they're not full, 

but again, they're like 14-line data sheets, so 

they're -- somewhat less than half of each of 

them are full, so there's a large number of 

radon breath measurements that were taken. 

We wanted to make sure that the CER database 

was actually reflective of what as in there. 

We looked at a few workers. We didn't do as 

extensive review as we did with the urine, but 

we took one worker and were able to track his 

radon breath data back to his original HASL 

data sheets. They matched. I think there was 

one date that was transposed -- you know, the 

date was read wrong; it was 4 instead of a 9, 

but in general those appear to be faithfully 

reproduced in the CER database. 

These values are listed as percent of 

tolerance. The percent of tolerance was one 

picocurie per liter radon in breath at that 

time. That was I think construed to be equal 

to what would be a body burden of radium during 

that time frame. 

The detection limit value is pretty clear from 

the HASL reports that they reported nothing -- 

well, almost exclusively nothing less than .1 
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picocurie per liter. There are some samples 

that are listed as .006 picocurie per liter 

less than values. We're not quite sure what to 

make of that. It's a very small fraction -- I 

can't give you the number, but very small 

number of them. If you read the original 

reports, HASL -- .1 picocuries per liter is -- 

is a fairly well-established detection limit. 

In fact, this technique is still -- I have a 

1992 version of the HASL analytical procedures 

manual. This exact same technique is still in 

there. 

John has a question. 

DR. MAURO: Yes, I -- I looked at the protocol 

and some of the literature behind it. In fact 

there was the -- I think it was the Russian 

literature -- started with an S, long name -- 

DR. NETON: Uh-huh, (unintelligible), yeah, I 

won't pronounce it, either, but -- 

DR. MAURO: You know the one. 

DR. NETON: -- I know what it is. 

DR. MAURO: Now I noticed in his analysis he 

used -- the person would breath oxy-- breath 

oxygen beforehand --

DR. NETON: Right. 
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DR. MAURO: -- and there was a very 

sophisticated protocol to make sure that you 

had control over background -- 

DR. NETON: Correct. 

DR. MAURO: -- so that you could get a 

realistic measurement. Now in our situation 

here, that wasn't done, as I understand it. 

DR. NETON: In the early time frames that was 

not done. 

MS. BLOOM: Later on they did --

DR. MAURO: Later on. 

DR. NETON: After '51, '52 time frame they 

adopted the HASL procedure -- 

DR. MAURO: Okay. 

DR. NETON: -- with John Harley's 1951 article 

in the Archives of Industrial Hygiene published 

-- I've got a copy of it here -- it goes 

through that -- that procedure. 

DR. MAURO: Then my question goes to the 

earlier years. In that scenario where you're 

dealing with an individual where you're using 

the radon breath data before they were using 

the oxygen approach, and therefore you could 

theoretically have a background level that 

could be substantial. It doesn't take very -- 
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you know, in this room is probably about one 

picocurie per liter right now. Now, when you 

do that, if in fact you've used the radon 

breath data without subtracting background in 

the early years, you may very well come up with 

some very aberrant results. Under those 

circumstances, what's your fall-back position 

in terms of coming to grips with what the body 

burden of radium is when you really suspect 

that because -- because of the background 

complication? 

DR. NETON: We -- we really have no way of 

correcting for that and we would assume that 

this was equal to the radium body burden. If -

- if you look at it over time, it did go down. 

But of course there's a reason for that. In 

the -- in the '40 -- late '48, 1949 time frame 

this is when they had the campaign to reprocess 

the -- the K-65 material from SLAPS, so they 

ran through all of the -- or most of the 

radium-bearing K-65 material through the entire 

digester process. So there's a reason that 

those body burdens could be higher, but I -- I 

don't think that we would correct those. We 

would use them at face values. 
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There are other issues besides just the radon 

breath, and we can talk about that a little 

bit. The background in air -- there are also 

these people that worked in the plants. As 

we'll see later, there are very large 

concentrations of radon in the plant, well 

beyond -- all above a picocurie per liter. I 

myself have measured the half-life of radon gas 

in the body and it's about 24 hours. They did 

adopt a protocol where the workers came in on 

Monday morning after being away from the plant 

for 48 hours, recognizing they wanted to 

ventilate the natural deposition of radon in 

their bodies. Unfortunately though, they took 

some of these measurements early on in -- in 

rooms that had air that had higher than what 

you'd expect, and so some of that is 

contributing to the background. 

But as I mentioned earlier, most of these 

uncertainties do -- as you mentioned, do bias 

the values in a positive direction, not a 

negative direction. 

 MR. GRIFFON: (Off microphone) Larry's got a 

comment. 

 (Whereupon, the microphone available to Mr. 
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Elliott was not functioning and his remarks 

were not captured by the reporter.) 

DR. NETON: Right, yes. I'm not -- yeah -- 

well, we've never done that in any dose 

reconstruction so we take that at face value. 

But the other issue is there is a -- radon 

breath tends to be higher after eating a meal, 

what they call the postprandial effect, and it 

can be a factor of two higher. So if someone 

had breakfast and came in, it could be -- all 

of these things, again, add to the elevation of 

the data and not -- not negative biases, so -- 

but we believe it's a fairly reasonable bound. 

 MR. GRIFFON: Go ahead, Arjun. 

 DR. MAKHIJANI: Yeah. I'm sorry to sound like 

a broken record a little bit about this, but I 

do feel it's important. And I'm just trying to 

understand how these coworker radon breath data 

are really going to be used. We -- we've got 

radon data for 20 percent of the workers -- 

about. So for most of the production workers 

you're going to wind up using coworker data. 

Right? 

DR. NETON: (Off microphone) (Unintelligible) 

 DR. MAKHIJANI: Yeah, I'm not -- I'm not saying 
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that the approach that you outlined is not 

claimant-favorable, I'm just trying to 

understand the approach since this is the last 

full conversation we'll have about this. Then 

-- then you apply these ratios -- use the 

coworker data from radon breath and apply these 

ratios. Now if the assumption is that the 

radon breath was applied to people who were 

vulnerable to radium exposure, which would mean 

those who were working with the ore, 

pitchblende; those who were working with K-65 

material and barium sulfate residues. I mean 

those are the ones who I identify as the ones 

most vulnerable to radium exposure. Then it 

seems -- it seems to me that actually applying 

the co-- the coworker approach seems to be 

questionable for workers who were working with 

other residue because these ratios are not 

going to apply because you don't have -- if you 

don't have radon breath data for most of the 

workers, many of those workers are going to be 

in areas where you're handling these AM-7s, AJ4s and these various other residues. You don't 

have radium measurements for them and we have 

sort of an idea what the ratios were, but 
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you're going to apply -- I'm (off microphone) 

(unintelligible) difficulties how these numbers 

are going to be validated (unintelligible) 

those numbers. 

DR. NETON: Right. I understand what you're 

saying, Arjun. I think -- I think the way to 

look at this is if you have a radon -- a K-65 

material intake and you come up with some dose 

per unit intake of that material. Okay? Let's 

just make a number. Say it's 300 millirem per 

milligram intake. I don't know what it is, but 

let's just say it's that, and it's based on 

these K-65 ratios. And then we can do some 

other calculation on these other residues and 

demonstrate that this intake calculation, 

however we -- we contrive this ratio -- I mean 

construct this ratios are higher than the unit 

intake per milligram of the other materials, 

then it's -- it seems to me that you would -- 

you've given these people an adequate intake. 

You know, you would have to assume that they 

would be inhaling -- you're assuming that 

they're inhaling this full-time, on a chronic 

basis, and if the dose per unit intake that we 

construct is bounding, even for these other 
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residues, I think that we've adequately given 

these people a representative dose. But then 

it gets down to how much material can you 

inhale. Does that help? 

MR. GUIDO: I have a comment, but if you're 

satisfied I won't say anything. 

 DR. MAKHIJANI: Well, I -- I'm -- I'm puzzled, 

because I -- you know, actually we -- maybe 

this will be answered when you put your dose 

reconstructions on the table and I don't want 

to hold this up, but I -- I -- I am -- I remain 

puzzled as to how this (unintelligible) -- 

MR. GUIDO: So I'll comment. One thing we have 

to look at, and this doesn't really answer the 

question, but in looking at this approach the 

one thing you have to look at is if you start 

with a higher radium number intake and you use 

lower ratios, you might get more dose than if 

you -- in fact, in other words, we're -- we're 

going to assume that everyone was exposed to 

the stream that had -- that had much more 

radium in it. Well, the ratios -- the radium 

to thorium ratios might be a little lower for 

that stream, but the net effect as far as 

actinium, protactinium and thorium values might 
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end up being more bounding. And proof of this 

is going to be in the calculations, and we all 

realize this. But I think conceptually it's 

very possible, and we believe it to be true, 

that you can start with higher radium/lower 

ratios as opposed to lower radium with high 

ratios and your answer might still be in the 

same --

DR. NETON: 

place. 

MR. GUIDO: 

(Off microphone) Come out the same 

-- so that -- that's what -- that's 

what we have to prove, I -- I guess. 

 DR. MAKHIJANI: Now -- now I think you've 

actually clarified something and made my 

question bigger, because -- because this -- 

because the difference in the dose conversion 

factors is so large, I think -- I think unless 

you can actually validate these numbers in some 

way, this qualitative idea that you can have a 

higher radium and lower ratios -- because at 

least by my back-of-the-envelope, which I'm not 

going to stand by these numbers. My back-ofthe-envelope numbers show that that -- those -- 

the result is extremely sensitive to those 

ratios and not to the radium concentration. 
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You can take -- you can throw away the radium 

dose if you get the ratios right -- as an 

extreme statement. Admittedly extreme 

statement in the example that I did. The --

the -- and so if you have streams where the 

ratio of thorium to radium is two to one 

instead of one to eight or one to six, I think 

-- I think that this -- what you've said will -

- will be very far from being claimant 

favorable. And you have to be able to 

demonstrate that you know these ratios, not 

just of thorium to uranium then. You have --

if you're going to use -- the thing that 

concerns me -- let me step back. 

 The thing that concerns me is you have bioassay 

data for most of the workers. I think we 

settled the bioassay data quality and so on 

issues, whether they were fabricated, to a 

large extent last time. They're not 

fabricated. They're a set of data that -- that 

-- that would give you an indication of 

uranium. You have them for most workers. Now 

we've moving away from that for the most 

important radionuclide. We have radon breath 

data, 20 percent of the workers, and that is 
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going to become the source of the values of 

radionuclides for the most important components 

of the dose, not the bioassay data which is a 

more complete set of data that you have for 

individuals. And I -- I -- I'm -- I remain to 

be convinced that this is -- this is a sound 

approach. 

DR. NETON: Well, I guess we just need to show 

you the numbers. I mean that's --

 MR. GRIFFON: Denise --

DR. NETON: -- (unintelligible) -- 

 MR. GRIFFON: Denise has a comment. 

MS. BROCK: I'm confused myself with some of 

this and I'd like to ask a question. I have a 

-- a document in front of me, it's very hard to 

read, and I don't know if this has anything to 

do with that, but I'm just going to read part 

of it and then maybe you can explain to me if 

it has anything to do with what Arjun or what 

you all are talking about. 

It states (reading) It is apparent from these 

data that a considerable group of employees 

from Plant 6 are exposed to hazardous 

concentrations of dust. In Plant number 6 18 

employees are exposed to between 375 and 660 
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times the preferred level. 

And down further it -- this is so hard to read 

-- (reading) Employees exposed to 660 times the 

preferred daily alpha level inhale in 19 days 

the amount of alpha dust which would ordinarily 

be inhaled in the full working span of 35 

years. 

So my thought as to coworker data -- and this -

- I may be way out in left field with this, but 

if hypothetically you're one of these workers 

and there isn't maybe breath radon or something 

on you and you use a coworker, wouldn't this 

person be a lot more exposed than just the 

typical person? And are they not going to get 

a full amount of -- of what they -- they should 

be in their dose? Or is this way off in 

another... 

DR. NETON: Well, I think that speaks to us 

using the 95th percentile of the distribution 

and assuming that they were in the most heavily 

exposed population. That's what we would do. 

 MR. GRIFFON: Okay. I was -- I'm still on 1(d) 

DR. NETON: Okay. 

 MR. GRIFFON: -- and I've got -- I've got about 
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-- I've got a bunch of questions on that. I 

wondered if we wanted to break for lunch at 

some point or -- have I got one vote for lunch? 

Why don't -- if it's okay with everybody, why 

don't we break for lunch now and come back -- 

 DR. WADE: I'd like to say one thing before 

lunch if I might. I mean early on Denise asked 

a number of questions that had more of a policy 

sense as to where does the SEC process sit 

relative to the site profile process. Those 

questions have not been lost on us, Denise. 

think we're here today to talk about the -- the 

technical issues surrounding the site profile 

review. How that relates to the SEC process is 

something that certainly the Board will need to 

discuss more completely, so your questions have 

been heard. 

 MR. GRIFFON: All right. I guess we'll 

reconvene at 1:00. 

 (Whereupon, a recess was taken.) 

 DR. WADE: We've spoken during lunch to some of 

the members who are trying to participate by 

telephone and they say that you all need to 

shout, as I am shouting now, and be close to 

the microphone. And again, we value their 

I 
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participation and to maximize it, we need to do 

this. 

I would also ask those on the phone, if anyone 

starts to speak that gives you trouble, speak 

up and we'll reprimand the person forthwith and 

we'll have them speak louder. 

We will be talking about today some of the 

example dose calculations, and those are here 

in hard copy. Mike Gibson, I don't know if you 

would like us to try and FAX that material to 

you -- are you on, Mike? 

 (No responses) 

 Is anybody on? 

 (No responses) 

Well, my little speech didn't work. LaShawn, 

could we... 

 MR. GRIFFON: Speak louder. 

 DR. WADE: No, I don't think there's anybody 

on. 

 MR. GRIFFON: (Off microphone) I think we've 

got --

UNIDENTIFIED: We've exhausted 

(unintelligible). 

 DR. WADE: Not all of them. I can think of a 

couple who would -- who will be here. 
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 DR. MELIUS: We have a few that will outlast 

all of us. 

 DR. WADE: No doubt about that. 

 MR. GRIFFON: (Off microphone) (Unintelligible) 

minutes (unintelligible)? 

 DR. WADE: No, I think we should -- we'll wait 

three and then we'll start. 

 MR. GRIFFON: Yeah. 

 DR. WADE: We don't -- now the clock is ticking 

on us. No, we're here till 5:30. We can be 

here longer. 

(Pause) 

 DR. MAKHIJANI: Dr. Wade, are we going to go 

much beyond because I need to change my 

reservation. 

 DR. WADE: I don't think so. We can -- is 

there anyone on the phone who's willing to 

speak up? 

 MR. GIBSON: This is Mike Gibson. 

 DR. WADE: Mike, would you like us to try and 

FAX you the materials that will be the 

representative dose reconstructions that will 

be discussed later this afternoon? Is that 

possible? 

 MR. GIBSON: The printer I'm using right now 
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doesn't have a FAX machine on it. 

 DR. WADE: Okay. With apologies, those 

materials have just appeared today. We'll try 

and be clear in our discussions of them. 

 Again, we've talked about here the need for 

people to speak as loud and as aggressively as 

I am, but if anyone starts to speak and those 

of you on the phone are having trouble, please 

shout out so we can make real time adjustments. 

My only other question is are there any Board 

members other than Mike on the call right now? 

 (No responses) 

 Any Board members other than Mike Gibson? 

 (No responses) 

Okay. 

 MR. GRIFFON: I think Jim wanted to say 

something, then we'll get back to our agenda. 

 DR. MELIUS: Something that came up this 

morning I want to just make sure we're -- we're 

clear on in terms of our next meeting, and I 

think Cindy and Jim Neton were referring to 

sort of the ongoing work and further 

calculations and further changes, and I think 

that's all fine. But I think it's very 

important for the Board that -- that there be 
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good communication between NIOSH and SC&A 

beyond this meeting so that we don't get into 

our next meeting in St. Louis and have a -- 

something presented that no one's heard of -- I 

mean from both -- either side, either a 

criticism that's -- that's new or a new set of 

calculations or a new approach, because I think 

that's going to put us all in a very difficult 

-- or could put us all in a difficult 

situation. So you know, to the extent that you 

can exchange your, you know, information, 

critiques and so forth, I think that's good. 

think we've got the process set up, but I just 

don't, you know, think -- you can certainly go 

beyond some of the dates involved if that will 

help to give a more finalized, you know, 

presentation at our next meeting in St. Louis. 

 DR. WADE: Good, and we'll let common sense 

prevail in terms of involving the working 

group. I think if it's possible, if we know 

there's going to be a call, we can let the 

working group members know and they could join. 

If that's not possible, I think we'll 

understand the intent of what Jim's saying. 

John, are you comfortable with that? 

I 
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DR. MAURO: Yes, any developments whereby we'd 

like to discuss certain ambiguities in some of 

the issues we're talking about today, or the 

degree to which these -- we leave on the table, 

as we have so far, certain questions when we -- 

we're -- 'cause our plan is to prepare a report 

to the Board on our understanding and our 

position regarding each of the issues that 

we're discussing today so that you would have 

something well before the meeting. And in 

order to get to that point, what we will 

probably need to do is to discuss these matters 

with Jim. At that time we will get in touch 

with you, Lew, I presume, to let you know that 

we'd like to open up a conference call. 

 DR. WADE: Fine, thank you. 

 DR. MELIUS: But that -- can I just add, I 

think -- you'll prepare your report, but you 

also prepare your presentations. And you know, 

we get them at the meeting, you know. You 

prepare them the night before or whenever, and 

to the extent that those change what's in the 

report -- and that may be very appropriate that 

there's new information or -- change. I don't 

mind as much the Board being surprised by it, 
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but I would be concerned that -- if SC&A 

presents something and NIOSH is surprised by it 

or hadn't heard it before, and vice versa, so 

that -- that -- you know, you both have had a 

chance to think about it. And I frankly -- you 

know, the few days before the meeting, I don't 

want you wasting your time trying to set up a 

call. I'd much rather have there be, you know, 

communication. I mean you both should be 

close, but there may be some new wrinkle or 

something that would help to vet or at least 

have discussed so that people are prepared to, 

you know, respond to it at the meeting, to the 

extent possible. 

 DR. WADE: With permission -- all right, go 

ahead. 

 DR. MAKHIJANI: Yeah, as -- as -- Dr. Melius or 

somebody is going to be taking a first crack at 

the SC&A report anyway and drafting it, I -- I 

-- I -- there are a lot of outstanding issues 

already, and I actually asked John, are we -- 

are we going to see some revised thing from 

NIOSH in the next couple of days so that we can 

look at the resolution of them? Are we to 

submit -- I'm not clear on this, I think it's a 
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little vague, if you don't want surprises, 

'cause there are big issues on the table. Are 

-- are we to send a draft on which then we will 

have a conference call? I -- I'm not sure 

exactly how you intend to prevent these 

surprises. 

UNIDENTIFIED: (Off microphone) 

(Unintelligible) rest of the day and then 

(unintelligible). 

DR. NETON: I think that -- that's acceptable. 

 MR. GRIFFON: (Off microphone) (Unintelligible) 

too, yeah. 

DR. NETON: By the -- by the original schedule, 

SC&A's review to the Board is, right now, due 

August 16th. We're still 12 good days away 

from there, and you've had a very good peek at 

our position. Now I do admit that we're going 

to have to come to grips with some of these 

issues, but I would prefer to do that, as Dr. 

Melius suggested, with some open dialogue 

between us because this process of us 

developing a position and then getting a 

counterpoint formally, it just really takes 

much more time and effort than it would if we 

could discuss among ourselves. And I would 
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hope that we could do that without having to 

have formal Federal Register type noticed 

meetings because it just gets difficult. 

 DR. WADE: Well, if -- Mark, if it's agreeable 

with you and the other members of the working 

group, if -- if that's the sense of this 

working group, then -- then let John Mauro, Jim 

Neton and I sort of work through these issues 

as they come up and we'll do the right and 

proper thing within the spirit of what's been 

discussed here. And Denise, I'll certainly be 

keeping you informed. 

 MR. GRIFFON: Yeah, I think that's agreeable to 

all of us. I mean I -- like Jim said, we just 

want -- we want no surprises by the meeting, so 

that would be good. 

All right, I think we'll go back to the regular 

agenda here. Item 1(d), we were discussing the 

second part of that, the reliability of the 

breath radon data, yeah. And I don't know, did 

-- I had a few questions on this that I just 

have looked at some of the data and a couple of 

things came up in my mind. One thing, looking 

at the hard copy data versus the CER database, 

I noticed that on my rough tally of this data 
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about 25 to 30 percent of the data in those two 

years said either lost or not analyzed. And 

I'm not sure what that -- what that mean-- you 

know, I don't know if you have a sense of what 

that meant from the HASL lab standpoint, if -- 

if they -- well, and -- and -- and second part 

of that is how would you handle -- if you had 

raw data with someone's name and all you had 

from them was something that said lost or not 

analyzed, how do you -- you just use coworker 

data, I guess, or --

DR. NETON: Right, that -- that would be our 

approach. And I'm surprised it's 25 to 30 

percent is --

 MR. GRIFFON: So was I, that's why I tallied 

up, yeah. 

DR. NETON: I really don't know, you know, what 

happened to invalidate those samples or not 

pick them to be analyzed, but we would -- we 

would use the data that we have and -- and 

develop the coworker distributions then, you 

know, follow through that way. Cindy might --

MS. BLOOM: On some of those "not analyzed" 

samples there is indication in the records that 

the laboratory was unable to process so many 
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samples, and so some that may not have been 

processed may have been excess samples. Also 

just a general note on a "lost" sample, that 

tends to indicate that something happened 

during processing where the sample was 

invalidated somehow. It was either the 

chemistry didn't go quite right or something 

like that. It doesn't mean that all these 

samples were physically not found, but that the 

DR. NETON: Yeah. 

MS. BLOOM: -- analysis didn't work the way 

they had hoped it would. 

 MR. GRIFFON: That's a general observa-- I mean 

you don't know preci-- for this dataset 

necessarily that --

DR. NETON: No. 

 MR. GRIFFON: -- "lost" meant that or... 

MS. BLOOM: No, but I -- I have looked at a lot 

of bioassay analyses and -- and it's pretty 

typical. "Not sent" or "didn't arrive" or 

"blank" might indicate that a sample was 

somewhere else, but -- and it's definitely -- 

it's -- it's a subjective word. 

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was the high percentage. If it was, you know -

-

DR. NETON: Yeah. 

 MR. GRIFFON: -- a few percent, or ten percent 

even, I -- but it was 25 to 30 percent for 

these years and I thought that was rather high, 

especially when you're dealing with a fairly 

small dataset already -- well, maybe not that 

small, but anyway... 

There's a -- also wanted to point out that -- I 

don't think there's any data in 1956 or '57, is 

there, for the radon breath? Any or very 

limited, I don't -- I don't know if that's... 

Am I right about that? 

MS. BLOOM: I think there were four samples in 

'57. The program had pretty much -- had run 

down, the reprocessing of the radium was over. 

Towards '55 it had wound way down prior to 

that, but I think that probably -- my sense is 

that they weren't so curious about that 

anymore. I can't guarantee that there's not 

more data out there, but that was my sense, 

that -- that they just stopped measuring for 

radium, that they weren't processing that -- 

doing the reprocessing of the -- 
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 MR. GRIFFON: Okay. 

MS. BLOOM: -- the radium anymore. 

 MR. GRIFFON: So that's consistent with the 

process history is what you're saying, that 

that --

MS. BLOOM: Yeah, they weren't doing the 

pitchblendes anymore, they were getting in 

concentrates instead. 

 MR. GRIFFON: Right. And -- oh, Arjun, go 

ahead. 

 DR. MAKHIJANI: Yeah. If we know they were 

doing concentrates at -- at -- I think that 

would be fine because then you don't have 

radium. But if they were doing other ores, you 

still have the disproportion of the radium at 

the filter stages 'cause that's not dependent 

on the grade of the ore, simply the uranium 

goes away. And so is it well established that 

they were doing only concentrates in '56/'57 

or... 

MS. BLOOM: I didn't look at that question 

specifically. That was just my sense as I 

looked at the different data and that things 

did wind down there, and that they had stopped 

at some point processing the pitchblende, even 
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though -- and that they were doing some 

concentrates later on. Also with the domestic 

ores you would have -- even though the ratios 

would be the same, the actual intakes would be 

lower because your concentrations would be 

lower, so -- and I just think they weren't 

measuring it. I don't -- and we're not saying 

we're not going to account for exposures. I 

think we're just going to -- as Joe said before 

-- take that line and draw it straight across 

'cause we don't know how to fill it in without 

data. 

 DR. MAKHIJANI: Which line? 

MS. BLOOM: The radon breath analyses results. 

 DR. MAKHIJANI: Oh, okay. 

 MR. GRIFFON: You're going to -- you mean -- 

draw it straight across, you mean extend it out 

to what years, to -- through '57 or -- yeah. 

DR. NETON: Right, and -- and the numbers go 

down. I have some graphs here that were not 

distributed. These are just -- what I'm 

showing here on the screen -- 

 MR. GRIFFON: Oh, okay. 

DR. NETON: We did look at the distribution of 

radon breath analyses by year, and these are 
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NIOSH evaluations. They may be slightly 

different in the decimal place or two because 

we did these independently of ORAU team, but in 

general what we're showing here is 

distributions through '49, '50, '51, '52, '53 

and '55 that are fairly -- you know, straight 

line distributions again, no real evidence of 

truncation of data, that sort of thing. And 

this last graph here is a breath radon trend, 

which shows -- it's a log scale, but the 

concentration of radon in breath went -- the 

median value went from about .3 in 1949 down to 

somewhere close to .1 in 1955 -- I'm sorry? 

Oh, yeah, .2, I'm sorry. Thank you, Arjun. 

And you -- you run into a practical issue here. 

The radon breath analyses, as we discussed 

earlier, have a detection limit of .1 

picocuries per liter, so you have a missed dose 

issue here anyways. I mean we will assign -- 

you know, if -- if there were no positives in a 

given year, the smallest intake you could infer 

would be .1 picocuries per liter, which would 

be one-tenth of the body burden and that would 

certainly -- at least, at a minimum -- be our 

assumption. 
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 MR. GRIFFON: Arjun? 

 DR. MAKHIJANI: This -- this limit of detection 

thing, on page 79 of the TBD, Mark and I were -

- were you going to ask about that? 

 MR. GRIFFON: Go ahead. 

 DR. MAKHIJANI: Well, you -- you say that the 

limit of detection was .1, but there was 

confidence in readings equal to .5 picocuries 

per liter. I don't know what that means, if 

the -- and how -- since most of your readings 

are between .1 and .5, where does that leave us 

in terms of confidence? 

DR. NETON: I think what -- what you're seeing 

there is the confidence that these are actual 

true -- true radium-derived body burden 

estimates and in fact that the concentrations -

- the body burden may actually be lower than 

that, but there was confidence that these 

values would certainly represent some type of 

radium intake. 

The detection limit, by the way, cited in the 

profile, .006, really is the detection limit I 

believe that was used by the Massachusetts 

Institute of -- MIT and the HASL detection 

limit really is .1 -- it's fairly well 
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established in their documents that it's .1. 

 MR. GRIFFON: And can -- I'm trying to also 

understand the -- would the -- to develop the 

radium/uranium ratios, you considered -- I 

wonder if these were even going to come into 

play. Anyway, you considered the -- the -- the 

entire cohort from the CER database to do the 

radium ratios. I assume you did the same for 

the uranium. 

DR. NETON: That -- that's right, the entire 

CER dataset. 

 MR. GRIFFON: CER database, and I -- I was 

curious whether any attempt was made to look at 

the subsection of the uranium CER database that 

would apply to those people that were analyzed 

via radon breath monitoring. I mean it seems 

to me that you should compare apples and apples 

to establish this ratio. I'm not sure that 

it's intuitively obvious which way it's going 

to take the ratio, quite frankly, but I'm just 

-- just throwing that out there that -- I don't 

know. 

DR. NETON: Well, I would think that it would 

increase the uranium -- uranium intakes would 

be higher in the production areas of the plant 
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that weren't -- yeah, I mean if -- if plant -- 

if you're working with uranium metals, your 

uranium intakes are going to be -- I mean the 

process of -- of uranium. So if we've included 

that, our uranium intakes -- 

 MR. GRIFFON: My -- my sense -- I'm not sure 

exactly who got radon breath monitoring, but 

I've heard you guys tell me again and again 

that the people that worked with the residues 

were being pretty favorable because all this 

stuff was wet processing, so the chances of ur-

- a lot of uranium dust are probably lower in 

those areas than maybe in other -- that -- 

that's what was going through my mind -- 

DR. NETON: Agreed. 

 MR. GRIFFON: -- as I was thinking --

DR. NETON: Agreed. 

 MR. GRIFFON: Is -- so if that was the case, 

then you could have higher uraniums in your 

overall database that are driving the ratio the 

other way. 

DR. NETON: But that was the reason that we 

went with the radon breath measurements because 

you -- you independently calculate a uranium 

intake, and then you're not applying any ratio 
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to come up with the amount of radium, and we 

still have this issue that Arjun raised about 

thorium 230, I'll grant that. But -- but the 

radium breath -- the radon breath data gives 

you radium intakes independent of whatever the 

uranium intakes were. 

 MR. GRIFFON: Right, so that -- that's what I -

- I started this discussion by saying I'm not 

sure it's relevant anymore 'cause I don't think 

you used -- but --

DR. NETON: Well, if this approach were used, 

that's true. 

 MR. GRIFFON: Right, right. And -- and so the 

radium/uranium ratio in this report was really 

considered just to validate it against other 

ratios like the silo ratios and things like 

that. Is that part of why you presented the 

radium --

DR. NETON: Well --

 MR. GRIFFON: -- to uranium ratios? 

DR. NETON: -- the whole full -- the full 

progeny ratios are presented, but we are 

definitely proposing to use the ratios beyond 

radium for those portions of the decay series. 

 MR. GRIFFON: Right. 
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DR. NETON: So the silo -- the silo ratios are 

relevant if you use radon breath beyond radium. 

I mean you've got lead and polonium and those -

- those isotopes, radionuclides. But the --

the analysis, as you can -- as you can read the 

document, you've all -- we're trying to 

establish these ratios and how you do the dose 

reconstructions and then -- you know, the 

ratios are established if we were not going to 

use radon breath, but then after we decided, 

looking at the data, that radon breath were 

more appropriate for the K-65 workers -- you're 

right, the ratios are not as relevant for 

uranium to radium, but certainly from radium to 

the other progeny is -- is still relevant 

'cause we have to -- we have to be able to 

infer the doses -- the intakes for those 

nuclides. 

DR. MAURO: Jim, I have a -- I have a -- it's a 

really relatively simple question in that -- I 

know we've been focusing in on the -- the 

radium body burden and the radon breath, but 

let's -- let's go back to the worker who worked 

with ore, whether it's pitchblende or American 

ore. And you have a high level of confidence 
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that that's what he did. Okay? There may be 

some possibility that on occasion he may have 

worked with some of the residue material. 

Okay? And you have urinalysis data for him. 

Okay? And that's it. And you've got the 

fluorometric analysis, you know what the ur-- 

the radi-- the uranium is in the urine and now 

we're going to say okay, well, what are we 

going to assume about this fellow's exposure to 

other radionuclides, specifically radium? Now 

I could see two paths being taken. One, we'll 

assume the one to one ratio, equilibrium with 

the -- or alternatively, you're going to -- 

here's where the judgment comes in. This is 

tough call. If -- looking at his work history 

there's some ambiguity about whether or not he 

did -- he was exposed to some residue. Right 

now is it your inclination when those 

ambiguities exist, would you say yes, he got 

his uranium plus the 95 percentile on the radon 

breath, or the one to one ratio with the 

radium? In other words, it's going to be a 

tough call on criteria for parsing out that 

circumstance. Have you -- have you given much 

thought on what kind of guidance you will be 
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giving to your dose reconstructors on dealing 

with that situation? 

DR. NETON: It's a tough question because it 

depends on the situation, and you give some -- 

you give an example, but it's hard to say from 

an example how we'd do it, but certainly he 

would at a minimum get the one to one ratio. 

But I suspect that if we were not able to 

definitively position this worker only at one 

to one but he had the potential for much 

higher, we would give him the 95th percentile. 

We're always going to err on the side that is 

the most defensible, and in that case it would 

be the 95th. The distribution of doses would 

be for someone who -- who was sort of an 

ancillary worker that was not near the process 

equipment that was generating some of these 

dusts and that sort of thing. 

 MR. GRIFFON: Just to -- just to go back to the 

radium/uranium ratio for a second -- last 

question on this sub-- just to understand for 

myself, you -- you won't -- there's not a case 

now that you -- that you can foresee where you 

would use the urinalysis data and just apply 

those source term ratios -- 
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DR. NETON: Well, I --

 MR. GRIFFON: -- I mean you'll use the radium 

data or the radium coworker dataset all the 

time to generate your radium intakes? 

DR. NETON: That's our intent right now. 

 MR. GRIFFON: Okay. 

DR. NETON: Now we do need to go back and -- 

and look at this issue that Arjun raised with 

thorium 230 because --

 MR. GRIFFON: Right. 

DR. NETON: -- it is a little bit vexing, but I 

think the -- you know, we need to look at more 

than just the fact that thorium 230 is there. 

We need to look at the concentration of thorium 

230 in the source term and is it even 

plausible. We know the ratio of uranium to 

thorium in say the airport cake, and it creates 

very high ratios. But one needs to look at how 

much was there. And given that amount of 

projected uranium intake, a person were 

required to inhale fairly substantial 

quantities of airport cake, we need to -- we 

need to look at that to use it as a bounding -- 

bracketing scenario. So my cautious answer is 

yes, we intend to, but -- you know, I'll never 
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say never while this is evolving. 

 MR. GRIFFON: Any other questions on 1(d)? 

Anybody have any... 

What I was going to propose after this is to 

move into item 6 and have you guys present some 

of these cases. I think it might be good to go 

from 1 to 6 because most of what you're going 

to describe in 6 I think continues -- 

 DR. BEHLING: (On telephone) Mark, can I 

interrupt? We're still getting a very 

inaudible and fragmented reception for those of 

us who are on the phone. Either there's a 

problem with the microphone or people are not 

speaking into the microphone. 

 MR. GRIFFON: Sorry about that, Hans. Is that 

better? 

 DR. BEHLING: Yeah, you're coming across loud 

and clear and so is Dr. Wade, but whenever Jim 

Neton and Mauro and -- and others have been on 

the microphone, it's very, very fragmented, 

words at a time, at best. 

DR. MAURO: Hans, this is John Mauro. Can you 

hear me now? 

 DR. BEHLING: Yes, I can. 

DR. MAURO: Okay, so the problem is I've just 
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not been speaking loudly and directly into the 

microphone. 

DR. NETON: And I guess that's the same thing -

- can you hear me, Hans? This is Jim Neton. 

 DR. BEHLING: Yes, I can. When people speak 

directly into the microphone, it's not a 

problem, but as soon as they withdraw, even by 

a matter of inches, then everything becomes 

very fragmented. 

 MR. GRIFFON: Okay, we will try to pay 

attention to that, yeah. 

 DR. BEHLING: Thank you. 

 MR. GRIFFON: All right. So I think we're 

ready to move on to item 6 --

DR. NETON: All right. 

 MR. GRIFFON: -- if you guys want to --

DR. NETON: We have prepared -- this is going 

to be difficult to speak directly into the 

microphone when I'm using props, but we have 

prepared four dose reconstructions, and 

actually these were done by Joe Guido. I'll 

set the stage here and then maybe let Joe flesh 

out the details of what we have here. 

But this was a case where -- item 6(a), it 

indicated where we had urine, air and breath 
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radon data, how we would do a dose 

reconstruction. So here we have a worker who -

- as an example case -- may have had a prostate 

and a colon cancer. The person started work in 

'51 and -- and completed their work in 1958. 

So we pulled out from the database the person -

- in our NOCTS database, our claims tracking 

system -- is listed as a chemical operator, and 

here you see Joe has pulled out the 

designations that appear on the various 

dosimetry data forms that -- that are available 

from the database. And one can see that this 

person worked in a variety of different 

positions, even though one -- he's ostensibly a 

chemical operator. And I think the chemical 

operator designation actually comes from what's 

on the EE3 form, the claim form that's filled 

out by the claimant. So we can see that he 

worked as a furnace room person; a fork truck 

operator; dingot, which would be uranium metal; 

cleanup; ore room -- that sort of thing. 

Data summary -- briefly, we do not deal much 

with external dosimetry data in these -- in 

these reconstructions, but you can see this 

person had a deep dose of -- of 10 rem 
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recorded. Now that would indicate -- that type 

of exposure would certainly indicate potential 

for exposure to raffinate type materials where 

you have disequilibrium of radium and uranium. 

And we had no thorium bioassay on this person, 

although we didn't have any reason to believe 

that he was working in Plant 7E, which is where 

the thorium processing work was done. And 

there were seven breath radon samples that 

ranged from ten percent of tolerance, which is 

.1 picocuries per liter, up to .18 -- that's an 

odd num-- that must be an average -- yeah, 

that's the average, up to 30 percent of 

tolerance. 

And here we have a number of uranium sample 

results, most of which were above the detection 

limit, and you can see that this person was -- 

was excreting fairly consistently, over a fiveyear period almost, fairly large -- by today's 

standards, fairly significant quantities of 

uranium. The detection limit here I believe is 

ten micrograms per liter -- is that right, Joe? 

So anything less than 9.5 picocuries per day 

excretion would be undetectable and he only had 

a couple of those. There's a few fairly large 
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intakes, doses, in April and July of '53. This 

is a summary of his radon breath, as you see 

it. 

And then we get down to the approach. It's 

very consistent with what we've been talking 

about earlier today. Joe modeled his uranium 

intake from his bioassay data, his radium 

intake from the radon breath monitoring data 

using this document which I provided a copy of 

to interested stakeholders of OTIB-25, which is 

the -- sort of the historical and rationale 

behind converting radon breath measurements 

into body burdens. The progeny intake were 

normalized to radium based on the ratios that 

we described from the Fernald silos. And here 

we have the ratios that were used. 

So one gets down to this relevant column, which 

is the intakes, and you can see that a chronic 

intake was -- was projected based on the 

bioassay for uranium of about 510 picocuries 

per day. There -- there is this acute intake 

that's been modeled, and that is so that one 

can be consis-- have the -- have the data fit 

the available information properly. You have 

to -- you have to have had a fairly good acute 
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intake early on for these data to fit the 

chronic model, so you end up with this 1.8 

times ten to the fifth. It sounds like a lot 

higher than the chronic, but if one takes the 

chronic intake at 510 picocuries per day, you 

end up with about an equivalent amount of 

intake per year now from that point on. It's 

about 1.8 times ten to the fifth picocuries per 

year intake, which is very much in line with 

what one sees in the site profile for -- for 

different types of jobs for time-weighted 

average, ten to the fifth, ten to the sixth is 

-- is fairly consistent. 

The radium breath -- radon breath measurements 

ended up projecting a radium 226 intake of 

seven times ten to the fifth picocuries -- 

well, 4.4 times ten to the third picocuries per 

day in a chronic model, so that gives us 4.35 

times ten to the third times 365 -- gives you a 

1.6 times ten to the sixth picocurie intake of 

radium 226. So you're in the microcurie range 

of intake here. Fairly -- fairly substantial 

radium intake based on the radon breath model. 

Now let me explain a little bit about how that 

calculation comes about. You have a radon 
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breath intake that projects a radium body 

burden at that time, how much radium is in the 

body. One then has to run the IMBA -- the 

models backwards and calculate what amount of 

radon -- radium could -- should a person have 

breathed in to result in that type of body 

burden, and that's -- that's how you get 

intake. It's just a standard back calculation 

of bioassay data to intake. So that's how that 

value is arrived. 

Now you see the thorium 230, polonium 210, 

protactinium and actinium intakes are all 

ratio'd directly to the radium intake using the 

K-65 silo material at Fernald. 

I'm not sure they show up real well on your -- 

your -- your handout, yet -- Arjun? 

 DR. MAKHIJANI: Yeah, now in this specific case 

-- I mean if you look at the work history, the 

guy worked in the ore room and also had gang 

lead cake, so that would be the K-65 stuff. I 

don't know what -- I've forgotten what RAF 

means, what is RAF? 

UNIDENTIFIED: (Off microphone) Raffinate 

(unintelligible). 

 DR. MAKHIJANI: Raf-- so that's -- all cap -- 
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caps, okay. I've not seen it in all caps 

before. The -- sorry. 

MR. GUIDO: Sorry, I just tried to be honest to 

exactly the way it was written in the CER 

database. That doesn't mean someone else 

didn't transcribe it some other way. But I 

tried to be honest to the way it was actually 

just in that database. 

 DR. MAKHIJANI: Yeah. No, I'm just taking this 

at face value, assuming everything is correct. 

And so if I -- if I look at this and say pot 

room, ore room, raffinates -- which would have 

more thorium than radium, gang lead cake -- 

which would have more radium than thorium, ore 

room -- which would have equal radium and 

thorium, then how do you decide that the K-65 -

- so this is a specific question. So if you 

apply a one to one ratio and say this guy 

worked with ore most of the time, then you'd 

come up with a much bigger thorium number. 

DR. NETON: Arjun, this is about the third time 

we've talked about this, but you know, we 

acknowledge that the thorium 230 number needs 

to be worked out, and it's still our position 

that these values are bounding or are likely 
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bounding. We need to go back and document 

this, and I'll -- I'll give you the credit that 

it may not be, but we believe they are, based 

on certain parameters. For instance, we have 

projected that this person has a thorium 230 

intake of 545 picocuries per day, so he is 

receiving a 1. -- a two times ten to the fifth 

picocurie of thorium 230. Now we need to go 

back and look at the source term material for 

the other, the -- the ore -- the -- sorry, do I 

have those? (Unintelligible) 

What I'm suggesting here is -- is we've -- 

we've assigned a ten to the fifth picocurie 

intake of thorium 230. We need to go back and 

look at the airport cake and those other waste 

streams and say is it plausible that a worker 

can have a ten to the fifth intake of thorium 

230 from a waste stream that has X picocuries 

per gram of thorium 230, whatever that is. So 

there are physical comparisons that need to be 

done here, and I'll acknowledge that that's the 

case. 

So the -- the bioassay projection models here 

are essentially -- you know, the fit of the 

data -- I apologize, you probably can't see on 
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a black and white graph and our -- I assume 

this is right out of our IMBA software. It's 

not very graphically friendly. I mean it gives 

you a feel, but you can see the line going 

through the data points here. These were 

modeled as chronic -- chronic exposures. 

Now let's get over to what's of interest here, 

the dose table. Based on this level of intake, 

we -- we have provided the -- or Joe has 

provided the -- now these are not annual doses, 

either. It gets very difficult to provide 

individual annual doses. Those actually were 

used in the probability of causation 

calculation run. These are a summation of the 

doses from the date of first exposure to the 

date of cancer diagnosis, which is the relevant 

period that we do for all dose reconstructions. 

One can see that there is a fairly substantial 

dose from -- I'm having trouble with my 

bifocals reading this slide, but polonium 210 

gives about 6.7 rem dose to -- this was 

calculated to what organ here? 

MR. GUIDO: (Off microphone) Colon. 

DR. NETON: Is this the colon dose? Yeah, 

colon dose, I'm sorry. So this is the first 
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cancer that was in the file, so we end up with 

a total dose of about 18 rem to the colon. And 

then if one models the dose to the -- what we 

call the highest non-metabolic organ, that's 

the organ that doesn't concentrate any of these 

radionuclides, you end up -- I'm sorry, 12 rem 

to the colon and about 18 rem to the highest 

non-metabolic organ, which in this case would 

be the prostate gland -- you end up with 

probabilities of causation in the vicinity of 

20 percent for the non-metabolic and 26 percent 

for the colon. So these are fairly substantial 

doses, but the PC -- it's not low, but it's not 

past the 50 percent threshold, even given some 

of these fairly large intakes. 

If one goes down and looks at the -- now using 

the same data, the same input data, and one 

wants to infer what the doses to some of what 

we call the metabolic organs -- the dose to the 

liver, the bone surfaces and the kidney -- this 

is as we've seen in many, many dose 

reconstructions. The doses to these organs are 

significantly higher, 2,300 -- 20 -- 2,370 rem 

to the liver, fairly substantial dose. 

I -- I -- under almost any circumstance, these 
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-- these values are well above 50 percent. I 

don't know if we have the -- you didn't do the 

PC values for -- it's -- it's -- for those of 

us who work with these numbers a lot, these 

values are all well above 50 percent. Bone to 

-- dose to bone surfaces, 17,300 rem. The dose 

to the kidney is 173 rem, so very much in line 

with what we've seen at many other facilities 

in situations where you have very large intakes 

projected, the metabolic organs are well above 

compensability and the organs that do not 

concentrate the material don't get there. 

Now I will say that we have not included any 

external dose in this calculation or any missed 

dose due to external, nor have we included any 

dose from systemic radon, whether it's 

particulate or gas. We -- that's a subject of 

another issue here, but that was unlikely to 

raise these doses much higher, though, as a -- 

for a practical matter. These are so large, 

the radon doses sort of get lost in the roundoff here, but -- so that -- that's the first 

case. 

I don't know if there's any questions on this. 

This -- these would all change, of course, 
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depending upon the ratios that were used 

relative to the -- you know, the source term. 

 MR. GRIFFON: Just looking at the --

DR. NETON: Arjun is very correct. I mean you 

look at thorium 230, it is the -- it is the 

driver of the dose here for the metabolics of 

100 -- 100 rem out of 173 rem for the kidney. 

For the non-metabolics, thorium 230 is eight 

out of 17 or 18 or so, so it's -- what 

surprises us -- what surprises me was the 

polonium 210 value, 6.7 rem. I would have not 

guessed that, you know, at the start of the 

calculations. 

 MR. GRIFFON: Can I -- just a question on the 

radon breath table? 

MR. GUIDO: Sure, go ahead. 

 MR. GRIFFON: Why -- you have three listings of 

percent tolerance. 

MR. GUIDO: The CER database in -- has -- 

 MR. GRIFFON: Right. 

MR. GUIDO: -- two columns of data for each -- 

an analysis date, and generally the first 

column's populated -- once in a while, as you 

see on this individual, there's two data points 

per date. 
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 MR. GRIFFON: So you averaged --

MR. GUIDO: So I averaged those. Going to add, 

too, on this case that the ten rem of external 

would have -- would make this go over 50 

percent. This -- this individual -- this 

person has ten rem of external dose, and even 

without the modifying factor, that would -- 

that would be enough, but I didn't include that 

in the POC values. 

DR. NETON: Yeah, 'cause the doses -- internal 

doses stay the same, but you're -- you're sure 

ten rem would put those over? 

MR. GUIDO: Yeah, 'cause they're going from ten 

-- they're -- the thing about this case is it's 

two cancers, so each one needs to be -- 

DR. NETON: Right, yeah --

MR. GUIDO: -- (unintelligible) 30 percent -- 

DR. NETON: -- I think we're trying to keep 

that a separate issue, whether it's two cancers 

or not. We're trying to look at the individual 

cancers here because that's really what we're -

- yeah. I mean this is an example case and 

we're not trying to decide whether this pers-- 

this particular individual has any 

compensability, so -- but I think -- I think if 
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we took the individual cancers at face value 

and added ten rem, it would be my guess that 

they would not go over -- 

MR. GUIDO: No. 

DR. NETON: -- 50 percent. But -- you know, 

'cause it -- it's not a linear function, as we 

all know. 

I'd just like to point out a couple of things, 

is one is that the intakes that were projected 

here are fairly consistent with the Table 29 

values for -- for time-weighted averages, 

although arguably a little higher. They 

certainly aren't lower, and I -- I think if we 

actually used the time-weighted average value 

to estimate intakes here, we would have likely 

had a smaller dose -- in this particular case. 

I -- you know, it's -- it's very difficult for 

us to generalize to all cases. It's just not 

possible. But in this instance, I would say 

the radium intake by itself is about there. 

The uranium intake is about equal to Table 29 

values. But when you put them together, you 

end up with a slightly higher intake because we 

have separate estimates of intake. And again, 

I -- you know, this -- and that's -- that's 
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just for the radium and the -- and the -- 

radium. You start adding in the thorium 230 

source term of ten to the fifth picocuries per 

year, you end up with some fairly substantial 

intakes here. 

DR. MAURO: Just for clarification, if you were 

to use -- now what I understand is if you were 

to be using the previous method, you would be -

- the approach would have been to assume the -- 

you would have used the urinalysis for the 

uranium and, given his job descriptions, you 

would have assumed 100 times that concentration 

for radium in the urine, and then backcalculated what the intake would have been. 

DR. NETON: Right. 

DR. MAURO: In this case you're going with the 

radon -- the actual -- for this worker you have 

radon exhalation data -- 

DR. NETON: Right. 

DR. MAURO: -- and you have some value for what 

the radium body -- and you're saying that's 

what makes the difference, along with some of 

these other ratios you used -- 

DR. NETON: Right. 

DR. MAURO: -- so that we had a small 
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difference. Now, the question becomes if this 

worker did not have radon breath analysis and 

you would have had to have gone with the 95 

percentile, would that have had a substantial 

effect on the dose and the amount of radium 

taken in? 

DR. NETON: You make a good straight man, John. 

That's my next example. 

DR. MAURO: Oh. 

 MR. GRIFFON: (Off microphone) I figured that 

was (unintelligible) ask for one of those. 

DR. NETON: We didn't rehearse that. 

 MR. GRIFFON: (Off microphone) But there it is. 

Right? 

DR. NETON: It's our next example, but -- so -- 

it's -- it's a good point, though. You raise a 

very valid point here. 

One thing I'd like to point out, though, is -- 

and Arjun brought this up. If you look at this 

person's work history, it's pretty clear that 

he worked in a lot of different areas that were 

raffinate, no raffinate, maybe some thorium 

higher than radium -- it's hard to say. This 

guy was all over the place. I bel-- I suspect 

that, you know, based on the time-weighted 
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cards we have on a person like this, we could 

apportion based on time. It gets to be very 

unwieldy, though, and -- and then one gets down 

to exactly how closely do you parse these 

people's work histories out. I mean because we 

have it doesn't necessarily mean we have to use 

it all, you know. I mean it becomes very 

cumbersome at some point. 

So let's -- let's move on to number two, which 

is exactly the same case, but we -- Joe assumed 

that we had no -- we just didn't have access to 

the radon breath data. Where is it? 

MR. GUIDO: Make a comment there --

UNIDENTIFIED: (Off microphone) 

(Unintelligible) 

DR. NETON: I've got -- thank you. 

MR. GUIDO: -- in looking for these cases for -

- for active claimants we had all the data on, 

I could not find one that was, you know, 

clearly a ore/raffinate worker who didn't have 

radon breath. I had to go this route. Not 

that there isn't one out there, but I looked 

through the 129 claims we had and couldn't find 

it, so... 

DR. NETON: Okay. So this -- the demographics 
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on this case are identical 'cause it's the same 

case and we had all the same information, same 

bioassay for uranium in urine, applied the same 

ratios, got the same uranium projection -- 

although I'm not sure it's not just a cut and 

paste of the original analysis. But what we 

did was we did not have -- what, did I miss 

something here? I want to show the -- okay, 

there's the uranium in urine. Okay, the 

approach, uranium intake from uranium bioassay, 

radium intake from 90th (sic) percentile of CER 

radon breath analysis, and then the progeny 

were normalized to radium. There's the ratios, 

and there's your projected intakes based on the 

95th percentile. And you see he has 8.78 times 

ten to the third picocuries per day, so they -- 

he ends up with about 3.2 times ten to the 

sixth picocuries intake per year of radium 226, 

which is higher than I think the first case, 

but not ridiculously higher. I mean it's in 

the same ball park. 

Now that -- that shows you the radon breath 

ranges give pretty high projected intakes. I 

mean 'cause the sensitivity of this technique 

is not -- it's better than some cases, but it's 
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not as good as whole body counting, for 

example. You can get down much lower. 

 DR. MAKHIJANI: (Off microphone) 

(Unintelligible) 

DR. NETON: That was using the 95th percentile 

of -- of the radium. 

So anyways, let's move on to the doses. This 

would be --

DR. MAURO: Jim, I'm sorry, this is John Mauro. 

When you pick the 95 percentile, you work with 

the entire population of radon breath data -- 

DR. NETON: Correct. 

DR. MAURO: -- and not try to parse it in any 

way. 

DR. NETON: No. 

DR. MAURO: Okay, thank you. 

DR. NETON: We've looked at that. It's very 

difficult to parse those values. We have 2,500 

samples. Once you start breaking it out by job 

description, it -- it's tough to do. 

The bottom line dose here is that his colon 

dose is now 22 rem. I think it was what, 12 

rem before? His dose is about doubled here. 

And I suspect, as Arjun has pointed out, much 

of it is due just because of the larger radium 
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intake, which has jacked up the amount of 

thorium intake. 

As a matter of fact, let's go back and look at 

that thorium intake. Yeah, if you -- if you 

have more -- his thorium 230 now is 1.1 times 

ten to the third picocuries per day times 365 -

- it should be about double. I'm having 

trouble with my calculator. Yeah, he's at four 

times ten to the fifth, I think you've got two 

-- so it's about -- it's a little -- again, 

Arjun has correctly pointed out thorium 230 is 

a driver nuclide here in these calculations, 

very sensitive to that. But again, we're 

assigning a four times ten to the fifth 

picocurie intake of thorium. We need to do our 

homework and come back and convince folks, as 

we believe, that these values are plausible 

bounds of thorium intakes for these workers 

based on the other waste streams. That's --

that's what we need to do, and I totally agree 

with that. I totally agree we need to do that. 

Okay. So again, even though the dose has 

doubled here, neither -- neither of the colon 

nor the prostate gland are above 50 percent. 

However, I'm not convinced if you add in -- you 
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might add in the ten rem plus missed dose and 

be over 50 percent. I'm not sure that's the 

relevant part of this conversation. I mean 

that -- these are just how they came out. I 

don't think we need to model these doses to 

where the PC comes up. It's just for 

information only. 

 DR. MAKHIJANI: But if you take this specific 

example and you add up the probabilities of the 

two cancers, in the first case where you had 

the data, the person is non-compensable. And 

in the second case where you don't have the 

radon breath data, the person becomes 

compensable. No? 

DR. NETON: (Off microphone) He was noncompensable under both cases. 

 DR. MAKHIJANI: Oh, you don't add up the 

probabilities. 

DR. NETON: Speaking if they were individual 

cancers, the pers-- the individual cancers 

themselves, if taken separately, were noncompensable. If they were taken collectively, 

I believe they would have been compensable 

under both scenarios. 

 MR. GRIFFON: But I -- I think his point stands 
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that --

DR. NETON: But the point is that -- 

 MR. GRIFFON: -- the POC is doubled with -- 

when you don't have the data. Right? 

DR. NETON: Right -- well, I think this is -- 

this is something that is -- is -- is an issue 

with this program. The less you know, the more 

you have to infer. And when we infer in a 

claimant-favorable, that's what happens. I 

mean --

 MR. ELLIOTT: But these examples weren't 

designed or derived to demonstrate 

compensability. These examples were designed 

to answer the questions that were raised at the 

Board meeting that -- and we were charged to 

come back to you all with answers for, 

demonstrate how we would treat certain data 

streams. 

DR. NETON: But -- but Arjun is correct in 

pointing out that where we have workers who 

should have been monitored and weren't and we -

- we estimate doses, the doses will be higher. 

And this is not necessarily just relevant to 

Mallinckrodt. It's relevant across all the 

dose reconstructions we've been doing. 
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 DR. WADE: Denise? 

MS. BROCK: I just want to make sure that I 

understand. When you have two separate 

primaries, when I looked at that I guess I was 

thinking, too, that you add the two together, 

even though we're not discussing 

compensability. Is that correct, though, you -

-

DR. NETON: Right. 

MS. BROCK: -- you add the two together. 

DR. NETON: They're both considered. It's not 

additive, but you're right, they are -- they 

are -- there's a formula that we use to -- 

MS. BROCK: Combine it. 

DR. NETON: -- combine them. 

MS. BROCK: Okay. Thanks. 

DR. NETON: Yeah. We just wanted to segregate 

those, just because we're not really discussing 

compensability here. 

Okay. And then if one looks at the alternative 

organ doses that -- that Joe has calculated -- 

liver, bone surfaces and kidney; these are what 

we would call metabolic organs -- the doses 

have gone up, as well, and -- about doubled, 

and again, these dose-- these organs are all 
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compensable, you know, under both scenarios. 

Well, the doses are very high under both 

scenarios. So that -- that -- it demonstrates 

our -- our approach when we don't have radon 

breath data and we have radon (sic) in urine 

data. 

Okay, any -- any other questions on this -- 

this specific case? 

 DR. MAKHIJANI: (Off microphone) 

(Unintelligible) Is Joyce on the phone and does 

she have any questions? 

DR. NETON: I'm not sure. I'll speak directly 

into the microphone. Arjun has asked if Joyce 

Lipsztein is on the phone and she might have 

any questions. 

 DR. BEHLING: (On telephone) No, Joyce -- I got 

an e-mail from Joyce -- this is Hans Behling -- 

 DR. LIPSZTEIN: (On telephone) I -- I'm in 

(unintelligible) Hans. 

 DR. BEHLING: Oh, okay, you are on --

 DR. LIPSZTEIN: (Unintelligible) yes, I'm on. 

No, I don't have any questions now. I think 

that's okay. When you -- I don't see the 

slides you have (unintelligible), Jim, but when 

you back off the (unintelligible) radium from 
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the radon in breath, so you took an account of 

how many years the guy had been working -- 

right? -- for the cumulative radium in the 

bone? 

DR. NETON: We did this -- Joyce, we're having 

a lot of trouble hearing you, but I think your 

question is did we take into account the number 

of years the person was working, and we did 

this on an annual basis. The radon breath was 

assigned per year based on the values that were 

measured or inferred. 

Is that right, Joe? I think that's what you 

did. 

MR. GUIDO: Yeah. Yeah, I wasn't sure what her 

question was. I mean I know this -- the one 

thing that's strange about this -- 

DR. NETON: Speak directly into the mike. 

MR. GUIDO: One thing that's strange about this 

case is the radon breath data is only available 

for the first -- what is it, the first four 

year-- three years of employment, and yet we 

gave him -- that's the exposure based on a 

chronic, and extended it all the way out to the 

end of the employment. So I wasn't sure if 

that was your -- your question about the 
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duration of the exposure. It was for the 

entire employment period, even though the radon 

breath monitoring ended, you know -- and one 

could postulate why, but you know, you really 

can't determine a good enough reason to turn 

off the dose, as we talked about earlier. So 

does that -- does that help or does that 

totally miss what you were asking? 

 DR. LIPSZTEIN: It's very -- I can hardly hear 

you. 

 MR. GRIFFON: (Off microphone) She can't hear 

you. 

MR. GUIDO: Well, I can talk a little louder -- 

I can talk loud. 

 DR. WADE: Go ahead. 

MR. GUIDO: I'm not sure if the answer to your 

question is -- you know, in this specific case 

the radon breath monitoring data was only 

present for the first three years, yet the 

intake that was assigned was assigned -- you 

know, using that data for the entire employment 

period. So -- I mean is that an answer to your 

question, 'cause we were -- or not? 

 DR. LIPSZTEIN: Yeah, yeah, because I was 

thinking -- I was -- what I wanted to know is 
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that if you considered each -- as if it was 

just one year intake or the whole life because 

the radon would accumulate in the skeleton so 

what you see from the radon badge would 

(unintelligible) his whole working period. 

MR. GUIDO: Right, for -- so for this intake 

assessment we used the -- the three years -- so 

it was based on the three years of data, so we 

didn't postulate any data further out, but we 

did assign a chronic intake and it -- you know, 

it continued on beyond -- but the -- but the 

level of the chronic is based on the three 

years of data. 

 DR. LIPSZTEIN: Oh, okay. Okay, that -- that 

was my question, yes. Okay. 

DR. NETON: Okay, should I move on to example 

three then? 

All right, the third -- the third example I 

think has to do with the thorium workers, and 

we haven't discussed this much. By thorium 

worker here, we mean people who worked on the 

special project in Plant 7E, I think it was, to 

-- to take the airport cake which had thorium 

230 in it and concentrate it to ship to Mound. 

Now this was a -- a wet chemical process that, 
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to the best of my knowledge and looking at the 

data, never took the material to dryness. This 

was a thorium nitrate solution I think was 

actually what ended up being shipped to Mound, 

but it was -- the task at hand here was we have 

a thorium worker. We had uranium and thorium 

analyses and radon breath, which I'm not sure 

was relevant here. Let's see, this was to -- 

example internal dose asks for Plant 6 -- Plant 

7 thorium extraction worker. 

So it turns out then in looking through the 

database, we have found I think it's about 70 

bioassay samples that were analyzed for thorium 

230, and specifically for -- for workers -- I 

believe they were in Plant 7, although there 

might have been an indication that some of 

these workers were Plant 6 and moved over to 7, 

but in this time frame these were HASL results 

in the data files for workers. So we have 70 

bioassay samples. This particular person has a 

bioassay sample, so let -- let's just go 

through this. 

Ionium of course is the historical name for 

thorium 230. This particular case had a 

pancreatic cancer, who started work in '49 and 
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ended shortly -- '58 plus with a break in 

employment at one point. This was a laboratory 

technician. He had -- his dosimetry data 

indicated he was a chemist, a Plant 7E worker, 

a technician, a process Plant -- so there's a 

lot of indication here that this person worked 

in Plant 7E where the thorium extraction 

process was done. He has, again, a fairly high 

external dose, 8.2 rem, which is consistent 

with working with some material that had some 

high photon activity rather than just straight 

uranium. 

There was one thorium bioassay sample that was 

-- the result was 1.4 disintegrations per 

minute per liter. The person actually did 

have, it looks like, seven radon breath 

samples, which is interesting. So -- he also 

has uranium bioassay. So here a worker has a 

number of uranium bioassay samples; in the 

early days many of them above the detection 

limit, and after 1955 they were all less than 

detectable. Here is a summary of the radon 

breath data that appears to be increasing over 

time, somewhat substantially -- ten, 20, 40, 

20, 60, so that's interesting. And now we have 
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thorium in urine data, so if we -- and we used 

the -- these ratios -- okay, the approach, we 

analyzed the uranium from the bioassay data, 

the radium intake was from the breath data 

monitoring. The polonium was intake -- 

normalized to radium based on the ratios, and 

then the thorium intake was from thorium 

bioassay. So you're going to have to explain 

some of these normalized ratios that you used, 

I think, 'cause I don't think we've gone over 

these before -- Joe or Cindy. 

MR. GUIDO: Yeah, you mean the -- those are 

basically the ratio to radium or the ratio to 

thorium, and so I guess the terminology I used, 

when I said normalized, that's just basically 

you're applying those ratios. The polonium 

isn't present in -- the -- the thorium ratios 

don't include polonium, so I went ahead and put 

it in, at least on the radium 'cause there was 

radium -- radon breath monitoring. And this, 

again, is an example of being very claimant 

favorable because here -- the person -- if you 

look at their data on their card, they're 

clearly a -- a 7E worker. I mean they -- they 

worked -- I mean most of the data was tagged 
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Plant 7E. However, there was radon breath 

monitoring data, so we went ahead and said well 

-- we gave him the radon -- the radium exposure 

from that scenario, also. So it's probably 

double -- double -- you know, giving him twice 

of some things, but you can't really split it 

apart to say when he did one and when he did 

the other. 

DR. NETON: Okay. So here is the projected 

intakes -- (unintelligible). 

 DR. MAKHIJANI: I just -- I just want to 

understand these numbers. So what you did is 

you just carried the radium through the '58 

from the time that there was the radon breath 

data and then the thorium 230 for '55, '57, you 

derived from that one -- 

MR. GUIDO: Exactly. 

 DR. MAKHIJANI: -- sample. 

MR. GUIDO: Exactly. 

 DR. MAKHIJANI: Now how does that work when you 

have one sample in the beginning of the period, 

when did production start, how did production 

progress in terms of its volume, because that 

seems to me right in the beginning of the 

period. Right? 
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MR. GUIDO: Yes -- yes, it is. Well, it was 

assigned as a chronic intake with the -- you 

know, using that one sample 'cause that's -- 

that's the only data we have for it, so... 

DR. NETON: So you raise a point, this was 

early -- earlier on in the process, but you 

know, what amount of intake per day would it 

take to get up to that value, given the amount 

of time that -- that the person had -- had 

worked. Here's the radium bioassay projections 

fit. There's the uranium projection. 

And then let's look at the dose to the 

pancreas. This is 110 -- the rem dose to the 

pancreas, 75 percent of the dose is contributed 

to by the thorium 230. The rest of the intake 

values are very low contributors to this 

person's pancreatic dose. 

Now at 110 rem, this person -- if one were to 

do a calculation, PC is right at 50 percent. 

Now if we look at the alternative doses, what 

we call the metabolic doses, we've got the 

highest non-metabolic actually in here at 130, 

and that's -- that's going to be similar to the 

dose to the pancreas -- it should be, I can't -

- it should be right -- well, very close. Now 
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the dose to the liver, the bone surfaces and 

the kidney are much, much higher, which is what 

you'd expect for an organ that concentrates, to 

some extent, thorium 230. Although 

interestingly, the -- the bone surface dose is 

also driven, to a large extent, by the actinium 

227, which is not a surprise -- a fair amount 

of daughters, progeny, related to actinium 227 

that are alpha emitters. Actually that's the 

largest component of the dose, isn't it? Yeah, 

so that's the --

 DR. MAKHIJANI: Jim, in the site profile, in 

Table 29F, it says that the thorium production 

started in July 1955 and your sample's from 

April '55. 

MS. BLOOM: We definitely have information that 

they started in March --

 DR. MAKHIJANI: (Off microphone) Okay. 

MS. BLOOM: -- of '55, so I'm not sure if -- 

DR. NETON: That may be production -- 

MS. BLOOM: -- if that was better -- 

DR. NETON: -- versus --

MS. BLOOM: Yeah. 

DR. NETON: -- pilot operation. 

MS. BLOOM: Yeah. But the program did start up 
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in March. It -- it didn't start before 1955, 

in January, but we definitely saw something 

that indicated March was the start-up date. 

DR. NETON: Now one point of interest here, I 

suppose, if one looks in these values at the 

ratio -- 'cause remember, this is airport cake 

material. One can look at the ratio of uranium 

to thorium in these samples -- or in these 

projected intakes, and they vary over time, but 

the projected uranium intake is about 300 

picocurie. These are per day, I assume, here. 

So you know, there are some fairly large 

discrepancies here of thorium, but again, this 

was a -- this was a process that was 

concentrating the thorium into a thorium 

nitrate solution. So these are not necessarily 

relevant to the -- the airport cake product 

itself, but I think one doesn't see a ratio 

higher than 100 to one, probably. Yeah, so you 

know, you're below 100 to one ratio here, which 

I think is not that inconsistent with some of 

the airport cake material. 

Again, we need to -- we need to look at the 

airport cake material and see what the actual 

concentration of thorium 230 was in the source 
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material and the plausibility of getting higher 

intakes than -- than what we've estimated for 

the radium guys. 

Okay, I think case three -- or four -- I've 

actually forgotten what case four was, but it's 

a thorium worker where we have no bioassay -- 

or without thorium bioassay. We have uranium 

and breath, and the uranium and breath 

calculation, of course, would end up being the 

same. And the thorium and protactinium are 

normalized to uranium intake based on ratios. 

I think this -- this is where you applied this 

ratio, Joe? 

MR. GUIDO: Yeah, there's a -- there's one 

point of clarification here. The thorium --

this individual has four intake periods bec-- 

one of it's because there's a break in 

employment and such, but for the '55 to '57 

period, which would be the period of the 

thorium operations, for this case we said well, 

again -- you know, this is a thorium worker, 

but we don't have thorium data. So what we did 

is the thorium 230 is based on 100 times the 

uranium, and that did not make it into the 

approach paragraph there, I apologize for that. 
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But that's where -- that's the only difference 

between this case and the others. The examp--

so the purpose of this is just to demonstrate 

what would we do if we're convinced it's a 

thorium worker but we don't have thorium data, 

so we give it the 100 to one ratio, which is 

going to make the exposures higher. 

DR. NETON: Now what is the basis for the 100? 

You might want to explain that. 

MR. GUIDO: Yeah, that's from the -- the 

document here. You know, we're saying what the 

ratio of thorium 230 to uranium and -- where 

did those numbers come from, Cindy? 

MS. BLOOM: That's based primarily on our 

initial look at the AM-7 -- the -- the airport 

cake. 

DR. NETON: Right, okay. So in this particular 

case, using that 100 to one ratio to uranium, 

the bioassay projections are the same, the 

doses are presented here and again it looks 

like they about doubled over what was projected 

without bioassay. Thorium 230 is driving the 

calculation with 100 -- 200 rem out of 227 

total, and the PC value of course is well over 

50 percent in this case -- 67 percent. 
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If one looks at the alternative organ doses -- 

not the -- well, the -- the non-- that's the 

non-metabolic one I just showed. These are the 

metabolics and these are all of course higher 

than the last example, and the PC -- well, we 

didn't calculate PC value, but they're all -- 

they're all very substantial doses. For the 

most part, when you get above 100 rem or so, 

it's pretty -- depends on the case, but 100 rem 

will certainly get a PC of 50 percent or 

greater for most -- most calculations. I think 

I'm safe to say that. So again, the metabolic 

organs under this scenario are also 

compensable. 

But what we have here is a picture of some 

fairly substantial intakes. We knew that 

Mallinckrodt was a messy operation. These 

intakes are large. It's not surprising that 

they're -- they're coming out large with very 

large doses. That's what we expected. 

 MR. GRIFFON: Okay, I think we can -- if 

there's no more questions on the cases, I think 

we can go back to the -- to item number two, 

which is the handling of the radon exposures. 

Jim, maybe you'll --
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DR. NETON: Okay. 

 MR. GRIFFON: -- give us an intro. 

 DR. MAKHIJANI: (Off microphone) 

(Unintelligible) Joyce (unintelligible). 

DR. NETON: Joyce, are you still on the phone? 

 DR. LIPSZTEIN: I'm still on, but I can't -- 

now I can hear you. I couldn't 

(unintelligible). 

DR. NETON: Okay, I need to speak loudly, I 

guess, because we want to make sure that you 

hear -- hear what I'm saying. 

 DR. MAKHIJANI: Joyce, this is Arjun. I -- I 

sent you that little list. I don't know -- I'm 

relying on you here to ask the questions 

mainly, and I'll fill in, but -- so please 

speak up if you can't hear. All right? Thanks 

a lot. 

 DR. LIPSZTEIN: Okay. 

DR. NETON: Okay. On the first issue, which is 

item 2(a), resolve whether sufficient radon 

data are available, this was the result of the 

profile not actually addressing or utilizing or 

summarizing, rather, all of the -- all of the 

radon data that were available in the CER 

database. 
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We've gone back and analyzed those data -- I 

believe there are around 5,000 radon samples 

that were taken over -- over the relevant 

period here. And I've actually provided those 

-- the -- a document to the stakeholders that 

shows the results of those summary analyses, 

providing geometric mean standard deviations 

and relevant percentiles -- I think 84th and 

95th percentiles -- and along with some 

statistics that demonstrate goodness of fit. 

As has been the case with almost all these 

analyses, the data fit a lognormal distribution 

fairly well. We are proposing to use the 

distribution of the radon measurements in the 

facility to assign radon intakes to workers. 

Now -- so that, for instance, if a person were 

a worker in the Plant 6, they would be assigned 

a radon intake equal to the 95th percentile of 

the radon -- dose radon measurements in that 

plant by year. 

That said, we need to recognize that radon is 

the largest contributor of dose to the lung. 

We have done almost all the lung cancer cases 

in our possession already. And if I'm not 

mistaken, I think all of those have been -- I'm 
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not sure -- I'm pretty sure all those have been 

compensable, and that's driven by maybe factors 

other than radon, just -- just the -- the 

uranium intakes. I mean any time you get 

actinide intakes deposited in the lung, such as 

you have at Mallinckrodt, the lung doses are 

going to be very large, and that's been the 

case here. 

So when we propose to provide these 95th 

percentile distributions, we would apply them 

to lung cases that -- if necessary, to add to 

the dose to move them over 50 percent. We 

don't believe that's necessary in this case. 

Then we have to get to the relevant issue, 

which is do we start adding radon tissue doses 

-- that is what I would call systemic tissue 

doses -- to -- to the dose reconstructions to 

account for any dose that may be present due to 

radon gas or daughters. 

DR. MAURO: Jim, it's John Mauro. I have one 

question regarding the -- the radon database. 

If I recall in your write-up, within that 

database you excluded radon measurements 

associated with when they were cracking the 

lids, or is that data included in there? 
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DR. NETON: That data is included. I think 

that the write-up actually said that we did not 

exclude it, or something to that effect. 

DR. MAURO: Oh, I misunderstood. Thank you. 

DR. NETON: Yeah, so in some sense -- you know, 

we're assuming a chronic exposure to the 95th 

percentile of -- of the dataset that more than 

likely includes short term, episodic instances 

or incidents that could have occurred that were 

measured, you know, at that time. So you --

and you get some fairly high radon intakes in 

the -- in the early periods, 1949-'50. After 

that, it drops fairly well. I thought I had it 

plotted but I guess I don't have it here. 

MS. BLOOM: But you might -- you might have 

something on a file called "MCW preliminary". 

DR. NETON: Well, I don't -- I don't have it on 

my -- Arjun has it. I have a spreadsheet for 

radon here, let me just -- I think that's radon 

breath, yeah. I don't know what that is there. 

For some reason I don't know what the -- well, 

anyway, the data --

DR. MAURO: (Off microphone) I think you do. 

DR. NETON: -- are summarized -- do I? 

DR. MAURO: I think -- I think you do have it 
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in this document right here (unintelligible). 

DR. NETON: What's the document called, John? 

DR. MAURO: It's called "Draft Statistical 

Analysis of Airborne Radon and Coworker 

Bioassay --

DR. NETON: Right. 

DR. MAURO: -- and External Data". One of the 

tables I believe is the -- by year, the radon 

measurement data. 

DR. NETON: I think this is it right here, hang 

on. I've worked with so many files in the last 

ten days I can't keep them straight. And so 

has my col-- so have my colleagues, all of whom 

recog-- okay, yeah, here it is. 

There's a table, here we go -- yeah, this is a 

penetrating dose, external shallow, missed dose 

-- here we go, summary of statis-- of radon in 

breath, airborne rad-- I'm getting there. Bear 

with me, please. 

Table 7, Summary Statistics of Airborne Radon, 

Picocuries per liter. You can see in this -- 

the 50th percentile -- we calculated and 

measured -- let's just -- they're -- they're 

very close. That was just to demonstrate the 

goodness of fit. But we started off with the 
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50th percentile somewhere in the mid-30 

picocuries per liter '48, I'm not sure what 

happened there in 1949. 

I think what's more relevant, actually, if you 

go over -- we don't have the 95th percentile on 

here, but if one looks at the -- the 84th 

percentile, as you get out to the extremes of 

the distribution the values obviously get 

higher, and with the GSDs fairly large, 

particularly 1949. This is where we've had, 

you know, a massive influx of the K-65 material 

going through. And I think you can get 

somewhere upwards of almost 1,000 picocuries 

per liter at the 95th percentile in '49. 

 Now that sound-- that is a lot, and the lung 

dose is going to be huge from that. But -- and 

we can talk about this in part (b), but if we 

look at the radon dose to tissues, it's -- at 

least from the dissolved gas perspective, it's 

.6 millirem per picocurie per liter of radon 

gas in the -- in the tissues themselves, so it 

would -- it would add, at 1,000 picocuries per 

liter continuous exposure, somewhere around 600 

millirem dose. That's not trivial, it's not 

zero. For the metabolic organs it's very small 
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compared to what we've calculated. For the 

non-metabolics it may indeed be worth 

considering. 

That would be the worst case. I think as you 

go down from there, when you get into the 100 

picocurie per liter, 95th percentiles give you 

a 66 millirem. Now we need to discuss that, 

whether or not the gas is relevant or the 

daughters, but -- but we are proposing that we 

use the 95th percentile of the distribution and 

then just assign it to workers in the plant. 

Very similarly to the radon breath analyses, we 

would take the 50 -- the full distribution and 

apply it to people who did not appear to have 

worked full time in Plant 6, those who were 

ancillary support workers, that sort of thing. 

So that's where we are. We had hoped to get 

this more refined than that, but it just 

becomes difficult to definitively document -- 

when you start -- when you start parsing the 

worker job activities too finely, it becomes 

difficult to -- to demonstrate definitively 

that you -- you know, you've done that 

properly. So we are -- we are proposing to use 

at least these two distributions. There's a 
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possibility of a third, but we're not there. 

MS. BROCK: I have a question that's probably a 

really stupid question. Maybe I'm just not 

understanding. When -- I know you say that the 

lung dose with radon a lot of times is very 

high, and I -- I think that all the lung 

cancers so far have been compensable, so I 

guess I'm confused. When you talk about other 

tissues, are you referring to organs as well, 

and is it -- when you use this model, the 

breath radon model, to dose reconstruct the 

non-metabolic cancers other than lung or 

something that wouldn't seem as compensable, 

are the workers -- are the claimants going to 

be at a disadvantage using this because of the 

radon breath model? Would they be better off 

with the daily weighted average? Could you --

DR. NETON: This is somewhat different -- it's 

a somewhat different issue than the radon 

breath. This is -- this is a dose pathway that 

really was not addressed in the site profile. 

This is in response to an issue that was raised 

by SC&A in their review, who indicated that 

radon gas itself, the progeny, the daughters, 

are known to cause large doses to the lung and 
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in general the systemic organs, the doses 

removed from the lung, the soft tissue. The 

doses frankly have been ignored in every 

calculation I've ever seen. They're just 

assumed to be trivial. 

Now for -- but for Mallinckrodt, in -- in cases 

where you have these very high gas 

concentrations, it's possible to get doses to 

the systemic organs that are -- not zero, 

there's some value. Now we need to make a 

decision whether we're going to address the 

doses to those tissues and how we're going to 

account for those doses. So this is a separate 

pathway from the radon in breath. It's a --

it's a --

 DR. LIPSZTEIN: Hello? 

DR. NETON: -- very separate issue. 

MS. BROCK: Thank you for clarifying that 

because it's really confusing for me. 

MS. BLOOM: Well, one other thing I would say 

is that the radon in air has to go with the 

radon that's going into your lungs and exposing 

you from going into. The radon in breath has 

to go from the radon coming out from the radium 

already deposited in you, so those are two 
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different exposure --

MS. BROCK: Oh, okay. 

MS. BLOOM: -- pathways. In one we use to 

measure radium and we're not looking at 

anything to do with the intake of radon 

separately. 

MS. BROCK: Okay. Thank you. 

MS. BLOOM: Uh-huh. 

 MR. GRIFFON: I think I heard Joyce, yeah. 

DR. NETON: Joyce, did you have a comment? 

 DR. LIPSZTEIN: Yes, Jim, I'm talking about now 

the doses to the (unintelligible) tissues from 

the radium daughters. What did you -- I tried 

to get your results that you sent and I 

couldn't reproduce them. Did you just change 

the half-life in lung for ten hours for 

(unintelligible), for example? 

DR. NETON: I'll let Dave Allen address that 

issue because he's the one that did the model. 

MR. ALLEN: Hi, Joyce. I did quite a bit with 

this. I used the lead 214 and determined -- I 

-- I saw the models and determined the dose per 

unit intake for .0015 micron particles, and 

then I did it again for .25 micron particles, 

both assuming a 10-hour absorption half-life in 
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the lungs for the lead. 

 DR. LIPSZTEIN: Right. 

MR. ALLEN: Also I assumed a 13-hour absorption 

half-life for the bismuth 214 that in-grew in 

the lungs. 

 DR. LIPSZTEIN: Uh-huh, yes, I saw that. Yeah. 

MR. ALLEN: Okay. And I also had the bismuth 

214 behaving as its own biokinetic model rather 

than assuming it behaved as the parent. And 

then I had to apply an attached fraction to 

decide how much was .0015 micron versus .25 

micron, and also applied the equilibrium 

factors that are in the paper there. 

 DR. LIPSZTEIN: I -- I didn't worry too much 

about the -- the smallest particle size because 

you (unintelligible) fraction and it's only ten 

percent of the other one because I think the 

10-hour half-life is only applies to the 

attached fraction. But it doesn't matter 

because it's so small, the -- the fraction due 

to it, so the most important would be the .25 

(unintelligible) that you calculated. But I 

couldn't reproduce this. I -- I tried to and 

my numbers don't get to the same ones that you 

do and I don't know what -- how -- let's say -- 
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just (unintelligible) the lead 214. Did you do 

something else besides changing the 

(unintelligible) the absorption parameters from 

the respiratory tract from ten minutes to ten 

hours? 

MR. ALLEN: Joyce, I only caught about half of 

what you said there, but I mean obviously you -

- you're saying you didn't -- you couldn't 

reproduce the same numbers I got. Could you 

tell me if you were at least in the same ball 

park as the numbers I got? 

 DR. LIPSZTEIN: Yes, but for -- it's the same 

order of magnitude, but what shocked me is the 

-- the dose to the bone surface because I got a 

dose that was half of the one in the kidney and 

you practically got nothing at the bone 

surface. 

MR. ALLEN: If -- if it's --

DR. NETON: Okay. 

MR. ALLEN: -- all right with the members of 

the Board here, this -- this is getting kind of 

difficult. If -- you know, Joyce is saying 

that the numbers are in the same ball park, 

maybe this is one of those situations where we 

could call off-line and have a conversation. 
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DR. NETON: Yeah, I think --

 DR. LIPSZTEIN: Okay. Okay. 

DR. NETON: Yeah, we -- we could work with 

that. 

 DR. LIPSZTEIN: Yeah, okay. 

DR. MAKHIJANI: Let me try to -- since we have 

talked about this, at least, let me see if 

we're formulating the issue right that is to be 

resolved. When -- when we talked about it in 

preparation for this meeting, Joyce pointed out 

that the unat-- there's a small fraction of the 

radon daughters, the lead and the bismuth, that 

are mobilized rapidly and you need to take that 

into account so that the 10-hour and 13-hour 

half-life doesn't apply uniformly because for 

the very small particles there's a few percent, 

according to ICRP-65 Annex B that says that's 

mobilized rapidly, but it doesn't say how much. 

Did I get that right, Joyce? 

 DR. LIPSZTEIN: Yes. Yeah, uh-huh. 

DR. MAURO: This is John Mauro, I -- I'd like 

to just step back a little bit from this for my 

own benefit so I could come to grips with this 

issue, recognizing it's a new issue. We, SC&A, 

did include in one of our reports -- in fact, I 
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think it had to do with the Y-12 report where 

it started. I'm not quite sure when we first 

put this in. I'm not --

 DR. LIPSZTEIN: I can't hear you, John. 

DR. MAURO: It might have been this one, but -- 

UNIDENTIFIED: (Off microphone) 

(Unintelligible) cannot hear you. 

DR. MAURO: Let me -- let me explain what my 

perspective is. We did a calculation using an 

ICRP model that presented doses to organs other 

than the lung so -- per picocurie per liter. 

Okay? That was incorrect. First let me get 

this on the record. We agree with -- with 

NIOSH that there are other -- there are other 

ICRP models -- documents that recommend against 

doing that and we -- we have since learned that 

and we agree. 

However, we've had lots of conversations 

regarding this matter subsequent to that, and 

the nature of those conversations led us to the 

point where though there are -- there is 

currently no accepted ICRP model for deriving 

the doses to organs other than the lung or the 

respiratory tract, those doses are still not 

insignificant. And the actual numbers that we 
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had in our report, which -- which we derived 

using these ICRP models that we shouldn't have 

used, are probably not that bad -- perhaps high 

by a factor of two or three, but the doses are 

-- given that there are other doses, such as 

the ones we've been talking about, the doses to 

these other organs are not insignificant. 

For example, as I understand it -- and please 

correct me if I'm wrong -- when dealing with 

1,000 picocurie per liter of radon in the air, 

assuming 50 percent equilibrium with progeny, 

the doses to these other organs could be on the 

order of a rem per year when you consider both 

the diffused radon into soft tissue together 

with these short-lived progeny, the portion of 

which might actually make it to these organs. 

Correct me if I'm wrong or if I -- am I off by 

an order of magnitude or am I in the right ball 

park, more or less? And if I am, is a rem per 

year to these organs something that is not 

insubstantial (sic), that's some thing that 

might be important if there are not other 

contributors? In my mind, if I'm correct with 

the one rem per year on that order, it's 

something that we just can't put aside. 
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DR. NETON: Well, I -- I think I indicated 

about five minutes ago that we believe it's 

probably about 600 millirem per year, just 

based on the gas distribution alone. And I'm 

puzzled -- I don't know that your numbers agree 

with our numbers within a factor of two. I 

think there's substantial disagreement in your 

calculations versus ours from the gas model. 

But with that said, the relevant issue is do we 

include it. I find it difficult to imagine 

scenarios where a worker receives 1,000 

picocurie per liter radon intakes and does not 

-- is not going to have ten to the sixth, ten 

to the seventh picocurie per liter -- or per 

day per year radium intakes and -- and other 

associated -- so I -- I think, though, it's 

relevant, and for completeness purposes I would 

be hard pressed to argue against adding the 

dose. 

MR. ALLEN: I will. 

DR. NETON: Dave -- Dave Allen may. But I 

think just from a transparency perspective and 

to indicate its relevance, I don't know how we 

could not. 

MR. ALLEN: This -- this is Dave Allen again, 
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and as Jim pointed out this morning I think, 

he's actually measured and I think a number of 

people have measured that the gas -- radon gas 

in the body dissolved in the tissues is 

eliminated from the body with about a 24-hour 

half-life. If somebody is breathing 1,000 

picocurie per liter air, then there's going to 

be a substantial amount of radon gas in there, 

yes, but it's going to be coming out in their 

breath for days. And our approach right here 

is if this is occurring every day like you 

would give them credit for if you assumed 1,000 

picocuries per liter, then there should be a 

substantial radon breath measurement that we're 

assuming is radon -- or radium, I mean, which 

is going to be substantially higher for any 

organ than the radon gas is going to be. So by 

not subtracting the background radon that these 

people have been breathing, we're already 

overestimating this by a great deal. 

DR. MAURO: I would say that's a very good 

point and thank you. 

DR. NETON: Very good point, Dave. I'm -- I'm 

glad you're here. 

 MR. GRIFFON: But that of -- that of course 
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assu-- I mean the radon issues would be in the 

same areas as the radium monitored workers, is 

that -- that's an assumption there, I think, 

that you have radon breath data for those 

people that would be in the areas where these 

radon exposures are of concern? 

DR. NETON: Well, that --

MR. ALLEN: That's somewhat of an assumption, 

yes, but I mean if we're going to allow credit 

for somebody breathing 1,000 picocuries per 

liter all year, then some of those got breath 

analysis and the coworker would have -- you 

know, same story with the coworker data. 

DR. NETON: I think Dave raises a good point. 

I mean if you -- you know, I think it's the -- 

the -- the Oswalt* solubility constant, not to 

get too technical here, is about 1,000th for 

radon partitioning between the atmosphere and 

soft tissues, so you would end up with an 

equilibrium concentration of about a picocurie 

per liter in your body and ventilating that. 

And with a 24-hour half-life, you would easily 

end up with about two-tenths to maybe threetenths of a picocurie per liter of radon gas in 

your breath on Monday morning when you showed 
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up for your radium -- radium analysis. So 

that's a very good point that that -- you know, 

by assigning the 95th percentile to these 

workers, it does end up bounding the -- 

bounding the whole -- the whole picture. I 

think that's a -- that's a very interesting 

approach. 

Okay, that was good. All right. And then that 

-- that gets us away from having to model 

things that have never been modeled before 

because, you know, I'm very reluctant to start 

modeling things outside the ICRP's 

recommendations. 

 MR. GRIFFON: Arjun has a comment. 

 DR. MAKHIJANI: Yeah, I mean this is -- this 

argument is a new argument and it seems 

reasonable on the face of it. It's an 

important issue because it goes to trying to 

model something, as Jim said, that has never 

been modeled, which is not a happy proposition 

given that there's no recommended ICRP thing. 

So this is a very important thing -- I just -- 

I just am saying this because I think this is 

an important item that needs to be sorted out 

very soon because quite a lot could turn on it. 
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 DR. LIPSZTEIN: Arjun, can you repeat again 

what (unintelligible)? 

 DR. MAKHIJANI: Yeah, Joyce, I don't know if 

you picked up what -- did you pick up what Dave 

said? 

 DR. LIPSZTEIN: No, no, that's 

(unintelligible). 

 DR. MAKHIJANI: Okay, what Dave said is that if 

you're breathing in hundreds of picocuries or 

1,000 picocuries constantly of radon, then some 

fraction of that remains in the body for quite 

a long time and it would show up in many of the 

workers who had radon breath analysis, and so 

you'd have had very high results in the tens of 

picocuries per liter maybe, or higher even, of 

-- of -- of radon in the breath. And that 

would be attributed as a radium intake -- first 

of all, they're not seeing that in radon 

breath, and it would be attributed as radium 

body burden, so anyway it'd be very 

conservative. 

 DR. LIPSZTEIN: But they took the radon breath 

measurements after Saturday and Sunday. 

 MR. GRIFFON: Yes. 

DR. NETON: That's correct, Joyce, but radon -- 
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radon has about a 24-hour half-life in the 

body. 

 DR. LIPSZTEIN: Yeah. 

DR. NETON: And so if you come into equilibrium 

with 1,000 picocuries per liter, you're going 

to have somewhere about a picocurie per liter 

in your tissues. And if you -- if you decay 

that out over the weekend, I still think that 

you're going to end up having measurable 

amounts of radon in your breath on Monday 

morning that would be attributable to radium 

intake. 

 DR. LIPSZTEIN: I'm not sure, and I don't know 

how you can come out of the modeling anyway. 

DR. NETON: I'm sorry, I didn't understand what 

you said. 

 DR. LIPSZTEIN: I don't know how you can 

(unintelligible) the modeling anyway because 

you have -- you have something that is 

attributed -- attributable to radium and 

something that could be of the radium itself, 

so (unintelligible) measures, so you have to go 

out to modeling (unintelligible) again, and -- 

and the model is not -- is not going out of 

ICRP modeling. We are not doing that. The 
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only thing we are doing is putting another 

half-life in the lung, that's all. 

DR. NETON: Right, but a half-life is based on 

one publication that -- I don't know. 

 DR. LIPSZTEIN: Yeah, (unintelligible). 

DR. NETON: But do you not agree that the radon 

breath measurements would bound and be higher 

than just modeling the radon dose to the 

tissues? 

 DR. LIPSZTEIN: I'm sorry, can you repeat -- 

DR. NETON: If you assume radon breath 

measurements on Monday had a component of the 

radon gas that they breathed at the workplace 

and we would then be conservative in assigning 

those to radium intakes, not radon intakes. 

 DR. LIPSZTEIN: Uh-huh. Yeah, but -- but you 

don't know how much comes from one and how much 

comes from the other. 

DR. NETON: I know, but if we assume that it's 

all from -- from radium, the doses to the 

organs are going to be much higher than the 

doses that are from the radon daughters. 

 DR. LIPSZTEIN: Right, that's true. 

DR. NETON: I think that's the point, that -- 

you know, per unit intake, you're going to have 
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-- if you assume a much higher radium burden, 

you're going to give higher radium doses than 

if you -- just from the radon, so -- we -- we 

can work this out I think and -- 

 MR. GRIFFON: I think that we --

 DR. LIPSZTEIN: I think (unintelligible) the 

numbers on (unintelligible). 

DR. NETON: We'll have to -- we'll have to 

develop a -- an approach and a position on this 

 MR. GRIFFON: Yeah. 

DR. NETON: -- but I think -- I think this is 

very well worth -- worth fleshing out, and I 

don't think it would be that difficult to -- to 

document in fairly short order. I mean at 

least the approach. 

 MR. GRIFFON: I think I -- I agree with Arjun 

that I'd like to see it laid out. It sound --

DR. NETON: Sure. 

 MR. GRIFFON: -- sounds reasonable. The other 

question I have is, you know, there might be a 

-- a cut-off where you're not able to detect it 

in radon breath, and it might still be fairly 

significant dose. It might be a couple hundred 

rem -- millirem --
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DR. NETON: Right, but remember we're assuming 

a minimum of .1 picocuries per liter as a 

detection limit for -- for radon in breath. 

 MR. GRIFFON: Right. 

DR. NETON: And even if it's less than that, 

we're going to assume that that's the minimum 

that a person breath-- is exhaling. 

 MR. GRIFFON: Oh, okay, yeah. 

DR. NETON: See what I'm saying? So --

 MR. GRIFFON: So your cut-off's -- yeah. 

DR. NETON: -- so that the cut point is going 

to be above whatever you're saying is in the 

radon breath to begin with. 

MR. ALLEN: Yeah, I think --

 MR. GRIFFON: That's right, 'cause you're doing 

the coworker --

DR. NETON: Yeah, yeah, yeah. 

 MR. GRIFFON: I was thinking if they had their 

own data. 

MR. ALLEN: I think the simplest approach to 

demonstrate it would just be to go through 

these four examples we already have here on the 

table, and I could simply assume, you know, the 

coworker radon inhalation and then sub-- 

DR. NETON: Compa--
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MR. ALLEN: -- you know, for those years and 

then subtract that -- what would be coming out 

from the radon inhalation from the radon breath 

analysis, which would lower the radium intake 

and simply compare doses. And I -- I'm pretty 

confident what the answer's going to be on 

that. 

DR. NETON: Yeah, I think (unintelligible) some 

-- yeah -- something of a 30-minute effective 

half-life versus radium -- 

MR. ALLEN: Right. 

DR. NETON: -- is going to be much 

(unintelligible). We'll work on that. We'll 

take that as an assignment. 

 DR. WADE: Yeah, I mean I think we'll leave 

here with the understanding that NIOSH and SC&A 

will have further discussions on this issue 

prior to SC&A preparing their report. 

DR. MAURO: Yeah, I'd like to add that this 

strategy for resolution appears to be in the 

right direction. The arguments that I've heard 

seem to be a way to get by this issue in a -- 

in a claimant-favorable and scientifically 

valid approach. I'd like -- certainly we need 

to see the write-up, but I'm impressed with 
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this line of -- this strategy as being the 

solution. 

 DR. WADE: So I would encourage NIOSH to 

prepare materials as quickly as you can on this 

issue, share them with your colleagues prior to 

their issuing a report. 

MR. ALLEN: And who should I work with on this? 

I'm assuming I'm going to work on this one. 

Right, Jim? 

DR. NETON: That's correct. 

 DR. WADE: Jim -- Jim as your point of contact 

to John, and then John can -- 

 MR. GRIFFON: Yeah. 

MR. ALLEN: Okay. 

 MR. GRIFFON: I think we're on to number three, 

aren't we? 

DR. NETON: Yes, number three. Okay, 

application of correction factors for external 

doses to organs. It was raised in the profile 

review that there were certain geometries that 

-- Hans, are you there? 

 DR. BEHLING: Yes, I am. 

DR. NETON: Okay, I'll try to speak into the 

microphone. 

 Tim Taulbee, are you on the phone? 
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 MR. TAULBEE: Yes, I am. 

DR. NETON: Okay, good, we've got key players 

here. 

So, you know, it was -- we modeled, as -- as 

indicated in the draft Technical Information 

Bulletin we put out, using this Attila 

software, what the differences might be to the 

-- the photon -- what the different photon flux 

ratios might be relative to a lapel badge 

versus a -- a lower torso organ when people are 

working with a non-uniform exposure geometry. 

And I think we had three examples. One was a -

- working on a -- on a derby or something of 

that nature. One was cleaning up a spill, and 

the other one was -- I forgot what it was now, 

but it was another close geometry situation -- 

a tank, right -- a tank -- oh, yeah, a pot, ore 

pot geometry. And those Attila -- those Attila 

calculations indicated to us that it is 

theoretically possible at least for a lapel 

badge to -- to underestimate a person's dose to 

a lower torso, and by that I mean the organs in 

the trunk below the lung, by up to -- well, by 

half. You'll be off by a factor of two if you 

use the lapel badge. It could be twice as high 
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to the lower torso under those modeled 

geometries. There were some differences, but I 

think the highest was -- 2.1 is what I recall. 

So that said -- and I should point out that we 

did not model the actual dose to the individual 

organs. The intent of this Attila run was to 

model the variation in the photon flux relative 

to the badge. So in other words, we modeled 

what the response to the badge on a lapel would 

be if it were worn on the appropriate portion 

of the thorax, the lower torso. So -- and then 

that's the number we would use to convert to 

organ dose. So I don't want there to be any 

mis-- misconception that we were trying to 

model organ doses. We're saying the flux ratio 

is a factor of two difference, therefore the 

dose to the badge would be a factor of two 

difference. 

So we -- we -- Tim Taulbee and Greg Macievic 

have written that into a Technical Information 

Bulletin. We're proposing to use that factor 

of two to adjust badges -- badge results for 

certain classes of workers. 

In going through the cases that we have to 

process, it appears to us that about 57 percent 
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of the workers, of the cases that we have, this 

correction factor may be applicable. That is 

workers who were identified as chem-- operators 

and building trades type folks. It would not 

be possible for us to determine with any degree 

of confidence that they weren't exposed to 

these close-in -- what we call close-in 

geometries. 

There are a remaining class of workers that we 

believe -- administrative in nature and 

security guards, those type of folks who were 

not working with these close-in operations -- 

that these factors would not be applied. 

That's our proposal. It's certainly open for 

discussion, but I think that summarizes it in a 

nutshell. 

Tim Taulbee, is there anything I've forgotten I 

need to add into this? 

 MR. TAULBEE: Nope --

DR. NETON: Okay. 

 MR. TAULBEE: -- not that I'm aware of, 

although there could be questions. 

DR. NETON: Yeah, sure. 

DR. MAURO: Hans and our crew got together and 

had numerous discussions on this matter. And I 
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guess we walk away with the concept that yes, 

your factor of two to account for the 

particular adjustment that is of concern here 

does satisfy our concern. 

 However, Hans Behling has pointed out that 

there are two other adjustment factors, and 

perhaps others, that probably need to be 

brought to the table at this time. One of them 

goes toward a concern we raised in our task 

three report -- in fact, a couple of them do -- 

whereby other adjustment factors might be in 

order, especially for lower energy photons, 

that could actually -- and I'm -- I'm giving 

you sort of like the preview, and I'd like Hans 

to speak to this -- could have another factor 

of two to perhaps factor of three effect on the 

multiplier. And I think that we'd like to sort 

of air that out today, and I'd like to give 

Hans an opportunity to -- to -- to discuss 

this. 

DR. NETON: Okay. Before -- before we jump 

into this -- this discussion, which I think 

could be quite lengthy, I'd like to suggest 

that this may fall into that category of is the 

profile adequate and are we doing a reasonable 
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job versus can we reconstruct doses for 

Mallinckrodt workers. In other words, I think 

we all have an agreement that the badge is the 

appropriate starting point, and we have a very 

large percentage of workers that were 

monitored. How we adjust those doses is -- is, 

in my mind, a refinement of the dose 

reconstruction and not an ability to do them 

with sufficient accuracy. But that's certainly 

open for discussion. I don't know. 

 DR. WADE: Well, I think we should hear from 

Hans. I mean I think you make your point, and 

John made it earlier, but I think let's get it 

on the table while we're here and then we can 

make that judgment. 

 DR. BEHLING: Am I on? 

DR. NETON: Yes. 

 DR. BEHLING: Okay. During the last Advisory -

- full Advisory Board meeting that took place 

on July 5 through 7, I presented a summary 

report on our task three assessment, which 

looked at all of the various procedures that 

were used in dose reconstruction, including the 

Implementation Guide 1 that deals specifically 

with external dosimetry issues. And I made a 
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couple of points then and said I wasn't going 

to discuss any of the technical issues because 

we had at that point in time not really had a 

discussion with NIOSH and without any potential 

technical findings, which is the normal 

protocol. But given the fact that the SEC 

petition for Mallinckrodt is somewhat imminent 

and pressing, it was a internal decision on the 

part of John Mauro and Arjun and myself to 

perhaps air a couple of issues that may have a 

significant impact on -- on the impending SEC 

petition. 

And let me just talk about two particular 

points. First of all, I do agree with the 

multiplier of two that deals with the geometry 

that Jim Neton just explained, which 

essentially does nothing more than make a 

correction for certain tissues that are much 

closer to the source term than the lapel badge, 

mainly tissues such as the male testes, the 

colon, the rectum, the prostate, et cetera, 

which would certainly be -- be covered by this 

multiplier of two that Dr. Neton just finished 

discussing. 

However, there are a couple of issues that go 
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beyond that, and one of them is the issue of 

the uncertainty surrounding the response of a 

film badge or TLD to a radiation field. In the 

OCAS Implementation Guide 1 we -- we talk about 

different components of uncertainty and yet in 

the end restrict ourselves to really only one. 

And the three components are laboratory 

uncertainty, radiological uncertainty, and 

thirdly, environmental uncertainties. And of 

course the laboratory uncertainty deals 

specifically with the processing of the 

individual badge in terms of film development, 

the time of exposure, the temperature of the 

bath and so forth and (unintelligible) to find 

an uncertainty for that. On the other hand, 

the implementation guide does provide a very, 

very difficult process by which this 

uncertainty needs to be calculated, and we've 

already mentioned that to NIOSH. 

What is really not included in the uncertainty 

in numerical terms is the second component, 

namely the radiological uncertainty, and that 

incorporates, among other things, angle of 

dependence. In other words, when we calibrate 

a film badge or a TLD, we usually have a single 
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point source that's mono-energetic, such as 

cobalt or cesium, and then the badge in 

question is pointing at the source term at a 

zero degree angle. In other words, the face of 

the badge points directly at the beam, and that 

gives you the maximum response on the part of a 

film or TLD. 

Once you rotate the film or TLD on its own axis 

in any form that deviates from zero degree 

angle, there is a significant reduction. And I 

pointed that out in our task three report. And 

so for instance, when you look at a photon 

energy of about 110 keV -- and I'm quoting this 

directly out of a textbook, (unintelligible) -- 

the -- at 90 degree angle, a -- a film 

dosimeter would only respond to about 16 

percent of what it would respond to in terms of 

a zero degree position. And so angle 

dependence is a very critical element that has 

to be looked at, especially for very low energy 

photons. The angle of dependence does diminish 

with increased photons and at one MeV can be 

somewhat ignored. But for very low energy 

photons, angle of dependence is a very, very 

critical issue. 
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Also the issue of back-scatter. It's uncertain 

from looking at some of the procedures whether 

or not the back-scatter is incorporated into 

the dose calculations, including the DCF. In 

my task three report I identified the 

variability of back-scatter as a function of 

photon energy, and of course the size of the 

medium which serves as the back-scattering 

source. And they can contribute a significant 

amount of -- of dose that may or may not be 

currently being taken into consideration. 

So on the -- on the issue -- and of -- I guess 

thirdly I want to mention is another issue that 

was mentioned in the implementation guide but 

not necessary (sic) addressed and that is the 

environmental uncertainty. And on 

environmental uncertainty are issues that, for 

instance, look at the response of a dosimeter 

based on ambient temperature, especially in a 

very hot and humid environment where moisture 

can potentially introduce a certain level of 

uncertainty, as well as temperature. 

So those are the three major components, and in 

combination they will significantly exceed, I 

believe, the uncertainties that's currently 
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being assigned to both film and TLD under the 

guidance contained in the Implementation Guide 

1. 

 Having said that, let me move on to the second 

and perhaps more important issue that is also 

something that I identified in the task three 

report, and that is I looked at the dose 

conversion factors and I've come to the 

conclusion that there is a systemic problem 

here that affects the accuracy of dose 

conversion values. I have looked over the 

implementation guide and fully concur with the 

methodology that was used in arriving at these 

DCFs, but also concluded that the methodology 

is inappropriate for the use in dose 

reconstruction when the starting point is 

actually a -- an empirical measurement that's 

registered on a film or a TLD. 

And in preparation for this particular 

discussion, I had asked Arjun to perhaps -- or 

John -- to distribute to you one of the pages 

from the Implementation Guide Appendix B that 

identifies those conversion values. And the 

one that I think exemplifies the issue most is 

the dose conversion value for the female 
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breast, and I will briefly first ask if the 

Board members have been given a copy of that 

particular page. 

DR. MAURO: Hans, this is John. I have to 

apologize, I did not hand it out. I do have it 

in my hand. What -- what page number was that 

in OCAS-1? 

 DR. BEHLING: It's on page 67. 

DR. MAURO: Okay, I have -- I'm holding it in 

my hand now. Perhaps we could have a copy made 

and -- and pass it around, if that's not a 

problem. I -- Hans, I'm going to be getting a 

copy of it. It looks like it should be ready 

in a minute or two. 

 DR. BEHLING: Okay, I might want to just 

already start --

 MR. GRIFFON: Wait --

 DR. BEHLING: -- the conversation because -- 

 MR. GRIFFON: You know what, Hans --

 DR. BEHLING: -- (unintelligible) --

 MR. GRIFFON: Hans, can I interrupt? This is 

Mark Griffon. 

 DR. BEHLING: -- to a lengthy discussion, but 

let me (unintelligible) --

 MR. GRIFFON: It's hard to interrupt Hans. 
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 DR. BEHLING: -- by pointing out 

(unintelligible) I've elected to use the female 

breast as the sample that best exemplifies the 

concern I have regarding the DCF for the 

following reasons. 

It turns out that the female breast is 

anatomically at the location most people would 

be wearing either the film or TLD, and so 

therefore we can eliminate one of the issues 

about location because they turned out to be 

coincidental in terms of location for -- for 

moni-- personnel monitoring. And so let me go 

through and identify -- 

 MR. GRIFFON: Hans, can I interrupt a second? 

 DR. BEHLING: Yes. 

 MR. GRIFFON: This is Mark Griffon. We're --

we're just going to -- we're getting a copy, 

and it's a good time for us to take a break. 

 DR. BEHLING: Okay. 

 MR. GRIFFON: So would you mind if we can get 

the copy and then we'll address this on the 

other side of the break. Also I -- I want to 

keep in mind -- I think, my opinion at least, 

is that this is a -- an issue -- a program-wide 

issue. I don't know that it -- it reflects on 
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this discussion that we're having about 

Mallinckrodt. I think it could affect many 

sites if it af-- you know -- 

 DR. BEHLING: Yes, (unintelligible) -- 

 MR. GRIFFON: -- if we -- if we go that route. 

 DR. BEHLING: -- (unintelligible) --

 MR. GRIFFON: But we'll hear -- on the other 

side of the break you can lay out the issue, at 

least, and then we'll move on from there I 

think. 

 DR. BEHLING: Okay. 

 MR. GRIFFON: Is that okay? Okay. Let's 

break. 

 (Whereupon, a recess was taken.) 
_____________________ 

189 

C E R T I F I C A T E OF COURT REPORTER 

STATE OF GEORGIA 

COUNTY OF FULTON 

 I, Steven Ray Green, Certified Merit Court 

Reporter, do hereby certify that I transcribed 

the above and foregoing from the day of Aug. 4, 

2005; and it is a true and accurate transcript 

of the testimony captioned herein. 

 I further certify that I am neither kin 

nor counsel to any of the parties herein, nor 

have any interest in the cause named herein. 

 WITNESS my hand and official seal this the 

23rd day of August, 2005. 

STEVEN RAY GREEN, CCR 

CERTIFIED MERIT COURT REPORTER 

CERTIFICATE NUMBER: A-2102