This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

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

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1716 14TH ST. NW, STE. 200 

(202) 234-4433 WASHINGTON, D.C. 20009-4309 http://www.nealrgross.com 

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Sandia National Laboratories Working Group

Monday, April 11, 2022 

The Work Group convened via Video Teleconference 

at 11:00 a.m. EDT, Henry Anderson, Chair, 

presiding.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

2 

Present: 

Henry Anderson, Chair

Genevieve Roessler, Member

Josie Beach, Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Tim Adler, ORAU Team

Bob Barton, SC&A

Ron Buchanan, SC&A

Grady Calhoun, DCAS

Nancy Chalmers, ORAU Team

Joe Fitzgerald, SC&A

Eloy Giron, Petitioner

Rose Gogliotti, SC&A

Joe Guido, ORAU Team

Pat McCloskey, ORAU Team

Chuck Nelson, ORAU Team

Stephen Pittman, ORAU Team

Michael Rafky, HHS OGC

Lavon Rutherford, DCAS

Mutty Sharfi, ORAU Team

Matthew Smith, ORAU Team

Dan Stempfley, ORAU Team

Tim Taulbee, DCAS
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Sandia National 

Laboratories Working Group Monday, April 11, 2022

1

Welcome and Roll Call/Instructions 4

NIOSH Presentation: Overview of SEC-00188 

Sandia National Laboratories Petition 

Evaluation Report and Description of PostApril 2019 Activities with Timeline 5

SC&A Presentation: Review of SEC-00188 

Sandia National Laboratories Petition 

Addendum 2 (Jan. 1, 1997-May 21, 2011) 18

Work Group Discussion 46

Petitioner Comments 52

Work Group Discussion and Path Forward 54

Adjourn 78
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

4 

Proceedings

(11:00 a.m.) 

Welcome and Roll Call/Instructions

Dr. Roberts: Good morning. Welcome to the 

Advisory Board on Radiation and Worker Health. 

This is the rescheduled meeting of the Sandia Work 

Group. I'm Rashaun Roberts. I'm DFO for the Board. 

There is an agenda for today. It's on the NIOSH 

website under Scheduled Meetings for April 2022. 

Since Board members who have conflicts with 

regard to this Site can't sit on this Work Group, 

there are no conflict of interests for the Work Group 

members. As I do roll call, however, other staff 

need to state any relevant conflicts as I move 

through the roll call. So let's go ahead and start 

with the Work Group chair, Anderson.

(Roll call.)

Dr. Roberts: Thank you everybody, and welcome 

again. I just need to go over a couple of additional 

items before I give the floor to Dr. Anderson, who's 

the chair of this Work Group. So let's keep things 

running smoothly, make sure that everyone can be 

clearly understood by keeping your phone or Zoom 

on mute when you're not speaking.

The mute button for Zoom is in the lower left-hand 

side of your screen. If you're attending via 

telephone, a *6 to mute if you don't have a mute 

button. If you need to take yourself off, press *6 

again. The agenda, the presentations and 

background documents that are relevant to today's 

meeting can be found on the NIOSH/DCAS website, 

and all of these materials were sent to the Board 

members, the Work Group members prior to this 

meeting. So with that, I will turn the meeting over 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

5 

to Andy. 

Dr. Anderson: Well, I want to welcome everybody, 

and I'm glad to see the whole complement of 

NIOSH folks are here. The last time when we tried 

to meet, there were some problems going on, and 

I'm glad. It sounds like everything is pretty well 

resolved. So today we're going to review the Sandia 

Laboratory report, and we'll begin. This is on the 

overview of SEC-00188, and NIOSH is going to 

begin their presentation with the overview.

NIOSH Presentation: Overview of SEC-00188 Sandia 

National Laboratories Petition Evaluation Report and 

Description of Post-April 2019 Activities with 

Timeline

Mr. Nelson: Yes Dr. Anderson. This is Chuck Nelson. 

First of all, I'll apologize. I had a family medical 

emergency the morning of. It was like an hour and 

a half prior to, but that person is doing well and I do 

apologize for that, so I'll go ahead and try to share 

my screen here. Can everybody see that? It should 

be coming up.

Member Beach: Yes.

Dr. Anderson: Yes.

Mr. Nelson: All right. What I thought I'd do is I 

would go back over the initial presentation that we 

did some time ago. It was April 17th, 2019, as it 

was at the Advisory Board meeting. So I'll go ahead 

and move through this presentation. I think I might 

take myself off so you can see me too, just for this 

part anyways.

Okay. Here's a summary of the SEC-00188 petition 

history. It qualified as A-313 October 21st, 2011. 

The Petitioner proposed a class definition of security 

inspectors, clerks, firemen and many other officers 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

6 

and personnel at the Site for the period of January 

1, '63 through May 21st, 2011.

During the evaluation process, NIOSH proposed that 

the following class be added as a SEC on February 

21st, 2012, and that would have been all personnel 

that worked in any area at the Sandia National Lab 

in Albuquerque, New Mexico for the period of '49 

through 1994. So that SEC was in fact granted. The 

basis for the '49 to '94 class was insufficient 

monitoring and information to reconstruct internal 

doses from January 1, '49 through December 31st, 

1994, and that was due to a lack of internal 

monitoring program documentation as well as lack 

of internal monitoring data and were also lacking 

some process information for that period of time.

As I mentioned in the previous slide, the evaluation 

report was published on February 21st, 2012, and it 

concluded that external doses including medical Xrays performed on site, as conditioned upon, it can 

be reconstructed for the duration of the evaluation 

period, which was again January 1, 1949 through 

May 21st, 2011.

NIOSH continued the evaluation since the 

publication of the 2012 evaluation report. We've not 

identified any information that would contradict our 

conclusion that external doses can be reconstructed. 

I got behind guys. Let's see. Apologize. Okay. There 

was an addendum to SEC-00188, which covered the 

time period of 1995 to 1996.

In its addendum, NIOSH proposed the following 

class be added to the SEC on July 26, 2018, and 

that covers all personnel that worked in or near 

Sandia National Lab, Albuquerque, New Mexico for 

the period of January 1, 1995 through December 

31st, 1996. The basis for this additional class for the 

1995 and '96 period was that there were internal 

monitoring concerns and what we called air 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

7 

monitoring data deficiencies.

We had some uncertainties associated with the 

transitional and developmental nature of Sandia 

National Lab-Albuquerque internal monitoring 

program. We found evidence that the Site was 

making several improvements in the internal 

monitoring program, including the increased use of 

personal and air monitoring. However, the program 

seemed to be lacking formalization and that we did 

not find adequate evidence in that '96-'97 period 

due to some key implementing procedures didn't 

seem to be fully in place until that time period.

Our most current evaluation report is SEC-00188, 

Addendum 2. The focus of Addendum 2 was 

determining if internal dose reconstruction was 

feasible for the 1997 through May 21st, 2011. The 

evaluation report focused on the suitability of the 

monitoring program and associated documentation 

and monitoring data sufficiency. In addition, the 

evaluation report addressed security guards' force 

monitoring concerns. Is my slide showing up there 

everyone?

Dr. Roberts: Yes they -- yes, they sure are.

Dr. Anderson: Yes.

Mr. Nelson: Okay, thank you. My screen changed a 

little bit and everybody kind of disappeared. So I 

wanted to make sure that I wasn't out there by 

myself talking. Okay. The following are some data 

sources the NIOSH team reviewed for SEC-00188 

Addendum 2. We performed 21 interviews with 17 

people. There was one additional site data capture 

effort trip since the last SEC designation. We had 

four data capture requests and there were over 900 

relevant documents captured or reviewed since 

SEC-00188 was issued in 2012.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

8 

To date, we have over 5,500 total documents in our 

database pertaining to Sandia-Albuquerque 

including internal procedures and memos, 10 C.F.R. 

835 compliance self-assessment reports, and those 

memos associated; facility process information; 

radiation work permits; incident data; air 

monitoring data; internal and external radiological 

program audits and assessments. 

We also had extracts from Sandia's WebDose 

database. This is what the Site uses for bioassay 

monitoring results, as well as their radiation dose 

reporting tool. We have internal/external monitoring 

records, breathing zone and air sample records and 

derived air concentration records. 

Okay. This slide here shows the available internal 

monitoring urine bioassays in WebDose. So the first 

column is the non-tritium bioassay results. That 

would include uranium, plutonium, americium, 

thorium fission and activation products. You'll see 

that the totals to about the 2020 results. Total 

people is 317, that's the next column.

If you add all those columns up, it's not going add 

to 317. It will be a higher number because many 

people were monitored for, you know, each year. So 

the total number is going to be less than the sum of 

those columns. The next column is the tritium 

sample results. We have 7,209 tritium results and 

the persons sampled were 362. Okay. This slide 

here shows the number of whole body 

measurements and thyroid counts. They total about 

1,115 measurements with 207 folks monitored.

Again, the last columns aren't going to add up to 

207. As I mentioned before, some of those same 

people are sampled for each year. Now the following 

is an overview of the Site's internal monitoring 

program. Of note, Sandia shifted their emphasis of 

internal monitoring from reliance on bioassays to 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

9

the use of breathing zone samples as a primary 

benefit of internal monitoring that started in 1995.

It was Sandia's position that no individual is likely to 

receive the exposure of 100 millirem in a year, and 

that's stated in CEDE, in both the internal technical 

basis document. It was also concluded in some 

external assessments before 1996 and 1997. Sandia 

used what was called a confirmatory bioassay 

monitoring program.

As I mentioned previously, BZ monitoring was a 

primary method of internal monitoring, but the Site 

didn't rely solely on bioassay to assess the potential 

for internal dose. The Site stated they focused on 

engineering controls, the use of personal protective 

equipment including respiratory protection, as well 

as contamination and air monitoring of the 

workplace to provide an indication of potential 

exposure. 

So if they saw an upset condition, be it from a 

breathing zone sample or air monitoring or 

something unusual at the work site, then that would 

indeed trigger bioassay monitoring. We saw that 

looking at some incident reports. The Site changed 

their emphasis from internal dosimetry to internal 

radiation protection and reliance on other types of 

monitoring to be indicative of the need for bioassay 

to ensure workplace controls were adequate. 

I mentioned earlier about the assessment in '96 and 

'99, where they came to the conclusion that the 

Site, it was an internal dosimetry expert that came 

on site, evaluated the Site and said that are not 

likely to exceed 100 millirems CEDE in a year. If you 

might remember, 10 C.F.R. 835 requires that rad 

workers under typical conditions are likely to receive 

-- that are likely to receive a committed effective 

dose equivalent of 100 millirem in a year are 

required to have an internal monitoring program. 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

10

So moving on to the next slide. During our review of 

Sandia's radiological program, we found evidence of 

implementation of Sandia's internal dose monitoring 

program. There was a February 3rd, 1998 

document. It was a summary document from the 

Rad and Mixed Waste Management facility regarding 

the routine bioassay, where they stated the RCTs of 

the Rad Waste and Mixed Waste facility are on 

routine bioassay.

If a trend develops indicating internal dose, those 

people would undoubtedly be asked to -- the other 

rad waste/mixed waste personnel will undoubtedly 

be asked to submit special bioassay to determine 

the scope of the problem. It went on to say that if 

trends develop indicating elevated air 

concentrations or increased surface contamination 

levels, special bioassays would be requested from 

the appropriate facility personnel.

Additionally, as stated, job-specific RWPs require 

bioassay as appropriate for those workers involved 

with tasks, where significant levels of radionuclides 

or where certain radionuclides are handled. So we're 

seeing that Sandia was performing some routine 

bioassay samples for specific groups of workers 

based on their work activity and job category for 

confirmation purposes, that the rad protection was 

adequately protecting workers.

Incidentally, as a refresher, the Rad Waste/Mixed 

Waste facility was completed in 1995, and it was 

used for repackaging waste, characterization of 

waste, treatment, storage and in some case 

shipments of waste. Looks like I'm off one here. 

Let's see.

Okay. Additional -- make sure I'm right on track on 

here. Okay. Additional evidence of field 

implementation, there was a May 30th, 2001 memo 

documenting a routine bioassay program for RCTs 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

11

at the TA-V, and it said the current schedule calls 

for annual whole body counting and submitting 

urine samples for uranium, thorium, americium and 

plutonium. The Sandia bioassay program is 

confirmatory in nature. The bioassay program 

confirms the results and the effectiveness of 

contamination control and other personal protective 

activities. 

It went on to say since RCTs must be present in all 

work activities where the possibility of meaningful 

intakes is credible, the bioassay serves as a good 

proxy indicator for potential exposed personnel. 

Okay. The NIOSH team reviewed RWPs, work 

planning documents for indication of airborne 

radioactive material. We wanted to look at the 

respiratory protection if assigned, personal and area 

monitoring and bioassay requirements. What we 

found were indications of surface and airborne rad 

materials were noted. We also found the use of 

respiratory protection, personal and area 

requirements and bioassay requirements.

Our review of RWP supports Sandia's rad program 

was adhering to the procedures in place at the time. 

As I mentioned earlier, Sandia National LabAlbuquerque shifted the emphasis of the internal 

monitoring program of reliance on bioassay to the 

use of breathing zone sampling. We performed an 

analysis of the breathing zone data that we have on 

hand. We evaluated the internal dose associated 

with each of these BZ filters in our holdings by 

calculating the intake quantity associated with each 

BZ filter. 

The committed dose associated with the internal, 

the intake quantities were then calculated based on 

the stochastic ALI, annual limit on intake for the 

limiting radionuclide of the analysis type. So we did 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

12

each for gross alpha, beta/gamma and tritium 

analysis results. Committed dose was analyzed to 

determine the distribution of data grouped by an 

event, and we defined an event as a rad work, 

radiological work task at a given time on a given 

day or all radiological work tasks on a given day.

Now the results of our analysis of breathing zone 

data was that the median quantity or rad material 

available for internal uptake to individuals in the 

unlikely event that they were located alongside of 

personnel performing higher risk radiological work 

can correspond to an internal dose of .5 millirem per 

work event or work day.

So this dose quantity assumes that an individual is 

present within the work area, and not wearing 

respiratory protection although we did find that 

respiratory protection is typically used in the work

areas when the radiological work was being 

performed. So we didn't take into account 

individuals would have a significant reduction in 

take potential by the separation of the actual work 

in the area that could be occupied by the same level 

of radiological controls, which is PPP and 

engineering controls.

And that considering these conservative 

assumptions, we concluded that it wasn't likely for 

an individual to be able to receive 100 millirem per 

year of internal exposure CEDE under these 

conditions. This table right here the assigned 

committed dose in REM by year. These values are 

the internal doses of record. They are provided in 

WebDose for the time period of '97 through 2011. 

So the first column is tritium. For the total 15-year 

period of '97 through 2011, there was a total 

assigned dose of 4 millirem for tritium. For the next 

column, it represents breathing zone samples and 

dose associated with those, and for that 15-year 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

13

period there was a total of 26 millirem of record 

assigned for that period.

The next column is urine bioassay, and for that 15-

year period there were 42 millirem assigned. Next 

column is thyroid. There were 5 millirems assigned 

from the 15-year period. So the total effective dose 

equivalent for the 15 year period from all those add 

up to 77 millirem. NIOSH included the feasibility of 

internal dose reconstruction from the 1997 through 

May 21st, 2011 evaluation period.

Based on our review of the reactive materials used 

at Sandia in associated rad programs, we concluded 

the intakes for unmonitored workers with access to 

controlled areas were unlikely to have resulted in a 

committed effective dose equivalent in excess of .1 

REM or 100 millirem per year. 

Our conclusion was that based solely upon the 

implementation of 10 C.F.R. 835, but rather on the 

review of exposure monitoring records for 

individuals involved in radiological areas with the 

highest risk at the Site during the evaluation period. 

The feasibility of dose reconstruction. In summary 

the total dose, the total assigned internal dose for 

all employees combined for this 15-year period from 

my previous slide, from '97 to 2011 was 77 

millirem. Our review of breathing zone data 

indicates, and this is basically a summary of our 

review, that the median quantity of rad material for 

internal uptake to individuals located alongside 

personnel performing higher risk radiological risk 

result in a -- would correspond to an internal dose 

of .5 millirem per work event or work week.

Again, this assumes individuals present in the work 

area alongside of another worker. It also assumes 

that no respiratory protection should be in use, so 

there's no respiratory protection factors being 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

14

applied to that raw data. In either case, it's our 

conclusion that a total recorded dose of 77 millirem 

is not -- supports that it's not likely that an 

individual will be able to receive 100 millirem per 

year of internal exposure per year under these 

conditions.

Our assessment of potential internal dose concludes 

the individual has to be present for 200 events, 

based on our calculated median dose of .5 millirem 

to receive an exposure in excess of 100 millirem per 

year. 

As previously identified in SEC-00188, the original 

evaluation report in 2002, NIOSH finds it's feasible 

to reconstruct medical doses and principal sources 

of external radiation and exposure including beta, 

gamma, neutron radiation for Sandia National LabAlbuquerque was of sufficient accuracy. As 

previously identified in SEC-00188, the principal 

sources of internal radiation for members of the 

proposed class include exposures to plutonium, 

tritium, uranium, americium in fission and activation 

products.

Potential exposure pathways could have involved 

the handling of these radionuclides during waste 

burial or handling, or exposure or air contamination 

associated with reactor or accelerator work. 

Considering the potential exposure scenarios, 

program policies and procedures, modern data 

available, NIOSH finds it able to estimate these 

internal doses with sufficient accuracy for this 

period.

In conclusion, based upon its analysis of available 

resources, we found no part of the class under 

evaluation for which we could not estimate radiation 

doses to a sufficient accuracy. 

The next slide is a standard slide showing that we 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

15

believe dose reconstruction is seasonal for internal 

and external doses. And again, we see no health 

endangerment for this period of time. 

The next table, after the ER was presented 

evaluation or Addendum 2 was presented in April 

2019, we received some additional breathing zone 

data from the Site to supplement our current BZ 

data. We did share this with the Work Group in 

March 20, 2020. As you can see, the first column 

was the prior available alpha results. That's the 

most important. Alpha results drive -- they 

constitute the highest dose to an individual.

So looking at that table there, the first one on the 

left, the additional is the additional breathing zone 

results that we captured. We got a big boost in 

2003, 2009 and '11. So we added 1,200, over 1,200 

available BZ results, alpha results, beta results from 

1,900, and we got additional tritium results of 138.

These additional BZ results did not affect our 

conclusion. The analysis really didn't change much 

at all, and while the BZ data provides more 

complete coverage of the period analyzed, the 

conclusions for each are still the same, that we can 

bound dose and that the individuals are likely to 

exceed 100 millirem per year of internal dose. 

I thought I'd fill in this timeline, just to show what 

happened since the April 2019 Advisory Board ER 

presentation. During that meeting, SC&A was 

assigned to perform a review of Addendum 2. They 

set up, at request of the Site folks, is they'd like us 

to come out and visit the Site and we did that in 

January 2020.

The Site visit included a focused tour and we had 

interviews in a conference room following the tour. 

In March 2020, we got all of our interview notes 

together and we sent them out to the Site for 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

16

review. As you may remember, that was the 

beginning of the pandemic, so there was some 

delay in getting some feedback from the Site, 

because they obviously weren't at full force.

So we did get comment back on August 24th, 2020, 

that the Petitioner and the participants had no 

comments on the interviews and tour notes. During 

the week of 11/9/2020, SC&A provided a report, 

their evaluation report. On December 4th, '20, 

SC&A submitted an OUO copy of the review to 

NIOSH and the Advisory Board. On March 1st, '21, 

Sandia National Lab provided an unclassified 

unlimited release of SC&A's review, and SC&A had 

one finding and seven observations.

On 6/30/21, NIOSH provided a response paper 

titled "NIOSH's response to SC&A's review of SEC00188, Addendum 2. Then on January 3rd, '22, 

SC&A submitted the reply to our response, and to 

DCAS and the Work Group, and that's all I have for 

this presentation.

Member Beach: I guess we're waiting --

Dr. Anderson: I guess I'd better unmute.

Member Beach: There he is.

Dr. Anderson: Yeah. Are there any questions that 

Board members would have before we move on 

here?

Member Roessler: I have no questions. That was a 

very nice thorough report, Chuck. 

Mr. Nelson: Thank you, Gen, Dr. Roessler.

Member Beach: I agree, thank you.

Mr. Nelson: Thank you Josie.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

17

Dr. Anderson: Just a question Chuck. Were there 

any measurements for the security folks? I think 

you have --

(Simultaneous speaking.)

Mr. Nelson: We'll let y'all answer, but with regard --

when you say measurements, I don't believe we 

have any breathing zones because I think for the 

most part they weren't working in those areas 

where the activities were taking place. 

There was some earlier bioassays I think in earlier 

90's, where there was a bit of an upset condition 

that resulted in I think a couple of millirem being 

assigned. That was, correct me if I'm wrong Joe, 

you know, but I think that was in the early 90's.

Mr. Fitzgerald: That's correct, yes.

Dr. Anderson: Yeah, and thank you. The other is 

during this particular period, were there any major 

upsets or events that would have brought in the 

security folks or others on a kind of emergency that 

might lead to other exposures?

Mr. Nelson: We didn't identify any. We did go 

through some of the incident reports and what we 

saw were if there were upset conditions like high air 

samples or maybe a breathing zone result that 

might have been higher than they expects or an 

upset condition, we saw that they sent people for 

bioassay, but no particular one that I'm aware.

Dr. Anderson: Okay, thank you. Any other questions 

people may have? Okay. Shall we move to SC&A's -

-

Mr. Giron: Chairman? Chairman? My name is Eloy 

Giron. I am the Petitioner for 00188. Am I allowed 

to address the Advisory Board?
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

18 

Dr. Anderson: I think we have you on the agenda 

later on. Is there a specific question? Rashaun?

Mr. Giron: Okay, sorry about that.

Dr. Anderson: That's okay, yeah. 

Mr. Giron: Okay, I jumped the gun. I'll wait til my 

turn. Sorry.

Dr. Anderson: Yeah. It won't be long. Thank you. 

SC&A Presentation: Review of SEC-00188 Sandia 

National Laboratories Petition Addendum 2 (Jan. 1, 

1997-May 21, 2011) 

Mr. Barton: Okay. I guess that means it's our turn. 

Let me share our presentation here and then I'm 

going to ask Joe Fitzgerald to sort of kick us off 

here, and then we can get into the breathing zone 

data, which I think is sort of the long, long haul 

intent here. So let me just go here. Does that look 

good to everybody?

Member Beach: Yes, that looks great. 

Mr. Barton: All right, excellent. Okay.

(Simultaneous speaking.)

Mr. Fitzgerald: Let me jump -- yeah, let me jump in. 

Thanks Bob. Can everybody hear me?

Dr. Anderson: Yes.

Mr. Fitzgerald: Okay, yeah. I'm going to keep the 

picture off, just because my broadband is pretty 

suspect these days. At any rate, I'm not going to try 

to repeat what some of the details that Chuck 

mentioned, but just again SC&A was tasked April 

2019. The report was actually issued December 

2020, but keep in mind that unfortunately the 

review kind of spanned the beginning and depths of 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

19

the pandemic, so there was considerable, you know, 

delay I think that occurred because of just the 

interactions and difficulty in communicating with the 

Site and what-not.

We are fortunate to get the Site review done just 

before things got really bad, so that was a plus. At 

any rate, this was the -- actually given the 8314 

reviews that NIOSH had completed before, this was 

the first time that SC&A actually had a chance to 

really dig in and evaluate Sandia in terms of the 

evaluation report.

So this is a bit of a hybrid assessment, where we 

were looking at the conclusions of the ER as they 

stood for issues like external dose, because this is 

again the first time that we actually had a chance to 

review those conclusions. And then looking more 

specifically at potential SEC questions, in this case 

involvement of internal dose as well as other issues 

that were raised in the course of the addendum.

So at any rate, on the first slide Bob. Can you flip to 

the next slide?

Mr. Barton: Yeah, I'm hoping it should be on the 

first slide.

Mr. Fitzgerald: Yeah, okay. There we go. 

Dr. Anderson: We got it, we got it.

Mr. Fitzgerald: Okay, good. This is essentially an 

overview of where we came out, and we'll get into 

the specifics here shortly. But on external dose, 

again we went back and looked at the conclusions, 

this being the first opportunity, and we agreed I 

think with NIOSH's conclusions that we really didn't 

see any issues that would preclude dose 

reconstruction with sufficient accuracy.

In the course of our review, we did, did pick up on 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

20

some issues though, that in the end we decided 

were of -- what's kind of called Site Profile 

significance. One of these in particular was the, the 

severe radiation gradients at the Sandia Pulse 

Reactor, and we'll get into more detail on that. But 

that was identified during the Site Profile 

assessment, and it involved some real differences in 

potential exposures, depending on where the 

worker was located relative to the reactor itself.

We thought that issue needed to be addressed, at 

least from the standpoint of more information for 

the Site Profile and dose reconstructor. On the 

internal, internal dose side, again we spent some 

time looking at the weight of evidence argument 

that was provided by NIOSH in its ER, and the basis 

for the conclusion of reconstruction with sufficient 

accuracy for the time period in question, '97 to 

2011. 

And we concluded that it was feasible. However, we 

felt there was some questions revolving around --

and we do this for every site now in terms of 

verifying or -- V&V, verifying, validating the 

completeness of the data. Even though the weight 

of evidence, I think, was pretty clear to us and 

persuasive, we had some difficulty finishing the V&V 

in terms of the available records.

We didn't think it impaired the dose 

reconstructibility involved, but we felt it was a loose 

end for which we needed more information or 

clarification from NIOSH. That was the basis for the 

one finding that we provided, and Bob will get into 

that particular issue here in a few minutes, and we 

had six observations.

The next one, please. Okay. How we structured the 

SC&A review is a little different than we've done in 

some other ERs. We wanted to focus on four key 

lines of inquiry, which we felt were the central 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

21

questions that needed to be answered for Sandia.

The first of these is -- it's just a lot of this revolves 

around weight of evidence. Is the weight of 

evidence sufficient for feasibility, in terms of 

external and internal dose assessment? 

As I indicated before, we thought that was a yes for 

external, and we also felt it was yes for internal, but 

again the validation process for some of the BZ data 

we think left some questions that we felt needed 

clarification. So that's how the response to the first 

came out. 

That may sound a little contradictory, but in a sense 

there were a number of factors, and you heard 

some of these from Chuck, that were involved in 

this so-called weight of evidence assessment of 

what data was available for Sandia. We felt there 

were enough BZ samples to reach a conclusion of 

feasibility, but there were still some gaps that made 

it difficult to complete the validation.

So again, I think that's maybe one key question 

that we want to unpack for the Work Group, and 

Bob will be doing that here shortly.

The second line of inquiry was the question of 835 

implementation, which is a question that is raised at 

a number of the sites. If you recall with the 

promulgation of 835, it required radiological 

monitoring for any potential exposures of 100 

millirem or up, and that was the threshold that 

NIOSH highlighted in its evaluation, and what was 

being used for monitoring purposes at Sandia.

So the question there was in the timeframe of in 

this case the end of '96, did the evidence point to 

not just the planned and programmed 

implementation of Part 835, but was there actual 

evidence manifest in the documentation and these 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

22

self-assessments, and DOE's response that would 

indicate that the 835 requirements for monitoring 

were actually implemented. 

I think in this case, you know, our review across the 

board, implementation plans, site verification plans, 

self-assessments, enforcement reviews and DOE 

and in correspondence with DOE and the Site office, 

we looked across all of that and felt that by the end 

of '96 that it was pretty clear that implementation 

was happening at Sandia relative to those 

requirements.

Next slide, please. Okay. The third line of inquiry 

was really relative to the usage of BZ sampling, 

personal air sampling as a prime basis for personnel 

monitoring. In this case, was that reliance in terms 

of the assigning 100 millirems CEDE dose, which 

was the dose reconstruction threshold or approach 

that NIOSH was following for Sandia, is this wellfounded and does the weight of evidence support 

that assignment?

And again, we felt that the available records and the 

conservatism that was laid out in the NIOSH 

approach in the ER was sufficient in this particular 

case, and this comes again with the asterisk that we 

need, need a little more validation. But overall, we 

felt the weight of evidence was persuasive that one 

could assign an 100 millirem CEDE dose for workers 

that lacked monitoring records.

The fourth line of inquiry involved the security 

guards at Sandia, and this issue was similar to the 

third issue, which is could they likewise be assigned 

100 millirem per year for unmonitored intakes, or 

was there evidence that there were exposure

intakes that would exceed that level? 

And we spent a considerable amount of time 

examining that particular issue. As you know, 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

23

security guards had pretty much free rein in terms 

of the surveillance at the Site. Certainly, the 

surveillance includes the whole spectrum of nuclear 

facilities and materials.

So we wanted to spend some time looking at not 

just the documentation but actually touring the 

physical locations, talking to the individual guards, 

checking incident reports, looking at the source 

terms that might be involved, looking at the 

dosimetry at the -- certainly the guards would be --

that you would be relying on in terms of dose 

assessments at the site, looking at non-routine 

exposures as well as routine exposures and what 

the history would tell us for that time period.

And where there were intakes, we wanted to look at 

what kind of doses were being achieved, and all of 

which would be done in the context of answering 

that question. Is there a likelihood that, or a 

potential that workers would be receiving intakes 

that would equate to 100 millirem or more per year.

Our conclusion was that no, we didn't feel, we didn't 

believe and we didn't come to a conclusion that that 

kind of level of dose would be likely given the 

exposures and the conditions at the site, and again 

I think this was one in particular that we spent 

probably most of the time on this evaluation 

examining, because again it's a somewhat difficult 

question because then you have to deal with, you 

know, the location of the guard force, the interface 

of the guard force with certain facilities and certain 

source terms, and looking at potential exposure as 

well as the source terms that might be involved. So 

it was, you know, probably a pretty challenging 

review.

At any rate, that is a fairly broad summary of what's 

in our assessment, without going into the specifics 

of the one finding and the observations that were in 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

24

that report as well. So this is more the overview of 

our conclusions. Before I turn it over to Bob, does 

the Work Group have any questions on the 

overview?

Member Roessler: No questions from me.

Member Beach: None here either, thanks Joe.

Dr. Anderson: Nope, maybe later. Joe, the only 

question I had is with -- is there's kind of two 

different issues. One is there's a qualitative, a 

qualitative assessment of the data, and I would 

tend to agree with this. The question then becomes 

well is there a quantitative assessment that can be 

done that is kind of a going forward when we 

address this at other sites, that might be a 

beneficial thing?

Mr. Fitzgerald: Yeah. I think that might evolve from 

some of the discussion that Bob's going to lead here 

right after this.

Dr. Anderson: Okay.

Mr. Fitzgerald: Because I think that was kind of 

what we were trying to deal with, was in the way of 

evidence, some of that is a qualitative balancing of 

what we have and the conservatism of all you have, 

and what we also try to do is our typical 

quantitative assessment of looking at the amount of 

data over specific years, and then trying to validate 

completeness.

Even though I think the qualitative was very 

persuasive, we did have some questions on the 

quantitative. Not questions that would undercut the 

conclusion but, you know, nonetheless questions.

Dr. Anderson: Okay, thank you.

Mr. Fitzgerald: Maybe we can circle back to that 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

25

after Bob does his presentation.

Dr. Anderson: Right, thank you.

Mr. Barton: Thanks, Joe. I'd just add that this SEC 

investigation is a little bit unique because we're not 

necessarily talking about formulating a co-exposure 

model based on all this data. It's really using this 

data as evidence for the exposure assignment of 

again the 100 millirem CEDE, and again that's only 

to unmonitored workers or partially monitored 

workers.

If you were actually on the bioassay program or 

submitting in vivo counts, those are what is typically 

used in your dose reconstruction. So keep that in 

mind as we go through, but I agree. I think some of 

that will become clear, but also when we talk about 

completeness it's sort of in a different context here, 

only because we're not relying on trying to get a full 

set of data to essentially create a co-exposure 

model. We're using the data to justify a bounding 

assignment of 100 millirem.

With that, let me move into -- so if there were 

further comments before I move forward?

Dr. Anderson: Well that's fine. Thanks, Bob.

Mr. Barton: All right. No problem at all. Finding 1. 

As we were just talking about, obviously the 

question of completeness comes up in every SEC 

investigation, and typically what we look for is some 

sort of secondary reference, which could be a health 

physics report, an industrial hygiene report, and 

these things would usually come out periodically at 

different sites, you know, quarterly, monthly, that 

type of thing.

Usually we report things like how many smears 

were taken, how many bioassays submitted and 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

26

what we were hoping in an ideal situation, the 

number of either readings on samples that were 

issued during a given period or at least the number 

of workers who wore them during a given period. 

So if we had that secondary reference, we would 

kind of take a look at the captured data set that 

NIOSH has and have a sense on where we're 

missing data, how much is missing from different 

periods of time and how does that affect the

conclusions regarding again 100 millirem, not 

necessarily any conclusion about actually creating 

the traditional co-exposure model.

So that was Finding 1, which was the sole finding of 

our review, that we believe that that data is 

incomplete and as you'll see NIOSH agreed with us. 

We have a number of observations directly related 

to the completeness of these BZ samples. But those 

issues, as we'll get to the end, we don't feel 

obviates its use in justifying the 100 millirem for a 

number of reasons which we'll get into, that are 

quantitative reasons rather than necessarily 

qualitative.

So NIOSH's response to this finding was that, right 

there in the first bullet, is that they agree the data 

set that we have is incomplete. Now that's not a 

game-stopper by any sense, and what we do and as 

you will see as we go through this evaluation, is we 

try to inform ourselves well, we're missing. 

We're missing data on a lot of sites. What can we 

investigate to get a sense of what that missing data 

might represent? Is there any evidence that the 

missing data actually represents a group of workers 

who were in a higher exposure category, at a high 

exposure potential?

One of the -- and then in NIOSH's response, they 

noted they did a comparison between what's known 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

27

as DAC-hour tracking logs (phonetic), and these 

things somewhat regularly. Essentially, they were 

identify the breathing zone results during that 

period that came to a certain level that needed to 

be tracked by Health Physics for compliance 

purposes. 

So NIOSH had these DAC-hour tracking logs, which 

is in a sense a secondary source because it 

represents the people who had breathing zone 

samples that needed to be tracked by Health 

Physics. So this would be the higher end exposures 

during any given period. These DAC-hour tracking 

logs were available from 1997 through 2002, with a 

few missing months in there, and we've got at least 

almost 1,000 samples in the DAC-hour tracking logs 

to compare with the raw data that NIOSH had 

compiled and captured.

And based on that, close to 99 percent of the ones 

found in the DAC-hour log books, which again would 

be considered the higher end exposure categories 

are available in the raw data set, which we're using 

as the basis or NIOSH is using as the basis for the 

100 millirem dose reconstruction approach. So the 

conclusion there is that even if we're missing data, 

there's no indication that based on this DAC-hour 

log book comparison that we're missing higher end 

exposures. In fact, it looks like we pretty much had 

almost all of them, which would indicate that even 

though we're missing data, it's not likely that it is 

biased low. In fact, it's even logical that it could be 

biased high in some groups. 

So a lot of this I just said, but again we reviewed 

the DAC-hour tracking reports in a similar manner 

that NIOSH did, and we agree that when you do 

that comparison, and again it is somewhat limited in 

scope in that we don't have any of these secondary 

sources to check after 2002. Overall, there's a little 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

28

over a third of the applicable SEC months that we 

can make comparisons.

But nevertheless, it's again part of a weight of 

evidence that the missing data don't, do not in fact 

represent a different exposure potential that would 

certainly warrant an SEC discussion. However, since 

completeness is, you know, obviously such an 

important part of any SEC discussion, we obviously 

needed to bring this to the Work Group's attention 

for discussion, and that is why this final bullet here 

says it should remain in progress, because it really 

hadn't been brought in front of you all.

So that discussion will hopefully happen today, and 

hopefully we can close some of these out. 

Moving on to Observation 1, and this really has two 

parts to it. In one part we had identified that in the 

data set there were some duplicate samples 

included, and the reason this happened is there 

were essentially two different references that really 

had the same data in them, and this was for 2002. 

But they were in slightly different forms and it was 

certainly difficult to tease out the fact that these 

were actually representing the same breathing zone 

samples. There were about 150 of them.

So we pointed that out as an observation due to the 

low number and the fact that it was only one year 

where we found that many. You know, we didn't 

think it rose to the occasion of being a finding, 

because if you simply remove those and redo the 

analysis, but you'll see it was done. That's the first 

part of the finding.

The second part of the finding has to do with a 

specific table in the ER that reports the number of 

readings about samples available for analysis. Now 

when we went through the raw data sheets that 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

29

NIOSH provided and compared it to that table in the 

ER, we were coming up with very different totals. 

So we tried to investigate what that was, and 

NIOSH provided their own spreadsheets where they 

did their own compilation of the data.

What we found was that in certain cases, and I have 

a theory on how this happened, but in certain cases 

you might have a single breathing zone sample for 

an exposure event, in which it was measured for 

alpha, beta and tritium, and now it appears as a 

single line in the data set. For another one, gross 

alpha, beta and tritium might appear on separate 

lines. That's what they counted three times towards 

the total, again in a specific table.

And NIOSH's response to this, for the first part, the 

duplicate samples they confirmed there were 

duplicates in there. So they correctly removed 

them, re-ran the analysis, and it had very little 

impact on the end result, which was very to be 

expected, one because there's a lot of no detect 

breathing zones in the data set, and also because, 

you know, 150, 148 is not a very large portion of 

the overall data population.

With regards to the second part about how they're 

reporting the breathing zones, again in that single 

ER table that we were trying to match up against 

the raw data, NIOSH in the response noted that a 

more appropriate comparison would be to a set of 

tables that appeared further down in the ER report, 

where they broke it out specifically into alpha, 

beta/gamma and tritium. Those totals more closely 

reflect what data there is to analyze.

NIOSH reiterated that analyzing each component 

separately is appropriately. As Chuck had indicated 

in his presentation, really alpha's the driver here by 

several orders of magnitude, compared to 

beta/gamma and tritium. 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

30

So moving along, and so here's where SC&A is at. 

While we agree the duplicate results were removed, 

re-ran the data and it had little to no effect on the 

end results, so that's good. It cleans that one up. 

Let's see here. So as far as that first part, we really 

think that first part can simply be closed. It was 

there were duplicates contained in the data that was 

analyzed, they were removed and the new numbers 

don't change anything.

On the second part about how these things are 

recorded in the original ER, the table that -- I'm 

getting a little feedback. 

That is G-I-R-O-N. I think that's where the noise is 

coming from.

Mr. Nelson: That might be Eloy Giron. If you could 

hit *6. 

Mr. Barton: Okay. That seems like it's gone, so let 

me continue. So this second part about how the 

total number of breathing zones available for 

analysis was reported, and the specific table is Table 

6-1e, and it's title is "Available Breathing Zone Air 

Monitoring Results for the SEC Period 1997 Through 

2011."

Now in response to this observation, NIOSH said the

tabulation for 6-1e is related to the number of line 

items of data available to NIOSH which -- with each 

line item potentially containing more than one result 

type. So we understand where this came from. It's 

really I think an artifact of how the data was taken 

from those PDF files, put into a database file for 

analysis, and that you might have a breathing zone 

result where the alpha result is on one page, the 

beta result is on the next page and the tritium result 

is on the page after that.

So a lot of times that was input as three separate 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

31

lines, whereas in another format it might be, have 

all alpha, beta and tritium on the same PDF page, 

unless they're put on the same line in the database. 

I think when the ER was constructed, NIOSH has 

line items they put in a mixed bag of both of those 

situations. So it's not necessarily showing the total 

number of measurements sort of by alpha, beta and 

tritium, and it's not the single number of breathing 

zone events or exposure events either. So like I 

said, it's a mixed bag.

So I think when that happens, it's a little misleading 

and will actually overstate the amount of data. 

Certain breathing zones will appear in that table as 

a total of three, and some of them will appear as 

only one. And so that's something that I'm not sure 

if it's -- in the report we recommended that 

certainly for accuracy, it would be good to correct 

that, either to the total number of measurements or 

the total number of breathing zone evens, not really 

a mix of both.

So I'm not, and again this is an observation. It does 

not affect the end results of the analysis in any way, 

but it's just about the accuracy of reporting the 

amount of data available from which we're drawing 

these different conclusions. 

Another note, as you'll notice from Chuck's 

presentation, there was actually more data received 

after the ER was published. So I'm not sure if that's 

something that would be updated anyway to reflect 

a second, essentially the second data set that was 

received to fill in some of the gaps as Chuck noted, 

especially in the later years. 

Mr. Nelson: Hey Bob, this is Chuck Nelson. If I 

might add, what we intended to do for that if there 

were reasons, we would like to revise a table and 

put it in the Site Profile. It would take out, you 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

32

know, the duplicate issue that we had as well as all 

these other additional data points, and we would 

provide a clear, concise table making the summary 

of BZ results clear and consistent.

Mr. Barton: I certainly don't have any comment. 

That's one solution. I guess the only -- I don't know 

how easy it is to revise an ER. I'm not sure of that 

process. But I guess I would just be concerned that 

if someone was looking back on this, they might 

look at that table in the ER and say well, look at all 

these years that don't even have data or have very 

little data, some of the other totals might be a little 

inflated.

Mr. Rutherford: Well, I'd like to jump in. This is 

LaVon Rutherford. I mean typically we don't revise 

the ERs. If you think about the -- we go through 

this, the Board review process, and everything 

changes from that Board review process. There's a 

lot of things we learn and a lot of things that, you 

know, that shift gears and move around through 

that process, such that we don't always, you know, 

we definitely --

I think we've revised maybe one or two over the 

past. You know another thing we could do is issue a, 

you know, a one-page memo with that updated 

table, and make that clear that's what we were 

doing, or that we have updated that table and made 

corrections based on some of the things noted by 

SC&A.

Mr. Barton: That sounds like it's certainly a viable 

and a perfectly good solution to me. But I guess it's 

really up to the Work Group. I'm not sure if you 

want to discuss this now or wait towards the end of 

the presentation, or simply leave it alone for now. 

Dr. Anderson: I think we can come back to it. I 

mean you've got a few to go. How do others feel? 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

33

You want to see about it and talk about it now or --

I think it would be better to do, just go through all 

your observations. 

Member Beach: Henry, I agree with that, just to go 

through.

Member Roessler: Yes. I agree to, because there 

might be some other things too that we want to 

treat as a group at the end.

Dr. Anderson: Yeah, okay. Moving right along.

Mr. Barton: Okay. If we could -- but again like I 

said, this does not affect in any way the 

conclusions. It's really just the accuracy of reporting 

essentially to the public what we actually had for 

analysis as part of the data. 

Okay, moving on to Observation 2. As Joe sort of 

intimated, one of the things you -- the very first 

thing that you look at from even a completeness 

standpoint is well, how do these things look at over 

time? You know, you wouldn't expect any Site to 

have a constant number of breathing zones, you 

know, by month or year or whatever.

So you expect some changes, but you wouldn't 

expect necessarily any gaps or just, you know, very 

large swings month to month. So that's what we 

looked at, and so our observation here is simply 

that, you know, when we looked at the -- on the 

data set that we do have, it certainly looks like it 

was not a complete data set, and this was sort of an 

observation to inform that first finding, because 

again we believe the data set is incomplete, but 

without those secondary sources of how many BZs 

were actually done at the Site in a given timeframe, 

we just have no way to know necessarily how many 

are missing.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

34

But again, back to the DAC-hour log sheets, we can 

say at least for those years up to 2002 when doing 

that comparison, it was close to 99 percent of the 

NIOSH data sets. So based on those years and 

those secondary sources, it appears that the ones 

we have if anything could be biased high, and 

certainly no indication that they were biased low.

For example, if we had gone into those DAC-hour 

tracking sheets and found that a large portion of 

those were not included in the NIOSH data set, then 

that would certainly be of greater concern. But the 

fact that there was such a high percentage included 

in their data set is one piece of evidence that if it's 

not representative, it's likely biased a bit high by 

some degree.

And so SC&A and NIOSH agree on that, and again 

this was part of informing Finding 1 as to why we 

believe that the data set is incomplete. It should 

really just be -- we recommend that it be subsumed 

under Finding 1, however that is eventually decided. 

So that's what I'd recommend for now. Unless there 

are any questions on that, I'll move on to 

Observation 3.

Dr. Anderson: All right. Just keep going.

Mr. Barton: All right. This has to do with WebDose, 

which is part of Chuck's presentation as well, and it 

was again well, let's look at this electronic database 

we have from the Site, and let's compare that 

against the hard copy records that NIOSH has 

captured and are used to justify the use of the 100 

millirem. 

That's compared with the observation that yes, 

WebDose doesn't appear to be a complete source 

either, but that since WebDose's purpose was really 

as a Health Physics tool to track the folks that you'd 

want to make sue were in compliance with the 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

35

applicable dose limits, when you compared 

WebDose against the raw data, it really is quite 

good. 

So again that's another weight of evidence that like 

the DAC-hour log books, what we have in the data 

set and NIOSH has captured for evaluation is either 

representative or biased high, and certainly no 

indication that it was biased low, which would be an 

issue for SECs.

So we looked at the WebDose and we compared it 

against DAC-hour and we agree, that those log book 

entries in the DAC-hours are in WebDose. So and 

the DAC-hour log books are often included in the 

raw data sheets. So there's really no indication from 

this comparison that we might be missing a 

population that we monitored via readings that we 

don't have the results, that they're potentially 

exposed at a higher level. This in fact would 

contradict that notion. 

So again, like the previous observation, since it 

goes really to completeness and what does that 

incompleteness really mean in the SEC context, we 

recommend that Observation 3 also be just 

subsumed under Finding 1 of the discussions, 

because Finding 1, Observation 2 and 3 are really 

all brought together.

The next thing we looked at was let's see how many 

breathing zone samples do we really have among 

the individual workers that we can identify in the 

raw data, because as you recall from Chuck's 

presentation, part of this is well, how much dose are 

we really getting per event, per exposure event 

monitored by breathing zone, and then how many 

such events would it take to really surpass that 100 

millirem threshold?

The answer from NIOSH is no. It says well you have 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

36

about a half millirem per event, and so it would take 

200 events to surpass the 100 millirem. So we said 

all right, you know. Part of this question is what's 

the chance there are folks out there who were 

involved in more than 200 individual events? Which 

does seem like a pretty high number, but if you 

were doing it every day maybe it's not.

So we looked into the data. We found that eight 

percent of the total that we have are actually just 

for a single individual. So there was one individual 

that had the large number of jobs that involved 

breathing zone monitoring. But nearly four-fifths of 

the worker population in our data set had 20 

breathing zone samples or fewer in a given year. So 

you apply that 20 to the 200 it would take to reach 

100 millirem. 

NIOSH concurred with the observation, and it does 

not affect the assumption, and we obviously agree 

on this one, and so we just consider this informative 

to the Work Group as to different ways we looked at 

this problem of incomplete data to convince 

ourselves of whether the proposed approach would 

truly be bounding. And again, bounding for 

unmonitored or partially monitored workers.

Observation 5. We wanted to compare. All right, 

well let's see these workers in the breathing zone 

database. Let's compare them against the nontritium bioassay program, to see how many were 

also submitting bioassays. Is it a high number, is it 

a low number, is it none of them? We found out that 

let's see, 79 and 194, that are actually in the 

breathing zone records also participated in the 

bioassay program.

We also noted that the 11 workers that we identified 

that had the most breathing zone results per year 

and this includes the workers with the most BZ 

results per year and also the 11 workers with the 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

37

highest number over the entire period were also on 

the bioassay program. So that would suggest that 

those who were most often involved in jobs required 

the breathing zone monitored were often already on 

a non-treating bioassay program.

And so this method of 100 millirem really wouldn't 

apply to a significant portion of this population 

because you used their personal monitoring records, 

rather than the 100 millirem, which again is applied 

to the unmonitored worker. SC&A concurred, I'm 

sorry, NIOSH concurred with SC&A's observation 

here, that you know those workers, at least in the 

data set we have that have the most exposure 

events, also typically were already on the bioassay 

program. 

The other thing is to look at the actual exposure 

potential, and this is where the .5 millirem per 

event comes in. If you wanted to look at how, well 

how does this look on a yearly basis, because you're 

going to expect if you have analyzed the data over a 

long period of time like 1997 to 2011, you're going 

to have fluctuations by year. 

It's not like -- it's going to be lower in some years, 

higher in other years. Are there certain years where 

we should really be concerned about it? Are there 

certain areas in years where it looks like it's simply 

not going to be bounding for that particular strata of 

worker? I'm going to show a couple of charts real 

quick. 

You know, we did do a pretty significant breakdown 

in the report. If you look at Figures 5 through 8, 

that's just the percentage of different metrics that 

we looked at, and this is -- that use that -- 5 

through 8 are not necessarily exposure. But Figure 

5 was we looked at how it was distributed by 

general work area by year. 6 was the test by year, 

7 was radionuclide of interest by year and then 8 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

38

and 9 were respiratory protection used by year. So 

you can kind of get a sense of how these different 

things changed when we look at --.

There is one where this is actually using SC&A's 

evaluation of a dose. So the red line there, that's 

pointed out as a full SEC period dose value. That's 

where SC&A calculated from the entire data or the 

entire SEC period. That, I think, came out a little bit 

lower than NIOSH's estimate actually just because 

we used slightly different methods on how to deal 

with less than detection values and such.

But as you can see, like I said you're going to have 

fluctuations. Some years they're above, some years 

they're below, and I did this as a ratio for the very 

specific reason that there's a lot of factors that I'm 

going to go over at the very end of this 

presentation. So I wanted you to get a sense for 

how much it might go up by year, and as you can 

see, at the median level it can be as high as a little 

over a factor of two.

But again, just keep that in mind when we talk 

about how we did these exposure assessments and 

things like not including respiratory protection, 

which when you consider the protection factors that 

the different types of respirators will give you, it's 

much greater than two. And so we did not find 

these worrisome, although it's certainly an analysis 

that we wanted to point out.

If we found, you know, certain years where you're 

sitting at factors of, you know 50, 100, certainly it 

would be much more worrisome.

This looking at it by the area, and again that's 

SC&A's calculation for the entire period and again, 

this is a ratio. Now you can see that in those first 

two years, you can get up around a factor of six. 

And again, if you're thinking about respiratory 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

39

protection factors, that really is not very significant 

from that standpoint.

I can add, just for everyone's edification, I was -- I 

was looking specifically at those first two years and 

at 6580, and that's where the hot cell facility was. 

Especially in 1997, a very large portion of the 

breathing zone results were simply from that area. 

But the other thing I looked at was for those two 

years where it looks, you know, while you have a 

factor of six, is that something to worry about. 

Those work in the hot cells. Really, I think in the 97, 

about 96 percent of those breathing zone jobs 

involve respiratory protection of varying degrees. I 

think it was a little further down or 85 percent in the 

next year.

So you know, those two results look high. They 

don't consider any of that, whereas working in that 

hot cell facility, most of the work required 

respiratory protection. Now unfortunately I can't tell 

you much about what they were actually doing 

because unlike some other years in other areas, the 

actual work being done was either unspecified or 

would simply say "a job is in progress."

So I can't really speak based on these RWPs more 

about what was happening. But again, I think when 

we kind of look at these evaluations, as we get to 

the end and you put the whole picture together, you 

will see why SC&A recommends what we are. 

So what are those mitigating factors? So there are 

fluctuations by the year. There's fluctuations by 

area. However, when you look at these, the actual 

exposure assessments that inform those two charts 

and the table in our report, plutonium-239 was 

assumed for nearly all of the calculations, though 

some RWPs specifically would call it different things, 

like a fission product, cesium, depleted uranium, 

which all would bring the estimated doses based on 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

40

all the raw breathing zone data down considerably.

And again, respiratory protection was never 

considered in those two assessments, and you've 

got typical protection factors of 40, and that if you 

were in the bubble suits, which were in use for 

some of your operations, you can have protection 

factors on the order of 10,000. So when you 

compare those to the sort of ratios I was just 

showing, you can see why it is certainly not that 

worrisome based on a lot of these say conservative 

built-in assumptions, when essentially justifying 

whether 100 millirem would be bounding for the 

unmonitored or partially monitored worker.

Also the number of probable exposure events per 

year, the ratio is likely much less than 200. There 

were a couple of people like I said, in I believe it 

was in Observation 4 or 5, that did have a 

significant number of events per year. But are those 

people who are already on the bioassay program, 

and that most of the people in this breathing zone 

population did not show evidence that they were 

likely to get above 200 and in fact we feel it's likely 

much less than that.

And as I said, the individuals with the most frequent 

number of BZ events were already on the nontritium bioassay program. We call that non-tritium 

because again, it's the alpha component that's 

really driving this. 

NIOSH concurred with this observation and I believe 

the 100 millirem is still a big number and SC&A, as 

we stated in our original review and also our 

response to NIOSH's response, that SC&A 2020 

report and 2021, and the mitigating factors I just 

discussed concluded that dose assessment is 

sufficiently conservative, that the 100 millirem on 

an annual basis is appropriately bounding for 

unmonitored and partially monitored workers. So 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

41

we feel that this observation can be closed by the 

Work Group.

Moving briefly away from the internal breathing 

zone data, this was the sole observation concerning 

external dose, and if we have Ron Buchanan on the 

phone, he can describe this issue in greater detail.

Dr. Buchanan: Hi. This is Ron Buchanan, SC&A. Can 

you hear me okay?

Member Beach: Yes.

Dr. Buchanan: Oh okay. Observation 7 was 

concerned with the Sandia Pulse Reactor, radiation 

gradient dose. What this issue was was that the 

gradient was severe at the bottom of the reactor 

vessel. Now the radiation itself wasn't severe; it's 

just the gradient fell off very rapidly. This wouldn't 

be applicable to personnel working outside the 

immediate area, only at the bottom of the reactor 

vessel.

There was the potential that these personnel wore 

their badges on their chest, and therefore their 

head, eyes and hands may be exposed to a different 

radiation field than was reported on their dosimeter. 

And so that's why Observation 7 was concerned 

with this, and NIOSH agreed. They found further 

research was needed to do dose assessment for 

these particular workers.

Now there wasn't a large number of them, but they 

were monitored but they intended, they intend to 

do, conduct additional review and research to 

determine the need for adjustment factors. So they 

do have recorded doses, but the question is should 

the head, eyes and hands closer to the reactor 

vessel be assigned a different factor by a 

multiplication factor of some sort.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

42

And they had looked at this some. We had looked at 

it with them also. But they felt that they needed to 

investigate this further before they made a 

suggestion, and that they would incorporate that 

into the Site Profile. So we concur with NIOSH's 

plan to conduct additional review and research, and 

to provide this update in the revised Site Profile.

I would like to emphasize this is not an SEC issue. 

The only interest is certain parts of the body that 

may require a multiplication factor of the doses 

already in the dose record. And so that's what 

Observation 7 was concerned with. I'll turn it back 

over to you Bob.

Mr. Barton: Thanks, Ron. Just to kind of summarize 

here, again Finding 1 had to do with the fact that 

we do have an incomplete data set. Again, what can 

we say? What kind of investigative things can we do 

to either convince ourselves or not convince 

ourselves that what we have is either representative 

or bounding. 

And again, I think it's to a lesser level since this 

isn't forming a basis of a co-exposure model but 

rather a piece of evidence that the proposed dose 

reconstruction approach of 100 millirem in 

bounding. Now if we were going to try to take this 

breathing zone data and actually construct a coexposure model, then the bar gets set in my mind a 

little bit higher about what data is missing.

But again, what we found is really no indication that 

the data that's missing, the exposures that are 

missing would not be bounded, and in fact the data 

set suggests in comparison to the DAC-hour log 

books and the WebDose database, that if anything it 

might be as high. 

Observation 1 was about the duplicate samples, 

which NIOSH reevaluated. It did not make an 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

43

appreciable difference. That's no problem there. We 

can close that. There was the discussion about how 

to deal with, if not updating the SEC ER instead 

adding it as part of the TBD revisions and 

potentially a note associated with the ER about the 

fact that additional data came in after the ER 

addendum was issued.

That was evaluated. It ended up not changing the 

actual exposure conclusions regarding the 100 

millirem, but it certainly did, as Chuck pointed out, 

fill in some of the gaps that were seen, which is 

always a good thing, I think, just as far as optics to 

the public. It paints a better picture of the data we 

had to come to this conclusion. If we present the 

additional data but also correct for some of those 

anomalies about how different breathing zones were 

actually counted in the original ER table.

Observation 2 was simply looking at what we have 

over time, and we did that by year and we also did 

it by month, just to get a better sense. For 

example, you wouldn't expect to see, you know, 

100 breathing zones in one month and then zero for 

the next two, and then 50 the next month unless 

there is perhaps a shutdown or a strike. 

I think when we look at that, it convinced at least 

SC&A that we did not have a complete data set, 

which NIOSH agrees with. Now the question is is 

what we have sufficient to justify the 100 millirem? 

Again, Observation 3 was the same thing, but 

comparing it against WebDose this time instead of 

the DAC-hour reports. And again based on that, we 

feel that -- we're confident that the data we have is 

either representative or might be biased high. And 

again, this is all in the context of an unmonitored 

worker or partially monitored and as we found when 

comparing these breathing zone data against the 

actual bioassay data, there's quite a few of them 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

44

that were monitored internally by other methods, 

which would be used in their specific dose 

reconstruction.

4, this is one we looked at the number of BZ 

samples per worker per year, and we do not feel 

that this impacted the feasibility, because we didn't 

find it likely that a given worker was unmonitored, 

could have been involved in essentially 200 

exposure events in a given year.

And then Observation 5, as I just intimated, was a 

comparison of breathing zone participants and the 

actual non-tritium bioassay program, and both 4 

and 5 we recommend closure. Again, it was meant 

to be informative to the Work Group about the 

types of investigation tools that we looked at to 

again, convince ourselves that if the data is 

incomplete, how does that actually impact 

feasibility.

And then Observation 6 was again looking at the 

actual exposure potential across different years and 

different areas, and while there was certainly 

fluctuation that we saw based on the year and the 

area and what was going on, especially in the first 

few years with that hot cell facility, we don't believe 

that actually affects the feasibility of dose 

reconstruction here with the 100 millirem approach.

That's really because of all three, but maybe four 

main factors. The fact that in the analysis done we 

have assumed plutonium nearly all the time, it was 

close to 100 percent. Even a lot of these RWPs 

would actually specify that it was depleted uranium 

or fission products or something like that, which if 

the analysis had tried to go down to that level of 

granularity, would only have lessened the dose per 

event for these BZs. So lessened the dose per 

event, which would mean, even require even more 

than 200 events per year to exceed that 100 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

45

millirem threshold.

Again, no consideration for respiratory protection, 

even though a very large portion of these RWPs 

indicate that the workers had to wear to varying 

types and degrees. And so you add that -- again, 

it's going to have more specificity to the actual 

exposure analysis. This only would lower the dose 

further.

And then to add more we looked what does the data 

tell us about the probable number of exposure 

events for someone who is not monitored, and is 

that -- it seems unlikely to us that they would 

exceed the 100 millirem threshold. 

And in the fourth one, which is not shown here, but 

just noting that those folks who had or appeared in 

the breathing zone records to a degree of frequency 

were almost always included in the bioassay 

program anyway. So this 100 millirem threshold 

might, frankly doesn't even apply for most.

Observation 7, as Ron talked about, has to do with 

the Sandia Pulse Reactor, and the fact that folks 

could be underneath but wearing a badge on their 

lapel. So it's essentially a geometry correction issue, 

and so you just kind of need to see. There's data 

about -- folks were even wearing head dosimeters 

at one point, but also ring dosimeters. 

So there's data out there to come up with a 

geometry correction factor to address the fact that if 

you had workers underneath, you know, essentially 

underneath the reactor vessel, a dosimeter, an 

external dosimeter on the lapel is probably going to 

underestimate the dose received by the head and 

then certainly the hands as you're working above 

your head.

So in conclusion, the follow-up actions essentially is 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

46

the, you know, clarification on how those geometric 

correction factors will be developed from the 

available data, and the only thing left is that 

discussion about the data incompleteness. But as I 

said, we went at it a number of different ways, to 

see if there's any indication to us that what's 

missing, which is really unknowable since we don't 

have secondary sources that say how many BZs we 

should be having per month, per year, that sort of 

thing. 

We still believe based on the entirety of the picture 

here that dose reconstruction is feasible, sufficiently 

accurate and claimant-favorable during the 

evaluation period. That's my reference slide. Before 

I necessarily turn it over to questions, I just want to 

make sure Joe and Ron Buchanan, was there 

anything that you wanted to add before we open up 

the floor?

Not hearing any, can I answer any questions about 

breathing zone or Joe answer any questions about 

implementation or security, anything like that? Be 

happy to.

Work Group Discussion

Dr. Anderson: Okay, thank you Bob. I just have a 

question. I don't remember ever seeing this. When 

NIOSH does dose reconstruction analyses or does 

dose, do they include a respiratory protection factor 

at any point? This is not to you Bob, but maybe to 

NIOSH.

Mr. Nelson: Generally dose reconstruction would be 

based on a bioassay or other analyses in place. The 

answer to that, I guess you've got to give me a 

scenario but typically --

Dr. Anderson: Well, it's certainly through the 

biomonitoring and that sort of thing. It's what they 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

47

actually got not --

Mr. Nelson: Right. 

Mr. Rutherford: Can I add something to this?

Dr. Anderson: Yeah. Well, go ahead.

Mr. Rutherford: Yeah. This is LaVon Rutherford. If 

we use air sampling, air data in support of internal 

monitoring, we do not use a respiratory protection 

factor.

Dr. Anderson: Okay. Just I don't remember seeing 

it, but I never asked before. So that's what I 

assumed, but thank you. 

Member Beach: Yeah. I've seen it mentioned a few 

times in different scenarios Andy.

Dr. Anderson: Yeah, okay.

Member Beach: Bob, I had a question on the 

breathing zone samples, but you answered it. So I 

guess we're left to what is that about, 30 percent or 

35 percent of the breathing zone samples and the 

rest are unavailable, about 70 percent possibly? 

Mr. Nelson: I don't think --

Member Beach: My question -- oh, go ahead.

Mr. Nelson: Sorry, Josie. I don't think we know the 

exact number that are unavailable.

Member Beach: Yeah.

Mr. Nelson: Those are the years that we know are, 

had the highest ones contained. After that, any time 

there was a dose consequence it would have 

showed up in WebDose. That's the reporting tool. 

For the entire period, there was 26 millirem 

assigned. So we felt like that's certainly 100 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

48

millirem bounding for one individual, you know, 

compared to the dose of record.

So we looked at incident reports and other things, 

and didn't see any big dose consequences as a 

result. The BZs we saw were, when there were 

some BZs that they got results higher than 

expected. Then they actually followed it up with 

bioassay and did a complete dose evaluation.

Member Beach: Is there any plans to look for more 

data?

Mr. Nelson: Well, we thought we'd present this to 

you all what we had. I don't know that we'll know 

the exact number. Is there a log of every BZ? No, 

not that we know of. There is a couple. There's a 

visual, like this visual data system where it has all 

the or many of the air samples written down. It will 

have key words like "breathing zone."

We used some of those to capture some BZs, but it 

ends up being very involved to go back and mine 

those out through the mountains and so forth, and 

we felt we had a pretty good cache of breathing 

zone monitoring records, coupled with the dose of 

record in WebDose just showing that, you know, 

those consequences don't seem to very high and, 

you know, how far along do we want to keep 

digging and digging and capturing more data as I'm 

not sure we could tell you a percentage, ever.

Member Roessler: Right. Henry, I have a comment.

Dr. Anderson: Go ahead. 

Member Roessler: No questions exactly. Actually, I 

have two comments and what I have been thinking 

about as we go through this, the two comments is 

that I want to bring up a bottom line to see if 

maybe that will bring up discussion. We can move 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

49

this along and it's my impression at this point that 

NIOSH has presented enough information and 

reasoning using multiple things, the data and the 10 

C.F.R. 835 approach to back up their conclusion that 

they can do dose reconstruction for this particular 

period.

SC&A has done a very detailed and thoughtful 

evaluation of this, and it's my impression that SC&A 

is pretty much in agreement with that conclusion. 

However, there's this thing that's always hanging 

over one of these discussions, and it's the data 

completeness. 

This kind of brings me then into my second 

comment. Bob mentioned that, I think expressed a 

desire for having a quantitative way to look at 

completeness, and boy that would really be helpful, 

because these discussions that take place in other, 

on other Sites too, are quite frustrating because 

SC&A will say well, we don't feel that there's data 

completeness, but it's left sort of vague.

It's very hard for NIOSH to answer that and to come 

back then without some specific direction on, as to 

how to answer that question. Of course 

quantitative, if there a quantitative way, then that 

would make it much easier. So I guess my thought 

at this point is that the second part really doesn't 

affect the decision today, but it makes me think that 

we need -- it's an overreaching discussion, a 

separate discussion that affects other Sites. 

It seems like there should be maybe not for this 

Work Group but a special group within the Board to 

look at this particular question, as Bob brings it up. 

So that I think is kind of expresses my thoughts at 

this point in time.

Dr. Anderson: Thanks. No, that's kind of where I 

was heading on that other, that I think I missed, I 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

50

missed I think the data is, you know, pretty -- I 

think we're all probably pretty agreeable of dose 

reconstruction using the 100 millirem approach is a 

good one. 

Following up a question on that would be to you 

have some of the biomonitoring, and then those 

biomonitored workers were in the breathing zone, 

quite a few of them. My question to NIOSH would 

be if you just -- I'm going to have to go a second, 

sorry. Any other questions before that?

Member Beach: I want to make a comment while 

Henry's gone, and to you Gen, I thought your 

suggestion and your comments were very helpful, 

so thank you for that. I think that we should 

consider moving that discussion on incompleteness 

or completeness and quantity of data. It's 

something that does come up every single time we 

have a meeting. So that would be worth pursuing, I 

believe.

Dr. Anderson: As a separate issue?

Member Beach: Yes, as a separate issue.

Dr. Anderson: Yeah.

Member Beach: I mean obviously today we have 

agreement between NIOSH and SC&A, and these 

are generally Site Profile issues moving forward. But 

we don't want to lose track of the discussion on 

incompleteness. Tim's got his hand up. I'll call on 

Tim. Go for it.

Dr. Taulbee: I'd like to make a recommendation to 

you, Dr. Anderson. Following up with what Dr. 

Roessler just mentioned, this sounds like a very 

good -- the SEC Issues Work Group, of which I 

believe you're chair and Dr. Roessler's part of and 

Josie is also part of, that would be a good issue to 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

51

be tackled by that particular Work Group, especially 

for data completeness, because it does affect so 

many Sites. Just a recommendation.

Dr. Anderson: Yeah, yeah. I mean it sort of also fills 

in the issue of we -- routinely the comment used is 

"sufficiently conservative," which is quite a 

qualitative thing, and what constitutes sufficiently 

conservative is sort of -- I mean in our drinking 

water program it's a factor of ten uncertainty factor 

kind of a thing. So I think that kind of goes into 

what when is it overly conservative as opposed to 

sufficiently conservative as well.

So I'm not sure we'll ever resolve that to come up 

with a qualitative factor that we can look at the data 

as sufficient to say we're very confident that it's 

usable and not a wild guess kind of a thing, that you 

could always make something conservative. So I 

think we're -- I think, Tim, your idea of passing the 

issue along to another work group is probably 

worthwhile.

I think this is a good example of what can be done. 

Back before I snuck away there, my question was in 

using the 100 millirem, that also seems to be a 

bounding approach rather than the, trying to use 

dose reconstruction of co-workers, and of course 

co-workers has its other issues. But that could be, if 

in fact we had good evidence which you have put 

together here for this Site on other sites would be if 

in fact we're confident that the 10 C.F.R. 835 we 

had documentation that wasn't just supposed to be 

implemented but had been implemented, had been 

evaluated.

Then the 100 millirem for the unmonitored workers 

might become a useful tool moving forward 

elsewhere for those years, in the '97 and beyond 

years. But that's why I was wondering if you look at 

the workers who were biomonitored as well as had 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

52

breathing zones, and assume that they haven't 

been biomonitored, are the biomonitored data when 

it's used as the dose reconstruction always over 100 

millirem, or is it always under 100 millirem?

So we could sort of use the actual measurements as 

a way to also evaluate that 100 millirem assumption 

that's being used in this case. Other comments, 

Josie or --

Member Beach: None right now.

Member Roessler: Well then I'd like to -- I think 

we're in a position where I could move that the 

Work Group accept NIOSH's conclusion that they 

can do dose reconstruction on this particular SEC 

period. 

Dr. Anderson: On the subgroup, yeah.

Dr. Roberts: Actually, may I -- may I say 

something? There is an item on Petitioner 

Comments that are optional to Petitioner, then the 

Work Group, another Work Group discussion. Could 

we have that, the Petitioner have an opportunity to 

comment before we get into this?

Dr. Anderson: Yes, yes. Let's do that now. Yeah, 

hold that thought Gen.

Member Roessler: Okay.

Petitioner Comments

Mr. Giron: Chairman?

Dr. Anderson: There you are. I was going to say. I 

don't recognize your phone number, but go ahead.

Mr. Giron: Yes. I'm the Petitioner, Eloy Giron. First, 

I want to apologize for being on the phone and then 

trying to log on to Zoom, giving all that feedback. 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

53

So I am that guy that messes up. So sorry about 

that guys. Hope everybody's doing well.

First of all, I listened to Mr. Chuck Nelson's 

presentation today, and I'm not disputing any of his 

numbers or any of his conclusions on that. What I 

am disputing is we don't feel security personnel 

were included in those numbers that was provided 

from Sandia. I know the Working Group visited 

Sandia in January of '20, and we feel that as a 

group when they visited, that we weren't able to 

correspond exactly how we worked. 

It seemed that should have been easy, but we failed 

somehow and I take responsibility for that. For 

example, we took them to some of the locations 

that's for the pulse reactor, and during our security 

postures, we were in one of the rooms that had 

holes in the wall that were used for -- logistic holes 

for electrical cords, and they were big five-six inch 

holes, and they've been there for 50-60 years. 

Nothing has changed.

The working or the group that visited Sandia, they 

didn't see that, and that's what I feel bad about, 

that we were in that security posture when those 

jobs go off. None of us in security, I'm not going to 

dispute any of the bioassay that was completed 

throughout the lab, but we were not involved in any 

of that, on any of those programs. For sure we were 

not involved in any of the respiratory programs. 

One of the biggest failures we have was our 

dosimetries. There was no accountability on that. 

There was no really big push to make sure people 

were wearing them. I've read the, I've read the 

report, I've read the recommendation. I feel 

validated. It troubles me because we still have 

people getting sick, but we changed our security 

posture in the middle 2000's.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

54

I know that the Chairman had an excellent question 

on the respiratory factor. We were seeing operating 

personnel going to respirators, and we were with 

them without any respiratory protection. There's no 

documentation or anything like that with the 

security personnel using that. 

I know, I don't know who used the word but there's 

gaps, and there is gaps. Security was treated much 

different than operating personnel. So I could see 

Sandia providing that information and 

documentation for operating personnel, but I know 

there's nothing, no documentation as far as security 

personnel, the way we were working those areas. I 

know there's going to be a motion now to accept 

this. 

I was hoping, I know we had a meeting or we had 

no comment in I think August of 2020. There was 

no way I was going to be able to speak. That was 

during the COVID and we were on a skeleton crew 

and I was at work, I couldn't even get off work that 

day to do that. So I know there's going to be a 

recommendation to accept it. It's disappointing 

that's going to happen, because security was 

treated completely different.

I know you guys need to go put this to bed and get 

on with it, because you've been going at this for a 

while, but is there an appeal process for this? What 

steps do we have after this? That's a question. I 

guess that's to the Chairman. I don't know who to 

send that question to. 

Work Group Discussion and Path Forward

Dr. Anderson: Rashaun, do you want to talk, say 

something? 

Dr. Roberts: Yeah. There is an opportunity, I'm 

sorry, an opportunity to request administrative 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

55

review with the HHS Secretary's Office. 

Mr. Giron: Okay. Thank you. I'm just disappointed 

that this --

Member Beach: Can I -- I'm sorry to interrupt. 

Rashaun, is there a time limit on that or is that 

open?

Mr. Nelson: This is Chuck Nelson. If the Work Group 

and the Advisory Board agree that there's no SEC 

issue here, we will issue a letter, Mr. Eloy Giron, 

allowing him ample time to put in that 

administrative review request, and that will come in 

writing to you Eloy, if this should go that direction.

Mr. Rutherford: Yeah, this is LaVon Rutherford. I'd 

like to add to that what happens after the Advisory 

Board makes the determination that they are not 

going to recommend an STC, it will go up to the 

Secretary. The Secretary of HHS will make a final 

determination. At that point you will be issued a 

letter, and will be given a certain time period to 

make, request that administrative review. I just 

wanted to add a little to that.

Mr. Giron: Thank you. 

Dr. Anderson: So this is back to LaVon. Does --if we 

accept this, I mean do we need to vote to deny 

making it an SEC? 

Mr. Rutherford: That's correct, yes. In order for this 

to -- in order for him to be allowed to request an 

administrative review, a determination needs to be 

made by the Secretary.

Dr. Anderson: Yeah, but the Board is supposed to 

affirmatively approve SECs, but there's nothing in 

there that says we need to deny an SEC. It would 

seem to be that comes from the Secretary's Office?
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

56

Mr. Rutherford: No. The Advisory Board has to 

make a recommendation to the Secretary to deny 

the SEC, and then the Secretary would review the 

information by both the Advisory Board and NIOSH, 

and make the determination at that point to deny 

the SEC. Then the administrative review request 

would go out.

Dr. Anderson: Okay.

Dr. Taulbee: Right. The Secretary can't move 

forward until the Board makes a recommendation, 

whether it's to add or to deny. 

Dr. Anderson: Okay.

Member Beach: Andy, this is Josie again. Didn't you 

have a question early on in the presentation that we 

put on hold? Did that get answered?

Dr. Anderson: I don't remember. Do you remember 

what it was?

(Simultaneous speaking.)

Dr. Anderson: I've got all my notes here. I'm going 

to search through them.

Mr. Barton: I think the question was what Dr. 

Roessler brought back up, about is there a sort of a 

standard quantitative way we can approach these 

things across the entire program rather than site by 

site?

Dr. Anderson: Okay. Well, Josie and Gen, do you 

want to move forward? Do you want to --

Member Beach: Yeah. I think we need to. Do we 

settle that and then go through the different items 

that are recommended for closure?

Dr. Anderson: Yeah.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

57

Member Beach: Gen, did you have a motion? That 

was a motion to deny the SEC; correct?

Member Roessler: Sorry, I was on mute. I think I 

made a motion.

Member Beach: Yeah, I thought you did. I was just 

verifying that you had made the motion.

Member Roessler: On the, on the decision on this 

particular SEC time period, but I think then we have 

to follow through with the other discussion.

Member Beach: Of course, yeah. I'm going to go 

ahead and second that Andy, because based on 

SC&A's agreement with NIOSH, I believe that we 

need a motion.

Dr. Roberts: Okay. Just for clarification of the 

record, could you specify, you know, the class that 

you're denying, the proposed class being denied?

Member Roessler: I believe somebody from NIOSH 

should state that, to get it completely accurate.

Mr. Nelson: I'm trying to come off mute here, sorry 

about that. Okay. I want to make sure I say it 

properly. So the period that's left open for 

evaluation is 1997 through May 2011. I'm looking 

for it. I think it's May 11th. So those are the dates 

of this Addendum. The other previous periods are 

already SECs.

Member Beach: So January 1st, 1997 to May 21st, 

2011?

Mr. Nelson: I think it's '11. I'm trying to find it. I 

don't know why I'm drawing a blank with that.

Member Beach: I'm pretty sure it's May 21st, 2011. 

Member Roessler: Would it be sufficient to say 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

58

Petition SEC-00188, Addendum 2?

Mr. Nelson: Josie, you're correct. It is May 21st, 

2011. Yeah, Addendum 2 covers that time period. I 

don't know if you're -- what do you think about that 

LaVon?

Dr. Taulbee: This is Tim, if I could chime in here. I 

think a simple motion could be that the Work Group 

concurs with NIOSH that dose reconstruction is 

feasible based upon the SEC-00188, Addendum 2 

evaluation. So I think that should be sufficient.

Dr. Anderson: So I will -- and then we take it to the 

full Board.

Dr. Taulbee: That's correct.

Dr. Anderson: So that's the recommendation to the 

full Board, yeah. And it only pertains to the security 

workforce?

Dr. Taulbee: All personnel.

Dr. Anderson: All personnel? Okay.

Dr. Taulbee: Yes sir.

Member Roessler: Yeah, this is all personnel, 

according to the ER of 2019. 

Dr. Anderson: Yeah.

Member Roessler: Okay.

Dr. Roberts: And that has been seconded?

Member Beach: Yeah I --

Dr. Roberts: The motion to bring the 

recommendation to the Board.

Member Beach: Yes, I seconded it.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

59

Dr. Anderson: Okay. We've got a motion. It's been 

made and seconded. All in favor of accepting the 

motion, I don't know if we need to go through each 

of us. Why don't we just, since there's only three of 

us. Gen, how do you vote?

Member Roessler: Yes.

Dr. Anderson: Okay, and Josie?

Member Beach: Yes.

Dr. Anderson: And I'll vote yes too. So it's 

unanimous. It's hard as the chair; I can't make 

motions, and therefore if we're going to have a 

second, it has to be pretty unanimous. Okay. So 

we're onto any other comments others want to 

make before we -- we'll take this on the -- we have 

a Board meeting end of the month. We'll bring this 

to the Board with a recommendation, and we'll need 

I guess presentations, Chuck and Bob.

Mr. Nelson: I can probably give me statement. I'm 

going to be on vacation in the next week. I can do 

the same presentation or I'm just trying to think if I 

can get it over to them in time for adequate review. 

Oftentimes, we get it over in the last minute and we 

get a lot of flak for that, so I'll -- I don't know. I've 

talked to LaVon about that some. I don't know if 

he's got an opinion.

Mr. Rutherford: Yeah. I mean I think what you could 

do if -- I mean if it's appropriate, we can do the 

same presentation that you just did, and then Bob. 

But it would seem like it would be a much, you 

know, we'd want probably a shorter presentation --

Mr. Nelson: Yes.

Mr. Rutherford: --than that long one. 

Dr. Taulbee: I was going to recommend that same 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

60

thing, that it seems like a shorter presentation, 

perhaps Bob's, SC&A go through their findings and 

they recommended closure and everything's closed 

and the Work Group voted.

Mr. Rutherford: Right.

Dr. Taulbee: And that's really all that's needed.

Dr. Anderson: So can we -- kind of a question on 

the timing of it. We need to get, since we're going 

to recommend a denial here, I want to be sure that 

all the other Board members are going to have 

sufficient time to look at this. Are we going to be 

able to get this out, or do we need to postpone this 

to another Board meeting? 

It would be nice to get it here, but I don't want to 

have things coming out three days in advance, and 

full Board discussion will begin with completing I 

haven't had enough time to look at it if we're 

denying it. It's one thing if we're going to accept it. 

Mr. Barton: Well, this is Bob. It is pretty, I mean 

very short amount of time, and it does take a while 

to get these things, in particular not just to the 

Advisory Board but also available to the public. It's 

also obviously important, because they'll want to 

have time to review it as well.

Of course, the underlying documents are already all 

up there on the website. It would be -- the new 

material would simply be I guess the shortened 

presentations and the update from this meeting.

Dr. Anderson: Yeah, and you've gotten the 

clearance for this meeting, so unless you alter 

things.

Mr. Rutherford: Yeah. I was getting ready -- I 

believe the agenda's already out for this meeting, 

and Dr. Roberts can jump in here. But I --
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

61

Dr. Roberts: Right.

Mr. Rutherford: Go ahead.

Dr. Roberts: Yeah. The agendas can be revised.

Mr. Rutherford: Okay, and then the only other point 

I wanted to make, again this is LaVon Rutherford, is 

this is not only a short amount of time for the 

Board's review, but it's also nice to give the 

Petitioners enough time to prepare their whatever 

they may want to say as well.

Dr. Anderson: So I mean I am sort of leaning 

towards maybe postponing it just for all those 

reasons. We could report here that at the end of the 

month that we had the -- well no. Rashaun, what 

are your thoughts?

Dr. Roberts: Yeah. I think there's a lot of validity to 

the concerns about not giving the public and the 

Board sufficient time to review. Had we been able to 

hold this meeting back in March, it definitely would 

have been less of an issue.

Dr. Anderson: Yeah.

Dr. Roberts: But since it got rescheduled, I think we 

are a little bit jammed for that. So it sounds like you 

Andy may be leaning toward postponement.

Dr. Anderson: Yeah that's -- that's my thought. I'm 

not sure there's that much of a rush. It would have 

been nice to been able to do it, but I'd like to be 

sure that everybody has adequate time and that the 

discussion with the full Board doesn't lead to a lot of 

historic questions that people don't remember back 

from the early start of this.

Member Beach: Well, and I'm wondering if it 

wouldn't be better to go ahead and present, and 

have the discussions on both sides. I think we have 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

62

time on the agenda. I guess we could ask the 

Petitioner if he feels that's adequate time. He's on 

the line, and then if we don't get to a vote, then the 

information is out and then we --

(Simultaneous speaking.)

Dr. Anderson: It could be tabled. Yeah, you're right. 

It could be tabled --

Member Beach: It could be tabled. That's been 

done.

Dr. Anderson: Yeah, good. That's a good thought, 

right. Let's do that. Let's go through, make the 

presentations and start the discussion there and 

then see how it goes.

Dr. Roberts: So would that be SC&A and DCAS 

providing the same presentations as today or --

(Simultaneous speaking.)

Dr. Anderson: Yeah.

Dr. Roberts: --what we're asking.

Member Beach: Yeah. I think that they could 

definitely do that, and then provide the background 

documents as you did for this meeting.

Dr. Taulbee: May I make a recommendation here, 

that these be actually just a really short 

presentation by SC&A, and in the sense of going 

through their findings. I mean if you want Chuck to 

go through and redo his presentation, we can. I 

guess I can see going either way. It's just it seems 

like we're trying to fit a lot into, you know, this time 

slot here.

Dr. Anderson: I mean my thought on it is that if 

Chuck could go through. I think people ain't gonna 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

63

remember the earlier SEC, and the reason why you 

couldn't and then what changed in the '97 to 2011 

period that -- and we're saying there's data 

problems and shortages. But you know, it's more --

I think the tipping point was the ability to show that 

the Part 835 was in fact implemented. We have 

documentation on that, and that makes the use of 

the 100 millirems acceptable here versus the earlier 

time periods.

So I think people need to know that we're not 

changing in midstream here. We're up to this point 

everything has been made an SEC, and from '97 

forward, we're now saying things have changed and 

we need to say what is that and why do we believe 

it can't be done. 

So I think, you know, whether we have Bob present 

that history, but I think that's important to get to 

the Board and not have them necessarily have to 

try to wade through all of the earlier documents to 

come to that conclusion. At least that's my bottom 

line on why we're moving forward, able to accept it 

here more, because everybody agrees there's data 

problems.

But the use of the 100 millirem, which is built right 

into the 10 C.F.R., I think, is the key thing to focus 

on, that in fact that was implemented and was 

working effectively. 

Dr. Taulbee: Okay, I understand. 

Dr. Anderson: Yeah.

Dr. Taulbee: I understand what it is you're looking 

for now. Thank you very much for that clarification.

Dr. Anderson: Right, yeah. At least that's my 

thought. I don't know if Josie or Gen --

Member Beach: No, I agree also.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

64

Dr. Anderson: So I guess it's -- Tim, if you want to 

work Bob and Chuck, whether your -- Bob can go 

through all of that. I think that can be handled fairly 

quickly.

Dr. Taulbee: No, I think I can work with Chuck and 

we can get that done on our end, as to what it is 

you're looking for.

Dr. Anderson: Okay.

Dr. Taulbee: So thank you. And Bob, I'm assuming 

you're going to want to go through your findings 

and do recommended closures, but yeah.

Mr. Barton: Yeah, I think the suggestion you had 

earlier about really paring down both presentations. 

If you don't have to have the level of detail, then it 

won't necessarily take as long. I think that was a 

good suggestion.

Mr. Nelson: Now will this be just an update or would 

you be looking to eventually get a vote here?

Dr. Taulbee: I could go either way.

Dr. Anderson: Yeah. I would like to get a vote, but 

my concern is that are people going to be 

uncomfortable because they haven't had enough 

time.

Dr. Taulbee: Right.

Dr. Anderson: And if I get a sense at the Board 

meeting that that's the case, that I would think we 

may want to think in terms of not just churning 

away time with people being uncomfortable by 

enforcing a vote, but we could table it then. But I'm 

hoping the presentations will be sufficient, that 

Board members will agree with our Committee 

conclusions to recommend –
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

65

(Simultaneous speaking.)

Member Beach: Go ahead, Joe.

Dr. Taulbee: Go ahead.

Mr. Fitzgerald: Yeah. The only thing I would add is, 

you know, we need to reach back to our original 

review, which includes the treatment of the, you 

know, the security guard issue. We don't really 

address this specifically in these follow-up findings 

and observations. But that is contained in the 2020 

report that we produced, with an appendix of the 

interview and tour summary.

So you know, there's a lot of detail of how we 

reviewed that issue and how we came to the 

conclusion that, you know, it didn't necessarily 

present a problem with the 100 millirem criterion. 

So I'm just looking ahead and thinking if you're a 

Board member who hasn't been on this Work 

Group, that might be a little cryptic unless you were 

familiar with that work that was done on that 

particular issue of the Petitioner.

So that's the only thing I would add, that in the 

presentation, somehow that, you know, with the 

provision of a report or maybe even a slide on that, 

you know, on that review, that would probably fill in 

the hole that some Board members may have.

Member Beach: Joe, is that something you can work 

with Bob on?

Mr. Fitzgerald: Yeah, I mean that's easy enough to 

do. I mean it's maybe one slide, but I think it's an 

important one because again, we did spend a lot of 

time and effort on trying to put that one to bed, and 

I know Henry you and Josie were on the tour and on 

the interviews. But it may be a little hard for the 

other Board members to understand how we 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

66

dispatched or how we actually dispositioned that 

question.

Member Beach: Good point, Joe.

Dr. Anderson: Yeah, yeah. Okay, do we want to go 

back through the -- and close out the various 

points?

Member Beach: Yeah, back starting with 4?

Dr. Anderson: Yeah. Bob?

Mr. Barton: Yeah. Let me take myself off of mute. 

So a lot of these we recommended closure, but I'm 

not sure if they were actually formally closed out if 

that's what we're --

Dr. Anderson: No, we didn't. That's why I think we -

- we either need to say we're going to accept all 

your closure recommendations, and some we're to 

keep it open until the documents have been revised, 

or wait. Maybe we need to go through one at a 

time. So let's just quickly go through here.

Mr. Barton: Okay. Well I mean on this slide you're 

all looking at right now, Finding 1, 2 and 3 all had to 

do with whether we were dealing with a complete 

data set, which NIOSH and SC&A agree it is not, 

and frankly we don't know at this point how much 

data might be missing. So that's really the gist of 

those.

Based on the motion that was just voted on, it 

seems like Finding 1, 2 -- Finding 1 and Observation 

2 and 3 could be closed out by the Work Group as 

there are data completeness issues, but as they 

don't necessarily inhibit feasibility, they can be 

closed is what I would recommend.

Dr. Anderson: Can I have motion for one or the 

other?
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

67

Member Beach: So this -- my question on this 

would be would this have anything to do moving 

forward for Site Profile issues? 

Mr. Barton: Well, if we accept the 100 millirem, I 

would say no, because while there is a 

completeness issue with the breathing zone data, 

the totality of evidence suggests that 100 millirem is 

a bounding dose reconstruction approach. So I'm 

not sure what else we need to happen here, other 

than -- well as was suggested, it's sort of under 

Observation 1 here. 

The update to the TBD would have a more accurate 

depiction of the available breathing zone, as well as 

include the additional breathing zone that had been 

obtained after the ER. So that would be something 

that we would consider a TBD issue. But that would 

be under Observation 1. The fact that the Work 

Group recommends that 100 millirem is 

appropriate, then I think that essentially closes out 

the finding and two observations directly related to 

the fact that there's completeness, yes.

Member Beach: Yeah, and Bob thanks for bringing 

that up. I think that goes back to Henry's or Andy's 

question on whether we do a memo for the ER or 

it's placed into the Site Profile or the TBD.

Dr. Taulbee: I can tell you that my preference would 

be that we put it into the TBD, because that's the 

technical basis of how we end up doing dose 

reconstruction. 

Dr. Anderson: Well, if you're willing to do that, 

where reviewing or redoing the ER is quite different, 

then I think let's put that in and we can wait until 

that's been completed to close it out altogether.

Mr. Barton: That would be just -- that would be that 

second part of Observation 1. But that update to the 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

68

TBD wouldn't really affect your ability to close out 

Finding 1 and Observations 2 and 3, based on your 

recommendation that 100 millirem is sufficient. 

Dr. Anderson: Yeah.

Mr. Barton: So there's no completeness issue that 

says that we shouldn't be able to use that approach.

Dr. Anderson: Okay. Do I have a motion from 

someone to close? I mean we've discussed them 

and the issues have been basically resolved, and it's 

going to be going into the TBD. 

Member Beach: Yeah. Andy, I guess I -- I wasn't 

sure that this was -- this part of it was actually 

resolved. We had talked about maybe moving it into 

the SEC's Work Group. So under this, Bob's 

absolute correct. We agree that the 100 millirem is 

satisfied. 

Somehow I don't want to lose track of this moving 

forward because I think it's an important distinction 

that needs to be made. So --

Dr. Anderson: Shall we move on? Yeah.

Member Beach: Yeah. I guess we have to agree to 

close.

Dr. Anderson: Yeah. So is that a motion to close 

then?

Member Beach: Yes.

Dr. Anderson: Okay.

Member Roessler: Second.

Dr. Anderson: Okay, all right. So we're all vote 

along with that, so we're going to close these. But I 

think we need to remember at the Board meeting, 

Bob if you're going to go through these, we'll also 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

69

say to identify the issue that needs to go to the 

Committee. 

Mr. Barton: Okay. Well I can certainly indicate that 

as part of the discussion, and really I think Finding 

1 is very specific to this Site at this time, and I think 

as far as sort of a macro issue of how you deal with 

completeness across the program, I can certainly 

mention that.

Dr. Anderson: Yeah.

Mr. Barton: I think there's a way to transfer some of 

these inquiries to the SEC Issues Work Group. But 

in this case, we wouldn't really transfer Finding 1 if 

it's been decided here unless you all were hesitant 

about the completeness of the data here, in which 

you wanted the SEC Issues Work Group to take a 

look at it. It doesn't seem like that's --

Dr. Anderson: Well that's what I would, what I 

would -- I mean we can close it out as it relates to 

this Site. What I don't -- as Josie was saying, I don't 

think we want to lose that. So we may want to have 

it on the record at the Board meeting that yeah, do 

we want -- does our Committee want to recommend 

that it goes to the SEC Issues Committee?

Dr. Taulbee: I think that's a good recommendation 

there Dr. Anderson, is that coming out of this Work 

Group, the recommendation that the SEC Issues 

Work Group look at data completeness on a global 

scale across all of the sites and SECs.

Dr. Anderson: Yeah. 

Member Beach: I think moving forward, we would 

have to look at the examples, and this would be one 

of the examples. It would be closed here, but we 

would probably need to have examples listed for 

other sites and if it's going to be more global, this 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

70

completeness or incompleteness of data. So this 

would be a good one to not lose.

Dr. Anderson: Yeah.

Member Beach: Okay, thank you. Thanks for the 

explanation on that too Bob.

Mr. Barton: Okay. So we're closing Finding 1 with 

the caveat that there will be some language in the 

Advisory Board meeting that this Work Group is 

recommending the SEC Issues Work Group take up 

the more global issue of data completeness. 

So Finding 1 will be closed in this venue, as well as 

Observations 2 and 3. Observation 1 still has the 

TBD update, but the actual number of available 

breathing zone monitoring results to be updated. So 

that would sort of remain in abeyance, but not an 

SEC-related issue.

Dr. Anderson: Yeah.

Mr. Barton: Okay. All right, and then the next three, 

let's see. All right. This is -- this is again, these are 

observations that are describing what SC&A did as 

far as analysis, to convince ourselves that the data 

set that we have and the completeness issues that 

we have did not actually represent an infeasibility 

when it came to the 100 millirem, which I believe, 

you know, based on the discussions today, we 

recommended closure even in this presentation. So 

I guess unless there's more discussion on that, 

SC&A certainly will be recommending 4 and 5 are 

closed today.

Dr. Anderson: Do I have a recommendation for 

that? Board members.

Member Beach: Andy, this is Josie. I'll go ahead and 

recommendation that we close Observations 4, 5 

and 6, based on SC&A's recommendation.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

71

Dr. Anderson: Okay.

Member Roessler: Second.

Dr. Anderson: And I'll agree with that. So --

Mr. Barton: The last one here was, involved he 

external dose geometric correction factors for the 

pulse reactor, and I think the recommendation that 

was -- it seems like there's certainly a path forward 

to address that. We don't feel it's an SEC-related 

issue. 

It's just a question of how that geometry correction 

factor will be developed based on data we have of 

folks actually under that reactor doing work and we 

want more actual head dosimetry. It's just that 

hasn't been addressed yet. It's a Site Profile issue, 

so I would say that one would essentially be held 

perhaps in abeyance, because I think both SC&A 

agrees that there's a viable path forward, but we 

haven't seen it yet, the specifics.

So it's sort of a gray area, sort of in progress, but 

since we haven't seen the specifics of it, I'm not 

sure if we can put it in abeyance, because in 

abeyance usually means you know exactly what's 

going to happen. We just need to see it officially in 

writing.

Member Beach: Right.

Mr. Barton: And in this case, we don't know exactly 

what's going to happen.

Member Beach: I guess Bob we should hear from 

NIOSH, if they're planning on doing any work on 

that.

(Simultaneous speaking.)

Mr. Nelson: Yeah, actually -- sorry Josie. The 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

72

progress is underway on that. I don't know if you 

guys want a full report on it. We could give it to 

you, but we can write it all up and present it over to 

the Work Group so they can see it. We're not 

complete with it yet. 

We do have to do some further communication with 

the Site on a particular period of time, just to dial in 

some doses between work area measurements and 

actual measurements. Other than that, I think our 

principle internal, external dosimetrist has made 

some good headway on it, and I think we've got it 

laid out fairly good. We just have not completed 

that effort.

Dr. Anderson: We can keep this open then.

Member Beach: So it's actually in progress?

Mr. Nelson: Yes.

Member Beach: Yeah.

Dr. Taulbee: If I can make a recommendation that 

you designate it as a Site Profile issue that is in 

progress, to separate it from the SEC side of things?

Member Beach: Yes.

Dr. Anderson: Uh-huh, okay.

Member Beach: That makes sense. I agree with that 

recommendation.

Dr. Anderson: Okay. I think we're all in agreement 

on that. 

Mr. Barton: Right. So just to recap, Finding 1 is 

closed. Observation 1 is in progress or in abeyance 

as a TBD issue. Again, since we haven't quite seen 

it yet, I think it's probably still in progress. But in 

progress as an TBD issue, not an SEC issue. And 2 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

73

through 6 are closed, and then 7 is likewise in 

progress as a TBD issue.

Dr. Anderson: And the finding data completeness 

issue in a broader sense, we're recommending that 

it be forwarded to the SEC Issues Committee. 

Mr. Barton: Right, currently we're not necessarily 

talking about Sandia, though it form I think one of 

the examples going forward on that.

Dr. Anderson: Right, yes.

Mr. Barton: As Josie indicated.

Dr. Anderson: Yeah. 

Member Beach: And then I guess on that Andy, I 

have a question for you since you're the Chair of the 

SEC Committee. Maybe think about plans moving 

forward with that, and tasking -- I know we don't 

want to task NIOSH, but NIOSH should probably 

start that discussion possibly. I don't know if we 

need a work group meeting I guess is what I'm 

saying to get that started. 

Member Roessler: We certainly have to provide 

some wording and some backup justification for 

doing that, to give them something to work on. 

Dr. Anderson: Well, I mean one thing would be to 

we need to identify a number of examples of this. 

So this is an example, and then we could either go 

through what are the other sites that we've dealt 

with. I mean I think almost every one deals with 

data completeness. Now it's a little easier when 

there's no data, and that's been where we've 

entered with a lot of the approved SEC.

But more now as we get into dealing with co-worker 

model issues, data completeness also feeds into 

that at a certain point. So I don't know if SC&A, you 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

74

deal with all of the sites. If you would say there's 

one or two others that the Committee might want to 

look at as examples. 

Mr. Barton: Well, if I could comment, as you said 

we could provide examples. But as far as being able 

to actually develop quantitative criteria, I mean this 

is just my thoughts off the top of my head. But I 

see that as being very fraught with peril because of 

all these examples are really completely different 

from each other.

You might have a site where you have a 95 percent 

good data set, but as it turns out that five percent 

we're dealing with something completely different 

and had nothing to do with the 95 percent you do 

have. You might have another site where you're 50 

percent complete and that 50 percent represents 

everybody who's doing the hardest work, in which 

case is that really a completeness issue. 

In this case, we looked at from a couple of different 

angles what different areas, years, different types of 

tasks they were doing, and here it was concluded 

that the incompleteness, which we really don't even 

know and can't put a number on it, as Chuck 

mentioned, is not an issue. Whereas at a different 

site under different circumstances, it very well 

might be an issue.

So I think it's going to be very complicated to come 

up with a quantitative way to address this across 

the program, because really you have to look at the 

site and why does this incompleteness exist, and 

with what we have, is it appropriate to use in an 

SEC context. I'm not sure you can come up with a 

number or a formula that addresses that if you get -

-

It really comes down to the individual qualities of 

the site and what informs us about the incomplete 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

75

section of the data set. 

Dr. Taulbee: Right, but that's, this is the, that's the 

discussion that should be happening within that SEC 

Issues Work Group.

Mr. Barton: Sure.

Dr. Taulbee: I think what Dr. Anderson is bringing 

up is, you know, we come to the table with some 

examples that we've discussed in the past, and we 

start exploring those, of what are those differences 

to identify.

Member Roessler: Perhaps instead of specifying or 

suggesting a quantitative approach, just say a more 

definitive approach. 

Dr. Anderson: Yeah. I mean my conclusion before 

we've even looked at is I don't think at this time 

you can come up with a modeling approach that will 

address all sites. So that really is, as Bob was 

saying, a site-specific issue. You really have to look 

at each of the sites and then make a determination 

there. 

And that is not an easy task necessarily to do, but 

we can potentially come up with a list of here are 

the kind of things to consider, that the Committee 

would like to look at. I think we've done that at 

each of these other sites. You don't always arrive at 

the same conclusion. But I do think, you know, it's 

better to have as a larger group, a somewhat 

different group discussion about the issues.

I'm not sure we can resolve everything, but I think 

it is worth a broader discussion, and I think putting 

it in a Committee makes it a more manageable 

discussion than trying to do it with the whole Board. 

You know, it will just run on forever to try to do 

that. 
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

76

But I think if we could start it to say are there some 

commonalities that need to be addressed, that have 

been addressed, that begin to do, you know, getting 

to the issue of sufficient, to get a definition of 

sufficient is a challenge. So that's kind of where I 

would think our Committee would want to go. 

But it would be nice again to have some individual 

cases, where the committee that -- our Committee 

struggled with this a fair amount, for a long period 

of time and I think others may have as well. So it 

would be nice to get an idea which were those and 

then are there commonalities in them that we could 

then summarize and say this is the approach that is 

needed?

Member Beach: It sounds like NIOSH could 

potentially provide some of that start-up discussion, 

and then schedule a work group meeting.

Dr. Anderson: Yeah.

Member Beach: Is that correct Tim?

Dr. Taulbee: That's correct. We could come up with 

a memo to get the ball rolling.

Member Beach: There you go.

Dr. Taulbee: From that standpoint.

Dr. Anderson: I don't think we need a full --

Member Beach: No, no.

Dr. Anderson: I would go, I would go just with a 

memo if you can, and that would give us the 

foundation to pass it on.

Dr. Taulbee: Yes.

Member Beach: Yeah.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage.

77

Dr. Taulbee: Thank you.

Dr. Anderson: Okay. Are there other comments? Let 

me pull up our agenda here. I think we're pretty 

well finished with that. Okay. So we have the --

what's that, okay. So we've got follow-up actions. I 

think we've pretty well been through that. 

At the Board meeting, we're going to have the two 

presentations and the discussion there, and see how 

the Board members feel. I think we need to get the 

information out to them quite a bit and point out 

that, which isn't in the agenda particularly, that 

we're going to look for a potential Board vote. 

So that will really encourage people. There's a lot on 

the agenda. We really want them to prioritize 

looking at this one. Any comments?

Member Beach: Nope. I think you covered it Andy.

Dr. Anderson: Okay. I need a motion to adjourn.

Member Beach: I recommend that we adjourn.

Member Roessler: I second it.

Dr. Anderson: Okay, yeah. For us, we're a little past 

lunch but for the east coasters, you're well past 

lunch. So with that, I appreciate everybody's 

comments and participation here in the delay. I 

think we've brought it back on track and hopefully 

we can move forward at the end of or at the Board 

meeting. Any other questions people have before? 

Last chance. Okay, with that I'll adjourn the 

meeting. Rashaun, do you have any other 

comments?

Dr. Roberts: No, nothing here. Thanks, Andy.

Dr. Anderson: Okay. Thanks everybody.
This transcript of the Advisory Board on Radiation and Worker Health, Sandia Work Group, has 

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

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader 

should be cautioned that this transcript is for information only and is subject to chage. 

78 

Member Beach: See everybody in a couple of 

weeks.

Dr. Anderson: Yeah.

Adjourn 

(Whereupon, the above-entitled matter went off the 

record at 1:31 p.m.)