THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


VOL. I 


ROCKY FLATS 


The verbatim transcript of the Working Group 


Meeting of the Advisory Board on Radiation and 


Worker Health held telephonically on April 12, 2006. 

 

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C O N T E N T S
 

April 12, 2006 


WELCOME AND OPENING COMMENTS 


DR. LEW WADE, DFO 


INTRODUCTION BY MR. GRIFFON, CHAIR 11 


SEC PETITION EVALUATION REPORT 16 


MATRIX 114 

SAMPLE DOSE RECONSTRUCTIONS 322 


COURT REPORTER’S CERTIFICATE 347 

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TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


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


an unintentional or purposeful interruption of a 


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


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


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


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


"uh-uh" represents a negative response. 


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


without reference available. 


-- (inaudible)/ (unintelligible) signifies speaker 


failure, usually failure to use a microphone. 


-- ^ indicates failure in speech, often due to 


phone service in this case. 

 

 

 

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


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

GIBSON, Michael H. 


President 


Paper, Allied-Industrial, Chemical, and Energy Union 


Local 5-4200 


Miamisburg, Ohio 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


MUNN, Wanda I. 


Senior Nuclear Engineer (Retired) 


Richland, Washington 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 

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PARTICIPANTS
 

ALLEN, DAVE, NIOSH 


BEHLING, HANS, SC&A 


BRACKETT, LIZ, ORAUT 


DEMERS, KATHY, SC&A 


ELLIOTT, LARRY, NIOSH 


FALK, ROGER, ORAUT 


FITZGERALD, JOSEPH, SC&A 


FIX, JACK, ORAU 


HERNSBERGER, DAVID, ORAU 


HOMOKI-TITUS, LIZ, HHS 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAUT 


KATZ, TED, NIOSH 


LANGSTED, JIM, ORAUT 


LITTLE, CRAIG, ORAUT 


LOCHAMY, JOE, ORAU 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MCFEE, MATT, ORAUT 


MEYER, BOB, ORAUT 


MINKS, ERIN, SEN. SALAZAR 


NETON, JIM, NIOSH 


POTTER, GENE, ORAUT 


RAFKY, MICHAEL, HHS 


ROBINSON, AL, ORAU 


SHARFI, MUTTY, ORAU 


SMITH, MATTHEW, ORAU 


SUNDIN, DAVE, NIOSH 


ULSH, BRANT, NIOSH 

 

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P R O C E E D I N G S
 

(10:00 a.m.) 


WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO
 

DR. WADE: So again this is Lew Wade, welcome. 


This is a meeting of the working group of the 


Advisory Board. This is the working group 


again that looks at site profiles, individual 


dose reconstruction reviews, procedures 


reviews. Recently, they’ve looked 


extensively, this working group has looked 


extensively at site profiles related to Y-12 


and Rocky Flats. And then the Board has asked 


them, based upon that experience, to pick up 


and look at SEC petition activity with regard 


to Y-12. That we did yesterday, and Rocky 


Flats, that we’re doing today. 


NIOSH has recently issued a petition 


evaluation report on Rocky Flats that’s in the 


hands of all on the working group and on this 


call hopefully. And we’re looking at the 


possibility of a presentation of that 


evaluation report to the Board at the Board’s 

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meeting at the end of April in Denver, 


Colorado. 


What I’d like to do, a couple of 


things, is again we want to be mindful of not 


having a quorum of the Board. I really don’t 


think that’s an issue today, but we’ll 


identify Board members on the call now. And 


we’ve asked in the recently sent e-mail that 


Board members identify themselves when they do 


come on so that we avoid a quorum. Again, I 


don’t think that’s an issue. 


With regard to conflict of interest I 


would like to have our normal conflict of 


interest discussion. That would be my sharing 


you the realities of the Board and the Board 


members. And then we would ask SC&A, NIOSH 


and the broad NIOSH team which would include 


ORAU and other contractors to clearly identify 


who’s on the call and if any of those 


individuals have a conflict with regard to 


Rocky Flats. 


As is our custom we hope that 


petitioners will join us on these calls, and 


we give petitioners free license to speak as 


they think is appropriate. While we won’t be 

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having a public comment period, we do 


certainly welcome petitioner comments as they 


think those comments are appropriate. 


With regard to Rocky Flats at this 


point based upon the determinations that exist 


for Board members, there are no Board members 


who are conflicted on Rocky Flats. And I 


would then ask the NIOSH team to identify 


themselves and to state any conflicts that 


might exist. 


(Whereupon, the working group teleconference 


was interrupted by phone problems.) 


DR. WADE: Well, I won’t repeat my wonderful 


introduction although I’m sure you would all 


love to hear it again, but I’ll spare you that 


and we’ll go now to the NIOSH team including 


ORAU. We’ll identify who’s on the line and 


identify those individuals who are conflicted 


on Rocky Flats. 


DR. ULSH: This is Brant Ulsh in Cincinnati 


with NIOSH. I am the lead on NIOSH’s 


evaluation of the Rocky Flats SEC petition. I 


have no conflicts at Rocky Flats. I also have 


in the room with me some members of the ORAU 


team, Karin Jessen who took the lead in 

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preparing the evaluation report. Karin has no 


conflicts at Rocky. I also have Jim Langsted 


and Roger Falk who are here in the capacity of 


site experts. They do have long working 


histories at the site. 


DR. NETON: This is Jim Neton, NIOSH, I have 


no conflict at Rocky Flats. 


MR. ALLEN: And this is Dave Allen at NIOSH, 


and I have no conflicts at Rocky. 


MR. ELLIOTT: Larry Elliott, NIOSH, I have 


no conflicts with Rocky Flats. 


DR. WADE: Other NIOSH --


MR. KATZ: Ted Katz at NIOSH, no conflicts. 


MS. HOMOKI-TITUS: This is Liz Homoki-Titus 


of Health and Human Services, and I have no 


conflicts. 

MR. SUNDIN: This is Dave Sundin, NIOSH, no 

conflicts. 

MS. HOWELL: Emily Howell, Health and Human 

Services, no conflicts. 


MR. RAFKY: Michael Rafky, HHS, no 


conflicts. 


MR. MEYER: Bob Meyer --


DR. WADE: Go ahead. 


MR. MEYER: Bob Meyer with NIOSH/ORAU. I 

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have never worked on a contract with the DOE, 


and I have not worked at Rocky Flats. 


MR. LITTLE: Craig Little with the ORAU 


team. I have no conflicts with Rocky Flats. 


DR. WADE: We didn’t hear your name, sir. 


I’m sorry. 


MR. LITTLE: Craig Little. 


MR. ROBINSON: Al Robinson, NIOSH team, I 


don’t have any conflicts. 


MR. SHARFI: Mutty Sharfi, ORAU team, no 


conflicts. 


MR. SMITH: And this is Matthew Smith, ORAU 


team, no conflicts. 


MS. BRACKETT: Liz Brackett with the ORAU 


team, no conflicts. 


MR. McFEE: Matt McFee, ORAU team, and no 


conflicts. 


MR. FIX: Jack Fix, ORAU team, I don’t 


believe I have a conflict. 


MR. POTTER: Gene Potter with the ORAU team, 


and I worked at the site for about ten years. 


MR. HERNSBERGER: This is David Hernsberger, 


ORAU team, I have no conflict. 


MR. LOCHAMY: This is Joe Lochamy, ORAU 


team, no conflict. 

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DR. WADE: Anybody else on the broad 


NIOSH/ORAU team? 


 (no response) 


DR. WADE: SC&A? 


DR. MAURO: This is John Mauro, no conflict. 


MR. FITZGERALD: This is Joe Fitzgerald, no 


conflict. 


DR. MAKHIJANI: This is Arjun Makhijani, no 


conflict. 


DR. BEHLING: Hans Behling, no conflict. 


DR. WADE: Okay, Mark, I think that 


concludes the preliminaries. 


INTRODUCTION BY MR. GRIFFON
 

MR. GRIFFON: Okay, and I think the way 


we’re going to proceed is if anyone was on the 


call yesterday I think that worked pretty 


well. I’d like to have Brant Ulsh go through 


the evaluation report and then give us sort of 


an overview, a summary, of the evaluation 


report. And then after that --


MS. HOMOKI-TITUS: Mark, I’m sorry, this is 


Liz. I’m sorry to interrupt, but I wanted to 


give a brief Privacy Act reminder for 


everyone. 


MR. GRIFFON: Sure, go ahead. 

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MS. HOMOKI-TITUS: Just to remind everyone, 


ORAU, SC&A, NIOSH, the Board, the people who 


are on the call that these SEC petitions are 


still protected by the Privacy Act including 


the information, affidavits and everything 


that’s included in them. So that information 


should not be shared publicly. Just wanted to 


remind everyone that we’re still bound by the 


Privacy Act even though it’s an SEC petition. 


That was all. 


MR. GRIFFON: And the evaluation report 


itself, Liz, has no Privacy information in it 


because it’s been reviewed for Privacy. 


MS. HOMOKI-TITUS: Yes, it’s been reviewed 


for Privacy, that’s fine. 


MR. GRIFFON: So that’s fair to send it to 


the --


MS. HOMOKI-TITUS: Yes, and that’s --


DR. ULSH: Brant, some of the comments do 


deal with affidavits from the petition. 


MR. GRIFFON: Right. 


DR. ULSH: I mean, they’re not, they don’t 


contain personal identifiers, but --


MS. HOMOKI-TITUS: Right, and that’s fine. 


As long as there’s no personal identifiers 

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that’s what we’re protecting. But I just want 


to remind everyone that the information in the 


petition itself is protected, that the 


affidavits in the petition are protected. 


MR. GRIFFON: I think any comments in the 


matrix or in your response, Brant, we were 


careful just to not mention any names anyway. 


MS. HOMOKI-TITUS: Yeah, names, social 


security numbers, dates of birth. 


MR. GRIFFON: Right. 


MS. HOMOKI-TITUS: Identifying information 


that could identify the person who provided 


it. 


MR. GRIFFON: Yeah, I don’t know, again, the 


matrix has not been reviewed for Privacy. I 


don’t know if inadvertently by the description 


of incidents or, you know, the scenarios 


within the affidavit if we inadvertently 


identified someone that --


DR. WADE: Liz, why don’t you stay very 


cautious through the discussions. 


MS. HOMOKI-TITUS: I will. 


DR. WADE: If you see anything then let us 


know. 


MS. HOMOKI-TITUS: Thank you. 

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DR. WADE: Could we also have other Board 


members identify themselves just so I could be 


sure on the record of quorum issues. 


MR. GRIFFON: I’m sorry; I should have done 


that. And this is Mark Griffon chairing the 


work group. 

MS. MUNN: Wanda Munn, no conflicts, Board 

group. 

DR. WADE: No other Board members? 

(no response) 


DR. WADE: Okay, what about other federal 


employees on the line? 


 (no response) 


DR. WADE: And petitioners? 


 (no response) 


DR. WADE: Okay, Mark. 


MR. GRIFFON: So I think we’ll do similar to 


what we did yesterday. If Brant could give an 


overview of the evaluation report itself, just 


sort of a roadmap for it. And then we could 


go from there into the matrix. I’ve updated 


the matrix and sent it out. I hope that 


everyone involved has it. I sent it to 


usually one, I sent it to one person in SC&A, 


I believe, and I sent it to Jim Neton. I was 

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hoping that that would be forwarded from there 


to the appropriate people. If not, maybe you 


could be doing that this morning. 


And the matrix, I just want to step 


through those items to make sure that any 


outstanding actions have either been addressed 


in the evaluation report or NIOSH will address 


them between now and the Board meeting 


hopefully. 


MS. MUNN: Just to be doubly sure, we are, 


however, still working from the matrix that’s 


dated March 28th, correct? 


MR. GRIFFON: We are working from -- you’re 


going to make me pull it up here, Wanda. The 


one I sent out the other night. It should be 


dated March 28th meeting, right? 


MS. MUNN: Right, all right. 


MR. GRIFFON: So it’s the matrix which 


resulted from the last work group meeting, 


correct. And then after the matrix at the end 


of the matrix I think Brant has some sample 


DRs that he just forwarded, and maybe he could 


do similar to what Jim did yesterday which is 


step through those examples. All of us have 


just received them basically so I think just 

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to give us a sense of how they were done, what 


they covered, an overview of the cases that 


are provided. 


And I guess that’s it. I think we can 


start with an overview of the report. 


SEC PETITION EVALUATION REPORT
 

DR. ULSH: Here’s a quick summary of the 


evaluation report for the Rocky Flats SEC 


petition. There were over 200 pages that were 


supplied by the petitioner in the original 


petition. They also supplied over 500 pages 


in a supplement, an addendum, to the petition. 


The petitioner cited seven bases for 


the petition, the first of which was exposure 


to high-fired plutonium oxides or Super-S 


material. The second was inability to link 


exposures to specific incidents. The third 


was periods of inadequate monitoring and lack 


of monitoring and also changes in 


methodologies and inconsistency of procedures. 


The fourth was unmonitored exposures surfacing 


over time. Now these four bases were 


qualified according to the regulation so those 


are the qualified bases for the petition. 


There were three more bases which were 

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not qualified. Those were negative effects of 


site closure on the accuracy of dose 


reconstruction and worker recall monitoring 


programs going away, and also plutonium being 


linked to cancer. Those last three were not 


qualified bases. 


So to summarize the first four, the 


bases that did qualify, the short version is 


periods of inadequate monitoring, lack of 


monitoring, and/or changes in methodology and 


procedures over the history of the Rocky Flats 


plant which the petitioner asserted make 


accurate dose reconstruction over time 


impossible. 


Some examples that they provided 


include no routine lung counting until the 


late 1960s, no monitoring for neutron 


radiation prior to the late 1950s, and neutron 


measurements found to be in error until the 


1970s, and the impossibility of accurate dose 


reconstruction for high-fired plutonium oxide 


or Super-S material. 


And the petitioner requested that all 


represented members past and current of the 


United Steelworkers of America Local 8031 and 

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its predecessors who have worked at all of the 


facilities at Rocky Flats plant between April 


of 1952 and February 15th of 2005 be included 


in the class. 


NIOSH expanded that class to include 


all employees of the Rocky Flats plant 


regardless of union membership. That is any 


worker who worked at Rocky Flats between April 


1952 through February 2005. This class, NIOSH 


decided to expand this class because we 


determined that it would not be feasible to 


segregate union from non-union workers at the 


site with respect to their work and their 


exposures. 


Just a real brief overview of the 


Rocky Flats mission. The primary mission was 


production of plutonium triggers or PITs for 


nuclear weapons, and they also did processing 


of retired weapons for plutonium recovery. 


The evaluation report summarizes the 


development chronology of the key facilities, 


including operations and approximate date of 


operation start up. 


The next big topic covered in the 


evaluation report is internal monitoring. And 

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potential sources of internal exposure, 


significant sources at Rocky Flats include 


plutonium, americium, enriched and depleted 


uranium and the primary mode of exposure would 


have been chronic or acute inhalation or 


through wounds, breaks in the skin. 


The primary bioassay data that is 


available for dose reconstruction is 


urinalysis. And the intake exposure record 


for a typical worker consists of bioassay data 


and reports of incidents and accidents that 


the worker may have been involved in, and/or 


special situations. In some cases nasal 


smears served as supplementary data. These 


were largely screening-type measurements to, 


that were used in (inaudible). 


Fecal sampling was available in some 


cases. It was intermittent while site 


operations were active. The fecal samples 


served primarily as a means to verify an 


intake and to evaluate clearance rates. Fecal 


sampling was also used to quantify a suspected 


intake in some cases. 


The next topic is external monitoring, 


and like most other DOE sites, the technology 

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for external monitoring evolved over time from 


the beginning of the Rocky Flats plant 


operation. The dosimetry evolved from the use 


of film badges in the early years to TLDs. 


And that switch from film to TLDs occurred in 


the 1969, 1970 timeframe. Neutron dosimetry 


consisted of neutron track plates in the early 


years and later NTA films. And in 1971, the 


NTA film was replaced with TLDs. The badge 


exchange frequency was based on the potential 


for external dose. 


Now dosimetry records, dosimetry 


records are available for the entire 


operational period of the Rocky Flats plant. 


There were several electronic databases that 


were used over the history of the site, the 


first of which was the Health Sciences 


Database. That was used from the years 1976 


to 1990. The next one was the Radiological 


Health Record System, and that was, that 


covered the years 1990 through 1999. And 


finally, the HIS-20 Database, Health Physics 


Information System. And that covers the years 


1999 through 2005. 


I should point out to you that as 

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these systems were upgraded, these electronic 


databases, the data that was contained in a 


database was migrated to the system that 


replaced it. 


Next, CER provides evaluation of major 


topics in the petition. All seven of the 


bases brought up by the petitioner are 


addressed and discussed in Section 7.5 of the 


evaluation report. And in addition, nine 


specific statements by the petitioners are 


discussed. The petitioner also supplied 22 


affidavits. However, the majority of the 


affidavits deal with lack of monitoring. 


NIOSH decided to discuss nine of the 


representative affidavits explicitly. 


Other general concerns raised by the 


petitioners are discussed, and these include 


the use of lead aprons and their possible 


effects on dosimetry, improper control badge 


storage, and we also discussed the three major 


fires that occurred over the history of Rocky 


Flats. Those occurred in 1957, 1965 and 1969. 


And that is the nickel tour of the 


evaluation report. 


MR. GRIFFON: Brant, can I ask you to, on a 

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couple of the topics, if I could ask you to 


expand a little maybe on the processes. You 


hit on the major processes. There was also 


some thorium processing and americium recovery 


work that were kind of separate from those 


main ones you mentioned. Can you explain the 


thorium and americium? 


DR. ULSH: The americium is probably the, 


that started in, let’s see, I think 1957 if my 


memory serves me correctly. And that was 


separating americium from plutonium. In the 


early years, let’s see, I don’t remember 


exactly what process they used. I think it 


was a -- well, I would be guessing. But they 


did that in 1957 up to I believe 1967 when 


they implemented the molten salt extraction 


process. And that was used over the next 


several years. I’m looking at Jim Langsted to 


see if he’s got the -- when did that end, Jim? 


MR. LANGSTED: I don’t have that 


information. 


DR. ULSH: Don’t know? Okay. 


That started in ’67 and operated for a 


number of years. In 1973, okay, in 1973, that 


was replaced with a cation exchange procedure. 

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And the process underwent another major change 


in 1975 when ammonium thiocyanate steps were 


eliminated. By the way, Mark, this is 


described on page 20 of the ER, 5.2.2, I 


believe. 


MR. GRIFFON: Yes, I did see it briefly, 


yeah. 


DR. ULSH: Yeah, that’s the americium. 


Now with regard to thorium --


MR. GRIFFON: I guess the question there was 


there wasn’t necessarily any separate 


monitoring for those workers for americium 


exposures. 


DR. ULSH: There was monitoring, Mark, in 


the early years. Health physics had available 


gross alpha techniques, which would be capable 


of detecting both thorium and americium. 


Beginning in, I believe, 1963, Rocky Flats 


began widespread americium-specific bioassay. 


Although I think we do have some early 


examples of, earlier examples of bioassay 


specific for americium. By and large that 


ramped up in 1963. 


DR. MAKHIJANI: Brant, this is Arjun. Were 


you referring in the early years’ gross alpha 

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for bioassay like urine, or air monitor? 


DR. ULSH: No, gross alpha for bioassay in 


urine. 


MR. GIBSON: Excuse me. Lew and Mark, this 


is Mike. My power came on so I’m back online 


now. 


DR. WADE: Oh, Mike, good. 


MR. GRIFFON: Thank you. 


DR. WADE: Maybe a quick summary for Mike? 


I mean, we, after the introductions and the 


conflict of interest discussions, we started 


asking Brant to review the petition evaluation 


report, and that’s what he was doing. 


Brant, could you do just a 15-second 


summary? 


MR. GIBSON: I’ve been online for about 15 


minutes. I was just trying to find a 


convenient time to cut in. 


DR. WADE: Okay, fine, thank you. Go ahead, 


Brant. 


MR. GRIFFON: I guess the thorium then, 


Brant. 


DR. ULSH: Yeah, beginning in 1952, Mark, 


thorium -- this is discussed on page 18 of 86 


-- thorium is used on the site in quantities 

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in small enough that effluents were not 


routinely analyzed for thorium. The principle 


MR. GRIFFON: I don’t understand what that 


means. Can you explain what, because I see in 


some cases up to 238 kilograms a month 


inventory. 


DR. ULSH: Well, as you know --


MR. GRIFFON: Small enough that effluent 


wasn’t monitored routinely. I’m not sure I 


understand what, I mean there must have been 


some cutoff for effluent monitoring based on 


how much was processed. Is that what you’re 


saying? 


DR. ULSH: I really can’t give you any 


details, Mark, on what the criteria were. 


MR. GRIFFON: Okay, all right. 


DR. ULSH: In terms of thorium though the 


primary radiological hazards at the site were 


uranium and plutonium. And as you know, 


thorium has a very low specific activity, 


about one-third that of DU, and at the Rocky 


Flats site, DU was just barely recognized as 


radiological hazard. So the site pretty much 


considered that thorium was not a major 

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radiological hazard, and we’re not really 


aware of any credible scenario where a 


significant uptake would have occurred. 


MR. GRIFFON: What buildings would that have 


been associated with, the thorium work or was 


it multiple buildings? 


DR. ULSH: Hold on just a minute, Mark. Let 


me see if I can find anything on that. 


MR. GRIFFON: SC&A, did you guys look into 


the thorium question? I don’t recall much 


discussion on thorium before. 


DR. ULSH: Okay, Mark, I’ve got some 


information here for you I think. In Building 


71 there was some small scale thorium work. 


In Building 881 there was light production of 


thorium parts and some thorium strikes. And 


let’s see, in Building 334 there were small 


quantities of thorium and depleted uranium 


that were sheared. And this comes from the 


Chem Risk report, Mark. 


MR. GRIFFON: Okay, thanks. 


Any other follow up to that, SC&A? 


Did you have any comments on the thorium 


processing, or did you recall reviewing this? 


DR. MAKHIJANI: Is Kathy on the call? 

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MR. FITZGERALD: No, Kathy’s not on the 


call. I think we identified it as one of the 


other nuclides but didn’t --


DR. ULSH: Actually -- is this Joe? 


MR. FITZGERALD: Yes. 


DR. ULSH: Actually, you didn’t specifically 


identify it as one of the other nuclides. I’m 


thinking of, if I’m thinking of the right 


comment, Joe. That’s the ones that you sent 


over last week, the 17 --


MR. FITZGERALD: No, no. 


DR. ULSH: And there were two additional 


ones? 


MR. FITZGERALD: No, no, that was, I’m not 


talking about the original site review. 


DR. ULSH: Oh, I see. 


MR. FITZGERALD: We certainly looked at what 


was in the site profile and identified a 


number of nuclides, but we didn’t pursue 


thorium per se. 


DR. ULSH: Yeah, I think it was just 


generally not recognized as a major hazard at 


Rocky Flats. It was primarily uranium and 


plutonium. 


MR. GRIFFON: And then if, that’s really all 

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I had on the process areas unless other people 


had any clarifications they wanted of the 


process descriptions. 


DR. MAKHIJANI: No, I had a question about 


americium monitoring, but that --


MR. GRIFFON: Yeah, then I was going to go 


on to the monitoring. If you could, and maybe 


this is restating some of it, Brant, I 


apologize, but we’re kind of reviewing this 


real time, too. 


DR. ULSH: Yeah, I know. 


MR. GRIFFON: If you could give us a little 


summary of monitoring data that you’ll be 


relying on and maybe start with internal 


monitoring data. 


DR. ULSH: Okay, for internal monitoring 


data we’re primarily going to be relying on 


urinalysis. That’s almost always our primary 


bioassay data. In the later years starting --


let’s see, when did in vivo counting start? 


DR. MAKHIJANI: ‘Sixty-five. 


DR. ULSH: Nineteen sixty-five and later we 


also have lung counts that we can use. So if 


there’s a situation that would require us to 


use air monitoring at Rocky, I’m not aware of 

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it. 


What’s that? 


MR. GRIFFON: And it seems like -- I’m 


trying to recall, but is a lot of the 


urinalysis data pre-’65? Is there a lot of 


less than detectable data? 


DR. ULSH: Well, Mark, that’s a good 


question. I don’t know the answer to that off 


the top of my head. 


MR. GRIFFON: We might hit on more in the 


matrix. I don’t know, but Arjun, did you --


DR. MAKHIJANI: No, I’ve not looked other 


than the data integrity questions and kind of 


compiling things from the petition. I haven’t 


actually delved into the details of Rocky 


Flats. 


MR. GRIFFON: I’m thinking about the wrong 


site, too. 


DR. ULSH: There was a significant fraction 


that was left in the reporting level, Mark, 


which was, I think it was 0.88 dpm per --


MR. LANGSTED: Bioassay is for plutonium. 


DR. ULSH: For plutonium. I can’t really 


tell you what fraction of the measurements 


that we have are less than their reporting 

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level. 


MR. GRIFFON: And the urinalysis records 


available are primarily for plutonium or are 


they -- there’s gross alpha as well you said, 


right? 


DR. ULSH: Yes, there is gross alpha; there 


is plutonium specific; there is uranium 


specific. I think those are the major ones. 


DR. MAKHIJANI: Brant, this is Arjun. Don’t 


you also have americium monitoring? 


DR. ULSH: Yes, americium specific beginning 


in, I think, 1963. 


DR. MAKHIJANI: Nineteen sixty-three? 


DR. ULSH: Yeah, that’s -- is this Arjun? 


DR. MAKHIJANI: Yeah. 


DR. ULSH: Okay, that’s described, I think, 


in Attachment A of the internal TBD. 


MR. GRIFFON: And nothing on thorium and 


maybe for the reasons you’ve previously 


described but nothing on thorium specific? 


DR. ULSH: I think that that is the case, 


Mark. Gross alpha would have been used to 


measure that, but for the reasons I stated. 


It wasn’t generally recognized as a big hazard 


at Rocky. 

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MR. GRIFFON: And then whole body counting 


started in, I think you just said this, but 


’65? 


DR. ULSH: Yes. 


MR. LANGSTED: Lung. 


DR. ULSH: That was lung counting. 


MR. GRIFFON: Or lung counting, yeah. 


DR. ULSH: I should mention also that Rocky 


Flats did have some wound counters. We don’t 


make great use of those in dose 


reconstructions is why we didn’t focus on it 


too much. Those were used mainly as a 


screening technique to determine whether a 


worker had received a contaminated wound. But 


again, we relied primarily on the urinalysis. 


MR. GRIFFON: Right, and again, just to 


refresh our memories, I think for Rocky you 


had mentioned on several other work group 


calls that most of the -- and maybe I’m 


overstating this, but I think most of the 


individuals have individual bioassay records. 


In other words the use of the coworker models 


would not be a high percentage or is that --


DR. ULSH: That is true, Mark, and at the 


risk of putting out old numbers, let me see. 

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Give me just a second here. Okay, here it is. 


I just pulled these numbers off NOCTS this 


morning. We have a total of 1105 claims for 


Rocky Flats. We have completed about 62 


percent of those. And as of a couple of weeks 


ago there were only, I think, two cases on 


hold for coworker data. So you’re right. 


We’re going to spend a lot of time talking 


about this, but --


UNIDENTIFIED: Brant, those were for 


external coworker, not internal. 


DR. ULSH: Okay, thank you. That was Matt, 


right? 


 (no response) 


DR. ULSH: Okay, well, the answer to your 


question, Mark, is no, there’s not --


MR. GRIFFON: Not a heavy reliance on the 


coworker --


DR. ULSH: Exactly, although we will spend a 


lot of time talking about it. 


MR. GIBSON: Brant, this is Mike. 


DR. ULSH: Yes, Mike. 


MR. GIBSON: I have a question. As far as 


the data and stuff have, has NIOSH looked into 


what the FBI or anyone may have found based on 

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those, when they raided the place because the 


incinerators were burning plutonium? 


DR. ULSH: Yeah, Mark, or I’m sorry, Mike, I 


believe that the subject of that FBI 


investigation was environmental violations, 


violations of environmental statutes. We have 


had some communications with the petitioner. 


This has, well, as you know, this has 


come up in terms of their data integrity 


questions about there are some allegations 


that there was systematic -- or that’s 


probably not the right word. There were 


allegations that there was fraud and 


manipulation of the dosimetry results. That’s 


not tied to the FBI investigation, and I do 


have more to say about that topic when we go 


through the matrix items. 


MR. GRIFFON: But you’ve reviewed the FBI 


investigation findings to make sure that 


there’s no tie or no findings in, I mean, I 


understand there it was mainly more focused on 


the environmental side, but it is sort of 


hanging out there as a major thing that 


happened at that site. Has NIOSH or the ORAU 


team looked into those findings from that 

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investigation and the grand jury findings, I 


guess? I think there were grand jury 


findings. 


DR. ULSH: Mark, the only thing I can tell 


you is we didn’t spend a lot of time on that 


because, you know, again, it was violations of 


environmental statutes. So the answer to your 


question is no, we haven’t spent a lot of time 


with it. 


MR. GRIFFON: All right, and I was actually 


coming to the, skipped ahead a little bit on 


the data integrity, but can we go back to just 


an overview of the external monitoring? Go 


through the internal monitoring and then we’ll 


go to data integrity again. 


DR. ULSH: Data integrity is, well, as you 


know, is a big topic in the comment responses. 


In terms of external, in the early 


years, you know as at most sites, not everyone 


was monitored, but it ramped up pretty quickly 


at Rocky Flats. I believe it was in 1964 


where they integrated the dosimetry with the 


security badges. In the early years for 


neutrons they used neutron track plates 


followed by NTA films, and those were swapped 

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out for TLDs in the ‘70s, ’71. And films were 


also used for beta-gamma. 


And TLDs came into play for beta-gamma 


in the 1969-’70 timeframe. And we have a very 


high percentage of monitoring for workers, 


especially when they integrated the badges. 


Now after ’91 in the D&D period, only workers 


who were judged to have a potential exposure 


of greater than 100 millirem -- is that per 


year? Yes, per year -- were badged. Though 


for that later period not everyone was badged. 


But we do have dosimetry for all years 


available for coworker data should we need it. 


MR. GRIFFON: And I think you said prior to 


the NTA film, there was going to be, you were 


going to apply neutron-photon ratios for 


calculating neutron doses. Is that correct or 


DR. ULSH: Yes, that is correct, Mark. 


MR. GRIFFON: And what are the, I’m sure 


you’ve mentioned this before, but it’s just a 


refresher. Where are those derived from, the 


neutron-photon ratios? 


DR. ULSH: I am going to ask Roger Falk to 


give you some details on that. 

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MR. GRIFFON: It’s probably a review, but 


it’s, we’re covering a lot. 


 MR. FALK: That is described in Section 11 


of the Neutron Dose Reconstruction Project 


protocol. And it was based on the neutron 


doses derived from the NDRP project readings 


divided by the gamma results for those, and it 


was based on the building. And so we have the 


total ratio for those matched neutron and 


gamma results for the building, and that 


determines the building ratio. And then we 


had a combination method which used the 


building ratio as well as the average neutron 


dose for a specific worker if that worker had 


the qualified neutron readings for that year 


and for that building. 


MR. GRIFFON: Okay, and Roger, the, I think 


a conclusion of your report was that the 


likely highest neutron exposed individuals 


were not monitored. How did you establish the 


ratios for those buildings? 


 MR. FALK: We used the --


MR. GRIFFON: Seven seventy-one? 


 MR. FALK: We used the building ratios to 


determine for the first full year that they 

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were monitored, and we have quality data. And 


that was 1959, and we back extrapolated it to 


the earlier years. 


MR. GRIFFON: And similar processes were 


taking place is the assumption? 


 MR. FALK: Yes. 


MR. GRIFFON: Okay, thank you. 


Any other questions on the monitoring 


program, external monitoring program? 


Clarifying points, I guess, is what we’re 


really what we’re looking for. 


 (no response) 


MR. GRIFFON: Not hearing any, I’ll ask 


Brant to briefly go over the data reliability 


question. 


DR. MAURO: Mark, this is John Mauro. I 


took some notes as I was reading, and there 


was just one area that I noted. And this had 


to do with this, the lead apron. I don’t know 


if this is the appropriate time to bring this 


up, but since you’re talking external 


monitoring --


MR. GRIFFON: Yeah. 


DR. MAURO: I noticed that one place 


indicated that the lead apron only shielded 

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out zero-to-50 percent of the photons. And I 


was surprised to hear that considering the 


very low energy, certainly of the plutonium x-


rays. So I was surprised at such a small 


fraction of the photon. Radiation was 


shielded by the lead apron. I thought perhaps 


we’d get clarification on that. 


MR. LANGSTED: This is Jim Langsted. Yes, 


that’s the results of measurements that were 


taken at Rocky Flats with the lead aprons and 


the dosimeters that were in use, I believe, in 


the early 1990s timeframe. 


DR. MAURO: So I guess that would be for the 


americium, like a 61 keV as opposed to the 


lower energy x-rays? 


MR. LANGSTED: Well, that was in a plutonium 


storage vault, and so that would have been a 


combination spectrum typical of that 


environment. 


DR. MAURO: Okay, I guess it might be 


worthwhile doing a quick calculation to see if 


that makes sense. 


DR. BEHLING: John, this is Hans. It may 


also be due to the fact that you do have a 


beta component and an introduction of 

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Bremsstrahlung that may actually add some 


photon components that would otherwise not be 


there. 


DR. MAURO: But it was basically saying that 


the lead apron shielded out virtually a 


hundred percent. 


DR. BEHLING: Yes, but you may also 


introduce new photons so the result of betas 


impinging on the lead that then converted to 


Bremsstrahlung. 


DR. MAURO: Oh, I see what you’re saying. 


MR. GRIFFON: The beta was in a storage 


vault, Hans? Would there be beta? 


DR. BEHLING: Well, again, I don’t know what 


the source term is, but you do have ^ 


associated with uranium and other 


radionuclides that may have some involvement 


in introducing Bremsstrahlung. 


DR. MAKHIJANI: Yeah, that’s a peculiar 


thing to --


MR. GRIFFON: I agree in theory, but I -- a 


plutonium storage vault, I don’t know that 


that would --


MS. MUNN: Physically plutonium probably 


wouldn’t contribute much I wouldn’t think. 

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MR. GRIFFON: Anyway, so that’s -- and also, 


I think we’ve -- and this will probably, we 


can follow through on this a little more in 


the matrix because I know there was a question 


on where employees had the badges and that 


might impact on how you calculate these 


ratios. So I think we have that as a follow 


up item on the matrix. 


DR. ULSH: Yeah, Mark, this is discussed in 


comment number eight. These are the ones that 


SC&A has labeled data integrity comments. 


MR. FITZGERALD: Mark, this is Joe 


Fitzgerald. May I suggest, Kathy Robertson-


DeMers is going to join the call a little 


late, but I talked to her this morning. I 


think she should be part of this conversation. 


She should be on, I think, within the next 15, 


20 minutes. 


MR. GRIFFON: Okay, again, this is really an 


overview, and when we get to the matrix, when 


this comes up, Kathy should be on the call by 


then I would assume. 


If there’s nothing more on external 


monitoring, I wanted to go into, if, Brant, if 


you could give an overview of what NIOSH has 

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looked at in terms of data reliability. And I 


should say, well, maybe I should ask this 


question. Data reliability mainly we’re 


looking at this for the purposes of these, of 


the databases. And the database information 


would certainly be used for coworkers. And 


we’ve already heard that there is likely a few 


claimants that will be, that will have to rely 


on coworker data for their dose assessment. 


However, I’m not sure -- and maybe you 


can answer this question, Brant -- whether the 


data in an individual’s file is actually hard 


copy raw data, urine cards, you know, copies 


of film badge cards that were generated for 


the input into the database or whether they’re 


printouts of database. Oftentimes we’ve seen, 


some of the cases we’ve reviewed anyway, it’s 


been actual just printouts of the, for 


example, HIS-20 data records for that 


individual. 


And that certainly would not, even 


though it’s that individual’s personal data, 


it still raises a question of that database 


reliability. So are those, the claimants, 


when you say that only two are relying on 

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coworkers, the other ones have their 


individual data. Is that individual data raw 


data or is it printouts from the databases 


that we’re talking about. 


DR. ULSH: Well, in my experience, Mark, the 


dosimetry files that we have for claimants 


include both the raw records and the HIS-20 


printouts. Now this question is covered in, 


let’s see, data integrity comment number four. 


And so what I might do is -- Craig Little, are 


you out there? 


MR. LITTLE: Yes, I am. 


DR. ULSH: This might be a good time, Craig, 


to describe some of the comparisons that you 


have done. And for the benefit of people 


listening in, I would direct you to the 


comment responses, page 13. 


MR. GRIFFON: Now is this the one you just 


sent out, Brant? 


DR. ULSH: Yeah, I put it on e-mail --


MR. GRIFFON: April 06 comment responses? 


DR. ULSH: Yes, yes, it is. So it’s page 13 


is the beginning, I believe of what Craig is 


going to be talking about. 


Craig, if you’re ready, go right 

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ahead. Hello, Craig? 


MR. LITTLE: Can you hear me? 


DR. ULSH: I can hear you. 


MR. LITTLE: Okay, good enough. We did two 


exercises to compare a claimant’s file. The 


first thing we did was to compare original 


laboratory --


MS. MUNN: You’re fading in and out here. 


DR. WADE: You’re cutting out. 


MS. MUNN: You’re cutting out badly. 


DR. WADE: We don’t hear you at all now. 


DR. ULSH: Craig, are you out there? 


(no response) 


DR. ULSH: All right, until Craig comes back 


in, let me try to walk you through some of 


these anyway as best I can. 


The first exercise that they did 


compared original beta/gamma datasheets that 


were in the claimants’ files. And they 


searched, let’s see here, 2800 pages of those 


worksheets and time data for claimants. And 


that, when they compiled that that was 400 


worker quarters of data. 


Let me see, I’m skimming through 


Craig’s stuff here. And an example of that is 

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shown in Figure 5 which is on page 14. So 


there, Mark, is an example of the handwritten, 


the hard, however you want to describe that, 


the paper records, I guess, the scanned image 


of it. 


And they next retrieved data in the 


form of printouts from the claimant’s file. 


Craig, are you out there yet? 


 (no response) 


DR. ULSH: Okay, I guess not, so I will 


continue. 


There were 400 worker quarters of data 


as I mentioned, a total of 152 complete worker 


quarters were found in which there was 


complete agreement. And of those, there were 


33 complete worker years and an additional 20 


worker quarters of data. Complete agreement, 


when we say complete agreement, what we mean 


is that the total penetrating dose for a given 


worker year or given worker quarter as 


represented in the claimant file was exactly 


the same as what was taken from the beta/gamma 


worksheet. And that indicates that the data 


on the handwritten beta/gamma worksheets were 


accurately transcribed into the database. 

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Now there were also an additional nine 


complete worker years of data that showed some 


disagreement between the laboratory sheets and 


the claimant files. I’m pretty much just 


reading off page 13 here. In those instances 


the explanation that is most likely is that 


there was some neutron exposure that wasn’t 


captured on the beta/gamma worksheets. And 


the reason we conclude that is that the 


claimant file dose was always, without 


exceptions, larger than the beta/gamma 


worksheets. 


So to state that another way, the data 


in the claimant file included doses not only 


from the beta/gamma doses, but it also 


includes neutron exposures. And you wouldn’t 


see that on the beta/gamma sheets. So the 


dose, the bottom line is that the dose for the 


penetrating radiation in the claimant’s file 


was always the bigger number if there was 


neutron exposure. 


So what we concluded from that is that 


the dosimetry data in the claimant file 


accurately represents the data from the 


original beta/gamma worksheets. And in the 

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instances there were differences, it can be 


explained by a neutron dose. 


Craig, are you back yet? 


MR. LITTLE: Yeah, I don’t know what 


happened. 


DR. ULSH: Okay, you’re still a little faint 


if you can speak up, and let me tell you where 


I am. I’m at the bottom of page 13. I just 


covered the section called Comparison of 


Original Datasheets to Data in the Claimant 


File. So if you can pick it up with 


Comparisons of Original Datasheets to Data in 


the HIS-20 File, that would be great. 


MR. LITTLE: Am I clear now? 


DR. ULSH: Yes. 


MS. MUNN: Yes. 


MR. LITTLE: I’m on a landline so that’s 


better. 


Okay, so you went through the claimant 


file part. All right, we also examined 


beta/gamma film badge worksheets and compared 


them to the penetrating radiation listed in 


the HIS-20 database for non-claimants. The 


previous exercise was strictly for claimants. 


And for each worker year we combined -- the 

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HIS-20 database only has annual data in it. 


And so what we did was for each worker 


year, we found four sheets, four quarterly 


datasheets and combined those to create an 


annual beta/gamma dose record. We found 30 


such worker years and compared those to the 


same worker year compiled by HIS-20. Of those 


30 years we found 22 that were totally 


complete and agreed 100 percent with the data 


in the HIS-20 database. 


For five worker years out of the 30 we 


found one quarter was missing. That is, there 


was just blank data. I could not, that 


doesn’t mean it’s missing. It means in the 


file that I had we could not find that 


particular quarter for that worker for that 


year for that building. But the good news on 


that was that the annual total that was, that 


we calculated from the three quarters that we 


had was completely agreed with the HIS-20 


database. So if you combine those two, 90 


percent of the data that we looked at 


completely agreed with the HIS-20 database for 


the same worker in the same worker year. 


For three worker years that we looked 

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at some quarterly data were missing or blank 


and the annual totals didn’t agree. But in 


all three of these instances, the HIS-20 


database values were higher than the data that 


we pulled out of the beta/gamma worksheets. 


So what this likely means is that there was 


missing data for the years that we couldn’t 


find that’s been captured by the HIS-20 


database. Although we didn’t find it, that 


just means that the files that we looked at, 


which were a PDF again of the six years that 


we looked at, there were sheets missing in the 


file that we looked at. 


MS. MUNN: This is Wanda. But I understand 


correctly the error was always on the high 


side for the database we’re relying upon, 


correct? 


MR. LITTLE: That’s correct. 


DR. ULSH: Mark, where do you want to go 


from here? Hello, Mark, are you there? 


(no response) 


DR. ULSH: Is anybody there? 

DR. WADE: This is Lew Wade. 

MS. MUNN: Wanda’s always there. 

DR. WADE: Mark, are you with us? 
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 (no response) 


DR. WADE: Let’s give Mark a moment. 

MS. MUNN: He seems to have dropped off. 

DR. WADE: He usually comes back. 

MS. DeMERS: This is Kathy DeMers. I just 


joined the call. 


DR. WADE: Hi, Kathy, we’ve lost Mark for a 


minute so we’re trying to wait for him to 


reconnect. 


MS. MUNN: We hope it’s momentary since I 


don’t have his list of specific concerns. 


DR. ULSH: Kathy, we’re just at the overview 


point of the discussion, haven’t gone into any 


depth on these particular issues. 


MS. MUNN: In Mark’s absence maybe we can 


just continue the comments that we were going 


through because I know there was considerable 


concern about the next data integrity comment. 


In earlier conversations we’ve been concerned 


about how widespread the issue of unauthorized 


work practices has been, I think, alleged by 


more than one claimant. 


DR. ULSH: Wanda, that is addressed in one 


of the matrix items. I’d be happy to go into 


it now if you’d like to or we can wait and go 

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through it as a matrix item. Whatever you 


prefer. 


MS. MUNN: Probably the matrix item would be 


the best place to address it would be my 


guess. 


DR. MAURO: Along these lines, this is John 


Mauro, by way of orientation for myself, 


addressing these data integrity issues there 


was a memorandum that SC&A issued on April 5th
 

which was the results of Kathy DeMers’ visit. 


And to what degree does the discussion we’re 


having now overlap with or is related to the 


material provided in the minutes of that site 


visit? 


DR. ULSH: Well, John, I didn’t have time to 


explicitly merge in the material from Kathy’s 


report into the evaluation report because that 


went out on Friday. 


DR. MAURO: Oh, no, I appreciate that. I 


was just asking more from --


DR. ULSH: No, no, I understand; however, 


the comment responses that I’m referring to, 


the, I think it’s called 5 April 2006, those 


do include responses to the issues raised in 


Kathy’s report. 

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MR. LITTLE: And I might add the 


organization in terms of the sequence of 


issues is the same, so it’s actually pretty 


easy to follow. Additional language has been 


added. 


MR. GRIFFON: Hello. Maybe that power loss 


is going around. My phone cut out for a 


little while there. 


DR. ULSH: Okay, Mark, we just finished up 


everything. 


Okay, Mark, I’m not sure where we lost 


you. Craig was describing the exercises that 


we did to compare HIS-20 versus raw records. 


Did you catch that? 


MR. GRIFFON: I didn’t catch that. I 


apologize. 


DR. ULSH: Shall we repeat, Craig? 


MR. GRIFFON: Briefly if you can, I mean, I 


don’t --


DR. ULSH: Craig, give him the talking 


points if you would. 


MR. LITTLE: We pulled 30 worker years worth 


of data, original datasheets from the 


beta/gamma worksheet and compared those to 


HIS-20 data. HIS-20 data are annual so we had 

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to find four quarters of data to find, data to 


compare with HIS-20. In 22 of those 30 we 


found all four quarters in the files, and they 


were in complete agreement with HIS-20. There 


were five worker files where one quarter of 


data was missing. That is, it just means it 


was missing from the files we looked at, but 


the total that was calculated from those three 


quarters was the same as the total in the HIS20 database for the annual. And there were 


three worker years that we did not find data 


for where either the quarterly data was 


missing or blank, and for some reason then the 


numbers did not add up to the annual. 


But in those cases the HIS-20 database 


values were always higher than the data that 


we pulled off of the beta/gamma worksheet. 


Which simply means we didn’t find the 


worksheet, but when it was transcribed at the 


plant or later, it was probably captured and 


put into the HIS-20 database because we didn’t 


find any instances where HIS-20 had lower 


beta/gamma values or penetrating radiation 


values than the beta/gamma worksheets whether 


they were missing or complete. 

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MR. GRIFFON: Craig, you said 30 working 


years. How many individuals was that 


covering? 


MR. LITTLE: It was 30 worker years. 


MR. GRIFFON: It was 30 different workers? 


MR. LITTLE: Yeah, well, it may not, 


actually, there may have been double years for 


some of the people. 


MS. DeMERS: Was this an individual from the 

petition? 

MR. LITTLE: An individual from where? 

MS. DeMERS: From the petition. 

MR. LITTLE: No. 

MR. GRIFFON: Would have been claimants 


though or people with a file? 


MR. LITTLE: No, these were not claimants. 


These were non-claimants. These were just 


randomly sampled workers. 


MS. MUNN: Then there were multiple workers? 


There was not just a single worker or two. 


MR. LITTLE: Yeah, that’s correct. There 


were multiple workers. 


MR. GRIFFON: But not necessarily 30. You 


don’t know how many. 


MR. LITTLE: No, and I don’t have that off 

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the top of my head. 


MR. GRIFFON: And how, if these weren’t 


claimants, I thought there was an issue about 


getting raw records for non-claimants because 


that had come up before as far as pulling the 


string on some of these individual affidavits 


that have, Brant. You talked about you might 


not be able to do it because of the 


availability of those records since they 


weren’t claimants. 


DR. ULSH: Mark, I think -- Craig, jump in 


and correct me if I’m wrong here, but I think 


when we talked about this last time, we 


decided that at that time Craig had compared, 


done his comparison using claimants.
 

But we decided that we needed to pull 


the string a little bit further because I 


recall that when the site supplied data to us 


for a particular individual, a claimant, they 


did an additional QA step on that data. So it 


wouldn’t be surprising that that data might 


have better agreement than for non-claimants. 


And that’s why we had Craig go back and look 


at non-claimants. 


MR. LITTLE: Yes. 

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DR. ULSH: And I accurately summarized that, 


Craig? 

MR. LITTLE: Yes. 

MS. DeMERS: And what areas did these people 

work in? 

MR. LITTLE: Well, I’m trying to think 

exactly which buildings. I’m going to say 


Building 21, Building 81, Building 86, 


Building 83, Building 44, Building 59 maybe. 


I don’t have the file up in front of me, but 


it was a variety of different buildings. 


MS. MUNN: Okay, and were there any 


buildings from the 700 area? 


MR. LITTLE: I don’t think I had any in the 


700 area in this sampling. 


MR. GRIFFON: Just to shorten this 


conversation maybe, is this written up 


anywhere, Craig? Did you provide that? 


MR. LITTLE: Yeah, I provided that to Brant. 


DR. ULSH: Yeah, this is in, Mark, we’re 


looking at the --


MR. GRIFFON: It is in these comments, April 


5th? 


DR. ULSH: Yes. Page 13 of that. 


MR. GRIFFON: Oh, that’s right. You said 

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that. I’m sorry. 


And these 30 worker years, were they, 


I mean, they weren’t in the ‘90s were they? 


Were they --


DR. ULSH: No, they were the ‘60s. 


MR. GRIFFON: Okay, I assumed that, but I 


don’t want to assume. 


MR. SMITH: This is Matt Smith. I’ve just 


got one more thing to add, and it’s based on 


what others have said at other meetings. As 


far as the rest of the data in terms of its 


validity for everybody who’s a claimant on 


this program as I understand it, Kaiser-Hill 


went through and did a quality assurance check 


back to the worksheets. 


MR. GRIFFON: Okay, and I asked about that 


before, too, and there’s no sort of roll up on 


that, is there? You just did individual 


quality assurance against the worksheets. But 


there’s no sort of roll-up analysis of we 


looked at, you know, 500 of these and we found 


discrepancies in only one percent or whatever, 


and there’s nothing like that that exists, 


Brant. Is that correct? 


DR. ULSH: That is correct, Mark. We are 

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working with Ken Savitz, and Ken and his staff 


are the ones that did the QA procedure that 


we’re talking about. And according to Ken 

there is no roll up. They just did that on an 

individual basis. 

MR. GRIFFON: All right, thank you for going 


through that again. I apologize. 


DR. ULSH: You’re welcome. 


MR. GRIFFON: And data reliability then, did 


you talk at all while I was off the phone 


about the, was this the internal? 


DR. ULSH: Let me point out the difference 


for the situation between external and 


internal. For external with regard to the, 


especially the coworker data, we are relying 


on data from the HIS-20 database. For 


internal it’s a little different. We’re going 


to be relying on Speeder^ data, and so we have 


compared internal data from Speeder HIS-20. 


And Jim Lochamy, are you out there? 


MR. LOCHAMY: Yes, I am. 


DR. ULSH: Okay, it’s show time. 


There were a couple of documents that I 


placed, I e-mailed to you. I don’t remember 


the exact titles. I think if you open up the 

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documents they’re called Comparison of Rocky 


Flats, HIS-20 and CEDR Databases. 


MR. GRIFFON: Internal comparison of HIS-20 


and CEDR is one of them. 


DR. ULSH: Yeah, and there’s one called 


Follow Up. So those are the documents that 


Joe is going to be talking about. I should 


point out that there’s an error in the title 


of the first one, and that’s my fault. I 


missed taking that out. We took out the 


external because we’re not going to use CEDR 


data for external. 


So Joe, if you could walk us through 


your two analyses? 


 MR. LOCHAMY: Okay. Basically, the first 


analysis was an attempt to try to compare the 


two databases without literally going back and 


doing the entire coworker analysis over again 


using the other database. That’s a fairly 


large task. So what we tried was for 


plutonium and uranium, we did multi-year 


statistical analyses so that we would run 


multiple years at one time instead of doing it 


quarterly or annually as we had done with the 


actual coworker database or the actual 

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coworker statistics. 


We also did not do anything to the 


data to handle of zeros and other data that 


are handled somewhat differently in the actual 


statistical analysis. And if you look at the 


-- let’s see, you said you have extracted just 


the internal. I’m looking at that one copy. 


Is that correct? Hello? 


MR. GRIFFON: I’m not sure who you’re 

asking. 

 MR. LOCHAMY: I guess I’m just asking 

whoever did the extraction. I forgot who did 


it. You separated the internal and external 


and everyone is just looking at the internal 


version? 


DR. ULSH: That is correct, Joe. 


 MR. LOCHAMY: So if you look at Tables 1 and 


2 on pages three and four, you see actually 


more data than one needs or wants, but you can 


see that for the multiple years of plutonium 


and uranium there is a rough approximation of 


the number of samples. They’re essentially 


the same except in most case there is more 


data in the CEDR database than there is in HIS 


database except for the years ’86 to ’88 which 

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I’m assuming is because the CEDR database was 


extracted in 1988 and the year was not 


complete. The only explanation I can come up 


with. But in all other years there are more 


data points in the CEDR database than there 


are in the HIS-20 database. That, I guess, is 


just an observation. As a general rule, the 


maximum --


MR. GRIFFON: I was going to ask. You don’t 


know why that would be? 


 MR. LOCHAMY: Do not know why that is. 


MR. GRIFFON: It’s quite significant, you 


know. It’s not just a little --


 MR. LOCHAMY: Certainly for the ’86 to ’88 


there’s huge difference. There’s like a 


factor of two difference. 


MR. GRIFFON: Well, yeah, but even in the 


early years, I mean, I’m looking at ’53 to 


’57, 4300 versus 3000. 


 MR. LOCHAMY: Yeah, I do not know why they 


are, why CEDR, which is what we used, has more 


data in it. It does appear from my later 


study that most of those entries, those 


additional entries, are zero entries. So I’m 


not sure what happened there exactly. 

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Anyway, if you look at it, in same 


cases the two databases, the key data that are 


of most interest are the equation geometric 


mean and the equation 84th percentile which are 


like, I don’t know, somewhere in the middle 


there. And those two numbers if they were 


exactly the same database would compare 


closely. And those are kind of the -- of what 


we would be using to do the coworker analysis. 


With the plutonium, there is not a 


huge amount of agreement in the early years. 


In the latter years, there is much, much 


better agreement. In fact, identical from 


about 1968 where the HIS is just slightly 


larger for plutonium for the geometric mean 


and the 84th percentile. And then afterwards 


it appears -- I’m looking down to make sure 


I’m correct -- it appears that they’re 


identical except for the last year, ’86 to ’88 


where CEDR is actually larger for the 


geometric mean. 


Similar types of results for Table 2 


for uranium except in that case the -- I’ll 


look. I’m checking -- the CEDR database 


always has a larger value for both the 

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geometric mean and the 84th percentile or equal 


to the same. In most cases it’s larger. So 


when you first look at that, you say, okay, 


the uranium we claimant favorable in all cases 


for the uranium if we use the CEDR database or 


else equal to HIS-20. 


The plutonium is a little more 


questionable, and so I went back and ran 


individual years for some of the earlier data 


that were dramatically different. And that is 


shown in the next document called Follow-Up 


Evaluation. And if you look at the Table 1 


there, there are still clearly some 


differences if you look at the geometric mean 


and 84th percentile. 


And I extracted, well, I removed some 


of the extraneous data that only detracts from 


being able to find what’s important. And if 


you look at that data, you can see that the 


HIS database still reads higher for the 


geometric means and the 84th percentile until 


you get to the latter years starting about 


1968 they’ve become essentially the same as 


far as the numbers that we would use for doing 


coworker statistics. 

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And so I decided I needed to look 


further into the earlier years. And what I 


did in Table 2 -- let’s see, that’s not the 


one. Table 2 was uranium. And as you can 


see, we are still about equal to or larger 


than the HIS data. The Table 3 though is the 


yearly comparison which again I said didn’t 


seem to solve the question of what is going 


on. 


So finally, I went down to Table 4 at 


the end of the document, and said, okay, let’s 


treat the data as if we were actually doing 


the coworker analyses, to treat the zeros in 


some fashion. And so what we did, this was 


about the time that we were changing 


methodologies, but we had not changed the 


methodology when we ran this analysis. So the 


methodology that was being used at the time 


was to change each zero to a less than value 


that was equal to the cut-off value that was 


supplied in this Technical Basis Document for 


the site. 


These values varied over time, but 


during the periods that I looked at they were 


.2 and I believe .88 --

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DR. ULSH: Point 88. 


 MR. LOCHAMY: Yeah, .2 and .88 the earlier 


years, .2 the latter years, I believe. 


DR. ULSH: You’re referring to, at least in 


the .88 case, that’s the reporting level. 


 MR. LOCHAMY: That was the reporting level. 


It wasn’t an mda or anything. Any time they 


got a number smaller than that they wrote a 


zero. I believe it corresponded to about ten 


percent of the maximum permissible body burden 


or some such, but I can’t remember right off 


the top of my head. But nevertheless, they 


would cut off the numbers and report them as 


zeros if they were below that reporting level, 


the presumption being it was considered 


insignificant as far as their total dose. 


That would be my assumption. I don’t know 


what they were actually thinking, but that 


appears to be what they might have been 


thinking. 


So if we go back in and substitute 


these cut-off values and list them as less 


than values into the statistical analysis, of 


course, a less than value doesn’t get treated 


as a real number, but it does get treated as a 

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placeholder. And so it changes the 


statistical analysis and thus, the equation 


because of the placeholder position that it 


takes. 


And when you look at Table 4, you see 


the results of running CEDR and HIS for those 


special years. And you notice that the 


geometric means and the 84th percentiles are 


quite close. In some cases CEDR is higher, 


and in some cases HIS is slightly higher. It 


kind of vacillates back and forth in that 


case. Now we did not do that for uranium 


because we were already -- wait a minute --


I’m sorry, excuse me, I did do it for uranium. 


I’m sorry. I did it for uranium on there 


because that was the one of concern there. 


So essentially my conclusion was if I 


were to rerun the analyses using the 


methodologies that we used to run the coworker 


statistics I would get essentially the same 


numbers. I guess that was my conclusion. 


Even though the two databases are not 


identical, they are essentially the same as 


far as statistical analysis. 


DR. ULSH: So the bottom line -- this is 

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Brant. The bottom line, to recap this 


process, Mark, when we did the first analysis, 


we got pretty substantial agreement between 


plutonium and uranium. There were a couple of 


periods where there was some concern, and I 


asked Joe to refine the analysis, investigate 


those areas. And he did an excessive number 


of refinements to narrow in on these 


differences and what you see as the result is 


in Table 4, I believe --


 MR. LOCHAMY: Yes, Table 4. 


DR. ULSH: -- of that latter, the follow-up 


document. What you see is that we arrived at 


values for the geometric mean and the 84th
 

percentile which is what’s important for 


coworker data with pretty substantial 


agreement between the two. So therefore, we 


concluded that we’re going to propose to use 


CEDR for the internal data, coworker data, and 


there’s pretty good agreement between the two 


once we applied the right statistical handling 


procedures. And so that’s what we’re 


proposing for internal. 


Now I would reiterate that it’s not 


exactly a moot point, but as we’ve mentioned 

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before, the need for coworker data at Rocky 


Flats is pretty minimal, but that’s where we 


are. 


MR. GRIFFON: I guess I would have concluded 


that you, well, you had already modeled it on 


CEDR, correct? 


DR. ULSH: Yes, we ran the --


MR. GRIFFON: It appears to me that all the 


HIS-20s are -- oh, no, that’s not true. 


DR. ULSH: No, they are, toward the end 


they’re very comparable. Sometimes CEDR is 


larger, in fact, it looks like most of the 


time CEDR is larger. 


 MR. LOCHAMY: About 50-50. 


MR. GRIFFON: At any rate, a follow up or 


the same question sort of that I asked for 


external, which is this is database to 


database. What about database to raw data. 


Did any --


 MR. LOCHAMY: Brant, who took care of that? 


We were going to --


DR. ULSH: Craig Little is currently waist-


deep in that. That’s a significantly more 


difficult proposition, Mark. I’m not 


intimately familiar with the details of it, 

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but Craig is just pulling his hair out over 


it. 


MR. GRIFFON: Can you share some of where 


you’re at with that? 


DR. ULSH: Craig, are you still on? 


MR. LITTLE: I’m still on. 


DR. ULSH: Talk about just in general the 


approach that we’re taking with this to 


compare HIS-20 back to ^ records. 


MR. LITTLE: We’re doing essentially the 


same thing we did with the external data. We 


have claimant, urinalysis worksheets or 


handwritten urinalysis records. And we’re 


pulling those out and comparing those to 


database records to, essentially we’re doing 


the same thing we did before. We’re looking 


for places where we’re in agreement or 


disagreement, where we have missing data, et 


cetera. 


And it’s just much more difficult to 


do than external data because there are 


multiple entries per person as opposed to a 


quarterly entry or a monthly entry or 


something like that because you take it. A 


bioassay is essentially a snapshot of a point 

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in time, whereas, an external, a film badge or 


a TLD is an integrated measurement over some 


longer period of time. So for a given year 


you might have 20 or 30 bioassays for an 


individual as opposed to four film badge 


measurements. And we just don’t have enough 


of a sample yet to make a good statement about 


that. 


MR. GRIFFON: Okay, and these handwritten 


records, are they in the claimants’ files, 


these handwritten, I think you referred to 


them as -- I’m not sure. They weren’t cards, 


they’re --


MR. LITTLE: Yeah, actually they’re 


worksheets. 


MR. GRIFFON: -- worksheets I guess. 


DR. ULSH: No, you might be thinking of the 


beta/gamma worksheets, Mark. There were 


actually urinalysis cards in the claimants’ 


files. 


MR. GRIFFON: Okay, there are urine cards in 


the claimants’ files. 


DR. ULSH: Yes. I know that I’ve seen them 


there. I can’t tell you that I’ve gone 


through and looked for every year, but I 

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believe so. I have no reason to think that 


they wouldn’t be. 


MR. LITTLE: Oh, they’re in the claimant 


file, yes. 


DR. ULSH: They’re in the claimant file. 


MR. LITTLE: Yes, we’re getting them. We’re 


pulling them out of the claimant file. 


MR. GRIFFON: And did a similar quality 


assurance approach go on when they pulled the 


claims together as with the external side? 


MR. LITTLE: I’m sorry, would you repeat 


that? 


MR. GRIFFON: Well, for each, you mentioned 


that for each claimant, when they pulled the 


file together, Kaiser would do a sort of QA 


process where they would look at the external 


HIS-20 compared to the, now, did they do a 


similar thing for the urinalysis? 


DR. ULSH: I don’t, I think the answer to 


that, Mark, is no, probably for the same 


reasons that Craig’s having a hard time. It’s 


just much more of a difficult thing to do. 


But what that would tell you is that we 


wouldn’t have the same issue about having to 


look at non-claimants if that extra QA stuff 

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wasn’t done. So I think we can get some 


insights from claimant data. 


MR. GRIFFON: Anybody else have any 


questions or clarifications on the data 


validation question here? 


DR. MAKHIJANI: Mark, this is Arjun. I had 


a question in the first document we were 


discussing, the internal comparison. If you 


look at Table 1 for plutonium where the CEDR 


numbers are smaller because there were zeros 


there included and the number of data points 


are also larger. Then you go to the uranium, 


you see the number of data points are still 


larger, but the values for uranium are also 


larger, and that’s a little bit puzzling. Why 


is there so, difference would mean --


 MR. LOCHAMY: By the way, hello, Arjun, it’s 


been awhile. 


DR. MAKHIJANI: Hello, Joe. I wondered if 


it was the same Joe. 


 MR. LOCHAMY: I’m the same one. I’m looking 


at the --


DR. MAKHIJANI: Tables 1 and 2. 


 MR. LOCHAMY: I’m sorry. Say it again? 


DR. MAKHIJANI: Tables --

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 MR. LOCHAMY: Point to a year. 


DR. MAKHIJANI: -- 1 and 2 in the internal 


comparison of the HIS document. 


MR. GRIFFON: In which year, Arjun? 


DR. MAKHIJANI: If you look, most of the 


years it’s the same if you look at say the ’53 


to ’57, ’58 to ’62, ’63 to ’67. The equation 


geometric mean and so on, .26 versus .30 and 


.^ versus .5. That’s in Table 1. And then 


that’s presumably because there are zeros in 


the CEDR. 


But then you go to the Table 2 for 


uranium, and you see the opposite thing. No, 


not all the time but most of the time. The 


differences aren’t very big, but they are 


opposite indicating that the zeros are not an 


issue for uranium, but they’re an issue for --


I’m puzzled by that. 


 MR. LOCHAMY: I’d have to go back and look, 


Arjun, but I believe that the uranium had less 


zeros in it. I can’t recall. As I recall, 


plutonium was almost exclusively zeros. 


DR. MAKHIJANI: Then why are there so many 


fewer data points in the HIS database? 


 MR. LOCHAMY: That I cannot answer. I do 

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not know. They tend to merge in latter years 


until the very last two years. 


DR. MAKHIJANI: I see that, yeah. 


 MR. LOCHAMY: They’re very, very close in 


the latter years, but I do not know why there 


is a different number of data points in there. 


DR. MAKHIJANI: That kind of raises a 


question about the nature of your adjustment, 


you know, technically I see that you can make 


the numbers match up by the kind of adjustment 


that you did in the follow-up document. 


 MR. LOCHAMY: Yes. 


DR. MAKHIJANI: But that assumes that the 


CEDR database, this is an adjustment for 


uranium not the plutonium, and --


 MR. LOCHAMY: Let’s see, let me make sure 


because I was looking at that, and it’s been 


ten minutes since I looked at it, so --


DR. MAKHIJANI: Table 1 is plutonium. 


 MR. LOCHAMY: For some strange reason I was 


thinking that I had included that I was doing 


plutonium instead of uranium, but the table 


says uranium. 


DR. MAKHIJANI: Yeah, I’m a little surprised 


by that. 

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 MR. LOCHAMY: Yeah, I’m going to have to 


look at it. Hang on just a second. Let me 


look and see what I’ve got here. Well, it may 


be hard for me to determine. 


MR. GRIFFON: We can also let you follow up 

if you --

 MR. LOCHAMY: I’m --

MR. GRIFFON: -- come back to it if you --

 MR. LOCHAMY: -- thinking, let’s see, if I 

do ’53 to ’57 for plutonium, the geometric 


mean is very low, point double of something, 


and the -- no, it looks like I’m doing the 


uranium. 


DR. ULSH: Joe? 


 MR. LOCHAMY: Yes? 


DR. ULSH: Don’t’ guess, let’s -- if you 


need to investigate it, go check it out, but 


don’t make a guess. 


 MR. LOCHAMY: The table says uranium. 


DR. ULSH: Yeah, I’m wondering if you might 


have mislabeled the table. I don’t know. 


It’s something you need to check out there. 


MR. GRIFFON: Yeah, you don’t need to follow 


up live here. We can come back to you, but 


just a question. 

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 MR. LOCHAMY: Yeah, I think what I’ve done 


is I’ve accidentally typed uranium in instead 


of plutonium. 


MR. GRIFFON: Do we have access, Brant, to 


these two databases on the O drive, or are 


they not accessible to SC&A? 


DR. ULSH: Are you talking the HIS-20 and 


the CEDR database? 


MR. GRIFFON: HIS-20 and CEDR. I don’t 


think we have access to these, do we? 


DR. ULSH: Good question, Mark. I’m not 


sure I know the answer. 


MR. GRIFFON: If that could be done, I think 


that would be great if we don’t already. It 


might be --


DR. ULSH: People around the table are 


shaking their heads that HIS-20 is not 


currently accessible. 


 MR. LOCHAMY: I have a copy out there. 


DR. NETON: This is Jim Neton. HIS-20 is 


run by proprietary software, a product that is 


being used here. Unless, Joe, to do this 


analysis, have you downloaded these into other 


files though. You must have had them. 


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on the O drive. 


DR. NETON: A copy of a downloaded file. 


 MR. LOCHAMY: What happened was Jim sent me 


a flat ASCII file, and I imported it into an 


ACCESS database. 


DR. NETON: Okay, well, that would work, I 


think. 


MR. GRIFFON: Yeah, can that be made 


available, Jim or Joe? 


 MR. LOCHAMY: It’s sitting out there on the 


O drive. 


MR. GRIFFON: Well, it may be on your O 


drive, but we --


DR. NETON: Well, we need to be careful 


which O drive we’re talking about. If it’s 


available as an ACCESS database, we can make 


it available on the Advisory Board debut 


Document Review file. 


MR. GRIFFON: And the same thing for the 


CEDR so we can maybe look at this? 


DR. NETON: Yeah, I think we’ll just work 


with Joe Lochamy. 


 MR. LOCHAMY: Okay, the two are sitting out 


there right now together. 


DR. NETON: Yeah, we’ll have to put them in 

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the right location, that’s all. 


MR. GRIFFON: Thank you, Jim. 


DR. NETON: No problem. 


MR. GRIFFON: And Joe, we can come back to 


you on this question, or later in the 


discussion if you have more clarification on 


that. 


 MR. LOCHAMY: Table 4 is plutonium. It is 


not uranium. I accidentally, when I copied 


the table over to use it as a basis for 


building the next table, I --


MR. GRIFFON: This is Table 4 in the follow 


up? 


 MR. LOCHAMY: -- Table 4 should be PU. 


MR. GRIFFON: Excuse me, Table 4 in the 


follow-up document? 


 MR. LOCHAMY: In the follow-up document 


should be PU. And I’ve looked at the others. 


In fact, Table 3 should also be PU. I 


apologize for that. When you’re in a hurry to 


try to meet a deadline, you sometimes don’t 


pay attention to what you’re doing there. But 


the data are clearly plutonium data. 


DR. ULSH: This won’t be the last typo I can 


only --

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 MR. LOCHAMY: I can assure you, that won’t 


be the last time that happens. 


DR. MAKHIJANI: Except for Table 2 which is 


uranium. 


 MR. LOCHAMY: That is correct. Table 2 is 


definitely uranium. 


MR. GRIFFON: Thank you for that 


clarification. 


MS. MUNN: Will you correct that and send us 


the correction? 


 MR. LOCHAMY: I’m sorry. You want me to do 


that? 


MS. MUNN: Yes. I need somebody to do so 


that I --


 MR. LOCHAMY: Yeah, I’ll take the lead on 


that. 

MS. MUNN: -- and get the right ones. 

 DR. ULSH: Okay, can you just correct those 

errors? 

 MR. LOCHAMY: Yes. 


 DR. ULSH: So it’d be Table 3 and 4 should 


read plutonium instead of uranium. 


MR. LOCHAMY: So it should read plutonium? 


DR. ULSH: Yes. 


 MR. LOCHAMY: I’m sorry. 

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DR. ULSH: Wanda, I will do that. I will 


make those corrections and get them out. 


MS. MUNN: Thanks, Brant. 


MR. GRIFFON: Is there anything else on the 


data validation, data reliability question? I 


think a lot of the data reliability items, 


specific allegations, we’re going to cover 


through the matrix because there were a number 


of specific allegations brought up in the 


petition, and I’ve now included those in the 


matrix, maybe not in the best fashion. 


Sometimes they’re a little lengthy. I was 


trying to boil them down, but they’re, 


sometimes to keep the content, I had to 


basically copy the entire thing. But we can 


walk through those in that area, but if 


there’s other items here that we might want to 


discuss, anybody have anything? 


MS. MUNN: We had a brief conversation about 


that while you were off somewhere this 


morning, and the experts convinced me that I 


should wait for the matrix. 


MR. GRIFFON: Okay. 


DR. MAURO: Mark, this is John. I just 


clarify, I know a couple of the issues, of 

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course, one was data reliability and one was 


the coworker OTIB. I guess my sense was what 


we were talking about here is more oriented 


toward building a coworker database that could 


be used for your coworker OTIB. Or am I 


incorrect in that? 


MR. GRIFFON: Well, these two documents that 


we just went through, it seems, yes, this is 


all around how do you use the database for 


coworker model. 


DR. ULSH: And then Craig’s discussion 


compared, for external, compared HIS-20 to raw 


records so that would not just be coworker. 


DR. MAURO: So in other words in a way this 


discussion we had has validity not only to 


coworker, but also to data reliability? 


DR. ULSH: I don’t want to say that it, I 


certainly wouldn’t be optimistic enough to 


hope that it would put data reliability to 


bed. But I do think that it weighs in and you 


can draw some conclusions from it. 


MR. GRIFFON: Right, I think the data 


reliability, you know, the raw record, as 


Brant said, the external, they’ve done, 


they’ve made some efforts on the raw record 

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comparison, but the internal, I think they’re 


just delving into that. 


DR. ULSH: We’re in the thick of it. 


MR. GRIFFON: And anything else on data 


reliability? 


 (no response) 


MR. GRIFFON: And anything else on the 


evaluation report in general before we --


DR. MAKHIJANI: This is Arjun. There was 


one new thing in the evaluation report that I 


had a question about that I had not seen 


before, and it related to the americium zeros, 


which I don’t think has come up so far. 


DR. ULSH: Americium zeros, Arjun? 


DR. MAKHIJANI: Yeah. I think it is, but 


I’ve got so many files open I can’t find the 


evaluation report. I think it’s on page 41. 


DR. ULSH: Okay, I’m on page 41. 


DR. MAKHIJANI: This is from memory so I’m 


not there yet, but, yeah, it is on page 41 in 


the paragraph that starts, “In vivo Americium241 lung data ...” The second sentence there, 


“From 1965 through 1971, all results above 


4000 were reported as zero.” That whole 


discussion was kind of puzzling. 

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I understand the words, of course. 


You’re accepting the zeros at face value, but 


then there doesn’t seem to be any explanation 


of whether they’re real zeros or how you 


determined that they’re real zero, especially 


if, there’s some kind of indication the 


problem continued after that. But it’s not 


real clear that it continues so I was a little 


puzzled by this paragraph. 


DR. ULSH: Okay, I’m re-reading the 


paragraph right now. Give me a second here. 


Okay, this deals with Americium-241 lung count 


data from ’65 to ’88. Let me just -- for 


those of you who don’t have this open, let me 


just read this paragraph. 


In vivo Americium-241 lung data from 


1965 to ’88 were extracted from a Microsoft 


ACCESS table, and it gives the name. There 


were just fewer than 80,000 Americium-241 


records in the lung database. From ’65 


through ’71 all results, in parentheses, about 


4,000, were reported as zero with no 


explanation of what those values might have 


meant. So therefore, no analyses were 


performed on those data. Furthermore, the 

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Tech Basis Document mentions that Americium241 activities were quantified only if a known 


plutonium incident occurred. However, the TBD 


also says that results were sometimes recorded 


in counts per minute when no known incident 


had occurred. Some results were also recorded 


in micrograms or nanocuries. And finally it 


says, after ’71 positive values began to 


appear, but there were still no exclusion 


instructions for when zero values were 


reported. See the no calc discussion above. 


I’m not sure, I don’t know exactly 


where the no calc is, but therefore, zero 


results were treated as zeros because no 


better information was available. 


Calculations of the lung plutonium values 


recorded with the Americium-241 lung data were 


determined by using the Americium-241 data and 


an assumed concentration of 1,000 dpm by 


weight of americium and the plutonium. 


So that’s what the paragraph says. Is 


that the one you’re talking about? 


DR. MAKHIJANI: Yeah, exactly. 


DR. ULSH: Okay, I’m looking around the 


table to see if we’ve got any input to 

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provide. 


 MR. FALK: Yes, this is Roger Falk. I am 


thinking that that table came from the CEDR 


database. 


DR. ULSH: That is true. The name indicates 


that it is a CEDR database. 


 MR. FALK: That was basically transcribed 


from the raw lung count report. And 


basically, the situation is that the zeros 


that they are describing were actually blanks 


on the hardcopy original data. They should 


not have been put in there as zeros. It is my 


understanding that the CEDR database is based 


on microfiche copies done by Los Alamos in 


support of the epidemiological study, and that 


they transferred that data into the database. 


I am thinking, and I believe this fairly 


firmly, is that they misinterpreted all that 


data. The statement in the Technical Basis 


Document says that if there was not a 


confirmed lung deposition, there was no 


evaluation done for those lung counts, only if 


it was a confirmed deposition. Therefore, 


there should be no zeros put in there because 


it was a non-evaluated count per minute 

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signal. Therefore, that data should not be 


used to develop coworker for the americium 


results for the in vivo measurements. 


DR. ULSH: Keep in mind we’re not proposing 


to use that, the coworker. 


DR. MAKHIJANI: So not evaluated means what? 


 MR. FALK: See, when we did it on the 


record, it was either called normal or the 


result was called background. It was a 


qualitative decision. It was not a 


quantitative decision. 


DR. MAKHIJANI: So you’re not treating these 


as zeros in other words? 


 MR. FALK: They shouldn’t be treated as 


zeros. 


DR. MAKHIJANI: The words in the evaluation 


report read that they were treated as zeros, 


but it’s not being treated as zeros? 


DR. ULSH: You’re right, Arjun. The working 


in the ER might be a little bit misleading, 


but that refers to, again, to the CEDR dataset 


for americium in vivo counting. And we’re not 


proposing to use that for coworker data. 


DR. MAKHIJANI: But what about the 


individual data? 

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 MR. FALK: What I would like to point out is 


that the original lung count sheets are all 


part of the claimants’ data files. And the 


dose reconstructors will use that for the 


claimant. 


DR. ULSH: Not the CEDR data. 


DR. MAKHIJANI: No, so my question is so 


they have blank, and then what do they do? 


DR. ULSH: You mean during dose 


reconstruction? 


DR. MAKHIJANI: Yeah. 


MR. GRIFFON: Yeah. 


 MR. FALK: They will likely rely on the 


urine data. However, we need, probably one of 


the dose reconstructor team needs to clarify 


that. 


DR. ULSH: Mutty, are you out there? 


 MR. SHARFI: Yes. 


DR. ULSH: Do you have any insights to 


provide? 


 MR. SHARFI: Is this maybe a coworker 


question or just how we’d use the --


MR. GRIFFON: No, this is for an individual 


claimant. 


DR. ULSH: Individual dose reconstruction 

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question. I don’t --


 MR. SHARFI: Go ahead, Brant. What did you 


say? 


DR. ULSH: Arjun, I don’t, I think we’re 


talking about two different things here. 


We’re talking about data that’s in a CEDR 


database. If you look at the name of the file 


which is given in the second line of that 


paragraph, rff^. That’s a CEDR database. 


What’s going to appear in the individual dose 


reconstruction is the actual lung count 


report. 


DR. MAKHIJANI: I accept, you know, it 


seems, Roger’s explanation seems fine that 


this was something that was misinterpreted 


when entering, when transcribing the data into 


the CEDR database. But then the explanation 


kind of lead to this question of if it’s a 


blank in the original, then what do you do? 


How do you interpret that blank when there’s 


no information for the individual in whose 


record the blank appears? 


MS. MUNN: You’re doing an individual dose 


reconstruction and you have a blank there both 


^ to the reconstruction, right? 

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DR. MAKHIJANI: Yeah, that is the question. 


DR. NETON: This is Jim Neton. I think I 


might be able to shed some light on this. The 


in vivo measurements are typically used, we 


would start normally with the urine data to do 


an internal dose. And then the in vivo data 


are used to compare to make sure that there’s 


consistency between those two types of 


measurements. 


So if there were a blank there, I’ve 


been told that the original data are all there 


from the net counts per minute where one could 


actually calculate the detection limit for the 


measurement for the amount and compare that 


for consistency purposes to the intake 


determined from the bioassay urine 


measurement. 


DR. MAKHIJANI: Okay, thank you, Jim. 


 MR. ROBINSON: This is Alan, and I was, I do 


dose reconstructions, and I would confirm 


that. I mean, typically the raw counts are 


there. You use it for comparison, and we have 


from the TBD there’s methodology in there that 


we can calculate the mda and determine what 


the mda would have been for that count. And 

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then we can compare back to urine analyses to 


make sure that we’re consistent. 


MS. DeMERS: And we’re talking about 


americium here? 


MR. GRIFFON: Yes. 


MS. DeMERS: Okay, can I read you a quote 


from a report that was put out by the --


MR. GRIFFON: Is this Jennifer? 


MS. DeMERS: This is Kathy. 


MR. GRIFFON: Oh, Kathy, hi. 


MS. DeMERS: It was put out in February 5th , 


1963, by the Industrial Hygiene group. It 


says, “The plutonium analytical procedure 


adopted in 1961 is specific for plutonium 


alpha activity. This means that we are not 


screening employees for possible americium 


exposures. In addition, positive exposures to 


materials can be as much as 45 percent 


americium activity basis and are still being 


studied. As a result, an americium-specific 


urine analysis is under development.” 


So this would indicate that there is a 


period of time where there was a gap in the 


monitoring for americium. 


DR. ULSH: Kathy, could you read the first 

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part of that again about the gross alpha? 


MS. DeMERS: “The plutonium analytical 


procedure adopted in 1961 is specific for 


plutonium alpha activity.” 


DR. ULSH: Okay, that is the plutonium 


analysis. That is not gross alpha. What we 


said was in the earlier years prior to the 


development of the americium-specific 


bioassay, which was widely implemented in 


1963, we would cover americium with gross 


alpha bioassay, not plutonium-specific 


bioassay. 


MS. DeMERS: Well then, what are you doing 


from 1951 forward? 


DR. ULSH: Up until 1963 we would be 


covering americium with gross alpha. After 


1963 we would use americium-specific bioassay. 


MS. DeMERS: Okay, and you’ve got a document 


here that is stating that they haven’t fully 


developed that process. 


DR. ULSH: What’s the date on that? 


MS. DeMERS: February 5th, 1963. 


DR. ULSH: Oh, ’63. That’s when the 


americium-specific bioassay was implemented, 


in 1963. It was developed in 1963. That’s 

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when they started using it widely. 


MS. DeMERS: Okay, and you’ve got a gap 


there because it says, “The plutonium 


analytical procedure adopted in 1961 is 


specific for plutonium alpha activity.” 


DR. ULSH: Yes, and prior to 1963 we would 


have used gross alpha, not plutonium-specific. 


DR. NETON: It seems to me there were 


analytical techniques being employed at the 


same time, both a gross alpha and a plutonium 


procedure, that you’d get two pieces of data 


not just one. 


MS. DeMERS: And do you have the analytical 


method by which the bioassay samples were 


processed? 


DR. ULSH: I believe that is described in 


Attachment A of the internal TBD. 


MS. DeMERS: Okay, Mark, I don’t know when 


it’s going to be the best time to bring up 


some items. 


MR. GRIFFON: Well, this may come, we do 


have a section in the matrix where we discuss 


americium doses, the doses from americium and 


the monitoring for americium. So why don’t we 


save more details on this for the matrix if 

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that’s okay? 


MS. DeMERS: Well, I’d like to make one 


comment about NIOSH responses to my draft 


memo. They did not include --


MR. GRIFFON: Which, can you tell us what 


responses you’re talking about, the April 5th
 

responses is that --


MS. DeMERS: Right, right. They did not 


include a table in there that I added of the 


records that were not provided to me at the 


time I was at Rocky Flats. And these records 


were designated to get at the issue of when a 


zero was reported in the record, did the field 


conditions support that zero. 


MR. GRIFFON: Okay, again, Kathy, are you 


going to be available after, I think we’re 


going to break for lunch soon probably, but I 


want to pick up the matrix after lunch, and 


all these comments fall at the bottom of our 


matrix. So I want to take more time on all 


these I think if that’s okay. 


MS. DeMERS: That’s fine. 


MR. GRIFFON: Just to go back to the report 


for a few final things, Brant, I hope a few 


final things anyway and then maybe we can 

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break. 


I had a, just a question or a 


clarification. On page 42 at the bottom in 


Section 7.1.3, the first paragraph there, 


basically your conclusion on data sufficiency. 


DR. ULSH: Yes. 


MR. GRIFFON: And it says in the middle, 


similarly NIOSH also investigated the pedigree 


of internal dosimetry data found in the CEDR 


and HIS-20 databases, compared the CEDR data 


to HIS-20 data, and finally, compared HIS-20 


data to original hard copy records. I think 


that’s a little bit of an overstatement, isn’t 


it? 


DR. ULSH: I think I agree with you, Mark. 


That is one of those cases where real events 


caught up with me. 


MR. GRIFFON: Right, you’re in the midst of 


that, I guess. 


DR. ULSH: Yes, that is correct. 


MR. GRIFFON: I just wanted to make sure I 


was reading it correctly, and I think that’s 


something you need to probably follow through 


on. 


DR. ULSH: Absolutely. 

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MR. GRIFFON: And then on page 47, it’s the 


second paragraph under Section 7.2.1.3, 


Application of Coworker Model. I just want to 


understand this. It says, “These models 


coupled with claimant-favorable inputs may be 


used to reconstruct doses for unmonitored 


workers.” Fine, we understand that. “Or to 


fill data gaps where records may have been 


lost, incorrectly recorded or where assigned 


doses may have been underestimated.” 


I guess my question is do you have 


reason to believe that records were lost, 


incorrectly recorded or assigned doses were 


underestimated? 


DR. ULSH: No. 


MR. GRIFFON: Or was this sort of a catchall statement? I don’t --


DR. ULSH: It’s the latter. It’s meant to 


address the hypothetical if such, if evidence 


of that were discovered, or in situations 


where we suspect that might be the case, 


that’s what it’s meant to cover. But I’m not 


aware of any situations that we have 


discovered like that. 


MR. GRIFFON: All right, I just wanted a 

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clarification on that. 


And that’s really all I have. I mean, 


we have several, we’re going to get into more 


detail on some of these items within the 


matrix, but is there anything before we, I 


think it might be a good time to break for 


lunch in a few minutes. 


DR. MAURO: Mark, this is John. I just have 


one very brief question if that’s okay. 


MR. GRIFFON: Sure. 


DR. MAURO: On page 13 of your evaluation 


report, and this is a recurring thing which we 


noticed also in the Y-12, one of your lines of 


argument for being able to do a dose 


reconstruction is you make reference to all of 


the dose reconstructions that have been 


performed and that have been completed. I 


would be interested in hearing a little bit 


about when you have your full array of cases 


before you, and you’re going through the dose 


reconstruction selection process, I presume 


that there are some that need to be set aside 


for various reasons because certain protocols 


have not been developed, certain databases 


have not been developed, for example, coworker 

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database may not be developed. 


I think it would be very informative 


if the evaluation report developed that part 


of the story because to a large extent it is 


the challenges posed by those cases that 


represent the areas where there is some 


difficulty in doing dose reconstruction. And 


to a large extent, the ability to do dose 


reconstruction is to find ways of overcoming 


those difficulties. 


So I guess as a general observation I 


think that I would have liked to have seen 


some discussion along the lines of how, the 


degree to which that, you have encountered 


those kinds of challenges as you went through 


the dose reconstruction process for your cases 


on Rocky, for example. 


DR. ULSH: John, that’s an interesting 


comment. Thank you for that. We kind of came 


at this in a little different way, and that 


was through the example dose reconstruction 


where, through our discussions with the 


working group and with SC&A, we’ve identified, 


at least I hope we’ve identified the right 


areas to do sample dose reconstructions that 

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demonstrate how we would handle some of these 


situations that questions have been raised 


about. But I understand what you’re saying 


about, in terms of looking at real cases. 


MR. GRIFFON: And to the -- John’s point, to 


the extent, what is the extent of these sort 


of situations might exist within the real 


cases, yeah. 


DR. ULSH: Well, okay, I don’t want to 


comment specifically on how frequently these 


situations that are covered in the example 


dose reconstructions might exist because, you 


know, I want to wait until we talk about 


individual ones, but I can tell you that for a 


number of them the example dose 


reconstructions were done to answer a 


particular question that was raised by the 


Board or by SC&A. They weren’t done to 


represent necessarily situations that we would 


expect to see. And a good example is the 


coworker examples. We don’t expect to see 


that very often, but --


MS. MUNN: Indeed, you have not given the 


numbers you just gave. 


DR. ULSH: Right, but we had to construct an 

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example to show what we would do if we, you 


know, in those cases. So don’t take that 


example as being representative of the real 


universe of claims that we have from Rocky 


Flats, but rather they were constructed to 


address a specific question. 


DR. BEHLING: Mike, this is Hans Behling. I 


do have a question, and I guess I’d like to 


ask before we break for lunch. And that is 


the issue of gross alpha versus alpha 


spectrometry when we talk about urine 


bioassays for plutonium. Is there any 


difference between the actual up-front process 


between spectroscopy when we talk about the 


chemical isolation of plutonium? 


 MR. FALK: This is Roger Falk. The process 


of the alpha spectrometry was basically 


introduced I’m going to say around 1970, 1971 


when they started to get multi-channel 


analyzers. 


DR. BEHLING: Yes, and I’m fully aware of 


the fact that obviously with spectroscopy, you 


can isolate or separate the different 


plutonium alpha emitters from each other. But 


in fact, I would assume that the chemical 

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isolation of plutonium for either gross alpha 


or spectroscopy, spectroscopy’s the same, 


meaning that the issue of Americium-241 really 


isn’t an issue since obviously you would not 


expect significant amounts of carryover of 


Americium-241 as has been alluded in previous 


discussions. 


 MR. FALK: The use of the gross alpha is, 


was basically was a nonspecific-type of the 


analysis, and that was used in the ‘50s and 


‘60s primarily. And so basically any of the 


alpha emitters would have been caught by that 


process. 


DR. BEHLING: You mean to tell me you 


wouldn’t first isolate plutonium as a chemical 


element before you do gross alpha? I mean, 


you have to reduce a urine volume to something 


that is now countable on the planchette^ and 


suitable for alpha counting. And I would 


assume that involves the chemical isolation of 


plutonium from urine whether you do gross 


alpha or alpha spectroscopy. 


 MR. FALK: I do not know the details of that 


process, but it was my general understanding 


that there was minimal separation of ^ 

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basically prior to the counting. 


MR. GRIFFON: Brant, is this described in 


that Attachment 1 of the TBD? 


 MR. FALK: Yes. 

MS. MUNN: I thought it was. 

 MR. FALK: Yes. 

DR. ULSH: Attachment A, Mark. 

MR. GRIFFON: I’m sorry. Attachment A does 


cover the chemical processing of the samples, 


too and the kind of methods --


 MR. FALK: In a fairly broad brushstroke, 


however. 


MS. MUNN: I remember reading something, but 


it was, I was reading very fast, but there was 


something in there. And I came away with the 


impression that there was not a separation 


prior to the gross count. Perhaps I was 


incorrect. 


DR. BEHLING: Well, I just don’t know how 


you would essentially, if you talk about a 


urine sample, and you simply, let’s say, 


evaporate the water component, for a liter 


sample, you would end up with approximately 


one or two grams of total material from urea 


to sodium chloride to whatever. So there has 

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to be some chemical separation in order to 


avoid sample self-absorption. There’s no 


doubt in my mind. 


DR. NETON: This is Jim Neton. I seriously 


doubt they used a liter. It was probably 


more, a much smaller volume, and you could 


certainly dry off your organic material with 


wet ash and with nitric acid or something of 


that nature. And whether or not there was 


some sort of a calcium oxalate precipitation 


to separate out the bulk elements that would 


not preferentially remove transuranic or 


alpha-type emitters. You know, it’s not that 


uncommon. I mean, if you look at the HASL 


manual, I’m sure there are procedures in there 


for gross alpha analysis of urine. It’s more 


of a screening technique than anything else. 


It’s just much quicker. 


DR. BEHLING: Yeah, I was just curious about 


the issue of the Americium-241 being an issue. 


It was always my impression that even when you 


engaged in gross alpha counting for plutonium 


that you chemically isolated plutonium. 


DR. NETON: If you want to get plutonium-


specific, but the payback, the cost is fairly 

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enormous to start doing plutonium-specific 


chemical separation. The bottom line is if 


you can pull out the gross alpha emitters by 


themselves and demonstrate that there is not 


much there, you accomplished your mission 


without going to the great expense of some 


sort of ion exchange column or solvent 


extraction process. It’s not that uncommon in 


the early years for them to do those type of 


analyses. 


MR. GRIFFON: So we’re talking in 


generalities now, Jim. I mean, maybe over the 


break, Hans, if you haven’t reviewed 


Attachment A completely, maybe you can take a 


look at that. 


DR. BEHLING: Yeah, I’m actually looking at 


a document that a Savannah River site internal 


Technical Basis Manual which has nothing to do 


with the TBD for the energy employee issue 


here, and I’m looking here. And for a gross 


alpha counting they do, in fact, isolate 


plutonium by using Plutonium-241 as a tracer, 


et cetera, and chemically separate it. 


MR. GRIFFON: But again, that was Savannah 


River so maybe --

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DR. BEHLING: I realize that. 


MR. ROBINSON: Excuse me, this is Al 


Robinson. You know, in the TBD there it turns 


out that from ’52 to ’71 for gross alpha, what 


they did is they did an extraction method 


using either TBP or a TOPO. And basically it 


pulled out the plutonium, uranium as well as 


americium and natural thorium, the major parts 


of the urine matrix, and allowed it to be 


counted. So they were all pulled out, but 


there was some purification, but it was a 


gross purification of all the alpha emitters. 


MR. GRIFFON: So that’s in the TBD? 


MR. ROBINSON: Yeah. 


MR. GRIFFON: Do you have a page number and 


stuff, and maybe, Hans, you can --


MR. ROBINSON: That’s on page 42. 


DR. BEHLING: Okay, that would clarify it, 


so I’m not, you know, it’s been a long time 


since I read the TBD. 


MR. GIBSON: This is Mike Gibson. Could I 


ask one question, too, and I’m certainly not a 


health physicist, but the size of the sample, 


I thought I heard someone say one liter. 


That’s, in my task we’re just accustomed to a 

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complete 24-hour voiding for a bioassay 


sample. So if some smaller sample was used, 


how representative would that be? Would that 


actually show a representative sample of what 


you may have had in an uptake? 


DR. NETON: Well, Mike, this is Jim Neton. 


This issue sort of came up yesterday early in 


our discussion of the Ames Laboratory where we 


would, you know, oftentimes it was practiced 


when spot samples were taken for routine 


analyses, something less than a 24-hour void 


was collected. And in fact, that’s fairly 


common even today. 


Twenty-four-hour voids were collected 


in response to known incidents. The bottom 


line is when you take less than a 24-hour 


void, you do incur some amount of uncertainty 


in extrapolating to a daily voiding. But all 


of our internal dosimetry calculations, when 


they’re done, have an assigned geometric 


standard deviation of three, which 


incorporates some of that uncertainty. 


In other words, we don’t, none of our 


internal doses, if they’re reasonable 


estimates of internal dose, are assigned a 

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single value. They allow for the uncertainty 


distribution to be sampled as part of the IREP 


process, or as part of the IMBA, the IREP 


process. And if you recall, if the 99th
 

percentile is used so that the value of POC 


that is calculated, 99 percent of the possible 


outcomes are less than the value that we 


quote. And that would include the uncertainty 


assigned for the internal dose. 


MR. GIBSON: Well, I mean, and I’m just 


speaking from my own experience, that’s all I 


have as far as the DOE complex, but even on 


spot checks or incident checks, it was always 


a 24-hour sample not just a one-time voiding 


or a one-liter voiding. It was always a 24­

hour sample. 


MR. ALLEN: In the modern era I’m sure. 


DR. NETON: That was Dave Allen by the way. 


In the modern era that may be true for stuff 


like plutonium, but not in the early days. 


MR. GIBSON: Who asked me in the modern era? 


Who was that? 


DR. NETON: That was Dave Allen speaking. 


MR. ALLEN: Yeah, by modern era I mean, you 


know, after the, say, 1970 or... 

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MR. GIBSON: I was at Mound for about 25 


years, and it was that practice for at least 


the 25 years. 


DR. NETON: But again, if it were not as I 


described --


MR. GIBSON: I’m not trying to be 


argumentative, but I don’t know what you mean 


by modern times. 


MR. ALLEN: Well, basically, that type, but 


it’s timeframe into the ‘70s. The ‘50s, ‘60s 


things were a little different as far as 


trying to every plant sorting out something 


different it seemed like. But once you got 


into the ‘70s with plutonium, I think almost 


everybody was doing a 24-hour sample. 


DR. NETON: Again, the uncertainty is 


incorporated into the overall dose estimate. 


And in fact, the 95th percentile is somewhere 


around nine times higher than what the best 


estimate is, and that is sampled and part of 


the dose, part of the POC calculation. 


MR. GIBSON: Okay, like I say, I’m not a 


health physicist, and I’m just trying to 


clarify that for myself. Maybe if I’m off-


base, you know, someone’s got the expertise 

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and can speak in, but just had that question. 


MR. GRIFFON: Yeah, and that point has been 


raised before, Mike. I think we’ve, and 


they’re, you know, we have discussed it and 


the ways to adjust for it and account for it 


and added uncertainty in for it. And I think 


Jim pretty accurately described that. 


MR. GIBSON: Okay, that’s fine. 


MR. FITZGERALD: Mark, Joe. Just one quick 


question that really deals with the overview 


as opposed to the matrix. On page 44 of the 


evaluation there’s a conclusion that none of 


the other radionuclides present at Rocky was 


in high enough quantities to contribute 


significantly to internal dose. Just as a 


point of clarification, is there any 


characterization analyses or anything that 


would tie that to work-specific activities 


such as those involved in thorium strikes? 


I guess I was just curious about the 


basis for that, you know, pretty much pushing 


that off the table at this point. Given the 


fact that it was, did figure rather 


prominently during the Y-12 analyses, it just 


seems like we ought to be clear on what the 

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basis of that conclusion is. 


MR. GRIFFON: Right, good point. 


DR. ULSH: This is Brant. In terms of 


thorium, if you read that paragraph there, 


Joe, where it talks about the thorium strikes 


that you mentioned --


MR. FITZGERALD: Right. 


DR. ULSH: -- those occurred during the midto-late 1960s. At that time Rocky Flats was 


doing gross alpha, and so they did have a 


bioassay method in place to detect, I mean, 


that bioassay method would have covered 


thorium. As I mentioned before, it wasn’t 


generally observed that there was a large 


potential exposure to thorium, and that’s the 


way they would have monitored it with gross 


alpha. 


Is that, I mean, you asked 


specifically about thorium. 


MR. FITZGERALD: Well, no, I was just saying 


that there’s sort of a list of the minor and 


trace materials. And I tend to agree that 


trace materials that were used in the weapons 


program I can see where the, just the 


quantities would be so small as not to be 

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significant. But between the thorium maybe, 


the neptunium, is there an analysis or 


anything or is it just strictly based on the 


amount of material handled? 


DR. ULSH: Well, I guess I would base it on 


the amount of material present. I’m not sure 


what you mean by --


MR. FITZGERALD: But was the conclusion 


based on just the amount of material handled 


and the fact that, I guess in the case of 


thorium, you would expect the gross alpha to 


pretty much encompass whatever exposure the 


worker would have had. 


DR. ULSH: Right, I think what you’re saying 


is probably accurate. 


MR. GRIFFON: Brant, I don’t think you’re 


even in that situation, the way I read this. 


If you had gross alpha in those years, even if 


a person was working in those areas where they 


had the thorium, unless you had specific 


information, you probably just assumed the 


gross alpha was, what, plutonium or the most 


claimant-favorable assumption in that case? 


DR. ULSH: Yes, that is correct, Mark. 


MR. GRIFFON: But you’d never assume thorium 

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I guess is what this statement says, you know, 


that these were not significant. 


DR. ULSH: We would not assume thorium. 


Okay, let me put it this way. If it were 


possible for a worker to be exposed to a 


multitude of alpha-emitting radionuclides and 


all we had was gross alpha, we would assign 


that to the most claimant favorable of the 


possible choices. And I can’t think of a case 


where that would be thorium, but I’m looking 


around for someone who’s more of an expert to 


correct me. 


UNIDENTIFIED: I think it would usually be 


plutonium. I can’t think of a case that would 


be thorium. That wouldn’t be an easy high 


dose already. 


DR. ULSH: Does that answer your question, 


Mark or Joe or whoever asked it? 


MR. GRIFFON: Yeah, I mean, I can understand 


that gross alpha would encompass the 


potential, you know, that you could use the 


gross alpha to calculate thorium doses, but 


here you’re saying that these nuclides are, as 


Joe stated, you know, sort of off the table 


because they weren’t of a significant quantity 

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to contribute to the internal dose 


significantly, and that’s a different 


statement, you know? 


DR. ULSH: Okay, so you’re differentiating 


between thorium and the other ones that were 


present in lower quantities. Is that 


accurate? 


MR. GRIFFON: Well, I, no, I’m using thorium 


as an example. Are all of them, are you 


saying that thorium, oh, you’re saying limited 


amounts of neptunium, americium, plutonium. 


DR. ULSH: Right. 


MR. GRIFFON: So those are the ones that 


you’re saying are not of significant quantity? 


DR. ULSH: That’s correct. 


MR. GRIFFON: Okay, I’m brushing over the 


paragraph quickly. I apologize then, so if 


you knew that a person was in a thorium area, 


for instance, and you had gross alpha data, 


you may reconstruct thorium doses as opposed 


to just assumed the worst radionuclides? 


DR. ULSH: I suppose theoretically that 


would be possible although I would have to 


look at whether we could ever say that a 


worker was only exposed to thorium and not to 

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something else. 


MR. GRIFFON: Right, so when in doubt, you 


would defer to the most claimant-favorable 


nuclide? 


DR. ULSH: That’s correct. 


DR. MAKHIJANI: Mark, this is Arjun. In 


some cases -- I think this has come up before, 


maybe in my own -- in some cases thorium is 


the worst rated. 


DR. ULSH: Then we would pick it. 


MR. GRIFFON: Okay, and I just don’t 


understand. It’s not clear to me how within 


this, how you determine whether someone was 


working in the thorium areas. Do you have 


enough specificity as far as job title, 


location, timeframes, et cetera to make a 


determination? 


DR. ULSH: I don’t think I could say that we 


do, Mark. We do know, in general I think, 


where the thorium was on site. If we could 


pin a worker to a specific area, we could 


maybe do that, but I can’t say with confidence 


that we would have that level of detail. But 


if a particular building handled thorium in 


one area and plutonium in another area, and we 

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know that a worker worked in that building, we 


would include all of the possible radionuclide 


alpha emitters from that building. 


MR. GRIFFON: And again I’m just looking for 


clarification myself, so thank you. 


Joe, did you have a follow up on that, 


or Arjun? 


DR. MAKHIJANI: No. 


MR. FITZGERALD: I think that helps. Again, 


I think that paragraph had a lot in it. I see 


that he had two basic conclusions there, but 


it wasn’t clear what the basis of the first 


was. And you’re saying the gross alpha. 


MR. GRIFFON: And I think at this point 


unless there’s anything else pressing in the 


evaluation report, we can maybe take lunch and 


come back and start in on the matrix. Is that 


acceptable? 


DR. WADE: Makes sense. How much time 


should we take? 


MR. GRIFFON: Can we try to be back by 1:00 


p.m.? 


DR. WADE: Let’s try 1:00 p.m. We’ll call 


back in. 


(Whereupon, a lunch break was taken, and the 

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meeting resumed at 1:00 p.m.) 


MS. MUNN: And it is page 43, by the way, 


when he starts talking about gross alpha. 


DR. WADE: Just if I could have all Board 


members identify themselves. I know Mark, any 


other Board members besides Mike, Mark and 


Wanda? 


(no response) 


DR. WADE: Mark, go ahead. We don’t have a 


quorum, and we’ve all been identified as to 


our prejudice. 


MATRIX
 

MR. GRIFFON: I think what I’d like to do is 


go back to the matrix that we worked from in 


the past work group meetings. And I sent a 


revised version of that out. I just wanted to 


make sure that everyone was able to get that 


including the petitioners, if anyone’s on from 


the petitioners. 


Did that get to the petitioners, Jim? 


DR. WADE: I asked Jason to send it to them. 


MR. GRIFFON: And now Mark has to find it. 


I know I’ve got it in one of my folders here. 


DR. MAKHIJANI: That’s the April 10th file, 


right, Mark? March 27th, 2006, Mark, April 

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10th, 2006. 


MR. GRIFFON: Yeah, March 27th it should say. 


MS. MUNN: March 28th, actually. 


MR. GRIFFON: Does it say 28th? I forgot how 


DR. MAKHIJANI: Yeah, and in the text it 


says 28th . 


MS. MUNN: My heading says 28th, too, March 


28th
 . 


DR. MAKHIJANI: A different one. 


MS. MUNN: Prepared by ABRWH Work Group 


March 28th, 2006, in parenthesis. 


MR. GRIFFON: The file name, I think the 


file name is what Arjun is talking about. It 


says March 27, but the header should --


MS. MUNN: Oh, your file name. I’m sorry, 


Arjun, I’m just reading off the paper that’s 


in front of me. 


MR. GRIFFON: At least I think that’s what 


Arjun was referring to. 


DR. MAKHIJANI: Yeah, the file name says 


March 27 to April 10th . 


MR. GRIFFON: Anyway that two-day meeting so 


I got a little confused. If we start with 


that matrix then it is, the file name has 

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Rocky Flats SEC Issues Matrix March 27, ’06. 


And the header actually says prepared by the 


work group March 28th, ’06. And again, this 


cross-references back to the February 27th
 

matrix. Just for formatting reasons I didn’t 


include all of the actions from previous work 


group meetings. I carried them through into a 


March 28th action. 


MS. MUNN: They were much too cumbersome. 


MR. GRIFFON: Yeah, it was just too unwieldy 


to carry all that through. 


So anyway, comment number two, I guess 


it’ll make most sense to go right down this as 


an overview. You’ll see that the, this is 


much lengthier, and the main reason is because 


after issue, what previously was called new 


issue number two and new issue number one, I 


relabeled those ten and 11. And then from 12 


on our, the issues that we identified through 


the review of the petition, many, some of 


these I should say, have no further action 


necessary, but I thought we need to capture 


these in summary form so I tried to do that. 


So going back up to the top starting 


with comment number two, I guess just to 

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follow up, the TIB-0049 SC&A was going to 


review this. Now I don’t know if SC&A ever 


got any formal comments back to the Board or 


to NIOSH on this. 


DR. MAURO: This is John Mauro. We have 


reviewed it. We have not submitted formal 


comments. However, I can say that the 


discussions and review of the material 


represent a very scientifically robust 


approach to evaluating high-fired, the doses 


from high-fired plutonium when you know the 


lung burden. We also are aware of a great 


deal of work and material that NIOSH has 


prepared are related to when you have 


information on urinalysis and the, whereby 


your starting point is the activity in urine. 


However, the material we saw, of 


course, that was all part of the working group 


discussions. We are not aware of a revision, 


at least I’m not aware of any revisions to 


OTIB-0049 or any other OTIB where that 


protocol has, in fact, been adopted or 


incorporated into any documentation. But we 


are certainly familiar with the work that was 


done and have done a great deal of work on our 

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own to independently evaluate NIOSH’s position 


regarding this matter. 


MR. GRIFFON: Are you in a position to 


provide any of your analysis to the Board or 


to the work group I mean? 


DR. MAURO: We are planning on doing that as 


part of our report. That was sort of center 


stage of some of the work that we were 


preparing to put together. At the risk of I 


guess speaking up before we have a chance to 


put all of our material together, I would like 


to say that the material that we did review is 


very compelling. I guess we were expecting --


correct me if I’m wrong. I don’t think we’ve 


seen anything in GI tract yet though nor 


related to, the marriage between the high-


fired plutonium issue when you’re starting 


point is urinalysis and the GI tract protocol 


and the lymph node protocol. We are, of 


course, very familiar with the other organs. 


And of course --


MR. GRIFFON: I think 1-c, John, 1-c is an 


action for NIOSH to provide those other, I 


don’t know if it’s going to be a different 


procedure or expansion of TIB-0049, but --

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DR. NETON: Mark, this is Jim. We provided 


that at the last working group meeting. 


MR. GRIFFON: It was provided, okay. 


DR. NETON: Yeah, on March 21st, 2006. The 


title was “Approach to Dose Reconstruction for 


Super Type-S Material. And I went over that ­

-


DR. MAURO: Yes, do that, but did that 


include the GI tract? 


DR. NETON: Yes, it did. 


DR. MAURO: Then my apologies, I must have 


missed on that. 


DR. NETON: Yeah, it started with TIB-0049 


and then based on the models that were 


generated in TIB-0049, and then we adapted 49 


to adjust from urine data and included an 


analysis for GI tract, systemic organs and the 


extrathoracic regions. 


DR. MAURO: As I said, I missed that. 


DR. MAKHIJANI: I have it here. This is 


Arjun. I can send it to you, John. 


DR. MAURO: Thank you. 


MR. GRIFFON: What I’ll say here is SC&A, on 


both those items SC&A will review and 


incorporate comments into their final review 

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of the evaluation report. Is that --


DR. MAURO: That’s correct. 


DR. ULSH: Considering the timeframe that 


we’re operating on here, is there any 


estimated time that we will get comments on 


that? 


MR. GRIFFON: Well, it’s probably going to 


be the same question as, I don’t know, it 


might be a different question then. Why don’t 


we, Brant, I would ask if we, let’s go through 


the matrix and at the end of this let’s 


discuss process if that’s okay. 


DR. ULSH: Okay. 


MR. GRIFFON: Because I know we have two 


weeks, and yesterday we discussed all kinds of 


deadlines for Y-12 as well. So I think we 


only have a finite number of people involved 


so I think we, let’s discuss, if that’s okay. 


And, Lew, I would ask you, too --


DR. WADE: Sure. 


MR. GRIFFON: -- if we could discuss process 


maybe at the end. I think that’s important, 


but --


DR. WADE: Yeah, I think we need to go 


through those technical issues. We have to 

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take a look back and see what’s reasonable and 


do able. 


MR. GRIFFON: And item 1-b, item 1-b was 


actually just the fact that you provided the 


background materials. So that’s completed as 


well. 


The only reason there’s a pause here 


is I’m trying to do my updates real-time so I 


don’t have to spend hours updating these 


matrices. 


MS. MUNN: So 1-b now essentially falls 


under the same response as 1-a, correct? 


MR. GRIFFON: Right, correct, so 1-a and 1­

c, those comments will be incorporated into 


your final comments of the evaluation report 


for SC&A. 


And then I’m up to comment number 4, I 


guess, if we can move ahead on this. Unless 


there’s any discussion of those items while 


we’re on the phone, John, are you, I mean, 


really, you need to look further at the GI 


models that were provided? 


DR. MAURO: Yes. 


MR. GRIFFON: So you’re not in a position 


right now to comment or discuss that. 

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DR. MAURO: Yes, I’m not in a position right 


now to comment. I’m not quite sure if Joyce 


is on the line. 


 (no response) 


DR. MAURO: She has not joined us. She 


indicated she might be able to join us. But 


right now from caucusing within our group, I 


know that we have looked closely at organs 


other than, well, look at the lung and organs 


other than the lung but not the GI tract 


portion of the analysis. So we right now are 


not in a position to discuss that. 


DR. MAKHIJANI: But John and Mark, could I 


ask a question about that? I have the 


document that Jim Neton was talking about. It 


has two short paragraphs on the GI tract 


implying that there’s more underlying analysis 


that’s where this multiplication factor comes 


from and so on. Did we get that also or is 


that --


DR. NETON: Well, Arjun, I think you’re 


making more technical out of this than there 


really is. 


DR. MAKHIJANI: Oh, okay. 


MR. GRIFFON: Maybe you can re-explain it, 

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123 

Jim. It might just be that we’ve got so many 


sites running through our heads. 


DR. NETON: This whole analysis hinges on 


the model that was developed that I discussed. 


The model was developed for TIB-0049 which was 


the Super, it wasn’t only a model, it was a 


Super-S technique that was developed using the 


Rocky Flats case number 872 in conjunction 


with the Hanford one case. In using the 


clearance parameters developed from those 


combination of bioassay and in vivo counts, we 


determined that the maximum difference between 


the intake retention fraction for S versus 


Super-S at any time post-intake. It turned 


out that the maximum difference in those two 


values was a ratio of four. 


DR. MAKHIJANI: Yes, I remember. 


DR. NETON: So it’s very simple, and we did 


not want to speculate as to which portion we 


were applying it to so we just decided to use 


four over all times post-intake and that the 


genesis of that multiplier. 


DR. MAKHIJANI: Yes, yes, I see that. It’s 


here in Table 1 and in your charts, and, I 


forgot. 

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DR. NETON: After that analysis it’s a 


simple matter of adjusting the intakes by a 


factor of four and clearing the material to 


the GI tract with Type-S clearance parameters, 


which we believe is claimant favorable. So I 


think it’s all outlined there fairly well. 


DR. MAURO: Jim, I’m listening to you and I 


think that where we have the material we need, 


and really there’s no further clarification. 


It’s just a matter of us looking a little more 


closely at it to make sure that we all fully 


understand that all the issues have, in fact, 


now been addressed. 


With regard to our having a position 


on it, we will be writing something up, but I 


can say that the material you have provided is 


very compelling and very comprehensive. 


DR. NETON: Okay, thank you. 


MR. GRIFFON: If we, I guess we can move on 


to item 4 then, number one. 


DR. ULSH: Okay, Mark, this is Brant. If 


you look at the handout that I prepared, the 5 


April, 2006 comment responses, the first page 


there deals with this issue. I think the last 


time we talked about this at the last working 

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group meeting in Cincinnati in March, we 


presented some information to demonstrate or 


to document plutonium isotopic composition. 


And I think it was Arjun had a 


question about one of the bullets. That 


figure is provided on the first page of my 


comment responses. And the bullet that we’re 


talking about is the one second from the 


bottom where it says waste stream americium 


content. And the specific part that I think 


generated the question was in parentheses 


where it says the salt waste streams have 


heavy concentrations of Americium-241. I 


think that’s kind of the thing that generated 


the question. 


MR. GRIFFON: Yeah, regarding the americium 


processing I guess. 


DR. ULSH: Yeah, now we’ve talked about some 


of that this morning. Let me recap. 


DR. MAKHIJANI: What page are you on? I’m 


sorry. 


DR. ULSH: Arjun, this is the 5 April 2006 


comment responses, page one. You might 


recognize that figure. We showed it last time 


at the last meeting and you asked the question 

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about the next-to-the-last bullet. 


The thing that I didn’t notice at the 


time when we were talking about this the last 


time is up at that top of that figure you see 


that it says in the second line there, years, 


1985 to 1987. So in fact, what we’re talking 


about here is the molten salt extraction 


process and that began at Rocky Flats in 1967. 


And by that time Rocky Flats was using a 


solvent extraction process for americium-


specific bioassay, which began on an 


appreciable scale in 1963. So the intakes, 


any possible intakes that we’re talking about 


from the molten salt extraction process would 


have occurred during the period when Rocky 


Flats had americium-specific bioassay. 


MR. GRIFFON: No, no, we did discuss this 


last time because I asked Roger, well, there 


must have been some americium processing prior 


to that, a different process. 


DR. ULSH: Yes, there was. Prior to the 


molten salt process, Rocky Flats used a 


peroxide precipitation process and that was 


from ’57 to ’67. And during that era we would 


have used gross alpha to capture americium 

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doses as we discussed this morning. 


MR. GRIFFON: Arjun, any follow up? 


DR. MAKHIJANI: No, I think I understand 


what is being done. And then this morning’s 


discussion that there are actually gross alpha 


and americium bioassay kind of addresses the 


rest of that question. 


MR. GRIFFON: And Brant, I guess that would 


mean, I’m guessing that if you didn’t know the 


person was involved in americium processing, 


then you would pick what, the worst 


radionuclide for the organ of interest? 


DR. ULSH: If we couldn’t limit it down to a 


specific radionuclide, Mark, we would pick 


from the most claimant favorable among the 


plausible solutions. 


MR. GRIFFON: Any further questioning on 


that, Arjun, John, Joe? 


 (no response) 


MR. GRIFFON: Then I think that’s --


MS. MUNN: It was the issues with the 


americium issues then? 


MR. GRIFFON: I’m sorry, Wanda, I didn’t 


capture that. 


MS. MUNN: So are we now happy with the 

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basic questions about americium? 


MR. GRIFFON: Yeah, I think they’ve answered 


all the questions about how that would be 


handled, right? So I don’t think there’s any 


further action on this other than as 


incorporated into the final evaluation report. 


MS. MUNN: Right. 


MR. GRIFFON: And that answers number two as 


well I think, correct? 


DR. ULSH: Yes, I think so, Mark. 


MR. GRIFFON: Item one and two are -- Then 


on to item six. This is the NTA film 


question, and I know some of this overlaps 


with the later comments I think, but maybe we 


can address it at this point. 


Brant, is there any follow up on this? 


DR. ULSH: Mark, we had, I’m looking at our 


notes, and let me see. What I have from our 


notes is that the glass plate calibration 


issue has been resolved per Mark Griffon. And 


we talked about that last time. I don’t know 


if SC&A has any --


MR. GRIFFON: John, is Ron, Ron seemed to be 


the one that was looking mainly into this for 


your team. 

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DR. MAURO: Yeah, Ron’s not here but I got 


the impression that was closed as well based 


that the reaction that Ron had on the phone. 


MR. GRIFFON: I believe so. 


DR. ULSH: Yeah, I believe, that’s what my 


notes say as well. 


MS. MUNN: There’s some discussion, I can’t 


remember where, in the comments that just says 


DR. ULSH: About the glass plate issue, 

Wanda? 

MS. MUNN: No, not about the glass plate 

issue, just data and corrective dose. 


DR. ULSH: Yeah, it might be included in one 


of these 17 issues --


MR. GRIFFON: Yeah, I think it does come up 


again. We might hit this one again. I guess 


my feeling was I think we’re down to sort of 


proof of principle here and a sample DR might 


be useful in this area. I don’t know if one 


of the samples you have covers neutron 


reconstruction. 


DR. ULSH: Well, we do have neutron -- hold 


on a minute. Yes, the first example that we 


have is a hypothetical neutron dose assignment 

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for monitored worker pre-1970. 


MR. GRIFFON: So there you go. 


DR. ULSH: We’ll talk about that one. 


MR. GRIFFON: Item number seven then I think 


we’re on to. 


DR. ULSH: According to your action item 


there we provided the plutonium tetrafluoride 


calibration information, so I didn’t have any 


action for us. 


MR. GRIFFON: I think all actions are 


complete on that as well unless, SC&A is there 


any follow up on that? 


DR. MAURO: I’m going to pass the buck to 


Joe. I don’t. This is John. 


MR. FITZGERALD: This is on comment seven? 


MR. GRIFFON: Yes. 


MR. FITZGERALD: The only thing was the lead 


aprons issue, and I think the report that you 


identified and the analysis in that report, 


and Kathy also looked into this for us. I 


think we’re at a point where we can resolve 


that issue. I think that was the only 


question was the lead aprons. 


DR. ULSH: Yeah, lead apron is covered under 


one of the other issues. 

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MR. GRIFFON: Under your comments anyway. 


DR. ULSH: That was a question. You could 


certainly do it, but the question was whether 


the lead aprons might compromise that. 


MR. GRIFFON: And I think that does come up 


later, right, Brant? 


DR. ULSH: Yes, that’s covered under one of 


the other comments. 


MS. MUNN: Yes, it does. 


MR. GRIFFON: So we’ll close out seven I 


think. 


DR. ULSH: Right. 


MR. GRIFFON: Number nine, if you note, 


halfway down number nine, number five, I’ve 


captured the individual items in number five. 


I’ve separated them out into items listed 


further in the matrix because there was some 


overlap here I think. And I hope I did that 


appropriately, but so we don’t have to have 


the discussion twice, well start with number 


one anyway here. 


DR. ULSH: All right, number one, I think 


SC&A, what it says here is SC&A to review 


OTIB-0050. I believe they’ve done that. 


MR. FITZGERALD: Yeah, we had those three 

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specific issues that we discussed in 


Cincinnati, and you had responses to that. We 


had Ron Buchanan on the phone. And I think we 


satisfied those remaining issues. Those were 


the three issues that remained from that 


review. 


DR. ULSH: So closed for number one then, 


Mark? 


MR. GRIFFON: Yup. 


DR. ULSH: Number two is the job exposure 


matrix, the Ruttenber data. I think we agreed 


that that was not an SEC issue. Is that 


correct, Mark? 


MR. GRIFFON: That’s what it says, believes 


this is not an SEC issue, right. And I guess 


I took, I said that NIOSH believes it’s not an 


SEC issue only because I wasn’t exactly sure. 


I think the main utility of that information 


was going to be for job information. 


DR. ULSH: I can provide you a little bit of 


an update. I think it was last week Jim 


Langsted and I visited with Dr. Ruttenber at 


his office in Denver. He showed us the 


database that he has, and we noted that in 


particular for his penetrating dose estimate 

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he has not included, he’s not been able to 


include the NDRP data. So I think that what 


we have is superior for dose reconstruction 


purposes. 


You are correct that the primary value 


of Dr. Ruttenber’s data would be identifying 


specific work locations by time period for 


specific individuals. And that could 


certainly be useful in some situations, but 


it’s not, our ability to do dose 


reconstructions will not depend on doing that. 


MR. GRIFFON: It doesn’t seem now, and the 


reason I phrased it that way was because I 


wasn’t sure of your models, but it doesn’t 


seem as though the models you presented would 


be reliant on job information. That’s much 


more reliant on bioassay information. 


DR. ULSH: That was a very early issue 


because it wasn’t clear how the coworker model 


was developed. And I think you’re right, 


Mark. I think now that we’ve seen how that’s 


going to be handled, it’s certainly a lesser 


concern. 


MR. GRIFFON: Right, and I think that’s --


DR. ULSH: Is it closed? 

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MR. GRIFFON: I think it’s not an SEC issue 


at this point. 


DR. ULSH: Okay, so closed for terms of, for 


purposes of SEC action, maybe not for --


MR. GRIFFON: No further actions I don’t 


think unless others think otherwise. 


 (no response) 


MR. GRIFFON: Okay. 


DR. ULSH: Let’s see, number three, NIOSH 


provided analysis regarding completeness of 


external exposure data. We talked about that 


this morning. Since we talked about it this 


morning, I don’t suppose that SC&A has had 


time to review it. 


MR. GRIFFON: Well, and I think at this 


point will review and provide comments in the 


review of the evaluation report. I think that 


would be appropriate unless, the only question 


I would have here is if there’s anything, I 


guess that would be issued as supplemental 


data if you did do more on the internal dose, 


you know, oh, this is regarding completeness 


of external exposure. 


DR. ULSH: Right. 


MR. GRIFFON: But if you were going to 

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provide more, I guess it would include review 


of supplemental, you know --


MR. FITZGERALD: If I’m right, the external 


actually is treated in the evaluation. It’s 


the internal that’s not fully addressed. 


DR. ULSH: Right, the external, forget it. 


That’s accurate. 


MR. GRIFFON: So I guess I would say that 


that would be, you know, that SC&A doesn’t 


have to do a separate review. Rather, it 


would just be included in their review of the 


full evaluation report? 


MR. FITZGERALD: Okay. 


DR. ULSH: Okay. Number four, NIOSH will 


provide description of coworker model to be 


used, provide coworker database analysis 


files. We do have some example DRs that 


include coworker for unmonitored external 


dose. That’s example number three. And 


example number four is internal coworker. And 


with that I have provided the tables that show 


the distributions that we would be using for 


coworker data should we ever find a case that 


requires it. 


I don’t know, Mark. Do you want to 

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wait and get through the matrix items and then 


talk about the example DRs? 


MR. GRIFFON: Yeah, I think so. That’ll 


just make it easier. On this I would also say 


the review would be within the construct of 


the full review for SC&A. 


MR. FITZGERALD: Just to clarify the earlier 


description of the model. We were talking 


about data reliability, but in a sense we’re 


backing into some description of the basis 


perhaps of using the data for this purpose. 


Is that what constitutes a description or do 


we have something additional to that? 


DR. ULSH: Well, there is -- Joe, right? 


MR. FITZGERALD: Yes, hi. 


DR. ULSH: Joe, there is some material in 


the comment responses, you know, the 17 


issues? 


MR. FITZGERALD: Right. 


DR. ULSH: There’s some material in one of 


the, maybe a few of the responses there. So 


between what we’ve provided this morning in 


the frame within the framework of the ER and 


the comment responses, I think that that will 


be pretty much what we’ve got for now. 

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MR. FITZGERALD: Okay, I just wanted to 


clarify because again, it wasn’t addressed 


head-on in the evaluation. 


But I guess just to get back to what 


you were driving at, Mark, how do we deal with 


the ancillary information that interprets 


what’s not necessarily fully addressed in the 


evaluation? 


MR. GRIFFON: Right, right. 


DR. ULSH: Well now, I do want to point out 


that the evaluation report focused on issues 


that were brought up in the petition. There 


are additional issues and expansions of issue 


that were brought up within the context of 


SC&A’s review of the TBD. And so the ER was 


no meant to cover those expansions. I mean, 


we just focused on what was in the petition, 


so the question still remains, how do we 


handle that other stuff that was brought up 


outside the confines of the petition or as an 


expansion on that? 


MR. FITZGERALD: And I don’t know, Mark, 


maybe you want to take a stab at that. 


MR. GRIFFON: I still think coworker models, 


well, you know, whether they’re, they are 

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addressed in the petition or in the ER report, 


aren’t they to some extent? 


DR. ULSH: I think in the data sufficiency 


section we talked about that. 


MR. GRIFFON: And I, even though it wasn’t a 


specific issue maybe brought up by the 


petitioners, I think that. 


DR. ULSH: It’s a fuzzy line. 


MR. GRIFFON: Yeah, I guess from my 


standpoint any issues that we’ve identified as 


SEC issues through the work group process 


should also be rolled into SC&A’s evaluation 


of the petition, you know, of the, I mean not 


evaluation of the petition, review of the 


evaluation report. So I would say that unless 


you think that’s inappropriate, I would think 


that, since through our work group process 


with you guys on the line, we’ve identified 


these things as potential SEC issues with, 


that they should be included in SC&A’s SEC 


review. Does that make sense? 


DR. MAURO: Mark, this is John. Our plan, 


I’ll give you an example. When I reviewed the 


Rocky evaluation report, I noticed that 


reference was made to OTIB-0049 on the high­
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fired; however, there was -- and correct me if 


I’m wrong -- the development of the urine-base 


starting point worked ^ NIOSH and ORAU was not 


part of the evaluation report. And in fact, I 


noticed that there is reference, lots of 


reference in the evaluation report to some 


ongoing work, reference to OTIBs, such as 


coworker. 


Our plan was to use all the 


information in our review as if it were a 


supplement to the evaluation report, but 


nevertheless make a statement in our report 


that where we note that this material is 


really not contained in the evaluation report, 


not is it actually an actual OTIB, for 


example. So in effect, we will, our attempt 


was to point out where the evaluation report 


does not explicitly contain the information or 


the OTIB itself has not actually been 


published yet, the material or the substance 


of it has been provided to SC&A as a result of 


working group activities. 


And on that basis we will be able to 


make certain statements as findings and 


observations. So we’re going to be treating 

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all of this material, including the material 


that has been provided to us electronically 


yesterday and today, as part of the universe 


of material that we’re going to draw upon when 


we write our reports. 


MR. GRIFFON: That’s what I was hoping, 


John. 


DR. ULSH: With the one proviso being though 


that the SEC evaluation of record from NIOSH 


cites, for example in this particular case, a 


particular OTIB for the coworker model. So 


what we’re doing is compensating for not 


having that available OTIB and drawing from 


these various sources to glean what the NIOSH 


approach appears to be. That’s not as direct 


as the reference in the evaluation itself. 


So, well, we’ll have to qualify it certainly. 


Not certainly a review of that coworker model 


as it would be contained in the OTIB, but 


something that would be preliminary to that. 


MR. FITZGERALD: Yeah, we have draft OTIBs, 


OTIB-0038 and OTIB-0058, which describe the 


coworker external and coworker internal. I’m 


not sure I’ve got, I might have those numbers 


reversed. And we would be happy to provide 

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those to you like tomorrow. 


DR. ULSH: Resemble what we have pretty 


closely. That might actually be a little 


cleaner. 


MR. FITZGERALD: Yeah, I think so. 


MR. GRIFFON: Can you post those on the O 


drive in their folder in --


DR. ULSH: Yes. 


MR. GRIFFON: -- Board folder. 


DR. MAURO: By the way -- this is John 


again. All the more reason, the fact that 


we’re in real time working with material that 


is being developed as we’re working through 


the problems that we maintain this ongoing 


communication over the next two weeks because 


we will be using the material that has been 


transmitted to us electronically as part of 


our work. And since a lot of material, for 


example, is very much in draft form as, for 


example, we noticed that the uranium­

/plutonium-typos, that sort of thing. So I 


see this as we work through the problem, we’re 


going to have to work very closely with Jim to 


make sure we have the right material that has 


been sent to us that it is --

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MR. GRIFFON: With Jim or Brant, yeah. 


DR. MAURO: I guess my plan was to work 


directly, what I understood is that we make 


our call to Jim, and Jim becomes sort of like 


a traffic cop. 


DR. NETON: Yeah, I think for purposes of 


the Rocky Flats petition though, John, I think 


Brant’s been leading it up. 


DR. MAURO: Okay, so we’ll go through you, 


Jim, for Y-12 and Brant for Rocky. 


DR. NETON: Yeah, I would make sure, keep me 


cc’d, but I think in this case feel free since 


time is of the essence and Brant’s been taking 


the lead to deal with him directly. 


DR. MAURO: Okay, very good. 


DR. ULSH: Darn, I thought for a minute 


there I was off the hook. 


MR. GRIFFON: The other thing I would ask 


Brant, you said OTIB-0038 and 0058? 


DR. ULSH: Yes. 


MR. GRIFFON: And before you committed to 


OHIS and a CEDR, OHIS-20 and a CEDR databases 


or ACCESS versions of those databases being 


posted --


DR. ULSH: I will. 

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MR. GRIFFON: -- and also I would say the 


analytical files. I’m sure you have some 


Excel files that support those OTIBs for your 


extrapolation methods back calculations for 


intakes for the internal coworker model, et 


cetera. 


DR. ULSH: I’ll see what Joe can provide. 


MR. GRIFFON: All right, does that, I think 


that clarifies it then, John. And certainly, 


John, you’re right. We’ll keep in close 


contact on this since we’re moving in very 


real time here. 


Number five then I think we’re on to. 


DR. ULSH: Number five --


MR. GRIFFON: I was actually going to say if 


we, I think most of these items I’ve broken 


out in further issues at the bottom of the 


matrix so we can probably discuss them at that 


point. 


DR. ULSH: So do you want to pass over this, 


Mark? 


MR. GRIFFON: Yeah, pass over that one. 


Just someone might want to, I’ll try to 


crosswalk those and make sure that I didn’t 


miss any of them, but I’m pretty sure I lifted 

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all those out of there and put them in the 


bottom of the matrix. So try number six. 


DR. ULSH: All right, number six, this deals 


with this question of inappropriate low energy 


photon detector correction factors. 


MR. LANGSTED: I believe this is a K-16 


issue. 


DR. ULSH: Okay, I’m going to let Jim 


Langsted give you an update on that. 


MR. LANGSTED: Okay, I’ve done some research 


on this issue, and back in the initial 


implementation of DOELAP there was a 16 keV 


photon. It was a fluorescent x-ray technique 


that they defined as one of the test 


exposures. There was also a 30 keV x-ray 


spectrum, 30 keV average x-ray spectrum, that 


was specified. 


Since these two are very close 


together, it became a difficult issue to 


develop an algorithm that was robust enough to 


recognize the difference between these two 


exposure, respond appropriately to these 


exposure categories and then also respond 


appropriately to the photons in the more 


realistic regions that we needed to deal with. 

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So at the time that the algorithm that was 


developed at a bias associated with it that 


was somewhere between one percent and ten 


percent bias. In some cases that was a plus 


ten percent. In some cases that was up to a 


minus ten percent of bias in responding at 


these very low energies. That turns out not 


to be a significant problem because that’s 


within the recognized uncertainty of the 


dosimeter badges as we’re viewing them today. 


DOELAP recognized that this was a 


difficult issue to deal with and has since 


dropped one of that lowest keV 16 x-ray 


technique. And since then the algorithms have 


been refined to give a better response across 


the spectrum and not have to deal with that 


careful distinction at those low energies. 


So the conclusion here is that the 


response was adequate back when those 


algorithms were, the initial algorithms were 


used, and then was refined as the algorithms 


improved, and turns out not to be an issue. 


MR. GRIFFON: Is this written up in one of 


your -- I was just looking through the April 


5th
 . It’s not in those. 

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DR. ULSH: No, it’s not, Mark. 


MR. LANGSTED: That’s correct. 


MR. GRIFFON: I mean, that sounds, you know, 


I just wonder if we should have some sort of 


document just to answer that or just a memo 


just with what you said. 


DR. ULSH: Sure, we can do that. 


MR. LANGSTED: We’ll get that to you. 


MR. GRIFFON: Something for the record, 


that’s all. Unless, SC&A, any follow up on 


that one? 


DR. MAURO: No, but we do appreciate that 


these kinds of response, our plan right now is 


to put together a report that effectively 


starts with the issues as laid out either in 


the matrix or the petition. And then work our 


way through NIOSH’s position by making 


reference to the appropriate OTIBs, sections 


of the TBD, sections of the assessment and 


other material. 


So we would like to have a paper trail 


for every one of the issues. So please, yes, 


any time we have a response. In fact, this 


may not be possible, but the transcript of 


this conversation and yesterday’s conversation 

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is really going to be very important to us in 


the next several days to help us navigate our 


way through this. So that would be helpful 


also. I don’t know if that’s possible. 


DR. WADE: We’ll do what we can. 


MR. GRIFFON: Going on to number seven in 


that same category, issue nine, number seven. 


DR. ULSH: Okay, number seven, let me give 


you, this is also one of those issue that is 


included in the, as our responses to the 17, 


but let me give you the short answer here from 


my memory because I can’t locate it in my 42 


pages right at the moment. 


MR. GRIFFON: Did you get a written response 


from the petitioners? 


DR. ULSH: Yes, if you recall, we talked at 


the last working group meeting. We had sent a 


letter to Tony DeMaiori, the petitioner, dated 


March 16th . He had mentioned in his call that 


he had several investigations, so we wrote and 


asked him for those on March 16th . Jennifer 


Thompson stated that we would be getting a 


letter, and in fact, we did get it the next 


day. And basically, Tony said that he did not 


have access to those investigations. And he 

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directed us to a lady named Lisa Bressler^, a 


Freedom of Information officer. 


We talked, some of the ORAU team 


talked to Ms. Bressler. She directed us to 


some other personnel, DOE and Kaiser-Hill, and 


our conversations with them are ongoing. I 


tried a couple of times on Friday to reach her 


and couldn’t. I think it’s possible, I’m 


going secondhand here, but they might have 


talked to Tony to try to nail down some 


specifics about what he was talking about. 


And I think there were some Privacy 


Act concerns. I think we can iron those out 


once I manage to get in touch with these 


additional people. But that’s where we are 


with that right now. And I guess the bottom 


line is we haven’t seen anything that suggests 


fraud or manipulation of the data, but I have 


to say that our conversations are continuing. 


MS. MINKS: This is Erin Minks from Senator 


Salazar’s office. Is this a conversation that 


will be time sensitive to the same timeline as 


the meeting in two weeks? 


DR. ULSH: I’m sorry, could you repeat that? 


I didn’t hear it. 

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MS. MINKS: This is Erin Minks with Senator 


Salazar’s office. The conversation about that 


documentation with Tony from the Steelworkers 


DR. ULSH: Yes. 


MS. MINKS: -- is that going to be also time 


sensitive to the meeting in two weeks? Is 


that something that is going to be ongoing 


after this is --


DR. ULSH: Well, it’s hard for me 


characterize, but our goal is to provide all 


the information that we can to support the 


Board. I mean, at least it’s on the agenda 


right now for them to cast a vote so we’re 


going to provide all the information that we 


have at the time. 


MS. MINKS: Okay, thanks. 


MR. GRIFFON: That’s why I was saving the 


discussion for the, discussion of process till 


the end of the matrix here to see where we 


stand sort of. Because I do believe there’s 


some, I’m just wondering if there’s some 


issues that are going to be, that all parties 


are going to be able to complete in this two-


week timeframe. But let’s save that for the 

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end and have that discussion once we get 


through the matrix. 


DR. ULSH: Is there anything else on seven? 


 (no response) 


DR. ULSH: Okay, Mark, do you want me to go 


on to eight? 


MR. GRIFFON: I think so, yeah. I just 


think for seven that you’re, I added to the 


action that you’re in process of researching 


this specific investigations mentioned in the 


letter from Tony. 


DR. ULSH: Well, sort of, I mean, Tony, 


basically, Tony’s letter didn’t provide 


specifics. He just told us to talk to Ms. 


Bressler, and then she directed us to the 


other personnel. And I think Tony --


MR. GRIFFON: I think the process of 


researching past investigations. 


DR. ULSH: Yes. 


MR. GRIFFON: How about that? 


DR. ULSH: Yes. 


MR. GRIFFON: Maybe not specific. 


DR. ULSH: Number eight, we’ve talked about 


this this morning, I think, about where we are 


with this issue. Demonstrate reliability of 

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bioassay and external database data for the 


compensation program. And we talked about 


this issue about Kaiser-Hill doing a QC on the 


external dosimetry that they provide for 


individual claimants to us. And we also 


talked about that there is no roll up reported 


in that QC effort. That still holds. This 


morning we talked about, we compared the HIS20 to raw records for external, and we also 


compared, for internal, we compared CEDR to 


HIS-20 and we’re in the midst of going from 


HIS-20 to raw records. So that’s where we are 


with that. That’s the update. 


MR. GRIFFON: And we had some discussion of 


that previously. Any other discussion on 


that? 


Ken, is it fair to say that you 


incorporated further analysis within your 


evaluation report that we spoke from this 


morning, right? 


UNIDENTIFIED: Yes. 


MR. GRIFFON: The HIS-20 and CEDR comparison 


were in separate documents? 


UNIDENTIFIED: That’s correct. That’s 


outside of the ER. 

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MR. GRIFFON: Is there any further action on 


this? It sounds like there still is an 


outstanding action as far as --


DR. ULSH: I think that there is, Mark. 


MR. GRIFFON: -- the urine. 


DR. ULSH: Yes, going from HIS-20 to raw 


records for bioassay, I think, is an 


outstanding action. And I don’t know about 


the external. 


MR. GRIFFON: Well, the external was that, I 


think I asked, rather that was written up, and 


I forget the response to tell you the truth. 


But is that written up or --


DR. ULSH: Yes, that is --


MR. GRIFFON: The 30 worker years or 


whatever. 


DR. ULSH: Yeah, that’s included in one of 


our comment responses to one of the 17 


questions. When we walk through those, I’ll ­

-


MR. GRIFFON: So it’s within that 17, within 


that April 5th memo? 


DR. ULSH: Yes, yes. 


MR. SMITH: I have one thing to add. Hello? 


MR. GRIFFON: Yes. 

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MR. SMITH: This is Matthew Smith. I did go 


ahead and add Craig Little’s analysis into 


OTIB-0058. So when you look at that draft, 


and when it does become a final document, 


there’ll be a couple paragraphs there on this 


validation issue as well. 


MR. GRIFFON: Okay, thank you. 


MR. FITZGERALD: I guess before we leave the 


issue is the urine to raw records review, the 


one we just talked about, is that something 


that we’d likely see in the timeframe we have 


or is that perhaps further off? 


DR. ULSH: I hope it’s not further off, Joe. 


MR. FITZGERALD: Well, I’m just wondering 


because in the course of this review, 


obviously, if it’s going to be provided, we’ll 


certainly look for it. 


DR. ULSH: Yeah, is Craig on, Craig Little? 


 (no response) 


DR. ULSH: No, he’s not. I’ll double check 


with him. We’re going to try. We’re going to 


try as hard as we can. 


MR. GRIFFON: I guess we’re on to the next 


item. Any comment, any further comments 


there? 

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 (no response) 


MR. GRIFFON: Item number ten now, which 


used to be labeled New Issue One, but I didn’t 


feel like having New Issue One through 30 so I 


started renumbering. 


DR. ULSH: This is the roll-up issue where ­

- let’s see, only penetrating doses were 


available prior to ’76. I think your action 


item there spells it out, Mark, and that was 


an SC&A issue to review the approach? 


MR. GRIFFON: Right. 


And John or Joe, did you provide any 


written comments on this? 


DR. MAURO: This was Ron’s report. If I 


recall, there wasn’t really anything 


outstanding. There were a couple of minor 


comments. 


Joe, last time we spoke, there were a 


couple of things that were on the periphery 


but nothing center stage. 


MR. FITZGERALD: Right, that’s kind of what 


we said a little earlier. That we looked at 


those particular issues. He had three 


specific issues, and he had this comment as 


well. And my notes show that we certainly 

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reached satisfaction with his review at the 


last working group meeting. So I don’t see an 


outstanding issue on this. 


MR. GRIFFON: I’m going to put no further 


action on that. 


DR. MAKHIJANI: This is Arjun. Joe, wasn’t 


there a 1970 -- this is maybe a little bit 


off-base because I haven’t been that involved 


in this, but wasn’t there an issue of the 


specific year of 1970? 


MR. FITZGERALD: Yeah, yeah, we discussed 


that in Cincinnati, and it was a relatively 


short period of time, and the explanation was 


satisfactory. It’s like four months in 1970. 


MR. GRIFFON: All right. 


DR. MAKHIJANI: Okay. 


MR. GRIFFON: Okay, I think I’ll label this 


as no further action, if that’s --


DR. MAKHIJANI: Yes. 


MR. GRIFFON: Number 11. 


DR. ULSH: Let’s see, this was an algorithm 


MR. GRIFFON: Oh, don’t bother. I think we 


already addressed this, right, no further 


action? 

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DR. ULSH: Oh, no further action. Okay, 


good. That gives me, because I was scratching 


my head about this. 


MR. GRIFFON: Yeah, I think we’ve addressed 


that one. 


MS. MUNN: Yeah. 


MR. GRIFFON: Number 12 starts with those, 


the comments from the petition actually. 


DR. ULSH: So is that the 7/17, Mark? 


MR. GRIFFON: Yes, so that should go to 


your, it should be in the order that we 


addressed them last time. So they should go 


right down your document. 


DR. ULSH: Okay, so how do you want to 


handle this? Do you want to work from the new 


document or --


MR. GRIFFON: Let’s work from the matrix, 


but they should be in the order that you have 


them in your comments document, too, unless 


you have a different response. That might be 


the one difference, but we’ll find that as we 


go, I guess. 


DR. ULSH: Yeah, okay. If you look at the 5 


April comment responses, the first one we’ve 


already covered. That was one from the old 

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matrix. So we’ll start on page two with what 


is labeled Data Integrity Comment Number One, 


zero entries when badges were not returned. 


And --


MR. GRIFFON: Wait now, does that coordinate 


with number 12 on my matrix? 


DR. ULSH: Yes, I’m sorry, number 12 on the 


matrix. 


MR. GRIFFON: It is, okay. I just wanted to 


make sure. I’ve got to pull both these up at 


the same time. All right, got it. I’m sorry. 


DR. ULSH: So SC&A has provided, I think --


Joe, correct me if I’m wrong. This is from 


Kathy’s trip --


MR. FITZGERALD: Yeah, we again provided 


some interim information that was collected 


and reviewed from that trip. It again was a 


relatively brief trip, but these are some of 


the data points about that. 


DR. ULSH: Okay, so you can read SC&A’s 


comment, complete comments, on pages two, 


three, and then there’s some graphics, 


excerpts of logbooks that were provided on 


page four and five. And then you get to our 


response on page six. 

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The new, okay, it’s not a new comment. 


I’m trying to think of the right words here, 


the new write up that SC&A provided, the 


expanded write up that SC&A provided cited 


part of our comment response, but I’ve 


provided the complete text of the response 


here. And specifically I would direct you to 


a section of our original response that wasn’t 


reproduced, and that is on page seven. At the 


end of the paragraph it says entries of no 


data available indicated instances on and on. 


And that is we concluded that since anomalous 


readings were investigated, and I think that 


the excerpts of the logbook that SC&A provided 


certain show an example anyway that, at least 


in this case, problems with dosimeters were 


recorded. So in instances where there were 


anomalous reading, we contended that the 


presence of no data available entries in the 


reports that were given back to the workers 


don’t prevent us from performing dose 


reconstructions of sufficient accuracy. So we 


don’t see anything new here in the expanded 


material that SC&A provided that contradicts 


that, our previous response. And so in our 

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previous response we described how we would 


handle these situations and that is the 


assignment of missed dose. Now I don’t want 


to comment on documents that I haven’t 


reviewed yet. And we don’t have the complete 


logbooks. All we have is the excerpts that 


were provided in SC&A’s expansion of the 


comment. And we would want to do, of course, 


we would want to do a careful review. But 


they do provide some evidence, at least these 


excerpts do, that suspect badge readings were 


at least recorded. 


MR. FITZGERALD: And we had additional, 


certainly additional documentation that was 


coming in. This was just simply a cut to 


provide what we could within the last week or 


so. 


Kathy, are you on the line? 


MS. DeMERS: Yeah, I am. 


MR. FITZGERALD: Is there anything else you 


want to add to that? 


MS. DeMERS: The records that I reviewed at 


the Mountain View facility, which were the 


records that DOE provided, first of all, they 


didn’t give me all the records I requested. 

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And second of all, the ones I did copy are 


still at Rocky Flats. And there’s going to be 


a couple of additional records that come out 


of the data that I have received. 


MR. FITZGERALD: Kathy, was there any reason 


for DOE not providing the records requested? 


MS. DeMERS: I believe they couldn’t 


initially find what I was asking for and by 


the time they found it, it was the first day 


of my trip, and they didn’t have enough 


turnaround time. 


MR. FITZGERALD: To respond to, I think, 


Brant’s question though in terms of perhaps 


the relevancy of the kinds of documents that 


are being requested to the issue at hand, to 


give as to what these might show us? 


MS. DeMERS: When I interviewed the 


petitioners and several other people, there 


was a continued concern over them working in 


very hot areas but receiving zero dose on 


their record or receiving no data available on 


their record. NIOSH has responded that a 


dosimetry investigation form would be put in 


the file in these cases, and to date I have 


not found one. The reason I’m pulling the 

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secondary data is because workers indicated 


that the logbooks have some recorded doses in 


them for periods of time. These were jobs 


where individuals were assigned special 


dosimetry. 


DR. ULSH: Kathy, if I could maybe ask you 


for a clarification? When you’re saying the 


logbooks, are you talking about the logbooks 


that were used in the field to record the dose 


rates recorded with field instruments or are 


you talking about dosimetry logbooks? 


MS. DeMERS: No, I am talking about the 


contamination control and shift supervisor 


logbooks. And what I was told is that there 


is results from, exposure results basically 


for a particular job. 


MR. GRIFFON: So, Kathy, does this, these 


excepts that we have in this document that’s 


Brant’s referring us to, these are excepts of 


those logs that you’re talking about? 


MS. DeMERS: No, the only reason that those 


were put in there is to demonstrate that there 


are logs out there that do have notations that 


the crystal was lost or there was a problem 


with the reader. Now what needs to be done is 

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they need to take individuals and verify that 


they did an investigation of those 


individuals. 


MR. GRIFFON: Right, and you didn’t uncover 


any of that type of information. You 


requested some maybe, but you weren’t able to 


get to that yet? 


MS. DeMERS: What I didn’t get were several 


dosimetry records from individuals who made 


claims of mda results or zeros in the petition 


and the field logbooks that allegedly 


contained dosimetry results that would 


contradict with those being reported by 


dosimetry. 


DR. ULSH: Okay, again, I want to be 


cautious here because I haven’t seen any of 


these, any of this documentation, but it 


occurs to me that if you’re talking about 


shift supervisors and contamination control 


logbooks, that would have been based on survey 


data. You may not expect that to correspond 


one-to-one with what would show up on the 


worker’s dosimetry badge once it was read in 


Dosimetry. But I really can’t say beyond that 


because I haven’t seen the document. 

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MS. DeMERS: These were some of the records 


that were not pulled at the time that I was 


there. And we can get you to pursue them and 


look into the issue further. 


MR. GRIFFON: I think some of the actions 


that as we go down the matrix there’s a couple 


specific cases where we asked to try to pull 


the string. And that’s, I think those kind of 


things will be very interesting in this 


regard, but I don’t know, is there anything 


more to discuss on this particular item? I’m 


not sure. 


MS. DeMERS: Well, I guess I have a question 


for NIOSH. And that question is did you talk 


to the individuals that provided the 


affidavits, in the process of doing the 


evaluation? 


DR. ULSH: I’ll get to that a little bit 


later in the comment responses. We did pull 


some of the dosimetry records for those 


individuals. And once we had those dosimetry 


results, we felt that that was sufficient to 


cover the issue, to address the issue. 


DR. MAURO: This is John Mauro. I’d like 


to, I think this is a good point to raise 

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this. In working the problem in terms of all 


of the issues that are before us, I think an 


enormous amount of work was done on the 


technical issues. And NIOSH has put forth 


some very powerful material that I think has 


been very compelling going to chest cavity 


issues, neutron dosimetry issues and also, of 


course, the high-fired plutonium issues. 


The area right now where SC&A has been 


looking closely has to do with the data 


reliability issue. I think that this is 


center stage. It’s clear that there are a 


number of records out there that might be of 


great value to break the ground to obtain 


review interfacing perhaps with some of the 


folks that are expressing this concern to run 


these to ground as opposed to, let’s say, 


looking at records on file that you currently 


have working with the individuals that are 


making these claims. 


I think the, this one issue, data 


reliability, and the concerns regarding 


falsification of records is emerging as by the 


single most important issue related to this 


SEC petition. I think that to a large extent 

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everything has been done that’s humanly 


possible to address the, which I call, the 


more technical issues. So I guess I just 


wanted to put that perspective in so that we 


put the spotlight on what we believe to be the 


area that is of greatest concern to us. 


MS. MUNN: This is Wanda. I need to be, I 


need to have a clarifying point here. I 


believe I’ve been hearing from the beginning 


of our discussion that the dose 


reconstructions, one of which I tried to do 


and gave up in total despair early on, will be 


based on bioassay data not necessarily on 


dosimetry. Is that, am I incorrect in this? 


MR. GRIFFON: That would be for the internal 


dose, Wanda, not for external exposures. So 


you’re correct on the internal dose that I 


think the primary basis will be the bioassay. 


In vivo may be used to bound, right? 


Is this right, Brant? I mean, I’m 


summarizing, grossly summarizing here. But 


the dosimetry’s going to be relied on for the 


external, certainly. 


DR. ULSH: Yes, that is true, Mark. 


MS. MUNN: I’m having a hard time imagining 

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extreme external dosimetry issues that would 


not be reflected in the bioassay. 


MS. DeMERS: Well, in this case we’re 


talking about the dosimeter response. 


MR. GRIFFON: Yeah, I can certainly think of 


some scenarios where you’d have fairly 


significant external and limited internal. I 


mean, correct me if I’m wrong anybody, but I ­

-


MS. MUNN: No, I understand what you’re 


saying. 


MR. GRIFFON: Oh, okay. 


MS. MUNN: But it’s difficult -- well, never 


mind. I’ll think on that. 


DR. ULSH: As kind of an addendum to John’s 


previous comment, I would point out that we 


certainly have had conversations with the 


dosimetry personnel at Rocky Flats and also 


with, we followed up, at least partially, I 


mean, to the extent that we have been able to 


give them a timeframe, we have followed up on 


the leads that were given to us by Tony 


DeMaiori. 


Now we’re not at the end of the road 


on those. I’ll be up front with that, but we 

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do, we have had a number of conversations with 


dosimetry personnel who were actually 


processing the badges and who actually had the 


details of how these badges were processed, 


were recorded, what problems occurred with 


them. So we have done that. I mean, it’s not 


like we haven’t talked to anybody out here. 


But if you’re asking if we have interviewed 


everyone who submitted an affidavit in the 


petition, the answer is no. No, we have not. 


MR. GRIFFON: Well, and let’s try to go down 


the matrix a little because there are some 


specific ones where we asked that we thought 


would be useful to crosswalk and, I mean, I 


can recall the radiation technician with a 


very specific allegation, you know, that I 


thought would be useful to either demonstrate 


that the procedures were working or, you know, 


question whether they were. 


But I would say the only thing that I 


would note on number 12 here is I think there 


were two parts of this. One was to look at 


specific cases and the other was to look at 


the systemic problem or potential systemic 


problem by doing, I think you proposed some 

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statistical approaches of looking at the data. 


And I don’t know if you’ve looked at that at 


all, Brant, either. Have you done either one 


of those? 


DR. ULSH: We tried to do that, Mark. We --


let me tell you what we did. We had a number 


of years’ worth of quarterly data that we 


looked at. And what we were looking for was 


an indication that as workers approached limit 


over the year, there would might be a 


difference in the distribution of their doses 


by quarter. 


And that might signify either one, 


their badges were left in their locker as some 


workers have alleged or two, the workers were 


pulled out of the radiation areas as they 


approached their limits. Both of those would 


fit such a pattern. We performed that 


analysis and we didn’t see differences between 


quarters; however, after we talked about this, 


we decided that, you know, that’s not going to 


be, it’s not going to put the issue to bed. 


And the reason is that in some time 


periods the most exposed workers, which is 


where you would most logically expect to see 

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this kind of an issue, they would not be on 


quarterly badge reads. They might be on more 


frequent badge reads. And so we didn’t feel 


that that issue really got at what we were 


trying to do. In addition, we can compare to 


regulatory limits in place at the time, but 


that may not get at the issue either because 


in some situations there were administrative 


limits. 


And we really didn’t have a way to, on 


a large-scale basis, tie workers to particular 


situations where there were administrative 


limits in place. Those would have been the 


ones that would have been binding. You know, 


if a worker approached an administrative 


limit, he might have been pulled out of an 


area or, you know, and we just have no way to 


evaluate that. That’s where we are with that. 


We just didn’t feel it was terribly 


informative. 


MR. GRIFFON: All right. 


DR. MAURO: Where that puts us is when we 


last spoke quite frankly I was optimistic 


about that investigation in terms of putting 


to bed the, I guess the issue had to do with 

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how prevalent was that and making a judgment 


whether or not it was a deliberate act or just 


an inadvertent act, but how prevalent was it 


whereby an individual would go from relatively 


high readings and then the next cycle go to a 


zero reading? That, when we discussed it, it 


sounds like it was a tractable analogy. 


That is, looking at an individual’s 


records and seeing when the numbers sort of 


fall off the table indicating that some action 


was taken, that action could very well have 


been taking the person off that particular job 


because he was approaching the regulatory or 


administrative limit. But having an 


understanding of the extent to which that 


happens would give us some insight as to if 


that was very widespread. 


Now, what that does, if that’s do 


able, now certainly it doesn’t answer that 


question whether or not there’s, and I’ll use 


the word falsification of records or 


deliberate leaving your film badge somewhere 


else. But it does go to the frequency with 


which we have indication that there was some, 


I guess, abrupt change in activity that 

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resulted in a person going from having cycles 


where he was accumulating exposures, perhaps 


approaching some administrative limit, and 


then that exposure ceased in the next cycle or 


two or three and then perhaps picking up 


again. 


In other words that type of pattern 


and the degree to which that occurred is 


indicative of the prevalence. Now if that 


turned out to be not that prevalent, that in 


itself is very informative, and perhaps to a 


large degree could put to bed some of the 


concerns that we’ve been hearing. Is it 


possible just to get some information on those 


patterns or are you saying that the records 


are not amenable to that type of an analysis? 


DR. ULSH: Well, John, I mean to do this on 


an individual basis, I mean, certainly we can 


look at selected individuals. And in fact, I 


think one of the later comments deals with a 


couple of situations like that, but that’s 


only a couple of individuals. Now on a 


system-wide basis I can tell you what we 


found, and that was we didn’t detect great 


difference between quarters. 

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In other words, we didn’t see a big 


drop off from the limits in the fourth 


quarter. But again, that’s just quarterly 


data. Now I can also tell you that the, we 


basically had accumulative frequency so how 


many people’s badges recorded 50 millirem or 


less, 100 millirem or less and I can tell you 


that those histograms were far below 


regulatory limits in most, there were only a 


very few that would have been at the higher 


spectrum, but again, I’ve got to caution you 


on what conclusions you can draw from that 


because the regulatory limits may not be the 


appropriate limits to consider. 


MS. DeMERS: Can I make a statement here? 


This is Kathy. You should probably be aware 


that when someone received excessive exposure, 


then they were assigned to another area, what 


they liked to call a cold area. It was not 


necessarily an area without radioactive 


material and exposure potential. For example 


if someone was assigned to the americium line 


and was receiving too much exposure, they 


might send him to another area of the 771 


building which was still involved with 

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plutonium processing. 


DR. ULSH: Okay, wouldn’t the idea though, 


Kathy, be, I mean, it’s probably true that the 


dose potential would not be zero, but the 


whole idea of the move would be to move him to 


a lower potential area. 


MS. DeMERS: What I’m bringing that up for 


is because you’re looking for patterns where 


you have a dose and then all of a sudden you 


get a drastic drop. 


DR. ULSH: Right. 


MS. DeMERS: And the drop may not be as 


drastic as you might think it would be because 


they’re still in a radiological area. 


MR. GRIFFON: Yeah, and I think more to the 


point is your assessment, Brant, that you’ve 


got quarterly data and you had weekly 


exchanges or monthly exchanges. You know, I 


think it’s very hard --


DR. MAURO: Can’t do it. 


MR. GRIFFON: -- if your tool’s not 


sensitive enough to see those differences. 


DR. ULSH: That’s kind of my point. I would 


hate to -- yes. 


MR. GRIFFON: I think that’s the primary 

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point which brings me back to step back from 


that a second. All you have is the CEDR in 


this case? I’m wondering if the monthly or 


weekly was ever recorded in any sort of 


database. I guess if it was, you would have 


been using it so I’m assuming it’s not. 


DR. ULSH: Mark, Jim tells me that HIS-20 


does contain -- what data? 


DR. NETON: Cycle-by-cycle. 


DR. ULSH: Cycle-by-cycle data after ’76. 


MR. GRIFFON: Oh, after ’76? 


DR. ULSH: Yeah. 


MR. GRIFFON: And did you look at that for 


any pattern? 


DR. ULSH: You know, Craig is the one who 


did this. 


Craig, are you online? 


MR. LITTLE: I am online. 


DR. ULSH: Where did we get the data that 


you used, quarterly data? That was claimant 


data, wasn’t it? 


MR. LITTLE: Well, in the one instance it 


was claimant data, yes. In the other instance 


it was data that come off of the beta-gamma 


worksheets that we rolled up into a comparison 

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with the 20. 


MR. GRIFFON: But those are two cases that 


you tracked, right? I mean, that was looking 


for patterns or systemic, was it? 


MR. LITTLE: The data that Frank was talking 


about where we did the histograms came from 


the, essentially, I think the dose 


reconstruction database. I don’t know if you 


call that CEDR or not, but it’s a summary of 


all the data that’s in all the claimant files, 


but it is quarterly data. Now there is also 


in there some cyclic data as fine as weekly, 


and there’s a bunch of annual data. 


But this we tried to do a summary of 


some of that and put it into histogram form so 


that we could cut these histograms on a finer 


scale. And what we found was that the data 


got all coded the same way so there’s a huge 


amount of manipulation that has to go on to 


get the data to the point where I’m looking at 


all the same thing. 


In other words there may be a 


different, for example, in one case it might 


be week one, week two, week three would be the 


identifier for the data. That’s a weekly 

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badge. In another one it might be one-one, 69 


though 1769. It’s a text identifier that just 


makes it very hard to sort out without a lot 


of manual effort. 


DR. ULSH: And I think at the end of the day 


the biggest problem is, let’s say we see this 


pattern. We see a tail off. We can’t really 


say whether that was because the individual 


was pulled out or because they left their 


badge in their locker. 


DR. MAURO: Oh, I agree with that, but if we 


find out that it’s not a very common 


occurrence where that circumstance arises, 


that in itself is an important piece of 


information. 


MR. GRIFFON: Right, I agree with that. But 


if, and I’m just not sure, Craig, what 


database were you, well, you’re referring to 


this dose reconstruction database, but is that 


the CEDR? I’m getting a little confused on 


what database this is. 


MR. LITTLE: ^ the main port so I can’t 


really give you, I don’t really know the 


answer. 


MR. GRIFFON: Right, okay, but this probably 

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-- the ACCESS databases that you’re going to 


post on the O drive for us, right? These ones 


we’ve discussed before. 


MR. LITTLE: And I don’t know the answer to 


that either. 


MR. GRIFFON: Okay. Brant, do you know? 


DR. ULSH: I’m sorry, Mark, can you repeat 


that? What was the question? 


MR. GRIFFON: I’m just trying to figure 


which database, I’m not clear which database 


you were working from for this analysis. 


DR. ULSH: I think it was just claimant data 


that we had. I don’t know, Mark, because we 


kind of concluded that it wasn’t going to be 


that useful so I didn’t really focus too much 


on it. Why don’t I -- how about this? I will 


get together with Craig and Jim and maybe Ken 


and see how feasible it might be for us to 


look at some selected workers in the post-’76, 


post-’76 timeframe. And these are 


contemporary workers making these allegations 


so that might be the right timeframe. 


MR. GRIFFON: That would be from the HIS-20 


stuff, right? 


DR. ULSH: That would be from HIS-20. We’ll 

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see what we can do about conducting, I don’t 


know. I just have to, we’ll have to talk 


about it and see what it would take to do it. 


MR. GRIFFON: Okay, I guess that’s as far as 


we can go with that one. I’m going to leave 


that as sort of an outstanding action. 


MR. FITZGERALD: Can we summarize the 


action? It sounds like we have perhaps three 


different tracks of review. Certainly NIOSH 


has two, one being the systemic one we just 


covered. Another one being the contacts with 


DOE, Kaiser-Hill and basically trying to run 


down the issues that was. And then, of 


course, we’re looking at data, logbooks, and 


trying to corroborate through documentation 


which may have the data to speak to us in a 


way on separate cases. Is that a fair 


characterization? There’s basically three 


paths of follow up? 


MR. GRIFFON: And, what, I understood every 


one except the second one, Joe. What follow-


up with Kaiser-Hill? 


MR. FITZGERALD: Well, this is the one that 


I think Brant was referring to where he went 


to Tony, and Tony referenced these 

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investigations that were going on, and I guess 


eventually ended up with Kaiser-Hill and DOE 


trying to get additional information which has 


not been forthcoming yet. 


MR. GRIFFON: Those investigations, were 


they tied to the no data available-type of 


claim or were they different claims? 


DR. ULSH: I don’t know, Mark, because we 


haven’t really got, I haven’t heard the 


specifics from Tony, and I haven’t been able 


to get in touch with the DOE people yet or the 


Kaiser-Hill people. 


MR. GRIFFON: I don’t really know that under 


the past action items, but I agree with the, 


at least those other two that, the 


investigation of the systemic review, SC&A has 


continued to look for the field data. And I 


think that there’s also an action for NIOSH to 


check specific cases where available. And 


some of those come out in actions below this 


in the matrix. 


MR. FITZGERALD: But all of it comes out 


here. I guess that’s why. It sounds like 


your pursuit through Tony to Kaiser and DOE is 


looking at particular cases, Brant? 

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DR. ULSH: I believe so. I hope so. That’s 


what we asked Tony for so I hope that’s what 


he’s got in mind. 


MR. GRIFFON: Okay, so maybe that is in 


there, okay. 


DR. MAURO: Mark, this is John. I think 


from SC&A’s perspective, we’ve run this I 


think as far as we could. I know that some 


additional material might be coming in to 


Kathy DeMers, but Kathy, I guess I’d pose a 


question to you. Are we at a point where we 


really are passing off the baton? This is as 


far as we were able to take it in order to get 


documents to discuss these matters with some 


of the petitioners, and you’ve documented very 


nicely in your April 5th trip report. Are we 


at a point now where we’re really, have done 


what we can do or do you, Joe and Kathy, do 


you envision there are more things that is 


appropriate for us to do at this point? 


MS. DeMERS: I think that we need to pull 


the logbooks that I requested and the files, 


and I’ve spent a lot of time talking to 


individuals who have provided affidavits in 


the SEC petition and for NIOSH to go back and 

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do that. They would also have to potentially 


start over in that process. 


MR. GRIFFON: Kathy, did you, I’m sure you 


did, but I don’t know if you provided that in 


your trip report that sort of interview notes 


with those individuals that you talked to? 


MS. DeMERS: I integrated them into the 


answers, but the interview notes are not 


complete --


MR. GRIFFON: Because I wonder if you 


received these items you requested, I think I 


agree with John, is that you’ve sort of 


uncovered some questions. You’ve pulled the 


string on this a bit, but essentially I think 


it’s NIOSH’s role to investigate further. You 


know, SC&A’s in the position of providing the 


review of NIOSH’s products. 


So is that sort of where you’re going, 


John, with this? 


DR. MAURO: Exactly, in other words, if Joe 


and Kathy are at a point where, well, there 


are a few more things that are sort in the 


pipeline right now, might as well let that 


come to closure. But at that point I think we 


stop and just communicate, this is where we 

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are, this is what we have --


MR. GRIFFON: And provide the materials to 


NIOSH, right. 


DR. MAURO: -- this is what we envision 


might be good follow up, and then we just 


leave it with the working group. 


MR. GRIFFON: I agree, or and provide those 


materials to NIOSH. 


DR. MAURO: Exactly. 


MR. FITZGERALD: Now the only dilemma, just 


since we’re on the subject, I think both NIOSH 


and SC&A are both waiting for things that we 


don’t necessarily control in terms of access 


and timing. I suspect we will get what we 


want from DOE, but I can’t say when and that’s 


the only issue. Certainly, how far does one 


go and how long does one wait. And we 


certainly don’t know how long that’s going to 


take. So I think we both, NIOSH and SC&A, 


have similar issues, at least in that regard. 


DR. MAKHIJANI: This is Arjun. Kathy, are 


there documents you’ve gotten in the last week 


that might kind of exemplify some of the 


issues a little bit farther? 


MS. DeMERS: From the standpoint of --

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183 

DR. MAKHIJANI: From the standpoint of, you 


know, whether there were pressures at the 


plant of the type that the petitioners are 


talking about to alter the data, you know, to 


promote production or for other reasons, or 


whether any of the documents show some of that 


or don’t? 


MS. DeMERS: I actually have a statement 


that I wanted to read that I was saving for 


later, but it kind of shows or it creates 


questions about how important ^ was over 


production and what it is is the Atomic Energy 


Commission has issued a letter. 


COURT REPORTER: Kathy, I’m sorry, this is 


Ray. I’m getting a real bad noise out of your 


reception. I don’t know if it’s just me or 


what. 


MS. MUNN: It’s not just you. 


MR. GRIFFON: And I can hardly hear you. 


COURT REPORTER: Yeah, it’s hard to hear 


you. 


MS. DeMERS: Can you hear me now? 


COURT REPORTER: Well, you’re louder, but 


that noise is still in the background. 


MR. GRIFFON: Are you on speaker or not? 

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MS. DeMERS: No, I’m on. 

MR. GRIFFON: Is it bearable, Ray? Or can 

you... 

COURT REPORTER: Yeah, if, Kathy, I hate to 


ask you, but you’ll just speak as loudly as 


possible, that’ll help. 


MS. DeMERS: Or I could try and call back 


in. 


COURT REPORTER: I don’t know what’s going 


on. It sounds like there’s a big machine 


behind you. 


MS. MUNN: It may not be her line. I heard 


it when she was not speaking. 


COURT REPORTER: Oh, did you? Okay. 


DR. WADE: Well, why don’t we just try, 


Kathy, if you could speak loudly and let’s see 


how we do. 


MS. DeMERS: Okay, there was a letter issued 


from the Atomic Energy Commission to the union 


March 3rd, 1970. And there were several items 


that were listed in this memo, but what I 


wanted to bring your attention to was an item 


about the TLD dosimeter. And this reads, “The 


new thermoluminescent dosimeter, TLD, 


personnel badge for neutrons is an excellent 

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one, but it will not be put into use because 


(a) it is too expensive, and (b) the more 


accurate reading from this new dosimeter will 


pose a radiation exposure control problem 


which could close down certain operations and 


Production will object.” 


Now obviously, they went on and they 


implement TLDs in several buildings and then 


eventually spread out from there. But I guess 


the question is what does this statement mean 


with respect to questions on work practices 


and dosimeter assignments? Are you still 


there? 


DR. WADE: Yes, go ahead. 


MR. GRIFFON: We’re still here but we just 


have a -- They’re very challenging calls, 


aren’t they? 


DR. WADE: It’ll stop in a minute. 


MS. DeMERS: And this --


MR. GRIFFON: What timeframe did that say, 


Kathy, if I can ask you again? 


MS. DeMERS: March 30th, 1970. 


DR. ULSH: This is Brant Ulsh. First of all 


I’d like to see a copy of that. If you could 


send that over to us, Kathy, that’d be great. 

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We’d like to review it. Second point is that 


in 1969 and ’70, they did, in fact, institute 


the TLDs in ’71 for neutron. I really can’t 


comment any further because I don’t have the 


letter in front of me, but I’d sure like to 


see it. 


MS. DeMERS: Okay. 


DR. ULSH: And I guess that’s all I can say 


at the moment. 


MR. SMITH: This is Matt Smith in Richland. 


I helped set the job for the future. I know 


Jack Fix is not available right now because 


he’s talking with other OCAS members, but you 


know, he wouldn’t ^ from a Hanford perspective 


and likewise the ^, the historical things that 


went on across the complex at this time. And 


Brant, I recommend at some point we interface 


with Jack on that a little bit. 


DR. ULSH: Okay. 


DR. MAKHIJANI: This is Arjun. The thing 


that this call kind of brings up is the 


question, you know, in a way it’s a question 


of whether you believe what’s on the paper or 


whether there’s more to what the workers are 


saying in their statements and affidavits. 

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And what this seems to indicate is that there 


were production pressures and, you know, how 


those production pressures actually ^ and what 


was entered into the dose records --


DR. WADE: Larry, we can hear you talking. 


DR. MAKHIJANI: But it certainly raises the 


question beyond statements and the affidavits. 


DR. ULSH: Okay, but I think we have to 


focus on how is this, how does this relate to 


the SEC question, and that is if you contend 


that there were production pressures and the 


contention is that that might have compromised 


safety, that still doesn’t demonstrate that 


NIOSH cannot conduct dose reconstructions with 


sufficient accuracy. 


MR. GRIFFON: It goes to the reliability of 


the external dose measurement, I guess. 


DR. ULSH: It only goes to the reliability 


of the external dose measurement if evidence 


is presented or discovered that shows that 


there was some falsification by the dosimetry 


personnel or -- I don’t know. 


MS. DeMERS: Let me add one other thing. I 


don’t know if you’re aware of this but those 


working in the plutonium area were given 

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additional pay. 


MS. MUNN: That was common. 


MR. GRIFFON: Yeah, we heard that, yeah. 


I guess, Brant, I mean, I think I’m 


with you, Brant, on the fact that we need to 


see this memo. And I think I’ll go back to 


John’s original proposal which was if Kathy, 


if you and Joe can sort of roll up what you 


found into a mini-report I guess I’d call it, 


and any, and also forward any additional 


materials to NIOSH and the Board on this 


related to this topic, then we can go from 


there. 


I mean, it’s hard to sort of comment 


on a memo that we’re, I think we need to look 


into that more, and maybe if you can provide, 


and then I think, as John was suggesting, I 


think it’s appropriate that you’ve identified 


some things. It’s up to NIOSH to follow up on 


or respond to. Does that make sense? 


DR. ULSH: I’d like a clarification. If 


there are action items here for NIOSH other 


than -- let’s see, I think we were going to 


check out the plausibility of doing a 


statistical analysis on the post-’76 data from 

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HIS-20. 


MR. GRIFFON: Right. 


DR. ULSH: Is there another action item 


here? 


MR. GRIFFON: The only other action item I 


have outstanding which is that you’ll track 


specific no-data-available cases, but that was 


sort of, it’s not stated in the matrix, but 


it’s stated later in the matrix. That was 


sort of, you know, where possible was the 


underlying construct of that. And then to 


review the database for systemic. And that’s 


what you’re saying. You’re going to do post­

’76 now. But the other action I’m adding to 


this matrix item is that SC&A has conducted 


interviews with some individuals at the site 


and has recovered some additional materials, 


logbooks, et cetera, pertinent to the topic 


and will provide a report and materials to the 


Board and NIOSH. 


DR. ULSH: Okay, so is this the thousand or 


so pages, Kathy, that we’re talking about? 


MR. GRIFFON: I don’t know how extensive 


this is. Did she say? 


MS. DeMERS: With respect of tracking down 

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back to the secondary records? 


DR. ULSH: Let me look here. I thought that 


at some point you said you identified a lot of 


records. They were being shipped. Yeah, here 


it is. On page 41 in your response back 


there, I’m sorry, your comment, it says that 


as previously mentioned approximately 1,000 


records are being shipped to SC&A and required 


review. Are we talking about the same 


material here? 


MS. DeMERS: I think we’re talking about the 


secondary field records. The records that 


have not been pulled yet. 


MR. GRIFFON: Right, but what are these 


secondary field records related to? These are 


the logbooks? What are these records? 


MS. DeMERS: These are logbooks which 


correspond with time periods when an 


individual is on a particular project that 


allegedly contains information on personnel 


dose. 


DR. ULSH: Is this material that SC&A has 


asked DOE for, and they have not received it 


yet and they will be receiving it in the 


future? 

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MS. DeMERS: This is material that I 


requested that they pull. And when I was 


there, they had not pulled it. There is also 


material that I copied while I was at Rocky 


Flats, and that is still sitting at Rocky 


Flats. There’s probably a records box full. 


MR. GRIFFON: I guess what I’m trying to get 


a handle around is is there some sort of, you 


know, summary conclusion that SC&A can come 


to? And I’m not saying right here this minute 


on the call. But if there’s some point short 


of just waiting for all the records to come 


from DOE because I have the same concern that 


Joe mentioned with that. That that’s sort of 


an indefinite timeline, but based on your 


field interviews and some data that you were 


able to look at, we’ve got the following 


concerns on this issue. I mean, is there some 


way that SC&A can put together a report like 


that in short order, and then say, in addition 


to that say we’ve also requested further 


documentation including the following items 


which are still outstanding? 


MS. DeMERS: I can certainly pull together 


my concerns and the roadmap that I was going 

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to follow. Have all those records been 


pulled? 


MR. GRIFFON: Because I think that’s 


important because it may be that if you boil 


this down to an issue, Brant and the NIOSH 


team may look at it and say, we think we’ve 


addressed this already, and here’s why, you 


know, as opposed to just everybody just 


sitting and waiting for further records to be 


pulled. I just want to make sure that we know 


what all this is leading to maybe. You can’t 


tell until you have all the data, too. 


DR. MAURO: Mark, the only concern I have is 


to clarify this thing a little bit more is I 


think Brant and his folks have done a good job 


of following this thing along with the issueby-issue analysis, and I understand frankly 


the position that I’m reading which is we have 


not provided anything singular or new or 


sufficiently compelling to change the 


position, I think, that NIOSH has taken. And 


at this point I would agree that that stuff, a 


lot of the material should be ^. 


So the question I would have is in 


order to establish whether there’s anything 

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compelling on this particular issue, we almost 


would be relying on some of the information 


which is forthcoming. And my only concern, I 


expressed it before, it’s not clear since we 


don’t control DOE processes and stuff, how 


soon we could expect to have it and whether it 


would be in time to provide the Board the 


analysis you’re talking about. 


I’m just trying to put this on the 


table because I think that’s kind of where 


we’re at. That Kathy’s done a great job of 


identifying what’s there and what should be 


looked at, but the logistics of getting it and 


looking at it, if, in fact, we’re in real time 


now, is a big concern. 


MR. GRIFFON: Is any of this classified? Is 


it going to classification review? Is that 


part of the delay? 


MS. DeMERS: No, there has been no 


indication that it’s classified. 


MR. GRIFFON: It’s just a matter of shipping 


the box, or is it a matter of the contents of 


the box? 


MS. DeMERS: There’s really two separate 


issues. Rocky Flats needs to ship the boxes, 

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the box of information that I copied while I 


was there, but that’s one situation. And then 


there’s an issue where we need to pull the ^ 


they request and the dosimetry logs, and you’d 


have to get them copied. 


MR. GRIFFON: Who’s we? I mean, is that, 


did you leave specific logbooks that you 


wanted copied and they just have to do it for 


you? 


MS. DeMERS: No, they have not pulled them 


yet. 


MR. GRIFFON: But have you identified the 


specific ones that you --


MS. DeMERS: Yes. 


MR. GRIFFON: -- would like, or you have to 


-- you have? 


MS. DeMERS: Yes. 


DR. MAURO: Kathy, this is John --


MR. GRIFFON: It may be something that NIOSH 


can help facilitate as well. 


DR. MAURO: As a point of clarification, I’m 


looking at your Rocky Flats interview and 


records review report that was sent out under 


Joe’s signature on April 5th . There’s a Table 


1 in there that appears to list a number of 

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documents, goes on for a couple of pages. And 


it appears that, am I correct that that list 


of documents, as far as you can tell on the 


list of documents that you think need to be 


obtained and reviewed, or is there more than 


that? 


MS. DeMERS: There are, I think I would 


narrow that list down a little bit, and we 


also need to pull the logbooks from Building 


779 for a period. 


DR. MAURO: I think the thing that would be 


helpful is if we could have a very crisp 


recommendation in effect based on your site 


visit. What I’m hearing is you have 


identified a number of documents that you 


think might be important. I think that list, 


and basically our recommendations regarding, 


to the working group should be provided to the 


working group as a recommendation for follow 


up. That this material may contain 


information that will help to bring closure to 


the data reliability issue. 


MR. GRIFFON: I guess that’s what I’m asking 


for, John, a report and recommendation and why 


you believe it’s important to this issue. 

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DR. MAURO: And I think we’re close to it 


because in looking at the minutes of the site 


visit, it looks like a lot of that material is 


there. It maybe just a matter of repackaging 


it in a way as almost like a recommendation to 


the working group and of course to NIOSH that 


perhaps they may want to look into this, 


perhaps meet with certain individuals. 


In other words, the way I see this is 


in the end it’s going to be data reliability 


and the trust that the petitioners have that 


we have tried, you know, turned over every 


rock possible. We’re where the credibility of 


this process is going to lie. And it seems to 


me that Kathy is saying to us there’s an awful 


lot of stuff we still have to do. 


And when I say we, I guess I really 


mean NIOSH, that she has uncovered as a result 


of that visit. If NIOSH has already done that 


or if that’s well underway, all well and good. 


However, I think we owe it to the working 


group and NIOSH to communicate this clearly, 


some of the things that we found out and the 


actions that we think would really benefit the 


process. 

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DR. ULSH: And, John, I would add to that if 


this report relies on documentation that 


you’ve uncovered that we don’t have, if you 


could provide that with the report so that we 


can evaluate it that would be --


DR. MAURO: Absolutely. 


MR. GRIFFON: I think that’s --


MR. ELLIOTT: This is Larry Elliott. I 


agree with your comments there, John. And if 


in that crisp conclusionary summary if we can 


have a better sense of what the concerns are 


related to regarding data reliability, maybe 


that will help us determine if we’ve already 


seen the information or if we need to go out 


there and perhaps look at this box before it’s 


transferred to Kathy, wherever she’s asked for 


it to be sent. 


DR. NETON: Yeah, this is Jim Neton. I’d 


like to make a follow up. 


MR. ELLIOTT: No, I just think if we can get 


a better understanding of what aspect of data 


reliability, this information might reflect 


upon, that would enable us to do a better jot 


as well. 


DR. NETON: Larry, that’s exactly what I was 

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going to say. This is Jim Neton. We need to 


have a good sense as to what these shift logs 


and whatnot are believed to contain that will 


shed light on these issues because I frankly 


have looked at a number of such logs, and I 


think I can’t make the connection. And I’m at 


a loss, so it would be interesting if they 


summarize that very precisely in the analysis 


as to what light is going to be shed on these 


issues with these data. 


MS. DeMERS: May I make a suggestion? If we 


pass the torch to NIOSH that they actively 


allow the petitioners to be involved in the 


process. 


MR. GRIFFON: I think first you need a crisp 


recommendation. 


MS. DeMERS: Yeah, I realize that. 


MR. GRIFFON: And NIOSH has to decide 


whether they’re going to pick up the torch 


sort of. I mean, I think that’s what you’re 


saying, Jim and Larry, right? 


DR. NETON: Yeah. 


MR. ELLIOTT: Yes. 


MR. GRIFFON: Let’s weigh this first and 


make an argument to the work group and NIOSH, 

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and I would say within the next several days 


we’d like to see that sort of argument, John, 


if you can pull up a brief, crisp report on 


this within the next several days. Then we 


have to make a decision on path forward here 


certainly in the near future. 


DR. MAURO: In my mind this is, on the Rocky 


Flats petition, this is the highest priority, 


that we get this material to you in the right 


form so that you folks can make the judgments 


you need to make going forward. 


MR. GRIFFON: And as Jim said, if it’s 


related to data reliability, what specifics 


of, what specific aspects of data reliability 


I guess. Is it the no data available issue? 


Is it the, you know, is it only focused on 


that or is it broader than that. You know, 


you can describe that in your report. Is that 


fair? Can we move past that one at this 


point? 


MS. DeMERS: Yes. 


MS. MUNN: It’s hard to imagine what data is 


likely to be gleaned from these documents that 


would substantiate the concerns many of the 


claimants have with respect to falsification 

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of data. 


MR. GRIFFON: Well, that what, yeah, and 


maybe it’s other areas of data reliability 


that they want to get at. 


MS. MUNN: That’s really the bottom line, 


isn’t it? Is there anything that 


substantiates those claims? 


DR. MAURO: Wanda, this is John. I’d like 


to take that a step further. I think the very 


process of doing this and interfacing with the 


individuals that have expressed this concern, 


have given us the information that there might 


be something important there in these 


documents. That in itself is an important 


part of the process. 


It may turn out that after we go 


through this process, and it looks like a list 


of perhaps 20 documents and perhaps a thousand 


more pages altogether. I think when we go 


through that process itself, the process 


itself is going to lend credibility, and we 


may very well uncover important information. 


But I think there’s no choice but to go 


through the process. 


MS. MUNN: Yeah, I think you’re probably 

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201 

correct as long as we are focused specifically 


on charges that have been made or plans that 


have been made and not try to prove a 


negative. That’s almost impossible to do. 


MR. GRIFFON: Okay, I think we, let’s move 


on to 13. I think there’s a couple other 


actions that are similar to this number 12, 


too, but let’s go on to 13 and try and work 


our way through the matrix before we run out 


of time in the day here. 


MR. PRESLEY: Hey, Mark, Bob Presley. I’ve 


been back on for about an hour. 


MR. GRIFFON: Hi, Bob. 


MS. MUNN: Welcome back. Yes, it seems to 


me that all those items on the next page, 13, 


14, 15 are all sort of a, they’re all sort of 


in the same box as 12, aren’t they? 


MR. GRIFFON: Several of them relate, yes, 


although a couple are very specific. Let’s 


just walk through them and hopefully they’ll 


go faster than 12 in most cases. 


Brant, number 13. 


DR. ULSH: Yes, number 13 corresponds to I 


guess the SC&A comment that starts on page 


seven of the 5 April responses. And SC&A’s 

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expanded on their previous comment on page 


eight there. And our response is at the 


bottom of page eight. Basically, in our 


previous response we said that since instances 


where badges were missing, crystals were 


investigated, we contend that this does not 


prevent NIOSH from performing dose 


reconstructions with sufficient accuracy. 


We don’t see anything in the new 


expansion that would make us reconsider that. 


In fact, the logbooks actually show places 


where badges were processed that had missing 


crystals. I’m sorry, the excerpts of the 


logbooks, so that offers material support for 


what we said, and it was that at the time of 


the reading, the badges were sometimes missing 


crystals or contained damaged or contaminated 


crystals. SC&A has questioned the meaning of 


no crystal in the logbook, but --


MS. DeMERS: Well, that was a quote. 


DR. ULSH: A quote? 


MS. DeMERS: Yeah, from the logbook. 


DR. ULSH: Yes, in the logbooks there are, 


at least in the excerpts that were provided 


back on page four and five, I believe -- well, 

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I don’t know. I’m looking now and I don’t see 


anything that says no crystal, but let’s say 


that -- I don’t know. 


Okay, I think it’s fair to say that no 


crystals probably did appear in a logbook 


somewhere and that would seem to us to 


indicate that a crystal was missing. I don’t 


know. 


MR. GRIFFON: But you’re still saying that 


wouldn’t preclude you from --


DR. ULSH: Exactly. 


MS. DeMERS: I guess my concern is, yes, 


there are other logbooks that say, quote, no 


crystals, unquote. My concern is in reviewing 


several files I’m not seeing a dosimetry 


investigation form in those files. And what 


would be useful is if you took those problem 


dosimeters and followed through to make sure 


that that dosimetry investigation is in the 


files and is being provided to NIOSH. 


DR. ULSH: I’m not certain that in instances 


where a crystal was missing, that you would 


find an investigation report in the claimant’s 


file because what would occur is that they 


would calculate a dose from the other crystals 

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that were in the badge as shown the excerpt of 


your logbook here. 


MR. GRIFFON: Brant, I don’t disagree with 


what you just said, but your response says 


that these situations were investigated if you 


look in the matrix. Your previous response 


says it. I would tend to think that that 


might not require an investigation, whereas 


number 14 where you might have an elevated 


one, that would be more of an investigation 


situation. 


DR. ULSH: Yeah. 


MR. GRIFFON: I don’t know if you want to, 


you know. 


MS. DeMERS: There are several issues that 


are listed in the logbooks. It’s not just 


missing crystals. What do you do in the case 


of bad crystals? What do you do when the 


crystals are switched? And all I’m wondering 


is have you gone and verified that these 


dosimetry investigation forms are in files of 


individuals that have dosimeter issues? 


MR. LANGSTED: This is Jim Langsted. And 


you have to look at the periods of time here 


that we’re talking about. The procedures that 

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are quoted here are procedures from the mid­

‘90s, and from 1990 on, the whole DOE-nuclear 


industry became much more proceduralized than 


it was in the previous years. The logbooks 


that were looking at here are from the mid­

‘80s, and there was not that level of 


proceduralization and documentation. It’s 


unlikely that you will find any sort of report 


in the worker’s file resolving that crystal. 


MR. GRIFFON: Well then, Jim, I think you’re 


answering the follow-up faction because I had 


asked in the previous work group whether, at 


the bottom of the matrix, NIOSH will determine 


if a similar procedure existed for earlier 


time periods. 


MR. LANGSTED: And what we did find, Mark, 


was in the mid-‘80s there was a procedure. It 


was one of the first procedures I recall that 


were written formally on running the dosimetry 


operation. And it did talk about if you had 


dosimetry problems, take that issue to the 


supervisor. But that was about it, and how it 


was resolved was not formalized. 


MR. GRIFFON: Do you have a procedure number 


for that or any reference for that? 

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MR. LANGSTED: The procedure is Lincoln 


Pennock^ 1983, and if you want the complete 


citation, Mark, it’s on page ten of the 


comment responses, a caption to the figure. 


MR. GRIFFON: And so that’s mid-‘80s and 


prior to that you haven’t found anything prior 


to that probably. 


MR. LANGSTED: No, there were not procedures 


that we have located previous to that. 


MR. GRIFFON: Is there any follow up on this 


beyond what we’ve discussed to this point? 


Kathy or John? 


DR. MAURO: It sounds like we have the 


answer. The answer is that prior to a certain 


data that kind of follow up is not possible. 


DR. ULSH: I think that what we’re saying is 


prior to that date we don’t have procedures 


that document that. These were more 


procedures that were followed but not 


necessarily written down anywhere. 


DR. MAURO: So am I hearing that if we were 


to pull the string on some of these, we might 


very well find documentation prior to the date 


of those procedures? 


DR. ULSH: I doubt that you would find 

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207 

documentation. You might find it in the later 


years. After 1990 you could maybe find it. 


MR. GRIFFON: And guess to be specific here, 


I think the allegations were related to later 


years. Am I correct in that or am I, I’m 


going by memory here. But I think the 


allegations of chips fell out was made by an 


individual that was talking, were they talking 


about the ‘80s, the ‘70s, the ‘90s? 


MS. DeMERS: ‘Eighties. 


MR. GRIFFON: It was the ‘80s. 


DR. BEHLING: Yes, this is Hans. I would 


imagine that the chip issue falling out 


probably predates the use of Panasonic 802 


badge where you don’t really remove the, the 


TLD itself. It’s a sealed package and so the 


issue of chips falling out and being misplaced 


or handled with the issue of hands and hair 


and oils is probably something that dates back 


to the TLD systems. 


MR. GRIFFON: And is there a timeframe on 


that, Hans? Or actually Rocky specific? Do 


we know that? 


DR. BEHLING: I think I have to look at the 

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DR. ULSH: We’ve got it. 


DR. BEHLING: -- to determine when the 


switch over was to the more current Panasonic 


system. 


MR. GRIFFON: Jim probably can answer that, 


right? 


MR. LANGSTED: Nineteen sixty-nine through 


1983 were the loose chip TLD years. And 


that’s the period we’re talking about here in 


terms of contaminated chips and/or loose or 


lost individual chips. 


DR. BEHLING: And on the issue of the oil 


and hair, again I’m not so sure. Obviously, 


I’m familiar with the old TLD system where you 


handled it with forceps that are clean, but 


even there I’m not sure to what extent, for 


instance, body oils would introduce a false 


positive in the glow curve that would be 


misread as a false exposure. I’d have to go 


back and look at that as an issue. 


MR. LANGSTED: Yeah, our experience was that 


that would happen. And remember in those days 


we were not collecting glow curves. We were 


just integrating the charge on the instrument 


and reading it so you wouldn’t see the 

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difference in the shape of the curve. The 


chips were typically handled with forceps, and 


they were typically washed in alcohol prior 


to, each one was dipped in alcohol prior to 


being read to reduce this problem, but --


DR. ULSH: And that’s documented in Lincoln 


Pennock 1983, the procedure for cleaning 


chips. 


MR. GRIFFON: And that’s in 1983, and after 


that they really wouldn’t have used those 


types of badges you’re saying as of 1984. 


MR. LANGSTED: Yeah, ’83 was the start of 


the change over to Panasonic and that was a 


much more automated, less handled system with 


glow curves. 


DR. BEHLING: Yes, and then I’m very 


familiar with Panasonic system. Those issues 


are addressed in items 14 and 15 would 


probably not even be an issue. 


MR. GRIFFON: So I don’t know that, this 


question’s really been answered especially, 


you know, the preliminary matrix I have 


references the procedure that was in the late 


‘80s I think or early ‘90s. And then you’re 


saying this other procedure’s in ’83 and the 

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time period of concern is ’69 to ’83. 


DR. ULSH: Mark, the practices were 


implemented at the onset, but they weren’t 


formally, we haven’t located any formalized 


procedures prior to that, and we’re pretty 


skeptical about whether anything like that 


exists. I can’t -- So I don’t know. I think 


we’ve pulled the string as far as we can on 


this. 


MR. GRIFFON: Right. And we don’t, other 


than, yeah, I don’t know that we would be able 


to without logbooks, crosswalk any specific 


situation such as this. And even with 


logbooks if there was a recorded dose, you 


would expect that from the other chips, right, 


if you only lost one chip out of the --


DR. ULSH: That’s correct. 


MR. GRIFFON: Can we take this anywhere, 


SC&A, any follow up on this? 


MS. DeMERS: I think it would be worth it to 


follow up on a couple of people who had issues 


with their TLD chip and find out what kind of 


dose they were assigned and how it was 


assigned. 


MR. GRIFFON: But I’m wondering how, I mean, 

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how would they know if they had issues with 


their chips, Kathy? I mean, it seems like the 


people who reported, alleged this were in the 


dosimetry and chip-reading area, weren’t they? 


MS. DeMERS: The documentation I put into my 


report, there are badge numbers. 


MR. GRIFFON: So there are some specifics 


that you believe can be crosswalked? 


MS. DeMERS: Yes. 


MR. GRIFFON: I don’t know where to take 


this. I guess if that possible because I’m 


still thinking that it was a multiple badge 


system and if they allege, and it was true, 


that that one chip was damaged or fell out and 


there was a dose recorded, that wouldn’t 


surprise me necessarily because they’ve got 


other chips to use. 


MS. DeMERS: I think the concern is not so 


much missing one chip but other issues and --


MR. GRIFFON: Such as? 


MS. DeMERS: Well, like the TLD reader. 


COURT REPORTER: Kathy, this is Ray again. 


I’m sorry. It’s just very difficult to hear 


you. I don’t meant to complain, but it is 


just kind of difficult. 

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MR. GRIFFON: To hear you. 


MS. DeMERS: There were several issues with 


the gases in the TLD reader. There were 


issues with crystals being swapped. This is 

just two pages of what I collected. I have 

several more. 

MR. GRIFFON: Well, I guess that to the 


extent, I mean, this says chips fell out of 


TLDs and reading were not included. I think 


we’re addressing that specific item here. If 


we could crosswalk those badges, and they have 


a recorded dose, I think that sort of puts 


that to rest. That specific issue. I’m not 


saying there’s not other issues, Kathy, but 


that specific one. 


MS. DeMERS: They’re concerned not about 


whether there’s actual measured dose there, 


but they’re concerned about the zeros. 


DR. ULSH: And it may very well be possible 


that the recorded dose would be zero if that’s 


what was determined from the other crystals in 


the badge. 


MR. GRIFFON: It could be so we may not have 


a conclusion on this, but if there’s several 


badges, I don’t know, that might be easy 

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enough to crosswalk. It may not be that easy. 


I don’t know, how difficult would that be to 


crosswalk in HIS-20. 


MR. PRESLEY: Mark, this is Bob. We have 


some coworker data on any of this stuff? 


MR. GRIFFON: Yeah, we do, but this is 


getting at the data reliability question, I 


guess, and the allegations of intentionally 


sort of not including data within the database 


and that sort of thing, Bob. But you’re 


right, they do have coworker approaches if 


they have gaps in data. But this is going 


back to the whole reliability of the data 


itself. 


MR. PRESLEY: Well, it still looks to me 


like that we ought to be able to come up with 


some, if somebody’s claiming they’ve got a 


data reliability, they’d go back and check the 


coworker data. 


MR. GRIFFON: Yeah, but I guess we’re kind 


of looking for if there are any systemic 


problems like this. You know, if it’s an 


isolated one, correct, and maybe use coworker 


data or whatever. But this is checking to see 


whether there was any sort of systemic issue 

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here. 


Is that possible to do the hit 


comparison on HIS-20 by badge number? Anybody 


know that? 


MR. LANGSTED: HIS-20 in this period would 


only have quarterly data, and if this badge 


was a monthly or a semi-monthly badge, it 


would be buried in there with others. 


MR. GRIFFON: Okay, I wasn’t sure if they’d 


have monthly or not. 


MR. LANGSTED: No, not in this period. No, 


wait. Wait, wait, wait. I’m sorry, this is 


’86. This would have been cycle-by-cycle 


data. My apologies. 


MR. GRIFFON: So to the extent possible I 


guess my sense is that we try to, again, this 


is a previous request, try to track some cases 


back to the extent possible. And if Kathy’s 


got specific badges where this is alleged, 


then can we get those badge numbers to NIOSH 


and have you try to crosswalk those. It seems 


like that would be a limited effort. 


MR. LANGSTED: Yes, if you’ve got the 


specifics that we can trace to badge, we can ­

-

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MR. GRIFFON: SC&A, you can provide those to 


NIOSH maybe via phone. I don’t know if you 


want to e-mail that sort of thing. Is that 


correct, John, John or Kathy? 


DR. MAURO: That’s a question for Kathy. 


Kathy, do you have that information 


for them? Can you release that information? 


 (no response) 


DR. MAURO: Sounds like Kathy’s not on the 


line. 


MS. DeMERS: I just got back. 


DR. MAURO: I’m sorry. We were asking, 


Kathy, if you’d be able to send out, provide 


the badge numbers to NIOSH in a way that 


maintains the privacy information? Are you 


free to disclose that information? 


MS. DeMERS: It’s general logbook 


information so it’s not a particular person. 


DR. MAURO: Oh. 


MR. GRIFFON: I thought you said you had 


badge numbers that were --


MS. DeMERS: Yeah, but it’s multiple badges 


on one page. And I would assume that we can 


ship it in the same way as any other Privacy 


Act information. 

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MR. GRIFFON: Okay, so we can get this to 


NIOSH and try, you know, NIOSH will make an 


attempt to crosswalk this with HIS-20 and look 


at this issue. We’re not talking hundreds, 


we’re talking what? How many badge, 


approximately how many cases, Kathy? How many 


badges, badge numbers? 


MS. DeMERS: Well, I gave you examples of 


two sheets. I actually have about 15. What I 


would do is take a sampling. 


MR. GRIFFON: Just take a sampling of that, 


so we’re talking maybe ten badges total at 


most, right? In the tens I would try to limit 


it to. 


MS. DeMERS: Yeah, I would do the same 


thing. 


MS. MUNN: Do you know whether our claimants 


have had their claims, the ones that are of 


most concern to you? 


MS. DeMERS: What do you mean? 


MS. MUNN: I mean have the claimants that 


you are most concerned with already had their 


claims processed? 


MS. DeMERS: Not all these people are 


claimants. 

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MS. MUNN: Okay. 


DR. MAURO: Kathy, this is John. Are we 


talking about -- let me ask the question very 


straightforward -- it sounds to me that you 


spoke to some folks face-to-face who don’t 


really trust the process, that the records for 


them as individuals, in their minds anyway, 


are questionable. And the very fact that you 


spoke to them and they provided you with some 


information, and you’re following up and 


looking into it, are we dealing with something 


that would be called as much technical as 


bedside manner? 


MS. DeMERS: Yeah. 


DR. MAURO: So in a way going through this 


process with them, and let’s say a similar 


process being pursued by NIOSH, this is going 


to add credibility. 


Let me ask NIOSH a question. To what 


extent have you, these individuals that are --


These are petitioners that are part of 


the SEC petition? Who are these folks you 


were talking to? 


MR. GRIFFON: Without saying names. 


DR. MAURO: Don’t give, but are these 

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workers? 


MS. DeMERS: I talked to individuals who 


gave statements in the petition. I talked to 


individuals who had knowledge in areas that we 


felt we had incomplete knowledge, for example, 


production people. I talked to the 


petitioners themselves. 


DR. MAURO: And that very same process is 


going on right now with NIOSH. It sounds like 


you folks have started a process like that. 


DR. ULSH: I’m not sure what you mean, John. 


I mean, we have been working with the 


petitioner throughout the SEC process. They 


participated in the working group meetings as 


you know. We’ve had contacts with Tony 


DeMaiori, and we’re following up on, well, we 


plan to follow up on specific instances that 


we might get from those conversations. That’s 


what we’ve done. 


DR. MAURO: You could see where I’m going 


with this. You know, there are individuals 


obviously are, don’t really believe or trust 


the process, but it sounds like these one-onone type of discussions and perhaps one-on-one 


types of follow-up investigations are going to 

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be important to these individuals. And I’ve a 


feeling that, I don’t know where it’s going to 


bring us and what we’ll find out, but the 


very, again, the process of going through this 


is going to help out in terms of later on 


whatever decisions are made, the fact that 


these kinds of one-on-one conversations 


happened is going to be very important. 


MR. GRIFFON: I think you’re right, John. 


It just adds credibility that we’re checking 


these specific allegations. We’re making an 


attempt the best we can to check these 


specific allegations. I think I agree with 


you on the credibility standpoint, for NIOSH’s 


credibility in this process and for all of our 


credibility in this process. 


MR. ELLIOTT: This is Larry Elliott. 


There’s no argument that this adds value from 


the perspective of the claimants and the 


workers at a given site. However, we operate 


here under a strict timeframe and trying to do 


the best that we can in that timeframe with 


limited resources. 


And we will chase down whatever leads 


that we are given, but we have to do so with 

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some judgment as to what the benefit and the 


potential outcome might be of doing so. So it 


would help us to know, specifically again, in 


very crisp terms, what this, what a particular 


lead might relate to a concern that we need to 


pursue. I can’t promise that we’re going to 


touch everybody who worked at that site who 


may feel that they were wronged. 


MR. GRIFFON: And I agree, Larry, that’s why 


I’m trying the best I can to distill down 


these actions that we have. I agree with you, 


Larry, and in this case where the chips fell 


out, issue number 13, I think if we have 


specific IDs that NIOSH can crosswalk against 


the database, that’s a very, and it does go to 


the question of reliability of the external 


dose data in a broader sense. So I think 


that’s --


MR. ELLIOTT: I certainly want to be able to 


give an explanation to claimants or to the 


petitioners who raise issues recognizing full 


well they might not agree with or like or 


explanation, but I do believe and agree with 


you. They are owed an explanation if we can 


possibly give it to them. But we have to do 

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that and strike a balance with all of the work 


that we have underway. 


MR. GRIFFON: I agree. 


Can we move on in the matrix? 


DR. ULSH: I think we’re up to number 15 in 


your matrix, Mark. Is that correct? Oh wait, 


14. 


MR. GRIFFON: Fourteen is very similar 


though I think, but --


DR. ULSH: That’s the hair and body oils. 


MR. ELLIOTT: Wait a minute. This is Larry 


Elliott again. I want to make sure on what is 


going to happen next on this last issue that 


was just discussed. Kathy is going to send us 


information relevant to certain badge numbers? 


MR. GRIFFON: Yes, and you’re going to 


compare it against HIS-20 for those specific 


time period badge number questions. 


MR. ELLIOTT: And these are 20 different 


individuals or just 20 different badge numbers 


that may represent a smaller number of 


individuals. 


MR. GRIFFON: Yeah, I don’t know exactly. 


Kathy, I asked Kathy to keep it in the tens of 


numbers of badges. 

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MS. DeMERS: What I’ll do is I will provide 


you with the sheets and then you can choose 


the individuals you want to pursue. 


MR. ELLIOTT: Let me just offer this. We’ll 


look at the sheet of information, but the 


outcome of that viewing of the sheet may be 


that we don’t see an issue there, and we’ll 


talk to the petitioner about that, what we 


see. But I don’t know that I’m ready to 


commit that we’re going to go pursue a number 


of individuals out in Denver and --


MR. GRIFFON: I don’t thing this requires 


interviewing people, Larry. That wasn’t my 


intent anyway. I mean this is to look at 


these --


MR. ELLIOTT: I do think we owe the 


petitioner an explanation here, but once we 


start going down individual badge results it 


concerns me that, you know, a number of 


interviews that would result from efforts is 


just too time consuming and perhaps too 


difficult to accomplish in the short timeframe 


we have. 


MR. GRIFFON: Yeah, right, I agree. No, 


this is to look at the potential, you know, 

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this is specific allegations and we have 


specifics that we can crosswalk. That’s what 


I figured. And it may be that it’s 


inconclusive what we find, but it may be that 


you have these alleged chips fell out for 14 


different badges or 14 different people, you 


look back at those records, those time periods 


of concern, and you find out there’s a value 


in their records. Then we may conclude that 


you read the other badge in the multiple badge 


chip badge. 


MR. ELLIOTT: Yeah, I agree. It’s hard --


MR. GRIFFON: -- crosswalk these but I don’t 


think any of us are asking for you to go back 


to each individual that Kathy interviewed or 


whatever. 

MR. ELLIOTT: Okay, I just wanted to be 

clear on that. 

MR. GRIFFON: Okay, number 14, Brant. 

DR. ULSH: Okay, number 14, that’s the hair 


and body oils on the TLD chips cause 


inaccurate readings. That is addressed in 


page nine of my comment responses. It’s 


labeled Data Integrity Comment Number 3. And 


what you see here is SC&A’s comment is that, 

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let’s see, they requested external dosimetry 


procedures from DOE but were not successful in 


getting those. And therefore, they could not 


determine how the dosimetry staff is told to 


handle the chips. 


And I would direct SC&A to ^ because I 


mentioned earlier that, at least for 1983, 


that is an example of the procedure that tells 


exactly how to handle chips and how to clean 


them prior to processing. And I think we’re 


going to stand by our previous response. I 


mean, there’s nothing that would make us 


change that at the moment. Again, I would 


offer that the excerpts of the logbooks do 


present examples that such instances were 


recorded, at least in these examples. I’d 


like to see the rest of the logbooks before I 


comment too strongly, but --


MR. GRIFFON: Now in this particular one, 


Brant, I would assume that these type of 


instances would have been investigated and 


you’re, you think that’s the case? 


DR. ULSH: It’s documented. But in the 


later years and the years that were covered by 


the later references, in ’83 though you 

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probably have the same kind of a situation as 


you would for a missing crystal. It would be 


maybe listed in a logbook as you can see from 


Kathy’s excerpts. I don’t know that you can 


say that an investigation report would have 


been placed into a worker’s file. Not in that 


period. 


MR. GRIFFON: That was, I lifted this from 


your previous response so that’s why I’m 


asking. 


DR. ULSH: Well, we weren’t --


MR. LANGSTED: It got a little mixed up 


there. 


DR. ULSH: I mean the timeframes weren’t 


specified so, and that’s probably imprecision 


on our part. We should have specified the 


timeframe we were talking about there. 


MR. GRIFFON: Okay, so we don’t necessarily, 


there wouldn’t necessarily have been any sort 


of investigation or any document in a person’s 


file for these in the earlier years anyway? 


DR. ULSH: Not for instances like that I 


don’t think. 


MR. GRIFFON: Any follow up on that? I 


don’t know that we have any specific items 

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that we can follow through on here on this 


particular, the hair and body oils claim. Any 


follow up from SC&A on that item? And I think 


we’ve taken that action item as far as we can 


go. 


DR. ULSH: I think there’s really only two 


possible outcomes here. One is that the badge 


would have read artificially high which would 


not, I think that would be claimant favorable. 


Or they recognized that there was a problem 


and they read the dose from the other 


crystals. In either case I don’t think we’ve 


got a problem here. 


MR. GRIFFON: John, Kathy, any follow up on 


that particular item? 


MS. DeMERS: I think that we’re all falling 


into the --


DR. BEHLING: Just a comment from me. This 


is Hans. I was very much involved in the 


dosimetry program and I was at Three-Mile 


Island, and we did our own processing and I 


can tell you there were very, very strict 


procedures in place that would clearly 


identify how to deal with aberrant reads and 


how to resolve those issues. So it’s a 

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question of are there any procedures available 


that you could look at or point to that would 


provide some reasonable explanation at to how 


these aberrant reads, whether they’re false 


positives or missing crystals or loose TLD 


powder within and including the dependence on 


the 802 system, how they were dealt with. If 


there are such procedures, that would be the 


answer to resolve this as an issue. 


DR. ULSH: Lincoln-Pennock 1983 and the two 


later documents that were referenced from the 


‘90s. That’s what we have available. 


MR. GRIFFON: And no earlier procedures that 


you could find, right, at this point? 


DR. ULSH: That’s correct, Mark. 


MR. GRIFFON: And again, this issue most 


likely would have been from the time period 


’69 to ’83 due to the multiple badge or the 


system where you had to have badges? 


MR. LANGSTED: What was the question, Mark? 


MR. GRIFFON: This would have primarily been 


an issue, if it was an issue at all, would 


have been, the time for it would have been ’69 


to ’83? 


DR. ULSH: Hair and body oils issue? 

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MR. GRIFFON: Yeah. 


DR. ULSH: Yes, I think that is true because 


after that you had an automated process that 


would involve less handling of the chip. 


MR. GRIFFON: I think we’re on to the next 


item. 


DR. ULSH: This is, in the matrix it’s 


number 15, deliberately false entries were 


made into dose records. There’s a charge of 


deliberate falsification. For instance, a 


worker alleges that a supervisor would advise 


to this other worker that the correct dose --


no, I’m sorry. Would advise the dosimeter 


worker that the dose shown was too high to be 


possibly correct. And the worker was advised 


to change or delete the reading. And there’s 


another instance cited where a worker alleges 


that zeros were entered into dose records when 


the TLD reader failed. 


Our original response was that both of 


these scenarios are, could have plausibly 


occurred and neither one constitute 


deliberately false entries made into dose 


records in and of themselves because as we’ve 


talked about, unexpected dosimeter reading 

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could result from a number of causes. 


Shall I wait for the busy signal to go 


away or just continue? 


DR. WADE: Just continue. 


MR. GRIFFON: Go ahead. 


DR. ULSH: Those include, first of all it 


could be a high personnel exposure. It could 


also be exposure to the dosimeter when it was 


worn by the assigned individual, a 


malfunctioning of malfunctioning reader 


equipment. That this is a later time from 


claims year where we reference the ‘90s. 


They provided, those procedures 


provided procedures for conducting this 


reconstruction in those cases. They were 


investigated. Absent evidence to the 


contrary, we’re going to stand by that. The 


petitioners expressed concerns about the 


reliability of the data, but to date we don’t 


have any evidence that would support 


deliberate falsification on the part of the 


dosimetry staff. 


MR. GRIFFON: In the matrix, Brant, we talk 


about you were going to follow up with a 


petitioner, was that the same follow up from 

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before? 


DR. ULSH: Right, that’s what we talked 


about earlier where Tony directed us to talk 


to Lisa Bressler. We did talk to her. She 


directed us to a few other people who we are 


continuing to talk with. 


MR. GRIFFON: I was going to ask, in the 


matrix, and I don’t recall from the petition, 


but it seems like these are quotes. I don’t 


know if they’re quotes from the petition or 


quotes from individuals. I wonder if you did 


any follow up interviews with the individuals 


that made these claims. I don’t know if it 


was I think Tony necessarily. 


DR. ULSH: I think the quotes came from the 


-- let me make sure that what I’m about to say 


is true. I guess I have to look back at the 


SC&A comment. 


MS. DeMERS: Some of those quotes are from 


NIOSH’s initial response. 


DR. ULSH: Okay, I think, Kathy, weren’t 


some of also from the affidavits? Isn’t that 


where we got these affidavits in the petition? 


MR. GRIFFON: Yeah, I forget --


DR. MAKHIJANI: You got it right, Brant. I 

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made that initial --


MR. GRIFFON: One says SEC petition Part A 


on page 57. 


DR. ULSH: Yeah, so those were, these issues 


were raised in the affidavits that were part 


of the petition. 


DR. MAKHIJANI: And the petition itself, 


also. 


MR. GRIFFON: Did NIOSH attempt to follow up 


by phone or anything with the individual that 


made the claim? 


DR. ULSH: No, we didn’t follow up by phone. 


We didn’t feel that it was necessary. 


MR. GRIFFON: Okay, as you say there’s 


strong charges. I just wondered if it --


DR. ULSH: I mean, we’ve been pursuing this 


with Tony DeMaiori I think is --


MR. GRIFFON: Okay. 


MS. DeMERS: Can I say something with 


respect to records access? It became very 


clear to me when I started talking to the 


petitioners that they didn’t have access to a 


lot of the records that they thought could 


substantiate their position. So they were at 


a decided disadvantage. Unlike us they can’t 

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go to DOE and say pull this record, this 


record, this record and have that done for 


them. 


DR. ULSH: That’s why we’re pursuing this 


track with Tony DeMaiori. Hopefully, he’ll be 


able to provide us some specific examples that 


we can track down. I mean, in the letter that 


I sent to Tony, I asked him to please provide 


any records that he had available, or 


alternatively, just provide us specifics that 


then we could chase down exactly for this 


reason. 


MR. GRIFFON: So this is similar to the 


other item and that’s where you stand is 


you’re still trying to follow up on that to 


the best you can with the officer and other 


site document people, right? 


DR. ULSH: Yes, that is correct, Mark. 


MR. GRIFFON: I think that’s as far as we 


can take that now. 


I might use the prerogative of a Chair 


now to, would it be a good time to take a 


little break? Just a short break. I know 


it’s getting close to the end of the day, but 


I don’t think we’re going to get through these 

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and the sample DRs without at least a short 


comfort break. 


DR. ULSH: Okay with us. 


MR. GRIFFON: Okay, can we limit it to five 


minutes? 


DR. WADE: Sure. 


MR. GRIFFON: Because I would like to try to 


wrap up before 5:00, so let’s limit it to five 


minutes, okay? 


(Whereupon, a break was taken and the 


meeting resumed.) 


MR. GRIFFON: Ready to go? 


DR. ULSH: Did we leave off starting with 


number 16 on the matrix, Mark? 


MR. GRIFFON: Yes. 


DR. ULSH: All right, this is unauthorized 


work practices. We had, in the matrix it says 


no further action required. However; SC&A has 


expanded on its comments. On page 17 of the 5 


April responses you see one, two, three, four, 


five bullets that we would like to talk about, 


I guess. The first is eating in the area 


although eating in the uranium area was 


allowed. This seems to keep coming up. We 


concede that eating in a radiation area might 

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conceivably result in an ingestion intake of 


radioactive materials; however, when you start 


from bioassay results as we do at Rocky Flats, 


universally claimant favorable, to assume that 


the material that you might detect in that 


urine was a result of inhalation intakes. 


Now I say almost universally. If 


there’s a situation where that would not be 


claimant favorable, where it would be claimant 


favorable to assume ingestion, we certainly 


have the ability to do that. It’s easy to do 


with IMBA, and that we’d work in the 


urinalysis results just like we would any 


other case. And then instead of putting the 


button on inhalation, we put it on ingestion. 


So I don’t see why this an SEC issue. 


MS. DeMERS: I guess what I was doing here 


is trying to clarify where the petitioners 


were coming from because it was not, I felt 


like the NIOSH response wasn’t getting to the 


real concern that the petitioners had. That 


was a clarification. 


DR. ULSH: So are we in agreement that this 


eating in radiation areas does not constitute 


an SEC issue, Mark? 

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MR. GRIFFON: I think so. We had closed it 


out before so I --


DR. ULSH: Well, there were a couple of 


other bullets. I mean that’s only one --


MS. DeMERS: There are some other issues. 


DR. ULSH: So let me walk through those. 


The second bullet was not using respiratory 


protection when required. And we’ve, our dose 


reconstructions don’t rely on any assumptions 


about respiratory protection. We’re starting 


with urinalysis data usually, so I mean, that 


doesn’t rely on any assumptions about 


respiratory protection. If they fail to wear 


it, they might have had a higher intake and 


that would be reflected in the urinalysis 


results. So again, we contend that this is 


not an SEC issue. 


Mark, do you have any thoughts on 


that? 


MR. GRIFFON: I agree. 


DR. ULSH: The next bullet is de-posting 


airborne areas for tours. And we would, hard 


to comment on that without specifics; however, 


a scenario could be envisioned where -- you’ve 


got to keep in mind the airborne areas require 

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posting only for as long as there’s airborne 


contamination and there was processes and 


machinery that generates airborne activity, if 


those are ceased, possibly when a tour is 


scheduled, then the need for posting might be 


mitigated. In any event, I don’t see how de-


posting radiation airborne areas for tours 


would compromise our ability to conduct dose 


reconstructions. 


MS. DeMERS: These issues were mainly 


brought up to clarify what the petitioners 


were trying to say. 


DR. ULSH: Well, since they were brought up, 


it’s our obligation to address them with 


regard to whether or not they constitute an 


SEC issue so that’s what I’m trying to do. 


And then the last one -- oh, no, no, 


not the last one. The next one is 


manipulation of dosimetry, and I don’t know. 


It’s not clear to me who we’re talking about 


doing the manipulating. If we’re talking 


about where workers deliberately sabotaged 


their own badge or tried to make it read 


different, read inaccurately. 


MS. DeMERS: Yes, that’s what we’re talking 

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about. 


DR. ULSH: Okay, again, I think the best 


answer I’m going to be able to give at this 


point is that we do have methods for detecting 


and dealing with some situations where this 


might have occurred. We do not contend that 


we can detect it in all such cases. We’re not 


making that contention. As the petitioner, 


Jennifer Thompson, I think it was, said in a 


previous working group meeting, these people 


were not stupid. I have no doubt that if a 


worker was sufficiently determined to make his 


badge read inaccurately, you could come up 


with a scenario where NIOSH would not have the 


ability to detect it. But in situations where 


this is pointed out or where we have evidence 


to suspect it, we do have methods to deal with 


it. And we talked about some other action 


items on other comments that we’re going to 


take. I don’t think I have anything to add to 


that at this point. 


I don’t know, Mark, how you want to 


categorize this one, but --


MR. GRIFFON: I think it’s complete. I 


mean, I --

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DR. ULSH: Well, we do have one more bullet 


and another thing. This next bullet is --


MR. GRIFFON: You’re right, you should go 


through them. I agree, for completeness. 


DR. ULSH: The next bullet, performing jobs 


without radiation monitor coverage. It may 


not have been a good idea but it’s not clear 


how a lack of radiation monitor coverage would 


compromise our ability to do dose 


reconstruction. 


MR. GRIFFON: Right, agree. 


MS. DeMERS: Some of these are just showing 


you that there were unauthorized practices 


going on and there are safety reports that 


were issued. 


DR. ULSH: We don’t take issue with that. 


Mark, I think that --


MR. GRIFFON: Yeah, I guess, you know, in 


that context I guess Kathy’s point is that 


often, I mean, there are some statements that 


imply that certain procedures existed then 


there’s no issue here. 


So I guess that’s what you’re saying, 


Kathy, is that there are, at least these are 


cases where they say that even though they 

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have procedures, they weren’t being followed, 


right? 


MS. DeMERS: Right. 


DR. MAURO: This is John. I think that your 


answers are excellent, and I think that if the 


petitioners were aware that though they may 


have observed and experienced this, and they 


understood that it really didn’t prevent you 


folks from doing the dose reconstructions, 


that’s an important message to send out. 


Now, a lot of the material you’re 


covering here would be very comforting, I 


believe, to the petitioners. Right now, of 


course, you have your evaluation report, but 


not very much of this material is in it. Is 


there any vehicle by which this type of 


material is going to be made available to the 


petitioners? 


DR. ULSH: I think we’re participating in 


that right now. The petitioner is invited to 


participate in this call. I don’t know if 


they’re on. 


MS. MINKS: This is Erin Minks calling from 


Senator Salazar’s office. We share that same 


concern is the way to best communicate the 

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deliberations you are all going through to 


constituents we continue to work with. 


MR. ELLIOTT: This is Larry Elliott. Well 


certainly these transcripts will be presented 


on our website, and we serve to respond to 


inquiries to our website or by phone or by 


mail on any point that is raised. 


MS. DeMERS: While you brought that up, 


Larry, can I ask that any names be taken out 


of my draft memo? 


MR. ELLIOTT: Kathy, I’m not aware that 


there are -- oh, no, wait. Are you talking 


about the memo that was sent out last week 


under Joe’s signature? 


MR. ELLIOTT: I’m not aware of any names in 


there, but I could be mistaken. 


MS. DeMERS: Well, there are a bunch of 


names in the first --


MR. ELLIOTT: Out on the website now? 


MS. DeMERS: -- paragraph. 


MR. ELLIOTT: Is that on the website now? 


UNIDENTIFIED: No. 


MR. ELLIOTT: I’m glad to hear it’s not on 


the website, but yes, if we put it on the 


website, Kathy, we would redact personal 

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identifiers. 


MS. DeMERS: I’d appreciate that. 


MR. ELLIOTT: Certainly. 


DR. ULSH: Mark, we had --


MR. GRIFFON: And the other thing, just to 


follow up on that, is that this memo or this 


April 5th, 2006, comment response, that would 


be part of what’s available to the petitioners 


as well, right Brant, so in terms of following 


up on these items? Is that true? 


DR. NETON: It’ll be on our website. 


DR. WADE: Yeah, this is Lew Wade. If any 


of the petitioners or the representatives have 


suggestions as to how we can better do this, 


we would certainly be appreciative of that 


information. I mean, we want to get the 


information out --


MR. GRIFFON: Trying to go through, 


obviously difficult to go through and find --


DR. NETON: And also I thought John Mauro 


had indicated earlier that the totality of all 


this information was going to be considered as 


part of the evaluation, of our evaluation 


report. And to that extent then these things 


would be mentioned at least and referenced 

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somehow. 


MR. GRIFFON: Right. 


DR. WADE: But the reality is that all that 


we’ve done and the wonderful work that you 


people have done today is very difficult for 


people to understand who haven’t spent the 


time or really don’t have the background. And 


we need to explore ways to do this better, and 


we’re open to suggestions. Certainly, it’s 


what we want to do, so if you have any 


specific suggestions for us now or after 


you’ve been through the entire process please 


let us know. 


MR. ELLIOTT: This is Larry Elliott again. 


I think, and I feel that one way we can 


certainly accomplish a little bit better job 


in communicating with folks is to provide 


them, and particularly the petitioners, we can 


provide the matrix that has been a working 


document up to this point. But at some point 


in the near future it should be a finalized 


document and all of the other associated 


documentation that has been developed and 


generated through this deliberation for a 


given petition. We should provide that, I 

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believe, back to the petitioner as a way to 


help bring their level of understanding and 


bring closure to some of the questions and 


concerns that they have raised. 


MS. MINKS: This is Erin Minks again. I 


think that would be very, anything would be 


helpful, that openness that we’ve talked about 


building credibility in the process to those 


who are not able to engage in the level of 


deliberation you’re all engaging in. And I 


think that as this meeting comes up in two 


weeks out here in Denver, we’re getting asked 


by a number of petitioner constituents who we 


work with just trying to get a sense of their, 


you know, we’re trying to manage their 


expectations about how this meeting is going 


to be. 


And we can talk about this at the end 


of the meeting, whatever’s easiest today. But 


if we could have a sense of how the, you know, 


we talk about agenda or this is going to be 


presented and how. Summed up really in a 


very, I think the danger is to go so technical 


that folks don’t also feel as alienated in 


that angle as well. But that’s just what 

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we’re hearing from the Congressman Udall’s 


office and Senator Salazar. 


MR. GRIFFON: That’s a good point. 


DR. WADE: Thank you. 


DR. MAKHIJANI: Mark, this is Arjun. You 


know, we have, thanks to Dr. Wade and the 


other conversations that we’ve starting with 


Mallinckrodt when petitioners started actively 


participating, you know, when they send 


questions or we have at least a tentative 


procedure sometimes of interviewing 


petitioners and talking to them. So there’s 


already some interchange, a considerable level 


of interchange happening. 


And I think what Larry has suggested 


seems like an extremely good way to regularize 


it because we do answer questions. At least 


we will commit ourselves to anything in terms 


of what if there’s a question about something 


or there’s a normal kind of interchange about 


a technical matter. This sounds like a very 


good way to, that would be helpful to our work 


also. 


DR. WADE: This is Lew Wade again, one last 


item. As the DFO I’d be willing next week 

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possibly to have a discussion, a telephone 


discussion, with those of you who might like 


if you give me your name and number to talk 


about the agenda and the inputs and things 


you’re hearing. I’d like to spend some time 


exploring how we can do this well. 


MS. MINKS: That would be very helpful. I 


think there’s at least three members out here 


who would probably want to, of the 


congressional members out here who would want 


to be part of that. 


DR. WADE: Okay, if you would give me your 


name and number, and I’ll call you and we can 


set it up. 


MS. MINKS: Erin Minks, it’s E-R-I-N M-I-NK-S and it’s with Senator Salazar. 


DR. WADE: And the number? 


MS. MINKS: 3-0-3-4-5-5-7-6-0-0. 


DR. WADE: Erin, I’ll call you Monday and we 


can talk about setting up such a discussion. 


MS. MINKS: Wonderful, thank you. 


DR. WADE: Thank you. 


I’m sorry, Mark, to take time. 


MR. GRIFFON: That’s okay. That’s okay. 


It’s important discussions. 

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MS. MUNN: And Lew and Mark, in that regard 


early on Paul Ziemer made an effort at the 


outset of our meetings to try to sort of set 


the stage for people who had not been involved 


in the Board’s activity but only had 


interaction with NIOSH and their claim and 


labor. And we have not done that in recent 


times mostly I think because of the level of 


heavy lifting that was going to have to go on 


in our agenda of time constraints. It might 


not be a bad idea for us to consider a very 


brief overview, just five minutes or so, for 


new audiences to understand what has 


transpired with this activity prior to our 


actually appearing in their community. 


DR. WADE: I will talk to Paul, I mean, as 


soon as I can about that and based upon my 


discussions with our friends from Colorado, 


possibly will include that as an item. 


Thank you, Wanda. 


MR. GRIFFON: Let’s go back to the heavy 


lifting. 


DR. ULSH: I think we’re on number 17. Am I 


correct? 


MR. GRIFFON: Seventeen? 

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DR. ULSH: Seventeen from the matrix? 


MR. GRIFFON: Yes. 


DR. ULSH: Inappropriate subtraction of 


backgrounds. This comment begins on page 18 


of the 5 April document. 


MR. GRIFFON: Was there any added comments 


because we had no further actions. 


DR. ULSH: Yes, that’s correct. We did have 


no further action. SC&A says in their 


expanded comments that there was a report 


written. We are speculating that this was the 


one that was written some time in the mid­

‘90s. I don’t know if that’s right, but I 


think that we’re going to stand by our 


previous comment the full text of which is 


given on page 20, and I would direct you to 


the last italicized paragraph where it says 


that falsified ambient dose is assessed 


separately from dosimetry included in 


assessment. And in the worst case this might 


require ^ to that, but that’s easily 


accomplished, I mean, if evidence is uncovered 


that we should do that. But we don’t see it 


as an SEC in our response at the moment. 


MS. DeMERS: Well, let me make a comment. 

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That report has not been sent to me. That’s 


one of the reports that is in the box at Rocky 


Flats. And I guess I have a question and in 


order to answer this, you may have to look at 


page 60 of the external TBD. 


DR. ULSH: Hold on, give me a minute. Six-


zero, Kathy? 


MS. DeMERS: Yes. It’s Figure A-9. 


DR. ULSH: All right, we’ve got it. 


MS. DeMERS: There’s a column, second over 


from the right, D-K-1. What does that mean? 


MR. LANGSTED: That was the background that 


was -- now let’s see, this is from ’87, that 


was the background that was, environmental 


background that was subtracted from the badge 


or the crystals on the badge when loose chip 


TLD badge was processed. 


MS. DeMERS: Okay, and is there a reason, 


natural background or otherwise, why these are 


so elevated? 


MR. LANGSTED: Well, Rocky Flats is at about 


7,000 feet in a fairly uranium-bearing area, 


and typical environmental background was about 


a third of a millirem per day. 


MS. DeMERS: Okay, that was my question. 

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MR. LANGSTED: Does that make sense? 


MS. DeMERS: Uh-huh. 


MR. GRIFFON: All right, so are we at no 


further action required on that one? 


MS. DeMERS: Yeah. 


DR. ULSH: I’m in agreement with that. 


MS. DeMERS: Well, we haven’t had an 


opportunity to review the report that --


MR. GRIFFON: That’s still in the box, 


right? 


MS. DeMERS: Yeah. 


DR. ULSH: We haven’t had an opportunity to 


review it either obviously. However, again, 


if we need to adjust our background numbers we 


can do that. That’s not an SEC issue. 


MR. GRIFFON: I guess that’s the question, 


Kathy. Is this, would this be an SEC issue 


notwithstanding the documents that you’re 


going to look at. Is this something that 


couldn’t be adjusted if they found different 


information? 


MS. MUNN: It does not seem to exhibit any 


kind of dosimetry readings. 


MS. DeMERS: Well, I guess my answer is I 


don’t know. 

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DR. MAURO: This is John. I always, I’m not 


afraid to stick my neck out a bit. I can’t 


see that being an SEC issue. 


MR. GRIFFON: I think we’ll leave it there. 


I think we’ll leave it there for now, but I 


still think it should be followed up on, but I 


don’t see it as an SEC issue. So I think 


we’ll leave it there, Brant. 


DR. ULSH: Okay, I think then moving on to 


item 18 from Mark’s matrix -- let’s see, this 


is our oldest bugaboo about workers frequently 


did not wear badges in production areas. 


MR. LANGSTED: I don’t know if we have a lot 


to add here. We’ve talked about that a couple 


of times today. 


DR. ULSH: Do you want me to respond again 


or are you --


MR. GRIFFON: No, no, I’m just re-reading 


here. 


Is this, this is one of the specific 


cases, this wouldn’t happen to be one of the 


cases in the badges you’re going to provide 


would it be, Kathy? I mean, the idea here 


again I think was to try to track back this 


specific individual and see if there was any 

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reason to believe that the allegation or 


whether it was appropriately adjusted in the 


future quarters or, you know, it may not be 


conclusive what you find. I don’t know, but 


did you have any luck tracking or attempting 


to track back that individual? 


MS. DeMERS: You are on page? 


MR. GRIFFON: I’m on number 18 in the 


matrix. 


I don’t know what page, Brant, in your 


responses. 


DR. ULSH: Twenty-one. 


MR. GRIFFON: Twenty-one, thank you. 


MS. DeMERS: The worker in -- okay, this is 


not the one I’m thinking about. 


MR. GRIFFON: Yeah, I don’t think this is 


the radiation technician example. Again, I 


was asking Brant more than you, Kathy. 


Were you able to track this specific 


situation back? It doesn’t sound like it. 


DR. ULSH: I don’t think so, Mark. 


MR. GRIFFON: I mean was an attempt made I 


guess is the next question. I think this was 


a specific affidavit. 


DR. ULSH: I don’t know. I’m scratching my 

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head on this, Mark. We’re going to have to 


look, track down this, trying to find this 


affidavit right now. 


MR. GRIFFON: I may be wrong on that, too. 


DR. ULSH: I guess my answer, Mark, is I 


have no update on that. 


MR. GRIFFON: We’ll leave that outstanding, 


and I think this goes, holds true for all the, 


you know, the badge information that Kathy’s 


going to forward to you, but also some of 


these other specific cases. If you’re able to 


track back I think that was the idea to the 


extent that it helps answer questions about 


reliability of the overall, you know, overall 


set of data that we’re using for workers. 


DR. ULSH: So what we’re looking for is the 


petition part A, page 53, that’s referenced 


here. The first to a specific individual, the 


allegation here is that sometimes this 


individual didn’t wear their badge in the 


production area. What kind of analysis would 


you like us to do on this individual? 


MR. GRIFFON: I guess without looking at the 


actual page, you may come back and say 


inconclusive because we found some data but we 

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don’t know whether he off partially and had it 


on partially. So it may be inconclusive. If 


he reports to be in production areas for, if 


he’s very specific about when he was in 


production areas and has all zeros in those 


areas, you know, that may be telling depending 


on the area I guess. 


MS. DeMERS: I know who this person is so I 


can --


MR. GRIFFON: Is someone talking? I can’t 


hear. 


MS. DeMERS: There is an affidavit in the 


SEC petition by this person. 


MR. GRIFFON: So I guess Brant I’m not sure, 


but I would say take the affidavit, crosswalk 


it, and see what you can report back. And if 


it’s inconclusive; it’s inconclusive, you 


know? 


DR. ULSH: Okay, will do, Mark. We’ll see 


what we can do. 


MR. GRIFFON: Number 19 I’m on. 


DR. ULSH: This issue is number 19 that is 


the geometry issue. And this picks up in the 


5 April comment responses on page 22. There 


are a number of additional points that SC&A 

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has expanded upon, and so let me try to walk 


you through our response here which picks up 


on page 24. 


And the first issue raised is lead 


aprons. And what you see here on page 24 and 


25, we are relying a field study that was 


performed in two storage vaults in Rocky Flats 


that’s 1992 to come up with the bias correct 


factors that we present on page 25. And that 


gives us factors to use for situations where 


we’re talking about a cancer in a protected 


area. That is, an area that is under the lead 


apron and also an unprotected area, an area 


that is not under the lead apron, and then we 


also consider where the dosimeter was worn. 


And what’s presented here are bias correction 


factors that will account for this. 


There are some other specific issues, 


but I think maybe I’ll pause here to see if we 


want to have more of a discussion about the 


lead aprons. 


 (no response) 


DR. ULSH: Is that a no then? 


MS. DeMERS: Well, I haven’t had time to 


digest your responses to all of these since I 

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got them this morning. 


DR. ULSH: In that case the next issue, 


describe the situation where there were some 


storage carts apparently in a hallway, and on 


the carts were some parts of radioactive 


material presumably that were placed in 


storage boxes with a hole cut in the front. 


And the comment asserts this would create a 


directed beam. 


I would take some issue with that 


characterization. It’s kind of difficult. 


I’m visualizing this in my head. I don’t know 


the dimensions this, you know, the physical 


dimensions of the situation that we’re talking 


about, but if you have a part in a cubic box, 


let’s say, with a hole in one side --


MS. DeMERS: This is a shielded box. 


DR. ULSH: Okay, a cubic shielding box, what 


you’re going to have I would presume, I can’t 


see how it would be different, is sort of a 


cone-shaped field, not a directed beam. The 


only way you can get a directed beam that I’m 


aware of is if you have sort of a gun barrel-


type arrangement, and I don’t think that’s 


what we’re talking about here. Again, I don’t 

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have the specifics of the dimensions of these 


parts and boxes, but what you would have is a 


cone. And an issue that is being raised here 


deal with exposure geometry. 


And I would also remind you that you 


have to consider the fact that there would be 


scattering involved. I don’t contend, okay, 


I’ll grant you that there were heterogeneous 


radiation fields at Rocky Flats. But really 


the time that you have to worry about an 


exposure adjustment when you’ve got people 


working with discrete radiation sources for a 


significant portion of the badge exchange 


cycle. And the reason is that when you have a 


situation like that, a discrete source and a 


significant exposure time, it is possible that 


the dose recorded on the dosimeter badge might 


be different than the dose that would be 


received by some of the, for instance, if the 


badge is worn on the lapel area, the dose that 


was received by the abdominal organs could be 


different. 


And the reason for that is because of 


the one over r2

 of radiation intensity, the 


distance between the badge and the source is 

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greater than the distance between the 


abdominal organs and the source. We fully 


recognize this, and in fact, we have written a 


TIB to deal with exactly that situation. It’s 


OCAS TIB-0010, External Dose Reconstruction 


for Glove Box Workers. That TIB would also 


deal with the situation, the issue that SC&A 


raised where there were multiple glove box 


lines within the same room. 


That is certainly true. We know that. 


However, due to that same consideration, the 


dependence of radiation intensity on inverse 


of the square of the distance, a worker’s dose 


is going to be dominated by the glove box that 


he’s working in front of. That’s not to say 


that there’s no contribution from other 


sources, but it’s going to be dominated by the 


glove box that he’s working in. 


Furthermore, you have to consider that 


discrete sources in those other glove boxes 


have to get through not only the shielding in 


their own glove box but glove boxes or 


intervening structures that might provide some 


shielding. So that would even add to the 


dominance of the dose from the glove box that 

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the worker’s working in. 


DR. MAURO: Brant, this is John Mauro. My 


question is we just finished our review of 


that OTIB, and we matched your correction 


factors. 


DR. ULSH: That’s comforting, thank you. 


DR. MAURO: We have some comments. You’ll 


see it shortly. We’re working on publishing 


that, the Task 3 report, but it turns out I 


was involved in that one in particular, and we 


just about matched every one of your 


adjustment factors. 


DR. ULSH: I’m glad to hear that, thank you, 


John. 


MS. DeMERS: I would add one comment to 


this. Storage in the hallways was no uncommon 


at Rocky Flats in the tunnel. So I don’t know 


if it’s correct saying that these were, 


resulted in less exposure than glove box work. 


MR. LANGSTED: In the tunnels in 991 


Building? 


MS. DeMERS: Well, from what I’m reading 


there were various storage locations. There 


was a tunnel that was converted to a vault. 


MR. LANGSTED: Those tunnels that were used 

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for storage areas had very low occupancy 


factors. People would only be in there for a 


short period of time. 


DR. ULSH: And again, Kathy, you have to 


consider that if you’re talking about a cone-


shaped field, even if you don’t consider 


scattering, what you’re going to have to have 


is a worker standing in such a position that 


his badge is outside the cone and his body is 


inside the cone. And it just don’t find it 


credible that a worker would spend a large 


portion of his badge exchange cycle in those 


low occupancy areas standing in exactly that 


position. I just don’t find that credible. 


MS. DeMERS: Well, the statement about the 


directed beam was given by an RCT who measured 


it with field instruments. 


DR. ULSH: Well, I wonder if there’s some 


possible difference of interpretation here 


because like I said, the only way you’re going 


to get a directed beam is with a gun barrel-


type configuration. 


DR. MAKHIJANI: Brant, this is Arjun. I 


think the nature of the beam will depend not 


on the distance and geometry of the source. 

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And until, you know, it’s a point source, and 


I think you’re completely right. It would be 


like a cone. If it’s a more spatially 


extended source and a smaller hole in a 


shielded box then you might get more like a 


beam. But I think this is a, I don’t know, I 


guess sort of stepping back from it, it seems 


like a theoretical discussion of when we don’t 


know the specifics enough to sort out the 


situation. 


And if there are measurements, Kathy, 


is there a document behind these measurements? 


MS. DeMERS: I’ve asked to be pulled. 


DR. MAKHIJANI: Well, I think both things 


are possible. Brant is right that it could 


very well be a cone, but it just depends on 


what was being worked on. 


DR. ULSH: Yes, you’re right, Arjun. This 


is very much a theoretical discussion because 


I don’t have the layout of this situation in 


front of me. But I still contend that unless 


you have very thick shielding, you’re not 


going to get a directed beam. I will grant 


that you might have an unhomogeneous or let’s 


say a heterogeneous radiation field. 

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DR. MAKHIJANI: Right. 


DR. ULSH: But a worker would have to spend 


an appreciable amount of the badge exchange 


cycle standing where his badge in one position 


more or less, where his badge is getting a 


different reading. And I just don’t see that 


happening other than working with discrete 


radiation sources for a large period of time 


exemplified by glove box workers. If you guys 


come up with evidence otherwise, I certainly 


will 


DR. MAKHIJANI: Isn’t that the context in 


which this thing is being --


DR. ULSH: No, this is, no, this is --


MS. DeMERS: Well, there’s a --


DR. MAKHIJANI: there was a --


MS. DeMERS: -- couple of different issues. 


DR. MAKHIJANI: -- context of this. 


DR. ULSH: There were a couple of different 


issues raised in this comment. One was these 


putative directed beams that would be created 


by these storage boxes in the hallways. That 


was one issue. The second issue was multiple 


glove box lines within the same room. And 


what I’m saying is that the geometry issue to 

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the extent that there is one is typified by a 


glove box worker. And as John mentioned, you 


guys have just reviewed that TIB. 


DR. MAKHIJANI: Yeah, I think that’s 


probably right. 


MS. DeMERS: It’s difficult to give you a 


description because it’s treading on sensitive 


information. 


DR. ULSH: What you’re saying -- I don’t 


know. 


MR. GRIFFON: Are you saying that this might 


be a classified concern here? 


MS. DeMERS: Yes. 


DR. ULSH: So the configuration of these 


storage boxes and the parts that they 


contained and the storage areas might be 


classified information is what you’re saying? 


MS. DeMERS: Possibly. 


DR. ULSH: Okay, well --


MR. GRIFFON: Well, we can’t take that any 


further here obviously. 


DR. ULSH: Right, so I think that’s our 


response with this issue open to discussion if 


necessary. 


MR. GRIFFON: Yeah, I mean I think that just 

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about all we can say at this point is that 


NIOSH has provided a response in the 5 April 


comment memo, and SC&A will consider this 


within their review of the evaluation report. 


I mean, I think that’s where I’m going to 


leave it if that’s agreeable? 


MR. ELLIOTT: Kathy, this is Larry. Do you 


have any sense of the magnitude of this 


perceived problem? In other words how many 


workers might have been engaged in an activity 


where their badge would not have captured the 


dose --


MR. GRIFFON: Good question. 


MR. ELLIOTT: -- in this scenario? 


MS. DeMERS: It’s kind of hard to tell 


because you have to go back and this is for a 


particular time period. 


MR. GRIFFON: Was it for a very unique 


process of it was only for a limited 


timeframe? 


MS. DeMERS: It’s hard to get into this. 


This was --


MR. ELLIOTT: Let me suggest this. 


MS. DeMERS: -- plutonium fabrication 


facility. 

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MR. ELLIOTT: Fabrication facility, okay, 


but any way to narrow, give us a year or 


anything like that? Perhaps maybe I, let me 


suggest this. That maybe you with a Q 


clearance and one of the NIOSH folks who has a 


Q clearance and maybe one of the ORAU team 


need to have a discussion about this. 


MS. DeMERS: And I don’t have a lot more 


information to give you, but I don’t want to 


go into too much detail. 


MR. ELLIOTT: And I appreciate that, but it 


would help if you guys had a discussion to at 


least engage you about the magnitude or the 


number of people, the timeframe, where it 


occurred, et cetera. 


MR. GRIFFON: Thanks, Larry, good point. 


Okay, let’s leave that there and then 


go on to 20, I think. And I would suggest for 


efficiency purposes, 20, 21 and 22, the follow 


up on all these is that NIOSH will attempt to 


track the specific cases? 


DR. ULSH: We actually have tracked one 


here, Mark. 


MR. GRIFFON: So I’ll do that then. Number 


20. 

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DR. ULSH: Number 20. I think this 


corresponds, yeah, the comment starts on page 


25 and SC&A relates a number of situations 


here. I see three of them on page 27 in 


bullets. The first bullet is about a worker 


working around annular tanks and there was a 


ten-minute stay time, and he had no dose 


reported. Another employee accidentally ran a 


dosimeter through an x-ray machine and it came 


back zero. And certain high-dose projects 


would result in film badges that were reported 


as black. 


So I’d first like to address the 


affidavit that was provided in part B of the 


petition, page 32. This is shown in Figure 7 


on page 28. I have redacted it, and I would 


direct you to the second paragraph. This is, 


I think, the allegation for the part of the 


affidavit that SC&A’s comment concerns. And 


that is in the 1982-’83 timeframe, loading 


nuclear material into the stacker/retriever, 


he said that six quarters out of eight there 


is no data available for my dose. 


MS. DeMERS: Okay, this is broader than this 


particular individual. 

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MR. GRIFFON: Well, but we asked about this 


individual so --


MS. DeMERS: And it goes back to the zero, 


the unbelievable zeros by the workers. 


DR. ULSH: Okay, so let’s run this one down 


because we can. What you see on page 29 is a 


copy of the 1982-’83 dosimetry for this 


individual. And what you see are in ’82 we 


have dosimetry for quarter one, quarter two 


and quarter four. And for quarter three where 


we don’t have a quarterly read, we have a 


monthly read. The next year we have another 


monthly read in ’83, and then we have 


dosimetry results for all four quarters. 


So what you see here is that dosimetry 


does not support the assertion that there were 


six quarters out of eight where there is no 


data available. Now I will grant you that --


MR. GRIFFON: I’d like to see that, but I’m 


not sure I see that. 


DR. ULSH: Well, Mark, look at --


MR. GRIFFON: Well, I mean, I’m looking and 


I see zeros. 


DR. ULSH: Yes. 


MR. GRIFFON: Correct me if I’m wrong. Now 

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could zeros in a database form such as you’ve 


printed out here, could no data available have 


been transferred into zeros? I don’t know 


that. 


DR. ULSH: No. No data available indicates 


that there was no data available at the time 


the dosimetry report was reported back to the 


supervisors, I believe. And a zero indicates 


zero. 


MR. GRIFFON: So within the database there 


are columns that say nda or no data available? 


DR. ULSH: I don’t believe so, Mark. Those 


nda’s occurred -- I’m going to rely on Jim to 


help me out here. 


MR. LANGSTED: That no data available was a 


term that was used on the report that was sent 


out to the supervisors on an exchange basis. 


MR. GRIFFON: So these zeros would be just 


less than detectable all the time. 


DR. ULSH: Well, for the ones, yes, the 


zeros. Yes, you’ll notice that one quarter 


that is missing, quarter three of 1982. 


There’s a monthly read in --


MR. LANGSTED: That would have likely been 


reported as a no data available on the report 

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that went out to the supervisor for that 


quarter. 


DR. ULSH: But you do see numerical results, 


albeit some of them are zero in the dosimetry 


file. They are not missing for six out of 


eight quarters. 


MS. DeMERS: I think the point here was, 


again, that the worker was in an area with the 


very high dose rate, and they don’t believe 


the zero. 


DR. ULSH: Well, let’s talk about that. 


Areas that were posted for high dose rates are 


based on the highest dose rate in the area. 


That is not necessarily, you cannot assume 


that that is an average dose rate or 


representative of what the worker might have 


been exposed to. 


Furthermore, this person identifies 


themself as a radiological control technician. 


And it is consistent with our experience with 


radiological control technicians in accordance 


with the LARA procedures, they would stand 


back out of the ration field, and they were 


the ones that were holding the instruments 


until their services were required to go up 

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269 

and briefly take a reading near the source. 


And then they would retreat back to the low 


radiation area. So it is entirely plausible 


that a radiological control technician working 


in such an area might have had a badge read 


below the limit of detection. 


MS. DeMERS: Have you verified his readings 


with the general field conditions? Have you 


asked yourself does that make sense? Because 


if he’s standing in, say, 100 MR per hour 


field --


DR. ULSH: We are basing what I’ve said on 


the information provided in the affidavit. 


And it is entirely consistent, I mean, it’s 


plausible that a special situation could have 


existed without falsification of data. 


MS. DeMERS: This really goes back to a 


previous item we’ve already discussed. 


MR. GRIFFON: Okay, well, you did track this 


one back to the specific case, and I do 


appreciate that. That was, that’s useful. 


That’s what the action was, right? So we have 


a response --


DR. ULSH: Yes. 


MR. GRIFFON: -- for that specific part of 

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it. Now I guess SC&A added some bullets to 


this item? 


DR. ULSH: Well, these deal with other 


situations so, yes, --


Okay, the situation where, let’s see, 


there was a non-destructive testing technician 


asserting that his dosimetry readings did not 


match his job duties. And SC&A mentioned that 


this person was a claimant, and they have 


looked at the dosimetry. And I’m looking at 


it right now. 


I didn’t include it in the comment 


responses because I was a little worried about 


Privacy Act information at the time. But I 


don’t disagree with any, I think the 


description that SC&A provided of his 


dosimetry is accurate because I’m looking at 


it right now. And I would, we looked at his 


dosimetry files just like SC&A did, and we 


were not able to establish his work locations 


and his job duties. 


What you see is that in the early 


years, ’63 to ’68, he does have higher deep 


dose and skin readings. And then in ’69 there 


is a gap. There’s nothing recorded. In 1970 

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it’s pretty low, and the years after that are 


lower than they were in the earlier years. I 


would mention that since this person is a 


claimant, I was able to determine the status 


of his claim. It has been completed. I don’t 


want to give any personal identifiers, but the 


POC that was calculated was greater than 50 


percent. 


Therefore, you might ask what about 


this gap in 1969? That did not prevent us 


from doing dose reconstructions. This is a 


classic case where we could use either 


coworker data or more likely in the case we 


would use the nearby technique. But that was 


not necessary in this case, and we found that 


frequently. 


Now we don’t contend that the, we 


can’t warrant that 100 percent of all the 


claimant files, we can’t warrant that they are 


100 percent complete. We grant that there 


are, in certain instances there are gaps and 


that is why we have techniques like the nearby 


technique and coworker data to cover those 


periods. And it certainly didn’t pose a 


problem in this case. We successfully 

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completed the case with a POC greater than 50 


percent. 


MR. GRIFFON: And this was --


DR. ULSH: The non-destructive testing 


technician. And, yes, there is a gap there. 


Without specific information on his locations, 


which I did not find in his file, I really 


can’t comment on why there’s a gap there. 


MR. GRIFFON: What page are you in you 


comment --


DR. ULSH: Page 30. 


MR. GRIFFON: Page 30. 


DR. ULSH: I’m on page 30. 


I’m going to move on to the next one 


unless there’s some discussion necessary. 


 (no response) 


DR. ULSH: The situation, the next situation 


that was raised in this comment --


MR. GRIFFON: Sorry, just to step back. 


This person had a POC greater than 50 percent. 


Was it with maximizing, I mean, was it with, 


because of assumptions or was it a best 


estimate case or probably you may not know 


that. 


DR. ULSH: I can’t really tell you that, 

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Mark. I know what kind of cancer it was. Is 


Liz on the phone? 


MS. HOMOKI-TITUS: Yes, and you’re getting 


very close --


DR. ULSH: That’s why I asked. I think I’ll 


stop there, Mark. 


MS. HOMOKI-TITUS: We can have this 


discussion offline if you want to, Mark. 


MR. GRIFFON: No, no, no. Okay. 


DR. ULSH: The next situation described was 


the employee who, I think it was accidentally, 


ran his dosimeter through an x-ray machine, 


and the badge came back without a positive 


dose. That is entirely consistent with what 


you might expect. 


On the next page, page 31, I provide 


an example. Now it’s not this individual 


because I don’t know who this individual is 


that appeared in SC&A’s comment, but it’s 


exactly this kind of a situation. If you look 


at the bottom of page 31, what you see, the 


text that’s written in there, on experimental 


data it has been determined that multiple 


exposures to the portal x-ray devices would be 


required in order for a positive, detectable 

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reading to occur. 


What we’re saying here is that the 


dose delivered by a run through an x-ray 


machine would be below the limit of detection. 


And, in fact, the experimental data that’s 


referenced there, we have tracked, I think 


we’ve tracked it down. We contacted a Jason 


Flora^ who we believe did this study, and let 


me see what he says here. I just got this 


morning that’s why I didn’t include it. 


He says, “I did do a study with TLDs 


going through the x-ray machines during the 


early ‘90s. Thus, based on memory, we 


discovered that sending the TLD dosimeters 


through the x-ray security scanners that no 


measurable change occurred on the TLD.” They 


could not tell the control badges from the 


exposed group. 


In addition he says that he’s pretty 


sure that they sent them through the x-ray 


machine multiple times, and he does not 


believe that this was written up anywhere 


except possibly in some memo that he wasn’t 


able to provide. But the bottom line is it’s 


entirely consistent that if a badge was run 

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through an x-ray machine, it could come back 


with a less than LOD. 


MS. DeMERS: So you’re saying Security x-ray 


systems? 


DR. ULSH: Yes, the type of x-ray machine 


that was referenced in the SC&A comment wasn’t 


clear, that those details weren’t in there. 


MS. DeMERS: I need to provide you with 


further details. 


DR. ULSH: Okay. 

MS. MUNN: It just said the portal x-ray. 

DR. ULSH: No, Wanda, that wasn’t from 

SC&A’s comment, that was from the example that 


I provided which is not the individual, at 


least I don’t think it’s individual in SC&A’s 


comment. 


Okay, the next situation, I think 


we’ve kind of discussed this. This is the 


employee who was working around the annular 


tanks and there was a ten-minute stay time for 


this job, no dose was recorded. 


MR. GRIFFON: Are we still within comment 


nine? 


DR. ULSH: Oh, yes. 


MR. GRIFFON: These all fall under comment 

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nine, okay. 


DR. ULSH: It was a big one, Mark. 


MR. GRIFFON: It started out as one specific 


one. I kind of, I’m trying to keep this 


matrix... 


DR. MAKHIJANI: Mark, this is also the areas 


of high dose with low recorded dose. 


MR. GRIFFON: Okay. 


DR. ULSH: Yeah, I think that’s the thread 


that ties them all together. 


MR. GRIFFON: I just have this challenge of 


keeping this matrix up to date so I’m trying 


to -- anyway. 


DR. ULSH: Do you want to go ahead? 


MR. GRIFFON: Yep. 


DR. ULSH: All right, next we come to the 


situation where the worker was working in an 


area with a ten-minute stay time. Again, this 


is the same argument as before. Stay time was 


typically calculated based on the maximum dose 


rate in the area. We cannot assume that that 


is representative of an average dose rate that 


a worker would have been exposed to. 


I don’t know the details of the 


annular tank area so I can’t comment 

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specifically on that. But it’s certainly 


plausible that a worker working in such an 


area could have had a less than LOD reading, 


but I don’t have the details. 


MS. MUNN: As a matter of fact, Mark, that’s 


not the reason for posting things like a ten-


minute stay to try to avoid any unnecessary 


radiation at all. 


MS. DeMERS: Well, I guess what I would like 


to see is if people are concerned that in 


their dosimetry record they’re getting zero, 


and they’re saying, hey, the field data did 


not support that. Then that’s what has to be 


answered. 


MR. GRIFFON: I think all of our experience 


is that if you got down to calculating short 


stay times like that, there was hefty 


exposures going on. 


MS. MUNN: Yeah, somewhere, somewhere in the 


room. 


MR. GRIFFON: Somewhere where you’re doing 


the work. I mean, I would argue why would you 


base it on somewhere where you’re not doing 


the work? 


MS. MUNN: That’s true. 

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MR. GRIFFON: Like running in and out of a 


reactor core during a shutdown. I think 


that’s when you have very short stay time, and 


you cycle people in and out to do, you know --


MS. MUNN: That’s true. I wouldn’t argue 


that. 


MR. GRIFFON: So I would be surprised to, I 


mean, that surprises me a little assuming the 


allegation is accurate. 


DR. ULSH: Mark, all the allegation says is 


that he was working the area, the general 


area, where there was a ten-minute stay time. 


It’s possible that the area --


MR. GRIFFON: That he wasn’t part of the, 


yeah. 


DR. ULSH: Yeah, I just don’t know. I don’t 


have the --


MR. GRIFFON: We don’t know, okay. 


DR. MAKHIJANI: Mark, there may be like a 


sludge tank with americium or something like 


that where, a small area. I’m speculating 


obviously. 


MR. GRIFFON: But what Brant’s saying is he 


may not have been one of the individuals that 


was going down in the tank and doing something 

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or whatever. 


DR. ULSH: Well, pure speculation, I’ll 


admit that, and I don’t have the details but 


I’m just saying that it’s not a foregone 


conclusion that this necessarily have to 


represent a falsification of dosimetry. 


MS. DeMERS: Well, all I’m saying is they’re 


concern is that their dosimeter readings do 


not match the fields that they were in. And 


that’s what has to be addressed. 


MS. MUNN: Now we need a lot of detail in 


each case in order to address that. 


MS. DeMERS: And the purpose for putting 


these examples in was to let you know that 


it’s, you know, a fairly widespread concern. 


And I can go back to these people and get you 


all the details you want. 


DR. ULSH: If the Board decides that we 


should run down these individual cases, and 


you can provide the details, then we will do 


it. 


MS. MUNN: Might not be a bad idea to do at 


least one or two of them. 


MR. GRIFFON: Right, and I understand your, 


I mean, you could absolutely be correct on 

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both, the one I’m thinking back to is the 


radiation technician with the zeros. That 


could certainly be true, you know, if the 


thing that he mentions, or her or she. 


I don’t know if it’s a, but the thing 


that’s mentioned that’s also interesting to me 


is that he says in that area other workers 


were cycled out constantly. Now it could be 


that the rad tech was working, like you said, 


at the perimeter but then occasionally making 


readings, but that is an interesting fact in 


that situation, too. 


DR. ULSH: I’m not, again, I mean, we are 


willing to run this down if the Board 


determines that we should, and we can get 


adequate detail. If Kathy can provide that, 


that’d be great. 


MR. GRIFFON: But we also have to think how 


it’s going to help us if, you know, if you 


find X then what’s that going to prove or 


disprove or whatever? 


DR. ULSH: Now I would point out that there 


are a couple of specific instances where we 


have run these down. I’ve just shown you one, 


but certainly, if you feel that you would like 

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to see additional ones and details, sufficient 


details are provided, we will do what we can 


to run it down. 


MS. DeMERS: The individual that you ran 


down? 


DR. ULSH: I’m talking about the rad control 


tech with the dosimetry, and there were a 


couple of other ones in the previous meetings, 


the individual that said he was receiving dose 


while he was in Korea. That one didn’t pan 


out. 


MS. DeMERS: Okay, the question is, that the 


petitioners have is does the field data 


support that reading on the dosimeter? 


DR. NETON: But Kathy, this is Jim Neton. 


That’s almost impossible to determine. I 


mean, you would have to go and get the exact 


RWP that the person worked on during that 


period if they were even on that RWP. And 


then figure out their time and motion study 


within the fields. I mean, I don’t know, I’m 


not against doing this, but I just feel that 


it’s a wild goose chase. 


MR. GRIFFON: I don’t know where it’s going 


to get us, that’s the problem. 

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DR. NETON: I mean, it’s an assertion --


MS. DeMERS: You have to answer the question 


for them. 


MR. GRIFFON: But even if we go back, for 


this radiation technician, I mean, certainly ­

-


MS. DeMERS: What if you go back and he has 


the, and he spent ten minutes in the AR per 


hour field? 


DR. NETON: We wouldn’t know that because if 


the AR per hour field is in the right-hand 


corner of the room, and he walked into the 


entryway that was substantially west, he just 


-- you’re not going to get that time/motion 


information from the RWP for sure. It’s just 


recommendations as to where to avoid and where 


the hotspots are. I don’t know how you would, 


you can reconstruct a dose from an RWP. 


MS. DeMERS: Well, I guess what the bottom 


line is that that’s the concern. They don’t 


think their dosimeters are reflecting what 


they’ve received in the field, and that’s the 


question that you’re going to have to answer 


for them. 


MR. GRIFFON: Well, I guess, let me try to 

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ask this question on the radiation technician 


again. I’m trying to understand that when 


this no data available, how did that, that 


form went to the supervisor or where did that 


terminology come from and then how did we get 


to a zero, or where did that terminology come 


from I guess is what I’m trying to understand. 


MR. LANGSTED: This is Jim Langsted. That 


was the phrase that was used on the report 


that was printed out from the dosimetry system 


and sent to the supervisors. And so they 


would, if their group was exchanged on a semimonthly basis, every two weeks they would get 


a report after the badges were read with 


everybody in their group on it. 


DR. ULSH: And didn’t you say, Jim, that 


sometimes that was posted where employees 


could look at those results. 


MR. LANGSTED: Yeah, back in those days 


sometimes it was, you know, some supervisors 


didn’t show them to their group, some showed 


them to their group, some posted them on the 


bulletin board. 


DR. ULSH: So it is possible that workers 


would have seen the results of their dosimeter 

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in these reports and saw no data available. 


MR. GRIFFON: And so when they saw no data, 


when he or she again saw no data available for 


several cycles, it could have just been that 


he was falling within the, it was processed 


yet? Is that --


MR. LANGSTED: You know, as we discussed 


before, the report would have to be run 


sometime and sent in. If a badge was held up 


because of a, either not getting exchanged or 


because of some issue with trying to resolve a 


problem, sometimes the report was printed and 


sent out in a timely manner and all the data 


wasn’t on it. 


That doesn’t mean that the data didn’t 


ultimately get in a worker’s record, but they 


may not have seen that. If they didn’t 


exchange it, it would show up as a no data 


available, but they’d still be wearing the 


badge. But that no data available phrase does 


not show up in the records that are in the 


claimants’ files, the employees’ files today 


or in the electronic database. That was a 


phrase that was on that printed report. 


MR. GRIFFON: But within this employee’s 

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file it may be that their, if they had 


particular badges that were being held back 


or, you know, if there was an investigation or 


something like that, a note or something might 


show up in the employee’s record on that? Or 


not necessarily until later years probably, 


right? 


MR. LANGSTED: Well, Mark, that depends on 


the timeframe and back in this ’82, ’83 


timeframe it’s unlikely that there was a 


formal report or anything. 


MR. GRIFFON: I’m just trying to think 


through where we could possibly go with this, 


and I’m not sure that you could take it much 


farther, you know? But just my opinion 


anyway. 


Brant, I’ll turn it back over to you. 


I’m not sure where we left off. 


DR. ULSH: We’re still on this same comment. 


We just talked about the annular tank one. I 


think, let me make sure, I think the last one 


in this comment, yes, it is the last one, is, 


here’s what the comment states, “Certain high-


dose projects would result in film badges that 


were reported as black. The employees 

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involved indicated that their dose was 


reported as zero.” 


That is possible. It’s a 


characteristic of film badges that if they 


were exposed to light, it could blacken their 


badge. So this could be light contamination. 


That’s entirely possible. We would have to 


review the specifics of the situation. 


I mean, again, we’re in the same 


situation as with the annular tank guy. We 


don’t have the details to run that one down, 


but it is certainly possible that exactly what 


is being asserted in the comment could have 


happened. Certain film badges could have been 


blackened and that could have been the result 


of light contamination. 


MS. DeMERS: In one of the records I’ve been 


trying to pursue is the procedure for how 


those, in those situations, how the dose is 


assigned. 


DR. ULSH: Keep in mind you’re talking about 


the film badge era, so I think you’re talking 


pre-’69? Do I have the right year? Yes, pre­

’69, and it’s unlikely that, and we’re running 


up the same problem that we had with the 

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previous procedures that we referenced. 


There’s just not a lot of, not a lot available 


in terms of written documentation back in the 


timeframe. If you find something like that, 


that’d be great. We’d look at it, but we’re 


not aware of anything. 


MS. DeMERS: It’s one of those records that 


has not been provided. 


DR. ULSH: So that’s our answer, Mark. 


That’s all we have to provide unless there’s 


more that needs to be discussed. 


MR. GRIFFON: Let’s just go on to 21 if you, 


the matrix or I guess it’s ten in your --


DR. ULSH: Twenty-one in the matrix and ten 


in the comment responses. This issue is 


bioassays redone when they indicated high 


exposures. And in the matrix it says there 


are two examples cited. The claimant 


bioassays were redone or individuals were 


recounted when the readings were high and 


subsequent results were declared as having no 


exposures or false positives. 


Now really if you look at our response 


on page 32, the nuts and bolts of the whole 


thing is at the bottom of the page, and I 

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don’t know why this didn’t occur to me 


earlier, but it didn’t. We typically receive 


the raw bioassay data from a site for a 


claimant. And that would include results that 


the site had determined to be false positives. 


We don’t rely on that determination. 


I’ve had conversations with dose 


reconstruction personnel, people who do the 


dose reconstructions, and they indicated that 


it would be extremely unusual for us to 


exclude a bioassay result even if the site had 


determined it was false positive. Now, I 


won’t say that it has never happened, but we 


sure couldn’t come up with a situation and the 


bottom line is we would not rely on the site 


to make that determination. We would make 


that determination ourselves. And in almost 


all cases if not all cases, we would just 


include it as another bioassay plan. 


MR. GRIFFON: Assuming that the false 


positive was included in the records I guess, 


which may be reason not to believe. 


DR. ULSH: That’s correct, we have no 


indication of that. So I really think that’s 


all I’ve got to say about that one right now. 

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MR. GRIFFON: Okay, and SC&A, any comment 


back on that? 


MS. DeMERS: No, I’ve got some information 


that I will roll into the report. 


DR. ULSH: Next one, Mark, 22? 


MR. GRIFFON: Yep. 


DR. ULSH: Twenty-two on the matrix. It 


corresponds to page 33 in write up, data 


integrity comment number 11, instances of 


noted available in situations of high 


exposure. I’m looking at this one. Oh, okay, 


okay. Here’s what went on. SC&A says in 


their comments that they have addressed this 


issue under data integrity comment number 


nine. And I think our notes agree with that 


that this issue was not closed but merged 


under nine. So I don’t know if we need to 


talk about that again. It’s the same issue, 


no data available. 


MR. GRIFFON: Now this is affidavit number 


22 are we on? 


DR. ULSH: We are on number --


MR. GRIFFON: And there was, this again is 


no data available, but this is a specific 


affidavit, I think, and I asked that you track 

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back a specific case again? 


DR. ULSH: Oh, oh, oh, okay, I just read the 


next part of it, Mark, on the next page. This 


was the individual who worked in Korea, I 


mean, I’m sorry, who was in Korea. There 


might have been two concerns on his affidavit. 


I think the Korea one we discussed when we 


dealt with it last time. 


MR. GRIFFON: Yeah, we did. We touched on 


that. 


DR. ULSH: I don’t know that we’ve done any 


more on that at the moment. 


MR. GRIFFON: I didn’t think, is this the --


DR. ULSH: Yes, if you look at the next --


MR. GRIFFON: Korea. 


DR. ULSH: If you look at the next page, 


Mark, of your matrix, ten of 13 continues 


comment 22. 


MS. MUNN: It’s unclear to me whether that 


was one individual or two. 


DR. ULSH: I think it’s one individual, 


Wanda. 


MR. GRIFFON: Okay, I wasn’t sure about that 


either. 


MS. MUNN: Blackened film was one, I was 

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thinking blackened film was one, was the 


second individual. 


DR. ULSH: I think it’s one individual 


raising two issues, the blackened film and the 


Korea. 


MR. GRIFFON: So it’s the same individual 


but you didn’t, you tracked back the Korea 


aspect but not the other. 


DR. ULSH: Yeah, again, back in the film era 


I don’t know that there, I mean, we wouldn’t 


expect there to be an incident report -- I’m 


sorry, an investigation report in his file 


during that period. I don’t know what more we 


can provide other than the explanation of how 


that would be possible for a person to have a 


blackened film and get a zero read. 


MR. GRIFFON: I don’t know if you gave a 


specific timeframe for that. 


DR. ULSH: I don’t know. I don’t have the 


affidavit in front of me. 


MR. GRIFFON: I don’t know either. Can we 


leave that open to the extent you can make 


what comment on that you can? 


DR. ULSH: Okay. 


MR. GRIFFON: I mean, it may be inconclusive 

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or whatever but --


Twenty-three. 


DR. ULSH: Twenty-three, most worker, most 


exposed workers were not monitored for 


neutrons. This corresponds to comment number 


12 on page 33 of the comment responses. Let’s 


see, now our notes indicate that this issue 


was closed, but I didn’t have the matrix in 


front of me when I wrote that. I don’t know 


if we agree with that, Mark. Let me see. 


MS. DeMERS: There’s a question to be 


answered here. 


DR. ULSH: Okay, there are -- SC&A has 


raised some new, well, expanded on this issue. 


Okay, on page 35 of the comment responses, I 


think we’re getting into the stuff that Kathy 


might be referring to. And that was in the 


comment they talked about when fluoride was 


added to the molten salt extraction process, 


neutron dose rates increased significantly. 


MS. DeMERS: Those comments were just to 


alert you where they were saying there were 


neutron levels. 


DR. ULSH: Well, I’m wondering if there 


might be some confusion here because we’re not 

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aware that fluorination was ever added to the 


molten salt process. And I’m wondering if 


they might be thinking of the fluorinator. I 


mean, I’m just guessing, but that’s the only 


area that we know where that would be an 


issue. And that would have been in the 


plutonium-fluoride process. Now if that 


speculation is true, first of all that was 


originally a remote operation. Operators were 


in a control booth and protected by a water 


shield. But in any case, the fluorinator, if 


that’s what we’re talking about here, was 


covered by the NDRP. Like I said, we’re not 


aware of any evidence that fluoride was ever 


added to the process. I’ll most certainly 


look at it. 


DR. MAKHIJANI: What was the molten salt? 


DR. ULSH: That is the issue, that’s a 


process --


DR. MAKHIJANI: No, no, I’m not talking 


about what the process was. What was the 


chemical? What was the molten salt? 


DR. ULSH: Molten salt was a mixture of 


potassium chloride, magnesium chloride and 


calcium chloride salt. 

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DR. MAKHIJANI: So it was chloride? 


DR. ULSH: Correct. 


DR. ULSH: Oh, I see what you’re saying. I 


wonder if maybe that’s --


DR. MAKHIJANI: Yeah, I’m wondering whether 


there might be a, is there an alpha chlorine 


reaction in the same way? I don’t know off 


the top of my head. 


 MR. FALK: I don’t think it is a very 


efficient process. I do not recall any of the 


molten salt operations being identified as a 


high neutron exposure area. 


DR. MAKHIJANI: But if whatever neutrons 


were there from the description would be 


because of the shield, right? Or am I mixing 


up two things? 


DR. ULSH: I think you’re mixing up two 


things, Arjun. 


DR. MAKHIJANI: I thought maybe I was. 


DR. ULSH: The fluorinator, what we’re 


talking about with the water shield, that was 


remote operation in the early years, in the 


‘50s. 


DR. MAKHIJANI: Okay. 


DR. ULSH: That was the fluorinator. That’s 

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not the molten salt. 


DR. MAKHIJANI: Okay, sorry, I mixed up 


those two things. 


DR. ULSH: So I don’t know. That’s all I 


can say about that particular issue. With 


regard to other areas, other neutron areas, 


our contention that there were very few 


sources of neutrons at Rocky Flats that were 


not associated with plutonium operations. The 


chemistry of the uranium process that was 


performed in Building 881 until 1964 produced 


significantly less neutrons in the plutonium 


processing. 


And if you compare the neutron yield 


of the enriched uranium fluoride versus the 


plutonium fluoride, it’s about a factor of one 


times into the negative five. So it’s not 


clear to us how this would be a significant 


neutron exposure hazard. I would contend that 


it’s insignificant. 


MR. GRIFFON: I think that at this point 


we’ve got, this is one of those ones where we 


have your response and the evaluation report 


and SC&A is going to provide a review report 


and can include comments there unless there’s 

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any other clarification from SC&A’s side. 


DR. MAKHIJANI: No, I think we need -- Joe’s 


area. 


DR. ULSH: All right, Mark, I think, does 


that take us to number 24 on the matrix? 


MR. GRIFFON: I think so, yeah. Almost 


there. 


DR. ULSH: I’m getting a little tired. I 


don’t know about anyone else. 


MR. GRIFFON: I think all of us are, yeah. 


DR. ULSH: The issue here, neutron badge 


reading was defective and just cites, if I 


have this correct, my brain’s getting a little 


mushy now. 


MR. GRIFFON: I think we have no further 


action required on this. 


DR. ULSH: I think that’s the case. Let me 


see --


MR. GRIFFON: If that’s agreeable with SC&A. 


DR. ULSH: Yeah, we’re going to stand by our 


previous response. I think no action. 


MR. GRIFFON: And the next one as well 


unless there’s something new from SC&A’s side. 


DR. ULSH: Well, let me go into that one a 


little, the security guard issue. Data 

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integrity comment number 14, page 36. And 


SC&A says that they have not yet located 


security guards to verify the lack of 


monitoring among this worker category. 


Neither have we, so we’re in agreement with 


that. In fact, during the post-1991 period 


dosimetry was required to gain access to 


radiation areas. 


And in their expanded comment SC&A 


contends that assignment of coworker dose of 


unmonitored security guards may or may not be 


bounding. Let’s think about this for just a 


minute. Unmonitored workers with the 


potential for significant exposure, what we 


typically do is assign the 95th percentile 


value of monitored workers. So in order for 


this approach to not be bounding, we have to 


have a couple of things happen. 


First of all, keep in mind that only 


people who were judged to have an exposure 


potential of greater than 100 millirem were 


badged. Now, we do not contend that that was 


entirely, 100 percent reliable. In other 


words, we’re not saying that if a person was 


unbadged, necessarily they wouldn’t have 

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gotten a dose higher than 100 millirem. We’ll 


grant you that that might have happened in an 


individual case or two or more. I don’t know. 


But what we’re saying is that people 


who were judged to have this exposure 


potential, number one, that would have to be a 


mistaken judgment, that’s possible. They 


would also have to have entered a radiation 


area with dosimetry which was contrary to the 


radiation control policies in place at the 


time. 


And then finally, they would have had 


to have received doses that were higher than 


95 percent of the monitored workers in order 


for this not to be a bounding approach. 


Personally, I don’t see how that’s a credible 


scenario. 


MR. GRIFFON: Well, I guess the other, that 


may clarify one thing is that are you assuming 


that security guards would get the 95th
 

percentile in a coworker? 


DR. ULSH: If it was possible for a security 


guard to get a significant exposure potential 


then we would treat them just like any other 


unmonitored radiation worker. 

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MR. GRIFFON: Okay, because in some models 


you, I mean I could see an argument for not 


treating them like ^ necessarily. 


DR. NETON: Yes, that would have to be 


addressed on almost a case-by-case basis. 


MR. GRIFFON: Right, right. So if it’s 


case-by-case, then, Brant, your position 


doesn’t hold there, that they wouldn’t have to 


be higher than the 95th . Because sometimes you 


might assign them the 50th . That’s different. 


DR. ULSH: That’s true, but that would be an 


issue with that specific dose reconstruction. 


In other words, let’s say SC&A reviewed one of 


our dose reconstruction, and we had assigned 


the 50th percentile. And SC&A would say, no, 


this person actually had a significant 


exposure potential, and you know, we discussed 


it, and at the end of the day maybe we agree 


with SC&A. We go back and assign 95th
 

percentile, not an SEC issue. 


MR. GRIFFON: I guess you’re right. It’s 


more of a site profile, yeah, it’s a site 


profile issue. 


DR. ULSH: Moving on. Shall I move on? 


MR. GRIFFON: Certainly. 

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DR. ULSH: We’re up to matrix comment number 


26, I believe which the essence of it is that 


many incidents were not recorded, and that 


picks up on page 37 of the comment responses. 


SC&A’s expanded on their previous 


comment talking about the atmosphere at Rocky 


Flats that was such that incidents may not 


have always been reported. And they say the 


Operations personnel simply cleaned up spills 


and continued with their work. 


MR. GRIFFON: I think did we not address 


this by saying that you’ll provide a coworker 


approach? I mean that you believe the 


coworker approach is going to be bounding of 


this? 


DR. ULSH: Let me look, Mark. Let me look 


at our response. We do grant that some of the 


smaller incidents and minor spills may not 


have been reported. And we also grant that it 


may not always be possible to tie an intake to 


a particular incident. However, what we said 


at the last Board meeting was that if we would 


detect an intake in a bioassay, what we 


typically do is assign a chronic intake 


scenario that fits bioassay data. 

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And there seems to be some concern 


that if an incident was unrecognized, then it 


may not, special bioassay may not have always 


been performed. We grant that. That might 


make it difficult for us to tie an intake to a 


particular incident. We grant that, too. 


That does not prevent us from doing a 


sufficiently accurate and claimant favorable 


dose reconstruction. That’s the point. 


MR. GRIFFON: Right, and I think we’ve been 


through this before. I’m not sure, but --


DR. MAURO: Yeah, this is John. When we 


were talking about the high-fired plutonium, 


this subject came up, and you provided many 


examples of how you would go about placing a 


plausible upper bound for, not only chronic, 


but also acute exposures to an incident. 


So I think to a large extent as you 


move into the more technical issues, a lot of 


them have been addressed thoroughly, and we’re 


going to keep returning to the data 


reliability issue as being the underpinning. 


I think from a technical point of view, going 


back into this issue again, you know, you’ve 


covered it thoroughly, and I guess I’ll 

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reiterate. It’s data reliability that’s going 


to be center stage. 


DR. ULSH: Okay, well, that’s good. Can I 


dare to hope then that we don’t have to talk 


about this particular issue again because it 


seems to keep popping up. 


DR. MAURO: Yeah, this is John. I think 


that Jim and his examples in our last meeting 


in the handouts covered this subject. 


DR. ULSH: Okay, I do feel compelled that, 


you know, even on an issue, several issues 


have been designated as closed at the last 


meeting and then SC&A’s expanded on these 


comments. And I do feel compelled to respond 

to those. I’d sure like not to have to do 

that. 

MR. FITZGERALD: Well, let me make a point, 


okay? Kathy was doing this onsite visit 


during the time that we were having the 


meeting. So our discussion was completely 


devoid from her review. We provided the trip 


report pretty much as was. I mean, it’s not 


an attempt to re-open issues as much to convey 


that information she was able to collect. But 


recall again the timing of this, that her 

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review was happening at the very same time 


that we were meeting in Cincinnati, so there 


is a reason why these issues aren’t linked 


together as tightly as they might be. 


DR. ULSH: I understand what you’re saying, 


but when this came over, like I said, I did 


feel compelled to spend quite a lot of time 


and resources to address them. 


MR. FITZGERALD: We were trying to give you 


the benefit of what was identified as was 


requested but I do understand why there’s a 


little bit of overlap. 


DR. ULSH: Okay, Mark, would you like me to 


move on to the next one? 


MR. GRIFFON: I think so, yeah. 


DR. ULSH: This is estimating ingestion 


doses. I think we’ve already talked about 


this one. It seems to be similar to -- hold 


on, now -- seems to be similar to the issue 


that was raised earlier when we talked about 


ingestion. 


MR. GRIFFON: Yeah. 


DR. ULSH: My comment, you’ve probably seen 


that text before because I think I cut and 


pasted it. I would just reiterate that we 

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have the ability to model ingestion intakes if 


it’s a feasible scenario and it’s claimant 


favorable to do so. 


MR. GRIFFON: The comment I had before in 


the matrix, and I remember Jim Neton offering 


this, that you would re-evaluate the ingestion 


model to be used. 


Jim, do you remember saying that? 


DR. NETON: Re-evaluate the ingestion model 


to be used? 


MR. GRIFFON: Yeah. 


DR. ULSH: Here’s what I have on the matrix, 


Jim. This is comment number 27, page 11 of 


13. Workers ate in workplaces. One 


investigation concluded that there was 


ingestion via inhalation. However, bioassay 


data to be interpreted in light of this 


problem --


MR. GRIFFON: And I think hearing Brant’s 


explanation from earlier, it seems to suffice, 


but I don’t know why --


DR. NETON: I think what, it was a question 


that was ambiguous in the sense that was it an 


ingestion from eating in the workplace or was 


it ingestion from potentially from 

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resuspension? 


MR. GRIFFON: Right, that’s the way, it was 


in two parts. 


DR. MAKHIJANI: I think it might have been 


eating in the workplace, right, Kathy? 


MS. DeMERS: Yes. 


DR. NETON: Eating in the workplace, Brant, 


I think addressed the issue fairly well. I 


think the resuspension issue is what wasn’t 


clear in my mind. But that, I think, would 


have been a site profile comment. 


MR. GRIFFON: Right. 


DR. NETON: And we certainly have come to 


some consensus with SC&A on how we’re going to 


deal with resuspension in the workplace. At 


least if we ^ sampling data. 


MS. MUNN: And when we wrote this, we still 


hadn’t completely put the Super-S question to 


bed, had we? 


DR. NETON: And of course, it’s late in the 


day, and having said what I just said, I just 


remembered that we are reconstructing doses 


based on bioassay data not air sampling data, 


so the resuspension issue really kind of come 


out. 

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MR. GRIFFON: Yeah, it really, yeah, it 


does. It does now that I, yeah, I think we 


did this late in the day last time, too. 


DR. NETON: Using air sample data to 


reconstruct doses in suspension is not --


MR. GRIFFON: We still weren’t sure, I 


guess, last time. 


DR. NETON: Now that we have a coworker 


approach outlined, what we’re proposing here 


in data I don’t see this as a player. 


MR. GRIFFON: The last sentence to me is 


interesting, and I think it might overlap in 


some of the samples or examples that you’re 


going to do. The relevance of this is in the 


deposition of high-fired, in large parts of 


the plant due to the fires. 


And this gets into the question, I 


guess, one question anyway, of the exposure to 


a mixture of solubilities or different kinds 


of plutonium in different areas and how that 


would be addressed. But that’s really, I 


think we all agree that that was really 


something that we want to see in an example. 


But 27’s closed I think, from my standpoint. 


DR. ULSH: Okay, that brings us to 28 then. 

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And I think, unless SC&A tells me differently, 


I think we’re in agreement that this is not an 


SEC issue? This is the work week. The length 


of the work week was 45 hours instead of 40 


hours. 


DR. MAURO: Not an SEC issue. 


MR. GRIFFON: Right. 


DR. ULSH: Oh, oh, shoot. I thought we were 


done, okay there were two issues raised in, I 


guess it was Kathy’s write up. They were 


characterized as additional issues, and in our 


response to the first issue which dealt with 


other radionuclides at Rocky Flats, I kind of 


left in there, I took the liberty of leaving 


in there a question that I think Arjun had 


raised if my recollection is correct, about 


some 40 Plutonium-238 sources and one 


strontium source at Rocky Flats. And my notes 


aren’t real clear on this, what the reference 


was, but I think it was 1990 D&D document. 


Arjun, does this ring a bell? 


DR. MAKHIJANI: That’s correct. It was 


after the site had been renamed, I think. 


There were maybe 90 or 92 orphan sources that 


were at the site. 

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DR. ULSH: So I think the question was we 


weren’t clear whether those were sealed 


sources at the time we discussed it. Is that 


right? 


DR. MAKHIJANI: Or made at the site or 


imported. 


DR. ULSH: Okay. We checked this out this 


issue of other radionuclides. We already 


talked about some of them in earlier comments. 


Let me walk through them. The Chem Risk Task 


One report is a reference that we relied on 


pretty heavily for this. And that report 


contains a comprehensive list of the 


radionuclides present at the Rocky Flats site. 


Plutonium-238 was present as a 


contaminant in weapons-grade plutonium. That 


is true. And intakes of that radionuclide 


would be measured using plutonium-specific 


bioassay. And if it wasn’t clear which 


isotope we were dealing with, we would choose 


the most claimant favorable among the 


plausible choices. 


Oh, the Strontium-90, that was listed 


in the Chem report as having been present at 


Rocky Flats as a sealed source, plated source, 

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liquid source or analytical stock solution in 


small quantities used for research, analytical 


and calibration activities. So I think it was 


what we suspected, Arjun, that it’s one of 


these small, sealed sources that’s used in a 


lab or in a stock solution or something like 


that. 


Let’s see, I think Kathy’s report 


reads the tritium and noted that the tritium 


bioassay was performed at Rocky Flats. So 


that’s how we would cover that. 


MS. DeMERS: Well, it was performed, but 


what I have not been able to figure out is was 


it frequent enough to cover the exposures of 


the people involved. 


DR. ULSH: Don’t have an answer for that 


right at the moment. 


The next one was Americium-241 


processing methods. And when we covered that 


pretty much at length unless someone wants to 


go into that some more. 


U-233 was mentioned. Again, that one 


would have been detectable through either 


uranium-specific bioassay or through gross 


alpha bioassay depending on the time period. 

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We agree with SC&A with the comment that 


curium and neptunium were used as tracers then 


were handled in small quantities. We’re not 


aware of credible intake scenarios for those 


elements that would result in a significant 


internal exposure hazard. 


Polonium-210 falls into the same 


category as Strontium-90. It was one of these 


small laboratory sources according to the Chem 


Risk report. 


MS. DeMERS: In what time period? 


DR. ULSH: For polonium? 


MS. DeMERS: Uh-huh. 


DR. ULSH: I don’t know, Kathy. I don’t 


have it in front of me. It was just listed in 


the Chem Risk report. It was a comprehensive 


list that listed polonium only under that 


category, but I assume that that would cover 


all time periods. 


DR. MAKHIJANI: Could I ask a question about 


this Chem Risk report? My memory of, this is 


far back and my memory of it is foggy. But 


wasn’t it very heavily criticized as not being 


a good report or was that a different Chem 


Risk report or a different contractor perhaps? 

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I don’t want to be unfair to Chem Risk here 


because this is from vague memory. There was 


one of these kind of reassessment source term 


type of reports that was done that made 


reviewers very unhappy, and I don’t know that 


it was the Rocky Flats one to be fair, but it 


may have been. Does anybody have any memory 


of that? 


DR. ULSH: I’m looking around the table here 


in Cincinnati, Arjun, and no one’s aware of 


that for this document. 


MR. MEYER: Brant, this is Bob Meyer. That 


report was actually the beginning of the 


environmental dose reconstruction study and 


put a lot of time and effort into establishing 


the radionuclides present at the site. We’ve 


got all the details on that in addition to 


records review and classified records review. 


They also did a lot of interviews, and it’s 


the basic document that was used then for the 


rest of the, of that dose reconstruction. 


DR. MAKHIJANI: Okay, so I must be 


remembering something else. So thank you for 


correcting that record. I’ll withdraw that 


comment. 

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DR. ULSH: I think we have reached the last 


issue, I hope. 


MR. GRIFFON: There’s one more there I 


think. 


DR. ULSH: This issue that we’re about to 


talk about is the last one. And this was the 


second of the additional comments that were 


sent --


MS. DeMERS: You didn’t really get back to 


the issue of, that I’ve been discussing before 


that the field indications do not represent 


what’s coming out on the dosimetry. And we’ve 


already beat this to death. 


DR. ULSH: Okay, I think we’re in agreement 


there. I would just mention that there are a 


couple of references that SC&A would like to 


see. They’re listed there on the bullets on 


page 41. And I have those in a folder on my 


computer, and I’m going to burn a disk and 


send them over to you directly. So I’ll send 


them to Joe. Well, the ones that are listed 


there. 


MR. GRIFFON: With this last point, Brant, I 


think the one thing that we spent a lot of our 


afternoon on here was these specific 

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affidavits within the petition and the 


allegations. And to the extent you could, we 


did, you know, you were able to track back 


some, at least partially for some of these 


cases. I guess the thing I think that’s going 


to be important for this evaluation is, in the 


evaluation report if I, you know, one thing 


that we talked about this morning was the 


external database data and the internal 


database data. And I think it was mentioned 


that Kaiser-Hill indicated to NIOSH that they 


reviewed these cases and they matched pretty 


well. I think what this brings to light and 


makes even more important from my standpoint 


is that we need NIOSH to track that back as 


well and report on that fully. I don’t thing 


we can just take the word of an individual 


from Kaiser-Hill that says it looks like 


everything matched up pretty well especially 


with these allegations hanging out here from 


many of the petitioners. 


DR. ULSH: And Mark, are you talking about 


external data? 


MR. GRIFFON: I think external and internal. 


DR. ULSH: Well, for external, Craig Little 

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did talk about what we’ve done. 


MR. GRIFFON: Right, you did some specific 


analysis there so I guess more for internal is 


where the real gap is if you think that you 


did enough on external. I mean, that’s up to 


you to judge. 


DR. ULSH: I agree with you on internal. 


MR. GRIFFON: Yeah, you have to support 


case, you know, for the data being reliable. 


And if you think you’ve taken that far enough, 


that’s just your decision. 


DR. NETON: Mark, this is Jim. I think that 


these assertions by, in the affidavits are 


somewhat of a different issue. In fact, one 


would argue that if the badge read zero and 


the database says zero, the claimants or 


petitioners are still asserting that those 


zeros are not, except for sections, the zeros 


are inappropriate. 


MS. DeMERS: Yes, that is true. 


DR. NETON: That’s a different issue, and 


I’m not really sure how one deals with 


assertions that cannot really be 


substantiated, you know, 30 years, 40 years 


later. I’ve just been told that there were no 

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RWPs in this timeframe so even if we wanted to 


and had the resources, couldn’t go back to 


them. 


MR. GRIFFON: I guess to me, Jim, it just 


raises the importance that where possible we 


check these databases back to the raw --


DR. NETON: I totally agree with you. I’m 


trying to think about the other broader issue. 


And in my mind if I can’t go back because 


there’s no ^ or whatever, I think the only 


other approach then is to document the 


integrity of the dosimetry processing system, 


and to the extent possible, that there is no 


evidence of fraud where these numbers would 


have been altered. Because if a dosimetry 


system is capable of reading the dose on the 


badge, then one would have to assert that they 


were fraudulently made zeros. 


DR. MAKHIJANI: Yeah, I think, Mark, Jim, 


Jim is right and that there are two different 


questions here. The one question is about the 


transcription from the raw records into 


electronic databases. And I think NIOSH has 


done quite a bit of work on that transcription 


with Rocky Flats to show that it’s reasonably 

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good so far as I understood the discussion 


this morning. I haven’t looked at it in 


detail, but at least from the discussion. 


But the second issue is the one that 


Jim was talking about and there it seems to me 


is it is very difficult because you’ve got 


sworn affidavits on one side, and then you’ve 


got people who were there on the other side or 


a contractor currently saying, so you’ve got 


somebody’s word against somebody’s word. And 


there may be safety complaints and, you know, 


some documentation that could settle the issue 


because otherwise you’ve got dueling hearsay. 


MR. GRIFFON: I’m not sure what you mean by 


dueling. I mean --


DR. MAKHIJANI: Well, not really dueling 


hearsay. The workers who were present that’s 


unfair I guess to, to the people who’ve done 


affidavits in a way. There’s the people who 


were there who say, you know, they experienced 


X, and they don’t believe their data records 


because they may have been, they were 


falsified. I mean, that’s clearly the spirit 


in all of the allegations. 


And then you’ve got people who were 

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there in the health physics program or 


contractors who are saying, no, there was 


integrity in the program, and data were not 


falsified. So you’ve got dueling statements 


essentially. ^ statement without the 


historical information settle the question. 


DR. ULSH: Arjun’s characterization there 


where you’ve got dueling opinions, I mean, 


you’ve got workers saying that they falsified 


my dosimetry, and we’ve got workers who worked 


in the dosimetry department saying, no, we 


didn’t. So you do have dueling assertions 


here. 


MS. MUNN: This is Wanda. 


MR. GRIFFON: You’ve interviewed dosimetry 


people that have said in statements that none 


of this went on? 


DR. ULSH: Yes. 


DR. MAKHIJANI: Do you have sworn statements 


from them? 


DR. ULSH: No, not sworn statements. I 


can’t remember whether they were phone 


conversations or e-mails. 


MR. GIBSON: This is Mike, and I just, I 


mean, who’s going to admit that, the fact that 

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it’s true, you know? 


MS. MUNN: Well, who’s going to admit that 


they doctored their badge, but several of them 


have maintained that that was true. 


MR. GRIFFON: Quite a few of them admit that 


actually. 


MR. GIBSON: There is these dual opinions 


here, but let’s not say, well, let’s not 


believe the worker because he doctored his 


badge or --


MS. MUNN: No, no. 


MR. GIBSON: -- so by that same token, you 


know, I have seen people, have seen health 


physicists fired for doctoring records at the 


facility in Mound. 


MR. GRIFFON: I mean, part of what you have 


to consider, I guess, is the overall, you 


know, how many allegations were, I don’t know 


if we have an opportunity for that kind of 


thing here. We’ve got some affidavits, but 


not, you know. 


MS. MUNN: Is Kathy still on? 


MS. DeMERS: Yeah, I am. 


MS. MUNN: Kathy from the documents that you 


saw while you were onsite, do you have any 

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confidence that the field records that you’re 


talking about would really give the 


investigator at this stage of development a 


good feel for what the backgrounds were in the 


areas that our claimants are concerned about? 


I guess the bottom line question is even if we 


get the records and look at them, are we going 


to have, are we really going to have better 


information then? 


MS. DeMERS: I don’t know how to answer that 


because --


MR. GRIFFON: Well, I guess that’s what I 


asked John and you, Kathy, but SC&A to deliver 


to us is sort of, I forget how we said it, a 


more crisp recommendation on this. That if we 


ask NIOSH to look at these, SC&A expects that 


you might be able to look at what could be 


concluded from this potentially. And I don’t 


think you need to answer that on the fly here, 


but I guess that’s what we want to know is it 


worth --


Right, Wanda, is that what you’re 


asking, is it worth pursuing these and to what 


end kind of? 


MS. MUNN: I think what I’m really asking is 

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is there truly any way that we could in some 


way reduce the anxiety that the claimants have 


with respect to this data. Regardless of what 


information we get, is it going to be valid 


enough to be accepted? 


MS. DeMERS: The path that I laid out, I ran 


through with some of the site experts because 


I wanted to know whether I was going in the 


right direction. They felt I was going in the 


right direction. I have not seen one of these 


logbooks because they were not pulled for me 


so the exact contents of those logbooks are 


essentially, I can’t tell you exactly what’s 


in them. 


MS. MUNN: They’re still a mystery to 


everybody. 


MS. DeMERS: But I know what I’m being told. 


DR. MAURO: And Kathy, you said something 


very important. The folks that you talked to 


said you’re on the right direction. The 


implications being if you were to pursue that 


direction, it would enhance credibility. That 


is, it sounded like, yeah, that’s the kind of 


thing you need to do in order to find out or 


whether or not there’s a problem here. So I 

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mean, in a way they’re telling you if you want 


us to believe you, you’ve got to go look, you 


know, if you really want to get to the bottom 


of this, you have to do X, Y and Z. Sounds 


like we have no choice but to do at least some 


X, Y and Z. And the ball is in our court 


right now to lay out a crisp recommended plan 


of action that would do those things that the 


folks you interviewed feel need to be done and 


why, and what NIOSH might gain by looking into 


these matters. So I mean, I think the ball’s 


in our court right now to turn over something 


to the working group and NIOSH --


MR. GRIFFON: That’s my sense, John. And I 


was just saying, on the flip side of that, I 


think NIOSH should be pursuing the database 


versus raw records issue. Especially with 


regard to internal. I think that’s an opening 


right now which you’re well aware of. I mean, 


you brought it up earlier. 


DR. ULSH: We agree completely. 


MR. GRIFFON: But I think, John, I think 


that’s the path forward here is that SC&A if 


you could provide this crisp sort of 


recommendation back to us and then we need to 

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say is it worth going further? And if so, in 


what direction or to do what, to what end? Is 


this a fair point right now that we can leave 


this? 


MS. DeMERS: Yeah. 


DR. MAKHIJANI: Yep. 


DR. ULSH: Yep. 


MR. GRIFFON: Okay, plus we’re all getting 


tired. At least I’ll speak for myself. 


MS. MUNN: Yeah, can’t think much more. 


DR. ULSH: Okay, so what now, Mark? 


SAMPLE DOSE RECONSTRUCTIONS
 

MR. GRIFFON: Well, what now, I guess I 


don’t know how much we want to go over these 


cases, but I would like to, if you could go 


through the cases --


DR. ULSH: Okay, how about this --


MR. GRIFFON: -- and tell at least what 


kinds of cases you have there and give a quick 


snapshot. 


DR. ULSH: I provided a table, at this point 


in the day I can’t remember the name of the 


file. 


MR. GRIFFON: Yeah, Guide or something like 


that. 

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DR. ULSH: Yeah, that’s it. It lists 


examples by number, one through six. Now I’d 


like to caution you that these numbers 


correspond to the folders on the O drive and 


the folder that I mailed you, but I discovered 


that when I opened up the actual example dose 


reconstruction report, the titles of them 


didn’t always match the numbers. Sorry, that 


was a late night error on my part. 


MS. MUNN: They all got here. 


DR. ULSH: Example one, I’ll just walk 


through this table and then, Mark, maybe you 


can let me know if you want me to go any 


further. Example one covers a hypothetical 


neutron dose assignment for monitored workers 


pre-’70, and it also considers missed dose 


zeros assigned for blanks and reported zeros. 


Those are the two issues that are covered in 


that one. 


Example number two is an example of a 


geometry correction factor for external 


dosimetry. That was performed using the glove 


box TIB. That was an issue that was raised so 


we thought that would be an appropriate one to 


include. 

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Example number three is coworker 


unmonitored external dose and also lead 


aprons. It demonstrates our approach for 


those situations, and I would also point out 


that the table of distributions that we are 


going to use for coworker external dose is 


provided with that example. 


Number four, hypothetical internal 


coworker assignment for unmonitored uranium 


worker. Again, I have to point out though 


both three and four are hypothetical because 


as we’ve discussed, the need for coworker data 


is pretty minimal at Rocky. I can’t say it’s 


zero, but it’s pretty minimal so let’s keep 


that in mind. 


Example number five is an ingestion of 


depleted uranium. This is an issue that seems 


to be a concern so we included a dose 


reconstruction showing that. 


And finally, the last one, number six, 


is our Super-S for a monitored plutonium 


worker, monitored meaning he had bioassay. He 


did not have chest count. He had some 


urinalysis results, some that were positive. 


Just to illustrate the range of possibilities 

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we covered four target organs, so this is 


really actually four examples in one. We 


covered the lung, of course, the GI tract, we 


modeled a colon for that, a systemic cancer 


that was a liver cancer and a systemic non-


metabolic which we took as the prostate as an 


example. 


So that’s what’s included in there. 


DR. NETON: Let me just fill in a little bit 


on number six. Those dose reconstructions 


were performed using the TIB-0049 document and 


the associated approach document that we 


discussed earlier in the day. 


DR. ULSH: So that might help SC&A in 


interpreting what we did if they refer to 


those documents in their review. 


MR. GRIFFON: And let me ask a couple of 


questions on those types of examples we might 


want to see, and I mean, it’s up to you what 


you want to provide, but this question, and 


it’s not, this is a hard time of day to 


discuss this because it’s not clear in my 


mind, but I know we talked about a potential 


for individuals to be in areas where they 


would be exposed to mixed solubilities of 

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plutonium including S or Super-S and how that 


was going to be handled in the dose 


reconstruction process. 


DR. NETON: Mark, this is Jim. We did one 


of those examples in the Y-12 case, and it 


turns out it’s not that difficult an issue. 


We just pick the one, if truly we can’t tell 


what the worker was exposed to, we pick, you 


know, you run the scenarios through the models 


and pick the one that gives the highest dose 


to the individual organ. 


MR. GRIFFON: So you would just, at the end 


of the day, if Super-S was going to give the 


highest dose, you’d always assume Super-S? 


DR. NETON: Yes, if Super-S is a credible 


exposure scenario and we couldn’t tell, yes. 


If a person was working with a tank of 


plutonium nitrate, we might not do that, but 


yeah, sure. So that’s not that, unless I’m 


missing something, those examples are not that 


difficult for us to do. We could certainly do 


it, but --


MR. GRIFFON: Yeah, no, I guess it’s more of 


understanding our explanation especially when 


you have a lot of less than detectable values. 

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DR. NETON: Yeah, well, that’s standard. We 


define the half of the detection limit, assign 


a chronic intake and pick the most claimant 


favorable solubility --


MR. GRIFFON: Even including Super-S. I 


mean, I thought for Y-12 we didn’t have the 


Super-S possibility. 


DR. NETON: No, but Super-S is really just 


one more choice in the dose reconstructor’s 


toolbox for plutonium, and it turns out, 


actually, it’s kind of interesting. The 


Super-S approach did not substantially in my 


mind, you can look at the example. I looked 


at it briefly this morning. Does not 


substantially alter the compensation profile 


for the cases as we kind of expected. 


In other words the lung dose went up 


dramatically, the liver dose increased, both 


of those would have likely been contestable 


under the S scenario. And the prostate dose 


is in the five percent range. Well, it’s kind 


of interesting how that worked out. 


MS. MUNN: It was interesting. 


DR. ULSH: Okay, Mark, that’s my description 


of the dose reconstructions. 

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MR. GRIFFON: And the only other questions I 


have was we raised thorium this morning a 


little more, and I understand gross alpha, 


really I don’t know if there’s a need to see 


any kind of thorium reconstruction especially 


if you’re going to assume worst case nuclide 


if you don’t know. 


Other people have opinions on that 


though? Arjun or John? 


DR. MAURO: I don’t. It sounds like that is 


a bounding assumption. 


DR. MAKHIJANI: I don’t know. I’m very 


tired. 


MR. GRIFFON: And then the other thing I 


didn’t see on here was americium, but again --


and I don’t know if this, that is sort of the 


policy within the evaluation report, the 


approaches that when in doubt, we’ll assume 


any of these radionuclides that will deliver 


the highest potential dose to the organ of 


interest? Because you’ve got the americium 


separation workers theoretically that could 


have been working solely in that americium 


area prior to americium-specific urinalysis. 


DR. ULSH: Right, that’s sort of a program­
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wide policy that we have that if we lack 


information to pin it down specifically, and 


there are numerous, plausible choices, we’ll 


pick the one that claimant favorable. I mean, 


Mark, if you’d like to see an americium dose 


reconstruction example, we can do that. 


MR. GRIFFON: I don’t know. I’m just noting 


that these things aren’t within the cases and 


just exploring whether they need to be. I’m 


not, it sounds like probably they don’t need 


to be, but I’m just --


DR. ULSH: And we took our best shot at 


guessing what you’d want to see. If we’ve 


missed any, and you’d like us to do them, we 


can do it. 


DR. MAURO: This is John. I think that the 


way to proceed is as we work through putting 


our report together and then drawing upon your 


examples, if we feel that completing our 


report, that the report would benefit from a 


few more examples, we’ll give you a call and 


say, and explore other examples with you. But 


right now we have plenty on our plate. 


MR. GRIFFON: Well, I guess we’re, in this 


situation I know what you’re saying, Brant, 

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and that’s true, and I think in other 


situations we had dealt with facilities that 


were primarily uranium and then to just make 


blanket assumptions that, yeah, we can, if we 


didn’t know we’d assume americium, thorium or 


plutonium. That would very much shift the 


dose profiles for individuals, but in this 


situation you’re dealing primarily with 


plutonium so shifting to thorium or americium 


is really no big deal probably. 


MS. MUNN: Yeah, it’s almost pointless, 


isn’t it? 


DR. MAKHIJANI: I think that the actual --


MR. GRIFFON: I think that’s the difference. 


I mean for instance Mallinckrodt or Y-12, you 


know. 


MS. MUNN: Whole different ballgame. 


DR. MAKHIJANI: If you have the bioassay 


results, I think the dose conversion factors 


are close enough. You know, they are 


different, but what I think might be useful 


since there’s been a lot of discussion of 


americium data is to, if you can communicate 


some case of claimant numbers to us or show 


us, since all of us have done our Privacy Act 

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training and signed the papers and so on, to 


be able to actually see some of these bioassay 


data. Do you have any positives? 


You know, the petition deals with 


high-fired from non-plutonium transuranics 


radionuclides. So since americium was being 


processed, I don’t know if it was being 


processed into oxides. It would be useful to 


see some real data, and I haven’t tried to 


actually go and look at claimant information 


to try to find it so it might be easier for 


you to find. 


DR. ULSH: So Arjun, are you asking for 


claim numbers that might contain, or the 


worker’s dosimetry file might contain 


americium-specific bioassay or gross alpha 


bioassay? Is that what you’re asking? 


DR. MAKHIJANI: Yeah, and if you’ve already 


done a dose, since you’ve done so many dose 


reconstructions already, if you handled a case 


like that already it might be more useful just 


to look at that rather than setting up a 


schematic, and also there’s very little time. 


DR. ULSH: Okay, we’ll try to find something 


like that. 

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MS. MUNN: It’s simpler, I think. 


MR. GRIFFON: And I think, I guess the last 


thing we need to discuss unless there’s more 


discussion on the case is that the sort of 


timeline or path forward. We are looking at 


two weeks out from an Advisory Board meeting. 


DR. MAKHIJANI: Less than two weeks. 


MR. GRIFFON: Yeah, less than two weeks. 


Okay, less than two weeks. And my sense, 


well, I think we have maybe a few more loose 


ends in this than we did in Y-12, and I’m 


wondering just about the timeline or 


deliverables. We have many of the same people 


especially from SC&A’s team that are going to 


have to do a review of the petition. And I’m 


just wondering what we can expect for the work 


group to deliver to the Board by the time of 


the Board meeting. 


DR. WADE: Well, this is Lew, let me just 


talk out loud. I mean, next week is our week, 


obviously, so if we could imagine an exchange 


of information the middle of the week, 


Wednesday. I know when we talked yesterday, 


we had asked John to put his shoulder to 


trying to share the report on Y-12 by the 

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middle of the week. If we can do that to the 


maximum degree possible, and it’s possible for 


the work group to get together by phone 


Thursday, Friday to have one more discussion. 


I don’t know that at this point we’re 


not all so tired that we might not be able to 


sort the issues exactly now, but it would seem 


to me there might be benefit from as much 


information exchange as possible, as much 


dialogue as possible, and then one follow-up 


opportunity. You know, three or four hours to 


try deal with remaining issues. 


MS. MUNN: Well, the e-mail inquiry today 


was asking whether we were available on the 


20th
 . 


DR. WADE: What day was, I don’t have a 


calendar in front of me. 


MS. MUNN: That’s Thursday. 


MR. GRIFFON: Thursday. 


DR. WADE: I think there were some people 


who were suggesting Thursday was better for 


them. 


MS. MUNN: Yeah, and there’s an inquiry out 


asking are we available on Thursday. 


MR. GRIFFON: I’m also thinking about we 

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have I think more significant pieces, 


especially I’m thinking about the data 


reliability question. You know, we’ve asked 


John, SC&A, to deliver a product to us about a 


path forward on some of these specific 


allegations about no data available, et 


cetera, you know, that general category. And 


I would expect that if we’re lucky, they might 


be able to complete that by the end of the 


week. I don’t know that we really can expect 


a full review of this report and Y-12 by the 


middle of next week by SC&A. I think, I’m not 


sure that we’re ready to push this forward in 


the full Board meeting. That’s my opinion 


anyway. Push this forward to a vote in a full 


Board meeting, I think we also have the 


outstanding question of the database data 


versus the raw data especially for the 


internal or the bioassay side of the equation. 


Brant says that they’re in the middle of 


working on that. 


DR. WADE: Well, this is Lew again. Let me 


just sort of talk through generically the 


issues, and I don’t take any exception to what 


you’ve said. I would imagine that by the end 

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of next week based upon whatever information 


has been shared and made available NIOSH will 


have to make the decision as to whether or not 


it wants to present the evaluation report 


formally to the Board. 


I assume NIOSH, and I’ll depend upon 


their integrity, if they feel that they have a 


case to make, they’ll make the case. The 


Board then, assuming NIOSH presents, then the 


Board has its option as to whether to act on 


that positively, negatively or the rule does 


allow for the Board to ask for additional 


information upon which to make its decision. 


So I think that’s a path we’re likely to take 


forward. The working group could strongly 


recommend to the Board that these things be 


pursued. It could only be at full Board 


meeting that we could make that decision. 


MR. GRIFFON: Correct. 


DR. WADE: So I think, you know, what I 


would like to see happen is we work as hard as 


we can through the week. NIOSH will have to 


make a decision as to whether or not it wants 


to go forward and make a presentation. 


Assuming it does, then the Board will have to 

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deliberate and hear from the working group and 


then make its decision. If NIOSH decides to 


not present, then it becomes a moot point save 


for the decision as to how to go forward to 


fill the gaps that NIOSH would bring. So I 


think that’s --


MR. GRIFFON: That sounds reasonable. 


DR. WADE: So I think that’s likely what 


will happen. The question is what do we want 


to do in the time available? We could put our 


efforts to Y-12 or we could try and do as much 


as we could on Y-12 and also do some things on 


Rocky. That’s a decision for the working 


group to take now. 


MS. MUNN: My personal feeling is that we’re 


totally committed to Y-12. 


MR. GRIFFON: That’s my sense, too. I would 


like to see one complete rather than two not 


quite complete. So I would say from a 


priority standpoint anyway, I think we should 


try to hone in on Y-12 and then it doesn’t 


mean that we completely stop these actions 


that we’ve outlined for Rocky, but the 


priority would be to complete the review of Y12. If we’re trying to set priorities, 

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especially for SC&A. 


Wanda, I’m sorry. 


MS. MUNN: That was my statement. 


MR. GIBSON: This is Mike. I feel the same 


way, but on one hand though it’s like we’re 


hitting these towns for these meetings --


MR. GRIFFON: I know. 


MR. GIBSON: -- behind the eight ball, and 


so that’s just another perspective look at, I 


agree with, you know, there’s just of work we 


have to do, and we need to close these issues, 


but I keep going to these towns to towns and 


not have something done. 


MR. GRIFFON: No, I agree, and I think we, 


if nothing else, we need a thorough status 


report in Denver. And the other thing I would 


say is that John, you know, SC&A should 


definitely try to complete crisp or mini 


report on that one issue that we’ve talked 


about in the very near future. 


And that NIOSH should pursue the 


internal bioassay reliability question so that 


we can show at least progress on the matrix 


and outstanding actions definitely. But, and 


I’m not saying maybe we will have time to wrap 

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up both, but I would say let’s prioritize Y-12 


because my feeling is I think we’re closer to 


completion on that. 


MS. MUNN: I hope that’s true. It’s 


unfortunate from my point of view that we have 


so many of the same people working on both 


sites. 


My feeling is that we actually are 


much further along here on Rocky than it looks 


like we are right now. I’m really sorry that 


we don’t have access to those, to the data 


that Kathy has tried to get her hands on 


earlier. That would be very helpful, but --


MR. GRIFFON: Yeah, I guess the biggest 


thing, as John stated earlier, probably the 


biggest item is the data reliability, and I 


think that’s one item that’s definitely high 


on the petitioners’ mind. So I think we’d be 


remiss if we didn’t at least try to go a 


little farther with that. 


MS. MUNN: I agree. 


MR. GRIFFON: I don’t want to not appear in 


Denver and try to close this out without at 


least taking that a little father. 


MR. FITZGERALD: Yeah, Mark, this is Joe. I 

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just wanted to clarify because this is pretty 


important schedule wise, clearly by the middle 


of next week as we said yesterday, the Y-12 


review of the review by SC&A should certainly 


be available and ready for discussion. 


Perhaps at the same time --


MR. GRIFFON: Review of the evaluation 


report, right? 


MR. FITZGERALD: Right. And certainly by 


then, if not before then, to have this handoff review if you want to call it that, the 


passing of the torch, the mini-review with 


very clear, sharp, proposed things that could 


be done, have that ready for the data 


integrity issues certainly early next week no 


later. That’s what I’m kind of hearing. Not 


the whole thing in terms of Rocky, certainly 


that piece. 


MR. GRIFFON: I think that seems, as 


priorities that seems like what I’m, that’s my 


feeling anyway. 


DR. WADE: Then I would propose that the 


working group have a call on Thursday and 


attempts to close its business on Y-12, and 


then possibly take a small amount of time just 

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to assess the situation with regard to Rocky. 


And then the working group can decide if it 


wants to meet before the Board meeting in 


Denver or whether or not the call on Thursday 


would be their preliminary discussion of what 


they’d present to the Board. 


MR. GRIFFON: And we can figure that out on 


Thursday I guess. 


DR. WADE: What time? Let’s just while 


we’re all here, what time, ten a.m.? 


MS. MUNN: That’ll be fine with me. My 


response was I’m available anytime preferably 


after eight my time, but I can do ten. 


DR. WADE: You want to try, let’s do 11. 


MR. GRIFFON: No, earlier would be better 


for me, so I’ll compromise on ten. 


DR. WADE: Okay, ten. 


Let me just, quick roll call, Mark, 


that’s okay with you? 


MR. GRIFFON: Yeah. 


DR. WADE: Mike, ten a.m.? 


MR. GIBSON: Yeah, that’ll be okay. 


DR. WADE: Robert? 


MR. PRESLEY: I will not be available 


Thursday. 

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DR. WADE: Well, since we’re going to be 


doing mostly Y-12, with your permission, we’ll 


go ahead and meet. 


MR. PRESLEY: You’re going to have to. 


DR. WADE: Okay, thank you. 


So ten a.m. eastern time next 


Thursday. I’ll make the arrangements with the 


call-in number. And I really pushed today so 


I could get things posted on the website and 


let people know so thank you. I’ll stop 


talking, and you guys can conclude your 


business. 


MR. GRIFFON: I think we’re concluded if 


any, unless anyone else has any comments, I 


think that should wrap it up. 


DR. MAURO: This is John. I just want to 


make sure that I understand. We have two 


deliverables to have in your hands prior to 


that conference call on the 20th . That is 


SC&A’s full evaluation, review of the 


evaluation report for Y-12 and the other, I 


guess, crisp report that we’ll try to get to 


you before then. 


MR. GRIFFON: Yes. 


DR. MAURO: We won’t have in your hands 

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anything related to the technical issues 


associated with Rocky. In other words, we 


won’t, even though we are right now in a 


position where we can probably put material 


together related to the three major technical 


issues that were raised on Rocky, mainly, 


high-fired plutonium, chest counts and neutron 


dosimetry, though the information is there. 


We have the information in our hands. 


We have the wherewithal to address those. 


It’s just really a matter of that would dilute 


our ability to go and deliver a complete 


product for Y-12. That’s basically how I see 


it right now. 


MR. GRIFFON: I agree, John, yeah. 


DR. MAURO: And assume that we have time, of 


course, we’ll move forward to work on those 


issues if we get the first two priorities 


finished by then. 


DR. WADE: Yeah, I would, again, this Lew 


speaking, the technical project officer. If 


you can do it without diluting the effort, I 


think the process is best served, even if it’s 


for the Board to be able to consider most 


fully its decision which could well be to 

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delay. I think the process is served with 


complete work if it’s doable. 


MR. GRIFFON: Right, we agree. If you’ve 


got time on your hands, John, then go ahead 


and give us the whole kit and caboodle. 


MS. MUNN: Squeeze time out of your hands. 


DR. MAKHIJANI: Mark and John, I think I 


hope complete doesn’t mean long. 


MR. GRIFFON: I hope it doesn’t, too. We’re 


all in agreement there. 


DR. MAURO: Yes, if we could keep it brief, 


yes. 


DR. MAKHIJANI: I was thinking sort of like 


a letter report. 


MR. GRIFFON: Yeah, we’ve got a lot of 


documents out there already so to the extent 


you need to cross, you know, refer to other 


documents that already exist, don’t be 


redundant. 


DR. MAKHIJANI: One other question is in 


regard to the sample dose reconstructions on 


Y-12. I mean, in the essentials if they 


illustrate things that don’t need, I think at 


this stage to try to reproduce a calculations 


and so on that doesn’t seem to me the 

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priorities, the principles that have been 


discussed in those things as they might apply 


to what the Board has to consider might go 


into a short report because otherwise it’ll 


get pretty out of hand, and we might get 


buried in the weeds in the details if you 


expect that. So I just want a little 


clarification. 


MR. GRIFFON: No, I guess, the way I 


consider those is we’re looking for proof of 


principle. 


DR. MAURO: Right. 


MR. GRIFFON: So that’s the way we expect 


you to review them as well. 


DR. MAKHIJANI: Okay, so we won’t try to 


reproduce the numbers. 


MR. GRIFFON: That’s not my expectation. 


Wanda or Mike? 


MS. MUNN: It’s certainly not mine, no. The 


more concise the better. 


DR. MAKHIJANI: Mike? 


MR. GIBSON: Right. 


DR. MAKHIJANI: Would that be all right? 


MR. GIBSON: Yes. 


DR. WADE: Thank you all for just a 

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Herculean effort today, and certainly the 


effort is appreciated and we’ll be back 


together at ten a.m. eastern time Thursday 


next. 


MR. GRIFFON: And Ray will have those 


transcripts for us before then, right? That’s 


another action item which was addressed. 


No, I’m kidding a little bit, but all 


kidding aside I think we did state earlier if 


these transcripts could be ready, you know. I 


think these will be very important, especially 


prior to the Board meeting. 


DR. MAURO: And especially the Y-12 portion. 


MR. GRIFFON: Yeah. Since we’re 


prioritizing that, yeah. 


DR. WADE: We’ve heard you. 


MR. GRIFFON: John, do you want a conference 


call? We were all on for the record 


yesterday, we were just on mute. 


DR. MAURO: Yesterday I called a conference 


call and everyone else was on mute so we 


didn’t hear, no one reacted. 


DR. MAKHIJANI: I’m here today so we can 


talk. 


MR. GRIFFON: Good work today, everyone. 

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It’s been a long day on the phone. Thanks a 


lot. 


(Whereupon, the working group teleconference 


concluded at 5:50 p.m.) 

______________________________ 

347 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of April 12, 


2006; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


14th day of July, 2006. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102