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 


ROCKY FLATS
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Hebron, Kentucky on March 


7, 2007. 

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C O N T E N T S
 

March 7, 2007 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


WORKING GROUP UPDATE 13 


COMPLETENESS OF DATA 21 


1969 DATA GAP 94 


OTHER RADIONUCLIDES - THORIUM 157 


DATA INTEGRITY, SAFETY CONCERNS AND LOG BOOKS 177 


SUPER S (TIB 0049) 192 


NEUTRON DOSE QUESTIONS 201 


COWORKER MODEL 210 


WOUNDS ISSUE 221 


PROOF OF PROCESS 233 


RECAP OF ACTION ITEMS 251 


COURT REPORTER’S CERTIFICATE 269 

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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. 

 

 

 

4

 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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IDENTIFIED PARTICIPANTS
 

ALBERG, JEANETTE, SEN. ALLARD 


BRACKETT, LIZ, ORAU 


BROEHM, JASON, CDC WASHINGTON 


BUCHANAN, RON, SC&A 


CHANG, CHIA-CHIA, NIOSH 


CHEW, MEL, ORAU 


ELLIOTT, LARRY, NIOSH 


FALK, ROGER, ORAU 


FITZGERALD, JOE, SC&A 


HOFF, JENNIFER, ORAU 


HOMOKI-TITUS, LIZ, HHS 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAUT 


KATZ, TED, NIOSH 


KOTSCH, JEFF, DOL 


LABONE, TOM, ORAU 


LIPSZTEIN, JOYCE, SC&A 


LITTLE, CRAIG, ORAU 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MCFEE, MATT, ORAU 


MEYER, BOB, ORAU 


NETON, JIM, NIOSH 


RICH, BRYCE, ORAU 


SHARFI, MUTTY, ORAU 


SHIELDS, LASHAWN, NIOSH 


SMITH, MATTHEW, ORAU 


SUNDIN, DAVE, NIOSH 


ULSH, BRANT, NIOSH 

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P R O C E E D I N G S


 (9:30 a.m.) 

WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO
 

DR. WADE: We’re about ready to begin. This 


is Lew Wade, and this is a meeting of the work 


group on Rocky Flats site profile and SEC 


petition. That group is most ably chaired by 


Mark Griffon, members Gibson, Presley and 


Munn. Ms. Munn and Mark are here in the room, 


and by voice I understand that Presley and 


Gibson are on the phone. Is that correct? 


MR. GIBSON (by Telephone): Yes. 


MR. PRESLEY (by Telephone): This is Bob 


Presley. 


 DR. WADE: Are there any other Board members 


on the call? 


 (no response) 


 DR. WADE: Any other Advisory Board members 


on the call? 


 (no response) 


 DR. WADE: Clearly then we don’t have a 


quorum of the Board, and that’s good. We will 

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proceed with the work group meeting. 


What I’m going to do is ask for Board 


members to identify themselves, then NIOSH 


team members, including the ORAU team, SC&A 


team members to identify themselves. Then 


I’ll ask other feds. I’ll ask petitioner and 


worker reps to identify themselves, members of 


Congress or their representatives. And then 


I’ll ask any others who would like to be 


identified for the record. 


A little bit of talk about phone 


etiquette to begin with, special attention 


today because Ray is not with us. Shane is 


with us and without Ray I think we need to be 


particularly careful to identify ourselves 


when we speak and speak clearly. 


Also, we’ve lived through all kinds of 


background noises from dogs barking to babies 


crying to elevator music. So keep an eye 


towards, an ear towards what goes on in your 


background. Mute when you’re not on. When 


you are speaking, don’t speak into anything 


but the handset. Don’t try and use a speaker 


phone. It creates all kinds of interference. 


As we go through the Board member 

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identifications, NIOSH and SC&A team member 


identifications, I would ask that all of those 


individuals identify their conflicts, if any, 


with regard to the Rocky Flats site. So we’ll 


start again with Board members, and here we 


have... 


MR. GRIFFON: Mark Griffon with the Advisory 


Board. 


MS. MUNN: Wanda Munn, Advisory Board, no 


conflicts on Rocky. 


 DR. WADE: And on the line? 


MR. GRIFFON: No conflicts either for Mark 


Griffon. 


 DR. WADE: Mike? 


MR. GIBSON (by Telephone): Mike Gibson, no 


conflicts. 


 DR. WADE: And Robert? 


MR. PRESLEY (by Telephone): Robert Presley, 


Board, no conflicts. 


 DR. WADE: And I assume there are no other 


Board members within the sound of my voice. 


 (no response) 


 DR. WADE: Okay, let’s start with NIOSH team 


members here around the table. 


MR. ELLIOTT: Larry Elliott, no conflict. 

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DR. ULSH: Brant Ulsh, NIOSH team, no 


conflict at Rocky. 


 DR. WADE: Okay, ORAU team. 


MR. MEYER: Bob Meyer, no conflict, NIOSH 

team. 

 DR. LITTLE: Craig Little, no conflict. 

 MS. JESSEN: Karin Jessen, no personal 

conflict. 

 MR. McFEE: Matt McFee, ORAU team, no 

conflicts at Rocky. 


 MR. SHARFI: Mutty Sharfi, no conflicts at 


Rocky. 


 MS. HOFF: Jennifer Hoff, no personal 


conflicts. 


 DR. WADE: Other NIOSH/ORAU team members on 


the telephone? 


DR. NETON (by Telephone): Jim Neton, no 


conflict. 


 DR. WADE: Good morning, Jim. 


MR. FALK (by Telephone): This is Roger 


Falk, and yes, I have a conflict. 


 DR. WADE: Good morning, Roger. 


MR. SUNDIN (by Telephone): This is Dave 


Sundin, no conflict. 


MS. BRACKETT (by Telephone): Liz Brackett 

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with the ORAU team, no conflict. 


MR. CHEW (by Telephone): Mel Chew with the 


ORAU team, no conflict. 


 DR. WADE: Good morning, Mel, welcome. 


MR. RICH (by Telephone): Bryce Rich with 


ORAU team, technically conflicted. 


MR. LABONE (by Telephone): Tom LaBone, no 


conflict. 


 DR. WADE: Other members of the NIOSH/ORAU 


team? 


MR. SMITH (by Telephone): Matt Smith, ORAU 


team, no conflict. 


 DR. WADE: Last chance. 


(no response) 


 DR. WADE: SC&A? 


MR. FITZGERALD: Joe Fitzgerald, no 


conflict. 


DR. MAKHIJANI: Arjun Makhijani, no 


conflict. 


 DR. WADE: On the telephone? 


DR. MAURO (by Telephone): John Mauro, no 


conflict. 


DR. LIPSZTEIN (by Telephone): Joyce 


Lipsztein, no conflict. 


 DR. WADE: Good morning, Joyce. 

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MR. BUCHANAN (by Telephone): Ron Buchanan, 


no conflict. 


 DR. WADE: Good morning, Ron. 


Other members of the SC&A team on the 


line? 


 (no response) 


 DR. WADE: Are there other federal employees 


on the line by virtue of their employment? 


MS. HOMOKI-TITUS: Liz Homoki-Titus with 


Health and Human Services. 


MS. HOWELL (by Telephone): Emily Howell 


with Health and Human Services. 


MS. CHANG (by Telephone): Chia-Chia Chang 


with NIOSH Director’s office. 


MR. KATZ (by telephone): Ted Katz with 


NIOSH. 


MR. BROEHM (by Telephone): Jason Broehm, 


CDC Washington office. 


MS. SHIELDS (by Telephone): LaShawn Shields 


with NIOSH. 


MR. KOTSCH (by Telephone): Jeff Kotsch, 


Department of Labor. 


 DR. WADE: Welcome, Jeff. 


Other feds here by virtue of their 


employment? 

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 (no response) 


 DR. WADE: Representatives of workers, 


petitioners, those directly involved in Rocky 


Flats? 


 (no response) 


 DR. WADE: Workers, petitioners, those 


directly involved at Rocky Flats? 


 (no response) 


 DR. WADE: Members of Congress or their 


representatives? 


MS. ALBERG (by Telephone): Jeanette Alberg 


with Senator Allard’s Office in Colorado. 


 DR. WADE: Good morning. 


Other Congressional representatives? 


 (no response) 


 DR. WADE: Any others on the line who would 


like to be identified for the record? 


 (no response) 


 DR. WADE: Okay, I think we’re done with our 


introductions. Mark? 


MR. GRIFFON: I see we have another small 


working group for Rocky Flats discussion. I 


e-mailed, but I’m not sure everyone has this, 


but it’s a very brief outline of an agenda to 


start us off, some of the primary issues that 

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remain on, frontloaded on this agenda. 


WORKING GROUP UPDATE
 

Well, actually, before we get into 


those items it might be worthwhile just to go 


through sort of where we’re at with this whole 


process, winding down toward a final 


evaluation report from SC&A. And it’s been a 


long haul obviously, but I think we’ve made 


quite a bit of progress, and I just want to 


point out some of the items that we’ve gone 


through in this process. 


Item number one, the Super-S, which 


has been on our matrix forever, I think we now 


have agreement on the model and I think the 


latest news from SC&A -- I don’t want to 


misstate this -- but I think that SC&A has now 


gone through the supporting cases that were 


not used as design cases. And they’ve made a 


determination that those also would be bounded 


by the design cases. So I think we’ve 


basically completed our review of Super-S and 


SC&A’s in agreement with NIOSH’s model and 


approach. Is that correct, Joyce? 


DR. LIPSZTEIN (by Telephone): Yes. 


MR. GRIFFON: Also, with the second item, 

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and this item involves three sort of sub-


items, but data reliability, safety concerns 


and logbooks reviews. The bottom line 


conclusion, I think there were, there still 


are some disagreements on some individual 


items within those reviews. 


But the bottom line sort of question 


was do we see any systemic problems, systemic, 


you know, problems. And SC&A has concluded on 


those three, that three-pronged review that 


they haven’t identified any systemic problems 


through that review comparing those items with 


the individual radiation files. So I think 


that’s a lot of progress. That was a lot. 


There were several items on that, involved in 


that. 


The third item, the other 


radionuclides, I think, well, I know that 


we’re down basically in our discussions to 


thorium, which we’ll have on the agenda today. 


But other than that we, NIOSH and the ORAU 


team, did quite a bit of research on these 


other radionuclides, and SC&A was comfortable 


with the approach described for the various 


other radionuclides on that original list. So 

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that’s off the table. 


The D&D worker question I think with 


as we’ve evolved here and NIOSH expanded their 


coworker model to cover that D&D period, and 


again, that gave us any comfort that there 


would be a bounding approach for these D&D 


workers with regard to internal exposures. So 


I think that D&D question is no longer an 


ongoing item. 


MR. FITZGERALD: Yeah, and I think we’ll 


talk about the O-14 extension that was the one 


remaining issue, and Joyce is on the phone. 


But I think that’s substantially completed. 


MR. GRIFFON: And the last thing, I guess, 


would be the coworker models for internal and 


external dose reconstruction. And I think 


that we had some disagreements, I think we’ve 


essentially concluded that any differences in 


the model basically at this point would be 


site profile issues, not necessarily SEC 


issues. So those models themselves, the 


coworker models I think are basically, there’s 


agreement there, or they’re not SEC issues. 


And I want to qualify that just a 


little bit to say that that’s not withstanding 

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the ongoing concern about the data that 


populates those models. So we still have some 


questions on the table about the data in those 


models. But the models themselves seem to be, 


I think we’ve concluded our discussions on 


those. 


So I just wanted to point out that as 


in introduction that we have made some 


progress. Sometimes I think we lose sight of 


that. 


 DR. WADE: Mark, can I ask you, your second 


was a brace of three: logbooks, safety 


concerns, and what was the third? 


MR. GRIFFON: Data reliability. 


MR. FITZGERALD: Data integrity. 


MR. GRIFFON: Data integrity, I’m sorry. 


MS. MUNN: And that’s more than just a 


little progress. That’s a staggering number 


of items that have been addressed. I don’t 


think it’s possible to be any more thorough 


than this group has been with respect to these 


issues. 


 DR. WADE: All have been well served by this 


group of people. 


MR. GRIFFON: So I think where we stand in 

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looking at the agenda for today, the items I 


wanted to look at first were the question of 


completeness, data completeness. And I know 


it’s been a separate agenda item, so I should 


have probably separated this ’69 data 


question, but those two sort of tie together a 


little bit. 


But those two items, then the thorium 


will be our next thing to discuss. And then 


the third item on my agenda is some updates on 


these other items. And some of those may be 


like Super-S, you know, I think that will be a 


fairly quick update, but I think SC&A’s 


completed that review and we can just hear 


SC&A’s report on that. 


The last item I have on my agenda, 


which I brought up at the last Advisory Board 


meeting, and this is this proof of process 


question. And we had some examples early on I 


think that were provided to the work group. 


But I feel like, well, first of all, I’m not 


sure that those original examples use the 


current coworker models. I don’t even know if 


coworker models were around when those were 


out there so I think we might have to re­
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examine... 


And parenthetically, I gave some 


possible examples of what I might want to see 


a sort of proof of process on, and we can 


discuss that further. I’m not sure if my list 


is exhaustive or appropriate. Those were some 


things that came to my mind that we may want 


to see, and we may, I would consider if NIOSH 


-- we can discuss this more later -- but if 


NIOSH could identify case numbers that use 


certain approaches. 


I don’t think, you know, we can keep 


those case numbers and the Privacy information 


off the record, but if they can point us at 


those cases, I think that would be more than 


adequate to meet that need so I don’t see 


additional work necessarily other than 


identifying the cases. 


All right, to start off, well, first 


of all, is there anything I missed on the 


agenda or any big items? There might be some. 


MR. PRESLEY (by Telephone): Bob Presley, 


what about the new item on here, the wound 


scenario question? 


MR. GRIFFON: Yeah, under these updates the 

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wound scenario question came up at the last 


work group meeting, and that was something 


that was brought up about specifically whether 


the sort of chronic inhalation approach would 


be bounding of a wound scenario when the 


wound, when there was no record of there being 


a wound so they didn’t know it was a wound. 


And I think Mutty and Jim Neton talked 


about maybe examining that and seeing if, in 


fact, it was in all cases going to be 


bounding. So we had a brief discussion on 


that. I don’t know if you, I thought we had 


it as an action item, but I was going to list 


this as an updated action item. Not a big 


hitter I don’t think but ... 


MS. MUNN: I was surprised when I saw it 


because I didn’t remember that we had an 


action on that. I know there was some 


discussion about it, but --


MR. GRIFFON: I’m pretty sure I’m right. 


Brant, am I wrong on that? I thought Jim --


DR. ULSH: I do recall that we talked about 


it. I don’t know --


MR. GRIFFON: I thought Jim said, you know, 


we need to look at this and make sure it is 

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bounding and maybe I didn’t capture it. 


 DR. WADE: I think they’re ready. 


MS. MUNN: It just wasn’t on my list of --


DR. NETON (by Telephone): I did discuss 


this with Dave Allen awhile ago, and I don’t 


have a complete report to talk about, but 


maybe the two experts we have on the phone, 


Liz and Tom LaBone might be able to help us 


out a little bit. 


MS. MUNN: Is the volume up as high as we 


can get it on that? 


 DR. WADE: Jim, could you just count to ten 


or something like that? 


DR. NETON (by Telephone): Pardon me? 


 DR. WADE: Could you count for us? We’re 


going to get the volume up. We’re having 

trouble hearing. 

DR. NETON (by Telephone): I was just saying 

I’ve discussed this with Dave Allen briefly, 


but I’m not prepared to provide a detailed 


report, but I think we have some, Liz Brackett 


and Tom LaBone on the phone. They might be 


able to help us out when we come to it, when 


we get there. 


 DR. WADE: Okay, thank you. That was much 

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better. 


DATA COMPLETENESS
 

MR. GRIFFON: So to start off the data 


completeness report, and I think this is the 


52 cases that were reviewed. And I forget the 


breakdown. There were some production workers 


and some randomly selected, but it totaled 52 


individual radiation files were reviewed. 


And I guess the purpose of the, the 


overall purpose of this was to make sure that 


there was, that the data within radiation 


files in general for Rocky Flats workers for 


the entire class was complete enough, was 


adequate for dose reconstruction. And I think 


that I just wanted to make sure that we 


discuss it. We’re looking at can we do dose 


reconstruction for the entire class at hand 


here for all organs of interest. 


So that’s kind of where, that was our 


rationale for doing this sampling in the first 


place was to see if we randomly select and we 


picked claimants’ files only because they were 


more readily available rather than picking 


radiation files from out of the database. And 


it would have been a lot more work to find 

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those radiation files. So SC&A provided a 


report. I think we all, that was submitted to 


NIOSH, ORAU at the last work group meeting. 


Is that correct? 


MR. FITZGERALD: Yeah, --


MR. GRIFFON: Or shortly before the meeting? 


MR. FITZGERALD: -- the scoping of that was 


very specific of the work group on what we 


were to cover. It was just strictly --


MR. GRIFFON: Yeah, the scope of that was 


basically for -- just a point of 


clarification, I guess -- SC&A’s scope was to 


sort of do a screening, look for these data 


gaps and identify them. And I think, at least 


it was my understanding, and I’m pretty sure 


that we had discussions about this, that these 


data -- and we even discussed it in the last 


work group meeting -- that SC&A did identify 


some data gaps, but they did not walk through 


the work histories or compare to the radiation 


monitoring policies or practices of that time 


period. 


Rather, they were just going to hand 


that over and say, okay, NIOSH, you’ve got 


more of that information available anyway. So 

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these are sort of potential, you know, gaps 


but maybe not unexplainable gaps. But that is 


how it was set up. 


And we’ve now got a response from 


NIOSH which came in, I’m not sure on the dates 


again, a week or so ago. 


MR. ELLIOTT: Yeah, a week ago. 


MR. GRIFFON: So I guess we can ask, maybe 


Brant can summarize what the findings are on 


that. 


DR. ULSH: I do have copies of our report on 


the data completeness issue and a separate 


report specifically on 1969 and ’70. I’ll 


circulate those around the table if anyone 


wants to have a copy while we talk about this. 


And there is one other handout that I 


want to send around, but I have to issue a 


note of caution here. This last handout 


contains what are called job history cards, 


and there is Privacy Act material in here. So 


feel free, Board members, SC&A, to take it 


home if you’d like to, but don’t leave it 


laying here on the table. Get it back to me 


if you’re not going to take it. 


DR. MAKHIJANI: Brant, are you going to make 

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this electronically available? 


DR. ULSH: It is electronically available 


now. 


DR. MAKHIJANI: On NOCTS? 


DR. ULSH: Yes. All the job --


DR. MAKHIJANI: No, no, I mean the 


compilation. I know the individual histories 


are there on NOCTS. This particular Word 


document, are you going to, the new one, the 


new one that you said you’re sending around? 


DR. ULSH: Arjun, there are three things 


coming around. The first two are our reports. 


DR. MAKHIJANI: Which I have. 


DR. ULSH: Which you have. And the last one 


is just an example job history card. That’s 


all. 


All right, so just to add a little bit 


to Mark’s summary --


MS. HOMOKI-TITUS: Brant, can I just follow 


up? 


DR. ULSH: Yes, please. 


MS. HOMOKI-TITUS: This document that Brant 


just sent around that has all of the Privacy 


Act information in it, please be very careful 


when you’re referring to it on the record 

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because there’s a lot of information that 


could make it possible to identify an 


individual. So you need to be careful about 


what information you pull out of here when 


you’re making statements on the record. 


DR. ULSH: I’ve blacked out things like the 


name, social security number and all that, but 


the job exposure -- sorry -- the job history 


itself is specific to a person so like Liz 


said, let’s just refer to that in the 


abstract. 


 DR. WADE: And I might make a brief comment 


as well. Mark mentioned that this has been a 


long and arduous process, but it’s been a 


rapidly evolving one. So the work group 


decides to pursue a certain line of inquiry 


and documents are generated by NIOSH, 


documents are generated by SC&A, not in all 


cases do we have the ability to have those 


documents reviewed. 


So documents will come in front of the 


working group, in front of the NIOSH and SC&A 


participants, that haven’t been scrubbed for 


Privacy Act consideration. That serves the 


process. Certainly, we’d like to have 

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everything scrubbed and available to everyone 


when we discuss it, but that’s not always 


possible as this is very rapidly evolving. 


So again, to those people who are not 


part of NIOSH, SC&A, the teams, the work 


groups, some of these documents might not be 


in your possession, and we apologize for that. 


But again, rather than delay the process or 


slow the process, this is the course of action 


we’ve chosen, and I think it’s the appropriate 


course of action. Thank you. 


DR. ULSH: To go to our report on data 


completeness, the data completeness 


evaluation, as Mark mentioned the 52 case 


files that were selected by SC&A for review 


consist of -- let me make sure I get this 


right. There were 32 randomly sampled, and 


then there were 20 that we categorized as 


individuals who had received high cumulative 


exposures. So that totals 52. 


SC&A started out by reviewing 12, and 


I think sometime in December presented those 


results. And it was agreed by the working 


group that we should expand the scope of the 


review. And that’s how we wound up with 52. 

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In January, SC&A, on January 10th, SC&A 


issued their report on their data completeness 


evaluation of the 52 files. And then as Mark 


mentioned, the NIOSH response to that was 


issued last week, Wednesday. So that is out 


now. 


As Mark mentioned, and I think Joe 


also mentioned, SC&A’s analysis consisted of 


categorizing the time periods for these 


workers when they had monitoring available, 


and time periods when there was no monitoring 


records in their file. And NIOSH agrees that 


there are time periods when workers don’t have 


monitoring records in their file. 


I think where we perhaps diverged is 


the significance of those. In the main body 


of SC&A’s report, they really did not talk 


about the significance of the data gaps as is 


appropriate because you can’t really tell what 


the significance of those gaps are without 


doing the kind of analysis that NIOSH has now 


done where you look at the radiation files in 


detail and also at the job history cards which 


are available in NOCTS for numerous employees. 


It’s only after those kinds of 

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reviews, reviews of that kind of data that you 


can come to any conclusion about whether or 


not any data is missing. And that’s where I 


think that we took issue with some of the 


conclusions of SC&A’s report when there were 


gaps or when there were periods when there was 


no monitoring data available. And the 


conclusion was then drawn that this data was 


missing. 


And I cautioned about that a couple of 


times in the past, and that has, I think our 


analysis has shown that that caution was 


justified because what we found of the 52 


cases, first of all it, it should be noted 


that dose reconstructions had been completed 


for 48 of the 52 cases. There are four that 


are still in process. 


There are none identified that we’ve 


concluded we can’t do dose reconstruction. 


And it’s also worth noting that I think there 


was only one of those that used coworker data. 


DR. NETON: Correct. 


DR. ULSH: Correct? Okay. And for these 52 


cases we found that 60 percent of them had a 


probability of causation greater than 50 

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percent. 


Now for the cases, we looked at each 


individual case, each of the 52, and what we 


found was where there were periods with no 


monitoring data, the most common explanation, 


well, there were two that were pretty common. 


Number one, the employee wasn’t at the site 


during the time when there was no monitoring 


data, and so you certainly would not 


categorize it as missing data. I mean, that’s 


appropriate that there is no monitoring data 


for them in that situation. 


The other common occurrence was if you 


look at the example job exposure card that 


I’ve sent around. Now these cards are 


available in NOCTS for employees of the prime 


contractors. So throughout Rocky Flats’ 


history, Dow employees, I think Kaiser came 


too late. These cards -- now this is just my 


anecdotal recollection -- these cards were 


available up into the 1980s, and I didn’t see 


any for the latter part of the ’80s and into 


the ‘90s. So I think they discontinued the 


use of these cards. 


But if you take a look at the example, 

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what you can see here is it lists occupations, 


and in many cases, well, it lists the 


department where they worked. I don’t want to 


talk in detail, for Privacy Act reasons, about 


this example, but I just wanted you to see the 


kind of information that is available for many 


of the claimants. This was one resource that 


we relied upon to determine whether or not the 


periods with no monitoring data represented 


missing data or whether they were readily 


explainable. 


Now there are certain employees where 


we don’t have these cards, for instance, 


subcontractors. We don’t have these cards for 


subcontractors so we got clues to their 


employment of information in the radiation 


files themselves. You’ll see, I don’t know. 


I don’t remember the name of the 


actual document that’s in there, but it’s kind 


of like a pay stub or that kind of thing. And 


it tells what company they worked for. S&W 


was common, Swinnerton & Walberg (ph) and also 


Lumnes (ph). So we get data on those people, 


on the subcontractors, from a different source 


than these cards. But by and large we’re 

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talking about employees of the prime, so we’ve 


got detailed job exposures -- I’m sorry, I 


keep saying that -- job history cards. 


And what we looked at in these job 


history cards were when SC&A identified a 


period where there was no monitoring data, and 


we also looked at the file and saw the same 


thing, we asked ourselves, well, is there a 


reasonable explanation considering the badging 


policies in place at the time for this person 


not to be monitored. Or is it a situation 


where you would expect this person to be 


monitored because he had a significant 


exposure potential. 


And an example might be an operator in 


Building 71. If you looked and there was a 


period where that person was not monitored, 


and you determine that he was onsite, that 


would be kind of surprising if he didn’t have 


data because those were some of the higher 


employment, higher exposure potential 


employment positions at the site. 


On the other hand if you looked and 


you saw job titles and work locations that did 


not indicate high exposure potential, an 

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example might be a janitor, then it might be 


entirely reasonable that that person would not 


be monitored because over time with the 


badging policies in place at the site, people 


who had the potential to receive greater than 


ten percent of the tolerance level were 


required to be monitored. If they weren’t 


expected to have that exposure potential, then 


it was not mandatory that they be monitored. 


So what we found in the 52 cases, keep 


in mind that these 52 cases represent hundreds 


of man years of monitoring data. And they 


also, there are two types of data that were 


looked at, external dosimetry data, that’s the 


film badge or TLDs that you wear to monitor 


external radiation. And then there was also 


internal monitoring data, bioassay data. So 


this would have been urinalysis, lung counts 


and those kinds of things. 


So if you take 52 individuals, 


multiply by the number of years that they were 


employed, you get hundreds of man years of 


monitoring data, both internal and external. 


And what we found was that there was one gap 


where it represented missing data. There was 

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one person who had one year of external 


monitoring data that was not present and that 


was clearly noted in his file. And it’s 


legitimate to conclude in that case that is 


missing data. 


There were no other cases of missing 


data. There were ready explanations 


available. Either the person wasn’t onsite 


during the time or he was working in a 


position where there was low exposure 


potential and would not be expected to be 


monitored. Therefore, we concluded that the 


monitoring data for these 52 individuals was 


essentially complete with that one exception 


of one year of external monitoring data. 


It should also be noted, as I 


mentioned, that for that one case where there 


was legitimately missing data, we were able to 


complete a dose reconstruction with a 


probability of causation of greater than 50 


percent. Therefore, there is not a single 


case among these 52 where the data is missing, 


except for that one instance, and more 


importantly, where the data is so incomplete 


that we could not complete a dose 

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reconstruction. 


So that was the conclusion of our 


report on that. Now, Mark, I can hold off. 


Do you want to discuss this before I get into 


’69 and ’70? 


MR. GRIFFON: Yes, I guess we’ll take them 


one at a time. 


Joe? 


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


Arjun address this. But I just want to 


clarify on this issue of scope and charge that 


we approached this from a standpoint of the 


working group’s express request to develop a 


sampling plan and to actually sample the, at 


random, the frequency and extent of gaps. 


Now these gaps were initially 


identified in the 12 cases that I think Arjun 


and Ron presented early in the fall. And we 


got into November the charge from the work 


group was to expand that through a sampling 


plan and to focus on identifying gaps in terms 


of frequency and magnitude. 


The charge beyond that was simply to 


then provide that information to NIOSH and for 


NIOSH then to -- as they have -- to 

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characterize the implications and the 


explanation for these so-called gaps. And 


again, I think we appreciate and were very 


careful about the distinction between 


ascribing and implication that the data’s 


missing for a gap. So the context of our 


sampling was to identify gaps. 


Arjun. 


DR. MAKHIJANI: Thank you. Yeah, in regard 


to this missing gaps, I agree, Brant, that it 


came up and there was that caution. And we 


actually took that caution quite seriously. 


If you look at the report on completeness, the 


word missing actually doesn’t appear in the 


report itself. 


Unfortunately, in one summary table 


the word missing was left in the summary table 


numerous times and then one other place where 


it’s in a comment. And it’s clearly 


inadvertent. The word missing actually 


doesn’t appear in our analysis. And as I 


said, it appears inadvertently in one summary 


table. That’s it. 


The individual cases where there are 


gaps in the data in the tables themselves of 

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the cases are all identified as gaps. And so 


it’s rather surprising that when NIOSH quoted, 


cited SC&A’s individual case characterization, 


it was noted that we said it was missing data 


when the individual line items actually say 


gaps. And so I thought we settled that issue. 


And the analysis actually, we did look 


at one aspect of the jobs in the sense that we 


did conclude that the non-monitored workers 


were not in plutonium areas and that the 


external gaps were, dose gaps were 


concentrated in the 1950s. And so along with 


identification of the gaps, that much was 


handed to NIOSH. 


Our overall conclusion is a little bit 


different than what was characterized by 


NIOSH. I’d like to mention that briefly. 


NIOSH concluded that our position seems to be 


that any lack of complete data record 


automatically makes it impossible to 


reasonable, to make dose when my reading of 


what we said was sort of the opposite of that. 


I thought we said that the gaps don’t 


indicate that you can’t, you shouldn’t 


automatically conclude that you can’t estimate 

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dose. I just would like to read that for the 


record because in my impression, what we 


explicitly said was the contrary to what’s in 


NIOSH’s report. 


We said it might be possible to fill 


in the gaps using the data from Rocky Flats 


and other sites for uranium, external, shallow 


and deep dose provided that additional 


analysis as regards claimant favorability 


relating to actual working conditions is 


carried out. However, no firm conclusion is 


possible at the present time since NIOSH has 


not done the requisite analysis including, for 


instance, about shallow dose exposure 


conditions in the uranium foundry operations 


in the 1950s. 


So we explicitly have an open door 


about the possibility of dose reconstruction 


to fill in the gaps using Rocky Flats and 


other data. So I think, well, I leave it to 


NIOSH whether they want to amend the report. 


But at least our report is very clear on that 


point. 


We haven’t had a chance to, there’s a 


lot of paper on the table and, of course, we 

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will be completing our report after a full 


reading of that. So it’s not possible to 


fully respond to everything. But I just 


wanted to make a few observations about what’s 


on the table from NIOSH’s side and its 


analysis, and what we had been looking for 


when we described the gaps and the extent of 


the gaps. 


So the main point that NIOSH has made 


about completeness and dose reconstructability 


is that almost all, in the 52 cases almost all 


the dose reconstructions are complete; and 


therefore, this is a demonstration that 


there’s a feasibility of dose reconstruction 


with sufficient accuracy under 42-CFR-83. And 


as I see it those two propositions are kind of 


different because 42-CFR-82 allows you to do a 


lot of things, but they don’t fall under the 


rubric of 42-CFR-83. 


Specifically, out of these dose 


reconstructions, actually, may I read a couple 


more that are completed at least in our 


preliminary evaluation? Maybe they’re not 


settled yet with the claimants, but there is a 


dose reconstruction file (inaudible) 52. And 

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under those 31 have been compensated and 19 


have not been compensated. 


Out of the 31 that were compensated, 


28 were minimum dose reconstructions. Minimum 


dose reconstructions by definition are not 


bounding dose reconstructions. Research had 


been cut short for efficiency purposes. This 


is beside the point for demonstrating a 


bounding dose reconstruction under 42-CFR-83 


where you have to show that you have an upper 


limit reasonable dose that can be used for 


compensation or denial. 


So of these 28 there were some partial 


dose reconstructions that were done using only 


internal dose, some only external dose. One 


was actually only medical dose which we have 


not discussed in an SEC context, and one was 


external and medical both. 


Of the ones that were denied there 


were 19. And out of that, 15 were maximum 


efficiency doses so far as we could see. And 


this is a preliminary reading. We haven’t had 


a chance to actually examine all of these 


things in detail and a few all have contrary 


information -- and please correct me -- but as 

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we noticed in 15 out of the 19 cases, TIB 002 


had been used which is explicitly an 


efficiency tool to calculate, to cut short 


research to be able to deny somebody without 


undue delay. 


And this is not a dose reconstruction 


approach that would be applicable for 


calculating a bounding dose. Efficiency 


methods of cutting short research belong in 


42-CFR-83 and not under 42-CFR -- I mean 82, 


and not under 83 for the purpose of 


demonstrating the ability to do a dose 


reconstruction. And we found coworker data 


was used only in two cases in, rather than 


one. Maybe it’s one that’s not yet been 


completely settled with the claimant so far as 


our file is concerned. 


In actually using the data, and we 


haven’t gone through all of it as yet, it 


appears that the zeros and gaps in the record 


seem to have all been treated as being under 


the limit of detection because the coworker 


model was used only twice I think. And we 


haven’t actually looked to see as to how it 


was applied and whether it corresponded to any 

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of these gaps. 


So in brief, even if dose 


reconstruction had been completed under 42­

CFR-82 and without making any comment about 


those dose reconstructions themselves, it 


doesn’t address the issue that we raised which 


was specific to the kinds of workers who were, 


the class of workers who were not monitored, 


the exposure potential for some of those 


workers which according to documentation in 


the early periods may have been high. 


And we specifically called attention 


to foundry workers in the 1950s. So far as we 


could tell none of the 52 cases had any 


foundry work in the 1950s. We may be wrong. 


We have to look at the job category more 


carefully. But on a preliminary look, I did 


ask Ron Buchanan to look at it. 


Ron, are you on the phone? 


MR. BUCHANAN (by Telephone): Yes, I’m here. 


DR. MAKHIJANI: Ron, could you describe your 


search a little bit, please? 


MR. BUCHANAN (by Telephone): This is Ron 


Buchanan with SC&A. I went through the 52 


cases and looked at the personnel exposure 

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cards which I think you’re calling the job 


history cards and to see what their job 


assignments were and usually that’s gives the 


building and a job title. I looked through 


those 52 cases and I do not find any foundry 


workers in Building 44 or 444 in the 1950s. I 


found one worker that had some work in 


. 


DR. MAKHIJANI: So the issue on the table in 


data completeness in regard to external data 


in the ‘50s identified a sub-class of workers 


hadn’t been addressed so far as we can see in 


the NIOSH analysis. There was one piece of 


data in regard to foundry workers that is in 


NIOSH’s report -- and if there are more, 


Brant, please correct me because I’ve gone 


through a lot of paper in a short period of 


time. 


That piece of data related to the mean 


doses for foundry workers in 1968 and only the 


mean doses were provided. The distribution 


was not provided. There’s no substantive 


discussion on how that relates to the 1950s or 


establishment of working conditions in the 


1950s. And that’s particularly relevant 

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43 

 

 

 

because (ph) document from 1982 that 


was quoted in SC&A’s analysis identified 


particularly the early years that Building 444 


as being particularly problematic. 


Now, NIOSH seems to not have accepted 


that analysis in the sense that dose 


measurements are regarded as contact doses 


that don’t necessarily indicate high exposure 


potential. And then the high dust identified 


in the document is also dismissed 


essentially. I don’t want to unfairly 


characterize it so let me just kind of refer 


to the NIOSH document itself. Give me a 


moment to find it. 


And I’m just reading it as it is 


written there. The concern expressed about 


dust high in Thorium-234 and PA-234M would 


seem to be unfounded. First, given the nature 


of foundry work, it seems unlikely that large 


amounts of dust would have been created that 


contained these two radionuclides. Second, 


very little skin would have been exposed for 


dust accumulation. Finally, given that any 


contamination on the skin was easily removed 


by washing, it would not have accumulated. 

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Now the first statement about the 


concern regarding dust being unfounded is 


contradicted largely by the 


document. It said that dust which was 


generated in burnout and breakout areas and 


settled on various pieces of equipment. 


And from there there were additional 


beta radiation fields generated. This also 


resulted in excessive dust in the atmosphere. 


Now, he feels it was well handled, but this 


appears to be primary documentation from Rocky 


Flats about high dust in the 444 atmosphere 


and also the high dose potential is documented 


here. 


So we’re not, at least on this first 


reading, in accord with NIOSH’s statement 


about exposure potential. There is some 


documentation about foundry workers from 1969, 


if I can just refer to that even though it’s 


in the other paper because it directly 


concerns foundry workers. Maybe we can just 


discuss the foundry issue as a whole. 


That’s in an unnumbered table, but 


it’s on page, there’s no page numbers on this 


document so it’s on page three anyway. The 

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title of the table is 444 Foundry Workers 


Exposures by Year Penetrating Skin Dose in 


Millirem. It shows four quarters of data for 


1968 and four for 1969. And it shows that the 


workers had zeros in 1969, the first three 


quarters, essentially indicating the kind of 


zeros we’ve been talking about, that their 


badges weren’t read and zeros were entered. 


And then it shows a fourth quarter 


measurement for the workers, which were done 


for these seven foundry workers. And actually 


this data indicates that this idea that it was 


generally ten people who were not badged or 


people who were badged and their badges were 


not read had less than ten percent of their 


exposure potential, this data actually doesn’t 


validate that assumption. 


Now, we went through this at Y-12 in 


that, you know, they may have made their 


judgment with the best of intentions, but as 


the data stand one worker did not return their 


badge. The data for six workers in the fourth 


quarter of 1969, out of those six workers, 


four of them had more than ten percent of the 


exposure potential for penetrating dose 

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because ten percent of the exposure potential 


for the quarter is 125 millirem. And for 


shallow dose one had more than the ten percent 


of the exposure potential out of six. 


That’s a limited set of data, but it’s 


not a very good validation of the idea that 


exposure potential was generally less than ten 


percent, and that the calls that were made for 


those who were not badged, or in 1969 those 


whose badges were not read, were correct. 


And so the implication of this for the 1950s 


when many of the workers were not badged don’t 


actually justify the conclusions that NIOSH 


has made that the concern about the exposure 


potential were unfounded. 


Specifically, the idea that when there 


are zeros in the records they can be replaced 


by LOD or limit of detection or the limit of 


detection divided by two for the gaps does not 


appear to be justified as a uniform policy. 


So that the zeros that are there, the ones 


that are gaps, have to be distinguished from 


the ones, from the badges that were read and 


where the reading was below significant 


detection. So it’s a fairly significant issue 

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there. 


The other sort of example that NIOSH 


has provided about the ability to do dose 


reconstruction and the availability of data to 


fill in the gaps relates to Building 81, 


enriched uranium, and actually provided more 


data here for 1960s. And that’s on page five 


of NIOSH’s completeness report I believe. I 


have my version with all my comments on the 


side so I don’t know whether my page numbers 


are right. 


DR. ULSH: I think you’re correct, Arjun. 


You’re talking about the table on page five, 


right? 


DR. MAKHIJANI: It’s at the bottom there. 


And so it does appear that the Building 81 


workers have identified and identifiable 


doses. And in the example given we agree with 


NIOSH that the coworker models weren’t applied 


in the example given for that year. The 


coworker model doses are clearly more than the 


extrapolated doses for one year from the 


fourth quarter. 


But as NIOSH says, there were no data 


for this group of workers in the 1950s. And 

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the main problem identified for external dose 


in terms of data gaps at Rocky Flats was for 


the 1950s. NIOSH has given two reasons, and 


then there’s a similar demonstration for ’61, 


and we agree with that demonstration and 


NIOSH’s characterization of it. 


 DR. WADE: There is someone breathing very 


heavy on the telephone so I would ask you to 


mute or if mute’s not possible to take the 


mouthpiece away and just listen because we’re 


hearing from others on the phone that they’re 


having great difficulty following. So please 


deal with that situation. Thank you. 


DR. MAKHIJANI: On page seven of NIOSH’s 


paper at the top there are two bullet points 


explaining how the presented data can be 


applied to the 1950s. And these are very 


qualitative. They don’t actually present an 


analysis, and they don’t present any 


references or documentation as to the 


assertions.
 

The first rationale is that the amount 


of enriched uranium processed increased 


throughout the 1950s and plateaued in the 


early 1960s. Therefore, the source term in 

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the early 1960s was higher than the source 


term in the 1950s. We’ve discussed this 


particular kind of rationale for estimating 


individual doses before in several contexts, 


and the main one in which this one can be 


applied actually to an individual dose is when 


you’re going from a worker who would be 


working for a few hours or part time to full 


time and when work is increasing so that the 


number of hours of an individual’s work goes 


from part time to full time. 


But if you have ten full-time workers 


and then you have 50 full-time workers, it 


doesn’t indicate that the ten full-time 


workers had more doses than the 50 full-time 


workers. Those are determined by the working 


conditions for those ten workers. And there 


are many conditions in which there are few 


workers but high exposures and then many 


workers had lower exposures and that just 


depends on the conditions. 


And so unless there’s some kind of 


data that indicated that enriched uranium 


workers, part-time work, in the 1950s, I think 


this particular argument doesn’t appear to be 

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germane for individual dose reconstruction. 


You know, number of hours per year and so on 


is germane for the thorium discussion when 


agreed that it was part-time work in the light 


machining or whatever would come to that. It 


doesn’t seem to be germane here, at least 


there’s not data that’s presented to indicate 


that it is applicable. 


And then the second is that there were 


no major changes in Building 81 configuration 


shields, for example, shielding improvements, 


et cetera, that would have depressed doses the 


workers received in the early 1960s. So that 


there’s the argument that, inference that you 


can actually assume that workers to the doses 


in the ‘50s were similar to those in the early 


‘60s. 


Now, there’s no documentation or 


references where we can see that there were no 


major changes, but accepting it on face value, 


there are lots of instances where you can find 


considerable variations in working conditions 


from one week to the next that are documented 


especially in the 1950s throughout the weapons 


complex. 

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And I think in the absence of data or 


some kind of demonstration it’s at least hard 


for us to accept this argument at face value 


that because there were no major, physical 


infrastructure changes that that automatically 


means that your doses in the 1960s would bound 


the doses in the 1950s. 


Generally, there was a trend of 


declining doses from the ‘40s and ‘50s into 


the ‘60s and ‘70s in the weapons complex with 


some exceptions in particular places and times 


and operations but an unmistakable trend so 


far as my experience indicates. And so this 


particular rationale as a general rationale I 


think doesn’t demonstrate that a bounding dose 


can be developed from the 1960s data. 


So in sum we’re kind of left without a 


substantive demonstration under 42-CFR-83 that 


dose reconstruction of sufficient accuracy can 


be done for this group of workers who were 


either not monitored or their badges were not 


read in the 1969-’70 period. Again, it’s not 


to say that this can’t be done or that 


suitable models can’t be created or even that 


the existing coworker model wouldn’t cover the 

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situation. 


But none of the arguments presented, 


whether it’s the 52 cases dose reconstructions 


or the specific analysis of enriched uranium 


and 444 operations addresses the issue 


substantively for the 1950s. For the foundry 


workers it’s unclear how long that issue might 


go on. For enriched uranium workers I think 


there is a convincing demonstration for the 


two years for which there is data. The 


coworker model does envelope the available 


data for those workers. 


Let me just stop there. 


DR. ULSH: Perhaps I can respond. 


MR. GRIFFON: Can I just ask one thing 


before we get into the details of Arjun’s 


comments. It struck me, too, the cases, not 


all of them, but many of the cases it seemed 


to point out that the fact that they could 


complete those and I’m not sure. I wonder 


about the relevancy to what we’re, the task at 


hand was really look at these cases. 


MR. ELLIOTT: But who picked the cases? Who 


selected the cases? I mean, they were 


randomly selected. 

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MR. GRIFFON: Right. 


MR. ELLIOTT: Why didn’t we go after the 


foundry cases first if that’s what --


DR. ULSH: I’ll perhaps address that. 


MR. GRIFFON: Yeah, we can address the 


foundry thing separately, but I’m, the point 


is the cases were randomly selected. We all 


agreed that the claimants would be the easiest 


population to sample from. But the question 


that is before the work group and the Board is 


can NIOSH reconstruct dose for the entire 


class and for all organs of interest. 


Now just because you can do one, just 


because a case was completed, I think it’s 


kind of irrelevant to answering that question. 


That’s all I’m saying. Am I wrong? I mean, 


you seem to state that again and again. I’m 


not disputing whether it can or cannot be done 


in each case, but is it relevant to that 


answering our ultimate question? That’s what 


I’m trying to get at. 


DR. NETON (by Telephone): This is Jim. I 


think that there’s fairly compelling evidence 


though that once we went through these cases, 


the whole point of the data completeness issue 

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is the work group wasn’t convinced that they 


thought we were, they thought that we would 


have to rely more substantially on coworker 


models. In all these cases I think it was 


shown that only two relied on coworker models 


in general. It may have been the case that, 


at least in this random sample, that they 


aren’t heavily relied on and that was the 


whole point of doing this data completeness 


evaluation. 


DR. ULSH: There’s another --


MR. GRIFFON: Yeah, I don’t think that was 


the whole point. I think --


DR. NETON (by Telephone): Why were you 


worried about data completeness other than 


when they rely more heavily on a coworker 


model than you heretofore believed? 


MR. GRIFFON: Because originally we were, 


that was suggested to us that the coworker 


model was going to be relied on for a couple 


cases. And then we asked that question. We 


got a different response later because I think 


-- maybe not a different response, but a more, 


it was examined further once the coworker 


models were fully --

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MR. ELLIOTT: I that’s been taken out of 


context. I think what Brant said early on, 


and the transcript will show that his remarks 


about use of coworker data were relative to 


the claims that had already been 


reconstructed. And that we knew that there 


were some claims ahead of us that we’d have to 


develop coworker datasets for. Am I correct 


in my understanding of that, Brant? 


DR. ULSH: What I said at the time was I 


said at this time there are two cases that we 


know of that would have to rely on coworker 


data. This was, I don’t know, some time last 


year, middle of last year --


MS. MUNN: Yes. 


DR. ULSH: -- I don’t remember when. I 


would have to look at the transcript to be 


sure, but I think I said at the time that, you 


know, there are still X number of claims that 


we have not completed, and I can’t tell you 


what the reliance on coworker data will be 


there, but it looks like we are going to have 


to use it far less than at other sites. I 


said that then. I maintain it today. My 


decision is not --

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MR. GRIFFON: Yeah, I don’t want to drag 


this down into pulling out transcript quotes 


as has been done in some reports, but I might 


look at the Denver (Blackberry interference) 


report if people are interested. But I mean, 


we got the impression that there was going to 


be very little reliance, and now I agree 


there’s probably still not a great reliance on 


the internal dose (unintelligible) more 


reliance on the external it would seem is 


where I think is where we’re at. And I just 


want to move. I’m not trying to point any 


fingers, I just want to try to move forward. 


 DR. WADE: Let’s deal with Mark’s question. 


Arjun raised it and I think it’s easily dealt 


with. I mean, there was the 52 cases were 


looked at, certain data gaps were identified. 


NIOSH has gone through a fairly complete job 


of identifying them. But in the body of the 


NIOSH report, there contains the logic that 


this represents proof that we can do dose 


reconstruction with sufficient accuracy. 


I think that’s not necessary to say 


because as Arjun points out many of the dose 


reconstructions are overestimates or 

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underestimates. It doesn’t need to be said. 


The statement adds nothing to the debate, and 


I think it creates a false impression. 


DR. ULSH: There were a lot of issues in 


Joe’s comments and then Arjun’s comments and 


the comments now. The reason that we talked 


about whether or not dose reconstructions were 


complete is because that, at the bottom, is 


the whole reason that we’re looking at this. 


Is the data sufficient to do dose 


reconstructions of sufficient accuracy? Now, 


it was certainly true --


MR. GRIFFON: For the entire class for all 


organs of interest. I mean, that’s --


DR. ULSH: Okay, so we approached this data 


gap question with two questions in mind. One, 


do gaps exist, and two, if they do exist, do 


they prevent us from doing dose 


reconstructions. We have tools that let us 


deal with situations where the record is less 


than complete, and they are the tools that you 


have mentioned: overestimates, 


underestimates, coworker data, et cetera. 


So to answer the question do we have 


data sufficient to do dose reconstruction, you 

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have to look at were we able to do the dose 


reconstruction even if there were situations 


where the data was incomplete. And I have to 


stress that we found, by and large without one 


single exception, the data were complete in 


the first place. 


Furthermore, we had sufficient data to 


do dose reconstruction, and that’s why we 


made, we put that analysis in the data about 


whether or not we had been able to do a dose 


reconstruction. I mean, that’s the bottom 


line question right there. So let’s talk 


about, there were a lot of different issues, 


and I think we’ve talked about a couple of 


different groups of workers, and there’s a lot 


of issues being conflated here that I think we 


need to de-convolute. 


First, I think when Joe summarized the 


scope of SC&A’s analysis, I’m in complete 


agreement that that was the scope of SC&A’s 


analysis, that you all were going to look at 


when data was present and when it wasn’t. 


That was the task. That’s the way I remember 


it, the task put before SC&A for the working 


group. 

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Where I have a little heartburn is the 


situations that Arjun mentioned calling them 


inadvertent where the attachments to this 


report, there were in fact two spreadsheets 


where they concluded the data were missing. 


And if you want to back off of that 


characterization that’s fine. 


But my heartburn with that 


characterization is that that is 


misinterpreted by members of the public and 


Congressional representatives. When they hear 


that data is missing, then that forms the 


basis of bills in Congress. It forms the 


basis of beliefs by members of the public that 


there are gross problems with these records, 


and that is simply not true. And that is what 


I have real heartburn about. 


DR. MAKHIJANI: Can we settle that, please? 


DR. ULSH: Yes. 


DR. MAKHIJANI: If you look at, we conceded 


that term missing was not appropriate. We 


said that the term missing is not used in the 


analysis at all, and if I’m wrong, please 


correct me. The term missing appears really, 


essentially in one table, Table 3 of 

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Cumulative Analysis which is only a summary. 


It’s an error. It’s inadvertent. We 


certainly called attention to the fact that it 


was an error, and it will be corrected. 


But if you look at the actual 


compilations, Table 1, Table 2, data 


compilation gap 1980, gap -- I personally went 


through and changed all of these things where 


it previously said missing in the first draft. 


We had our discussion. You pointed this out. 


I know that I personally changed these things. 


Now, we’ve had a lot of things with sending 


them for Privacy review, you know. There has 


been a lot of versions of paper floating 


around, and I truly regret that there was one 


summary table and with the word missing 


unfortunately it appeared maybe ten times. 


DR. ULSH: Twenty-four. 


DR. MAKHIJANI: What? 


DR. ULSH: Twenty-four on one table, 20 on 


the other. But I think we’re --


DR. MAKHIJANI: You’re looking at the wrong 


version of the tables. I got this off of your 


website, our report on your website. 


DR. ULSH: Okay, well, I’m looking at the 

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61 

version that when I objected to this at the 


January 9th working group meeting, you sent a 


message to Joe, and Joe forwarded it to me. 


It said being responsive to Brant’s comments, 


and that was my objection to the use of the 


word missing. The spreadsheets that were 


attached, and there are two, contain the word 


missing 20 times on one of them and 24 on the 


other. And this has been picked up in public. 


DR. MAKHIJANI: Well, Brant, this is not the 


public report because the, we really should 


settle this issue because, both for the 


process and the record, because what is public 


is what is on the NIOSH website. And 


actually, if it’s different than what you have 


it shows that we actually went back and in 


good faith made the corrections. 


And unfortunately, as I said, in one 


summary table the word missing appeared one, 


two, three, four, five, six, seven, eight, 


nine, ten, eleven times in one table, but it 


doesn’t, and in one other place, but otherwise 


everywhere the word missing was replaced by 


the word gap in accordance with our accepting 


your comments. So let’s not snatch defeat out 

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of the jaws of victory here. 


MR. GRIFFON: I think we’re in agreement. 


DR. ULSH: I think we’re in agreement. 


We’re in agreement that it’s not appropriate 


necessarily to conclude the data is missing so 


I think we can move on. 


DR. MAKHIJANI: We agreed with that. 


DR. ULSH: Okay, now there are a bunch of 

other --

 DR. WADE: Let Joe speak. 

MR. FITZGERALD: Yeah, Joe Fitzgerald. One 


other comment, too, and this process is 


evolving, and this was the very first draft 


that we provided NIOSH and the work group. 


And when I e-mailed that I think I even said 


in the transmittal that this hadn’t gone 


through copy editing and the only purpose of 


providing it was to facilitate discussions at 


the table. 


Now by the way, I’ll acknowledge that 


these have been posted in a public way which 


certainly complicates things when you’re 


dealing with the issue of first drafts. But, 


you know, in providing a first draft I think 


there’s got to be an expectation and an 

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understanding that we would expect to have 


comments. In fact, the comments we’re 


receiving from you right now on this first 


draft were certainly going to reflect, be 


reflected in the report that we’re writing. 


So I guess keep that in mind as well that this 


is a process that’s evolving, and it has come 


into a public forum the way it has worked out. 


But this, again, is a draft that both from the 


content standpoint as well as editorial 


content standpoint we would expect to get 


feedback, make corrections and that’s what you 


do with first drafts. 


MR. GRIFFON: And I think, clearly, even 


from last work group meeting, I think 


everybody is in agreement that we should call 


these things gaps and that statement was made. 


DR. ULSH: Well, I think we can move on. If 


everyone’s --


MS. MUNN: This is Wanda. You know, we’re 


really getting hung up on semantics. And the 


semantics are not the issue really. The issue 


is how do other people outside of this group 


and outside of the technical community 


interpret that word; whichever word you use is 

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interpreted by other individuals who do not 


understand either the process nor the comment 


about source terms and where things lie. 


They interpret that as being something 


that is not there that needs to be there; and 


therefore, conclude, possibly erroneously, 


that something cannot be done since 


information for some reason does not exist. 


Now that’s, it doesn’t matter what word you 


use, that’s what comes into people’s minds 


otherwise. 


And the point that Brant made is well 


taken. This leads to concern by elected 


officials. It leads to concern by 


organizations that have representation for 


workers, and it certainly leads to concern 


from the workers themselves. So the word is 


secondary. The meaning that is transmitted is 


of concern when we in our attempt to be 


completely open in what we do stress over and 


over again some point like this. 


What we are doing in my personal 


opinion is misleading both the public and the 


individuals who are most concerned with what 


we’re doing. So I would urge us not to argue 

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about the terms so much as to be cognizant of 


the impact that our deliberations have. 


One other point, it is disturbing to 


become adversarial over issues of this point. 


I would like you to remember that SC&A is a 


contractor to the Board whose charge was to 


point out to us major items that may have been 


overlooked in the process that the agencies 


were undertaking here. And this is not an 


auditing process, and this is not an 


adversarial process. 


This is two organizations, one an 


agency and one a subcontractor of the Board, 


who are attempting to identify what truth is 


and what can and cannot be done with respect 


to the very extreme amount of information that 


we have on sites like Rocky Flats, and we do 


have a plethora of information here. So it 


behooves us to step back once in awhile and 


remember who we are, what our object is and to 


review for ourselves whether we are or are not 


playing fair with the public, with our elected 


officials and with the workers when we take 


our deliberations perhaps past the point of 


reason in terms of what we can and cannot do. 

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MR. GRIFFON: And I think that we can, I 


agree with the point that we can have 


disagreements here, but we don’t need to have 


it so, you know, it doesn’t have to get 


adversarial. I think we all need to sometimes 


step back from that and remember that. 


Everyone’s just trying to do their job in this 


way. 


MS. HOMOKI-TITUS: I’m sorry to interrupt. 


I just got another e-mail from some people on 


the phone saying after the burst of static now 


they can’t, they can barely hear at all. So 


they want to know if we would mind hanging up 


and try calling back into the call-in line. 


Sorry. 


 DR. WADE: Do you want to take a quick 


stress break? 


MR. GRIFFON: Yes, we’ll take a break. 


 DR. WADE: We’re going to take a quick break 


and try to re-establish the phone line. Thank 


you. 


(Whereupon a break was taken.) 


MR. GRIFFON: I think Wanda has --


MS. MUNN: One more question before we go. 


I was going to ask a question of Dr. 

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Makhijani. I wanted to ask whether there was 


any other category of workers other than 


specifically foundry workers that he has any 


personal reservations about coverage for to 


date with the efforts that have been brought 


before this working group. 


DR. MAKHIJANI: Well, as I mentioned in my 


sort of follow-up to Brant, there are the 


Building 81 workers in the 1950s for whom 


there is a question about back extrapolating 


the data from the ‘60s. Generally, the gaps 


that we identified, Ms. Munn, were for 


external data for non-plutonium workers in the 


1950s and to show that the existing coworker 


models, the new coworker models could cover 


them. And foundry workers seem to be the ones 


with, of the ones that we knew, we haven’t 


studied all the processes that had them, 


seemed to have at least some potential for 


high exposure. 


But those are the only two groups that 


I know of in terms of what we’ve looked at. 


Enriched uranium Building 81 workers in the 


1950s and the back extrapolation involved 


foundry workers, the period a little unclear, 

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1950s and maybe somewhat into the ‘60s. I’m 


unclear because we only have one point of 


reference, well, two, 1968 and 1969 in terms 


of the data so it’s a little bit harder for me 


to say there. 


MS. MUNN: I see, so those are the only two 


that you have outstanding concerns about at 


this time that you anticipate? 


DR. MAKHIJANI: Well, we --


MR. GRIFFON: I guess I would say there’s 


other questions I have on the data 


completeness thing. I think the one that’s 


most likely to present a question with regard 


to being bounded by the coworker approach is 


this foundry question. But there’s certainly 


questions that I have still remaining in the, 


in some of those middle gaps, that period 


where even though there’s some arguments made 


that based on the job title or the likelihood 


of radiation exposure, that there’s no 


surprises in gap there. 


All policies that I was aware of 


before this seemed to point to that they 


should have been on at least a quarterly 


monitoring program. So why not is kind of 

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what I’m asking. Now I don’t expect that they 


were high exposed. So I’m expecting that you 


could probably use a coworker model to fill 


that gap if, in fact, there is a gap. 


MS. MUNN: I anticipate that we’ll be going 


there later on your agenda, but I just wanted 


to make very sure that there were no other 


real categories of individuals of potential 


claimants that you had any reservations about 


at this time. 


DR. MAKHIJANI: We haven’t talked about 1969 


so maybe --


MS. MUNN: No, that comes later, but I --


DR. MAKHIJANI: Within the framework of this 


discussion, I think I, I don’t know, Joe, I 


presented our analysis and what we’ve 


discussed in terms of where we feel the gaps 


are. 


MR. FITZGERALD: Yeah, I think that what 


we’ve given NIOSH and what we’ve been talking 


through I think it pretty much scopes what 


we’ve identified. 


DR. MAURO (by Telephone): This is John 


Mauro. Can I say something about the 


discussion I’ve been listening to for a 

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second? 


MR. GRIFFON: Sure. 


DR. MAURO (by Telephone): Thank you. I 


think we may, I know we got into deeply into 


some complex issues. I’d like to step back a 


little bit and go back to the sampling 


findings that NIOSH reported regarding gaps on 


the 52 cases. I think there’s something very 


important that happened there, and 


unfortunately, I think we went by it a little 


too quickly. 


I think originally the reason we did 


the sampling as I understand it there was 


concern that there might be gaps out there 


that represented missing data that might be 


important to fully characterize and 


appreciate. What I heard is that we did find 


gaps, but it turns out for all intents and 


purposes there really isn’t anything that you 


would call, what I heard was missing data. 


That is, people that if there was 


missing data, there’s a reason why it was 


missing. It was completely consistent with 


what was going on. So it’s not that there, 


this is part of the purpose of the 

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investigation as I understood it was what are 


the size of the gaps and what the reasons for 


the gaps are. And I think that the reasons 


have been fully explained except it sounded 


like in one place we did have some what you 


would call, I think there was one individual 


in one year. 


I think it’s important to separate 


that and understand that -- I think we have 


closure there unless the method is 


undisputable, what was characterized by Brant. 


So I think that was a very, very important 


finding. That is, notwithstanding the fact 


that there were a substantial number of gaps 


which Larry called on the order of about 30 


percent of the records. That was the number 


that stuck in my mind regarding both internal 


and external over if we look across the whole 


body of data. 


But it sounds to me all of those gaps, 


there’s a reason why there was a gap there 


which is perfectly understandable. And I 


think that’s important in terms of the 


robustness of the dataset upon which we’re 


looking at. 

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Separate from that I think this is 


what happened in the conversation we just had. 


Separate from that is that now we have, we’re 


entering really a different question. And 


that is when you have a gap, even though 


people may have deliberately not have been 


monitored; for example, when I heard that in 


the 1950s there were time periods when people 


were not monitored, perhaps according to 


today’s standards you would have monitored 


them, but they weren’t. And it was 


deliberately done. 


That is not missing data. That is 


part of the gap, and it’s not missing data, 


but it certainly represents a situation where 


we have people who may have been exposed, but 


we need to reconstruct the doses for. So I 


think what happened in the conversation is we 


left the subject of the 52 samples and what it 


tells us and what value it has to this 


program, and I think that it has served its 


purpose. 


And now we’ve really left that, so I 


don’t think there’s any controversy there 


unless I hear differently, and now we’re 

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moving on to the subject. But nevertheless we 


do have people who were not monitored. We do 


have places where there were zeros. Now 


that’s separate from this question of the gaps 


and the reason for the gaps. 


Now we’re really moving into the realm 


of when there is, in fact, people who were not 


fully monitored for whatever reason, how do we 


go about reconstructing their doses. So all 


I’m trying to do right now is point out that I 


think those are two separate subjects. I 


think we very successfully addressed the first 


part unless there’s some question regarding 


the, you know, NIOSH’s interpretation of the 


fact that for all intents and purposes there 


is no missing data, there are gaps, and there 


are legitimate gaps. Gaps now that we’re 


about to talk about that we can discuss, the 


extent to which there are methods in which 


those individual doses can, in fact, be 


reconstructed. 


What I’ve just described, do you have 


the same sensibility regarding that? Is that 


what just transpired? 


MR. GRIFFON: Short answer, no. 

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DR. MAURO (by Telephone): Okay, that’s 


important to me because that’s the reaction I 


MR. GRIFFON: I think you’re ahead of me in 


terms of agreement with NIOSH’s findings. I’m 


not there yet. I’m not saying that they’re 


inaccurate. I’m just saying I’m not quite 


there yet, John. And part of what I was, you 


made a point in the middle of your statement 


that there were some gaps that based on 


today’s monitoring practices wouldn’t have 


been there. 


That’s not what, I think you might 


have been picking up on my point earlier, and 


I wasn’t talking about on today’s monitoring 


standards. I was talking about the monitoring 


practices of the time. And so I’m trying to 


still flush some of that out in my mind 


anyway. There’s time periods, we’ve discussed 


a few of these fairly extensively at the last 


meeting, that one person that had, for all 


intents and purposes we saw in the site 


profile, I believe, and correct me if I’m 


wrong on the year, but I think in 1964 


everyone at that point was badged except maybe 

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75 

the subcontractor question which now is a 


clarification on that. 


So I’m still trying to get my handle 


on the, do what’s reflected in the records 


match up with the monitoring practices of the 


time period? And I was hoping that there may 


be some sort of spreadsheet-style analysis 


that backed up each one of these paragraphs 


rather than, because they’re all sort of 


making different points on why a certain case, 


that you had data sufficient for that time 


period of interest. But without seeing it 


laid out in table format, it was a little hard 


to go through systematically. 


But there’s the one person, there’s a 


few people actually that have this potential 


gap in their records in the ’64-to-’75 range, 


and even though in most cases, and I think 


it’s reflected in NIOSH’s report, they look 


like low radiation potential jobs, 


notwithstanding that according to the policy, 


my understanding was that they should have 


still been on a quarterly badge program. 


Now that might be that memo where we 


said in 1969 that they had a policy, at least 

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for some period of time, where they didn’t 


read, they might have been badged, but they 


didn’t read the badge for quarterly workers. 


And basically it was because of probably the 


volume of work or whatever. It was probably a 


cost reduction thing, and it was supported by 


the fact that these were lower exposure 


workers. I don’t dispute that. 


But then we see this, in some workers, 


this continues, and I’m not sure we’ve got a 


handle on when that starts and stops and I was 


looking for more of this kind of, and I know 


it’s difficult because sometimes you just 


don’t have the documents, but you know, a 


borderline test for that to say, okay, that 


gap makes sense because that was the policy 


for ’69 to ’72 or whatever. 


DR. MAURO (by Telephone): That’s what I was 


trying to do, Mark. I heard Brant’s 


presentation regarding their detailed analysis 


of those two cases, and where we identified 


gaps, I think it was my understanding that 


there was a reason based on their 


investigations of why that gap existed. And I 


guess I did not walk away, Mark, from the 

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conversation that went on for quite a bit 


after that with the sense that I appreciated 


what did the sampling tell us then. 


In other words, how did the sampling 


program and the gaps that we’ve identified, 


and then the analyses that NIOSH has done 


regarding those gaps and presented their 


findings regarding them, what does that tell 


us now regarding the records? How does that 


help us move, you know, and I guess I had a 


little trouble understanding the process that 


we’re in. 


MR. GRIFFON: I guess my understanding of 


it, and this sort of goes to Jim Neton’s 


question earlier, too, but my understanding of 


what we’ve gotten here is basically, you know, 


we went down this data completeness approach 


more because it was apparent that there was a 


stronger reliance at Rocky Flats for the 


individual radiation files, that they had the 


data for the individuals. 


We started looking at coworker models 


early on and the database data, and we came up 


with some questions, but we were, at least I 


was given the impression that for the most 

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78 

part, and I’m not, again, I’m not trying to 


pull transcript quotes or anything like that, 


but for the most part there wasn’t going to be 


a heavy reliance on these coworker models 


because in fact each individual had a complete 


radiation file, complete enough to do dose 


reconstruction. 


So then we said, well, for the class 


we’ll sample from this and say for the class 


are these records complete enough. And if 


not, if we find gaps that we believe are truly 


gaps in their records, would the coworker 


approach, you know, do we need to use the 


coworker approach to fill that gap. And if 


so, is the coworker approach adequate. Is it 


bounding and is the data in that reliable. 


So sort of we got away from, you know, 


it’s sort of this two-pronged test that if you 


don’t use the coworker models much, we sort of 


stopped pursuing the question of HIS-20 versus 


CER and all these concerns about the data. 


If, in fact, we end up needing these coworker 


models more, then the question comes up again. 


And I think we’ve answered, you know, 


I think we’ve got responses on both those 

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fronts, so I don’t thing we’re, at the end of 


today we’re not going to ask for more research 


to be done. We just want clarifications now. 


But that’s sort of the reason we went down 


this path. 


And then the other question will be, 


and I think NIOSH is saying we’ve got 


approaches that they’ve used already, and they 


also additionally have coworker, not 


necessarily coworker, but some techniques, DR 


techniques to fill in gaps and additionally 


they have these other, the TIB-038 and TIB-058 


coworker models. 


But what I’m not completely 


comfortable with, and part of it’s because I 


just haven’t digested the entire scope of the 


report, but the question, if you look at each 


case sort of summary that NIOSH provided, then 


to me there’s still some questions on the 


monitoring policy at the time. Whether the, 


if you line up the data the individual had 


during that time period and the monitoring 


policy of the time, was there that strong of a 


match? So I guess that’s where I’m still at 


on the data completeness section of it. 

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80 

MS. MUNN: And I’m not quite in the same 


place, John, for your information. But I’m a 


little concerned that we’ve kept Dr. Ulsh 


waiting for over 30 minutes to respond to the 


comments that Dr. Makhijani made earlier, and 


perhaps we could hold our discussion a little 


bit while that response came forward that 


might answer some of the questions for us. 


MR. GRIFFON: Go ahead, Brant. 


DR. ULSH: All right, some of the, okay, 


like I said, there were a lot of issues that 


were mentioned, and I think there’s a lot of 


things that come into play here. And it’s 


important to discuss them separately, de-


convolute it. 


There were a couple of, for lack of a 


better word, groups of workers that SC&A was 


concerned about. The first is foundry 


workers, and the second is enriched uranium 


workers in Building 81. There were also a 


couple of different time periods that were 


mentioned, the ‘50s and 1969 and ’70. And 


those were, all four of those factors there 


are completely different. They’re separate. 


So let me just start first of all with 

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81 

 

the foundry workers in the ‘50s. I don’t know 


that SC&A said this explicitly, but you seem 


to be under the impression that foundry 


workers in the ‘50s were not monitored. Am I 


misstating your --


DR. MAKHIJANI: No, yes, you are. We 


haven’t, all we’ve said is that the data 


completeness findings were that the non-


plutonium workers had the gaps in external 


dose in the 1950s. That’s where the gaps were 


concentrated. 


DR. ULSH: Okay. 


DR. MAKHIJANI: So there would be uranium 


workers, everybody was outside the 700 series 


buildings. Now the foundry worker question, 


we did not actually look for foundry worker 


data, just for the record, because of what 


Larry Elliott brought up. You know, why 


didn’t we look at foundry workers was the 


concerns. The non-plutonium workers became a 


concern because of the analysis of the random 


cases. We didn’t know beforehand what we were 


going to find, and the foundry workers became 


a concern because in that context there was 


also the document from *, that said 

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that this was a place of particular concern. 


Now we haven’t found any data for the 


1950s for foundry workers nor have we looked 


through to try to identify a database. We 


were looking to you to show some foundry 


worker data for the ‘50s for whoever was there 


because we understood that you might do that 


and that they would be monitored because of 


their higher exposure potential, something 


like that. We didn’t find any. 


DR. ULSH: Well, in fact, that’s exactly 


right. I’m going to circulate some more 


Privacy Act material. Please get this back to 


me if you’re not going to take it home. 


In a discussion that SC&A and NIOSH 


had, your interview with Roger Falk, we 


discussed that the enriched uranium workers in 


Building 81 were not monitored until the 


fourth quarter of 1960, and that’s true. 


We’re in agreement there. They weren’t. 


That’s not the foundry workers though. 


The material that I’m handing around right now 


is dosimetry, just an example of dosimetry 


results for foundry workers in 1953. In fact, 


the foundry workers, as you stated, Arjun, 

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83 

because they had a higher exposure potential 


relative to other uranium workers were, in 


fact, monitored. They are not unmonitored 


workers. 


Coworker data is not a question for 


these people in general. Now, I don’t want to 


swear that there’s not a single unmonitored 


foundry worker, but in general, the group that 


includes foundry workers were monitored. So I 


think that the urgency in terms of 


applicability of coworker data to foundry 


workers in particular is not really 


appropriate because they were, in fact, 


monitored and here’s an example of that. 


Now, you’re right, Arjun, that the 52 


workers that we looked at for data 


completeness, I’m not aware of any foundry 


workers in that 52, in that group of 52. So 


your caution about making any conclusions 


about that is justified because there weren’t 


any in that 52. But this group of workers was 


monitored in the ‘50s. 


 DR. WADE: How do we know if we’re looking 


at foundry workers? 


DR. ULSH: If you look at the top corner, it 

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says Building 44, and then we’ve gone and 


that’s the uranium, that’s the DU foundry that 


we’re talking about here. 


This group includes not only the 


foundry workers, but I think there’s also 


management types in here as well. But this is 


the Building 44 workers for this particular 


badge exchange cycle. 


DR. MAKHIJANI: And we would be able to go 


back to the documents and see that there are 


many foundry workers in here. This is the 


first time I’m seeing a record of foundry 


workers. 


DR. ULSH: I know. I got this because of 


the question that came up. What you would 


have to do, Arjun, to make that determination 


is make sure that you’re looking at Building 


44 because that’s where the foundry was. And 


then beyond that you have to look at the job 


exposure history cards and look for terms 


like, I think, operator or, I don’t know, 


there might be a couple of other titles. But 


that would indicate to you that if they were 


an operator in Building 44, there’s a good 


chance they were doing a foundry-type 

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operation. 


DR. MAKHIJANI: Were there only foundry 


operations at 44 or other operations, too? 


That’s what I’m not clear about. 


DR. ULSH: Building 44 was in large part, I 


mean, it was a metallurgical operation for 


handling DU, and it’s a little too bright a 


line to say foundry workers versus non-


foundry. I mean, they weren’t, I don’t think 


that they were split up that way. They were 


doing operations, not chemical operations, but 


typical types of metallurgical operations that 


occur in a DU metal-type operations. So if 


you --


MR. GRIFFON: You said you’ll see management 


types on this list as well? 


DR. ULSH: I think that this includes, well, 


I don’t want to say all building for those 


pages I’ve given you. I don’t want to say all 


Building 44 workers although I think that 


that’s true for this badge exchange cycle. 


And that will include foundry workers as well 


as the salaried, management-type. 


MR. GRIFFON: So someone made a judgment 


that anybody in that, based on that premise 

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you’re saying anybody could have received 


greater than ten percent of the RPG because 


that was the practice at the time, right? 


MS. MUNN: If you’re relying on the 


assumption that the major source term is 


there, yes. 


MR. GRIFFON: Often time we’ve said 


managers, you know, we look at job titles and 


make decisions based on that so if we’ve got 


management and salaried people --


DR. ULSH: I think, Mark, though that 


judgment was not necessarily made on a per 


individual basis. I mean, this group of 


workers included people who had the potential 


to get greater than ten percent; therefore, 


they monitored the group. 


MR. GRIFFON: I’m just trying to understand 


DR. ULSH: I understand. That’s a good 


thing to be clear on. 


DR. MAKHIJANI: Brant, what’s the indicated 


badge cycle here and the units, are they in 


roentgens or looks like that, but I’m not sure 


if it is --


DR. ULSH: It does look like that, Arjun. 

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DR. MAKHIJANI: It’s not indicated. 


DR. ULSH: I don’t know. I’d have to go 


back and investigate that in terms of what the 


units are. 


UNIDENTIFIED: It will give you an issue and 


return date. 


MS. MUNN: It looks like --


DR. ULSH: Yeah, in terms of the radiation I 


would have to check that out. 


DR. MAKHIJANI: But it’s a monthly cycle? 


DR. ULSH: It is a monthly cycle. 


DR. ULSH: Okay, so that’s the foundry 


workers. Now that’s the foundry workers in 


the ‘50s. We need to keep that distinct from 


’69 and ’70. That’s a separate situation, and 


we’ll talk about that separately. 


Now in terms of the Building 81 


enriched uranium workers, we know that they 


were not monitored until the fourth quarter of 


1960 as our report discusses. And we’re in 


agreement with SC&A that they were not 


monitored. The question is why weren’t they 


monitored. Well, the reason is because with 


the badging policies in place at the time, 


those who were not expected to exceed ten 

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percent of the tolerance limit, it wasn’t 


required that they be monitored. 


And if you look at once they were 


monitored in the fourth quarter of 1960 and in 


1961, that judgment appears to be justified 


because they were lower than the tolerance 


limit. But of course, the question as Arjun 


has pointed out, the question remains can you 


go back in time, extrapolate back into the 


‘50s. And I think that’s a valid question. 


The things that would give me pause 


about extrapolating back in time would be if 


there were the source term was different or if 


there were exposure conditions that might have 


been different, for instance, improved 


shielding or whatever. And that’s why I put 


those two bullets that Arjun referenced into 


this report because if you look at the 


material balance and account ledgers, which 


for enriched uranium, are classified. 


But SC&A has people who have 


clearances, and if you want to verify this, 


you can do that. But those account ledgers 


show that the amount of enriched uranium that 


was processed at Rocky Flats throughout the 

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‘50s steadily increased up to a plateau in the 


early 1960s. And in some time in the middle 


‘60s -- I can’t remember if it was ’63 or ’65 


-- all of those operations, enriched uranium 


operations, were transferred to Y-12. 


So what you see in terms of the source 


term present is that the amount that was 


present that was being handled in the ‘60s was 


higher or equal to the amount that was being 


processed throughout the ‘50s because of that 


steady ramp up throughout the ‘50s. 


And also you don’t see major building 


configuration changes. For instance, I mean, 


in other buildings, I think in particular 


around the americium line, there were projects 


to increase shielding. They observed high 


exposures, and they increased the shielding. 


Well, obviously, if you had enriched uranium 


operations in the ‘50s and then in 1957 you 


said, wow, we need more shielding, and you put 


it in, and the people aren’t monitored, and 


you don’t have monitoring results until the 


‘60s, well, that would give you some pause 


about extrapolating backwards. 


We don’t see that situation for 

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Building 81; and therefore, that gave us some 


comfort that the, what we’re seeing in 1960 


and ’61 would be applicable back into the 


‘50s. The judgments of the health physicists 


in place at the time that these workers were 


likely to have exposure potentials lower than 


ten percent seems to be justified. 


And furthermore, then the question 


becomes, well, all right, if they were not 


monitored in the ‘50s, and we know they 


weren’t, what are you going to do? Well, one 


thing that we might do is apply coworker 


models. And if you look at OTIB-58, and you 


look at the values of the coworker models that 


we are proposing for the 1950s and into the 


1960s, in no case does the exposures that you 


see in this group of workers, these enriched 


uranium workers once they were monitored, does 


it even approach, does it even remotely 


approach the amount of dose that we’re going 


to apply under coworker if we choose to use 


coworker data. That’s not always necessary. 


So that was the genesis of that discussion in 


our report. 


Now, Mark, you also asked the question 

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about badging policies at the site over time, 


and if you recall, it was our, I think in our 


TBD, and it was our original assumption that a 


particular quote about in 1964 -- this is from 


memoirs -- in 1964 we were able to incorporate 


the dosimetry badge with the security badge. 


This was an improvement from the standpoint of 


assuring that employees was (sic) wearing a 


badge while working on the job. 


We originally interpreted that to mean 


that beginning in 1964 everybody was 


monitored. And you recall that that caused 


some confusion when SC&A presented the results 


of the analysis of the first 12 workers in the 


data completeness because, well, if everyone 


was monitored, then why do we have this one 


particular individual who wasn’t? And so we 


went back and took another look, and it turns 


out that we actually misinterpreted that 


comment to mean that everyone was monitored 


onsite. 


Throughout the ‘50s there was the rule 


about greater than ten percent of the 


tolerance limit. We know that. It is true 


that in 1964 they expanded the monitored 

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population, and that was facilitated by the 


combination of the security badge. But it 


appears that even at that time that there were 


people who had low exposure potential who were 


not monitored. 


And you can see that from the graph 


that we put out, and I think it might even be 


in one of SC&A’s reports reproduced where it 


shows that there is less than 100 percent in 


all years at Rocky Flats. We know that. We 


know that that is the case. Now periodically 


they expanded the monitored population, but at 


no time does it appear that they had a policy 


to monitor everyone who ever set foot on the 


site. It appears that there were always some 


exclusions for people who had no significant 


exposure potential. 


And if you look at our write up on the 


badging of personnel at Rocky Flats, and the 


one that I have is dated November 30th, 2006, 


but I’m not sure if this is a draft or when 


exactly we sent it over to SC&A and the 


working group. That gives some information on 


this periodic expansions, different groups 


being monitored, being added to the monitored 

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population. So, Mark, as you digest this, our 


report on data completeness, that might be a 


helpful thing to look at in terms of 


determining what the badging policies were at 


the time. 


So it’s certainly true that in our 


original TBD we made an incorrect assumption 


that beginning in ’64 everyone was monitored. 


That does not appear to be the case, and we 


will be revising the TBD to handle that if we 


haven’t already. I don’t know. 


MR. MEYER: We haven’t yet. 


DR. ULSH: Okay, so that’s in the works. 


Let’s see, I think, okay, so my main 


points here that’s it’s important to keep the 


foundry workers separate from the enriched 


uranium workers, to consider them separately 


because their situations were different in the 


‘50s. The foundry workers were monitored. 


The Building 81 EU people, EU workers, were 


not until 1960, fourth quarter. 


Now that brings us up to 1969 and ’70, 


but, Mark, I don’t know if there’s more that 


you want to discuss on this before we get into 


’69 and ’70 or if you’re ready to jump into 

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that? 


1969 DATA GAP
 

MR. GRIFFON: I think it’s probably okay. 


DR. ULSH: Go ahead? 


MR. GRIFFON: Arjun or Joe? 


MR. FITZGERALD: That’s fine. 


DR. MAKHIJANI: That’s fine. 


DR. ULSH: All right, 1969 and ’70 was a 


strange time at Rocky Flats. They had the, 


the big event was the Mother’s Day fire that 


occurred in May of 1969. That was a very 


disruptive event. It occurred in Building 


771, I think, 776. And it essentially stopped 


plutonium production operations for a time. 


Now, concurrently -- this happened in 


the first quarter of 1969 -- there was a 


policy, administrative policy, that workers 


who were stationed outside of plutonium areas 


and were on quarterly badge exchange cycles, 


their badges would not be read unless the 


circumstances warranted it. That was 


administrative policy. 


And the motivation behind that was 


that they were preparing to switch over to 


TLDs. There was a lot of manpower, a lot of 

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resources, being dedicated to reading these 


film badges for workers who were at low 


exposure potential. And when I say low 


exposure potential, I’m drawing that from the 


fact that they were on quarterly badge 


exchange cycles which is the longest badge 


exchange cycle. 


And they made those determinations 


about which cycle you were on based on your 


exposure potential. So those workers, their 


badges were not read, and that has caused a 


lot of consternation around the tables and me 


included. 


The way that this was originally 


discovered, I think SC&A noticed that the 


frequency of zero badge readings increased 


suddenly in 1969 and went on into ’70. And so 


as we investigated this, you know, you’ll find 


the history of our investigative efforts on 


this issue in particular in our report and 


also in SC&A’s report. We originally, when 


presented with this increased incidence of 


zeros, we considered a lot of different 


hypotheses. We put everything on the table 


just to try to find out what the reason might 

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be. 


The hypothesis that we started with 


was something related to the fire. Well, that 


relatively quickly became evident that that 


didn’t explain the situation. And then we 


happened upon this report. It was a monthly 


progress report from the dosimetry section 


that set out this policy to not read the 


badges for these particular workers. 


And so then we started evaluating the 


patterns that we see in external dosimetry in 


’69 and ’70 against that policy. And what we 


found is that it’s consistent. It is 


consistent with that policy. And we actually 


saw film worksheets for people that were 


affected by this policy where there’s a zero 


at the top of the page and then an arrow all 


the way down the page covering a number of 


different employees. 


And the problem came in with the 


treatment of those zeros. Those zeros were 


interpreted as real zeros when in fact they 


should have been interpreted as unmonitored 


people. If you’re wearing a badge, but the 


badge isn’t read then you’re not monitored. 

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And so the question comes up, well, what do 


you do with that then because in the data that 


we use for coworker distributions, HIS-20, 


those zeros were treated as if they were 


zeros. And that’s a problem. 


It doesn’t indicate anything 


nefarious, you know, they were out to deceive 


anybody, but it’s a problem in terms of 


coworker distributions. And so the question 


then becomes, well, what do you do. What 


impact does this have on our coworker 


distributions for 1969 and ’70. 


And another question that we have been 


wrestling with is when did this policy end. 


And, Mark, I would still love to be able to 


hand you a memo that says as of X date, this 


policy’s rescinded. We have not found that, 


and I don’t think we’re going to find that. 


Therefore, you have to look at the weight of 


the evidence. 


Bob, are you --


MR. MEYER: I was just going to say we’ve 


put an awful lot of effort into trying to find 


that memo, and it doesn’t seem to exist. 


DR. ULSH: So let’s look at the weight of 

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the evidence. Consider that the reasons 


behind, the motivation behind this policy was 


the resources that were being expended to read 


film badges for people who were at very low 


exposure potential, at least putatively judged 


to be at low exposure potential. That 


motivation goes away with the transition at 


the site to TLDs, and that happened, 1969 and 


’70 were transition years, and by the end of 


1970 everybody was on TLDs. 


Also, as pointed out by SC&A, the 


incidence of zeros, those years where you see 


the high incidence of zeros was limited to 


1969 and ’70. And so from the weight of the 


evidence it appears that this policy was in 


effect done away with, no longer applied, by 


the beginning of 1971. It would be an issue 


in 1969 and ’70. 


MR. GRIFFON: Can I just add, when you said 


in ’71 everyone was on TLDs, you meant 100 


percent of workers. 


DR. ULSH: Thank you, Mark, 100 percent of 


the people who were monitored, were monitored 


with TLDs. That’s correct. I’m not saying 


that everyone on site was wearing a TLD. 

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I don’t know, Craig, am I missing 


anything in terms of the weight of the 


evidence? 


 DR. LITTLE: Well, the, we know the TLDs 


were phased in through time. They didn’t all 


hit at the same time, and in the report we’ve 


got about six or seven monthly progress 


reports that make statements about when things 


were, when TLDs were phased in at the various 


buildings, into 771 in September of ’69, and 


in 76 it was February of 1970 that, the 


December 1970 progress report which is written 


in January ’71, says all film badges have now 


been replaced with TLD badges. 


We also know that people went in in 


the immediate aftermath of the 1969 fire were 


wearing TLDs. They were wearing TLD badges 


because we have a summation of external 


exposures to people who were in that fire 


during the period through May, June and July 


of 1969. The maximum external dose to any 


single person who was attending to that 


situation was under 200 millirem with the vast 


majority under 50 millirem. Only three people 


received over 150 millirem. 

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So we know that they did use TLDs. 


They had some on site. They did use them. 


They didn’t have enough to start using them 


through the whole plant and didn’t make that 


conversion until the end of 1970. And they 


staged in as you would expect with the higher 


exposed people getting the TLDs first, then 


the lower exposed people getting TLDs later. 


DR. ULSH: And that actually is a good 


segue, Craig, thank you. 


One of the concerns that SC&A has 


raised about this non-read policy, it applied 


to people who were stationed, officially 


stationed, outside of plutonium areas. 


However, SC&A presented a couple of 


individuals, one of whom went into Building 


776 after the fire occurred, and there is no 


external monitoring data in his file. So it 


makes you wonder. Well, I think it makes you 


wonder, why not? 


And what Craig has said is that the 


people who went into the building after the 


fire were wearing TLDs. So let me clarify 


what that means. We talked to several 


individuals, several people who were directly 

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involved in the fire including the fireman who 


was in charge of the response. And they all ­

- okay, without it in front of me I don’t want 


to say all. Many of them said, those who 


commented on whether or not they were wearing 


dosimetry say, yes, we were badged with TLDs. 


And if you look at the memo that is 


included in our report, it talks about 


personnel TLD dosimetry data. These were 


special TLDs. They were not the dose of 


record. They were not issued to you as your 


routine film badge. They were issued on a 


job-specific basis as special dosimetry is by 


the supervisors in charge they would hand out 


to the workers that were on this particular 


job. 


These are not the dose of record, and 


that’s why it is not inconsistent when people 


say everyone who went into the building was 


wearing a TLD, but we don’t see TLDs on a 


couple of individuals that we know went into 


that building. It’s because they’re talking 


about special dosimetry. It’s not their 


routine film badge. 


And furthermore, the concern was 

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raised then if there was someone going in who 


was not monitored, and we’ve just talked about 


the fact that they were indeed monitored, but 


they were in Building 776, had high exposure 


potential after the fire. Well, I want to 


talk about that second premise as well. You 


cannot assume that someone who went into 


Building 776 in the aftermath of the fire was 


at a high exposure potential. 


In fact, we know that that is not the 


case because if you look at the memo that’s 


included in our report, dated July 24th, 1969, 


as Craig mentioned, there are 173 people who 


received between zero and 50 millirem, 28 


people who received between 51 and 100, four 


who received between 100 and 150 and three who 


received between 150 and 200. And over the 


time period, 5/11/69, that’s the date of the 


fire, through 7/22/69, July 22nd, 1969. So the 


premise that these people were at high 


exposure potential is not supported by the 


monitoring data that we have. 


MR. FITZGERALD: And is that -- excuse me, 


Brant -- is that reflecting a consideration of 


Super-S? 

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DR. ULSH: No, Joe, this is external. 


MR. FITZGERALD: You’re saying it’s 


external. 


DR. ULSH: This is external. That’s 


correct. 


There’s certainly the potential for 


intake of plutonium, and certainly high fired 


plutonium because it was a major fire 


involving plutonium, and that’s one of the 


ways you get it. So this says nothing about 


potential exposures of Super-S. 


Now the issue that your question 


raises is how, okay, we’ve talked about 


external dosimetry potential, but what about 


internal doses? And for that situation we 


would certainly apply Super-S if it’s claimant 


favorable to do so for a person who went into 


the building after the fire, absolutely. 


 DR. LITTLE: But there was monitoring data 


for a number of the people that went into the 


building. They have chest counts. 


DR. ULSH: That’s correct. 


 DR. LITTLE: And only one of the people that 


was, and I think there were 45 people if I 


remember right, who were given chest counts in 

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a very short term after the fire. Only one of 


them had a significant lung count, and that 


was a person who was indeed a fireman who had 


somehow gotten, who went up on the, he could 


not understand how he got it. 


He surmised that he might have gotten 


it because he went up on the roof, and that’s 


the one place he thought he might have gotten 


an extra long exposure. But none of the other 


people, including some of the people who were 


raised up in some of these reports, have 


internal lung counts that are significant, 


above that. 


DR. ULSH: So what we’re left with is there 


is no evidence that the judgment that the 


people whose badges were not read were at high 


exposure potential. It is true that on 


occasion they might have gone into a building 


like 776 but not on a routine basis. 


And when they were going into a 


situation where there might be an exposure 


potential, the examples that we have, for 


instance the aftermath of the fire at 776, 


they were monitored through special TLDs. Now 


I don’t want to say anything beyond that, 

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beyond the examples that we have, but we don’t 


see evidence that in fact these people had 


high exposure potential, and they were not 


monitored. 


Now what about the foundry workers, 


our old friends the foundry workers. I’m 


going to rely on Craig a little bit to 


summarize what data does exist for the foundry 


workers in ’69 and ’70. But one thing, the 


standard that I would like you to compare it 


to is the coworker dose that we would assign 


in 1969 and ’70. 


And if I can come up with that -- the 


current version of OTIB-58 assigns for 1969 at 


the 95th percentile. Keep in mind we’re 


talking about people who would have worked in 


radiation areas so we would assign the 95th
 

percentile. What you see for penetrating 


doses, OTIB-58 assigns 2.47 rem, 2,472 


millirem, for 1970, 2,071 millirem. 


For non-penetrating doses, this is 


shallow doses, we assigned 2,574 millirem in 


1969, and in 1970, 2,115 millirem. There is 


absolutely no indication that the foundry 


workers ever approached those dose levels. So 

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it is, we maintain that the coworker dose that 


we would assign in this situation if you have 


an unmonitored foundry worker is very, very 


claimant favorable. 


Is there anything else to add? 


 DR. LITTLE: Well, the only thing I would 


add is if you look at the table that is on the 


report that Arjun commented on earlier, we 


were able to find for foundry workers in ’68 


and ’69, we found film badge worksheets for 


’68 that had data for most of those people for 


most of the quarters. I mean, there were a 


few that were not, they had blanks because 


they didn’t return the badge or in a few 


instances they just had zeros. 


And then in keeping with that policy 


that we talked about of not reading workers’ 


badges who were not expected to be 


significantly exposed, we found in the first 


three quarters of 1969 zeros for everyone 


except one of these guys. And we, this is, I 


don’t want to leave people with the false 


impression that we think we know who all the 


foundry workers were in ’68 and ’69. We don’t 


I don’t think, but we have identified some 

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here that we are sure of. 


And our intent with these people was 


to, our intent in total was to try to find the 


memo or find the period of time when this 


policy went away if you will. And so we said, 


well, let’s find some of these guys, so we 


found ‘68. We found they had data. We 


followed them in ’69. They didn’t have data 


in the first recordings, but all but one of 


them have data in the fourth quarter which is 


an interesting situation. 


We couldn’t follow all of them into 


the ‘70s, into 1970, because what happened is 


a lot of these guys changed, they either 


changed department numbers, that is, the 


department number got changed. And that’s how 


you identify who’s who. You know, on the 


supervisors’ reports they’re by department 


number, and then you can backtrack to the lab 


worksheet or the supervisory report. 


Or they actually changed jobs. They 


went into another, so it’s hard to, it’s a 


much more difficult task than you might think 


to go find somebody and track them back 


through time to find out where they were or 

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find them now and track them forward in time 


because they moved to another department 


number or numbered building, something like 


that. 


But one point I’d make about this 


table is they’re all zeros in the first three 


quarters for virtually all these foundry 


workers but in the fourth quarter there’s 


data. We’re not making the assumption that 


that data represents the, a cumulative for the 


year. We’re not making that presumption. 


It’s possible that that’s true, but we are 


saying this is in keeping with that policy 


that says we’ll read it if we think there’s, 


if we think they’re going to get a significant 


exposure. 


So they didn’t do anything that was 


considered to be a, maybe they didn’t even 


operate the foundry in the first three 


quarters. I have no clue, but there are zeros 


there. Then all of a sudden the fourth 


quarter these people all show up with data. 


Something happened to make them read the 


badge, plain and simple. 


DR. ULSH: And keep in mind the original 

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policy said the badges for these workers will 


not be read unless circumstances warrant. So 


if circumstances warranted, their badges were 


read. But that’s what the policy says anyway. 


 DR. LITTLE: Right. So also, the numbers 


shown in the fourth quarter there, only one of 


the numbers in there, one of the workers, that 


is, has numbers that approach the values that 


Brant was just reading. 


MS. MUNN: What were those numbers like, 


Craig? Just a few. 


 DR. LITTLE: External range from a low of 42 


millirem to a high of 280 millirem. 


MS. MUNN: Okay, thank you. 


 DR. LITTLE: Skin doses range from a low of 


65 to a high of 3,460, but that one person was 


pretty much an anomaly in this group. 


Everybody else was in the 400s, 500s. There 


was one 740. But remember that the tolerance 


dose for a quarter was 1,000 millirem, or ten 


percent of the tolerance dose, I’m sorry. The 


tolerance dose was ten rem for skin in 1969. 


MR. FITZGERALD: And just to clarify back 


again, Brant, you were indicating that OTIB-58 


if applied would be well above, I think you 

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mentioned, 2,000 as opposed to four or five 


hundred at the 95th percentile which would be 


the presumption for these workers working in a 


rad area. 


DR. ULSH: Yes. 


MR. FITZGERALD: So that would be the 


likelihood, likely application. 


DR. ULSH: Yes. 


DR. MAKHIJANI: The 2,000 would be for the 


whole year for shallow or deep? 


DR. ULSH: Arjun, the numbers for 


penetrating ’69, in 1969, 2,472 millirem, in 


1970, 2,071 millirem. Now non-penetrating, 


shallow dose, for the 95th percentile in 1969, 


2,574, and in 1970, 2,115. 


DR. MAKHIJANI: So the non-penetrating 


actually doesn’t cover even one quarter of one 


of these workers, right? The fourth quarter 


for this one worker is 3,460. 


MR. MEYER: That’s the normal statistics you 


expect to see. 


DR. MAKHIJANI: There are only six workers, 


and actually if you do, compare it to log 


normal for these six, you get a 95 percentile 


that’s more than the highest reading, so, 

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because there are only six workers. And so 


the, actually, one of my comments was that in 


my notes, was that this application actually 


shows that even with six workers you’ve got an 


exception in terms of coworker model. 


DR. ULSH: Well, keep in mind, Arjun, that 


they said, the policy said that badges would 


not be read unless circumstances warranted. 


That would indicate that if they followed that 


policy accurately, then the people who had 


high exposures would be monitored. You would 


not be applying coworker data to them. 


DR. MAKHIJANI: Well, you know, it’s a 


little bit of a problem technically in my view 


because you’re trying to, you know, so it’s a 


little bit of a circular argument in the sense 


that if there’s data, you assume that somehow 


it was determined that there was high exposure 


potential so they were read. And you’re now 


assuming that everybody who was somehow 


thought to be exposed, their badges were read, 


and that was then comprehensive so nobody will 


slip through your net. 


But because in your coworker model 


you’re not covering all of the people who were 

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at high exposure potential just from this list 


of six for whom we have data. So it’s a 


little bit of a problem because you’re trying 


to go back and say that they were, they knew 


pretty well when to read these badges and when 


not to read the badges when there are a 


thousand badges per quarter that they weren’t 


reading. 


 DR. LITTLE: A thousand badges for the year. 


They estimate in that --


DR. MAKHIJANI: A thousand badges per year? 


 DR. LITTLE: Yeah, a thousand packets is 


what they expected they would save by that ’69 


policy of not reading badges. If they did 


that it’d be 250 people. 


DR. MAKHIJANI: It’s still a sizable number 


to go back, and I have not seen, you know, you 


all have made a better, certainly more 


thorough evaluation of the records and are 


more familiar with them. There was a policy, 


and I have seen those exceptions that we’ll 


read there are exceptional circumstances, but 


I didn’t see any guidance for the 


implementation of that policy. How did they 


determine when an exceptional circumstance 

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happened that they got alerted and actually 


went and read the badge? 


 DR. LITTLE: Well, let’s just make a premise 


here with these six people who are zeros. One 


of these people is a supervisor. He’s the 


supervisor of these people. He knows whether 


they’re running the foundry, to make an 


extreme example. He knows we’re not running 


the foundry for three quarters or we’re 


running it on a very limited basis or 


whatever. 


He says under the policy I don’t have 


to read the badges. I don’t have to turn them 


in. Or I turn them in and I tell them we 


haven’t done anything. They don’t need to be 


read. If, on the other hand, I mean, he’s the 


hands-on guy with these people. He knows what 


they’re operating. He says it’s time, we need 


to read these badges now. 


I mean, in an operational sense I 


don’t think there’s a whole heck of a lot of 


mystery about whether somebody may or may not 


be exposed depending on the situation. If 


you’re, if that’s your job, and you work in 


that environment all the time, you’re going to 

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know if there’s some possibility of doing 


something that’s off normal, if you will, from 


what you normally do. 


And look at their ’68 doses. They --


DR. ULSH: And is it possible that a 


supervisor in that situation, or whoever’s 


making the decision about whether a badge 


should be read, could make a mistake. 


Absolutely, it’s possible, not very likely 


because you’re working with this process every 


day. But can you make a mistake? Sure, you 


can. That’s why we use the 95th percentile to 


cover instances like that. 


DR. MAKHIJANI: But when did the policy 


change from monthly to quarterly for foundry 


workers? In the ‘50s, the sheet that you 


handed out indicates monthly and now your 


foundry workers are quarterly. 


DR. ULSH: I think in 1953, Arjun, from the 


example that I’ve shown here, they were on 


monthly. But they very quickly changed to 


more frequent than that. I don’t want to give 


you an exact --


DR. MAKHIJANI: More frequently. 


MR. ELLIOTT: That’s less than a month? 

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DR. ULSH: I think so, but I would have to 


double check that. So don’t take that to the 


bank. I would have to look at the actual 


records. But I think that they very quickly, 


once they started monitoring them, they 


started on a monthly cycle, and they saw what 


kind of doses they were receiving. And I 


think they went to a more frequent badge 


exchange, but I’ll check on that. 


 DR. LITTLE: I could say that in ’69, it 


might have been ’68, we found some of these 


same people with biweekly badges, a few, just 


a very few biweekly badges. And those are 


interspersed in with the, in the lab 


worksheets. And there’s no particular 


pattern, but that again is a situation where 


on a process knowledge basis, the supervisor 


may have said, okay, we need to pay closer 


attention during this period of time or 


something. 


MR. ELLIOTT: Was that found only in 


Building 44? 


 DR. LITTLE: Well, it was just specific to 


this group and this table. I just happened, I 


mean, frankly, we’re, we were screaming 

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through these data, but I was tracking it by 


building number. And the way the lab sheets 


are organized by building number and by 


period, period being a code two is a biweekly, 


a code four is a quarterly, a code three is a 


monthly. And so you go through these things 


and you look for various buildings. And I 


happened to run across a 44, a Building 44 


period two and some of these guys were on 


there. And I didn’t have time to investigate 


that. 


MR. ELLIOTT: And the biweekly results 


produced a dose above the LOD? You didn’t 


look that close. 


 DR. LITTLE: I didn’t look at that. I 


didn’t, no. 

MR. SMITH (by Telephone): Brant, this is 

Matt Smith. 

DR. ULSH: Yes, Matt. 

MR. SMITH (by Telephone): One thing I had 

on the numbers that you quoted, we would use 


those numbers and their base line coming into 


the OTIB-58 process, and then on top of that I 


believe was also add missed dose. The way 


would do that for those years is we would 

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apply 23 cycles of a missed dose based on the 


fact that would be the highest possible 


exchange frequency for those kinds of data. 


DR. ULSH: Matt, I thought, I think I pulled 


these numbers out of Table 71 in OTIB-58. I 


don’t have that in front of me. But if I did 


pull it from OTIB-58 from Table 71, I think 


that includes missed dose but double check 


that, please. 


But at any rate this is at least, I 


mean the numbers I gave you are the minimum or 


the actual numbers. We might be adding missed 


dose on top of that. 


DR. MAKHIJANI: Could we request some of the 


data that you, Craig, that you looked at so we 


can kind of go back and look at a little bit 


of it in this final stretch? That would be 


helpful. 


 DR. LITTLE: You want the laboratory 


worksheets? 


DR. MAKHIJANI: Or tell us where they are, 


you know, where they are in these --


MR. GRIFFON: When you say laboratory 


worksheets, are you talking job history 


worksheets or a different worksheet? 

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 DR. LITTLE: These are worksheets, the 


handwritten laboratory worksheet. 


DR. MAKHIJANI: Are they in the site 


research database somewhere? If you can just 


send me an e-mail with the site research 


database. 


 DR. LITTLE: They’re all available on the O 


drive. I know that. 


DR. MAKHIJANI: I’ll try to find it myself. 


MR. ELLIOTT: Let’s hold it in for you. 


DR. ULSH: All right, I’ve got a member of 


the team looking in the Building 44 DU workers 


put on a weekly exchange frequency starting in 


May of 1954. 


DR. MAKHIJANI: Weekly? 


DR. ULSH: Yes. 


DR. MAKHIJANI: And were there any non-zero 


doses then? 


DR. ULSH: I didn’t ask that. There might 


have been. 


MR. GRIFFON: Listening to what you said, I 


think the foundry worker might be a good case 


example if we can find in our fourth item on 


the agenda some samples. Because I think you 


said that that, that you may apply the 

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coworker model depending. And I think a real 


example of a foundry dose reconstruction might 


be a good thing to look at in the final 


stretch. 


DR. ULSH: Mark, I can commit to trying, but 


I do want to caution --


MR. GRIFFON: You may not have one. 


DR. ULSH: Exactly, because first of all the 


number of claimants that had employment -- now 


wait a minute. Are we talking about ’69 and 


’70? We are, right? 


MR. ELLIOTT: We’re talking about ‘50s. 


DR. ULSH: Okay, the number of Rocky Flats 


claimants with employment in the ‘50s is not 


great. And keep in mind that in terms of 


coworker dose, coworker dose reconstructions, 


that came late. So a majority of the dose 


reconstructions that we’ve completed were done 


without coworker data. And then I can’t think 


of an obvious way to say this person is a 


foundry worker without just going in and 


looking manually. So I will try, but I can’t 


commit that I can actually find one that meets 


all those criteria. 


DR. MAKHIJANI: Mark, do you think that in 

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the absence of that, looking through some of 


these datasheets and maybe tracking a couple 


of individual workers would be helpful? It 


seems it would be helpful to try to resolve. 


If Brant can’t find an actual dose 


reconstruction example in that area, it might 


be helpful. 


We can just go through that since, you 


know, this is the first time we’ve actually 


found, you know, it seems like a fairly 


extensive data, and they have weekly data and 


so on which indicates that they weren’t in 


that three month swap where we tended to find 


the gaps. 


DR. ULSH: I think, Arjun -- and I don’t 


want to put words into your mouth -- I think 


the places where you found gaps corresponded 


largely to Building 881, but I don’t know if 


you’re -- Is that your recollection? 


DR. MAKHIJANI: I just want to -- no, I 


don’t remember actually. I’d have to go back 


to the table and look, but there was more of a 


Plant B. Would that be 881? 


DR. ULSH: Plant B is Building 881. 


DR. MAKHIJANI: Right, so if I recall, it 

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was more of a Plant B in the sample of gaps, 


yes. 


MR. GRIFFON: Well, I guess the datasheets 


that you’re talking about, Craig, are these, 


what datasheets are we talking about that are 


on the O drive that you, they’re not from 


individual radiation files? 


 DR. LITTLE: No, they’re laboratory 


worksheets. 


MR. GRIFFON: Laboratory worksheets, that’s 


what I’m looking for. 


 DR. LITTLE: And they are, that’s what they 


were. They’re film badge worksheets. 


DR. ULSH: For the ‘50s. 


 DR. LITTLE: No, I’m talking ’68, ’69. 


DR. ULSH: That’s what you’re interested in 


’68, ’70? 


MR. GRIFFON: That’s why I’m clarifying. 


 DR. LITTLE: He wanted ’68 and ’69, Arjun 


did. 


DR. MAKHIJANI: What was Bob looking at just 


now for in terms of Building 44 in the ‘50s 


for the weekly --


DR. ULSH: That is the example that I passed 


around. The example that I passed around. 

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That’s one example. And those are in the site 


research database, but we’ll point you to it. 


MR. GRIFFON: So you can put those all in 


one spot, and I guess consider those in your 


file. That’s what I would say, right? 


DR. ULSH: That’s for the ‘50s. 


DR. MAKHIJANI: That would be there then. 


MR. GRIFFON: Can I --


DR. ULSH: Yeah, I’m done. I’m done. Go 


ahead. 


MR. GRIFFON: I think we’re almost ready to 


break for lunch, but I had, just with these 


case write-ups. I think I -- or Joe, I saw 


your e-mail trail on this with the question of 


supporting data to back this up. And maybe I 


can just explain why I’m asking this. This is 


just one example that I happened to grab here. 


It’s the job title’s a photographer 


worked in a cold area, and 15 years all he got 


one gram total exposure, and then it says file 


consistent with monitoring policies at the 


time. What I don’t understand is if I look at 


SC&A’s, a review of SC&A’s findings they say 


missing ’58 through ’61, comma, ’63, comma, 


’69. And then there’s a lengthy comment about 

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the ’69 zeros versus blanks. I don’t know if 


you went through this in a way that we said, 


okay, here we had this guy. 


We, first of all, I’m not sure he was 


a for the entire time period, and if 


he was, and he worked in a cold area, why 


would he be badged some years and not others? 


Was he going in, I just don’t get it. If I 


saw a clean sheet, and it said no monitoring, 


then I could take your argument of worked in a 


cold area, a , no data. I don’t 


expect any, but he has some and then he has 


missing periods. That’s what doesn’t make 


sense. 


DR. ULSH: This is a good example, Mark. 


Let me tell you how I approached it. How I 


and the other team members approached this 


particular one. I knew this guy well. Let me 


rephrase that. I’m very familiar with this 


guy. This is the who went into 


Building 776 after the fire, right? Yes, and 


it was one of the ones SC&A was concerned 


about because he was subject to that policy of 


non-reading in 1969. And that’s why you see a 


period with no monitoring data in ’69. Now 

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124 

 

what about the other years there where he 


doesn’t have data? The way that we approached 


this was we went to NOCTS and pulled out this 


particular claimant’s job exposure, job 


history card. It’s listed as personnel 


exposure, and that’s where we determined where 


he was stationed and what his job duties were. 


He was a at --


MR. GRIFFON: But he didn’t lay this out is 


my guess. I mean, if I was poking through 


this I might lay it out. Here’s his years of 


work. Here’s his data. Here’s his jobs over 


time. This is why we see these gaps. 


DR. ULSH: I didn’t reproduce his job 


history card in this response. I was looking 


at it when I was looking at the years in 


SC&A’s table where there was no monitoring 


data, and I said, a-ha, in this year he was a 


in whatever building. So I mean I had that 


data available in front of me, and I went 


through and addressed, well, we went through 


and addressed, considered each of those years 


where he didn’t have data and what was he 


doing at that time. That’s how we approached 

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MR. GRIFFON: So it may be that he had a 


different job in the interim or something like 


that. I guess that’s what I’m trying --


 DR. LITTLE: I don’t think, in this 


particular case I don’t believe so. 


DR. ULSH: I think he was a . 


MR. ELLIOTT: He might have been assigned to 


go take at a rad area where he --


MS. MUNN: This has certainly been the case 


on other sites. I know several who, 


generally speaking, have no need to be 


monitored. 


MR. GRIFFON: I don’t dispute those, I mean, 


those are obvious general statements anybody 


can make. That’s clear. I’m just asking --


DR. ULSH: Mark, if you wanted --


MR. GRIFFON: -- if I wanted a detailed 


review, how do I, you know, a , how do 


you, how can you make, but how do you 


determine for those years that were missing he 


was working in cold areas, but then for those 


years that he had data, you know, all of a 


sudden, I mean I guess it’s just basically are 


you saying they made the right decision or is 


there more there that indicates that he was, 

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you know. 


DR. ULSH: Here’s how you can get more 


information on this. If you’ve got the NIOSH 


ID there -- and don’t repeat it because I 


think that’s Privacy Act, but we can go on 


NOCTS and --


MR. GRIFFON: No, I have the job history 


cards. --


DR. ULSH: Oh, you do. 


MR. GRIFFON: I’m just wondering if in your 


putting together this, that you had a 


spreadsheet built then I wouldn’t have to. 


I’m hoping that you saved me a step and I 


could look at your analysis files of how --


DR. ULSH: There is no spreadsheet. 


MR. GRIFFON: You just went right from the 


hard copy PDFs to this report. 


DR. ULSH: Exactly. There’s no Excel 


spreadsheet. There’s a spreadsheet in my head 


when I did this, when I laid the job exposure 


card versus the table that SC&A constructed 


that showed which years he didn’t have data. 


I took those and laid them side by side and 


said what is the explanation if there is one 


for all these years that he didn’t have data. 

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And also, something else that 


indicates that he was at low exposure 


potential is that for the years that he was 


monitored, his doses were very low. So I mean 


you would have to make the assumption that for 


some reason they monitored him in the low 


exposure years but didn’t monitor him in the 


high exposure years, and I don’t think there’s 


any evidence for that, and that would be an 


assumption that wouldn’t be intuitive to make. 


But that’s how we approached each of these 


cases. 


MR. GRIFFON: Yeah, I’m just trying to 


understand from a policy standpoint how 


someone would take that kind of person on or 


off of a badge program. It seems like he 


might be doing various things around the plant 


all the time, and how they determined in one 


year he was just taking pictures in cold 


areas. 


MR. ELLIOTT: Wouldn’t you have to look at 


the areas that he wasn’t monitored in and 


verify that they weren’t rad controlled areas. 


DR. ULSH: Well, actually you bring up a 


good --

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MR. GRIFFON: And I don’t know if you have 


that much information on the work history 


card. 


DR. ULSH: I don’t, but you bring up a good 


point, Mark, and that is you’ve got workers 


who were officially stationed, you know, 


wherever it was, cold areas or wherever. But 


on occasion they might have gone into Building 


776 or some other area where people who work 


there all the time were at higher exposure 


potential. That is certainly true, and this 


is a case in point. This guy went into 


Building 776 after the fire. But in 


determining his total dose potential you have 


to take into account not only the dose rate 


that he might have been exposed to, Building 


776 tended to have higher dose rates than 


other areas onsite. But you also have to take 


into account the amount of time that he spent 


there. As a to go in for an hour and 


and leave does not in and of itself indicate a 


high exposure potential. So you got to, you 


know this. 


MR. GRIFFON: What I don’t get is how 


someone makes that decision, you know, from 

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year to year. Maybe a supervisor or maybe he, 


himself, determined, I don’t know how that 


kind of person goes on and off the program 


that much. But the main question I wanted was 


to see if you had backup analysis for the 


document that could help me just review that 


quickly. 


DR. ULSH: I’m sorry I can’t save you that 


step. 


MR. GRIFFON: The job history cards we have 


will --


DR. ULSH: Yes. 


MR. GRIFFON: -- and we can certainly pick 


out a few that were some questions about and 


review them that way. That’s fine. 


Joe, did you have any, Joe or Arjun, 


Arjun’s not here. Is there anything before we 


break for lunch? 


DR. MAKHIJANI: Let me just look at my 


notes. 


MR. FITZGERALD: And if this was the case 


for all these cases that you were able to by 


virtue of the job histories be able to 


construct an explanation. I mean, it seems 


like except for the one case that was detailed 

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enough and plausible enough to make that call. 


DR. ULSH: That was our conclusion, but let 


me clarify something you just said. The job 


exposure histories, those cards, they only 


exist for --


MR. FITZGERALD: Up through. 


DR. ULSH: Well, up into the ‘80s and only 


for prime, employees of the prime contractor. 


So if you have an S&W guy, you’re not going to 


find a card. And I don’t think that it’s true 


to say that even a 100 percent of the primes 


have the cards as well. I can’t swear to that 


fact. 


 DR. LITTLE: I think that’s correct. We 


have some of them at least, but not very many. 


DR. ULSH: Not many, but --


 DR. LITTLE: They have a card and it just 


doesn’t have all the information. We know he 


worked there for a longer period of time, but 


it doesn’t show, it doesn’t have every job 


change he ever went through. 


DR. ULSH: But by and large the cards are 


there for the primes, and that was the primary 


resource that we relied upon to determine 


their work histories. Now, if that wasn’t 

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there, for instance in the case of 


subcontractors, we went into the actual rad 


file to look for clues. Like on the 


urinalysis cards, what buildings that they 


were in. Frequently some of the earlier 


urinalysis cards, and there’s also 


documentation in there for what employer, who 


their employer was. That’s how we determined 


that they were subs. 


 MR. FITZGERALD: And the only fly in the 


ointment in a sense though, even though I 


think the photographer clearly went into 776, 


the dosimetry department really just knows 


that these individuals were assigned to, say, 


44 and 41 and based on that that they would 


not monitor or would not read the badges 


unless in fact the supervisor would call them 


out. 


So in a sense you don’t really know if 


these workers might have moved around even 


though they had the same department number. 


The supposition is that they probably worked 


and stayed in those areas unless you have 


information otherwise. I mean, that part of 


it, that’s the only part that can’t 

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necessarily be pinned down by the job history, 


that they moved around. 


DR. ULSH: I think it would be over-


interpreting the job exposure history cards to 


say that if a person was based in Building 


123, he never went to 776. I wouldn’t make 


that assumption at all. But I think that he, 


you can make the assumption that he spent most 


of his time probably in 123 and periodically, 


occasionally, maybe went into the other 


buildings. 


 MR. FITZGERALD: Right, the situation you 


see at some sites where even though they 


carried the department number, they actually 


did something entirely different or did other 


work. 


DR. ULSH: Joe, I don’t think you would 


expect that, but I don’t necessarily want to ­

-


MR. GRIFFON: Well, the one example, but 


there was a pipe fitter in there, and that was 


one I would question. I would question the 


crafts. Sometimes they work out of a, and 


maybe it would have been a clean pipe shop but 


they get sent to the various buildings --

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MR. FITZGERALD: We went through this at Y12. Sometimes what shows up on the job card 


doesn’t reflect what they end up doing because 


they get, go over and help so-and-so in 776 do 


this kind of maintenance work, and because the 


reader’s only going to see the department 


number, they’re going to say, well, this 


person’s in a low exposure area. We’re not 


going to read the badge, but yet maybe they 


were doing other work. Now I think for a lot 


of these that wouldn’t be the problem, but for 


the crafts, there’s a few crafts people I 


think you pointed out --


DR. ULSH: I think actually though, and 


they’re all flowing together for me now, I 


know that I have seen pipe fitters who were, 


who operated out of Building 776. They did 


jobs in there and you do see monitoring data 


for them. I don’t want to overstate the case 


though. 


MR. FITZGERALD: Right. 


DR. ULSH: I mean I think that would depend 


on where they were located. 


MR. GRIFFON: I guess then in summary if 


we’re wrapping this one up, and I think we 

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are, I think the biggest and most important 


new piece of information I heard was, which 


may make this sort of analysis more difficult, 


is that there wasn’t a clean policy in ’64 to 


monitor 100 percent. I mean, that wasn’t, it 


was in part based on their radiation exposure 


potential. 


DR. ULSH: That was a misinterpretation on 


our part. 


MR. GRIFFON: And that does make it 


difficult. We don’t have that bright line 


anymore to say, you know, even though this 


person’s a secretary post-’64, they should 


have been monitored. That’s not the case. 


That does make, that makes the evaluation 


certainly there’s more gray in there. But I 


mean that’s where we’re at so we’ve got to 


deal with it. 


And then the ’69, just for one final 


clarification, the ’69 in the memo, there’s no 


indication that that was prior, that policy of 


not reading even when people were badged, not 


reading some badges, it didn’t extend to 


prior, I know you looked post, but did you 


look prior to ’69? There’s no indication that 

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it would have started before. I can’t 


remember how the memo read. 


DR. ULSH: You’re right. 


 DR. LITTLE: The memo was written for the 


March report, the March progress report in 


1969, and so it took effect for the first 


quarter. 


MR. GRIFFON: And it said we initiated this 


policy --


 DR. LITTLE: Yes. 


DR. ULSH: And the other thing, recall the 


thing that originally brought this to our 


attention was SC&A found that there were high 


zeros, and we didn’t see that in ’68. We did 


see it in ’69 and ’70. So the weight of the 


evidence, Mark, doesn’t suggest that it was 


before then. 


DR. MAKHIJANI: A couple of things. One 


sort of one thing of detail and one of a 


bigger thing. Page ten of NIOSH’s 1969 


report, in the middle there it says Table X-4, 


NIOSH Response Table X-4 is slightly 


misleading with the column labeled Deep Dose 


1969 refers only to the first quarter. It’s 


not clear what information we gleaned. I just 

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wanted to clarify that. And in our 1969 


paper, Table X-4 is labeled, I think, Fourth 


Quarter 1968 and First Quarter 1969. So I 


think there should be no confusion about 


what’s in there even though the titles in the 


individual columns --


 DR. LITTLE: I understand that. 


DR. MAKHIJANI: So the point of the 


comparison was similar to what you did for the 


full year, 1969, just if you look at case 


number 102 and 103 -- and these are made up 


case numbers -- the beta dose was 1240 


millirem and 1880 millirem. That was more 


than ten percent of the exposure potential, 


but then they were, their badges weren’t read 


in the first quarter. Now there may be an 


explanation for that or not, but we found that 


if you just literally interpret the policy for 


people with low exposure potential, their 


badges weren’t being read and here you have a 


couple of examples at least of people over the 


ten percent limit whose badges weren’t being 


read, and you know, all of them were non-zeros 


above the limit of detection. 


 DR. LITTLE: Well, the policy doesn’t say 

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ten percent. That ’69 policy doesn’t say ten 


percent. 


DR. MAKHIJANI: Right, I agree with that. 


 DR. LITTLE: That’s a different memo that 


has to do with a different issue. 


DR. MAKHIJANI: The consistence or 


implication has been the common thread is low 


exposure potential, and the reason I say ten 


percent --


 DR. LITTLE: That part’s true. 


DR. MAKHIJANI: -- is that that’s the one 


quantitative guideline that has been 


consistently on the table as to what the term 


means other than whatever, unless you’re 


interpreting it to say whatever the supervisor 


thinks on any given day. The only 


quantitative analysis is that ten percent of 


exposure potential. 


So I’m just saying if I seem puzzled 


why this table is there. And that’s why this 


table is there. First of all there’s a bunch 


of non-zero readings and then a couple of them 


were over the ten percent exposure potential. 


Then their badges weren’t read in the next 


quarter. They don’t make a judgment about 

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what happened there, but it certainly raised a 


question. All these things were put in there 


because it raised a question. 


 DR. LITTLE: I guess one of the questions 


would be is ten percent a significant number 


or not. 


DR. MAKHIJANI: Well, it seemed to be 


significant in terms of the policy of the time 


as NIOSH has represented it --


 DR. LITTLE: But the 1969 policy that 


doesn’t say ten percent. I keep saying ten 


percent, but that policy doesn’t say ten 


percent. It says significant. 


DR. MAKHIJANI: And was there an idea then 


of what significant might be if not ten 


percent? 


DR. ULSH: Not defined. 


DR. MAKHIJANI: Oh, I think that multiplies 


the problem. 


DR. ULSH: It’s not defined in and of 


itself. The memo itself says people who were 


in non-plutonium areas on quarterly badge 


exchange cycles would not be, their badges 


would not be read unless circumstances 


warranted. That’s all it says. 

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DR. MAKHIJANI: I have read the memo. I 


understand that, but you know, if it is that 


subjective as being now presented, that 


implicitly, I understood that implicitly at 


least the supervisor’s guideline would be ten 


percent even though the memo doesn’t say that. 


I agree with you on that. It does say 


extraordinary circumstances or some such 


thing. The badge will be read when warranted. 


 DR. LITTLE: I think it’s important to keep 


in mind these are quarterly badges, too, these 


are not monthly badges. There are a bunch of 


other people out there getting monitored on a 


monthly basis, on a biweekly basis --


DR. ULSH: And the policy doesn’t affect 


them. 


 DR. LITTLE: Right, the policy’s not, I 


think we’ve got to keep that in mind that if 


someone in a supervisory or the health physics 


operations role was to decide who was on a 


quarterly or who was on a monthly, you’re not 


going to put somebody with a high potential on 


a quarterly badge. 


DR. MAKHIJANI: Well, naturally you only 


looked at quarterly badges here. 

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140

 DR. LITTLE: You’ve got to keep that in 


mind. This population is low exposed, period. 


MS. MUNN: One of the things that seems 


fairly obvious when you’re determining policy 


with respect to radiation exposure on a site 


like Rocky Flats where you have such a strong, 


well-rounded health physics department 


overseeing these issues, it would seem logical 


that the health physicists would have been 


part and parcel of any policy-making with 


respect to where exposures could or could not 


be considered to be, to have an impact on the 


workforce. 


So when we talk about who makes these 


decisions, and you’re talking about a site 


where you have professionals designated to 


make those decisions, can’t we be reasonably 


certain that the health physics staff 


certainly would have made surveys in all these 


areas would be the final authority with 


respect to what workers were likely to be 


exposed and which ones were really low 


exposed? 


DR. MAKHIJANI: You know, I don’t think it’s 


a question about whether there was a final 

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141 

authority or not. It’s a question in my mind 


as to how you go back and know what the 


quantitative implications of what they were 


thinking in the context of putting a number to 


it for somebody’s dose which is the problem at 


hand. And some of these numbers indicate that 


some people were exposed. 


One guideline we have from the ‘50s 


that a quantitatively low exposure potential 


is ten percent, and you use that as a 


guideline in this context to decide whether 


there was some consistency in that policy or 


not. It’s not clear that there was. 


And now maybe the foundry workers were 


all monitored and we’ll take a look at that. 


But when we found the data gaps, it wasn’t 


clear from the universe of people that may not 


have been monitored or whose badges weren’t 


read as to what the import of those judgments 


were for dose reconstruction. 


So it isn’t like casting aspersions on 


what the health physics staff did. It’s a 


question, answering a different question than 


what they were trying to answer. How do you 


go back and put a number that says this is a 

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bounding dose for this population of people 


which is a very different question I think 


than those that we’re trying to answer. 


DR. ULSH: Well, let me perhaps address that 


question directly. What do you do? You have 


this policy in place that people who were 


wearing badges but weren’t monitored. By and 


large I think we’re safe in assuming that 


these people were at low exposure potential. 


Now I can’t tell you that every single one of 


them was. I can’t tell you that. I mean, 


this is a human institution. Mistakes happen 


sometimes. 


But what is the implication of having 


these zeros that aren’t really zeros. 


They’re, in fact, unmonitored. And I think 


SC&A’s correctly pointed out that in this 


situation you can’t just blindly assign missed 


dose and assume that it bounds the exposure. 


That is entirely correct. You have to 


consider, if you’re going to do that, you have 


to provide some rationale for doing that. 


And I think that we have made an 


attempt to do that by showing when people were 


monitored, what were they getting compared to 

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143 

the coworker doses. And we’ve presented, I 


think, a fairly strong case that in fact 


applying missed dose here in this situation 


would by and large be claimant favorable. 


But even if at the end of the day the 


working group disagrees with that, you know 


what, we just don’t find that convincing. 


Well, we always have the option of saying 


these zeros that we see in 1969 and ’70 are 


suspect. They’re not real. We can’t really 


work with them so we throw them out. We don’t 


use the zeros when we calculate coworker 


distributions. We use only the positive 


recorded doses. Now that’s a possibility. 


Of course, it’s going to make the 


coworker doses go up. Of course, it will, 


especially at the 50th percentile. I think 


it’s better to go with the missed dose 


approach, but if at the end of the day the 


working group doesn’t concur, then that’s 


always a possibility. I don’t think this is 


an SEC issue because we have a way to address 


it. It’s just a matter of agreeing on what 


way is appropriate to address it. 


MR. ELLIOTT: Another option might be -- if 

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I can throw this on the table -- another 


option might be that you take up the 


assumption that those people who were badged 


but the badges weren’t read, they’re 


unmonitored, had a similar, if not the same 


type and level of exposure potential as when 


they were badged and the badge was read and 


use that assumption to build your distribution 


and take your appropriate percentile. 


DR. ULSH: I think that would be claimant 


favorable. 


MR. ELLIOTT: I think it would be claimant 


favorable. 


DR. ULSH: Because you recall what happened 


in ’69 compared to, say, 1968. ‘Sixty-eight, 


Rocky Flats is operating. They’re producing 


plutonium and uranium. No, I’m sorry. The 


enriched uranium was gone by then. They might 


be (unintelligible) used up. But in ’69 we 


had that fire that shut down plutonium 


operations essentially for a large chunk of 


the year. So I think if you assumed that the 


conditions that might have applied in, say, 


1968 would bound 1969. That would be a safe 


assumption because of that event if for no 

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145 

other reason. 


MR. ELLIOTT: That’s just another option. 


DR. MAKHIJANI: Let me lead to a bigger 


point which is in our report, we raised two 


issues with regard to 1969. One was the issue 


of, you know, you’ve got these zeros that 


really were gaps that are different than limit 


of detection. 


MR. ELLIOTT: It’s not a missed dose. 


DR. MAKHIJANI: The gaps when badges were 


not read, you’ve thrown away the badges. You 


have no way to verify what actually happened 


because the badges were thrown away. The 


position in our paper was that once you throw 


away the badges and don’t read it in the first 


place, that becomes a data integrity problem 


of some proportion. Whether the doses were 


low or not. 


Even if all the judgments that were 


made were right, and the people were actually 


exposed to very low levels of radiation 


becomes a problem in its own right. And we 


said would we meet the normal tests of 


scientific integrity. And that’s what, the 


judgment that was made in the report that we 

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sent you. 


So there’s got to be some way of 


dealing with, it was done not with the intent 


of covering up high doses or anything, and we 


said that, too. It wasn’t done with that 


intent. It was done with the intent of 


following that policy. But now you’ve got a 


set of data in which two kind of zeros are 


mixed up. And moreover, one set of zeros in 


1969 resulted from a questionable policy at 


best. 


And so then the question how you deal 


with, how do you mix up the values from a 


questionable policy with legitimate values 


that were zeros from reading badges. And I 


think dropping, there may be, there are 


solutions to it that’s up to the working group 


and the Board to determine. But that is kind 


of an issue in its right that needs to be 


addressed. 


But I agree on that, you know, you say 


that they need to be disentangled, and they 


do. These two kind of zeros need to be 


disentangled. 


DR. ULSH: Well, we could, okay, now that we 

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know that there are a certain population of 


zeros that really can’t be trusted because 


they’re actually unmonitored doses, we’re 


faced with a couple of questions. I mean, we 


can tell by looking at the laboratory 


worksheets which ones are the ones that 


weren’t read because there are zeros at the 


top and a red arrow down the page. So we 


could go through and manually pull those out. 


Alternatively, for reasons of 


efficiency and it’s claimant favorable, we 


just say, you know what? Forget it. Take all 


the zeros out. There might be some legitimate 


zeros, but it’s claimant favorable to go ahead 


and just take them out. And for terms of 


efficiency I don’t care about, I mean I don’t 


have any objection to giving workers a little 


higher than what they got. I don’t have a 


problem with that just for a matter of --


MR. GRIFFON: I thought at one point you 


also indicated that this was all quarterly 


people. So you can find quarterly and drop 


all the quarterly end zeros. 


DR. ULSH: Yeah, you can do that, Mark, if 


you go in and manually find out, find those 

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148 

quarterlies. I might be confusing a couple of 


issues now, but I think in HIS-20 there’s a 


lump sum prior to a certain year, and I don’t 


remember which, some time in the ‘70s. So it 


might not be easy to do that. 


 DR. LITTLE: Yeah, that would have been ’69 


or ’70. 


DR. ULSH: It might not be easy to do that 


on a systematic basis, but yeah, you could do 


that. We could do that. 


MR. ELLIOTT: Can we agree that this is a 


site profile dose reconstruction issue and how 


we go about handling missed dose versus 


unmonitored dose in the sense and not an SEC 


issue? 


MS. MUNN: I certainly agree that’s the 


case. 


MR. GRIFFON: I think there’s still this 


proof of process question that I have, but I 


think it’s, I think we’re close to there. I’m 


not sure I’m there yet. 


MR. FITZGERALD: It’s becoming more 


tractable. 


MR. GRIFFON: I mean, I think we need some, 


there is still proof in my mind --

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149 

MR. FITZGERALD: I think this goes a long 


way to explain the process and the fact that 


the data can be worked which is not something 


that was clear before. So, yeah, I think in 


terms of just understanding how it would be 


implemented, it’s sort of the gold standard 


with the actual, get an actual claim, but I 


understand that’s a tough proposition. 


DR. ULSH: And we’re not going to have a 


claim that exists currently. 


MR. ELLIOTT: I understand your intent of 


proof of process, but only, I’d offer this 


only for your consideration and for the 


record. Proof of process is not going to be 


fully established until the last claim is 


reconstructed. As we do individual dose 


reconstructions every claim has its set of 


circumstances around it that could be brought 


to question. And so, yes, I want a healthy 


pursuit --

MR. GRIFFON: And that’s what I’m saying. 

MR. ELLIOTT: -- of process as best we can. 

MR. GRIFFON: And that’s why we identified 

that’s sort of illustrative of what we want. 


MR. ELLIOTT: Just keep in mind. 

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DR. ULSH: Now, Mark, for this case, I mean 


this particular case where there’s not going 


to be an existing dose reconstruction that 


illustrates how we would handle this. I mean 


we can set up just as an example a dose 


reconstruction like we presented before. You 


know, a worker who worked from 1968 to 1971, 


and here’s how we would reconstruct his 


external dose, and he’s unmonitored. That 


would be a simple example to put together and 


to show to the working group how we would do 


this. Is that the kind of thing that you’re 


talking about? 


MR. GRIFFON: Well, I think that you have 


for these coworker ones I think you’ve 


identified. You gave us a count at the last 


meeting of 100 and some that used OTIB-58. 


DR. ULSH: That is true, Mark, but keep in ­

-


MR. GRIFFON: Why don’t I just pick one of 


those cases? 


DR. ULSH: Well, keep in -- I can do that, 


but keep in mind that OTIB-58 as it is 


currently written doesn’t incorporate these 


things that we’ve talked about. 

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MR. GRIFFON: Okay. 


DR. ULSH: Excluding the zeros or applying 


missed dose or, well, it does incorporate 


applying missed dose, but it kind of 


determines what kind of agreement we come to. 


MR. GRIFFON: I think that, I mean, it may 


be that we see that example and we say we’re 


comfortable with this approach. We don’t need 


to drop all these -- I mean, you know, I would 


say at least offer that and then maybe you can 


add on an explanation that, you know, look at 


this and consider our discussion at the last 


work group meeting. We could possibly do this 


for this time period or whatever. 


DR. ULSH: I will take that as an action 


item to locate the dose reconstructions 


currently completed using external coworker 


data in 1969 preferably, and ’70. I’ll try to 


find one of those for you. 


MR. GRIFFON: I don’t think it has to be 


adjudicated unless we do a full case review, 


right? We’re not --


 MR. SHARFI: Most of those are more recent 


which might not be adjudicated. 


DR. ULSH: I assume that that’s not an issue 

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unless we --


MR. ELLIOTT: You can do that. You just 


can’t report out. 


DR. MAKHIJANI: But is there some value --


there is in my personal opinion, but is there 


some value for this issue where non-reading of 


issued badges has resulted in zeros and data 


records, simply purge that data record, and 


you’re saying you’ve identified a set of data 


that for the particular reason, bad data, 


purge the record of the bad data. And as a 


result, so you’ve gotten, there’s a process 


issue there of how you treat that data. And 


then you can also show, obviously, the result 


of that that the reconstructions become more 


claimant favorable because you’ve removed a 


bunch of zeros. And I don’t know if that 


solves everything, but I kind of have a 


concern about a process that leaves data 


that’s been identified as having an integrity 


problem. There’s agreement --


DR. ULSH: There’s two parts --


DR. MAKHIJANI: -- yeah, so I see this as a 


two-part issue. How do you deal with 


identified bad data? And I think one way to 

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deal with it is to get rid of it. I mean, 


potentially, of course, this is new --


MR. GRIFFON: Just a possibility. 


DR. MAKHIJANI: -- and I think Brant did 


bring that up so that struck me as something 


that, and Larry mentioned it informally 


earlier on, and it struck me as something that 


would be valuable to consider because it’s a 


precedence. It’s the first time we’re dealing 


with a situation --


MR. GRIFFON: Yeah, Jim, go ahead, Jim. 


DR. NETON (by Telephone): We keep talking 


about integrity issues and bad data, and I 


think that a little bit oversteps the issue. 


I view these workers, and essentially we would 


treat them as unmonitored workers, period, as 


if the badge was never issued. I’m not sure 


how that would create a data integrity issue. 


I mean, then you have the situation of 


deciding whether the workers who were 


processed with their badge readings were 


actually representative of the workforce, or 


if not, were these the highest exposed workers 


in the workforce. The only way that would 


become invalid is if they selectively threw 

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away the highest badges they could find or 


they thought would be high. 


MR. GRIFFON: Right, we have all indications 


that it was the other, the reverse. 


DR. NETON (by Telephone): It’s a little bit 


overstating the issue to say that there’s the 


bad data and integrity issues here. 


DR. MAKHIJANI: Well, the only way in which 


I used that, I did not use it in the sense 


that you were talking about. What you were 


saying is can it be addressed technically and 


was there some kind of malfeasance, you know, 


they were trying to cover up high doses. And 


I think we’ve said explicitly that they were 


not, that we haven’t found any evidence that 


this was some kind of a problem or trying to 


hide high doses. It wasn’t to the best that 


we can tell. 


The only reason I used those terms and 


the terms that are there in our report is when 


you issue badges that you didn’t read and 


threw away the badges and then wrote zeros, 


this seems to me like a problem in its own 


right even though we know that these workers 


were on quarterly cycles and generally judged 

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to be in lower exposure potential and all of 


that. It may be that in some other situation 


that that may not be a low exposure potential 


people and you have to decide how you’re going 


to deal with that. 


MR. ELLIOTT: It seems to me we ought to 


take the zero as a zero. 


DR. MAKHIJANI: Right. 


MR. ELLIOTT: If the recording had been not 


read, then I think we’d be in a different, we 


would all be saying, hey, we won’t use that 


stuff. We misinterpreted -- as I understand 


it -- those zeros and treated them as missed 


dose where we should have treated them as 


unmonitored dose. 


DR. MAKHIJANI: That’s right. And when that 


is done then the data integrity problem --


MR. FITZGERALD: Yeah, I think that takes 


care of it. 


 DR. WADE: We need to think a little bit 


about lunch. 


MR. GRIFFON: Yes. 


 DR. WADE: What time do you think we want to 


get back so I can tell these people. 


MR. GRIFFON: About 1:30. 

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 DR. WADE: We’re going to aim at 1:30 to get 


back. We’re going to break contact and aim at 


1:30. 


(Whereupon a lunch break was taken from 


12:30 p.m. until 1:30 p.m.) 


 DR. WADE: Is Robert Presley with us? 


Robert? 

MR. PRESLEY (by Telephone): Yes, I am. 

 DR. WADE: And Mike Gibson? Mike, are you 

with us? 

 (no response) 

 DR. WADE: Mike Gibson on mute? 


 (no response) 


 DR. WADE: Any other Board members on the 


line? 


 (no response) 


 DR. WADE: Any other members of the Advisory 


Board, fine people all, on the line? 


 (no response) 


 DR. WADE: Okay, we’re ready to begin here 


then. 


Mark. 


MR. GRIFFON: I don’t know if we have 


anything more to close out of data 


completeness. I think we kind of wrapped it 

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up on data completeness. And if that’s the 


case, let’s go to move on to the thorium 


question, the next thing on the agenda. The 


last report came from NIOSH, right? 


THORIUM ISSUE
 

MR. FITZGERALD: Right, we really came down 


to two fundamental issues for thorium. One 


was the question, source term and some of the 


relatively recent information that came out of 


the Dow discussions. And the other issue, I 


think, is the model itself, NUREG-1400. So 


those are the two focal points. There are 


some other issues, but those are the two key 


ones that we’ve addressed, and I think we’re 


prepared to respond to both of those. 


DR. MAKHIJANI: Do you want us --


MR. FITZGERALD: Yeah, you can jump in. 


DR. MAKHIJANI: It’s a long paper, and I 


can’t say we’ve gone through it all carefully 


so it’s a little bit of a preliminary 


response. But just to get to the main issues 


that were there in terms of NUREG-1400, NIOSH 


has done some new analysis in terms of 


validating NUREG-1400 with data from a couple 


of sites. The issue really goes quite a long 

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ways. They’ve taken their data from the site, 


from Simonds and one other site --


DR. ULSH: Rocky Flats. 


DR. MAKHIJANI: Rocky Flats, I read it very 


early in the morning. 


UNIDENTIFIED: Can you turn up the volume a 


little bit? We can hardly hear anyone. 


 DR. WADE: We’re going to try. I don’t know 


whether that works for you. We’re going to 


also do some microphone readjustment 


spatially. 


MS. MUNN: And persuade Arjun to speak up. 


 DR. WADE: Ask Arjun to speak up and not 


into a computer. 


DR. MAKHIJANI: From Simonds the data 


validation took a weighted average data, 


compared it to the NUREG-1400 result, and the 


differences in this analysis compared to the 


October analysis that NIOSH did was that there 


were two factors of ten that were not in this 


comparison. The source term was not reduced 


by a factor of ten, and the confinement factor 


was assumed to be one since, in this case, it 


was unventilated compared to the assumption 


for Rocky Flats, ventilated. 

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159 

And the comparison came out quite well 


for, in both cases, for NUREG-1400. The 


reservation that I have about this Simonds 


analysis -- I don’t remember the other one as 


well -- it is that it was done on the basis of 


a weighted average. And we have on previous 


reviews, both in an SEC and TBD context, for 


instance, at Mallinckrodt said that you can’t 


use weighted averages for bounding dose 


estimates. And that’s what we’re after here 


is if we’re after a bounding dose estimate, a 


weighted average can’t be used to validate 


NUREG-1400 for that. Because there are a lot 


of variations from one day to the next, and 


one worker to the next, and you need something 


like a 95 percentile to validate it. 


And very often in the early days, like 


at Simonds, I don’t know about Simonds, but 


certainly in several other places, the number 


of measurements that go into each location are 


sometime one, two, three, four, typically in 


that range. And so it raises questions about 


how you’re going to come up with a 95 


percentile of that. We recommended it but 


haven’t seen a method for it. 

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160 

So that’s a kind of caveat, but I 


think that said that this analysis and this 


validation certainly you know, set any of our 


concerns. But there was the analysis of an 


actual operational process in NIOSH’s December 


report that showed considerably higher doses 


than calculated for NUREG-1400. Now NIOSH has 


dropped the source term factor, reducing the 


source term by a factor of ten which we think 


also resolves some of our concerns. 


But John Mauro has been looking more 


at the operational processes question, and 


maybe John might summarize our finding. We 


still have reservations about using NUREG-1400 


even though this analysis carries things quite 


a lot farther. 


UNIDENTIFIED: Could you speak up a little 


bit? 


DR. MAKHIJANI: I said we still have 


reservations for using NUREG-1400 versus using 


data from the time that actually reflects dust 


loading where you might be able to put a 95 


percentile on similar operations. So we have 


that reservation still, and John will inform 


you of some of the research he’s been doing 

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because I haven’t done that. 


DR. MAURO (by Telephone): In fact, I’d like 


to just pass on that recently Jim Neton 


provided a report to us at SC&A specifically 


on thorium. And there is a very nice chapter 


that summarizes the machining experience of 


thorium and uranium. That’s a relatively new 


document that has a lot of information that’s 


I think very relevant to thorium machining 


issues and the potential for airborne 


exposures. 


And, of course, the last time we spoke 


I had mentioned a reference that we referred 


to as the A-D-L-E-R, Adler report. That also 


has a great deal of information on machining 


uranium. My sense is that that source of 


information which presents airborne dust 


loadings for a whole range of those types of 


operations, machining operations, extrusion 


operations, is going to be a very important 


resource not only to address thorium 


activities, handling activities, machining 


activities for Rocky, but I guess across the 


complex. 


And so I would suggest rather than 

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162 

going to the NUREG as your default method, 


that actually there appears to be pretty good 


reports out there with actual measurements of 


both uranium and to a lesser extent, much 


lesser extent, thorium. But it’s clear from 


reading these reports that the experience of 


machining uranium has applicability to the 


machining of thorium also in terms of the 


milligrams per cubic meter that might be 


generated during various types of machining 


operations. 


So I guess my perspective is that we 


have a situation where I think it’s tractable. 


It’s a matter of just selecting the proper 


dust loadings associated with the types of 


activities that took place at Rocky with 


regard to machining thorium. And, of course, 


there’s still a question of the extent of that 


exposure, that is, who was exposed and how 


often, you know, the time periods in which the 


exposures may have occurred. 


But certainly, that’s going to be a 


matter that needs to be looked at. I think 


that the NUREG approach is not the best 


approach for this particular case because I 

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think there is some good information out 


there. 


MR. GRIFFON: John, just to clarify, the 


reference you’re talking about is Albert? Is 


that --


DR. MAURO (by Telephone): Yeah, it’s the 


Roy Albert book, and I don’t know if Jim’s on 


the line. He graciously actually had the 


whole book, about 200 pages, scanned and then 


sent me a CD. And I sent the CD on, and 


meanwhile, Mark, I’m trying to get a copy to 


you. Probably, it’s a large file so I don’t 


think they were able to electronically send it 


to you, but I did ask Judy, the office 


manager, to send you a CD Federal Express. It 


will probably arrive at your home today. 


MR. GRIFFON: That’s fine. The other 


reference you made I saw some funny 


expressions. The Adler document, I think when 


you said we discussed it last time we talked, 


it was actually at the Chapman Valve meeting. 


Not everyone in here was at that meeting. 


DR. MAURO (by Telephone): My apologies, 


that’s correct. 


MR. GRIFFON: Adler is the other, a similar 

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reference about uranium machining. 


DR. NETON (by Telephone): Mark, Adley I 


think is the name of that document. 


MR. GRIFFON: What is it? 


DR. NETON (by Telephone): Adley. 


MR. GRIFFON: Adley, okay. 


DR. NETON (by Telephone): John, I’d like to 


take credit for having that reproduced, but 


Brant bore the brunt of that responsibility. 


DR. MAURO (by Telephone): Okay. With 


regard to the Adley report, Jim, is that now 


up on your website anywhere? 


DR. NETON (by Telephone): The Adley 


document. You know, there’s so much going on, 


I don’t know. I know I committed to having it 


up there. I think it is, but I can’t swear to 


it. I’ll have to check. 


DR. MAURO (by Telephone): I think both 


documents are really very important source 


documents that will help us deal with uranium 


and thorium dust loading in the early years 


and practices and experience. They’re going 


to have value for now with this particular 


issue that we’re dealing with now, but across 


the board. 

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165 

DR. MAKHIJANI: So the sum of this, there 


are two pieces of the thorium issue. One is 


the dose reconstruction for the source terms 


that have been identified, and the sum of that 


is while NUREG has been considerably 


clarified, and we don’t have the same kind of 


really grievous reservations that in this 


situation partly because it’s the bounding 


nature of this thing hasn’t been demonstrated 


by the use of weighted averages. There is, 


there are data available that should be 


examined, but since we’ve come to that 


conclusion we can say that in principle it 


should be possible to proceed for the source 


terms that are known, calculate --


MR. GRIFFON: Calculate more of a site 


profile --


DR. MAKHIJANI: So it seems like there 


should, this piece of it where the source 


terms are identified should be more of a site 


profile issue. Then there’s the question of 


what are the source terms. 


DR. MAURO (by Telephone): But I do think 


it’s a point that other folks look at these 


documents. I think I, I mean, I’ve looked 

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166 

very closely at them for various reasons, and 


I just brought this up because I think it may 


have applicability here, but I think it’s 


important that, you know, everyone around the 


table feel comfortable that this strategy is, 


in fact, reasonable. 


DR. MAKHIJANI: Yeah, and just, I don’t 


think anybody else on our team has looked at 


it. John is the only one, and he’s been 


urging us to do it, and I certainly intend to 


do it. 


MR. FITZGERALD: Right, I think we got the 


material late last week. 


DR. MAKHIJANI: So in the spirit of our 


comments being in a preliminary way, just 


trying to share with you what, where we are. 


MR. GRIFFON: But I think at least for that 


those two things, like you said, the source 


term and the exposure model, and I think at 


least we’re probably at the point where we can 


say we may not agree with them all right now, 


but we think it can be, there are ways to 


model and bound the dose assuming we know the 


source term. Is that a fair synopsis? 


DR. MAKHIJANI: Yes, I think that’s fair. 

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167 

MR. GRIFFON: And then I think the upshot of 


that I think is that it’s removed from our SEC 


sort of deliberations, at least that aspect of 


it. We want to still bring it to ground, but 


it’s not on that urgent, profile. 


DR. MAKHIJANI: And on the thorium strikes 


piece of it, I still don’t see the logic of 


NIOSH’s argument, but if we accept 100 


Becquerels as the alarm point of the maximum 


that could have possibly have happened, that’s 


in the same kind of category. The one 


Becquerel piece that comes out of NUREG-1400 


remains unconvincing. 


John? 


DR. MAURO (by Telephone): Yes. 


DR. MAKHIJANI: Right? Okay. 


DR. MAURO (by Telephone): Oh, I agree. I 


think when you’ve got data that is directly 


applicable to the problem at hand, I would not 


resort to the NUREG and reserve use of the 


NUREG for circumstances and then use it. When 


I look at the results, the dust loading that 


was coming out of urinalysis were so low that 


I didn’t find them convincing at all. And 


then when we came across these other reports 

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that dealt with this very issue, that seemed 


to be by far the superior method of coming at 


this problem. 


MR. GRIFFON: Okay, so then where are we at 


with the source term? 


DR. MAKHIJANI: With the source term the, 


for the thorium source term we’re more or less 


in the same place. We haven’t found any 


evidence that there were more things with 


thorium that happened. Haven’t had a chance 


to look at the declassified material on the O 


drive. Thank you for doing that, and I’m 


intending to look at it. 


The issue isn’t whether NIOSH has, 


this should never be whether NIOSH is properly 


representing the classified data that it has 


reviewed. The issue has been that as the 


discussion has gone on new things have come to 


light, not in the sense of the maximum amount 


of material that was stored at Rocky Flats. 


At least until 1976, we seem to have a pretty 


good fix on that, the declassified documents 


about it that have been in the discussion for 


some time. 


But it was a surprise that in 

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169 

December, you know, after saying that we had 


gone through the classified documents and it’s 


six kilograms ten times a year, that’s the 


main source term that a -- what was it? Three 


times or four times six? I can’t remember the 


canning and rolling source term, but it was 


much bigger for that 1960 year that entered 


the discussion. 


And new air monitoring data that were 


not part of the discussion were part of 


NIOSH’s report. And we have no evidence that 


there is another source term out there, but 


and we will, I think Joe can describe maybe 


he’s going out to, you’re going out to --


MR. FITZGERALD: Yeah --


DR. MAKHIJANI: Maybe that’s not part of the 


same issue. 


MR. FITZGERALD: That’s not really part of 


the same issue. I think what it comes down to 


is there’s been a faithful review of available 


documentation by both camps to the extent that 


I don’t think there’s anything left to find. 


I mean, I think the gold standard in this 


case, and I think Brant in the response you 


talk about shipping records. 

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170 

 

I mean, that would have been the gold 


standard to demonstrate where things had 


actually moved and get beyond the interview 


for anecdotal references. But I think 


literally we pretty much have seen all the 


documentation that we can identify and the 


documentation isn’t conclusive. We found some 


that was suggestive, but at this point in time 


it’s not conclusive in terms of the source 


term. 


So I think that’s where we are, and 


we’re willing to accept that. But there isn’t 


conclusive evidence to demonstrate that the 


source term thorium is something that we 


should be concerned about or is outside of the 


descriptions that we have. So that’s where we 


are. I mean, I don’t certainly see any 


further actions to turn over any more rocks on 


this one. I think we’ve been at it now for 


more than several months so I think that’s as 


much as one can do on this one. 


MR. GRIFFON: The only thing I would ask is 


I don’t know if is on the phone. 


 (no response) 


MR. GRIFFON: I guess not. 

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DR. MAKHIJANI: The alloy issues are 


separate. 


MR. GRIFFON: Yeah, we did ask at the last 


meeting if had any more information on 


this, and he said he was going to talk to some 


people, but we haven’t heard back from him so 


I guess... 


DR. MAKHIJANI: The alloy issues we have 


actually through the Board meeting, the last 


Board meeting, there was somebody from Dow 


Madison there, and I interviewed him. And he 


was quite specific -- and I believe he had 


been interviewed also and some of his other 


materials are on NIOSH’s O drive, but I 


haven’t looked at those. But I did interview 


him. 


I don’t have his interview currently 


back from him so I haven’t circulated it. I 


have sent it to him for verification to make 


sure he agrees with what I wrote about what he 


said. So normally I don’t circulate things 


until I hear back. But he very clearly said 


he remembers four truckloads a month going on 


average of magnesium-thorium alloy between 


1962 and 1965 to Rocky Flats. I talked with 

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him in various ways. How do you know it went 


to Rocky Flats? How do you know it wasn’t a 


partial shipment that dropped off most of its 


stuff in St. Louis? And he also recollected 


stamped-out parts. It was sheets, and so 


stamped out sheets of essentially remainder 


alloy coming back labeled Rocky Flats. 


Now that’s in direct conflict with the 


interviews, and we’ve looked at the interviews 


that NIOSH has done obviously, of senior 


people who we have no reason to disbelieve. 


And so I have no reason to disbelieve the 


person I interviewed. He seemed very 


straightforward. He seemed to have a very 


clear memory. And we haven’t taken it 


anywhere else. I mean, we do have names of 


shipping clerks. Now, he didn’t have 


documents. He did give me names of people who 


would have done the paperwork at Dow. We have 


not tracked that further. 


MR. GRIFFON: He doesn’t have any names on 


the Rocky Flats side? 


DR. MAKHIJANI: He didn’t have names on the 


Rocky Flats side. I have quite a bit of 


information in terms of how it could be 

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tracked in the Dow Madison side, but we have 


not done that. And that’s where the names, 


the thorium-tungsten alloy in terms of welding 


we don’t have SEC-type of concern so we can 


leave that out of the discussion. 


MR. FITZGERALD: But I guess I would again 


go back that unless there is some more 


compelling documentation that would move this 


issue forward on the magnesium alloy, I think 


we were going to say that this pretty much is 


all one can do. And even though we have 


suggestive entries like this, I think the 


piece that NIOSH put together in the last 


response is a fairly comprehensive treatment 


of the subject. I think we’re going to, 


again, feel that that pretty much answers the 


question. 


Even though we still have these issues 


that we haven’t resolved completely, I think 


the only thing that would resolve that would 


be information such as shipping records or 


something that would establish it went from A 


to B and here it is. But even then I think 


the inventory records and some of the other 


information that was included in the NIOSH 

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response is pretty persuasive so that’s where 


we are. 


I don’t think we’re going to get a 


perfect answer to this, but I think it’s been 


a good faith effort on both sides to try to 


come to some understanding of what happened on 


this. 


DR. MAKHIJANI: Mark, is there some, I mean, 

I know that had said something about 

looking into it. It may be, I don’t know 

whether NIOSH should do it or we should do it 


or whether it should be done, but it would be 


good to maybe at least --


MR. FITZGERALD: I think we should close the 


door. 


MR. GRIFFON: I think we should close the 


door and make sure there’s no more information 


that they’ve got to add it to the fray. We 


don’t want to find out about that in two 


months. 


MR. ELLIOTT: So SC&A’s going --


MR. GRIFFON: SC&A’s going to follow up --


MR. FITZGERALD: We’ll follow up with 


and see if he has anything on it. 


MR. GRIFFON: But assuming there’s no more 

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information there, I think it’s a pretty much 


closed item. 


MR. FITZGERALD: Yes. 


MR. GRIFFON: Response? 


DR. ULSH: Well, I am gratified to hear that 


we’ve reached consensus that while we may not 


agree on every point on thorium, it doesn’t 


look like it presents SEC implications at this 


time. That’s I think what I heard. So I’m 


gratified that we’ve reached that point. It 


was an arduous process coming to this point, 


so that’s very gratifying. 


And I don’t really want to rock the 


boat since it was so hard to get to this 


point, but with regard to NUREG-1400, perhaps 


that discussion can happen outside of the 


context of an SEC consideration. I hear what 


you’re saying. I hear that you’re not yet 


convinced. We did --


MR. ELLIOTT: Can I stop you just there? 


DR. ULSH: Yes, maybe you should. 


MR. ELLIOTT: Well, you know, SC&A’s going 


to finalize their report, and I would hope 


that in that finalization of this point alone 


they would refer to the consensus I think I 

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hear today and designate the issue as being 


site profile related then we can take it up in 


that form. If you’re explicit enough in what 


your concern is about NUREG, then we can react 


to it from this report in a site profile 


discussion form. 


DR. MAKHIJANI: Yeah, we will do that. I 


mean, John and I have talked about this and 


obviously Joe and I have talked about this, 


and I’m going to be re-drafting this for our 


internal review this week. 


MR. FITZGERALD: Yeah, I think there’s going 


to be a number of issues that will be like 


that where we didn’t agree on some of the 


details and implementation, but clearly, it’s 


just an advise. And I think we actually are, 


we’ll get to this in a bit, but with Ron 


Buchanan’s piece on external we’ve been kind 


of probing those kinds of issues now for a 


couple months just trying to figure out what 


the site profile-type implications are. 


MR. ELLIOTT: I think to do all the work 


that’s gone, done underway here, and yet 


contain and maintain the focus on what we need 


to continue to discuss outside of an SEC --

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 DR. WADE: And remember this work group was 


constituted to look at both SEC issues and 


site profile issues. You set the order that 


way, and that’s reasonable. It shouldn’t be 


left unresolved. 


DR. MAKHIJANI: I will try to give you 


enough details so we can proceed. 


MS. MUNN: It would really be nice if we 


could put the SEC portion of this to bed. 


MR. GRIFFON: We’ve got agreement on that. 


MS. MUNN: And define that all other 


outstanding items in this regard are site 


profile issues that we’ll address in that way. 


DR. ULSH: I’m done. 


DATA INTEGRITY, SAFETY CONCERNS AND LOG BOOKS
 

MR. GRIFFON: I think we’re under what I’ll 


define as an update item and the first one --


I’ve lumped these three together -- is data 


integrity, safety concerns and logbooks. I 


think the logbook one is probably the one that 


we have a most recent response from NIOSH on. 


Is that correct? 


MR. FITZGERALD: Yeah, well, we also got one 


on data integrity, right, so just to back up a 


little bit, certainly the conclusion from the 

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178 

 

pieces in January that we provided that we’re 


responding to is even though there may be some 


specific disagreements on individual cases 


that figured in those reviews, or specific 


logbooks that have figured in those reviews. 


In general, we felt that there was no 


pattern or evidence of a systemic issue. 


Evidence where it was clear that by virtue of 


policy or by virtue of practice that the 


records were being altered, falsified or 


entries were made intentionally that were not 


in fact valid. So we did decide that it 


didn’t rise to that level where we would 


believe an SEC issue exists of the logbooks 


review. 


And, of course, the genesis of that 


was to take from the petitioners and claimants 


concerns of whether or not this was going on 


and to establish in some means, this was 


typical at Rocky because there really wasn’t 


anything hard-edged that gave you a 


substantiation of the issues so we had to sort 


of do a secondary source to look at logbooks. 


And these were all recommendations 


from and from the former union to go 

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ahead and look at the logbooks, look at safety 


concerns. And we did look at the logbooks. 


The response certainly points out that there 


is agreement on the SEC issue. It does give 


us a wealth of specific comments though on 


comparisons, that there are still some 


differences on, and we believe there are 


agreements. 


Certainly, NIOSH has contested that 


interpretation. We’ll take a hard look at 


those and certainly reflect that in the final 


report. If there’s any technical accuracies 


or interpretations that these comments bear 


out are problems, we will go ahead and make 


those changes in the final draft. So that’s 


the process I see at this point. 


 DR. WADE: I need to make one clarification. 


Just so everyone understands what might be on 


the table, what might not be on the table, 


SC&A submitted a working draft on data 


reliability, data integrity examples analysis, 


and in the attachment to that, Attachment 25, 


there’s a column that shows the NIOSH 


response. That response was excerpted from 


the NIOSH response. And what I asked John to 

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180 

do was in any subsequent documents to include 


the entire response, and he’s agreed to do 


that. 


MR. FITZGERALD: Yeah, and thank you for 


bringing it up. In one of the matrix tables 


to, I think this was the data integrity 


examples. In order to format the matrix, we, 


in some cases, paraphrased some of the 


position statements on certain examples. And 


NIOSH has rightfully acknowledged certain 


cases where that may have inappropriately 


changed the intent or meaning. 


So what we’re going to do is go back 


and restore the literal language. It probably 


can’t be a matrix anymore. Some of the 


comments are six pages long, so it may end up 


being something other than a matrix, but we 


are going to restore the literal language and 


positions so that there’s no 


misinterpretation. 


 DR. WADE: Very good, thank you. 


MR. FITZGERALD: Of course, we’ll take back 


or retract that original Attachment 25 as 


well. 


MR. GRIFFON: There is a follow-up action so 

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181 

it’s the logbook. 


MR. FITZGERALD: Yeah, in saying that in 


essence that the broad conclusion is that 


certainly we’ve got a request from the working 


group in support for NIOSH to first-hand 


sample, I think the term is the 450 boxes, but 


it really is 450 sets of data that were the 


total inquiry that NIOSH conducted through the 


Records Center in Denver. And next week on 


Monday Kathy Robertson-DeMers and myself, 


personally, we’re going to go out for five 


days and just basically do a very defined, 


narrow sampling. 


MS. MUNN: Thank you. 


MR. FITZGERALD: You’re welcome. 


That is really designed just to answer 


some of the questions that have come up 


relative to coverage of certain years and 


certain facilities, and also to perhaps 


confirm some of the questions that we’ve 


raised in the course of the logbook review. 


But again, very specific and confined to a 


sampling process over a few days. 


And Mountain View -- I keep saying 


Mountain View. I guess it’s changed now. But 

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whatever it is now, the Records Center in 


Denver has contacted and they have all the 


sample, boxes to be sampled have been put 


aside and ready. So we’re planning to go out 


Monday to do that. And we’ll certainly write 


this up and report it back provided, through 


the same process that we have provided to the 


work group that NIOSH will see at the same 


time. 


Certainly, General Counsel will review 


it for Privacy Act issues, so we’ll go through 


the same process. We’ll try to get it to you 


as soon as we can and as soon as we get back 


so there won’t be any waiting for those 


results. Those results will be forwarded to 


the overall logbook review. So I think that 


will perhaps satisfy, there was a lingering 


question or two at the end of the session on 


logbooks that will perhaps help satisfy that 


and be responsive to that. But again, this is 


a sampling exercise not some exhaustive 


survey. 


DR. ULSH: We talked about this in other 


conference calls but my understanding of what 


you and Kathy are looking for, what the 

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working group had asked originally, was you’re 


looking for data-rich logbooks. Now we had 


talked earlier in this process sometime last 


year -- I don’t know when -- that our position 


has been that after a certain point in time, I 


think --


MR. ELLIOTT: ‘Seventy-one. 


DR. ULSH: -- ’70, ’71, yeah, the logbooks 


that contained a lot of data ceased to be 


kept. There are still continuation control 


logbooks, form logbooks and other types that 


aren’t as useful to us. But, Mark, I think 


you had expressed at one time that what you 


were really interested in was entries in these 


logbooks compared to the hardcopy rad files. 


So it wasn’t quite, it wasn’t as much of 


interest to compare computer printouts to 


computer printouts in the rad file. So what 


we’re looking for here or what you’re looking 


for, I guess, is data-rich logbooks that we 


might have missed. 


MR. GRIFFON: And it may be that you have, 


there may be some computer printouts in these 


records? 


MR. FITZGERALD: We’re not changing, we’re 

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184 

not changing the comparative analysis. I 


think this is more of a scoping question as 


you point out, Brant. That’s pretty much the 


extent of it really. 


MR. GRIFFON: And I don’t know, I mean 


there’s, I think what they reported that you 


issued, that NIOSH issued, it’s best, at least 


for this, in my opinion, there’s a lot of 


specifics, responses, to SC&A’s, some of the 


individual findings where they had 


discrepancies. 


DR. ULSH: Are you thinking of the data 


integrity examples or the logbook? 


MR. GRIFFON: I was thinking of both 


actually. I was just going to say I don’t 


know that it’s worth going through these at 


this point. 


MR. FITZGERALD: But we haven’t been able --


MR. GRIFFON: -- fully reviewed them. 


MR. FITZGERALD: Yeah, we haven’t been able 


to go through systematically. In fact, Kathy 


is at Pantex all this week, so in a way we’ll 


definitely go through and item-by-item 


reconcile, or attempt to reconcile, the 


comment with the current version. Even though 

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185 

we are in agreement, I think, on the SEC 


issue, for the safety of accuracy and 


representation, we will go through that 


process and make sure that the tables reflect 


the comment. Now we may not necessarily agree 


with each specific comment, but the ones that 


certainly point out accuracy issues, we do 


agree we want to make those changes that 


reflect that. 


MR. GRIFFON: And then you also said in your 


final rev you’ll be responsive, as much as you 


can, to NIOSH’s most recent report. And I 


think --


MR. FITZGERALD: That’s what I’m just 


saying, right. 


MR. GRIFFON: -- the only thing I would say 


is from now until the time you write this 


report out maybe the lines can be open, too. 


That if SC&A had a follow-up question on your 


response, you know, they can call you --


DR. ULSH: As always or e-mail. 


MR. GRIFFON: -- and there can be a 


clarification or whatever. 


MR. FITZGERALD: Yeah, the iterative process 


will be important because of the amount of 

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ground we have to cover on this issue. 


That covers kind of two things, too. 


I think on data integrity likewise we have the 


same context of, you know, we’re in agreement 


overall from SEC’s standpoint in terms of data 


reliability, but it’s just specific cases that 


we’re going to be talking through. Anyway, 


that’s data reliability. 


I think you had a Super-S, do you want 


to go to a Super-S? 


MR. GRIFFON: I didn’t know if you were done 


with data reliability. 


MR. FITZGERALD: No, I think the key issue 


there is --


MR. GRIFFON: The only other thing I did 


want to bring up about the logbook thing, and 


maybe this is a mistake. On the next to the 


last page the question of the logbooks and 


your comparison with this claim versus SC&A’s, 


and I’ll preface this by saying I don’t think 


that SC&A spent a lot of time to compare your 


numbers with their numbers. But I did notice 


that there’s, you know, you end up with quite 


a different percentage of positive matches. I 


thought, well, I think we need to understand 

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that. 


I think we need to know why, and SC&A 


hasn’t had a chance to go through this line by 


line. Brant did provide, there was a 


spreadsheet that you posted that has the back 


up. So I think as a follow-up action you need 


to at least respond to that specifically in 


your write up. 


I just wanted to clarify my 


understanding of your table. It’s on page 15. 


There’s no number or anything, but in this you 


say 115 out of 124. I think that might have 


been, supposed to have been 125, but anyway, 


yielding 92 percent match. I notice that the 


second line down it says entries with no 


reference in HIS-20 for ten employees. And 


those were excluded from your denominator in 


this compilation. 


DR. ULSH: That’s correct. 


MR. GRIFFON: And I think they might have 


been included in SC&A’s, so part if it --


DR. ULSH: That could be part of it. 


MR. GRIFFON: And if was, you know, well, I 


guess the question, and I skimmed this, too, 


but I think the rationale for excluding those 

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was basically that they were people that had 


retired before this 1977 or ’76, whatever data 


that is, and therefore, were pulled from the 


HIS-20 database. 


DR. ULSH: Well, they never made it into the 


HIS-20 database. 


MR. GRIFFON: And then some people would 


have been added back in though that retired 


before that date but not all. 


DR. ULSH: Correct. 


MR. GRIFFON: So they were people apparently 


not added back in. 


DR. ULSH: If they were a part, they would 


have been added back in if they were part of 


the medical recall program in the late ‘90s. 


And these people are not part of the medical 


recall program. 


MR. GRIFFON: So I guess I just want people 


to understand that in my opinion that’s not 


really, I thought that it should have stayed 


in the denominator, but because it does 


reflect on the overall, you know, what’s in 


the database versus what’s not in the 


database. These people aren’t in there. Why 


they were dropped, you’ve explained very well 

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why they were not in there because they 


weren’t in there. So they have radiation 


hardcopy records, but they’re not in the HIS20 database. 


DR. ULSH: If they were, if we did it the 


way that you suggested, Mark, if we included 


those in the denominator, it would drop the 


percentage agreement by a couple of percent. 


MR. GRIFFON: I’m not disputing that. I was 


just trying to understand how you did the 


analysis versus how --


MR. FITZGERALD: Right, and I think that’s 


probably the action that we’re going to have 


to work with on that. 


MR. GRIFFON: Another spreadsheet with all 


that detail. 


MR. FITZGERALD: Understand the difference 


in the numbers and try to reconcile it if 


possible. 


MR. GRIFFON: I don’t think we need to go on 


that any further. Just to be aware of it. 


MS. MUNN: What difference, is it pretty 


small at this point? 


MR. FITZGERALD: I think except for one 


instance where the percentage differences were 

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a little higher, 20 percent difference. 


MS. MUNN: Was it? Did I miss that reading 


too fast? 


MR. FITZGERALD: I’ll have to go back and 


check, but I think it was one parameter that 


was a little divergent. 


MR. GRIFFON: The only other factor in this 


table that I’m not sure was defined the same 


way in both reports was this term, close 


match. So that might be another thing that 


accounts for it. 


MR. FITZGERALD: It could. 


MR. GRIFFON: And you describe close match 


as, there’s 21 of these, and you, generally, 


you’re saying that these are background 


readings, and the database had a value. 


That’s why I wanted to look at the data that 


you have to be clear on that. 


DR. ULSH: And you will find that in the 


spreadsheet. There were a couple of 


situations where I think we would categorize 


as a close match like you said, Mark. In the 


logbook perhaps it might have been recorded as 


background, whereas, there was a value in the 


HIS-20 or vice -- well, you wouldn’t see 

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background in HIS-20. 


Also, keep in mind that there are a 


number of different dates that are associated 


with particular samples. The date that it was 


collected. The date that it was analyzed. 


The date that it was reported. And so if it 


was pretty close in time, you know, a couple 


of days, we would call that a close match. So 


that’s the kind of thing that we’re talking 


about. 


MR. GRIFFON: All right, I guess for 


anything else on those three items then? 


DR. ULSH: No, not from me. 


MR. GRIFFON: I think we’re okay. 


MR. FITZGERALD: I guess the only thing I 


would ask on the safety concerns, that was a 


very early piece that, I can’t recall. We got 


a similar response from you from back when. 


Are you planning to review that in the same 


level of detail because that’s going to 


somehow be melded in. 


DR. ULSH: The reason that we didn’t issue a 


report on safety concerns as requested by the 


working group, I mean, you can pretty much 


tell which issues are the most important from 

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an SEC standpoint, and we ranked safety 


concerns as last because, quite frankly, we’re 


in a similar situation where SC&A and NIOSH 


agreed, were in concurrence, that there may 


not be SEC issues. There were particular 


instances where we may not agree on every 


single safety concern, but it doesn’t rise to 


the level of SEC. 


MR. FITZGERALD: Okay, so you’re not as 


concerned on the individual case differences. 


I’m just trying to --


DR. ULSH: I understand. It’s a good 


question. Like I said we put that last on the 


list, and we just didn’t have time to issue a 


report, and I didn’t feel that it was terribly 


important to do so. 


MR. GRIFFON: We certainly didn’t ask you to 


look at, respond to those individual cases. 


DR. ULSH: Right. I think we’re in 


concurrence. 


SUPER S, TIB 0049
 

MR. GRIFFON: I think we’re on to Super-S. 


MR. FITZGERALD: Super-S, and I’m going to 


let Joyce get into this, but in general, this 


goes way back. The June 5 Board meeting, 

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Joyce Lipsztein gave a pretty detailed report 


to the Board in the public session about our 


review of OTIB-49 at that time. And certainly 


our conclusion was that we were in accord with 


a conceptual approach of the model and found 


it was claimant favorable and felt it 


addressed certainly the potential SEC issue 


that was raised by a petitioner relative to 


being able to do dose reconstruction for 


plutonium oxide, the Super-S mode. That was 


back last summer. 


And beyond that I think the concern 


was whether or not the model cases upon which 


the OTIB was based were, in fact, conservative 


from the standpoint of being able to envelope 


workers that were exposed to the ’65 fire. 


And Joyce, with the assistance of the files 


that were provided for 25 workers, she’s 


reviewed those. 


And I think the conclusion that we’ve 


reached -- and you haven’t seen this report 


yet -- but that they, in fact, are 


conservative. They do envelope. So we don’t 


see a validity question relative to those 


model cases. And that’s taken a little bit 

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longer just because of getting the records and 


going through a lot of process. So I think 


certainly it doesn’t appear to be a validation 


problem. 


And finally the third item which gets 


a little bit toward what Mark’s been talking 


about to some extent which is how does the 


OTIB-49, in this case the model, work or apply 


to sort of real life situations or scenarios 


or circumstances at the plant. We wanted to 


look at that relative to some cases of workers 


that might have been exposed to Super-S before 


in vivo counting at Rocky. You know, sort of 


test the outer bounds of whether it would, in 


fact, the model would be inclusive. 


And actually, we’ll provide that 


material to you in written form. We felt it 


did, in fact, envelope even these cases. So 


in general, I think on the Super-S, and 


certainly on those three facets, three main 


facets, we felt the analysis underscores that 


OTIB-49 certainly addresses the Super-S issue. 


And there’s not a, certainly no SEC issue that 


we can see. 


Joyce, are you still on the line? 

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DR. LIPSZTEIN (by Telephone): Yes. 


MR. FITZGERALD: Do you want to add any 


particulars to that? 


DR. LIPSZTEIN (by Telephone): I think you 


summarized everything. I could not -– I 


analyzed all the 25, the data from all 25 


workers that were involved in the ’65 fire to 


see the (unintelligible) that were chosen to 


be the design cases, the design model, and to 


see if there were others that could be chosen. 


And from the other 19 workers, only two could 


qualify and even one of them had prior 


exposures to plutonium, but he had so much 


exposure during the ’65 fire that maybe he 


would qualify also. 


So I analyzed those two cases in 


detail, and I saw that the real model design 


was based on two cases, one from Hanford, one 


from Rocky Flats. And the -- I developed 


those two. So I think that we have concluded 


that cases were well chosen by NIOSH, that 


they are significantly conservative for those 


years. 


Do you want anymore details? 


MR. FITZGERALD: No, I think that’s helpful. 

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Don’t go away though. We haven’t gotten to 38 


yet. 


DR. LIPSZTEIN (by Telephone): They -- you 


were talking about the implication of 49 and 


other documents for some cases. We had 


someone that worked in Rocky Flats and was 


given examples of people that could be, could 


not have been, actually worked at Rocky Flats 


before in vivo counting. And there was where 


he did (unintelligible) these people would not 


have (unintelligible) calculation of the dose. 


So we, based on the values it was 


suggested (unintelligible) Rocky Flats of 


exposures for each of them we would use either 


OTIB-49. We had to use OTIB-38. We used it 


with the multiplications that were agreed to 


be done by NIOSH which is the use of the 95th
 

percentile. And also, we had to use for the 


people that had results below detection limits 


we had to calculate the missed dose based on 


the MDA. 


And we saw that most of the time the 


application of these three documents would 


calculate the dose in a fair way to the 


workers. I think we should -- and I’m not --

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it’s not related to NIOSH. This is the way 


that they really would treat those cases and 


especially should discuss the application of 


the MDA with NIOSH. But in general, I think 


that the worker would be fairly treated using 


the documents. 


MR. FITZGERALD: Just as a post script we 


had a number of conversations about this 


question of applying the coworker model and 


this 95th percentile. And I think the issue 


there is the conservatism in terms of fitting 


a dose distribution. And we appreciate, I 


think Jim has reminded us that certainly the 


95th percentile in these circumstances is 


available to NIOSH, but again, that’s NIOSH’s 


discretion to apply that as needed. So I 


think there’s a, maybe it’s more of a site 


profile question on that one. But there’s a 


question and I think Joyce has articulated it 


which is under what circumstance and specific 


case would the 95th percentile in fact be 


applied. 


MR. GRIFFON: It may be useful to kind of 


one, know Joyce’s scenarios that she ran and 


ask NIOSH to run a Super-S pre-in vivo with 

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the coworker model as one of the examples 


because I think there is this proof of process 


question. And I’m not sure, at least in the 


ones I’ve looked at they ever used the 95th , 


but maybe they would consider it, and maybe 


it’s a plausible up or down, but I don’t think 


it’s being used currently. I think it goes 


back to that proof of process question. 


DR. ULSH: I don’t know. You kind of caught 


me off guard with that question about internal 


coworker and when we’d apply the 95th . I can 


tell you that in general our rule, you know, 


the methods that we operate under. If you 


have an unmonitored worker for internal, what 


we’re going to do is if there is indication 


that this person was a significant exposure 


potential, and that’s defined by working in a 


radiation area, for instance, then we would 


apply the 95th percentile. 


If a person -- and I’m going to look 


at my ORAU colleagues here. If a person --


just to make sure that I’m saying this right. 


If a person only periodically visited 


radiation areas, had very intermittent 


potential exposure, then we would apply the 

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50th percentile. If a person never really went 


into radiation areas, then we would apply 


ambient environmental. 


Now, have I misspoken? I don’t think 


I have. 


 MR. SHARFI: It’s more of an external issue. 


The 95th, 50th is more an explanation of the 


external issue. In the internal we have a 50th
 

percentile, then calculate the GSD which would 


give you the distribution assigned, and that 


normally would assign, I don’t know of a time 


that we’ve assigned to internal is 95th
 

percentile, the max, the maximum bound. So 


like the numbers, I know in one of the 


previous calls we had talked about possibly 


using for Rocky the 95th and that was a 


discussion at the time --


MR. GRIFFON: Well, it was only offered as ­

-


 MR. SHARFI: Yes, it was offered as a 


possible solution for this particular site, 


but it’s not a common practice for internal 


coworker. 


DR. ULSH: With regard to Super-S and when 


it would be applied, I didn’t catch whether 

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there was still some outstanding questions 


about that or --


MR. FITZGERALD: No, no, this was more of 


this context. I’m not going to get back into 


the conversation we spent a couple meetings 


and conference calls talking about this issue. 


But I think that was where we left it. But 


the fact that it was available, certainly, it 


might be an option. But the distribution, the 


question of conservatism and fitting the 


distribution which is where Joyce had all the 


concerns I think was something that would be 


addressed by this. But again, we’re the first 


to admit that’s not an SEC issue. 


MR. GRIFFON: This is more of a coworker 


model side. 


MR. FITZGERALD: Yeah, exactly. 


Is that right, Joyce? 


DR. LIPSZTEIN (by Telephone): Yes, this is 


the coworker model. (Unintelligible) I think 


it’s not an SEC issue, but I think it’s very 


important. I understood that NIOSH would 


apply the 95th percentile, but that’s another 


discussion not really applied here. I think 


I’m (unintelligible) I think that OTIB-49 is 

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(unintelligible) was fairly treated by NIOSH 


in relation to the workers. 


MR. GRIFFON: Let’s save that other piece 


for later on, yeah. 


MR. FITZGERALD: Sure. 


Thank you, Joyce. 


MR. GRIFFON: So then we’re on, I think 


we’re on sounds like Super-S, I mean the 


outstanding issue really was the, checking 


those other 19 cases to see if original 


assigned cases were bounding, and Joyce has 


looked at that and is happy with that. So I 


think we’ve been happy with the model for 


awhile. We were just doing that final piece 


and I think it’s closed. 


MR. FITZGERALD: And that final piece is in 


written form, and likewise, as soon as we have 


a chance in the next four or five business 


days, we’ll send that over so you will have 


that. 


NEUTRON DOSE QUESTIONS
 

MR. GRIFFON: Next issue is the neutron dose 


questions. I think you’ve already sort of 


spoke to us, Joe, but this is Ron’s. 


MR. FITZGERALD: Yeah, I’m always concerned 

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about wading into those waters because it’s 


actually been a very intense dialogue that’s 


been going on between ORAU and Ron Buchanan on 


some remaining issues. I think fundamentally 


probably the latter part of last year the 


conclusion was this didn’t appear to be an SEC 


issue. There were some questions on tables 


that were included in the OTIB-58 coworker 


model that we had some questions and problems 


about. I think we’ve been working with NIOSH 


and ORAU to try to resolve those issues. And 


I think we’re closer. 


Ron? 


MR. BUCHANAN (by Telephone): Yeah. 


MR. FITZGERALD: How close are we? 


MR. BUCHANAN (by Telephone): Yeah, this is 


Ron of SC&A. Yes, we have been working on 


this now, and what the conclusion I’ve reached 


at this point is that the model seems 


reasonable, doesn’t present an SEC issue. I 


still have some questions on the application 


of the NDRP that I need to clear up, how the 


’59 values are used for ’52 to ’58. 


From what I know at this point, I 


don’t see that there’s SEC issues 

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(unintelligible) site profile issues if the 


data’s there to support the model. On OTIB58, the coworker model, I think that that’s 


going to have another revision from the one 


put out in January if I understand Brant 


correctly. I do have some questions on the 


non-penetrating there. Again, that could be 


site profile rather than SEC issues. 


MR. FITZGERALD: Ron, could you illuminate a 


little bit because I think a central question 


was the back extrapolation on the neutron 


doses for that 1950, was it ’52 to ’59? 


MR. GRIFFON: ‘Fifty-two to ‘59. 


MR. FITZGERALD: That was one of the central 


issues raised early on. Can you illuminate a 


little bit more on where that stands? 


MR. BUCHANAN (by Telephone): Okay, that’s 


’52 to ’58. Our understanding is that in the 


NDRP report they stated that there was not 


enough neutron data to create year-by-year 


neutron-photon ratios. During this period 


there was very little neutron monitoring took 


place in ’52 to ’58. It didn’t really begin 


in earnest until ’59 and ’60. 


So what NDRP recommends is to using 

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the N-over-P rations from ’59 to determine the 


neutron dose in ’52 to ’58. And then it’s 


broken down by buildings, mainly the plutonium 


buildings. That’s where most of the 


monitoring took place. And if you weren’t in 


one of those then it falls in an all other 


building category. 


And the way it stands now is that the 


NDRP report, of course, went back and 


calculated those doses, those neutron doses 


for the workers during the ’52 to ’58 period 


and other periods, but this is the period 


we’re interested in right now, using the 


photon dose in most cases the ’52 to ’58. 


Then we can calculate their neutron dose, add 


those together and get their total penetrating 


dose. And this is an acceptable method if the 


N-over-P values remain the same or 


approximately the same for ’52 to ’58 as they 


were in ’59. 


Now, there’s one thing that I had 


requested that we have not had was, there were 


two items actually. Number one is we have 


some of the data for the neutron monitoring 


that was done ’52 to ’58, but we don’t have ID 

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numbers with it, and so I can’t see what dose 


belongs to what worker. 


You go back and calculate the average 


N-over-P values which I’d like to compare to 


that published in the Table 11.1 of NDRP to 


see if, indeed, we need some benchmarks to 


show that the N-over-P ratio in those early 


years were approximately the same as those in 


’59 that we’re going to use, and they were 


used in NDRP. And so I really still need 


those ID numbers to go with those earlier 


neutron measurements to set down some 


benchmarks. 


And the second item of concern was I’m 


still not clear on how many of the NDRP doses 


in ’52 to ’58 were notational doses which were 


calculated from N-over-P ratios, or they were 


average dose as compared to the actual neutron 


film measurement. And we have a conflict 


there because Roger Falk, his letter to Brant 


the other day said that only 1958 did they use 


50 of those data. All the rest of it is 


occasional doses. However, Brant sent me some 


files that shows there’s neutron data for ’52 


to ’58 scattered in some of the workers, the 

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ones I need IDs for. 


And so that is an area that needs to 


be clarified. So to summarize what I need is 


to be able to do some benchmarks from ’52 to 


’58 to see if they fall in the range of ’59 Nover-P ratios were. And in my final write up 


on this Section 4, I went back and looked at 


some N-over-Ps that I could find from the 


scattered data that I got together. And it 


looks like the Table 11.1 NDRP, the values for 


N-over-P there are average values. They are 


not bounding values that I could find in 


earlier years, and I’d like to verify that. 


So saying that, if that can be 


verified, then it looks like we can do the 


dose reconstruction because we have the 


recorded photon dose for the workers that were 


probably exposed to neutrons. And so that’s 


where it stands at this point. 


MR. GRIFFON: You asked for the long 


explanation. That’s good. That’s good. 


Joe. 


MR. FITZGERALD: I was just going to say I 


know you’ve been in contact with your 


counterparts. Is that requesting that 

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information? 


 (no response) 


MR. FITZGERALD: Have you made the request 


or is that, is this something new? 


MR. BUCHANAN (by Telephone): Me? Joe? 

MR. FITZGERALD: Yes. 

MR. BUCHANAN (by Telephone): No, I made 

that request for going on a year now. I still 


need some ID numbers tested with data we do 


have for the actual neutron films that were 


read and re-read and from ’52 to ’58 so that I 


can go back and do some benchmarking. 


MR. GRIFFON: I’m going to include that 


action again. If it was already given, we 


don’t know, but either way it’s an action now. 


And if Brant needs clarification on that, Ron, 


I’ll ask that he contact you directly maybe 


and make sure we get the right stuff to --


MR. BUCHANAN (by Telephone): Yeah, that was 


in the August 14th phone conference we had on 


this subject. Now they did send me the data I 


requested. The ID numbers were left off, and 


the problem with that is a list of, a table of 


film badge results, but I don’t know who they 


belong to so I can’t pair them up. And that 

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item and then the non-penetrating in Table 7-1 


of OTIB-58 are the two remaining, major 


remaining items in that area. 


MR. GRIFFON: What’s the issue on the non-


penetrating? 


MR. BUCHANAN (by Telephone): The non-


penetrating in Table 7-1 of OTIB-58 is that 


the non-penetrating to penetrating has a ratio 


of about 1.1 to 1. And the information that 


I’ve got in some of the other data that Brant 


has sent me shows that the ratio is more 


around 1 to 5, the penetrating is one. The 


non-penetrating is five. And they haven’t reissued that, but I think it’s going be reissued with the same values in Table 7-1. 


And so I haven’t brought this up to 


Brant yet because I just got this information 


in recently. But that’s another area that I 


would like to look at. I feel that the non-


penetrating in the Table 7-1 are okay for the 


plutonium workers but might not bound the dose 


for non-penetrating for uranium workers. 


MR. GRIFFON: This is TIB-58, Table 7-1? 


MR. BUCHANAN (by Telephone): Yeah. 


MR. FITZGERALD: Ron, just to sort of help 

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everybody, if you can kind of lay that out 


very clearly in a maybe e-mail to Brant, copy 


to Mark and I or the usual suspects that will, 


I think, help Brant out as well as --


MR. BUCHANAN (by Telephone): Yeah, right, 


I’ll spell it out there, those two items of 


concern and reiterate them. Now the non-


penetrating to penetrating, I just did a 


recent item and I haven’t requested, I haven’t 


brought that up before because we just decided 


what to do with Table 7-1 and OTIB-58, I mean, 


what Brant has recently informed us. So that 


is a recent item that just came up because of 


that. 


MR. FITZGERALD: And I want to again 


underscore, there’s been a lot of give and 


take on this issue over the last couple of 


months trying to come to closure on this. But 


again at this point it’s not an SEC issue as 


much as making sure it’s representative of how 


OTIB-58 is going to be used. 


MR. GRIFFON: Yeah, I guess the one thing I 


would say maybe is if we can, that first item, 


getting the identifiers to Ron. Before we, it 


would be nice in the next month or so if Ron 

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can at least say to us he’s got the data. And 


even if there’s disagreement on what N-P ratio 


should be used, we can always debate that in 


the site profile. 


MS. MUNN: We can deal with that --


MR. GRIFFON: Yeah, we can deal with that 


later as long as he’s got information there 


that you can calculate N-P ratios with. I’m 


assuming you have the N-P identifiers. If we 


can get that far, that would be a plus. Then 


we know we can do it, and we can debate what 


the right number is later. 


Is that it on neutron questions? I 


think it is. 


MR. FITZGERALD: Any more Ron? 


 (no response) 


MR. FITZGERALD: I think that’s pretty much 


it. 


MR. BUCHANAN (by Telephone): That’s the 


major issues that (unintelligible) site 


profile. 


MR. GRIFFON: All right, thank you. 


COWORKER MODEL
 

Then the coworker model is the next 


thing I have, coworker model or models. 

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MR. FITZGERALD: Well, you know, certainly 


we had looked at each of the coworker models 


when they were issued from a conceptual 


standpoint. Ron has looked at OTIB-58. We 


just touched on that, and actually, this is 


all part of his review on OTIB-58. 


Joyce has certainly looked at OTIB-38, 


and quite extensively in terms of the concept 


and how it’s set up. By extension she has 


also looked at OTIB-14 which was the extension 


of OTIB-38 for D&D. 


DR. ULSH: It’s actually OCAS TIB-14. 


MR. FITZGERALD: OCAS, okay. And even 


though we had some initial questions, I think 


input from NIOSH on the fecal versus in vivo. 


I think that resolved the one concern that we 


had on OTIB-14. So from a conceptual 


standpoint I think we’re in accord with those 


models. And as I was saying for OTIB-38, 


we’ve actually more turned to looking at the 


application of those models and begin to look 


at how they would apply and whether they 


would, in fact, envelope the different 


populations. 


And I guess the one thing we have not 

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broached as much, both Ron and Joyce, and they 


can dive in when they want, this question of 


whether the data that populates the site 


profiles I think is the question that we’ve 


sort of gotten into on the completeness 


question. But that’s kind of where we’re at 


right now in terms of the final aspects of the 


coworker models that we feel needs to be dealt 


with. Again, we’ve looked at parts of that, 


but I don’t think we’re completely finished 


with it in terms of validating. 


MR. GRIFFON: And I know there’s several 


papers out there especially related to the 


internal coworker model. I keep calling it 


Donna Cragle piece. I’m not sure it was not 


only Donna Cragle that wrote that comparison 


of HIS-20 and CER. 


DR. ULSH: It was the ORAU team. I think 


the first author might have been Joe Lockamy. 


I’m not sure. 


MR. GRIFFON: And then there’s another one 


that looks at the calculating intakes using 


HIS-20 versus using the CER data. That’s 


Lockamy I think. And there may be a third. 


DR. ULSH: I think there were two Lockamys. 

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There was the first one that he wrote, and 


there was a follow up. 


MR. GRIFFON: So I guess we, I think we need 


to address that certainly in your final 


evaluation. 


MR. FITZGERALD: Right. 


MR. GRIFFON: You need to address that in, I 


think in some of the discussions we’ve had, 


and this is how it gets back to the 95th
 

percentile, some of the discussions we’ve had 


I think have turned on the fact that, well, 


the upper limits of these things, these 


databases look similar, and they yield similar 


intakes. And I asked, I think the prior 


action was for SC&A to look at these and make 


sure you were comfortable with that Lockamy 


analysis. Make sure --


MR. FITZGERALD: Right, and we spent, and 


certainly Joyce has spent time looking at 


those analyses and certainly one concern is 


this very issue that the dose distribution 


that she had looked at for OTIB-38, the 


concern was that the 50th percentile would not 


necessarily envelope some of the higher end 


doses as would the 95th . And that’s where I 

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think this question of conservatism in terms 


of applying the coworker model came into play. 


Is that right, Joyce? 


DR. LIPSZTEIN (by Telephone): Yes, that’s 


right, I think. The first question whether to 


use one distribution or the other. I looked 


at the two papers by Lockamy, and actually one 


of the things that I noticed that both CER and 


HIS-20 they have enough data to elaborate a 


model because I think that OTIB-38 is a model. 


It’s a model based on real data, and as long 


as they have enough data, either of the 


distributions are good for application of the 


relation of a model. Because one of the 


things that has to be understood is that OTIB38 is just a model. 


The best way to draw a model from this 


data that’s what is important in discussion. 


One example that I can give is, for example, 


on the Lockamy table some values, for example, 


’64 and ’65 are different from the 50th
 

percentile. And the number of data that was 


used is different from the ones that are on 


OTIB-38. That’s because on OTIB-38, some of ­

- I think, but I’m not sure, but I think it is 

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because some of the data were taken off 


because they are said to be related to an 


extraordinary incident. I think that’s the 


explanation that I got. 


But what I mean is that more important 


than the use of CER or HIS-20 is the criteria 


for taking off some of the samples. Because, 


for example, on the Lockamy table in ’64, for 


example, Lockamy says that there were 4,761 


samples. No, I’m sorry, 4,976. And then the 


OTIB-38 is 4,761. So I have less, around 200 


samples less. And the maximum on the Lockamy 


is 1,000,800 DPM, and the maximum at OTIB-38 


is 2,290. 


So obviously, this sample with 


1,000,800 DPM per 25 (unintelligible) either a 


huge accident or an error. So it was taken 


out from OTIB-38. So the discussion of which 


data stays and which one is taken out is more 


important than if it’s using CER or HIS-20 


because both databases have a lot of data. 


The second thing is that when you 


analyze the data, and you made, NIOSH made a 


model from it, if the rise in intake for 


various subsequent years. So although for 

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most of the years the urine, you know, you got 


the urine for each quarter at the 50th
 

percentile, urine for each quarter, and some 


of the years were for the year, but when you 


make the IMBA run and make the intake, then 


the intake is made for values years in a row 


because this is a model. 


And so when you speak of the 50th
 

percentile, it’s not the value that 50 percent 


of the workers are below that, and 50 percent 


of the workers are above that. It’s just the 


intake that was derived (unintelligible) to 


value years of data. So even if you look at 


OTIB-38, you’ll see the (unintelligible) is 


corresponding to the real urine and you’ll see 


that there are value points that are above 


that line. 


So when we discuss 50th percentile or 


95 percentile, we’re not talking about real 


data or all the workers being below 95th
 

percent or 50th percent. We are talking about 


a model that will reproduce urine data, but we 


should be aware the manuals, the data will be 


many of the 50 percentile urine data, will not 


be above that line. 

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I don’t know if I’m making it clear, 


but I think if I write this and you read it, 


it will be much clearer if you look at the 


graphs. What I want to say is that this is a 


model, not the intake, just a model. A run, 


there was an IMBA run into the urine, into the 


medium which is the 50 percentile. If you’re 


going for the 95 percentile, will happen the 


same thing. There will be some years or 


quarters of years that will be above this line 


and some that will be below that line. 


Can you understand me? It’s very 


difficult to explain to you by telephone. 


MR. FITZGERALD: I think --


DR. LIPSZTEIN (by Telephone): Yes, because 


probably you don’t even OTIB-38 with you 


because it some OTIB-38. But it’s very 


difficult to explain. But this is a model. 


This is not, you’re not talking about real 


data. 


DR. ULSH: I only have two questions, and 


they’re not technical because this is deep 


water and I’d like to see the write up first. 


But it’s not clear to me whether the issues 


that you’re presenting are in SC&A’s 

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estimation SEC issues or more TBD-type issues. 


DR. LIPSZTEIN (by Telephone): Oh, no, they 


are not, no, no. I think there is a model. I 


think there is a way to reconstruct 


unmonitored, you know, to apply this model to 


unmonitored workers. I agree with it, and 


then we just have to agree on the numbers. 


DR. ULSH: Okay, well then I’ll hold off on 


my second question. 


MR. GRIFFON: Joyce, did you review this 


other paper we’re talking about? Because you 


mentioned the two Lockamy papers, but the 


Donna Cragle --


DR. LIPSZTEIN (by Telephone): Yeah, but 


then it’s just the number of sample, and good 


thing to do with the Lockamy tables is that 


they have the percentiles from it. So it’s --


MR. GRIFFON: So no concerns that the 


numbers are a little different? 


DR. LIPSZTEIN (by Telephone): I think NIOSH 


explained it to us, that they have taken out 


some numbers because they are either related 


to incidents. Isn’t this true? 


MR. GRIFFON: No, I’m not talking about the 


Lockamy stuff compared to OTIB-38 as much as I 

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am about the year-by-year CEDR versus HIS-20. 


Those are larger discrepancies. They’re just 


not removing incidents. There’s differences 


in data, and they did explain that as well 


because people were never in, people pre-1977, 


as we’ve discussed, were not in the HIS-20. 


But there’s some large differences in it. I 


guess we’ll leave that alone for now, but I 


don’t know where that --


MR. FITZGERALD: No, I think this point is 


sufficiently complex. I wouldn’t propose we 


continue on the phone, but the write up will 


be circulated and it’s not in our view an SEC 


issue, but nonetheless it’s a TBD question 


that we ought to give you, certainly have an 


opportunity to close on. 


Okay? Thank you, Joyce. 


MR. GRIFFON: I thought you had some 


coworker models? 


MR. FITZGERALD: No, again, I think much of 


what Ron is dealing with is OTIB-58 and its 


application and some of the loose ends that 


we’re trying to resolve, but none of which 


appear to be SEC issues. And the same thing 


with Joyce. I think in general, without 

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getting into the population of these models 


with data, which is other issues, we’re 


certainly okay on the models. 


MR. GRIFFON: And I think from that 


standpoint I will say because that’s still one 


of my concerns, but I think we’ve got so many 


pieces out there speaking to that, I think now 


we’ve got to just evaluate the, sort of the 


weight of the evidence. 


MR. FITZGERALD: We’ve been coming at it 


from different says. 


MR. GRIFFON: We’ve got, and I admit I 


haven’t even looked at this yet, but NIOSH has 


looked at the correlator reports as I 


requested and compared those to the database. 


And we’ve got internal comparisons between the 


databases, and explanations. We’ve got this 


last logbook comparison which looks at some 


raw data compared to the database. So I think 


we’ve just got to, we’ve got all these pieces 


now, and we’ve just got to weigh this. 


DR. ULSH: Did you mention the progress 


reports? 


MR. GRIFFON: Quarterly reports, progress 


reports, whatever you want to call them. 

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MS. MUNN: This is post-April. This issue, 


these pieces we can put together. 


MR. GRIFFON: Yes, I mean I guess what I’m 


saying is I don’t think we need any more 


pieces from anybody. I think we’ve got it on 


the table, and we just have to --


MR. FITZGERALD: Yeah, it has to be 


developed into a report, and made into 


analysis and conclusion. And we do have 


various pieces that have to be woven together, 


but I think we’ve got the basics. 


MR. GRIFFON: Nothing else on coworker 


models I take it? 


MR. FITZGERALD: No, I want to reaffirm that 


we have spent a great deal of time on 


different facets of this. We can only go back 


to the OTIB-38 debates on 95th percentile. We 


have spent a lot of time. I think there’s a 


question of data completeness, but other than 


I think we’ve done a lot of review on this. 


MR. GRIFFON: Well, the only last item I 


have on here is proof of process and maybe 


picking some cases that we’re interested in. 


WOUNDS ISSUE
 

But the wound scenario question, and I --

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Jim, are you still on with us? 


DR. NETON (by Telephone): Yeah, I’m here. 


MR. GRIFFON: Okay, I mean I guess the very 


specific question that -- I think I raised 


this. Actually, I’m sure I raised it -- there 


were some early write ups, early reports. I 


think it was in part what put me onto this was 


reading some of the early progress reports, 


and noticing that oftentimes the incidents 


were attributed to wounds, wound scenarios, 


and then there was a paper, and I must admit I 


forget who the health physicist was at the 


time, but he had a write up saying that now 


that they have wound monitoring, they thought 


they had a good handle on this. But he -- and 


this was kind of an historical piece so the 


first decade, I think, at Rocky, he did have a 


concern that in the earlier years that this 


would probably, could have been the most 


significant internal doses. And they may have 


been missed since they didn’t have this one 


monitoring technique. And so I was just, it 


just raised a question in my mind as to 


whether our model would effectively bound sort 


of any scenario we could come up with related 

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to wounds where you could have somebody intake 


via a wound but didn’t know they were wounded 


and on their routine urinalysis you wouldn’t 


necessarily have indication that they were 


wounded so you treated inhalation. 


DR. NETON (by Telephone): I’m in agreement. 


I think that we can, the wound dose, the dose 


that’s delivered from a wound is directly 


related to the amount that becomes systemic, 


and we’ve talked about this before. In a 


sense, you got a release from the wound into 


the system and that would show up in the urine 


sample. So it seems like we would model this 


as a lung count and a lung intake. 


And then if the projected bioassay 


results were overlaid on top of the urinalysis 


results, you essentially have the same thing. 


You’ve got the systemic dose then calculated, 


and it doesn’t really matter whether the 


material’s ingested from the lung or from the 


wound as long as you, the injection profile 


shows the same amount of systemic urine for 


the urine which the systemic burden, you 


should get the same answer. 


But we can do this. We can go back. 

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We have a wound model in the OTIB on that, I 


believe. 


DR. ULSH: It’s in 22. 


DR. NETON (by Telephone): So we could go 


back, and we haven’t done this, Mark, which is 


do a broad comparison of what the TIB-49 


calculations would do versus the model might 


show based on possible urine profiles. So 


it’s systemic, and that’s going to deliver a 


certain dose to the organ. As long as your 


projected urine excretion curve is the same, 


you should get the same number. 


DR. LIPSZTEIN (by Telephone): Jim, I think 


that you’re right. The only worry I have is 


for unmonitored workers because OTIB-38 is 


applied to unmonitored workers and inhalation. 


DR. NETON (by Telephone): Right, but then 


unmonitored workers, oh, I see, the urine 


sample as the result of unmonitored workers is 


not necessarily the appropriate one. 


MR. GRIFFON: That was sort of the question 


that you were going to follow up on. 


DR. LIPSZTEIN (by Telephone): Yeah. 


DR. NETON (by Telephone): We need to go 


back and re-think this then, because I was 

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thinking from the other perspective where we 


have the monitored data. 


MR. GRIFFON: Now we don’t have a lot of 


these I think is what Brant’s going to say. 


DR. ULSH: You’re reading my mind, Mark. 


DR. LIPSZTEIN (by Telephone): Actually, 


what you say on the OTIB on monitoring is you 


have a general (unintelligible) and if it 


doesn’t fit your data you go on and fit it 


yourself for the TIB. Nothing to discuss on 


that. I think the issue is unmonitored 


worker. 


DR. ULSH: Yeah, just to elaborate on, Mark, 


I mean just my comment, keep in mind what 


we’ve --


DR. NETON (by Telephone): Yeah, we need to 


think about this a little more. We’ll get 


back and re-huddle and see what our position 


is on that. 


DR. ULSH: All right, but keep in mind 


though that in the data completeness review, 


the 52 cases, we found no gaps. 


DR. MAKHIJANI: Oh, correction. 


DR. ULSH: In internal. 


DR. MAKHIJANI: There were no gaps in the 20 

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highly exposed cases if I remember correctly. 


I will check. 


DR. ULSH: All right, Arjun, perhaps I 


should specify what I’m saying. I should be 


more careful with my words. NIOSH found no 


suspect gaps. Now I’m not saying that SC&A 


necessarily agrees with that, but that’s what 


we found. 


DR. MAKHIJANI: Okay. 


DR. ULSH: And also keep in mind the number 


of dose reconstructions that we have done and 


that have required internal coworker data. I 


think there were a total of around 110 or 


something, but of those most of those were 


external. There were only ten or so internal. 


And I don’t even know how many of those were 


before, you know, in the ‘50s before the wound 


counter, the lung counter. So just keep that, 


it’s important to keep the scope of the issue 


in mind. 


DR. MAKHIJANI: We agree there were gaps in 


the, in our count, that is, one year or more 


with no monitoring data in the random sample 


including 73 percent in the 1964 to 1992 with 


at least, 73 percent of workers with one year 

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or more of gap. Now when we looked at the 20 


cases of high cumulative doses, we concluded 


that because those records were complete in 


this definition that you should have no 


problem in terms of coworker model in 


principle looking to job types and, you know, 


some caveats, but there wasn’t like an SEC 


issue there. But on the random sample there 


were many cases of workers who didn’t have any 


monitoring record for one year or more. 


MR. GRIFFON: I do understand the scope, but 


I just think --


DR. ULSH: I’m not trying to say we should ­

-


DR. MAKHIJANI: And we did not consider this 


wound question. It was just from the 


completeness question. 


MR. GRIFFON: I think we’re, it’s a NIOSH 


action that’s agreeable and it leaves it at 


that. 


MS. MUNN: SEC or non-SEC? 


MR. GRIFFON: Well, assuming they can 


demonstrate that it’s bounding, I think it’s 


non-SEC. 


DR. NETON (by Telephone): Yeah, I think 

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that you’re right, Mark. 


MR. GRIFFON: Also, it’s very apparent that 


most people have monitoring data so there’s 


not been many unmonitored for internal. So my 


sense is it’s going to end up non-SEC, but I 


would like to have an answer. 


DR. ULSH: Mark, for clarity could you just 


restate the action item as you see it because 


I just want to make sure that we understand --


MR. GRIFFON: I think we want to see a 


comparison of the, how, whether the coworker 


model is bounding for wounds for unmonitored, 


you know, a person who was exposed by a wound 


but wasn’t on a monitoring program. 


DR. NETON (by Telephone): And the 


difficulty of non-monitoring’s going to be, 


essentially, you almost need a coworker wound 


model which I don’t think we have. But then 


you’re going to have to assume at some point 


that the people with wounds are also included 


in the urinalysis database and therefore, 


would be covered by, say if we picked the 95th
 

percentile -- I don’t know. I have to think 


about this, but there are ways around this 


issue. 

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MR. GRIFFON: Give us some response. My 


sense is it’s not an SEC, my sense is it’s not 


going to be an SEC issue. 


DR. NETON (by Telephone): We’ll put it 


together thoughtfully. 


 MR. SHARFI: Are you looking for a 


comparison using coworker as a wound versus 


coworker as an inhalation? 

DR. NETON (by Telephone): Oh, no. 

MR. GRIFFON: No. 

DR. NETON (by Telephone): I think what 

we’re looking for here is to show that we can 


handle our current approach with sufficiently, 


with people who could have had wounds that 


were unmonitored, and that the coworker data 


that we’re using, the urinalysis data, would 


be sufficiently bounding. 


And we have data, data, and we can 


handle it. We have a TIB on that. We’ve got 


urinalysis data, and if we apply the 


urinalysis data using the lung model, I’m 


pretty confident we’re okay. But you’ve got a 


person that was never monitored, and you apply 


the coworker lung model, does that bound his 


potential wound if he’s got one? 

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MR. GRIFFON: I think that’s the reason I’m 


getting a funny look from Mutty probably is if 


you’re unmonitored, how do you know what the, 


how big the wound was or --


DR. NETON (by Telephone): I think we need 


to go back and look at the urinalysis coworker 


model which was not necessarily a urinalysis 


of everything, wounds, ingestion --


MR. GRIFFON: I even looked at some 


scenarios of, and I must admit it wasn’t 


wound. I just assumed injection just because 


it was easier. And I did some scenarios with 


less than MDA values, and I thought -- these 


are real rough calculations, but I thought I 


had some circumstances where the doses 


wouldn’t have been bounding with the 


inhalation approach. 


DR. NETON (by Telephone): That’s hard to 


believe though. 


MR. GRIFFON: I know. It doesn’t make sense 


of what we discussed, but --


DR. NETON (by Telephone): If it’s not 


coming out in the urine, we’re going to come 


up with a dose less than MDA values. 


MS. MUNN: Is this a scenario we have 

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encountered in any claimant? 


DR. NETON (by Telephone): I guess this 


followed the scenario, you know, of proving a 


negative almost, but --


 MR. SHARFI: That’s where I’m getting 


confused. 


MS. MUNN: Do we have claimants --


DR. NETON (by Telephone): I would agree 


that there are potentially people out there 


that could have had a wound that went unkept. 


MR. GRIFFON: Well, it’s not only this 


hypothetical thing. It’s in the paper, this 


guy presents in, you know, I wouldn’t just say 


DR. NETON (by Telephone): Okay, well that 


might be a paper that might be helpful. 


MR. GRIFFON: When we first talked about 


wounds, I mean, I thought no big deal because 


in most cases I could think of if somebody got 


a wound health physics would know that it was 


a wound and model it that way and it would be 


in the rad file. But then this paper 


describes actually in the early years it 


probably would not have been necessarily 


documented or monitored that way. So that’s 

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the context I brought it up in. 


MR. FITZGERALD: I think he hasn’t seen it, 


the paper. 


MR. GRIFFON: And I’ll have to, I can 


certainly forward the, it’s on your O drive. 


I’ll point it to you. 


DR. MAKHIJANI: It’s a paper that describes 


the particular process inside the plutonium 


processing area that have a sharp band that 


workers cut their fingers on. 


MR. GRIFFON: And it even goes on to say, it 


suggests certain design changes in the glove 


box. 


DR. NETON (by Telephone): It makes you kind 


of wonder how these people would have been 


totally unmonitored, but I suppose --


MR. GRIFFON: Right, these people may have 


been monitored if they were in that area. So 


therefore, we’re going to be able to assign 


less than MDA. 


DR. NETON (by Telephone): Okay, we’ll take 


a look at it and get something on paper. 


MR. GRIFFON: Okay, that’s all we’re asking. 


And I don’t think it’s going to be an SEC 


issue. 

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PROOF OF PROCESS
 

I guess the last item, the last item 


is this question of proof of process and some 


example or sample cases. And I’ve tried to, I 


mean, well, just to go in my parenthetical 


there, the examples of coworker models I think 


would be useful. And if the ones that are 


available, I think it would be good to look at 


real cases. 


And if you need to add an explanation 


that, you know, as we discussed in the work 


group we could just, for the time period or 


whatever, if the current model doesn’t display 


the, we certainly could, you know, that would 


be certainly appropriate I think. I don’t 


know. The ones we heard this morning I 


thought we talked about an example foundry 


worker, but we also said that that may not be 


possible to find, right? 


DR. ULSH: Yeah I do have some --


MR. GRIFFON: I know it’s not very good --


DR. ULSH: I do have some thoughts on this, 


Mark. I do like your suggestion that we 


actually look at real cases, just point out 


the numbers to you and let you guys take a 

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look at them. I think that’s a really good 


idea. And I think that will certainly be 


possible for internal coworker model, external 


coworker model, and we are starting to get 


some in now with Super-S. So I think we can 


do that. We can provide some examples of you, 


examples for you in those categories. 


Now in terms of uranium foundry --


I’ll get to thorium, but in terms of uranium 


foundry workers in the ‘50s, what we have 


shown, at least this morning, and I know that 


this is all new information to you, is that 


those folks were indeed monitored. So dose 


reconstructions for uranium foundry workers in 


the ‘50s aren’t going to look any different 


than other monitored workers in the ‘50s. 


It’s going to look the same because they were 


monitored. So I don’t know if there’s still a 


need to do that or not. I guess I’d like to 


get your pulse on that. 


MR. GRIFFON: Right, I’m not sure either. 


That was new information this morning. 


MS. MUNN: It seems to me you’ve got 


monitored, when you have monitoring data, you 


use the data you have. 

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DR. ULSH: I think our action item on that 


was to point out to SC&A or to SC&A and the 


working group with the monitoring data for the 


foundry workers. 


MS. MUNN: To show that they were in fact 

monitored. 

DR. ULSH: Show that they were monitored, 

right. 

MR. GRIFFON: I think we have that as 


another action item. 


DR. ULSH: And if we do that, and let’s just 


assume for the sake of discussion that we do 


that and you’re satisfied that, yes, they were 


monitored, then my question is do we still 


have a need for an example for uranium foundry 


worker in particular? 


MR. GRIFFON: I wouldn’t think so. 


What do you think, Arjun and Joe? 


MR. FITZGERALD: Examples of foundry workers 


at the factory would establish that there is 


data, that they were monitored. 


DR. MAKHIJANI: Well, if you’re limited you 


might not find as many examples always. It 


would seal the question. If you have the data 


and you can apply it in an example, but I 

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think if we can look at the data and look at 


the practice in terms of weekly, biweekly, 


monthly badging, the kinds of data that you 


circulated for 1953. If we can see that is 


more pervasive than the data were actually 


there maybe it might be equivalent. I just 


have to think about that a little. 


MR. FITZGERALD: Yeah, I think -- I don’t 


want to conflate the question of completeness 


versus proof of process either because if we 


demonstrate completeness, I’m not sure that’s 


different than what we’re trying, I think, to 


do here. So I don’t know. If you can provide 


the data, I’m not sure that doesn’t answer the 


question we have. 


DR. MAKHIJANI: It would answer the question 


we had on the --


MR. FITZGERALD: Foundry workers. 


DR. MAKHIJANI: -- the completeness thing. 


You know, we identified gaps among the non-


plutonium workers, and identified foundry 


workers as ones having potential for higher 


exposure, and if they have data, then that 


completeness, if they were systematically 


monitored, and they have been identified 

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internally as having potential high exposures 


then that piece of it would go away. 


MR. FITZGERALD: Yeah, I think we’re talking 


about really the models themselves. Whether 


it’s 49, 38, 58, we’re looking at how they 


would be applied in practice, and I think 


that’s the -- am I right? That’s kind of --


MR. GRIFFON: Well, those three we agreed --


MR. FITZGERALD: Beyond those three, I 


guess, is the question we’ve got. 


MR. GRIFFON: Well, I mean, it may not be 


the uranium foundry workers. It may be these 


other uranium workers --


DR. MAKHIJANI: It may be. 


MR. GRIFFON: -- in 881. We know they’re 


not monitored. 


DR. MAKHIJANI: Well, the 1950s. 


MR. GRIFFON: Is that right? 


DR. ULSH: That’s going to look like the 


external coworker model. 


MR. FITZGERALD: Yeah, that’s what I’m kind 


of getting at, that when you get to that 


issue, it’s really going to be the same 


modeling. 


MS. MUNN: Right, and when you have the data 

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for the ‘50s folks, you know, you’re going to 


use the data. You know how you’re going to 


get that. 


MR. GRIFFON: I was thinking there was a 


separate uranium and plutonium external, but 


it’s all rolled into one external for the 


coworker model. 


DR. MAKHIJANI: I think the more outstanding 


question is the one we raised actually about 


Building 881, understanding that it’s not the 


same kind of issues as the foundry. It’s the 


back extrapolation from 1960 and ’61. We’ve 


said that the coworker model looks okay when 


you look at the 1960 and ’61 application and 


covers the situation adequately, but the back 


extrapolation didn’t seem as convincing. And 


so how that back extrapolation is going to be 


done is still a question. 


MR. GRIFFON: Now what you’re telling me if 


you give us a real case it’s going to be the 


regular model. We’re not going to see 


anything --


DR. MAKHIJANI: We’re not going to see that 


because the back extrapolation, the questions 


that we raised in relation to that are (a) 

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that typical production was lower, doses would 


be lower, and (b) above the infrastructure in 


its relationship to dose. I don’t know how 


we’re going to get there. I haven’t thought 


about it enough. We haven’t discussed it. 


MR. FITZGERALD: Not that aspect, but I 


think that’s --


DR. ULSH: Yeah, really, I mean, to be fair 


we just gave you our report last week, and you 


might need a little more time to digest that. 


And if you have more comments then --


DR. MAKHIJANI: You know, when I present 


things, of course, they’ve been vetted 


internally, and just as the principle author, 


I’m just saying things that we’ve vetted. So 


this thing we have not vetted internally. 


MR. GRIFFON: What about the question of the 


thorium example? 


DR. ULSH: Yeah, I wanted to get to that. 


All along it has been our position that there 


were not significant, there wasn’t the 


potential for significant thorium exposures. 


Now, I know that I don’t want to assume that 


we have concurrence with SC&A on that 


particular piece. And I don’t want to upset 

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the apple cart here on the agreement that we 


hatched out with thorium. 


But what we would do for a situation 


where there was someone with thorium is, I 


mean, if they had bioassay, we would use it. 


And if they don’t, I mean, we would have to 


have some kind of an indication that they had 


a potential for intake, say, for instance, 


maybe they were involved in the thorium 


strike. And we’ve laid out our approach on 


that. I mean, it relies on NUREG-1400, which 


I know that SC&A has some reservations about 


still. 


In terms of in this context though, 


Mark, where you’re asking for proof of process 


for thorium workers, I mean for people who 


might have had thorium, I’m not going to be 


able to present you with a real case on that 


because the numbers were so low, you know, 


number of workers were so low, I mean, I 


haven’t seen a case with --


MR. GRIFFON: To date you haven’t had a 


claim that you’d use that modeling? 


DR. ULSH: That’s correct. We were using 


NUREG-1400 to show a bounding approach and 

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show that even under these boundings, what we 


consider bounding scenarios, there’s not a 


single potential so we don’t really have to 


deal with it. 


MR. GRIFFON: You haven’t found anybody that 


worked in operations or in those areas? I’m 


not sure how you’re defining who. I guess 


that was part of the proof of process. How do 


you define if someone was a thorium, 


potentially exposed with thorium. 


DR. ULSH: I won’t tell you that we know 


every single name of every single person who 


was involved in it, but we do know quite a 


number of them. The thorium ingot operation 


in 1960, there was a list in Kittinger’s 


logbook that covered that time period that 


said these people were involved in the 


operation. I don’t recall that any of those 


were claimants, but don’t hold me to that. 


In terms of the thorium strikes, we 


know a couple of people who were involved, and 


we know that the numbers were small. But I 


can’t think of an example of a completed dose 


reconstruction that we have done on a person 


who was involved in, off the top of my head, 

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so I don’t know if I can present you with a 


real --


MR. GRIFFON: I think thorium, you know, if 


you presented today it would be a hypothetical 


example with NUREG-1400. 


DR. ULSH: That’s what we had today. 


MR. GRIFFON: And I think you already posted 


one of those. I don’t know. 


It doesn’t help anyway. 


MR. FITZGERALD: I really think the three we 


just talked about, the ones that we’re looking 


to validate so to speak on this. 


MR. GRIFFON: That might be the only one. I 


was just exploring. 


DR. ULSH: Internal coworker, external 


coworker, Super-S. Okay, we can do that. We 


can do that. We can give you lists of 


claimants that fall into those categories. 


 MR. SHARFI: Any or partials? I mean 


partial assessment. 


DR. ULSH: We’ll work out the details. 


 MR. SHARFI: Partials. 


DR. ULSH: Yes. 


MR. GRIFFON: The Super-S or partials. 


 MR. SHARFI: Probably the ones that we’ve 

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done. The ones we’ll probably shoot for will 


be the easier one. 


DR. ULSH: Yeah, that’s true. I mean, the 


Super-S is --


MR. ELLIOTT: Partial meaning they’re an 


underestimate? 


DR. ULSH: Yes. 


 MR. SHARFI: Most likely. First one we 


should (unintelligible) the lung cancers, and 


work our way to the harder ones. 


DR. ULSH: We’ll give you what we’ve got. 


Keep in mind though that Super-S is, we’re 


just working those in the claimed process so 


we’ll give you what we have. 


MR. GRIFFON: And I think that’s probably 


the third in importance really. 


MR. FITZGERALD: Right, and we’re sampling 


from this rather small, I think somebody said 


ten internal coworkers or is there something 


different? 


DR. ULSH: Something like that. 


MR. GRIFFON: Now the only other, I guess 


the other sort of example I was thinking of is 


one of these, I mean, you mentioned that you 


use other, well, I’m not sure we need that, 

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but I’m just thinking out loud here. The 


other types of dose reconstructions that are 


out there are these ones that you used, other 


techniques to fill in, for lack of a better 


word, gaps. You know, you used your other 


approaches, your LOD over two or LODs or 


whatever. Rather than a coworker model you 


used other techniques to fill in the gaps, but 


I’m not sure that’s going to shed much light 


on what we reviewed here. 


MR. FITZGERALD: I think that would be 


rather conventional, I mean in terms of 


missing data, bridging missing data in terms 


of using LOD over two. I think that’s pretty 


much the same process we’re seeing elsewhere, 


right? 


MR. GRIFFON: Yeah, yeah. 


DR. ULSH: So do you want to stick with 


these three? 


MR. GRIFFON: Yeah. 


DR. MAKHIJANI: Yeah, I think so. 


MR. ELLIOTT: At the risk of upsetting this 


tentative agreement, I thought I heard earlier 


that you wanted us to try to show where we 


attended to unmonitored situations by using 

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missed dose, that the missed dose actually, 


did it cover, did it address, did it envelope, 


did it include the unmonitored? 


MR. GRIFFON: Yes. 


DR. ULSH: Are you talking about in the 


wound model discussion? 


MR. ELLIOTT: No. 


DR. MAKHIJANI: These are the gaps. 


MR. ELLIOTT: Where we took the unmonitored 


to zero and narrowed down through the 


unmonitored. The badge went unrecorded, you 


know. Didn’t we agree that we would provide 


you an example showing you that either the 


missed dose approach, LOD over two or LODU 


whatever did include, did bound, did cover, 


envelope, to use a Joe term here, envelope the 


effect. 


DR. MAKHIJANI: You’re right. I think we 


authorized that. 


DR. ULSH: Okay, some of those that we 


provide in internal coworker and external 


coworker --


MR. ELLIOTT: And have us to come back later 


and say we didn’t do something. 


MS. MUNN: So they’ll be covered by --

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MR. GRIFFON: Make sure, yeah. 


DR. MAKHIJANI: We actually agreed on that. 


MR. ELLIOTT: This is for the ’69 timeframe 


with the unmonitored zeros, that are truly not 


zeros. We all agree that they’re probably not 


zeros. But that our missed dose approach 


either addresses that properly, or if it 


doesn’t, what are we going to do about it, I 


guess. 


DR. MAKHIJANI: Yeah, and is there a, this 


is not a sort of principle thing. It’s in 


relation to an action on the question of the 


zeros when there was no monitoring, what 


action would be taken because I think that 


might be an important issue in its own right. 


I don’t know whether you think it’s an 


important issue in its own right that that 


should be settled in this context of whether 


it can be bumped to some other context. 


DR. ULSH: Well, I think what Mark suggested 


was we’ll present you with an example of, say, 


external coworker model in OTIB-58 as it is 


now. And then we’ll make a note if we were to 


exclude zeros, here’s the values that would be 


applied in those years. 

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Right? Is that what you said, Mark? 


DR. MAKHIJANI: Yeah, I’m not talking about 


that in the context of proof of principle 


which I think is fine. I’m talking about that 


as an issue in its own right independent of 


dose reconstructability is that when you come 


to making a decision there’s a question of 


having a database and would it be legitimate 


to use that database. If you could 


demonstrate we’re technically okay, for 


instance, if we legitimately use that database 


knowing that it had this kind of information. 


I think that’s an important thing because it’s 


the first time you’re going to confront that 


issue. There is a kind of a resolution that’s 


possible about it just on its own merits. And 


I think --


MR. GRIFFON: That probably is something to 


consider because we’re acknowledging that at 


least some of those zeros and certainly see 


from the --


MR. ELLIOTT: They’re not true zeros. As we 


said before, they’re not true zeros. 


MS. MUNN: So the real question is --


MR. GRIFFON: Someone could say you’re using 

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a database that you know, you’ve acknowledged 


on the record, is, you know --


MR. ELLIOTT: Essentially, we’re creating a 


database, a distribution of dose including a 


zero which is not a zero. 


MR. GRIFFON: Right. 


MR. ELLIOTT: We shouldn’t do that. 


DR. MAKHIJANI: And I think we’ve said that 


in the record here. I think there’s been real 


progress, that we have agreement about that. 


We’re clear here about all the terms and what 


we mean by them. I, you know, having been on 


the outside on this very same question in a 


different context where I came across this 


non-monitoring data for an air release data 


radionuclides through stacks. I’m on the 


record as having taken a very dim view of 


using this kind of information. And so I just 


think that this is an issue in its right, and 


there is a solution to it, and --


MR. ELLIOTT: But I don’t know where you’re 


going with this. I think we agree with you 


that it’s, we need to do something right here. 


DR. MAKHIJANI: No, no, I agree. I think we 


have an agreement. All I’m saying is that 

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agreement going to be a formal part of this 


process of completing and closing out the SEC 


process or is it going to be a proof of 


principle that we could do it one way or we 


could do it another way and it doesn’t really 


matter. 


MR. GRIFFON: In other words, he’s saying 


are you going to leave the zeros in but 


demonstrate that it wouldn’t matter or are you 


going to actually just say, you know, we’ve 


identified this or do you think it’s best to 


just remove them all. 


 DR. WADE: Systemically solve the problem. 


MR. ELLIOTT: I think we need to 


systemically solve the problem. 


MS. MUNN: What’s the global policy? 


DR. ULSH: We won’t use that data. 


MR. ELLIOTT: We should never use bad data. 


I think we’re in agreement on that, but I 


still think you’ve asked us to show, we made a 


statement earlier today that we were operating 


under a belief that the missed dose concept 


bounded the unmonitored piece. Now to come 


back to you and say we still believe that, we 


need to show that in proof of principle here, 

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proof of process. If we come back to you, and 


we say we don’t think that that’s right, and 


I’m not saying we don’t, I think we agree we 


don’t, do we still have to do that? Do we 


still have to show you an example or should we 


just go forward and change it. I think we 


should just go forward and change it. 


 DR. WADE: Solve the problem. 


MR. ELLIOTT: Yes. 

MR. GRIFFON: I agree. 

MR. ELLIOTT: Stop this wrangling back and 

forth. Let’s just accept it and move, make 


the change. 


DR. MAKHIJANI: Agreed. 


MR. ELLIOTT: Thank you. 


MS. MUNN: My only concern with that is that 


if by doing so it appears that we over-inflate 


the calculated dose, then again, we’re 


misleading everybody if we do that. So I 


guess seeing what the difference would be --


MR. ELLIOTT: Would be informative for you. 


MS. MUNN: Would be informative. 


DR. ULSH: I had it earlier. I can tell you 


qualitatively, Wanda, in here somewhere in 


this box file. 

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MR. ELLIOTT: I think we can do that, too. 


I think we can be informative and --


MR. GRIFFON: I don’t think it’s going to 


make a huge difference. 


DR. ULSH: Not at the 95th percentile. 


MR. ELLIOTT: Let me ask this question. Do 


you have any knowledge of any other site 


situations where we encountered unmonitored or 


people who were badged but the badges were 


never read and we’ve included that data, those 


zeros? Do you have any idea that we had that 


anywhere else? 


MR. GRIFFON: Outside of Rocky Flats? 


MR. ELLIOTT: Outside of Rocky Flats. 


DR. MAKHIJANI: No, I know this issue has 


come up in Fernald in relation to the stack 


monitoring data, and it is an SEC petition. 


MR. ELLIOTT: I think the message here is we 


better take a good hard look and make sure 


that we’re not using bad data to create 


distribution. 


RECAP OF ACTION ITEMS
 

MR. GRIFFON: Can I just go back over a few 


actions just to make sure. Going back to this 


morning I have NIOSH will post lab worksheets 

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-- am I getting that right? And do you have a 


timeframe on that? 


 DR. LITTLE: ‘Sixty-eight, ’69 for the 


foundry workers. 


MR. ELLIOTT: How soon will you post I think 


is where he’s going. 


MR. GRIFFON: I was asking for what he 


answered, but I’m assuming as soon as 


possible. 


MR. ELLIOTT: As soon as possible. 


MR. GRIFFON: Can I ask just to answer to 


that question ’68, ’69 for foundry workers. 


Are there any of these other lab worksheets 


that could be -- they stop in ’70, right? I’m 


going over old ground here I think, but --


 DR. LITTLE: Yeah, well --


DR. ULSH: The zeros with the arrow down the 


page. 


 DR. LITTLE: Oh, yes, the zero, that stops. 


Well, we haven’t actually --


DR. ULSH: Those are film worksheets. 


They’re going to stop in ’70. 


 DR. LITTLE: Absolutely, they’ll stop in 


’70. The question was do they continue into 


’70, and I can’t answer that question. 

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MR. GRIFFON: And is there anything prior to 


just for this, if you’re doing foundry 


workers, do we want some in the early years 


also? 


DR. ULSH: Well, we’ve got the ‘50s that 


we’re going to provide, the monitoring data 


like the example. 


MR. GRIFFON: Yeah, right. 


 DR. LITTLE: Well, what do you want to see? 


That’s the question. Do you want to see 


actual data? 


MR. GRIFFON: We have these lab worksheets 


for foundry workers for different times for 


those. 


 DR. LITTLE: Well, you know, as you saw in 


that table for three-quarters of 1969 you’re 


going to have a zero with a line down it. For 


’70, I think for fourth quarter ’69 you’re 


going to see actual numbers. 


MS. MUNN: Now wait, you’ve lost me again. 


I thought we were talking about ‘50s and all 


of a sudden we’re back in ’69. 


 DR. LITTLE: I confuse myself. 


DR. ULSH: Let’s make it clear we’re talking 


about foundry workers. What we’re going to 

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provide as I understand it is these lab 


worksheets that show the zeros with the arrows 


down it in ’69 and ’70 for the foundry 


workers. In addition, we’re going to provide 


what Arjun’s holding up right now, which is 


like the example that I passed around this 


morning, the Building 44 that includes the 


foundry workers, their dosimetry results just 


like the example. 


MR. GRIFFON: I understand. If you can do a 


couple of those --


MR. ELLIOTT: Different years. 

MR. GRIFFON: Between ’50, what is that, 

‘54? 

MS. MUNN: That’s ’53. 


MR. GRIFFON: ‘Fifty-three, between ’53 and 


’69. 


DR. ULSH: We’ll provide you with more of 


this. 


MR. GRIFFON: Not the whole set, a few 


examples. 


MS. MUNN: Very few. 


 MS. JESSEN: That’s two action items so far. 


DR. ULSH: Two action items so far? 


 MS. JESSEN: I’ve written down on this 

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clarification. 


MR. GRIFFON: Well, I thought it was all 


part of one, but it might be two. 


 MS. JESSEN: Well, break it down into dates. 


MR. GRIFFON: The second one is SC&A will 


contact the petitioner regarding thorium 


question just to see if he has anymore 


information on source term. 


The third one, and I may have missed 


something so we’ll go to you all at the end. 


Third is NIOSH to provide identifiers for 


neutron data needed by Ron. 


And then the fourth one I have is 


there’s this question in TIB-58, table 07-1 of 


the non-penetrating versus penetrating. 


That’s an ongoing correspondence between --


DR. ULSH: Yeah, I just sent something to 


Ron this week, so it’s probably --


MS. MUNN: And not an SEC issue. 


DR. ULSH: No, well, no. 


MR. GRIFFON: That’s non-penetrating, I 


don’t think that one is. 


And then the only other one I have I 


think is the three examples, and I may have 


missed some. 

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DR. ULSH: Examples of the three different 


types, proof of principle, but we missed wound 


modeling. 


 DR. WADE: Jim was going to think -– 


 MR. ELLIOTT: And Joyce was going to provide 


something in explanation of the --


MS. MUNN: She was going to provide graphs 


and things. 


MR. ELLIOTT: Right, further elucidation of 


what the issue is. 


MR. FITZGERALD: Well, actually we have her 


write up, and what I’m going to try to do is 


get that to you. 


MR. GRIFFON: Joyce’s write up modified 


maybe. 


MR. FITZGERALD: Right, right. 


MR. GRIFFON: Is there anything else? 


MS. MUNN: I had SC&A’s response to NIOSH on 


the logbooks and reconciling the differences. 


MR. GRIFFON: Oh, yeah. 


DR. ULSH: Your visit next week. 


MR. FITZGERALD: Oh, the review next week. 


That’s right. That’s a deliverable. There’s 


going to be a number of written deliverables 


that we’ll provide as we have the others, and 

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that will be part of the extension of logbook 


review. There will be one on internal that 


will include Joyce’s, and you just got Ron’s 


which is in Privacy Act review. You might 


also see D&D which, again, is not an SEC 


issue, but just so you have that section. 


MR. GRIFFON: Yeah, these are from old --


MR. FITZGERALD: These are just individual 


sections that we’ll make available as soon as 


we can and go through this process and make 


sure it’s all PA cleared. And it will help us 


put the report together so we don’t have to do 


that 500 pages at once. 


DR. MAKHIJANI: It’s not a proof of 


principle. It lists an EU back extrapolation 


method. Is there going to be some 


clarification on the part of NIOSH or do we 


just write it up or how do you want to proceed 


on that? 


MR. GRIFFON: I think they’ve given us a 


report on that, right? 


DR. ULSH: We’ve given our position. 


MR. GRIFFON: My sense is that NIOSH has 


provided, so I would say include your analysis 


of that in your final write up under EU. 

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That’s part of your final write up. Your old 


reaction is your final write up. 


MR. FITZGERALD: No, right, there’s a number 


of things we didn’t even touch on today that 


were included in NIOSH responses that and God 


knows what else, but we’ll certainly address 


that in the report. 


MR. GRIFFON: Any other actions from today? 


MR. BUCHANAN (by Telephone): This is Ron 


Buchanan. I just wanted to clarify with Brant 


that hold off on those ID numbers. I’m going 


to send you an e-mail to clarify exactly I 


need so you don’t go through a lot of work on 


material I don’t need. So I’ll send you a 


clarification e-mail on that. 


DR. ULSH: Okay, thank you, Ron, I 


appreciate it. 


MR. ELLIOTT: We certainly made a lot of 


progress today. Would you be kind enough, 


Mark, to, if you could, summarize what issues 


remain as SEC-related issues? I think we’ve 


moved several into the site profile dose 


reconstruction category, but I’m not clear 


what remains as an SEC-related issue that 


we’re still tracking here. 

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MR. GRIFFON: I think this question of the 


completeness and data reliability still is 


hanging out there. We certainly got some much 


more information today including the, a little 


more knowledge on the monitoring practices of 


the early time period. But I still think we 


haven’t completely closed that issue. 


All indications are that the thorium 


issue is closed as far as an SEC issue. We 


are going to give the opportunity to 


petitioners, since we did offer it before, but 


if we don’t see anymore in the way of source 


term information, I think it’s definitely 


closed. 


The data integrity, logbook, safety 


concerns are all closed as far as SC&A agrees 


that there are no systemic problems 


identified. The only thing hanging in the one 


report is the logbook HIS-20 comparison, I 


think, and resolving the sort of differences 


in numbers there. I don’t think there’s 


really a difference, reconcile those. 


MR. ELLIOTT: But do you see that as an SEC-


related issue or? 


MR. GRIFFON: Well, only in the sense that 

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gets at the question of the data used in the 


coworker models. 


Super-S is resolved. Neutron dose 


questions appear to be, I mean, I’m convinced 


that they’re site profile issues. I would 


like to hear back, you know, if Ron got those 


identifiers and can calculate N/P ratios for 


this time period, then I think it’s definitely 


a site profile issue. 


And then the coworker models, the 


models themselves I think we agree on. I 


think the only question is the data populating 


the models so that’s that final question. 


So really it’s data completeness and 


then this data reliability which are woven 


together a little bit. We’ve come a long way 


on that even I think. And the one scenario 


that I don’t think that’s an SEC thing, but I 


think it’s easy enough to put to bed. I think 


that we should do it. 


Do you agree with me, Joe and Arjun? 


MR. FITZGERALD: Yeah, I think that covers 


the ground. 


DR. MAKHIJANI: Yes. 


DR. ULSH: A couple of remaining questions, 

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you might be getting to this, Mark. I think 


in general the big action item is, you know, 


or the next thing that’s going to happen is 


SC&A’s going to issue a final report. When 


might that happen? 


MR. GRIFFON: Right, when did we, we talked 


about --


MR. FITZGERALD: We’re talking about 


certainly trying to do that by no later than 


early April, meaning that we’re assuming we 


will need to finish up PA review. Certainly 


incorporate the results of next week’s 


sampling at Rocky in Denver, and also to do 


the reconciliation, the reflection that we 


want to do on the specific comments you just 


gave us this week. And I don’t want to 


underestimate the amount of work entailed in 


that because we’re talking many, many specific 


comments. So we’re already starting to do 


that, and we’ve given you a lion’s share of 


the write ups. But those write ups will have 


to be reworked, I think, to reflect a lot of 


what we’ve done this past week. So we’re 


aiming for sometime between three-to-four 


weeks from now to not only have it written, 

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but also hopefully have it Privacy Act 


reviewed and available which, I think, will 


meet the objective that we discussed before to 


give the public and the petitioners at least a 


month, four weeks, with the document when it’s 


available. 


MR. GRIFFON: So the first week in April 


we’re saying. 


MR. FITZGERALD: Yeah, I think that’s going 


to entail some iterative -- I’m glad you 


offered to do that. We’re going to have to 


have the ability, I think, to do things in 


real-time just because of the tightness of 


time and trying to make sure if we need to run 


something through, we’ll try to do that 


directly rather than try to send you a 


document that goes back and forth. We don’t 


have time to do that. 


MS. HOMOKI-TITUS: It would be really 


helpful when you send documents to us if you 


give us either a drop-dead deadline of when 


you want them back or a priority list. 


MR. FITZGERALD: Right, and I think what’s 


mitigating this is the fact that the most 


significant parts of this document you’ve 

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seen. So really we’re refining those 


important parts of the document. Now you’re 


not going to see them for the first time. 


You’ll seem the refinements. In other words, 


what we’ve just discussed so the rest of it, 


the D&Ds and the internals, Ron’s piece, those 


are pieces I think we’re in agreement so I 


don’t think there’s going to be as much 


controversy in terms of putting those into 


final form. 


DR. MAKHIJANI: Yeah, and there’s going to 


be no new cases and things so that since 


you’ve already reviewed, you’ve already 


reviewed all the tables, I mean, unless 


there’s some stuff that comes up on foundry 


and what we get from NIOSH, they’re not going 


to be, the data completeness, I don’t know 


what’s going to happen in the foundry 


discussion. 


 DR. WADE: Let’s talk as a work group, let’s 


talk a little bit about how this will likely 


play out. I think it’s worth spending a 


little bit of time. 


So we’re likely to see an SC&A report 


at the beginning of April. It’s entirely 

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possible that the next thing that will happen 


will be the Board meeting in May where the 


work group will report out. Now, following 


our normal procedure, the work group isn’t 


going to give a recommendation to the Board. 


The work group is going to report out its 


findings, and there’ll be an opportunity for 


Mark and other members to speak. And then the 


Board will take up and vote on the SEC 


petition that’s in front of it. 


Now, again, you could follow a 


different path which would be the Board, the 


work group to make a recommendation to the 


Board, but that’s not how this body has done 


its business. So again, in May, the first day 


of the meeting will set it up. There’ll be a 


detailed work group report made, an 


opportunity for questioning, interaction, 


comment by petitioners, presentation by NIOSH, 


and then the Board will take up a vote 


sometime during those three days. 


MS. MUNN: We have not had quite such an 


extensive, long-term series of issues in other 


work groups that we’ve had in this one. This 


one has certainly been the granddaddy of all 

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work groups in terms of how many boulders get 


climbed and how many sentences get parsed. I 


would hope that the work group would have an 


opportunity to meet once after SC&A’s report 


is out just to make sure that we really don’t 


have any unresolved issues when we go to the 


Board. 


MR. GRIFFON: Yeah, we may want to do even a 


phone meeting. 


 DR. WADE: Phone call, it would be 


appropriate. 


MR. PRESLEY (by Telephone): Hey, this is 


Bob Presley. I agree with that 100 percent. 


MR. GIBSON (by Telephone): This is Mike. 


This has been an exhausting process that just 


in taking the role of the Savannah River site 


and some other things, it looks like it just 


may be typical of what’s coming down the road. 


So I just think we all need to get prepared 


for that. 


 DR. WADE: Wise counsel. 


MS. MUNN: The SC&A report is going to be 


out by the first week of April, then, Mark, 


you’re going to have a subcommittee meeting on 


the 11th . 

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MR. GRIFFON: Yeah, but we’ve got like three 


meetings that week. 


MS. MUNN: We do. 


 DR. WADE: It’s too early, too. How about 


the middle of the next week, the 18th? 


MR. GRIFFON: The 17th or 18th have a phone 


call? 


DR. ULSH: Now is this a call involving SC&A 


and NIOSH or just the working group? 


MS. MUNN: I think it’s the cast of 


thousands just to make sure --


MR. GRIFFON: We probably need everyone 


there. 


MS. MUNN: Yeah, without everybody there if 


there are any nits to be picked then we’ll --


MR. GRIFFON: Let’s set it up as a phone 


call the 17th, 18th . 


UNIDENTIFIED: The 17th is tax day so you may 


not want to deal with that. 


MR. GRIFFON: Why don’t we say the 19th . 


 DR. WADE: Ten a.m.? 


MR. GRIFFON: The 19th at ten a.m. 


 DR. WADE: A telephone call? 


MR. GRIFFON: Let’s plan it as a conference 


call, but if, depending on a change, if we see 

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the report and we think we need a face-toface, we can maybe work around. 


MS. MUNN: That’s way too early. Can I 


persuade you to do it at 11 a.m., please? 


MR. GRIFFON: What’s that? 


MS. MUNN: Could I persuade you to do it at 


11 a.m. your time? 


MR. GRIFFON: Yeah, 11 a.m. 


 DR. WADE: Mike? 


MR. GRIFFON: Yeah, Mike. 


MR. PRESLEY (by Telephone): No, this is Bob 


Presley. What day is the 19th on? 


 DR. WADE: Thursday. 


MR. GRIFFON: Thursday. 


MR. PRESLEY (by Telephone): Thursday? I 


have a problem with that. Is it going to be a 


phone call? 


 DR. WADE: Yes. 


MR. GRIFFON: Yeah, most likely. 


MR. PRESLEY (by Telephone): Okay, I can 


make a phone call. That’s no problem. 


 DR. WADE: Tentatively a phone call, 11 a.m. 


eastern time on Rocky Flats. Mark, as 


chairman, will reserve the right when SC&A’s 


report is out to poll the group about the 

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possibility of getting together face to face, 


but right now it looks like a phone call. 


MR. GRIFFON: Any other old business? 


MS. MUNN: The only other request is may I 


also have a copy of that CD, the 200 page 


document we discussed this morning? 


DR. ULSH: I’ll get it to you, Wanda. 


MR. GRIFFON: And can we get it on the O 


drive? 


DR. ULSH: Yes. 


MS. MUNN: I need a CD. 


MR. GRIFFON: Wanda, wants a CD. 


DR. ULSH: Okay. 


MR. GRIFFON: I think we’ll close now on 


that note. Thank you. 


 DR. WADE: Thank you all very much. We’re 


going to go away. 


(Whereupon, the working group meeting 


concluded at 5:00 p.m.) 

______________________________ 

269 

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 March 7, 


2007; 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 


6th day of April, 2007. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102