NIOSH Dose Reconstruction 

Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 1 of 12 10/27/05 

Meeting Date: 

February 10, 2005 

Meeting with: 

PACE Local 5-550 and SPFPA Local 111 

The meeting was arranged with union leadership and highly publicized locally. Of the 

approximately 200 people in attendance, the following chose to sign-in: 

Attendees: 

Name Affiliation Name Affiliation 

Eugene L. Caldwell Allied Signal Lloyd Brazell PACE 

Harold Russell PACE Cora Harris PACE 

Betty Rushing PACE Dennis Tyner PACE 

Debbie Paulson PACE Jesse Tyner 

Harold Robey Mary J. Warren 

J.D. Armstrong Jeanne Bone 

Avanell Hornsby Rodney C. Smith 

Homer G. Bullard Jay Stoll SPFPA Local 111 

Mike Kaufman SPFPA Local 111 Fred Carter 

Ron Fowler Joe Walker Paducah Sun 

Robert Pierce Glenn Young 

Bernard Janselm C. Woodford 

Barry Anderson Chris Naas 

Frances Crawford Sue West 

Ralph West Cephus Robertson 

Billie Ellis Cathy Pigg 

Cherry Lee Don Valentine 

James E. Smith Ira Myers 

Doris Myers Fred Golightly 

Kenneth Collier John C. Locke 

Steve Lewis J.B. McGinnis 

Billy Feezer Union Carbide James M. Crews IW Local 782 

Trent Griffin USEC Charles & Dora Humphrey Union Carbide 

Herman & Mildred Englert PGD Plant Tom Emerson PGD Plant 

Charlie Baker PGD Plant 

NIOSH and ORAU Team Representatives: 

Peter A. Darnell – National Institute for Occupational Safety and Health (NIOSH), Office of 

Compensation Analysis and Support (OCAS) 

Jay Maisler – Integrated Environmental Management, Inc. 

William “Bill” Murray – Oak Ridge Associated Universities (ORAU) 

Mark Lewis – Advanced Technologies and Laboratories International Inc. (ATL) 

Dawn Catalano – ATL 
NIOSH Dose Reconstruction 

Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 2 of 12 10/27/05 

Proceedings: 

Leon Owens, Coordinator of the Worker Health Protection Program for PACE Local 5-550, 

called the meeting to order at approximately 10:15 am. He thanked everyone for coming and 

said that the topic would be the Site Profile for the Paducah Gaseous Diffusion Plant. He 

announced that individual claims would not be discussed; but those people with questions about 

their claims should attend a reception at the union hall following the meeting because 

representatives from the Resource Center would be there. Mr. Owens encouraged attendees to 

ask questions and to take advantage of the opportunity for interaction with NIOSH. He added 

that this would be the most direct means to have worker issues considered in Site Profile 

revisions. He then introduced Mark Lewis to give an overview of the presentation. 

Mr. Lewis also thanked everyone for attending. He explained that the Site Profile is a tool used 

by radiation specialists conducting dose reconstructions. Mr. Lewis said that he is a PACE 

member from the Portsmouth Gaseous Diffusion Plant, and understands the workers’ point of 

view. The Site Profile is largely based on official government records, and workers’ input is 

needed. He said the Site Profile can be changed with new information. Accurate documentation 

requires the institutional knowledge of the workers. Mr. Lewis then introduced Jay Maisler, the 

Team Leader of the group that prepared the Paducah Site Profile, and Peter Darnell, representing 

NIOSH. 

Mr. Darnell explained that NIOSH is responsible for only the radiation section of the Energy 

Employees Occupational Illness Compensation Program Act (EEOICPA). The Department of 

Labor (DOL) runs the overall program and NIOSH performs radiation dose reconstructions. Mr. 

Darnell said that a good deal of the work is done by NIOSH contractors, and introduced Mr. 

Murray to give a more detailed explanation of the program. 

Mr. Murray extended his thanks to all in attendance and expressed hope that they would find the 

presentation informative. He introduced the members of the Outreach Team and described each 

person’s role. Mr. Murray said that Mr. Maisler’s experience leading the development of the 

Site Profile for Paducah and Mr. Darnell’s subject matter expertise would help them provide 

accurate answers to questions regarding the document. He also pointed out that both were there 

to listen to the workers’ concerns regarding the site profile. Mr. Murray introduced Dawn 

Catalano, explaining that she would take notes for formal minutes. He added that the meeting 

was being recorded only for the sake of accuracy in the minutes and that no one would be quoted 

by name. The draft minutes would be forwarded to the union leadership for comments before 

they are finalized. Mr. Murray reiterated that the Site Profile is a “living document,” subject to 

revision as new information is received. 

Mr. Murray asked that attendees share handouts. He said that the complete document was 

available on the NIOSH website for anyone who had not received a copy, and that the large 

crowd was unexpected but welcome. He asked that questions and comments be held until the 

end of the presentation considering the size of the meeting. 

Mr. Murray said that the main reason for the meeting was to discuss the Site Profile for Paducah, 

developed under the EEOICPA. He explained that all EEOICPA claims are sent to the DOL, 

and that NIOSH and ORAU only handle claims under Subtitle B for radiation-induced cancer. 
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Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 3 of 12 10/27/05 

The law was revised in 2004, shifting responsibility for Subtitle E from the Department of 

Energy (DOE) to DOL and making it a federal rather than a state compensation program. 

Claims filed under Subtitle B are forwarded from DOL to NIOSH for dose reconstruction. Due 

to the volume of claims to be processed, NIOSH contracted the work to ORAU, who in turn 

brought several subcontractors on board to help with the effort. 

The Site Profile is used as a handbook for dose reconstructors, providing consistent technical 

information for a specific site. This minimizes the need to interpret data, thus assuring that all 

claims are treated the same. New information is always considered and is used to revise Site 

Profiles in an effort to have the most reliable resource possible. For example, outreach meetings 

with labor representatives have resulted in revisions to the Hanford, Y-12, and Savannah River 

Site Profiles. 

Mr. Murray described the five separate sections: the Site Description, which includes the work 

that was done, the activities and processes, and the possible contaminants present; the External 

and Internal Dose sections, which generally apply to workers who were monitored in dosimetry 

programs; the Environmental section, which is used mostly in estimating radiation doses for 

people who were not assigned dosimeters; and the Medical X ray section to assign doses from 

employer-required x rays. The external and internal doses are based on DOE records, but 

NIOSH and ORAU give additional dose with the environmental and medical in order to help 

claimants get a 51% probability of causation. The dose reconstruction result is sent back to 

DOL, which makes the final determination on whether the claim is awarded or denied. The Site 

Profile Team was established in 2003, and the document has been comprehensively reviewed by 

NIOSH. 

Mr. Murray said that the Site Description provides an overview of the radiation sources and 

materials that are known to have been present in the plant. The plant began operations in 1952 

and activities reported include enriching uranium as well as handling radioactive waste. There 

were known radionuclides, most prominently uranium, but technetium, neptunium, and 

plutonium were also identified. 

The External Dosimetry section discusses the external dosimetry program, including sources of 

potential exposures, methods and practices used for monitoring, and the minimum detectable 

limits. Mr. Murray explained that the minimum detectable limits were considered in cases where 

the dosimeter readings were zeroes because the least amount of dose the badge would pick up 

(minimum detectable limit) was not reached. In such cases, a dose of half the minimum 

detectable would be assigned for each exchange period. Measurements were taken at Paducah 

for beta and photon exposures from 1952 to the present. Quantitative monitoring for neutron 

dose began in 1998. 

For the Internal Dosimetry section, the Team looks at the same elements of exposure, but the 

dose is based on what is inhaled or ingested into the body, rather than absorbed from external 

sources. Whole body and lung counting are considered, as are the urinalysis results. The 

bioassay program started in Paducah in 1952. Measurements of gamma-emitting radionuclides 

using lung counters began in 1958, and whole body counting began in 1960. 
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Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 4 of 12 10/27/05 

Mr. Murray explained that the Environmental Dose is used mostly for workers who were not 

monitored with dosimeters and bioassay. Site-wide monitoring for air concentrations is used as a 

basis to determine internal environmental doses, and materials in storage and waste pits are 

considered for external environmental doses. The external dose was measured using dosimeters 

placed around the site. Most workers had badges, but they were not issued consistently. 

The Medical dose for employer-required x rays is included in the dose reconstruction and takes 

into account the frequency and the type of equipment used. X ray machines changed over time. 

The older ones gave higher radiation doses. 

Mr. Murray emphasized the importance of making the Site Profile an accurate document. He 

said that the Site Profile can change when new input is received. Mr. Murray explained how to 

provide input on the Site Profile to NIOSH/OCAS. He also explained Paducah’s status as a 

Special Exposure Cohort (SEC) site, and said that doses did not have to be reconstructed for the 

cancers covered under the SEC. Mr. Murray then opened the floor to comments and questions. 

Discussion Session – Q/A 

Question: 

What is the reference for the percentages of feed materials used in the Site Description? It 

would be helpful if the number of pounds was included. 

Jay Maisler: 

The references are in the back of each section. Either poundage or percentage would work 

for the purpose of dose reconstruction. The Site Description is only used to provide 

background information; the Internal and External Dose sections go into greater detail on the 

feed materials. 

Comment: 

The Site Description is not in agreement with the Internal Dose Section in this regard. 

Jay Maisler: 

The Site Profile Team is still in the process of revising the document in order to fix any 

mistakes that might have been missed before. 

Question: 

The same section of the Site Description mentions “High Radiation Areas.” How is that 

defined? 

Jay Maisler: 

That is in accordance with Atomic Energy Commission (AEC)/DOE regulations that set the 

limits. The glossary in the back specifies that a High Radiation Area is an area in which the 

dose rate could exceed 100 millirems per hour within 30 centimeters from the source. 

Question: 

Is there data on workers who were exposed in that High Radiation Area? 
NIOSH Dose Reconstruction 

Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 5 of 12 10/27/05 

William Murray: 

Anyone who went into the area was supposed to have a dosimeter according to Atomic 

Energy Commission (AEC) regulations. However, NIOSH and ORAU can’t know for 

certain that people followed regulations. 

Jay Maisler: 

In a discussion about Missed Doses in Section 6.5, data from PACE is included regarding 

average and maximum doses that were given. 

Comment: 

The areas were not categorized in the late 1940s to early 1950s, and there was no 

requirement for dosimeters. That should be reflected in the Site Profile. 

William Murray: 

Claimants are called for extensive telephone interviews as part of the dose reconstruction 

process. During the interview, the claimant has the opportunity to discuss their personal 

work history including what parts of the plant they were assigned to, whether or not they 

were badged, and other specific issues pertinent to their claim. All that information will be 

considered in the dose reconstruction. 

Comment: 

Despite having been diagnosed with a non-functional thyroid in addition to skin cancer, my 

claim was denied on the basis of not having received a high enough dose. This is a travesty 

and contrary to the principles of this country. The definition of human rights violation is to 

knowingly cause death or harm to citizens. In this sense, the U.S. Government is guilty of 

violating the human rights of the workers in the plants. Dose reconstruction should not be 

necessary – the workers were not made aware of the dangers and the Government owes them 

compensation for that alone. 

Leon Owens: 

One goal of this meeting is to help the Team enhance the Site Profile for more accurate dose 

reconstruction. Your input is appreciated. 

Question: 

The source expert for the Paducah Site Profile had performed some contract work at the site. 

A conflict of interest exists in using this person’s work in the document. 

Peter Darnell: 

NIOSH is aware that the person mentioned did contract work in the past, but it is not 

confirmed that she authored the report. The documentation was thoroughly reviewed to 

ensure its appropriateness for inclusion. 

Comment: 

Table 6-1 was taken from a previous report. What was the source for the information 

presented? 
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On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 6 of 12 10/27/05 

Jay Maisler: 

References for the table are provided at the end of the section. Mr. Darnell has the specific 

documentation used, although it may not be public information. Mr. Richard Miller was also 

provided with this information. 

Question: 

Why was the general value at the Cascade Building zero, but other buildings that were also 

cascades show a value? 

Peter Darnell: 

That would be something NIOSH and ORAU would have to look into in more detail. 

Question: 

How can I get my claim forwarded from DOL if they haven’t sent it for dose reconstruction 

yet? 

Peter Darnell: 

NIOSH has no knowledge of any claims until DOL verifies employment. 

Question: 

Dose reconstructions were completed before the Site Profile was approved. How can the 

dose reconstructions be accurate if the Site Profile was not complete? 

Peter Darnell: 

Under Title 42, an efficiency process is used to expedite claims. If a partial dose 

reconstruction shows a high likelihood that the probability of causation will be 51% or 

higher, it can be completed. Conversely, if there seems to be very little possibility of 

reaching 51%, the claim can be denied. The assumptions are based on the upper bound 

maximum credible dose coming out to less than 50% in accordance with general physics 

knowledge of radioactive material. Documentation is not connected to any specific site, so 

the maximum credible dose does not have to come from the Paducah Site Profile. 

Question: 

Cesium pellets were found in the plant parking lot, but it was not noted in the Site Profile. 

This was documented in the mid 1990s. 

Peter Darnell: 

NIOSH and ORAU did not have this information but it will be considered in revisions of the 

Site Profile. 

Comment: 

Employees were specifically instructed to remove their badges when handling hot materials. 

Peter Darnell: 

This is something heard very often at Site Profile meetings. Individual dose reconstructions 

take this practice into account when the claimant mentions it in the phone interview. 

Comment: 

The use of the Site Profile is redundant and does not help claimants in any way. The Site 

Profile only represents incorrect, inaccurate, and incomplete information provided by DOE. 
NIOSH Dose Reconstruction 

Project Meeting 

On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 7 of 12 10/27/05 

Peter Darnell: 

NIOSH and ORAU use information from all sources available, not only DOE records. Site 

Profile meetings are held with the intent of both informing workers about the process and 

gathering information that may otherwise not be found. 

Comment: 

PACE and the University of Utah did a research study indicating that electronic records from 

the plant were filed containing errors. The Site Profile does not show any verification of the 

records, particularly of the external dosimetry. Did NIOSH look at any paper records to 

verify the accuracy of these electronic records? 

Peter Darnell: 

NIOSH goes to the site to pull the paper records, performs data capture, and then forwards 

them to DOL. Electronic files are only part of the data NIOSH uses as a source. 

Question: 

According to a memo prepared at Paducah in July of 2000 regarding the quality of radiation 

dosimetry records, there were 765 records that had inaccurate dates of intake of 1919 that 

actually were from the summer of 1999, and all of the internal doses that were calculated 

from those records were in error. They also found 53,597 records that had inaccurate sample 

numbers due to data migration problems. If you wanted to go back to paper files of these 

records, it would be difficult to match them up. How are problems with the database 

reconciled? Also, recently declassified documents show that exposures in the C-410 

Building in 1972 were 9-1/2 rads per hour for beta-gamma. In fact, in the C-410 building 

they have found beta-gamma levels as high as 230 rads per hour. Have you encountered 

upper bound estimates of 230 rads for workers, and if not, how do we know NIOSH and 

ORAU are not underestimating the maximum potential dose? 

Peter Darnell: 

I don’t have the Site Profile memorized, so I don’t know precisely what information was 

used to determine the doses. The current process uses available dosimetry records... (Mr. 

Darnell was interrupted by the following comment) 

Comment: 

If you’re relying on personnel records kept by the plant, there is a major lack of credibility. 

No one here believes that any reliable record-keeping has been done here at Paducah. 

Peter Darnell: 

This is a common problem we encounter when reconstructing doses for a Site Profile. Many 

workers were not monitored properly. Initially, NIOSH must rely on official dose records 

until other information is available. Please submit these comments in writing directly to 

NIOSH. 

Comment: 

Between 1957 and 1992, the workers were not monitored for transuranics because they were 

worried about the union’s demands for hazardous duty pay, as well as adverse publicity. The 

workers at Paducah were central to getting the EEOICPA passed so they are intimately 

familiar with the issues involved. But the scandals here at Paducah have caused us to be very 
NIOSH Dose Reconstruction 

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On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 8 of 12 10/27/05 

skeptical about the lack of credibility of the data that has been compiled to calculate the dose 

reconstructions for the Site Profile. 

Peter Darnell: 

These are very emotional issues – everyone here is aware of the Paducah scandal. That is the 

basic reason Paducah qualified for the Special Exposure Cohort. NIOSH and ORAU are 

trying to do the best we can with the data we have. The Site Profile exists as it is because of 

the Executive Order directing NIOSH to go forward with the existing information. 

Question: 

Another memo said that film badges were dumped in the landfill. What does NIOSH do to 

make up for that lost information? 

Peter Darnell: 

Please be sure to submit information of this nature to NIOSH in writing. The information 

you provide regarding the actual doses you received will be instrumental in changing the Site 

Profile to the workers’ advantage. 

Question: 

Workers were exposed to neptunium at a rate of 356 rems to bone per year in Building C400. There was a 90% concentration of neptunium in the air. The draft Site Profile only 

assumes a fraction of that concentration – a mere 20%. Missed doses do not come anywhere 

near the reality of what people were exposed to. Why is this? 

Jay Maisler: 

The Team will review all information provided to correct the document. It is possible that 

during the broad technical review something could have been missed or overlooked. The Site 

Profile is always subject to revision. 

Question: 

Some of the data used in the Site Profile was taken from an earlier report that was written by 

a member of the Site Profile Team. It is not likely a person would contradict their earlier 

work, whether it was correct or not. A conflict of interest is created by this situation. 

Peter Darnell: 

Conflict of interest depends on which dose reconstruction a person works on. If the person 

doing the dose reconstruction is not gathering data for the Site Profile, there is no conflict of 

interest to calculate dose for a worker at that site. There is only a pool of about 150 health 

physicists who work on the Site Profiles and dose reconstructions. 

William Murray: 

Based on concerns such as this, the conflict of interest policy was extended to include people 

who write the Site Profiles. The issue did not come up when the work first started on the 

Paducah Site Profile. There were already 15 Site Profiles underway when NIOSH and ORAU 

started looking at this concern. 

Comment: 

Legal distinctions don’t help claimants. People don’t want the same person who authored 

documentation used in the Site Profile doing their dose reconstructions. 
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Jay Maisler: 

To clarify this issue, the person in question does not work on dose reconstructions. 

Question: 

The PACE/University of Utah report should be used but is not included in reference to levels 

of exposure. The report ranks potential exposures, but notes that this information should not 

be used for individual needs, such as dose reconstruction. With that in mind, should 

summary data be appropriate for dose reconstruction? 

Peter Darnell: 

The section with that reference is only giving an overview, but Section 6 gives more specific 

and detailed information. Individual dose reconstructions are calculated based on specific 

information from the site. 

Question: 

Can information be used in the Site Profile without validation? 

Peter Darnell: 

The Site Profile was only recently published, and the information is still subject to revision if 

an error is found. Comments need to be submitted in writing to NIOSH to point out any 

potential inaccuracies or additional information that would add validity to the document. 

Alternate methods of dose reconstructions, such as the use of nuclide concentration, can be 

used to develop upper bounds. If a claim is given a high dose based on the type of site, a dose 

reconstruction could be accurately completed. 

Question: 

The presentation Mr. Murray gave indicated that occupational environmental dose is given 

for unbadged workers. However, the Site Profile does not address the issue of hot equipment 

coming in from other sites like Oak Ridge. Anything that is mentioned only goes back to 

1952; materials were brought in earlier – at least 1951, but there’s no way to even speculate 

on it without it being brought up in the Site Profile. 

Jay Maisler: 

These concerns have recently been brought up to the Site Profile Team, who are now 

gathering information to update the Site Profile. 

Question: 

Will you confirm or deny the allegation that contaminated equipment was brought to the site? 

Peter Darnell: 

That is something NIOSH does not know about, so any comment would be ill-advised. 

Comment: 

Why did NIOSH wait so long to make an attempt to get worker input? If it had been done 

earlier, there is a good possibility that more people would have received compensation before 

they died. I personally did not know about my exposure history when I was diagnosed with 

cancer in 1998. The DOE document is misleading, especially in regard to the urinalysis 

program. The samples were usually taken after long weekends in the 1970s, so they would 

be less indicative of the true dose received. Likewise, Chemical Operations scrubbed the 
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On Paducah Gaseous Diffusion Plant Site Profile 

Final Minutes 10 of 12 10/27/05 

walls down before installing monitors – the real dose will never be known. Are chemical 

reactions considered with the radiation dose? 

Peter Darnell: 

Standard procedure includes back-calculating the urinalysis with the understanding that the 

kind of thing you described was common. The clearance time from intake is also considered; 

the health physicist can take the measurements recorded and back-calculate based on 

clearance time for a more accurate dose. 

NIOSH will respond to your other questions after an evaluation of your claim. 

Comment: 

The cancer program that was set up in the community was a great help; thank you for your 

involvement in that. My phone interview was not as helpful in getting my claim approved 

though. There were too many instances and experiences that could have contributed to my 

dose to remember them all. The best way to handle that would be to hold a meeting with 

workers and NIOSH representatives where everyone could be deposed. 

Radiation badges that were intended to measure dose in ten minute intervals were used for 

full shifts. Records have been destroyed. The Federal government knows all about it but will 

never let that information come out. 

Question: 

Have the authors of the various sections of the Site Profile compared urinalysis samples to air 

samples for a more accurate overall assessment of the level of contamination? 

Jay Maisler: 

Data had to be made available in order for NIOSH and ORAU to conduct such a comparison. 

The plant may or may not have also looked at this. 

Comment: 

Workers were instructed not to wear the film badges so they wouldn’t be ruined by the overexposure. 

Peter Darnell: 

Not much was known about radiation at the time the operations began. Historically, the 

government did not know the kind of damage that could be caused by exposure. Protection 

practices that were implemented in the early 1950s were considered sufficient at the time. It 

was generally believed that radiation was not particularly damaging. Science just didn’t 

know any better during the infancy of the program. 

The DOE probably did not tell everything they learned, and NIOSH is working to find all 

documentation that will help with the Site Profile. 

Comment: 

Records simply do not exist – the DOE and contractors either did not keep records or they 

destroyed what they had when they realized the potential danger to the workers. Secretary of 

Energy Bill Richardson spoke in Paducah and openly admitted that the DOE knowingly put 

workers in harm’s way. 
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Question: 

When questions are submitted to NIOSH, what is the turn-around time? When will the Site 

Profile Team make revisions? 

Peter Darnell: 

There is no definite timeframe. It depends on the amount of time needed to research the 

question and the time it takes the Program Officers to prepare a proper response. 

William Murray: 

In the past, the Outreach Team has taken comments back to NIOSH regarding the concerns 

expressed in these meetings. The questions and concerns are addressed and the Team sends 

information back. We can do a return trip for discussion of the revisions to the Site Profile, 

but I don’t know the timeframe. 

Comment: 

Worker advocates’ biggest concern is the dose reconstructors’ dependence on the Site Profile 

for non-SEC cancers. 

Peter Darnell: 

The formal process that NIOSH follows includes review of claims that may be affected 

positively by new information that is added to the Site Profile. There is a Program Evaluation 

Report completed for all revisions. NIOSH will look at denied claims against the new 

criteria. All health physicists get the reports even if there is not necessarily enough difference 

to do a new dose reconstruction. 

The Site Profile Team leaders can take information from today’s meeting back for immediate 

re-evaluation. There has already been useful information brought to our attention today that 

will be a topic for discussion. 

Comment: 

There is always an emphasis about the Site Profile being a living document at the Outreach 

meetings. If the Paducah Site Profile is revised based on information gathered from workers, 

will all the claims be reviewed to consider the possible benefit? 

William Murray: 

Yes, especially if the claim was close to 50%. The nature of the information will provide a 

better idea about how much it will impact claims. 

Comment: 

There have been comments and information submitted to NIOSH regarding inconsistencies 

and inaccuracies in the Site Profile already. So far there is no evidence that the information 

has been incorporated into the documents, so people are quite skeptical in general. 

Question: 

According to Section 2.3, there were two cascade upgrades – one between 1958 and 1962, 

the other between 1973 and 1981. This would cause a higher potential for exposure. Has 

NIOSH defined these exposures? 
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Jay Maisler: 

Assumptions were made in the first draft of the Site Profile based on the information that was 

available at the time. Your comments will be addressed and considered when revisions are 

discussed. 

Question: 

The values used on table 5.4 were the default maximum values – were previous 

concentrations considered? 

Jay Maisler: 

That is something that would need to be looked into specifically. 

Question: 

Was any other data considered in establishing the maximum values? 

Jay Maisler: 

Information such as that included in general incident reports was included. PACE also 

developed a great report, but it would have to be confirmed specifically that the information 

was included. The Site Profile Team will follow up on this. 

Comment: 

The information for the gap in Section 6.1 can be taken from data in the PACE/University of 

Utah report. 

Peter Darnell: 

Please submit that to NIOSH in writing. A formal follow-up process will ensure that the 

information is considered and that we can answer appropriately 

Comment (Moderator): 

DOL will be holding public meetings on March 29 and 30. They will be able to discuss 

changes in the program regarding Subtitle E, and will also be able to answer questions 

specific to individual claims. 

Mr. Murray asked if anyone else had any questions or comments. He thanked everyone for their 

participation. He stated that the information was appreciated and that any additional comments 

should be sent directly to NIOSH in writing. The meeting was adjourned at approximately 12:45 

p.m.