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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Carborundum Work Group

Thursday, June 13, 2019 

The Work Group convened via teleconference at 

10:30 a.m., Eastern Daylight Time, Genevieve 

Roessler, Chair, presiding. 
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2 

Members Present: 

Genevieve S. Roessler, Chair

Bradley P. Clawson, Member

R. William Field, Member

Also Present: 

Ted Katz, Designated Federal Official

Robert Anigstein, SC&A

Robert Barton, SC&A

Joe Guido, ORAU

Stuart Hinnefeld, NIOSH

Michael Rafky, HHS

John Stiver, SC&A

Tim Taulbee, NIOSH

Tom Tomes, NIOSH
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3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Carborundum Work 

Group Thursday, June 13, 2019 1

Welcome and Roll Call 4

DCAS White Paper: NIOSH Response to 

Findings on the MCNP Analysis for 

Carborundum 5

NIOSH Finding 1 5

SC&A Response 10

NIOSH Finding 2 18

SC&A Response 18

NIOSH Finding 3 19

SC&A Response 19

Plans/Follow-up 20

Adjourn 20
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Proceedings

(10:31 a.m.)

Welcome and Roll Call

Mr. Katz: Welcome, everyone. This is the Advisory 

Board on Radiation and Worker Health. It's the 

Carborundum Work Group.

And the agenda for today's meeting is posted on the 

NIOSH website under meetings. So if you go to 

meetings, this date and you'll find both -- well the 

agenda and the two documents that are relevant to 

the discussions today which are quite technical.

Anyway, and also just a general note everyone 

please keep your phones muted except for when 

you have to address the group. And if you don't 

have a mute button, press *6 to mute your phone,

*6 to come off of mute. But please keep it muted. 

That would be good for everyone.

Okay, then let's start with roll call. So I know I 

have Gen. Let me speak to conflict of interest too 

because this is a specific site this Work Group deals 

with.

So the Board Members on this Work Group do not 

have a conflict so I address that up front. But for 

agency and contractors and so on please speak to 

conflict as well when you report in on roll call. 

(Roll call.)

Mr. Katz: Okay, then. Then with that I just want to 

remind everyone keep your phones on mute, and, 

Gen, it's your meeting.
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DCAS White Paper: NIOSH Response to Findings on 

the MCNP Analysis for Carborundum

Chair Roessler: Okay. I hope everyone has had 

their coffee and are ready to go. I want to do just a 

brief recap. Our Work Group last met on December 

4, 2018, and after that meeting we reported our 

status at the Board meeting on December 12.

At that time we reminded the Board that the 

Carborundum SEC Petition 223 was denied at the 

March 22, 2017 meeting and that all of our Site 

Profile issues were resolved except for three. And 

these three dealt with the MCNP modeled 

calculations of external dose from fuel pellets.

The full Board then voted to accept the Site Profile 

review and our proposed resolutions and tasked us, 

the Work Group, to work through the three open 

issues. And that's what we're going to do today. 

And as we'll find out there will be two that I think 

are going to be relatively easy and one that will 

need some discussion.

So we'll follow the agenda and have NIOSH first 

respond to their three findings based on their 

January 18, 2019 White Paper. And then we'll have 

SC&A follow with their paper which was published 

on April 24, 2019.

So we will start with NIOSH, and my understanding 

is that Dr. Taulbee is going to present.

NIOSH Finding 1

Dr. Taulbee: Thank you, Dr. Roessler. I'm just 

going to present our position on the Finding 1, our 

response to Finding 1, and then Tom Tomes will 

take over for Findings 2 and 3 here.

Just a little bit of a recap. What we're talking about 

here is the difference in the air kerma to fluence 
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dose conversion coefficients that are in ICRP 74.

There's two tables of these that are in ICRP 74, 

Table A.1 and then column 2 of -- or I'm sorry, 

column 4 of Table A.21. They both list kerma to 

fluence dose conversion coefficients.

So what we're talking about here is that there's a 

difference between those two tables purportedly 

using difference in data from Hubbell 1982 and then 

Hubbell and Seltzer 1995, or just what we refer to 

in our report as Hubbell 1995 for simplicity here.

And so one of the reasons that we are disagreeing 

with SC&A on the use of the column 4 values in 

Table A.21 is the consistency with our 

implementation guide.

And that is the whole ICRP 74 was used when we 

developed all of our dose conversion coefficients, 

and those were all developed before this latter data 

of Hubbell 1995 came about.

And if you go through the text of ICRP 74 you can 

see in the development of all those organ dose 

conversion factors that that's where that -- that 

they were all generated before this time period. 

They were all using that Table A.1.

ICRP itself on I believe it's page 36 indicates that if 

-- for the conversion coefficients for effective dose 

and operational quantities that -- for photons may 

be presented in a manner to be consistent with 

those of neutrons in terms of particle fluence and to 

provide a complete database for the possible -- as 

possible for a variety of calculational purposes the 

data can be transformed into conversion coefficients 

using photon fluence using the information in Table 

A.1.

And so this is why we use Table A.1 in conjunction 
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with column 2 of A.21 to develop our ambient dose 

equivalent per fluence. So it was more from a 

consistency standpoint. 

One other point that I should mention that we didn't 

put here into the paper is that this is the method 

that we've used in other Site Profiles such as 

Blockson and GSI.

The second reason that we disagree with SC&A as 

far as using that, I believe it's column 5 of ICRP 74 

-- or Table A.21 of ICRP 74 is that the variability in 

these values is really small. And Bob -- or SC&A 

even mentions that in their write-up.

ICRP whenever they were doing their comparisons 

in the generation of ICRP 74 even indicates the

excellent agreement between the older values and 

the newer, that they were all less than -- I believe 

they were quoting 3 percent there.

So when you put this in context of what we're doing 

with the dose conversion factors which is our 

discussion here in point number 2 is these dose 

conversion factors that we use have a very wide 

range of uncertainty associated with them such that 

this 2 percent is really -- we use the word trivial. 

It's just not as significant. So from that standpoint 

we feel that this particular issue is really not critical.

But the final reason is really the main crux of why 

we are disagreeing with SC&A in this particular 

case. And that is there's an implication here that 

the older values are outdated. And we're not sure 

that they are outdated. There's a draft report out 

by a joint commission of the International 

Commission on Radiation Units and Measurements, 

ICRU, and the ICRP. 

And we've got a copy of that. And the title of it is 

Operational Quantities for External Radiation 
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Exposure. And if you compare the dose coefficients 

for air kerma within that particular report you will 

see that those values, and this is our Table 1 in our 

response by the way, and I hope you have that in 

front of you.

Actually for those that don't I'm wondering if I can 

present it here. Hold on. Give me just a second 

here. See if I can share it. No, okay. Sorry. 

There's a new app here. Okay. Hopefully 

everybody has Table 1 there.

And what you'll see is that the values from 10 KeV 

up to about 60 KeV, that they vary between Hubbell 

'82 and Hubbell 1995, but the draft ICRU/ICRP are 

following very closely, within rounding error really, 

of Hubbell 1982.

So this is one of the major concerns that we have is 

if we were to make this change when the ICRP/ICRU 

document comes out and if these are the values 

that come out then we would be changing back. 

And so we've got a consistency issue with previous 

Site Profiles as well as intelligence telling us that 

these values are going -- that the draft values we 

published here are what's going to be coming out.

And so from a resource standpoint to make the 

change and then next year or later this fall when 

the ICRU/ICRP document comes out we would be 

changing back, or having to update other 

documents.

So that's why we are currently sticking with our 

current calculations, our current methodology. Are 

there any questions?

Chair Roessler: Does the Work Group have any 

questions? Well, I have some comments later, but I 

think if there are no questions or other comments 
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should we move on then to the other findings? 

Mr. Katz: Gen, it's Ted. I'm just wondering given 

that you just had this nice summary from Tim I 

wonder if this isn't -- if it wouldn't be easier for all 

of you actually to follow the argument if you hear 

from Bob now on this matter and then you can 

move on to the other two which are easier to 

resolve.

It's up to you. Other Work Groups generally try to 

go one by one on these.

Chair Roessler: That sounds like a good flow to me 

if Bob is ready. And I'm sure after he presents 

there will be more questions and perhaps 

comments. 

Mr. Katz: Yeah.

Chair Roessler: So, Bob, are you ready to present?

Mr. Katz: Bob, is that okay?

Dr. Anigstein: Yes, well, I have a -- yeah, I have a 

presentation. Skype seems to have changed. I 

hope I can get it to work.

I think maybe I'm just going to talk because this is -

-

Chair Roessler: It looks like something is coming 

up.

Dr. Anigstein: And it's going to take me -- give me 

one more moment.

Mr. Katz: While you're struggling with this, let me 

just check and see --

Dr. Anigstein: I think I've got it.

Mr. Katz: Let me just check and see. Do the other 
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Board Members have -- are you on Skype? I know 

Gen is. I don't know about Brad and Bill.

Member Clawson: Ted, I'm not on Skype. I can't 

get it.

Mr. Katz: Okay. What about you, Bill?

Dr. Anigstein: Okay. I think I'm just going to read 

my presentation.

Mr. Katz: Yes, that makes sense.

Dr. Anigstein: Yeah, because -- 

Mr. Katz: That's fine, Bob.

Dr. Anigstein: Is there anything on the screen? I 

have something on the screen now. Does anyone 

see my presentation?

Mr. Katz: Yes, your report is on the screen but Brad 

doesn't have it anyway, so -- and I don't know 

about Bill.

SC&A Response

Dr. Anigstein: Okay. What I heard from Tim 

Taulbee is that really what we're talking about is 

policy issues. And that's not really SC&A's province 

to address NIOSH policy issues.

Basically I'm not completely won over by his 

argument. I'm not going to say it doesn't have any 

merit, but it does have some.

First of all, we have one observation which is that 

the calculation of -- let me stick with my -- reading 

my presentation.

We believe that since ICRP has presented in its 

Table A.21 column 5 they've already presented the 

-- there's no need to calculate the air kerma 
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multiplied by the -- there's one factor which is the 

H*10 divided by air kerma. That's in the second 

column of the Table A.21.

And then there is the ratio of the H*10 to air fluence 

already done through the photon fluence. So that

has already been done by ICRP. 

Now ICRP apparently used in this table, according to 

the footnote, they used the latest, the latest being 

the 1995 which are still currently used. This is 

Hubbell and Seltzer 1995 which is the NIST, 

National Institute of Science and Technology. These 

are the latest physics.

The physics has changed significantly between -- I 

mean somewhat from 1982 mostly because much 

better instruments were developed during the 

period of time.

And since NIOSH claims and DCAS claims that using 

these new numbers will be inconsistent with the 

Tables A.2 through A.20, but apparently ICRP does 

not think it's inconsistent because they have in the 

same calculation they multiply it out.

They don't display the numbers that NIOSH is using. 

Meaning the old air kerma from Table A.1 multiplied 

by the H*10 to air kerma dose conversion factor. 

They have not done that.

They have instead given a new set of values. And if 

this is what ICRP has presented I think it should be 

used. That's basically the argument. 

And there is an observation also that there was an 

error in the calculation in the MCNP files that we 

saw and were used, and there were two places. 

One for the 0.01 MeV, in other words 10 KeV, where 

according to the DCAS methodology the factor 

should be 0.059 and the one in the MCNP file is 
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0.011. So that's a fivefold reduction.

And there is a small error also in the 1 MeV which is 

instead of the calculated value 5.23 they have put 

one of 5.16. So these are apparently errors of data 

entry into the MCNP input file. Those will be 

corrected in any case.

The argument that the -- since the data in the 

OCAS-IG-001 uses already the number from Table 

A.21. And a footnote in Table A.21 says, and this I 

take it refers to all the values there, the footnote

says data compiled from ICRU Report 47 using 

Hubbell and Seltzer 1995.

So in fact the numbers, the H*10 divided by air 

kerma ratios which DCAS does use already used the 

newer data. So at least that's the way I'm 

interpreting it.

So consequently it would be inconsistent to do the 

opposite, to use the older values. And furthermore 

the MCNP analysis itself which is, well, previously 

they used the version 6.1 which has an error in it. 

They're going to repeat it using MCNP version 6.2.

Well, this was released about two years ago, and it 

certainly contained all the latest physics data. I 

mean, that's what Los Alamos does. It maintains 

the MCNP program, and it maintains the data file, 

and it stays current with the current physics. So to 

use 1982 data in conjunction with the 2017 MCNP 

calculations to my mind that would be inconsistent. 

And then finally as far as the new ICRU/ICRP, well, I 

and SC&A were not privy to intelligence that this 

report would be finalized.

So far it's two years old. The draft came out two 

years ago. ICRU has subsequently had later reports 

on different topics so they are continuing to publish 
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reports.

This report has never been finalized. There were 40 

comments during the comment period, and I looked 

at some of the ones from some of the major 

agencies like the Japanese Atomic Energy Agency. I 

think their name has changed.

And they had substantive -- nobody commented on 

this particular table, but then I did not read all 40 

comments. That would have been beyond the 

scope of our assignment. 

But nevertheless they had some substantive issues. 

Not just -- it wasn't simply they put this out pro 

forma and said okay, anybody comment, no 

comment, it was accepted.

There were comments on a number of issues within 

that report. So this report is not final. As a matter 

of fact it says on every page do not quote, not to be 

referenced or something like that.

So therefore that data should not be used. I think 

that it's not -- personal opinion is it's not so much a 

difference in the physics.

Air kerma is an approximation, and there are subtle 

differences in the way it's calculated. It's the 

energy deposited but then energy escapes, 

electrons escape. There is bremsstrahlung that 

escapes.

If you get into higher energy there is a pair 

production that allows energy to escape. And there 

are different ways of handling it. And I believe 

that's the difference between what the ICRP/ICRU 

draft report did, not so much that they used newer 

physics which of course they did use, but because 

there were some different assumptions.

And the thing is I think that it's questionable which 
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set to use. And I believe that given there is 

uncertainty we should go with the value that 

produced the higher doses. It seems to be -- that's 

sort of our position.

So that's about -- I think that summarizes what I 

have to say.

Chair Roessler: Okay. So does NIOSH want to 

respond to Bob's -- everything he has presented?

Dr. Taulbee: Yes, this is Tim Taulbee. I do have 

one small comment and that is the footnote in Table 

A.21 that Bob is referencing saying the data is 

compiled from ICRU Report 47 which is 1992.

He assumes that all of the data in that table is 

coming from that ICRU 47 as well as using Hubbell 

and Seltzer which is 1995.

And if you go to ICRU 47 and you look at the 

ambient dose per Ka values you will see that those 

values are -- well, except for 10 and 15 KeV follow 

along with ICRU 47 which is in 1992 which is three 

years before the 1995 data.

So it's not all using that newer 1995 data, that 

Table A.21. It's a combination. 

The difference is that Hubbell and Seltzer 1995 is 

the Ka for phi values. Ka for fluence values in that 

column 4.

And what ICRP did in Table 21 if you go through the 

math is take column 2, multiply by column 4 to get 

their column 5. 

So the update is that kerma per fluence values that 

they have produced there in Table A.21. At least 

that's my interpretation of these.

Dr. Anigstein: No, I checked those numbers. It is 
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in fact -- you're entirely correct. Column 5 is a 

product of column 2 and column 4.

Dr. Taulbee: What I'm saying is that column 2 

values are coming from the 1992 ICRU 47.

Chair Roessler: I heard a comment in the 

background. I think someone wanted to comment. 

Mr. Hinnefeld: Yes, Gen. Gen, this is Stu 

Hinnefeld. Can you hear me?

Chair Roessler: Sure.

Mr. Hinnefeld: Okay. I just wanted to comment 

along the lines of what Bob started his presentation 

with is that there's a policy decision here about the 

timing of finalizing this answer.

And our discussions with people involved with the 

ICRP publication that's in draft form is that they are 

likely months away from publishing it. Even though 

with two years I guess, it would have two years to 

resolve the comments or whatever, deal with the 

comments. But we're just some months away from 

publishing it.

And so our view that whether it's a few months, 

whether it's this fall or whether it's next spring or 

whatever it turns out to be, it's really a policy 

decision to decide let's wait for this update which 

seems to be at least on the not far horizon and 

make our decision based on those numbers that are 

in that update and sort of eliminate the debate that 

we're trying to have today.

So to me this is in fact a policy decision. I think the 

program's resources are better spent by waiting for

that rather than to change no matter which choice 

we make now, any change we made now we'd have 

to reconsider that anyway.
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So to me it's a policy decision, and it should wait for 

the publication of the ICRP document. And in the 

meantime the doses are so close that it's not as if 

it's a huge difference that we're talking about 

anyway.

Chair Roessler: Okay, thank you, Stu. I would like 

to follow on with what you've said. It seems for us 

the Work Group our decision really is should 

changes be made related to Finding 1 as proposed 

by SC&A at this time.

And Bob brings up some scientific reasons for doing 

that. But to me it seems that since this is policy, 

when in doubt we don't. We don't make a change 

unless you really have some good evidence to make 

it.

And especially in view of the anticipated new report 

and especially since it should be coming out. It 

seems like our Work Group, it would be prudent for 

us to not make a change at this time, but to wait. 

That's my view.

Member Field: Yes, this is Bill. I agree completely 

with you. I understand the arguments on both 

sides. I think they were well stated.

But it just makes sense that if we go back and make 

the one change and then there's an updated table 

we'll be facing the possibility of making another 

change. If it's truly going to come out in a few 

months I would think that would be the course to go 

from my opinion.

Chair Roessler: Okay, any other comments?

Member Clawson: Yes, Gen, this is Brad. I feel the 

same. If it's going to be an actual two months, not 

two years, I would wait until that officially comes 

out and in a document we can actually use and that 
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is set up for that.

Chair Roessler: I do have a question though. In 

Bob's presentation, Bob, you mentioned some 

numerical errors. Those seem to be kind of a 

different situation, and I'm wondering if those are 

things that if NIOSH could respond to that and if 

that's something that because they're actual errors 

whether that should be looked at.

Mr. Katz. KATZ: Bob, do you want to address that? 

Bob or Rick?

Mr. Tomes: Yes, this is Tom. Dr. Roessler, we 

verified that there are a couple of entry errors, and 

we plan to correct those on our update runs we plan 

to do.

Chair Roessler: Okay. That's -- had to make sure 

we answered that. Does anybody else have -- it 

seems the Work Group is in agreement on the 

approach. 

If we take this approach, Ted, I'm wondering how 

do we handle it as a Work Group. Do we actually 

table this finding discussion or how would we 

approach that?

Mr. Katz: Yeah, thanks, Gen. I think that's fine. I 

think essentially not tabling this discussion, but 

we're just suspending the matter until the new 

report comes out.

And at that time I think then NIOSH can determine 

what it plans to do, its course, given whatever 

comes out there and report back to the Work Group 

and the Work Group then can address that.

If there is some sort of substantive change before 

section -- before the Work Group meets could --

would review that.
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A change in whatever -- however the approach is I 

think SC&A should probably review that. Then we 

can have another Work Group meeting, right. So in 

a way it's tabled, but it's a mixed matter because 

there will be a new report.

Chair Roessler: Okay. What I've heard, and I 

assume this is a vote. I presented that we don't do 

anything at this time. Bill and Brad have agreed, 

and I think that's a unanimous decision by the Work 

Group. So I think we're ready to close this 

particular, this discussion on Finding 1. Dr. 

Anigstein: Yes, I have nothing further to add.

NIOSH Finding 2

Chair Roessler: Okay. All right, then let's move on, 

and I think the other two findings are going to be 

discussed by Tom.

Mr. Tomes: Yes. Finding number 2, this was an 

SC&A finding on the -- report back in November. It 

says NIOSH used incorrect source biasing in the 

MCNP analyses.

This was a reference that Dr. Anigstein made 

previously about the glitch in version 6.1 of the 

code that we need -- get corrected in our revised 

estimates by using MCNP 6.2. 

And we believe our updated values for americium241 are in agreement with Dr. Anigstein's values.

SC&A Response

Dr. Anigstein: Yeah, we're in complete agreement 

with NIOSH's proposed solution for Finding 2.

Chair Roessler: So we can -- if Work Group 

members agree, I certainly agree. We can close 

Finding 2. So Brad and Bill?
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Group, has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally 

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

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19

Member Clawson: Yes, Gen, this is Brad. I'm good 

with that.

Member Field: That sounds good.

NIOSH Finding 3

Chair Roessler: Okay. Now I think we can move on 

to Finding 3.

Mr. Tomes: Finding 3 was an issue that Dr. 

Anigstein identified in his report back in November. 

And he had a Figure 1 in that report which showed a 

presentation of how the geometry was arranged in 

our MCNP model such that the dosimeter would 

have been partially shielded by the floor of the 

glovebox. And we discussed that at the previous 

Work Group meeting and agreed to correct that.

And Dr. Anigstein suggested a fix to that, and we 

have adopted that suggestion, and we reran the 

results. And as I indicated before our results with 

both Finding 2 and Finding 3, changes made are in 

agreement with the independent calculations Dr. 

Anigstein did.

SC&A Response

Dr. Anigstein: Yes, I reread the proposed solution 

for Finding 3 and again we're in complete 

agreement. 

Chair Roessler: Okay. I think that was a very 

interesting discussion, and I think we really 

appreciate Dr. Anigstein's comments and review of 

that.

So I vote in favor of closing Finding 3.

Member Clawson: Gen, this is Brad. I agree with 

that.
This transcript of the Advisory Board on Radiation and Worker Health, Carborundum Work 

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

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

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20

Member Field: This is Bill. I agree as well.

Chair Roessler: Okay. So it looks as though we've 

completed the agenda. Am I missing something, or 

is there other further questions or comments?

Plans/Follow-up

Mr. Katz: Gen, so I think that's good. If you would 

just -- we had promised the Board that we would 

just keep them abreast as we knock out these 

issues.

So if you wouldn't mind giving a very brief during 

the Work Group session report-outs of just where 

this stands, very brief update, then I think you can 

explain it in a minute or two. That would be plenty 

I think.

Chair Roessler: Okay. We'll work on that, and we'll 

plan on reporting at the Work Group meeting.

Mr. Katz: At the Board meeting in August.

Chair Roessler: I mean the Board meeting.

Adjourn

Mr. Katz: Yes, yes. And I actually just want to 

second -- thank you from both sides I think for a 

very thoughtful consideration of the matter. I think 

that's great. The discussion was great so much 

appreciated on both sides.

And I think we can adjourn. Bill, if you could just 

hang on the line a second, Bill Field.

Member Field: Will do.

Mr. Katz: Thanks. 

Chair Roessler: Thank you.
This transcript of the Advisory Board on Radiation and Worker Health, Carborundum Work 

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

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

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

21

Mr. Katz: Thank you, everybody, and have a good 

rest of your day.

(Whereupon, the above-entitled matter went off the

record at 11:09 a.m.)