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

Advisory Board on Radiation and Worker Health

TBD 6000 Work Group

Tuesday, February 4, 2020

The Work Group convened telephonically at 1:00 

p.m., Eastern Time, Paul L. Ziemer, Chair, presiding.
2 

Present: 

Paul L. Ziemer, Chair

Henry Anderson, Member

Josie Beach, Member

Also Present: 

Ted Katz, Designated Federal Official

Nancy Adams, NIOSH Contractor

Dave Allen, DCAS

Nancy Chalmers, DCAS

Eva DuPuis-Nouille, DCAS

Rose Gogliotti, SC&A

Cheryl Kirkwood, ORAU Team

Megan Lobaugh, NIOSH 

John Mauro, SC&A

Pat McCloskey, ORAU Team

Robert Morris, ORAU Team

John Palastro

Mutty Sharfi, ORAU Team

Hugh Stephens

John Stiver, SC&A

Tim Taulbee, DCAS
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health TBD 6000 Work Group 

Tuesday, February 4, 2020 1

Welcome and Introductions 4

Review of the NIOSH responses for the 

Superior Steel Co. Special Exposure Cohort 

(SEC-00247) Issues Matrix 6

Petitioner Comments/Questions 50

Path Forward 54

Adjourn 57
4

Proceedings

(1:01 p.m.)

Welcome and Introductions

Mr. Katz: Welcome, this is the Advisory Board on 

Radiation Worker Health, it's the TBD-600 Work 

Group, and today we are addressing just one item, 

Superior Steel SEC petition, 1952 to 1957. 

And it's a pretty simple agenda, it's posted on the 

NIOSH website. We have an opportunity a little later 

for petitioner comments and questions, which is 

optional by all means. 

So, we'll get around to that a little later but first, we 

have staff presentations, discussion, and Work Group 

interaction with the Staff on the status of issues, 

discussions, and resolution on how the work is going. 

So, there's what we call a finding matrix, issue 

resolution matrix that is, I believe, posted on the 

NIOSH website along with the agenda so that folks 

can follow along with what the issues are, and those 

are described very summary form there. 

The discussion should flesh that out so everybody can 

understand them. 

So, we're going to do roll call and let me just say this 

preliminary note about how this Work Group is going 

to go a little bit. 

I have some health issues that may require that I 

interrupt this call because I have to be present at all 

times while the Work Group is meeting, so at times I 

may have to just break the call for a bit and I will just 

tell everybody to sort of hold on and we'll just break 

the five or ten minutes and come back. 

I apologize for that, there's not much I can do. And 

as a matter of fact, there's a couple staff people who 

have their own health issues and so I've asked that 

we at least have a break every hour. 
5

I really don't have a sense for how long this Work 

Group meeting will go anyway, but should it go on for 

long we'll have a break every hour at the minimum, 

but we may need to break in a more ad hoc fashion 

as I may require it or as someone else may require 

it. 

So, just be aware, and I apologize particularly to the 

petitioners for this if this does occur, but there's 

nothing I can do about it. So, having said that, then, 

let me just do roll call. 

Since this is a specific site, speak to conflict of 

interest. Board Members by definition don't have a 

conflict with this site so that's covered. 

And we have two of the Board Members on the line 

already, my Chair, Dr. Paul Ziemer and one of the 

Members, Josie Beach. They're longstanding 

Members of this Work Group and we'll have a third 

Member, Dr. Henry Anderson, shortly I'm sure. 

(Roll Call.) 

All right then, we'll proceed. We have two of our Work 

Group Members and that's good enough, and 

hopefully they'll join us at some point. Last thing to 

note, since we have a number of people who are used 

to coming to Work Group meetings, please, 

everybody, mute your phones. 

The only time you should be off mute is when you're 

actually speaking to the group and to mute your 

phone, if you don't have a mute button, press *6. 

That'll mute your phone for this conference line, and 

to come off of mute you just press *6 again. 

And also, please, nobody put this call on hold at any 

point. Hang up and dial back in if you need to but 

don't put it on hold because whatever background 

music your hold button produces, we'll get it for 

everything else and no one else will be able to 

conduct their business and we'll have to cut your line. 

So, if you'll do that for me that would be great and 
6

the meeting is yours, Paul.

Review of the NIOSH responses for the Superior 

Steel Co. Special Exposure Cohort (SEC-00247) 

Issues Matrix

Chair Ziemer: Okay, thank you, Ted. I'm sorry to 

hear about the health issues but we'll see how far 

along we can get here.

I want to start out just by giving a brief overview of 

the timeline here on Superior Steel in terms of the 

documents that we have before us, just a reminder. 

The SEC petition that this is revolving around is SEC00247. 

That petition was originally received May 1 in 2018. 

It qualified July 19th of 2018. NIOSH issued their 

Evaluation Report on November 16, 2018. And the 

Class that was actually evaluated was all members of 

Superior Steel who worked from January 1, 1952 

through December 31, 1957. 

The NIOSH determination, or the Evaluation Report, 

which is based on the evaluation of workplace 

monitoring records and air monitoring records, 

NIOSH reached the conclusion that they could 

estimate doses with sufficient accuracy. 

They issued their Evaluation Report on June 10, 

2019. I'm sorry, that was the SC&A evaluation that 

was issued in June of 2019. The evaluation by SC&A 

had two findings and four observations. 

NIOSH prepared responses to the SC&A review of the 

Evaluation Report and NIOSH's responses were 

issued on October 24th of this past year, 2019. And 

it's the NIOSH responses to the SC&A review that we 

have before us. 

You should have a copy of the findings matrix that 

spells out the SC&A findings as well as the NIOSH 

responses, and those we want to go through today. 

And I think probably our best approach here would 
7

be for NIOSH, rather, to go ahead and give their 

responses. I think you've all had the SC&A review for 

well over six months now, and we can go back and 

look at specifics on the review if we need to. 

But I think a good way to do this would be to start 

with the responses, which means that NIOSH has to, 

in a sense, tell us what it is they're responding to. 

Am I correct in assuming, Rose, that you would lead 

that discussion?

Ms. Gogliotti: I certainly can. I know that Megan put 

together a PowerPoint presentation. 

Chair Ziemer: Okay, well, whoever plans to do it, 

that's fine. I think, Rose, you wrote the original 

review, did you not?

Ms. Gogliotti: Correct. 

Chair Ziemer: For SC&A? Yes, if Megan needs to lead 

it, that's great too. Whatever you guys want. 

Dr. Lobaugh: This is Megan. I can lead it. 

I have a presentation and I'll ask you, Dr. Ziemer, if 

you'd like me -- the presentation starts with an 

overview of Superior Steel again and then the ER 

before we get into the responses, if you'd like me to 

cover that as well? 

Chair Ziemer: That would be great if we have that, 

that's great, thank you. 

Dr. Lobaugh: Okay. So, I'm going to show this on the 

Skype, I'm going to show my PowerPoint on Skype 

for those of you who are online. 

Ms. Gogliotti: It's posted on the website if you're not 

online.

Dr. Lobaugh: Yes, it is posted on the website as well. 

Mr. Katz: For the petitioners, so I just understand, 

the Skype is not available for the public for this 
8

meeting but you can look at the presentation online 

on the NIOSH website. 

Dr. Lobaugh: So, like I said, I'm Megan Lobaugh and 

I'm going to talk about -- I'm going to go ahead to 

Slide 2, which is going to give an overview of the 

presentation I put together. 

So, in this presentation I'm going to talk about a 

review of the Superior Steel Company, what they did, 

and their AEC contract. And then I'll discuss the 

Evaluation Report that we put together in our 

evaluation of the petition that we received. 

And then the last section will be actually discussing 

our responses to the findings and observations that 

Dr. Ziemer mentioned. 

So, I will go onto Slide 4 for those of you following 

along in the PowerPoint. So, this slide here is just a 

general review of the Superior Steel Site. 

So, Superior Steel is located in Carnegie, 

Pennsylvania, and in the picture you'll see the five 

interconnected buildings that make up this facility. 

They had a contract with the AEC to do uranium 

rolling because what they did was metal rolling. 

So, the covered period for this AEC contract -- well, 

the AWE period -- is January 1, 1952 through 

December 31, 1957. So, as Dr. Ziemer mentioned, 

that's the petition period as well, so we'll talk more 

about that later. There's also a residual radiation 

period, which means the site was not cleaned up at 

the end of the AEC contract. So, the residual radiation 

period starts January 1, 1958 and goes through to 

present day. 

There was some clean-up at the site but the total site 

has not been remediated so that's why it continues 

through present. 

Onto Slide 5, in this slide you'll see two pictures 

demonstrating the flow of work and the rolling 

stations that were used at Superior Steel. 
9

So, in the top picture is the layout of the former 

Superior Steel facility showing the area designations 

and approximate locations of process line machinery. 

So, Area C contains a storage shed and rolling area 

while Area A and B contain the finishing stands, 

roughing mill, and salt bath that we'll talk about in 

the next picture. 

The bottom picture is a layout of the actual uranium 

mill operations at Superior Steel. So, the process 

starts on the right side of this drawing with the salt 

bath and proceeds through to the left side. 

So, after the salt bath it goes to the mill run-out table 

and the roughing roll. The salt was then brushed off 

the plate at the brushing station and then put 

through the finishing stand and roll conveyor. 

So, this is just to give you a visual of the full facility 

as well as the actual rolling areas.

Just in general, the rolling started with about a oneinch-thick slab of uranium, anywhere from 61 to 89 

inches long, and anywhere from five and a half to 

seven inches wide. 

And then it ended with a slab that was about 182 to 

191 millimeters thick, so it got pretty thin. 

So, just some other little information I wanted to 

provide here is that the slab was typically passed 

through the roughing roll about five times and then 

sent through the finishing stand before it was cut and 

then transferred to a cooling area. 

So, that's just a real quick general overview of 

Superior Steel Company and now I'm going to talk 

more specifically about the Evaluation Report itself. 

I'm going on to Slide 7, for those of you following 

along. 

So, we received a Form B petition or an 83.13 petition 

on May 1, 2018 with an F.1 basis that the radiation 

exposures potentially incurred by the Members of the 
10

proposed Class were not monitored either through 

personal monitoring or through area monitoring. 

As Dr. Ziemer mentioned, we qualified this petition 

for review on July 19, 2018 and the Class that was 

actually under review is all Atomic Weapons 

Employees who worked in any area of Superior Steel 

Company in Carnegie, Pennsylvania during the period 

from January 1, 1952 through December 31, 1957. 

I want to mention that there were no other past SEC 

evaluations for Superior Steel so this is the first 

evaluation that was done. 

The documentation that was provided in support was 

the NIOSH Site Profile, entitled An Exposure Matrix 

for Superior Steel in Carnegie, Pennsylvania, Period 

of Operation: January 1, 1952 Through December 

31, 1957. 

And the petition emphasized the following 

statements, that individual uranium urinalysis data 

are unavailable for Superior Steel workers and none 

are known to exist, and that no external dosimetry 

results are available for Superior Steel employees. 

So, those are two statements from the Site Profile. 

Going on to Slide 8, the evaluation of the petition 

basis for internal monitoring. So, as I stated just 

before, the statement from the NIOSH Site Profile 

was given as support for the F.1 basis. 

And in our review of this basis we provided the 

following information, that when personal internal 

monitoring data are unavailable, NIOSH uses air 

monitoring data from worker breathing zones and 

work areas in accordance with our implementation 

guide, Internal Dose Reconstruction Implementation 

Guide. 

So, specifically for Superior Steel, we have air 

monitoring data and process data and information 

available to estimate uranium doses. One thing I 

haven't mentioned yet is that in addition to the 
11

uranium rolling that Superior Steel did for the AEC 

contract, we found in our evaluation of this petition 

that Superior Steel also had a commercial contract or 

a commercial venture to do thorium rolling. 

So, for thorium internal doses we proposed, or will 

use, airborne mass loading calculations from the 

uranium air monitoring data to estimate those 

internal thorium doses. 

So, I'm going on to Slide 9 which is talking more 

specifically about external monitoring and our review 

of the petition basis for the external monitoring. 

So, as I said before, the statement, no external 

dosimetry results are available for Superior Steel 

employees, was used as support for the F.1 basis and 

the statement, again, is coming right out of our 

NIOSH Site Profile that we use for dose 

reconstructions. 

Again, when personal and area external monitoring 

data are unavailable, NIOSH uses workplace 

information so source term information, process 

information to estimate dose. And this is in 

accordance with our implementation guide for 

external dose reconstruction. 

Specifically for Superior Steel, we would use the sitespecific source term and process information in 

conjunction with Battelle-TBD-6000 to model both 

uranium external exposures and thorium external 

exposures. 

So, here on Slide 10 is just a summary of our 

feasibility findings in our evaluation review for 

Superior Steel, SEC-47. So, we found that dose 

reconstruction is feasible for uranium internal doses 

and thorium internal doses, as well as external 

uranium, thorium, and occupational medical X-rays. 

So, that was a very quick recap on the Evaluation 

Report, but what I wanted to also do, because in the 

Evaluation Report we provided proposed dose 

reconstruction methods, so I want to go through 
12

those, again quickly before we get to the issues. 

So, I'm on Slide 11 now. So, this slide here covers 

our proposed dose reconstruction methods. This is 

applicable years. 

So, as I mentioned and I didn't really go into detail 

yet, the AEC contract really covered uranium rolling 

and so starting with uranium, the operations period 

or the contract period is June 27, 1952 through 

December 31, 1957 with a residual contamination 

period January 1, 1958 through the present. 

So, that's specific to the uranium rolling that was 

done for AEC. As I mentioned earlier, we found 

evidence of thorium rolling that occurred, at least one 

day of thorium rolling, and for this the operations 

period would be March 27, 1956 through April 20, 

1956. 

And this time period aligns with the time of the AEC 

licensing for thorium work that was done at Superior 

Steel Company. So, because this work was done 

during an AEC contract period, even though it wasn't 

for the AEC, those doses would be covered. 

So, for our post-ops contamination for thorium, this 

time period would be April 21, 1956 through 

December 31, 1957. 

So, again, because this is commercial non-AEC work, 

the dose from thorium contamination would only go 

through the end of the AEC period, the AEC contract 

period. 

So, the dates are important just to know for when 

these dose reconstruction methods would be applied 

and what time period. 

So, on Slide 12 we have a summary of the proposed 

dose reconstruction methods for the SEC petition 

period, so 1952 to 1957. You'll see a table, where the 

left-hand column is the intake information, so we'll 

go through each row individually. 
13

And then there's two columns, one for uranium and 

thorium. We'll go through uranium first. So, there's 

two different specific intake times that we're thinking 

about, or intake types, I would say. One is for rolling, 

when the actual uranium rolling was occurring, and 

that's the first row. 

So, the proposed dose reconstruction method here 

was assuming a 500-hour-per-year exposure to the 

uranium air concentration results that we have for 

Superior Steel. 

There is a teal box around 500-hours-per-year 

because this is a proposed change to the current dose 

reconstruction methodology. So, our current 

methodology, the current TBD, assigns 800 hours per 

year, so this is a slight reduction. Continuing with 

uranium but going to resuspension, the resuspension 

is resuspension of uranium contamination during all 

work processes. So this would be even when they 

were rolling non-uranium, when they were rolling 

non-radioactive metal. 

So, the resuspension time period that we're 

proposing is 2,000 hours per year, using 

resuspension methods that we currently use in the 

program. So, the 2,000 hours per year came from 

the fact that we're assuming there was overtime 

work that was done for 2,500 hours per year. 

So, the resuspension is calculated by the total hours 

minus that 500 hours we're assuming for rolling. 

All of this material would be assessed as U-234,

including recycled uranium contaminants, and this is 

because we know recycled uranium could have been 

used during this time period. 

So, that's a quick summary of the uranium internal 

exposures and some of the assumptions that we 

proposed in the ER. Next, I'd like to go through the 

thorium column. Again, starting with rolling, given 

the evidence that we found of the commercial 

thorium rolling that was done, it appears that there 

was likely one day of thorium rolling. 
14

So, we assumed ten hours' exposure during that 

March 1956 to April 1956 time period. Again, that 

March to April comes from the AEC license to be able 

to handle thorium. And the thorium air concentration 

that we would be assuming will be calculated using a 

mass loading approach. 

So, taking the uranium air sampling results and 

converting to mass, and assuming the thorium mass, 

assuming that the mass on the air sample would be 

the same for thorium contamination, taking into 

account the difference in the two materials. 

The next row here is resuspension so, again, because 

this is commercial work, we would only be assigning 

resuspension through the end of the AEC contract 

period, so for the remainder of 1956 through 1957. 

And here the material would be assessed as thorium232 including daughter products in secular 

equilibrium. 

Again, I want to just point out that the teal boxes are 

showing proposed changes from the current TBD. So, 

as I mentioned for uranium, the 500 hours and 2,000 

hours are changes. 

The 500 hours is a slight decrease. The 2,000 hours 

of resuspension is actually an increase. The thorium 

is completely new. Currently, we are not assessing 

thorium at all because we did not know about the 

thorium rolling when the Site Profile was developed. 

I'm going on to Slide 13, which covers the external 

exposures. So, these are the proposed dose 

reconstruction methods for the external exposures 

during the 1952 to 1957 petition period. 

Again we have a table with two columns, one for 

uranium and one for thorium, and again here the teal 

boxes represent changes from the current TBD. So, 

here we have four different exposure types; each row 

represents a different exposure type. 

So, starting with direct rolling for uranium, direct 
15

rolling was that time when the uranium was actually 

being rolled. And here this 500-hour-per-year 

assumption is the same as the internal exposure 

time, and how we would assess that is actually using 

the Battelle-TBD-6000 methodology. 

Currently, the current TBD uses a surrogate site, 

Simonds Saw and Steel, for these doses, so we 

thought it would be more appropriate to use the 

overarching guidance of TBD-6000. 

For submersion rolling, this would be actual 

contamination that goes up into the air and causes a 

cloud, and this would be the exposures from that 

submersion of 500 hours. 

So, the same exposure time as the direct rolling but 

here using EPA-FGR-12 methodologies. 

Member Anderson: This is Henry Anderson, I'm sorry 

to be a little late. 

Dr. Lobaugh: Hi, Dr. Anderson. The third row here --

just so you know we're on Slide 13 if you're following 

on your own in the presentation. 

Member Anderson: Okay, thank you. 

Dr. Lobaugh: So, the third row here is direct storage 

so this would be the time that the material was onsite 

but not being rolled. And you'll see a red box, this is 

different than before. The red box actually signifies 

that a change has been proposed from the actual ER 

proposed change. 

So, we'll talk about that more when we get to the 

actual findings and observations. But I just wanted to 

point out that there has been a subsequent change 

from this table of information. So, the direct source 

that was initially proposed was 500 hours per year 

and again here the dose rates and methodology for 

calculating those dose rates would be coming from 

Battelle-TBD-6000. 

Again, a change from the current TBD that uses a 
16

surrogate site. 

For post-rolling, this would be the time period after 

rolling was completed or the time period outside of 

uranium rolling when other metal rolling would be 

going on. 

This assumption would be 2,000 hours per year of 

submersion and direct exposure, using the EPA-FGR12 guidance. 

So, going on to thorium, again, all of this thorium 

information would be a change from the current TBD 

because at the time that the Site Profile was 

developed we did not know about the commercial 

thorium work that Superior Steel was licensed to do. 

So, starting with direct rolling, the proposed method 

would assume ten hours of direct rolling in the Marchto-April 1956 time period. And here we would use 

MCNP modeling and distance guidance that's 

provided in Battelle-TBD-6000. 

For submersion rolling, again, that time is the same 

as the direct rolling because this is just the 

contamination from the cloud, the cloud 

contamination that would occur during the rolling 

itself. 

So ten hours, again in that same time period, again 

using EPA-FGR-12 guidance. For direct storage, here 

the hours are 190 hours in that March-to-April 1956 

time period. Because Superior Steel was really only 

licensed to have thorium through the end of April 

1956, that's how the 190 hours came to be, assuming 

those two months. And again, using MCNP modeling 

and a dose rate at one meter. 

So, for post-rolling, this is again that time period 

outside of the thorium rolling when normal metal 

rolling would have been occurring so we would 

assume exposures for the remainder of 1956 and all 

of 1957, again submersion and direct exposure. 

So, that was a quick summary of the Evaluation 
17

Report as well as the proposed dose reconstruction 

methods that were provided in the Evaluation Report. 

So, the next thing in my slides was to actually review 

the SC&A review of the ER. I'm not sure if, Rose, you 

want to introduce each issue and then I could provide 

the NIOSH response?

Ms. Gogliotti: I think that makes the most sense, if 

that's okay with everyone. 

Chair Ziemer: So, before you do that -- this is Ziemer 

again -- let me ask if Josie or Henry have any 

questions to start with the Evaluation Report itself. 

Member Anderson: I don't. I went over it pretty 

carefully but this was a good summary. 

Member Beach: I just had a quick question on the 

thorium rolling. I went through, you guys are giving 

it a ten-hour day, and I know this is a Site Profile 

question. 

I know we only did 700 pounds so it probably didn't 

take a full day. There would not have been any way 

that would have went into overtime, is there? 

Dr. Lobaugh: Yes, so the information that we found 

says that they were requesting to receive about four 

ingots. 

So, from what we could tell, their throughput would 

have been more than four per day but it's a 

conservative assumption to do the entire day of 

rolling. 

Member Beach: Okay. 

Ms. Gogliotti: They would have known that they could 

have easily processed 25 slabs of uranium a day so 

they're making the assumption that it was all done in 

one day. 

Member Beach: Okay, that's what I thought. Thank 

you. 
18

Chair Ziemer: Let me also pose one additional 

question not directly on the Site Profile issues. I know 

there had been I think 35 dose reconstructions 

completed. 

I think those go back. Were those all done without 

looking at thorium at all? Were those all older? I don't 

know, Megan, if you know the answer to that?

Dr. Lobaugh: Correct, those would have all been 

done under the current Site Profile which does not 

assign dose from thorium. 

Chair Ziemer: So, those automatically all are going 

to end up having to be looked at anyway, is that 

correct? 

Dr. Lobaugh: Correct, so those would be --

Ms. Gogliotti: With the exception of the cases that 

we're already compensated. 

Chair Ziemer: That's right.

Dr. Lobaugh: Exactly. 

Chair Ziemer: Okay, thank you. Let's go ahead, then, 

with the next section. 

Ms. Gogliotti: Okay, we'll start with our first finding 

and this really had to do with the use of Vulcan 

Crucible Steel billing rate data. 

NIOSH had used it in their ER as well as in the TBD 

and there wasn't really any justification on why they 

felt that was an appropriate billing rate to use. 

It doesn't technically meet the Board's surrogate data 

criteria; however, we thought it was important that 

it be evaluated against those criteria. 

The actual review itself really only made a connection 

that the site was an AWE and also processed uranium 

metal, but there wasn't really any rationale for why 

that billing hour or billing rate was a reasonable 

substitute for Superior Steel. 
19

It was also unclear to us how the process conditions 

on the site were really impacting the final price. We 

did a cursory review and did find another site, Joslyn 

Manufacturing Company, that had a billing rate of 

$88 per mill hour. 

And if you were to use that billing rate, it would 

increase the number of hours by over 200 from the 

500 that were in the SEC. Actually, the TBD is 800. 

And I can turn it over to you, Megan.

Dr. Lobaugh: Okay. So, as Rose said, we did not 

provide this information in the ER so in our response, 

we actually evaluated the billing rate that we 

proposed, the Vulcan Crucible billing rate of $132 per 

hour. 

We evaluated that using the five criteria in the NIOSH 

implementation guide, the use of data from other 

facilities and the completion of dose reconstructions 

under the Energy Employees Occupational Illness 

Compensation Program Act. 

So, the five criteria in there are source term, facility 

and process similarities, temporal considerations, 

data evaluation, and review of bounding exposures. 

So, in our response we actually went through those 

five criteria and provided justification for why the 

Vulcan Crucible billing rate was a good surrogate 

billing rate for Superior Steel Company. 

So, just as a reminder, the choice of this billing rate 

is going to affect the hours that we assign for the 

intake, the internal dose exposure time period as well 

as the external dose exposure time that we discussed 

before. 

So, the 500 hours is coming from the use of the $132 

per mill hour and actually, Superior Steel Company's 

contract payment for 1957, which was $54,632. 

So, when you divide that out you get 414 mill hours, 

which we rounded up to 500 hours of rolling 

exposure, and again, that would be the assumption 
20

for the intake time period as well as the external dose 

time period. 

So, going on to Slide 16 for those following along, I'll 

just step through the five criteria in our 

implementation guide and discuss the justification for 

why the Vulcan Crucible billing rate would be a good 

billing rate. 

So, in terms of source term, both sites roll uranium 

billets, so the source term at the sites for their AEC 

contracts were the same. For the second criteria, the 

facility and process similarities both had similar 

processes. 

We went through specifically in the matrix, if you 

have the matrix in front of you. On Page 2 to 3 we 

went through the specifics for each of those 

processes. 

You'll see that the steps are pretty similar, go into a 

heating furnace, go into a roughing roll, finishing roll, 

cutting, and then moving through cooling location. 

And the time, the approximate time that it took to do 

both of these, were very similar: 75 minutes for 

Vulcan Crucible, 1 hour for Superior Steel, according 

to the documentation that we found. 

So, we found that both of these sites had similar 

processes as well as the time it took to do it. 

In terms of temporal considerations, the Vulcan 

Crucible billing rate that we used in the current TBD 

as well as propose to continue using in the ER is from 

1948. 

Again, the time period for this petition review was 

1952 to 1957 so we considered that within the same 

era of operations. 

For data evaluation, this is one of the criteria that 

doesn't directly apply because our implementation 

guide really discusses the review of exposure data, 

so what is called Type 1 data in the Board criteria. 
21

So, this billing rate that we're talking about is really 

a Type 2 data which really kind of is supporting data 

provided, not exposure data. 

So, while this doesn't directly apply, how we looked 

at this was reviewing what other available billing 

rates there were to us. 

So, in this process we performed some additional 

data capture and made additional data requests of 

different facilities, different archive facilities, to 

review and see if there was any information on 

rolling, rolled uranium, rolled thorium, rolling 

thorium, rolling uranium. So, we used several 

different source terms to try and find additional 

billing rates. And we looked for some specific sites 

that we knew did rolling like, for example, Fernald, 

Hanford, Joslyn, Simonds Saw and Steel. 

So, in this review we really found four billing rates 

that would fit the time period as well as the similar 

processes. I'll go through those here. 

Simonds Saw and Steel had $110.53 per rolling hour 

billing rate and here, the number of mill hours or 

rolling hours that you would calculate using this rate 

was very similar or comparable to what was 

calculated using the Vulcan Crucible billing rate. 

So, this was very similar to the 500 hours that we 

calculated using Vulcan Crucible. 

For Joslyn, we actually have two different billing rates 

that were found for Joslyn. The one, the first one here 

listed, was $450 per rolling hour. 

This was actually for a different process that required 

additional safety precautions, additional health 

surveillance, and likely that elevated number is due 

to the fact that these processes were different. 

So, this was determined to not be a good billing rate, 

surrogate billing rate, for Superior Steel because of 

the fact that the processes were different. 
22

The Joslyn billing rate that was mentioned in the 

SC&A SEC ER review of $88.03 per hour or $0.11 per 

pound we actually found was never implemented. So, 

Joslyn basically rebid, saying that they could consider 

a possible bid at cost plus 10 percent, which equated 

to $96.83 per hour. 

But actually, this was never implemented and it's 

quoted as Joslyn but it was really for Simonds Saw 

and Steel, is what we found when we looked at the 

documentation again. So, this rate was not a good 

surrogate billing rate because it was never 

implemented. 

The last one I'm going to mention here was actually 

in our subsequent data captures and requests that 

we made in response to this finding. We found the 

Superior Steel Company Modification Number 5 to 

their contract. 

So, during the evaluation period itself, during our 

evaluation for the SEC, we did not have access to this 

modification at that time. 

We were not aware of it, so this was found during our 

subsequent review, and here, we find that in that 

Modification Number 5 their actual rate was $1.01 

per pound for the rolling itself. 

And then there were some additional add-ons for 

additional services for inspection after pickling and 

before shipment to the heat treating facility, as well 

as an additional fee per pound for inspection of the 

slats before planing, and one last additional fee that 

could be added for beta-treating the slabs. 

So, if all these additional services were provided, the 

total rate per pound was about $1.15 per pound. 

What you'll notice is the first three billing rates that 

we talked about were per hour while the last one is 

per pound. 

The Simonds Saw and Steel that's listed here as 

Joslyn did give an $0.11 per pound -- in their 

discussion they talked per pound but the other three 
23

billing rates were per rolling hour, while the Superior 

Steel contract actually gave it per pound. 

And with that, I'm going to go on to Slide 17. So, that 

finished Criteria 4. We still have one more criterion 

that we discuss in the implementation guide and this 

is the review of the bounding scenario. 

So, again, this criterion really doesn't directly apply 

because the review of the bounding scenario 

discussion in our implementation guide really focuses 

on exposure data itself, and here we're talking about 

a billing rate that would be used to determine 

exposure time, not the exposure data itself. 

So, this is a Type 2, again just a reminder that this is 

Type 2 surrogate data. 

So, for review of bounding scenario, what we looked 

at, what NIOSH looked at, was a comparison to other 

information we have. 

So, we do have additional information in the 

Evaluation Report in Table 7-1, which is a table that 

lists the information that we found about rolling at 

Superior Steel from other sources of data. 

So, this Table 7-1 was compiled from a review of 

SRDB documents that we have, like the typical ones 

you would think of. So, the HASL air monitoring data, 

technical reports, as well as shipping paperwork. 

So, there was some customs paperwork that we saw 

as well as this other shipping information, so that's 

how this Table 7-1 was compiled. 

So, it gave us usually dates of rolling or at least the 

time period of the rolling, the type of material 

typically, sometimes it gave us number of slabs or 

the weight of slabs, the total weight of slabs that 

were rolled. Sometimes it didn't give us that 

information. 

So, Table 7-1 we felt was another compilation of 

information that we could use to compare this 
24

calculated rolling exposure hours to another form of 

information that could tell us something about how 

many hours they maybe rolled uranium per year. 

So, when we look at Table 7-1, depending on how 

you cut it and how you look at the information, we 

saw that this really yielded about 60 hours per year 

of rolling exposure. 

So, using the billing rate gave us a more 

conservative, claimant-favorable estimate of 

exposure hours versus this compilation of 

information that isn't necessarily complete but at 

least gives us another idea or a picture of how many 

hours of rolling there was. 

And again, like I mentioned before, in this review that 

we did, just to respond to Finding 1, we found the 

Modification Number 5 for the Superior Steel 

Company contract. 

And if we look at this Modification Number 5 and do 

some calculations, there are additional assumptions 

that we have to make here. So, because the Superior 

Steel contract payment was written in per pound, we 

have to make additional assumptions on the weight 

of the slab as well as the number of slabs rolled per 

day or per year depending on how you look at the 

exposure rate. 

So, in our response, in the assumptions that we made 

in our comparison, we found that, using this 

Modification Number 5, it was about 510 hours for 

the entire contract. 

So, how we actually calculated that was using the 

entire contract payment of $356,849, assuming that 

that was all paid for mill time, even though we know 

that some of that payment was actually for 

improvements to their processes and their 

equipment. 

We made the assumption that that entire payment 

amount was actually for rolling time and used this 

rolling rate of $1.01 per pound, so not including the 
25

additional services. And you find that it's 

approximately 353,000 pounds of uranium that 

would have been rolled. And if we look at slab 

weights, the slab weight information that is available 

in Table 7-1 of the ER, you see that the slab weights 

really ranged a whole lot. 

But if we use the overall average slab weight, 

average slab weight as well as assuming that they 

could approximately roll 25 to 30 slabs per day, that's 

how we ended up getting 51 days for the entire 

contract or 510 hours, assuming a 10-hour day. 

So, that was kind of a long, drawn-out explanation 

but the big thing I want to point out here is the 

additional assumptions that we don't have much 

information on, so the weight of slabs and the 

number of slabs really rolled per day or year. 

We do have that compilation and we can use that 

information but there's a wide variety of weight of 

slabs as well as the number of slabs rolled. 

So, in our response, our conclusion was that we really 

stand by the use of the Vulcan Crucible billing rate to 

determine the number of hours because of the 

claimant-favorable outcome of the 500 hours per 

year that we would assume, as well as the fact that 

there's less unknown assumptions going into that 

calculation. 

Ms. Gogliotti: Okay, and I think it's just important to 

point out here that when NIOSH did their initial ER 

review and when SC&A did our review of that 

document, there was no contract-specific information 

here. 

It was believed that the contract was destroyed which 

is the reason they had to go to the Vulcan Crucible 

billing rate because they didn't have site-specific 

data. Through this process, though, NIOSH found 

site-specific data. They found the $1.01 per pound 

and I think that SC&A and NIOSH are in agreement 

that we can absolutely bound the milling hours at 

Superior Steel. But it's our position that when you 
26

have site-specific data, you have to use it. I 

understand completely that this 500 hours is 

claimant-favorable and definitely bounding but we 

think in light of this information, it makes it not 

plausible. 

And the Board's hierarchy of data criterion should 

take -- the actual site data should take precedence 

over the surrogate billing rate. 

When we do preliminary calculations, which are in 

our Issues Matrix that we published on January 14th, 

we calculate an annual maximum milling hours per 

year of about 253 hours. 

And of course, you can argue about which one you 

could use to calculate that. But based on that, we 

don't believe that 500 hours is plausible. 

Dr. Mauro: This is John Mauro. I'd like to add a little 

bit to that. 

The concept of using larger plausible bounding 

numbers, as you did, as compared to perhaps a lower 

number that is more aligned with the site-specific 

information, is generally okay except when you're in 

a mode where you're compensating people. 

In other words, from my perspective looking at a 

number of cases, if in some places, in some sites, you 

use some kind of upper-end value and other cases 

you use more realistic values, the upper end are 

always -- you have a choice. 

As Rose pointed out, it's always preferable to use the 

realistic value, especially if it's sound, in other words 

you're comfortable that you can rely on that number. 

But it's also okay to use the -- when you have a 

choice. But my concern has been in the past, and this 

is a longstanding issue, is if you have different sites 

and you don't have a consistent approach between 

sites. 

In some cases you may have a site where you -- like 
27

in this case, you're going with a higher-end value, 

which is fine. 

But then you run into this dilemma that you might 

end up compensating people there, let's say at this 

site, where you used more realistic values at another 

site. And then there's this parity issue. 

I don't know the degree to which you have discussed 

this matter or what your opinion is regarding this 

matter but I thought that's something worth 

discussing. 

Mr. Katz: Thanks, John. Let me just cut in here, I'll 

add a little bit to what John just said. The bottom line 

here is you can be claimant-favorable to the extent 

that you have uncertainty. 

So, it is fine to calculate at a higher level to the extent 

that your uncertainty about the levels drive you to do 

so. 

But to the extent that you don't have uncertainty, of 

course, you don't go beyond that in terms of being 

claimant-favorable. 

Maybe that's the same as what John's saying? You 

don't go beyond that. And that's the limit. But to the 

extent that there is uncertainty and you need to deal 

with that by simply being more claimant-favorable, 

that's fine. 

And that's all that I think really needs to be judged 

here by the Work Group and, of course, by NIOSH 

and by SC&A, is how far do you need to go to ensure 

that you're not undercutting anybody because of the 

uncertainties that are involved? 

Chair Ziemer: This is Ziemer. John or Rose, have we 

received the hours that you just mentioned as an 

alternative set? Did we get a specific 

recommendation from SC&A on that?

Ms. Gogliotti: We did an example calculation that's in 

our January 4th Issues Matrix and that uses the 
28

billing rate specified without any adjustments for the 

additional 14 and a half cents that could up the billing 

rate using the smallest known slab weight, 25 slabs 

per day, which we know has been processed in the 

past. 

10 hours of milling per day using the highest annual 

billing, which was 217,000 less their reimbursable 

expenses that were specified in the contract of 

$79,000. So, roughly $138,000. 

Chair Ziemer: In terms of the total time, what are the 

two numbers? 500 hours per year?

Ms. Gogliotti: Is what NIOSH is assuming, correct, 

using the Vulcan Crucible Steel billing rate.

Chair Ziemer: The SC&A's number, again, was what?

Ms. Gogliotti: 253 hours. 

Chair Ziemer: Okay. 

Ms. Gogliotti: So roughly half. 

Chair Ziemer: Yes. 

Member Beach: And then there's a note in here, 

Megan, that NIOSH is still awaiting responses on 

three data requests. Can you tell us what those 

entail? Is it more sites or is it specific to --

Dr. Lobaugh: So, those three that we were awaiting 

were requests that we made of Hanford, the archive 

information that was stored at Hanford, we actually 

have received those since then. 

That information, again, was based on some key 

words that we chose around rolling uranium, 

thorium, Superior Steel Company, and those other 

sites that we listed in the matrix. So, like I 

mentioned, Fernald, some other locations that had 

rolling that we knew of. So, we have received results 

back from those searches and have not found 

anything additional. So, those three searches did not 

provide any additional information. 
29

Member Beach: Okay. 

Mr. Katz: Let me just add one other thing to this 

conversation about this issue. At this point, you have 

really two matters. 

One, the SEC matter, which is feasibility, and I think 

what you've heard from these two staffs is they both 

believe in feasible reconstruction. 

The question left on the table is the Site Profile issue 

of how conservatively you reconstruct. So, the Work 

Group really has two matters in front of it. 

One, which we normally address first, is the SEC 

matter of is it feasible or not? 

And the second matter, which could be addressed 

now or could be addressed down the road, is if the 

Work Group agrees that it's feasible, then it would 

take on the question of, well, what it is the 

appropriate dose reconstruction approach in the 

Work Group's opinion? 

Which it can address as well, like I said, either at this 

meeting or down the road, depending on how it 

addressed the first question, the SEC question. 

Chair Ziemer: Ziemer again. The first part of that, of 

course, we have, I think, agreement between both 

NIOSH and SC&A and that is that dose can be 

reconstructed. 

Is there any question on that part of the issue as far 

as the Work Group is concerned, Josie or Henry? 

Member Beach: For me, Paul, no, I don't have any 

questions on that aspect at all. 

Member Anderson: For me, the same. We actually 

have two methods here, I'm probably more 

comfortable with using the data from the facility since 

you've now got it. And we're really just into assessing 

the uncertainty. 

Is the uncertainty more than a factor of two different? 
30

Dr. Mauro: Exactly. 

Member Anderson: 500 and 250 could well be within 

the range. Each has different sets of uncertainty to it 

but I do think it sounds like it can be, to me. 

And looking back over some of the other facilities, of 

course, we have quite a number of these types of 

rolling operations that have been evaluated in the 

past.

And I think this method, either one, works, is 

consistent with what we've done in the past. So, I'm 

comfortable saying that, again, the doses can be 

reconstructed for these facilities during these rolling 

periods. 

Chair Ziemer: Well, it's clear that our Work Group has 

agreed on the first part of the question to the second 

part on what number you go with. 

I, myself, am in favor of using the actual site data 

when you had that versus -- in fact, the one reason 

you can describe the discrepancy being that large, 

it's basically double, is the uncertainty where you go 

without having site data. 

Your bounding ends up being bigger just because of 

the nature of how we do those uncertainties. But I 

think whenever we've had actual data, it's always 

what we want to go with, if possible. 

But, Josie, let's get your input on this part of the 

question.

Member Beach: I would agree with that, although I'd 

like to see what the actual data is a little more 

specifically. 

I wasn't really working on that as much as I was 

trying to understand the approach NIOSH was using. 

Dr. Lobaugh: This is Megan. One thing I would 

suggest, maybe, is -- I guess I'll throw myself under 

the bridge -- I will or I can, if you guys would find 

this helpful, pull together all the data that we have in 
31

terms of pounds and number of slabs, as well as the 

contract payments that we have again, because 

those are the big inputs to this calculation, so that we 

can see the variability in all those numbers and come 

up with something reasonable using the site data that 

we have. 

Chair Ziemer: That certainly might be helpful. 

I'm wondering at this point, is NIOSH's position 

currently that, in spite of having the site-specific 

information on the billing rate, in spite of having that, 

does NIOSH still prefer to go with, or are you 

recommending that we go with the 500 hours? 

Dr. Lobaugh: So, I can speak and then maybe Tim 

can speak more from a programmatic standpoint. 

But the information given in the response, the reason 

that we stuck with the 500 hours was really due to 

variability and uncertainty that I felt was present in 

the information that we had for the weight of the 

slabs as well as the number of slabs rolled per day or 

year. 

Because if you look at the information in Table 7-1, 

it really is quite variable, so anywhere from 9 slabs 

up to, you know, 150 slabs in the documentation. 

Now, because that documentation isn't specific to 

rolling, we don't know whether all the slabs were 

rolled over a two-to-three-day period or how many 

slabs are really done per day in a typical rolling 

operation for uranium slabs. So to me, given the 

uncertainty that was present and again, the 

variability that we saw on the data that we have in 

Table 7-1, the approach with the least number of 

assumptions was to use the surrogate billing rate. 

Dr. Mauro: Megan, this is John Mauro again. I 

appreciate the sort of situation you're in, that is there 

are multiple parameters that go into making these 

judgments, as you pointed out.

It's not only the dollars per hour, but also the number 
32

of slabs per hour and the time. It's almost like 

collectively -- and I think Ted alluded to this --

collectively you want to come down in a place that 

you think is reasonably bounding. 

And the 500-hour number you used comes out to be 

a factor of 2 higher than if you go with the dollar-perhour billing rate, but it's really the collective of 

information that goes into this. 

And as you pointed out, if there is this collective 

uncertainty that you're struggling with, you don't 

want to always pick the worst when you're using 

three or four metrics or parameters to come up with 

a number. 

You don't always want to pick the highest of each one 

because then you come out with a number, you're 

multiplying upper-end value by upper-end value, et 

cetera. 

So, yeah, in my opinion, if I was in your shoes, I 

would put myself in a place where I was comfortable 

that, taken in its totality, perhaps the 500 hours, 

even though I was critical when I started this, might 

strike the right balance when you consider all the 

other parameters, as you just pointed out. 

So, I'm just trying to help out a little bit here. But if 

you feel you struck reasonable values on all the 

different parameters and then you had this dollarper-hour number that you feel comfortable with, then 

I think that -- you see where I'm going with this? 

It's really a matter of thinking about just coming out 

at the right place and not necessarily coming out with 

an upper-end value that you say, well, this is the 

highest it could be, but you then run into this parity 

problem. 

You understand where I'm going? 

Dr. Taulbee: This is Tim, and I would like to just 

chime in here for just a moment here. 
33

What Megan is getting at with the values in Table 7-

1 of the ER there is that there's a lot of uncertainty 

here and I think everybody is understanding that. 

And so from our standpoint, we took an approach to 

come up with what we were certain or quite certain 

that this would be an upper bound that we could 

estimate these doses. 

We could go through and try and come up with more, 

better, weights per slab. I've seen ranging here from 

216 pounds per slab to 500 pounds per slab. There's 

a factor of two just on the weight of each slab. 

So, to try and sharpen this more, we just don't see 

that it's worth that effort but, of course, if the Work 

Group wants us to go through that we can certainly 

do so. 

But if you just look at some of that variability within 

this, how much more do we want to try and work on 

this? 

That's, I guess, our question back to you all. 

Chair Ziemer: And Tim -- Ziemer again -- I think it 

sounds like if you looked at it, you actually could 

picture this as a distribution of possible weight 

distributions that give you maybe a log-normal type 

of possibilities. 

And the upper end of that, you're saying, actually, 

you could have a scenario where, depending on the 

weight distribution, you could have the 500 hours?

Dr. Lobaugh: I don't think so. 

Dr. Taulbee: Well, we don't think it would be quite 

that high but is it 450? You go through all of that. 

It just seems like that's a lot of effort here and not 

much significant gain. 

Member Anderson: This is Andy. 

I would look at it also like our process has always 
34

been to use existing data from a facility and now that 

we have it, I just don't see the overwhelming 

evidence that this should be ignored. 

Now, whether you can rework the numbers on the 

estimates so that they get closer, but I would like to 

see it laid out a little, maybe because I'm late to the 

game here that there's stuff out there that I have not 

been able to wade through. 

But I would like to see why we ought to move to --

in this case, I don't know whether this is the first time 

using surrogate data when there was existing data 

for a facility or not, for a rolling facility. 

So, I wouldn't want to set a new precedent just 

because it ends up with a higher claimant-favorable 

number. 

What you really want it to be is how realistic is that 

as an upper-bound number or is it potentially one we 

can't defend as well? 

So, I don't know, maybe there's some data. Paul, I 

don't know if you have a better handle on some of 

this than I do, but that would be my issue. 

(Simultaneous Speaking.) 

Dr. Taulbee: We could go through --

Member Anderson: -- done it with the existing data 

unless we really have a way to show that the 

uncertainty in going with existing data is so much 

greater than the uncertainty as it's been applied to 

the other. 

Dr. Taulbee: I believe the uncertainty, Dr. Anderson, 

is about equal on both ends, using the surrogate data 

from Vulcan versus the uncertainty that we have on 

the individual slabs of what we would end up with, at 

the end of the day. 

But if your preference, if everyone's preference, is to 

use the site-specific data, I think that is something 

that we can do and we can incorporate that into the 
35

TBD. I guess I'll just leave it at that particular point. 

But do recognize that this will be -- the number that 

we come up with would be likely a distribution from 

that particular standpoint. And so that would be the 

number of hours we would end up using. 

Mr. Katz: Let me just ask one thing before we lead 

this topic, and I have to cry uncle and take a break. 

But do we want to close the SEC finding at this point? 

Because I think you've, in effect, done it but I think 

we should do it just formally, that SEC Finding 1. I'm 

not sure of its number. 

Chair Ziemer: That's Finding 1, I'll call it 1A. It's that 

part of the issue, is the dose reconstructable with 

sufficient accuracy? Each of the Work Group Members 

has already spoken to that. We've already agreed 

that we could so I don't think we have to officially 

vote. 

I can take it by consent that we've agreed to that.

Mr. Katz: Correct, I just wanted to have it stated for 

the record, that's all. Thanks, Paul. And you said it's 

1A?

Chair Ziemer: I just called it 1A. It's the first 

question, first part of the first finding. The second 

part was the actual value to use. 

Mr. Katz: Right, and that actually is a TBD issue, 

really, not an SEC issue. 

Chair Ziemer: Yes, so that's in the delayed --

Mr. Katz: It sounds like the agreement on that is that 

NIOSH will go back and maybe sharpen its pencil on 

its use of local data and come back to the Work Group 

with a proposal. 

Chair Ziemer: I want to make sure that we're not 

doing a whole lot of additional, unneeded work. 

Tim, for example, said it could be a tie, for example, 
36

450 hours rather than 250 and that was based on, I 

guess, just assuming a different set of rolling, right? 

Or what? 

Dr. Taulbee: No, that was just a guess estimate, Dr. 

Ziemer, when you consider that the uncertainty in 

the slabs, from what we're seeing in the data, is 

ranging from 216 pounds per slab to over 500 pounds 

per slab. 

So, when we run through all of the numbers and 

calculations, this could be a factor of two easily. 

(Simultaneous Speaking.) 

Chair Ziemer: Is it possible just to give us a few 

examples, just to demonstrate? That'll make it clear. 

I don't want to add months and months of work to 

this to show what's already appeared to be pretty 

uncertain. 

Dr. Lobaugh: This is Megan Lobaugh. I can pull that 

together, that information together, like the range of, 

the number of slabs that we're seeing rolled per day, 

as well as the weights that we see. 

The other important information here is what 

contract payment we're using, whether we're using 

the total payment over the entire contract, whether 

we're using an annual payment. I can pull all that 

information together and provide an additional 

response to the Work Group with, kind of, what we're 

seeing when we look at this those different ways. 

Chair Ziemer: I think that might be helpful for us, 

just to get a feel for that uncertainty and I think we 

need to try to resolve that. 

Member Anderson: That would be helpful to me. 

Chair Ziemer: They have the data available, right?

(Simultaneous Speaking.)

Mr. Katz: So, Paul is saying he doesn't want a great 
37

level of effort here for little value and you're saying 

you can do that, right, Megan --

Dr. Lobaugh: Yeah, I can do that. 

Mr. Katz: -- without draining the bank, so to speak? 

Dr. Lobaugh: Yes. 

Mr. Katz: If you all don't mind, let's take a ten-minute 

break, please? 

(Whereupon, the above-entitled matter went off the 

record at 2:20 p.m. and resumed at 2:30 p.m.) 

Chair Ziemer: Let's see, are we moving on to 

Observation 1 next? I guess we would do the second 

timing first, right?

Ms. Gogliotti: I think we should do Observation 1 only 

because it directly relates to --

Chair Ziemer: I think on your slide you had the timing 

first, but let's go to Observation 1, that's fine. 

Ms. Gogliotti: The BRS just lists it alphabetically, 

that's the reason that happened. 

Chair Ziemer: Right. 

Ms. Gogliotti: So, our Observation 1 has to do with a 

different observation. 

To our knowledge, we don't think that bounding the 

source term had been done based on contract billing 

in combination with another site's billing rate in the 

manner that it was done in the TBD or this DR review 

so we thought the Board needed to weigh in on this. 

But, of course, if we end up using the real site data, 

then that should be a moot point. 

Dr. Lobaugh: So, as Rose said, this was kind of 

thought to be a new approach. 

And I just want to point out again this, since it is 

discussing the billing rate, is talking about the 
38

exposure time specific to rolling hours for both the 

internal dose and external dose that would be 

assigned. 

I just wanted to remind or point out that we're not 

using this to bound the source term but really to 

calculate a number of hours, so exposure time. 

So, in our response, we clarify that the billing rate 

wasn't used for any source term assumptions. 

The source term information is really coming from 

the AEC contract information that we have about 

what they rolled as well as the AEC licensing that they 

had for the thorium rolling they did. 

So, the source term itself would be either the 

uranium or thorium based on the process information 

that we have and source documentation we have for 

that. 

So, our response was really just clarifying that, again 

that we're not using this to bound the source term 

but to bound the exposure time. 

Chair Ziemer: Thank you, Megan. This is Ziemer. 

Ted, just for clarity, normally on observations they 

don't have to be resolved necessarily in terms of 

action. 

I guess I'm asking if you can clarify for us, do we 

need anything beyond this? Or NIOSH and SC&A, are 

you asking for anything more than this?

Dr. Lobaugh: We just wanted to make you aware that 

it is different than we've seen in the past. 

Chair Ziemer: Right, I'm certainly aware of that. Ted, 

what do we need to do on this? 

Mr. Katz: So, with observations you really don't need 

to do anything other than what you might want to, to 

put it that way. 

So, in most cases, unless it has some issue that you 

want to follow up on, you can just close them out 
39

basically and say, okay, thank you, and we're done 

with this. 

If they lead you somewhere, of course you can go 

wherever they lead you. 

Chair Ziemer: And in a sense, what we do on Finding 

1 will address this as well. Let me ask Andy and Josie, 

do you have any additional questions or comments 

on the observations?

Member Anderson: I don't. 

Member Beach: I don't either and I think that I will 

sort itself out when we resolve Finding 1, as stated. 

Chair Ziemer: Right, very good. Okay, let's move on 

to Finding 2. 

Ms. Gogliotti: Okay. Just as a reminder, the only

uranium airborne monitoring data we have comes 

from four different HASL studies. 

There were two from 1953 and two from 1955, and 

what the ER review does is it suggests breaking them 

into pre- and post-1955 survey distributions, and 

assigning everything pre-1955 to 1953, 95th 

percentile, and everything post-1955 to the 95th 

percentile of the 1955. 

But when we looked at the data we found that there 

was insufficient evidence to support splitting the data 

into pre- and post-1955 survey distributions. 

We felt that the May 1955 sample results might not 

be representative of the typical working conditions of 

the site, and that's because they represented a 

theoretically small point of time when engineering 

controls were reducing airborne contamination. 

So, we can only definitively say that on the date of 

the survey those samples were low and the 

reductions in the air concentrations seen, there was 

an introduction of man-cooling fans as well as 

additional ventilation. 
40

But we think that was largely offset by the slab 

brushing that was instituted in September 1955.

So, lacking additional evidence of the engineering 

controls that were implemented and when they were 

done, we didn't believe that there was enough 

evidence to support the pre- and post-1955 

distributions.

Dr. Lobaugh: So, in our response, the NIOSH 

response to Finding 2, we performed hypothesis 

testing on the data sets to see whether these data 

sets were from the same distribution or not. 

So, what was found was that the May 1955 data was 

not from the same distribution. We did not do testing 

to tell whether it was higher or lower, it just told us 

it was not from the same distribution. 

Visually, when you look at the visual plots of this 

data, it does look lower. So then our proposal was to 

basically remove the May 1955 data from the intake 

analysis and use only the three other data sets to 

determine intake rates for the entire exposure 

period. 

So not parse it out as originally proposed but to just 

use the three data sets to determine the uranium 

intake rate, which then would also feed into the 

thorium intake rate by doing the mass-loading 

calculations. 

Mr. Katz: Someone on the line isn't muted. So, the 

only person who should not be muted at this point is 

Megan, who's presenting. If you don't have a mute 

button, please press *6 because it's getting to be 

pretty noisome listening to the interference. Thanks. 

Ms. Gogliotti: Okay, and based on NIOSH's response, 

they basically agree with our suggestion to remove 

the May 1955 sampling data and combine the 

remaining three samples. 

So, we recommend accepting that modified 

approach. 
41

Chair Ziemer: Okay, let's get input from the Work 

Group on that, or questions or comments? Go ahead, 

Josie. 

Member Beach: I agree with that assumption. I did 

want to point out, I think, Megan, on Page 10 of the 

matrix -- oh, wait, this is SC&A. 

There is a typo I believe on the first bullet, the May 

1953, that says, therefore, they're using 19 samples 

from the May 1955 data set. 

Is that correct or should it be '53?

Dr. Lobaugh: Yeah, it should be May 1953. 

Member Beach: Okay, I just wanted to verify that. 

And I agree with this, removing the May data for 

1955. 

Member Anderson: I don't have any problem with 

that. Good pick-up on the typo there, Josie. 

Chair Ziemer: So --

(Telephonic interference.) 

Mr. Katz: Paul, you're breaking up. I'm sorry, Paul, 

your voice isn't coming through. I don't know if it's a 

speakerphone but your voice isn't coming through. 

Chair Ziemer: I took it off speaker, can you hear me 

now?

Mr. Katz: Yeah, that's perfect. 

Chair Ziemer: Okay. I just wanted to ask --

(Telephonic interference.)

Mr. Katz: You're breaking up again. Sorry, Paul, we 

couldn't hear what you said. 

Chair Ziemer: I'm just going to move to a different 

spot. Can you hear me? Are we good?

Mr. Katz: Right now you are, yes.
42

Chair Ziemer: Okay. Is there reason to believe that 

the data actually is -- is different but if you look at 

the data --

(Telephonic interference.) 

Mr. Katz: Paul, every other word of yours, just now 

in the question again, was lost. You're going to have 

to restate it, Paul. Again we lost you. 

Chair Ziemer: It must be the Lafayette weather. Is 

there reason to believe that the data set is actually 

not good? Obviously, it's a different data set, it's from 

a different year. But is there reason to believe that 

it's invalid?

Dr. Lobaugh: So, as Rose kind of mentioned, what 

we found in the reports from HASL was that there's 

some indication that they were trying to use 

increased ventilation, additional fans, man-cooling 

fans and things like that, to try to decrease the 

airborne contamination.

Other than that, that's really the only information we 

can find that would lead us to believe why this data 

is different from the other data sets. 

Dr. Taulbee: Paul, if I could interject here just a little 

bit, to state it another way, they were doing some 

experimentation to, as Megan said, try to reduce the 

airborne levels, trying different things, engineered 

controls, and there's no indication that those 

continued on past that date. 

So, they were doing sampling during a particular 

rolling, trying out some new things, and there's no 

indication that it continued or was prior to that 

particular rolling. 

Dr. Lobaugh: The other thing Rose mentioned, too, 

was that they instituted brushing because there was 

some salt left on the slabs themselves and so they 

instituted this brushing at some point, which could 

have, even if they continued ventilation, could have 

increased the airborne contamination, again, by 
43

brushing the slabs after rolling. 

Chair Ziemer: Okay, thank you. 

Dr. Mauro: Megan, this is John Mauro. This is a 

question I always ask myself when I have real data 

at AWE sites. 

We rely very heavily all the time on TBD-6000 and 

the look-up tables, and one of the things that always 

interests me, and of course it has no direct bearing 

here so I apologize if I'm --

(Simultaneous Speaking.) 

Mr. Katz: John, can I just interrupt now, though? 

Dr. Mauro: Sure. 

Mr. Katz: Because in this case the Work Group's 

already opined on this one. 

Dr. Mauro: Never mind, I withdraw. You know where 

I was going. 

Mr. Katz: I'm just trying to hang in here. 

Dr. Mauro: Okay. 

Mr. Katz: I'm sorry. 

Dr. Mauro: That's okay. 

Chair Ziemer: So, I think the Work Group has agreed 

to this proposed solution that NIOSH has given, 

SC&A's agreed to it. 

I'll take it by consent that we'll remove the May 1955 

data and use the other three data sets for the intake 

rate for the entire exposure period. Is that agreed to?

(Chorus of yes.)

Chair Ziemer: Okay, thank you. 

Mr. Katz: Great.

Chair Ziemer: I think we're ready for Observation 2. 
44

Ms. Gogliotti: Okay, for Observation 2 our initial 

observation was that there was a sound basis for the 

use of some fraction of uranium concentrations as a 

basis for thorium concentrations when there is no 

thorium monitoring. 

However, we noted that the one-to-one ratio could 

be important for consistency purposes between this 

site and other sites and the ratio was very claimantfavorable. 

And, of course, the bearings on Finding 1, for Finding 

1 being resolved would also impact this issue of the 

amount of thorium. 

Dr. Lobaugh: So, in our review of this Observation 2, 

we just wanted to clarify that the main difference that 

we're seeing here, as we mentioned in the ER and 

mentioned here in this slide presentation that you 

can see, this mass-loading approach was actually 

used at Bridgeport Brass. 

And at Bridgeport Brass the thorium intake rate was 

equal to ten percent of the uranium intake rate.

So, the question was, well, how come we're using a 

smaller number, ten percent, versus one-to-one for 

Superior Steel, which we're assuming?

So, one major difference between Bridgeport Brass 

and Superior Steel was that the uranium and thorium 

were rolled concurrently, meaning on the same day 

using the same processes. So, there might be a 

uranium slab going through and thorium after it, and 

the air sampling would be done during both of those 

rollings. So, the air sampling would maybe be run 

during the whole day.

So, the air sample itself could have both uranium and 

thorium on it, the filter itself could have both uranium 

and thorium on it. So, when it was counted, that 

gross alpha count would have results for both 

uranium and thorium.

So, the major difference in Superior Steel is that the 
45

air sampling we would be using was from air 

sampling that was done only during the uranium 

rolling.

So, the four HASL air sample results that we just 

discussed were only done during uranium rolling and 

we have no evidence that there was air sampling 

done during the thorium rolling.

So, the one-to-one approach here is because we're 

assuming that the mass loading on the air sample 

itself, so the amount of material that would be sucked 

through the filter would be the same regardless of 

what material was rolled when we make corrections 

for the differences in materials as well.

So, the one-to-one that seems different from 

Bridgeport Brass really is because we don't have a 

concurrent result, basically.

We don't have a uranium and thorium result for an 

air sample where we need to make some sort of 

assumption on how much of that air sample result is 

uranium versus how much is thorium.

Here, we know the air sample result is all uranium.

(Simultaneous speaking.) 

Ms. Gogliotti: We understand the need for the ten 

percent assumption at Bridgeport Brass and why 

that's not applicable to Superior Steel, and that's 

simply because they were not processed 

simultaneously.

And I'll point out that all of the HASL studies were 

done prior to the thorium licensing so there's no 

possibility they contain any thorium. And based on 

that, we recommend closing this observation.

Chair Ziemer: Okay, comments, Board Members?

Member Anderson: No, I don't have any.

Member Beach: I didn't have any questions or 

comments and I agree with that.
46

Member Anderson: It's good to have the expanded 

explanation, though.

Chair Ziemer: I think we agree we can close this one.

Dr. Lobaugh: Okay, great.

Ms. Gogliotti: The next observation is Observation 3, 

it has to do with the storage time. I'll just read it for 

you here.

SC&A finds this storage time assumption to be 

inadequate to capture the length of time the material 

was likely found on site. If the site milled uranium 

metals for 500 hours per year, then it is reasonable 

to assume 10-hour milling once per week.

For the 250 pre-rolling and post-rolling hours 

assumption to hold true, uranium metals would have 

to arrive on the day prior to rolling and be shipped 

off the day following rolling. 

And when you look at Table 7-1 in the NIOSH SEC 

ER, it shows that the site roughly had more than a 

day's rolling inventory on site. And during the April 

2019 Board Meeting the petitioner indicated that the 

scrap materials was stored on site for extended 

periods of time. 

Mr. Katz: Excuse me, someone's on the line and is 

whistling and humming. Can you please just mute 

your phone? Press *6 to mute your phone. Thanks. 

Dr. Lobaugh: For our response to Observation 3 we 

did agree, given the petitioner's comments and our 

additional review of the reference documents that we 

have, that this exposure time needed to be changed 

from 500 hours. 

So, the proposed change was to year-round, so 

assuming the total of 2500 hours' exposure minus 

the rolling time for the entire operational period. 

So, assuming that the material could have been on 

site throughout the entire operation period.
47

Chair Ziemer: Thank you. I assume, SC&A, you're 

good with that too?

Ms. Gogliotti: I just want to point out that however 

we resolve Finding 1 will also impact this because 

you're minusing the rolling time, or subtracting the 

rolling time. 

But we, other than that, find the proposed approach 

to be consistent with the likely conditions on the site 

and we recommend closure. 

Member Beach: This is Josie. Paul, I appreciate 

NIOSH's responsiveness to the petitioner's 

comments and I agree with this, to close it. 

Member Anderson: I would agree with that. 

Mr. Katz: Paul, are you there? Maybe you're on mute, 

Paul.

Member Anderson: Whistle if you're still there, Paul.

(Laughter.) 

Mr. Katz: We had whistling before but it wasn't Paul. 

Member Anderson: No, I know. 

Mr. Katz: It sounded like he was having some phone 

problems, he might have just lost his connection 

there. He could be dialing back in.

I don't think we'll find him here, we'll get him back. 

It could be that he's talking to us and doesn't realize 

we don't hear him, in which case this would be a 

clued-in call. 

Member Beach: I don't think there was that much to 

say. He's probably calling back in. 

Mr. Katz: Yeah. 

Member Beach: Hopefully. 

Chair Ziemer: Well, my phone just dropped the call. 

So I'm back now. 
48

Mr. Katz: Welcome back, Paul. 

Chair Ziemer: I hope you closed that final 

observation. 

Mr. Katz: They did, actually. I don't know, where did 

you lose connection, at what point in the discussion?

Chair Ziemer: Just when I said we're ready to close 

on the observation. 

Mr. Katz: Okay, perfect. 

Ms. Gogliotti: All right, so we can move on to 

Observation 4.

Chair Ziemer: Right. 

Ms. Gogliotti: And this has to do with medical 

examinations on site. 

NIOSH was proposing to assign an annual medical Xray every year, basically, and we of course find that 

very claimant-favorable but we question the decision 

to assume an annual medical examination in spite of 

the lack of evidence that there were, in fact, medical 

X-rays performed. 

Just a reminder: the CATI reports don't indicate that 

anyone thought that they had X-rays, but historically 

people worked there over 50 years ago and there 

were very few claimants that were still alive. 

We just pointed out that in recent years the Board 

has made a concerted effort to improve consistency 

between sites and it was unclear if all AWE sites with 

no evidence of examinations received the same 

claimant-favorable assumptions. 

Dr. Lobaugh: In our response -- this is the NIOSH 

response. In our response, we pointed out that the 

proposed assignment of a pre-employment annual 

and termination PA chest X-ray dose was in line with 

our default assumption from OTIB-6. 

When evidence is lacking, we assign the pre-
49

employment, annual, and termination PA chest Xrays. And it also falls from our default assumption 

from ORAU, OTIB-79 when evidence is lacking. 

So, 79 tells us what to do, whether X-rays were taken 

on site or off site and so when the evidence is lacking 

we assume the X-rays were given on site and, 

therefore, the dose is included. 

So, the TBD currently follows this and the ER 

continues that approach, basically. 

Chair Ziemer: And this is basically consistent with 

existing policy? 

Dr. Lobaugh: Yes. 

Chair Ziemer: So, the assignment was made. And I 

think on that basis, we don't need any action. You've 

justified why you've done it and I think let's close the 

observation. 

And SC&A, you're okay with that too, I assume?

Ms. Gogliotti: Yes, we did do some cursory reviews 

just to double-check that. 

We were aware of the guidance of OTIB-6 and OTIB79 but we were more concerned with was that being 

consistently applied over 200 AWE facilities.

So, to investigate, just a really cursory look, I 

sampled ten AWE reviews that we already completed 

for the Subcommittee of Dose Reconstruction 

Reviews and found that all of those reviews were 

consistent.

However, many of them were overestimating claims, 

which would typically assume an annual scan for 

efficiency anyway.

But we didn't want to do a bigger scan or a bigger 

review of that because I think that would really 

require additional tasking.

Based on that, we feel satisfied, unless the Board was 
50

interested in a more detailed review.

Chair Ziemer: I think at this point for this Work 

Group, we just deal with this. Any questions or 

comments, Board Members? 

Member Anderson: No. 

Member Beach: No questions. 

Chair Ziemer: Okay, I think we're good on that, we 

agree that closes Observation 4. I think that's it. Is 

that it?

Dr. Lobaugh: Correct. 

Petitioner Comments/Questions

Chair Ziemer: So, we've closed everything but we 

have an open question on Finding 1 and NIOSH is 

going to follow up on that and give us some additional 

information for future consideration.

So, Ted, I think we're ready to hear from the 

petitioners at this point.

Mr. Katz: Right, so petitioners or a petitioner's 

representative, whoever their pick might be, if you 

would like to comment in any way or have questions, 

now is the time. 

Mr. Stephens: This is Hugh Stephens, I represent the 

Palastros, who are the petitioners in this case, and 

we helped them file the petition. 

We believe that there is significant uncertainty and 

we know that based on a review of Table 7-1. I think 

there are 49 rows on that spreadsheet and of those, 

10 of them have no indication of the number of slabs 

or the number of pounds. 

So, that was a significant amount of uncertainty. I 

think we talked about the idea that there's no real 

indication relative to how much these slabs weigh. 

We know some of them were heavy and some of 

them were light. 
51

So, the usefulness of a number of slabs is certainly 

not without uncertainty. And in fact, the 

uncertainties, as someone mentioned earlier, are 

multiplied against each other and it creates 

enormous amount of uncertainty. 

And we know that because NIOSH and SC&A both 

agreed early on in this process that $54,000, 

somewhere between $40,000 and $54,000 was the 

average of all of the years. 

And then later on we found some site-specific data 

and we learned that was an underestimate, and that 

the real estimate for 1956 was approximately three 

times that estimate. It turned out to be $138,000 

instead of somewhere between 40 and 55. So, we 

had a level of uncertainty where the idea was that 

the upper bound was somewhere in the $40,000 to 

$55,000 range and it turned out to be $138,000. 

So, I think when we were talking earlier about how 

these uncertainties can lead to an uncertainty level 

of two times, I don't think anyone should have any 

difficulty finding that in this record. 

Now, obviously, I represent a claimant whose claims 

have been denied. We'd like to see a Special 

Exposure Cohort. We think that the level of 

uncertainty here would warrant a Special Exposure 

Cohort. 

We seem to be the minority in that regard and we're 

sensitive to that. But I did just want to quote a little 

bit from Page 30 of 55 of the Petition Evaluation 

Report: however, the payments for the other three 

years were all consistently in the range of $40,000 to 

$55,000 based on the rolling data presented in Table 

7-1. NIOSH has no indication that the production rate 

for fiscal year 1956 was significantly different than 

the other years under evaluation. 

And then in the Superior Steel Special Exposure 

Cohort Issues Matrix dated January 14, 2020 on Page 

7, it turned out that the highest billing year, 1956, 

there was $138,246 which represented $217,246 
52

less $79,000 estimated Schedule A reimbursement 

expenses with no credit taken for the slab furnace. 

So, I think one of the issues, this is kind of a moving 

target because we kind of get this information a little 

bit digested and we do our best to understand what 

we have here but it does appear that lots of 

information has been developed over the course of 

this process. 

And we'd love to have access to that, I'm not sure if 

we can have access to it but we would like to have 

access if that's possible. So, that's just one issue that 

we identified as showing that there's a significant 

level of uncertainty here that we believe meets the 

SEC criteria, which is insufficiently accurate. 

We think this is a reasonable method of performing 

dose reconstructions but it also can be described as 

sufficiently accurate in a claimant-favorable program 

like this one. 

And the other issue that we have is with respect to 

this sampling. There's another facility I believe in 

western York where certain measures were 

implemented to reduce the amount of airborne 

contamination. 

And we have that here, it appears, but then it sounds 

like there were other issues that caused, the brushing 

I believe caused, the exposure to go up. 

So, while the exposures decreased, they also 

increased. I think this also shows a level of 

uncertainty. And the sampling is done in years where 

the level of processing is much lower. 

1956 is the year when they're doing the most 

processing and yet there's no sampling during that 

year. 

In any event, these issues, the novel use of surrogate 

data, we are troubled by all of these issues and 

believe that a Special Exposure Cohort should be 

established. 
53

But in light of NIOSH and SC&A, who all appear to be 

in agreement, there's no need for Special Exposure 

Cohort here. We just have to agree to disagree on 

that. 

But with respect to the level of uncertainty, we think 

it rises to the level of a Special Exposure Cohort. 

But one way or another, this idea that we have 

enough information to reduce the number of hours to 

250 seems a gross underestimate of the level of 

uncertainty that we're dealing with, at least to us. 

And with that, I'll ask if Mr. Palastro -- John Palastro 

is on the line and I'll ask if he has any comments to 

add. 

Mr. Palastro: Yes, I do in a couple areas. One is the 

storage of scrap. They would have a train car in there 

and it couldn't leave until it was full. 

So, they probably put all types of scrap in there. The 

other one is that uranium is run on a conveyor and 

there's a certain amount of shale that falls off of it 

and it falls through the conveyor, and that stays there 

until it's time to clean out under the conveyor. 

And I can't tell you how often they clean down there 

but I know it wasn't every day. It was probably once 

a month. And there's residual radiation that would 

have been in the mill all the time. 

I also want to tell you one other thing. When it goes 

to the shears, there wasn't some automated machine 

that puts the crop in there if it's uneven when it's 

rolled.

It was a roller that pulled it off with a big pair of 

shears and stacked it up, and that stack was sitting 

there pretty close to them all along while they were 

rolling out the steel and once it got full they came 

over and took it and put it in the cart, which stayed 

right there. So, you've got a lot of radiation there that 

I think you forgot about. 
54

That's all I have to say.

Path Forward

Chair Ziemer: Okay, thank you, Hugh and John, for 

those additional comments, particularly the concern 

about uncertainty. We'll be visiting that issue on the 

number of hours from our discussion. 

So, that will be on down the line when we get that 

additional information back from NIOSH. I want to 

look here at the path forward. Ted, I understand we 

need to go to the Board on the petition action? 

Mr. Katz: We do. There's not a whole lot of work left 

for the Work Group really. 

The remaining issue on hours is a TBD issue and it 

sounds like it can get reported out to you in pretty 

good time, and I think they could really probably 

report out to you in a White Paper or memo to you 

and then we'll discuss that at the Board Meeting. 

I think it's probably reasonable to expect this would 

be ready for the April Board Meeting to be on the 

agenda, unless you have any concerns about that. 

Chair Ziemer: We could certainly bring to the Board 

Action on the petition itself at the Board Meeting. 

Mr. Katz: Yes, we haven't made a motion on the 

petition in its entirety but you've made a motion 

basically that's feasible so you've made a motion that 

corresponds to the findings that would have been 

related to our basis to add a Class. 

Chair Ziemer: If we need to formalize that, I'll simply 

ask the Subcommittee if we could have a motion to 

recommend to the Board that the SEC be denied. 

Mr. Katz: Or just a motion that dose reconstruction 

is feasible for the period in question.

Chair Ziemer: What's the correct motion for the 

Board?
55

Mr. Katz: That you concur with NIOSH's 

recommendation that dose reconstruction be found 

to be feasible for the period covered by the petition. 

Chair Ziemer: Will somebody so move that?

Member Anderson: So moved. This is Andy.

Member Beach: Second. 

Chair Ziemer: Okay, thank you. Any further 

discussion for the Board Members? Okay, Henry, you 

moved it, Josie seconded it?

Member Beach: Yes. 

Chair Ziemer: Okay, you're both voting aye?

Member Anderson: Yes. 

Member Beach: Yes.

Chair Ziemer: It's been moved and seconded and I'll 

vote aye, so we have a motion for the Board. Thank 

you. 

Mr. Katz: And Paul, I guess the last thing I would ask 

is what's the lead time for this? I don't know if it 

would be good for either SC&A or Megan to prepare 

a presentation. Megan, you prepared the 

presentation for this. Whatever your preference is in 

this case.

Often, SC&A prepares the presentation but you've 

already prepared the presentation for this so 

whatever your preference between the two of you. 

Chair Ziemer: I think it would be probably simple for 

NIOSH, Megan, you could make the presentation 

based pretty much on what you covered today, right? 

Dr. Lobaugh: So, I should point out, I will be able to 

prepare the presentation.

I don't know that I will be able to -- well, I know I 

will not be able to travel to the Board Meeting 

because I'm expected to have a baby in April. So, I 
56

won't be at the meeting but I think someone could 

present on my behalf, if you would like NIOSH to 

present. 

Mr. Katz: Or Paul, you often do your own presenting 

for these. It's up to you. 

Chair Ziemer: If Megan's in agreement, I'll utilize 

what she has and prepare something from that. 

Mr. Katz: I think Megan could prepare it for you and 

--

(Simultaneous Speaking.) 

Chair Ziemer: Are you okay with that, Megan?

Dr. Lobaugh: Yes, that's fine with me. 

Chair Ziemer: Okay, let's do that. 

Mr. Katz: That sounds great. And then, Megan, 

please, run that by Rose so that she has a chance to 

review it. 

And copy the Work Group when you do that and the 

Work Group will have a chance to review that 

presentation too. 

Dr. Lobaugh: Great, will do. 

Mr. Katz: And again, there's lots of time for that, 

there's no rush on that because we'll talk about April 

22nd Board Meeting. 

Chair Ziemer: It's almost three months.

Mr. Katz: Yes. We're hardly ever this well prepared. 

Paul, I think we're finished today with today's 

meeting's business. 

Thank you, everybody, and a special thanks to Hugh 

and John for joining us for this meeting, and I'm sure 

you'll want to join us in April for the Board Meeting. 

Paul and Josie and Andy, could you call back in on 

this line in about five minutes? 
57

Chair Ziemer: Sure. 

Member Beach: Yes. 

Mr. Katz: Okay, thanks. 

Adjourn

Chair Ziemer: Thank you, everybody. We'll declare 

the meeting adjourned. 

(Whereupon, the above-entitled matter went off the 

record at 3:13 p.m.)