1

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH

+ + + + +

WORK GROUP ON TBD-6000

+ + + + +

WEDNESDAY

DECEMBER 14, 2016

+ + + + +

The Work Group convened via 

teleconference at 3:00 p.m. Eastern Standard 

Time, Paul L. Ziemer, Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chair

JOSIE BEACH, Member

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
2

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

ALSO PRESENT:

TED KATZ, Designated Federal Official

BOB ANIGSTEIN, SC&A

DAVE ALLEN, ORAU Team

BOB BARTON, SC&A

PATRICIA JESKE

JOHN MAURO, SC&A

DAN McKEEL

JIM NETON, ORAU Team

JOHN RAMSPOTT
3

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

Contents

Welcome and Roll Call ............................ 4

Agenda Discussion ................................ 6

SC&A Review of Appendix BB, Rev 02 ............... 8

NIOSH Responses/SC&A Reply ....................... 8

Other Comments .................................. 36

Path Forward/Plans for March Board Meeting ...... 48

Adjourn ......................................... 49
4

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

P-R-O-C-E-E-D-I-N-G-S

(3:00 p.m.)

Welcome and Roll Call

MR. KATZ: So welcome everyone. 

This is the Advisory Board on Radiation and 

Worker Health, TBD-6000 Work Group. And the 

Work Group is addressing GSI only today.

MR. RAMSPOTT: Hey, Ted, is Dan 

McKeel on the line?

MR. KATZ: I'm going around, I doing 

roll call, John, so we'll get there.

MR. RAMSPOTT: Okay.

MR. KATZ: Yes, I imagine he will be. 

Anyhow, the meeting today, the materials for 

the meeting, most of the materials for the 

meeting and the agenda, they're posted on the 

NIOSH website, schedule of meetings, today's 

date. You can go there and pull those up and 

follow along with the documents that are being 

addressed.

One of the latest document from 

SC&A, which is a response to NIOSH's response 
5

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

to SC&A's review, has not been posted yet. 

Although I did email it to John. And Dan and 

Patricia, I'll send it to you just as soon as I 

have my hands free so that you have too. So 

that's a memo from Bob Anigstein basically, 

from SC&A. So that covers that.

I have all the Chair, Dr. Ziemer and 

the Members, Josie Beach, Wanda Munn, and Dr. 

Poston, John Poston are all on. None of them 

have conflicts with this work site. But let me 

do roll call for NIOSH and SC&A, and cover that 

when you respond, starting with the NIOSH ORAU 

team.

(Roll Call)

MR. KATZ: Dr. McKeel, welcome. And 

I don't know if you heard earlier, Dan. I 

emailed you a document that you probably didn't 

receive, and it hasn't been posted yet. That 

came in on Friday.

DR. McKEEL: Okay.

MR. KATZ: And that is the SC&A memo 

from Dr. Anigstein responding to Dave Allen's 
6

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

response to the SC&A review.

DR. McKEEL: Ah, okay.

MR. KATZ: The appendix, okay. And 

that should be in your emails. And I 

apologized about its late coming.

Okay, so I think that covers all the 

preliminaries. Everybody -- Bob, let me note 

that however you're speaking right now, you're 

very remote and hard to hear, so when you do 

speak, you'll need to either use your headset 

or some other arrangement.

But otherwise everyone, mute your 

phones except when you're speaking. Touch *6 if 

you don't have a mute button on your phone to 

mute your phone. You press *6 again, and that 

will take it off of mute. But that will help 

everyone.

And Paul, it's your agenda.

Agenda Discussion

CHAIR ZIEMER: Okay. I want to 

check first and see how my connection is. Am I 

clear, or am I echoing?
7

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

MR. KATZ: You're not echoing, 

there's a little bit but you're not bad. 

You're perfectly fine for listening to.

CHAIR ZIEMER: Okay. I was going to 

ask you, and I think you answered the question. 

The SC&A memorandum of December 9th, I had 

checked the website this morning, and it was 

not on. That's the one you were talking about, 

that --

MR. KATZ: Yes. That's your update, 

that's --

CHAIR ZIEMER: -- was not received. 

Yes, okay.

MR. KATZ: That's correct, Paul.

CHAIR ZIEMER: Okay. So, the other 

documents, we have the SC&A review of Appendix 

BB, Rev 2. And we have the NIOSH comments; 

those were dated November 4th. NIOSH response 

to the review of Appendix -- of Rev 2. And 

then we have this recent response by SC&A, 

response to NIOSH.

Now, so what we'll do, I don't 
8

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

think we need to go through the Appendix BB, 

Rev 2 specifically. But I think Bob Anigstein, 

you may want to just highlight sort of the 

bottom line on your review. Particularly with 

respect to Issues 1 and 10.

DR. ANIGSTEIN: Okay. First of all 

I have the Live Meeting, does everyone have 

Live Meeting?

MEMBER MUNN: Yes.

DR. ANIGSTEIN: You can see my first 

page?

MEMBER MUNN: Yes.

SC&A Review of Appendix BB, Rev 02

NIOSH Responses/SC&A Reply

DR. ANIGSTEIN: Okay, so I'll start 

with that. This is a brief summary. And by 

the way, I have -- there are two ways of doing 

this. There's only a couple of findings where 

we have some question about, actually just one. 

And I was wondering whether, should I go 

through all ten findings and then let Dave 

Allen respond? Or should I just go -- shall we 

handle the findings one at a time?
9

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

CHAIR ZIEMER: Well, I'll ask the 

Work Group this question, but Findings 2 

through 9, basically you had indicated earlier, 

and we all saw that, that you were satisfied 

with the NIOSH response to those original 

findings.

So I wouldn't -- we may want to 

formally close those as the Work Group, and we 

do that. I would just as soon do it as a group 

unless somebody objected. But basically I 

think SC&A was satisfied with NIOSH's response 

to 2 through 9.

DR. ANIGSTEIN: Yes.

CHAIR ZIEMER: But let me ask the 

Work Group Members. Do you want to 

individually go through those?

MEMBER MUNN: No, I think it had 

been our expectation. We'd gone through them 

many times, and it was certainly my expectation 

that we would agree with the --

MEMBER BEACH: Wasn't there some 

question on 1 also, 1 and 10?
10

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

MEMBER MUNN: No, 1 and 10 were the 

two open ones.

CHAIR ZIEMER: Yes, 1 and 10. I'm 

just talking about 2 through 9 right now.

MEMBER BEACH: I'm sorry, I thought 

you said 1 too. Okay, I'm good.

CHAIR ZIEMER: I meant 2 through 9. 

I know that SC&A considered those closed, and

if we want to formalize that, I guess we could 

ask the Work Group if we'd like to make a 

motion to agree with SC&A's recommendation that 

those be closed.

MEMBER MUNN: I would be pleased to 

accept SC&A's recommendations for Findings 2 

through 9, that they now be closed.

CHAIR ZIEMER: Second.

MEMBER BEACH: I'll second that. 

This is Josie. I agree.

CHAIR ZIEMER: Discussion.

(No audible response)

CHAIR ZIEMER: Okay, all in favor, 

aye.
11

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

(Chorus of aye.)

CHAIR ZIEMER: Okay, ayes have it. 

So we're going to concentrate on 1 and 10 then, 

Bob.

DR. ANIGSTEIN: Okay. I'll skip 

over some of my slides.

MR. KATZ: And Bob.

DR. ANIGSTEIN: Yes.

MR. KATZ: This is Ted. Just please 

keep in mind that the Live Meeting is only 

available for Agency.

DR. ANIGSTEIN: I understand.

MR. KATZ: Okay, thanks.

DR. ANIGSTEIN: I understand, so I'll 

go over it unless, well I have an email if it 

would be deliverable. I didn't -- I knew it 

wouldn't be posted in time, so we didn't do 

anything with it.

MR. KATZ: Well, no, I mean Live 

Meeting is not like --

DR. ANIGSTEIN: Okay, I'll discuss 

it unless you want to take a minute out, I 
12

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

could email it to you, and you could pass it 

on, if that's --

MR. KATZ: I'm happy to do that. I'm 

just, all I'm saying is please, just verbalize 

what you're discussing.

DR. ANIGSTEIN: Okay.

MR. KATZ: But please do send me the 

presentation so that I can also share it and we 

can have --

DR. ANIGSTEIN: Yes, afterward.

MR. KATZ: Yes.

DR. ANIGSTEIN: So we can share, 

okay, I'll do that.

Okay, well Finding 1 -- okay now 

this goes through two iterations here. So we 

start off with Finding 1, which was the 

original finding on the Appendix BB. And that 

is that in the Rev 2 -- Dave Allen has made a 

response, but I'm just, now, I'm speaking about 

the original document Appendix BB regulatory 

guidelines now.

That on the neutron dose rates, the 
13

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

dosimetric quantity was not specified. There's 

more than one type of dose. However, the 

values that were posted correspond to the 

calculated values for the ambient dose 

equivalent, which is known as H*(10). So those 

are -- that just needs to be stated, but the 

numbers are okay. They are the ambient doses 

equivalents.

However, the more significant issue 

is that there's a recommendation or an 

instruction in -- I'm just going to say 

Appendix BB, you know I won't keep repeating 

Rev 2, but I'm referring to Rev 2. There is a 

recommendation in the Appendix that all the 

neutron doses be treated as if they had 

energies in the range of 0.1 to 2 MeV, 100 keV 

to 2 MeV. And that was something that was 

noticed late, I noticed when reviewing Rev 2, 

and I checked to see is this really claimantfavorable?

And so this is by the way, out of 

the memo that was sent in response Rev 2, so 
14

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

that one is posted on the web. So this table 

that I'm going through that I'm discussing now 

is also in the memo for those people who don't 

have access to Live Meeting. And what I've 

listed here is, there are four energy ranges. 

There are really five energy ranges. There's 

one, a fifth one is above 20 MeV, but in these 

scenarios, there are no neutrons above 20 MeV.

So there are four energy ranges. 0 

to 10 keV, 10 to 100 keV, 100 keV to 2 MeV, and 

2 to 20 MeV. And according to this, if you 

take the doses from the uranium radiography, 

and these are in millirem per shift, and 

they're listed here. I won't read all of them.

And then there's also the uranium 

handling, which could be added here, because 

these are both exposures to the betatron 

operator, and however many shifts per year, 

it's the same. There are a few doses, in each 

shift there is an exposure to uranium 

radiography when he's in the control room and 

the betatron is irradiating the uranium slice. 
15

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

And then the handling of the uranium afterward, 

up for the next shot.

So these can be added together. And 

when you add them together for each energy 

range and then multiply by the dose conversion 

factor, for that energy range, for the lung. 

I'm just using the lung as an example. It's a 

very common, lung cancers are among the more 

common ones which are being, where dose 

reconstructions are made. So it just makes 

sense to use that as an example.

And if these are all added together, 

which you take the product of the uranium dose 

rate per -- uranium dose per shift and multiply 

by the dose conversion factor for that 

particular energy range. So under lung is the 

actual dose to the lung for those calculated in 

that manner.

So the total comes out to 

approximately 1.9 millirem per shift, dose to 

the lung. However, if you use the NIOSH 

method, where you simply add all of the doses, 
16

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

regardless of the energy, with all of the 

H*(10) doses (They are the external doses not 

to the organ but to the body)_ and then 

multiply it by the dose conversion factor for 

the 0.1 to 2 MeV neutrons, you only get 1.3 

millirem per shift.

So there is a difference of 45 

percent. So doing it by breaking down, by 

taking the breakdown of each energy range and 

multiplying the appropriate dose conversion 

factor by the neutrons in that energy range, 

you end up with a 45 percent higher dose to the 

lung than if you use the NIOSH method of using 

only a single dose conversion factor, assuming 

everything is in one energy range.

And then something similar happens, 

but a bit different. The betatron operator 

doing steel radiography, where he gets exposure 

from the neutrons in the control room. Once 

the steel is radiated, it doesn't give off 

neutrons, at least not -- if it does, they're 

extremely short lived. And by the time the 
17

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

operator gets there, they're all gone.

And there you get a 37 percent 

increase by doing it in the more detailed way, 

by breaking it down. And then finally, the 

layout man, who gets the stray radiation from 

the betatron when he's out there in Building 

10, working on the next casting, there's a 20 

percent difference. So, that's why we object 

to the NIOSH method.

And then, I don't know, shall we 

wait for Dave to make a response to that, or 

shall I just go on to the next Finding?

CHAIR ZIEMER: Let's stay with this 

Finding for now.

MEMBER POSTON: This is John. I 

have a question before you move on. Hello?

DR. ANIGSTEIN: Hello. What is it 

John?

MR. KATZ: John, we can hear you, go 

ahead.

MEMBER POSTON: Well, I wasn't sure. 

Would you give me those numbers again, just the 
18

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

first set. I mean, I know you can ratio 

anything to anything, but I thought those were 

pretty low numbers regardless of what you --

DR. ANIGSTEIN: I'm, one second. I 

just switched phones and am having a little 

trouble hearing. Could you ask the question 

again?

MEMBER POSTON: Sorry.

DR. ANIGSTEIN: I could hardly -- I 

didn't hear the last question.

MEMBER POSTON: The question is, 

it's not a question, it's a request. Would you 

read the two numbers that you began with for 

the dose evaluation for the first worker, 

whenever he was in the control room?

DR. ANIGSTEIN: Okay the numbers for 

the betatron operator -- is this -- am I clear 

now?

MEMBER POSTON: No, you're pretty 

low. I can hardly hear you.

DR. ANIGSTEIN: I have a problem 

with either -- I have two phones and neither --
19

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

one, I don't hear one well, and the other one 

is both. Okay I'm going to go back to the 

phone where I'm more audible.

But you guys are going to have to 

speak up louder for me to hear you on this 

phone. Anyway, on the -- I'm not quite sure 

where I should start again. There four energy 

ranges. And I listed the lung dose conversion 

factor. Those are out of the document, IG-001, 

OCAS-IG-001. And each DCF, the 0 to 10 keV 

range, the 10 to 100 keV, 0.1 to 2 MeV, and 2 

to 20 MeV.

So Ted, if you have the memo that 

was the original review memo from, I forget the 

date on it now, but it's definitely posted, the 

table is there. The table is taken right out 

of there.

MEMBER BEACH: Do you have that?

DR. ANIGSTEIN: And if you take for 

each of these energy ranges those conversion 

factors for the lung and multiply it by the 

total dose, the H*(10) dose, which is basically 
20

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

the dose at the surface of the body, and you 

take each of those dose rates, which were 

calculated with our computer model, our MCNP 

Model, and you multiply it by the dose 

conversion factor, you end up with a total --

maybe this is what you're after -- with a total 

dose to the lung of 1.942 to be precise, 

millirem per shift.

MEMBER POSTON: It's too precise by 

the way.

DR. ANIGSTEIN: This is of course 

multiplied by the number of shifts spent on 

uranium handling, which differs year by year 

during the covered period. That's why we do it 

per shift. Then it's easy to do it per year by 

just multiplying the number of years in all the 

shifts.

Whereas, the NIOSH method that 

assigns all of the neutron energies to the 0.1 

to 2 MeV range gives you 1.343 millirem per 

shift. So the difference between the two is 45 

percent. In other words the, doing the 
21

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

breakdown by individual energies gives you a 45 

percent higher dose than by assigning all of 

them to this 0.1 to 2 MeV energy range.

And so jumping ahead, the 

explanation would be that if you inspect the 

dose conversion factors for the different 

energies, for the lung, the 0.1 to 2 MeV is 

actually the lowest of the four. Of the dose 

conversion factor for each energy range, 0 to 

10 keV, 10 to 100 keV, 0.1 to 2 MeV, and 2 to 

20.

So the 0.1 to 2 is actually the 

lowest, so it's not too surprising that if the 

doses are spread out among those four energies, 

that assigning all of them to the 0.1 to 2 

can't help but be claimant-unfavorable.

Does that clarify?

CHAIR ZIEMER: John, are still on? 

So John had the question.

MEMBER MUNN: We're not hearing you, 

John. You must be on mute.

MEMBER POSTON: Okay, sorry. Well, 
22

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

I mean from a dosimetric standpoint, whether 

it's 1.9 or 1.3, they're still very low doses. 

And probably the errors associated with those 

are pretty high.

DR. ANIGSTEIN: Well --

MEMBER POSTON: So they would 

probably be in the same cohort or whatever you 

want to call them. I mean to say that, to 

start quoting 45 percent difference in tiny 

little numbers is just, I don't think it's 

appropriate in these kinds of situations. But 

the errors in some of these calculations are 25 

to 50 percent themselves.

DR. ANIGSTEIN: Well, no, the error 

in the calculation, I mean if you accept the 

model, the error in the calculation is only the 

Monte Carlo statistics.

MEMBER POSTON: No, that's not true. 

That is not true, Bob.

DR. ANIGSTEIN: No, now wait a 

second, I respectfully disagree. John, I'm 

being, possibly we're talking about two 
23

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

different things. I'm saying the error in the 

calculations, per se, because we have a model 

where we have the model of the betatron, the 

model of the radiation coming out of the 

betatron. We have the model of the human body, 

but that's already in, that's built into the --

this is basically, the dose conversion factors 

are basically based on the MCNP method of 

translating the neutron fluence into this 

quantity H*(10). The ambient dose equivalent.

That's straight out of ICRP 74. Now 

again, there may be some approximations there, 

but that's the official guidance that was being 

used.

MEMBER POSTON: Yes, well, that's 

not what I'm talking about, Bob. What I'm 

saying is you're trying to make a significant 

difference between two very small numbers. And 

I know from -- a fact from running Monte Carlo 

codes all my damn life, that the error in some 

of these Monte Carlo codes, because we don't 

the cross sections precisely -- in some cases, 
24

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

we don't know the cross sections at all. The 

error can approach 50 percent or even more. So 

I just don't --

DR. ANIGSTEIN: I see. So you're 

saying that there is a, that the data that goes 

into the calculations has errors, and I can't 

speak to that. I'm simply accepting --

MEMBER POSTON: Well, see the people 

typically run these codes, and what they use as 

the error associated with the calculation is 

based on the number of histories. That has 

nothing to do with the errors that are in the 

process --

DR. ANIGSTEIN: I understand.

MEMBER POSTON: -- and all the other 

things.

DR. ANIGSTEIN: Right. I 

understand. By the way, however to keep --

this is per shift. Now the shift, this gets 

then multiplied by the shifts per year. So we 

have as many as 50 per year. For instance, 

during the -- I'm just looking. During the 
25

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

first five years, there's 437 work hours 

assumed to be spent on uranium. So you divide 

that by 8, and you get approximately 50, a 

little over. You get a little over 50 shifts. 

So even though 1.9 may be a small number, that 

comes out to 50 shifts. So let's call it 2 

rounded up. So that's about a hundred millirem 

per year.

MEMBER POSTON: Yes, and so what?

DR. ANIGSTEIN: And for the 

neutrons, that's more significant.

MEMBER MUNN: Which is still a very 

small number.

CHAIR ZIEMER: Yes, I see that.

DR. ANIGSTEIN: A couple hundred but 

-- all right, I won't dispute that, these are -

-

MEMBER POSTON: I don't think we 

ought to make such a big deal out of it because 

it's a small dose. And you could take, you 

could round it to 2 if you want, and that's a 

hundred millirem per year. That's well, well, 
26

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

well if you have a good radiation safety 

program, I would say.

DR. ANIGSTEIN: Yes.

CHAIR ZIEMER: Well, let's hear what 

NIOSH's response involves.

DR. ANIGSTEIN: Again, it's a jump 

ahead. NIOSH has accepted this and made a 

change.

MEMBER POSTON: Well, that's fine 

for them to accept it because it's not worth 

arguing about. I mean, I'm trying to do --

DR. ANIGSTEIN: I --

CHAIR ZIEMER: John, Dave, what's 

NIOSH's bottom line on this?

MR. ALLEN: Well, in our response 

dated November 4th, we said we agreed that was, 

that should not have been the energy range that 

we used. And we recommended 2 to 20 MeV range 

as a favorable assumption and just still using 

everything as one energy category, not breaking 

it down into four separate numbers for IREP.

Since then, in that new response, 
27

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

Bob pointed out that that energy range for a 

few organs still isn't favorable, and he 

recommended essentially the less than 10 keV 

range, and we're willing to accept that too. 

We just want to use a single number and not use 

four different numbers for each year because 

it's such a small piece of the total dose.

CHAIR ZIEMER: Right, and the 0 to 

10, as I understood it had a lot more impact 

into the, I guess in this case you'd call it 

the most claimant-favorable number. Is that 

correct?

MR. ALLEN: Yes, that ends up being 

the most favorable. I wasn't interested in 

getting the most favorable, just one that would 

be favorable from the four categories added. 

And I thought I had that.

But Bob pointed out there was a few 

organs it wasn't favorable for. So that's why 

I'd just as soon take Bob's thought on that 

last memo and use the total neutron number. 

And use the less than 10 keV DCF on that 
28

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

number.

CHAIR ZIEMER: And that should take 

care of it, right?

MR. ALLEN: Right, that should be 

favorable to all organs.

DR. ANIGSTEIN: All right, use which 

one? Which DCF?

MR. ALLEN: The less than 10 keV.

DR. ANIGSTEIN: Right, right. Yes,

that would be -- that would absolutely take 

care of every organ because that's the highest. 

That's simply the highest of the four dose 

conversion factors for the lung. And probably 

for the other organs also. So as long as 

that's agreed, then the issue can be, we would 

recommend the issue be closed.

CHAIR ZIEMER: And that's, Dave, 

that's what you're planning to do then? Is 

that correct, so we understand it?

MR. ALLEN: Yes, that's what I'm 

planning to do.

CHAIR ZIEMER: Done. And I think, 
29

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

Bob, from the modeling point of view, that 

takes care of the issue you had. I think, 

John, either way, you're talking about the 

actual practical error, but it's a very, very 

small number in either case. Are you willing 

to accept the NIOSH proposal to use this one 

that is sort of the higher of the model 

numbers?

MEMBER POSTON: Yes, I'm willing to 

accept it, but I just think we need to, you 

know, we keep talking about favorable --

CHAIR ZIEMER: I doubt you'd see the 

difference in probably any of the cases, in 

essence.

MEMBER POSTON: So what does 

favorable mean? Does that mean the highest 

dose? Is that what we're trying to get at? Or 

are we trying to get a realistic estimate, you 

know? What does favorable really mean in this 

context where we have differences of opinion?

CHAIR ZIEMER: Yes, well they're 

recommend -- they're using this particular 
30

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

model, so given the fact that in the real 

world, the model is still an approximation, I 

think the proposal to use the model that gives 

the highest of the approximations, rather than 

going through the detail on every one and using 

all the four energy bands, and looking at them 

individually, since --

MEMBER POSTON: I understand, and I 

agree.

CHAIR ZIEMER: Yes.

MEMBER POSTON: I just had to get my 

thoughts in there because it's always bothered 

me about some of these things.

CHAIR ZIEMER: Yes. I want to, 

before we actually take action, I do want to 

give the petitioners, and I'm going to call on 

Dan McKeel, a chance to have input. I don't 

want to close everything because -- if the 

petitioners have input. So Dan do you have 

comments on this particular issue?

DR. McKEEL: Sorry, Paul. This is 

Dan. No issues on Issue 1. I have no 
31

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

questions, no problems.

CHAIR ZIEMER: Thank you. So can I 

hear a motion on this? Do you accept the final 

agreed to position of NIOSH and close?

MEMBER MUNN: Yes, so moved.

CHAIR ZIEMER: And seconded?

MEMBER BEACH: I'll second it, Paul.

CHAIR ZIEMER: Yes. Okay, any 

further discussions?

(No audible response)

CHAIR ZIEMER: All in favor, aye.

(Chorus of aye.)

CHAIR ZIEMER: Closed -- or noes, 

let’s see. Okay, that one's closed, I think. 

Now let's move to Issue 10. And I think this 

one is ready to close also. This was pretty 

minor. Bob, what comments do you have on Issue 

10?

DR. ANIGSTEIN: Okay. Issue 10 was 

just a matter of wording. The BB was -- the 

Appendix was not clear. It did say that we 

agreed that the dose was 10.225 rads per day --
32

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

year, sorry. And that number was agreed on, 

but the wording did not clarify what that was. 

That could be, again, more than one dosimetric 

quantity.

And we agreed, and that was the 

agreed upon value for the air kerma. But it 

was not identified as air kerma. And then the 

other thing was that the energy was given as 

the range less than 30 keV. When actually in 

our hypothetical model, we were trying to find 

a way to explain why it is that the -- very few 

of the badge readings were over 10 mR per week.

And yet, there was this report by 

this former employee of one firm that the 

betatron continued to give off radiation after 

it's shut down. So we simply hypothesized the 

worst situation. And that would be that the 

radiation is exactly 30 keV, and then this is 

the end, and then it comes from the back, and 

this is the amount that will be absorbed by the 

body and would not cause, it would be the 

lowest limit of detection, of 10 millirem per 
33

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

week.

So anyway this is how this number 

got derived, it was discussed at another Work 

Group, several Work Group meetings, you know, 

but I won't go into the details. So the 

hypothesis is that it's not less than 30 keV; 

it's exactly 30 keV taken into that. And so 

the DCF value should be specified.

Then I believe that if I can jump 

ahead, my last slide, if it's okay by Dave, the 

response paper, NIOSH response paper resolved 

this. So this is now basically, it's a matter 

of text revisions.

CHAIR ZIEMER: Right. And I think 

NIOSH has agreed that textual -- or change in 

the text can clarify that issue, correct? 

Dave, that's correct, right?

MR. ALLEN: I think so. You're a 

little bit gullible, but I think said it. It's 

just a text change, and yes, that's correct.

CHAIR ZIEMER: So, and you agree to 

that, and NIOSH is recommending closure on this 
34

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

one. Correct?

MR. ALLEN: Correct.

CHAIR ZIEMER: So, Work Group are 

you ready to close this?

MEMBER MUNN: Yes.

CHAIR ZIEMER: And then I wanted to 

ask if the petitioners have any questions on 

this item?

DR. McKEEL: Thank you, Dr. Ziemer. 

This is Dan McKeel. No, I have no questions.

CHAIR ZIEMER: Good, thank you. 

Then motion to close.

MEMBER MUNN: So moved.

CHAIR ZIEMER: Second?

MEMBER BEACH: Second.

CHAIR ZIEMER: All in favor, aye.

(Chorus of aye.)

CHAIR ZIEMER: Okay, thank you. 

Then we've closed the Issues on Rev 2. I guess 

Dave, this means that there will be a Rev 3 

with these minor changes in it?

MR. ALLEN: Yes, and I, in my 
35

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

original response to this, I think it's the 

last page shows where it's essentially three 

changes. They are already the same, with the 

exception that the neutron range at the end 

there will now change from what I'd recommended 

in that paper.

CHAIR ZIEMER: Right.

MR. ALLEN: And it's a small change, 

but we do have a review cycle, and it is a 

holiday type of season. So we'll get it as 

soon as we can. 

CHAIR ZIEMER: Three, and then we'll 

have to take a look at them, is that how it 

goes? 

MR. ALLEN: Yes. 

DR. McKEEL: Dr. Ziemer, this is Dan 

McKeel.

CHAIR ZIEMER: Sure Dan, go ahead.

DR. McKEEL: I may have 

misunderstood you, but I do have three brief 

comments to make about --

CHAIR ZIEMER: What in the --
36

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

DR. McKEEL: -- Appendix BB, Rev 2.

CHAIR ZIEMER: Sure.

DR. McKEEL: Is it possible for me 

to make those? They're not about Findings 1 or 

10?

CHAIR ZIEMER: No, that's quite all 

right. Go ahead.

Other Comments

DR. McKEEL: All right. The first 

one maybe Dave Allen could answer for me 

quickly. In the section of the version 

description boxes, which seems to me is a very 

useful area of the Site Profile documents, 

because it tells what are the changes from Rev 

-- in this case, Rev 2 to Rev 1.

And the way it's worded is that the 

version is simply a response to issues raised 

by the Work Group, and that is not very 

helpful. What doses increased; what doses 

decreased? So my question is can Dave Allen or 

Dr. Neton please identify that for me, unless 

it's very complicated. In Rev 2 of Appendix 
37

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

BB, what doses will increase, and what doses 

will decrease?

And I cite the relevance of this in 

that, I have previously gotten the 

developmental dose reconstruction reports for 

all 196 GSI cases under PER-057. And when I 

plotted those out, and I have in those reports 

the pre and post PER total doses, photon doses 

in millirems -- in rems, sorry. And then the 

pre and post PER Probability of Causation.

And it was interesting to me that of 

the 196 cases, you know 100 were flagged as 

being probably compensable.

But of the people who were not 

compensable, the other 96 on that list, twelve 

of them fell between POCs of 40 and 44 percent. 

Five more were between 44 and 47 percent. And 

another five fell between 47 and 49.9 percent. 

So there are, you know, 10 to 22 cases that are 

very close to the lines that might be affected

by the new PER, or -- and the new PER would be 

calculated based on Rev 2 of the Appendix.
38

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

So my question for today is, is it 

possible to even modify that section and update 

it? Because that doesn't usually happen until 

the next appendix rev comes out. Or just 

somehow put on the record today, from Appendix 

BB, what's been agreed to and these ten 

Findings and so forth, from BB Rev 2, what 

doses will change compared to Rev 1?

MR. ALLEN: Well, this is Dave. 

That section of the -- it's a standard template 

section on essentially why we created a 

revision. And it is nice if we can put in what 

the changes are in that, in the document. But 

once they get beyond just a few pages, we 

generally don't try to spell it all out there, 

or you end up with the whole appendix in one 

little box of the table.

So what I did there was simply put 

down, incorporated resolutions from the 

Advisory Board, which if you really want to see 

those, then that points you to our -- that can 

take you to our website with all the 
39

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

discussions and different reviews and responses 

and transcripts to see what all the different 

changes might have been.

This is intended just to be a small 

summary, and once it gets too big, all I can do 

is point you to where all the discussions are.

DR. McKEEL: Yes, for example, you 

know, all I can tell you is I think I'm pretty 

familiar with all those Site Profile documents, 

and the changes and so forth. And it was 

difficult, it is difficult for me to identify 

what changes, the big changes I'm talking 

about, the major changes that will increase 

dose. And possibly push those 22 people above 

the 50 percent compensation mark.

And I have looked at lots of other 

documents of this type for other sites, and I 

can just say that that table is often expanded 

to include four or five or six specific things 

that have changed. And so I hear what you 

said, but for example, I think one new part is 

the betatron operators are given credit for the 
40

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

gamma radiography that they also performed and 

so forth, so anyway.

Then I wanted, the main comment I 

wanted to make today though is about the use 

and the handling of the 1952 data. And this 

applies to all three documents: Rev 2, SC&A's 

review of it, and NIOSH's comments about it. 

There are many tables in all those documents 

that include the year 1952.

And as far as I can tell, in every 

single case, the 1952 data, as recorded by 

NIOSH, is a simple back-extrapolation from 1953 

and later dates. But as Dave Allen and Dr. 

Neton know, they contributed to the operational 

reports, the AEC operational reports. And I 

have one of them from December '52 that 

described the work that went on at GSI in 1952, 

under contract with the AEC and Mallinckrodt.

And work is described as 

experimental research and development work with 

the betatron to improve image quality using a 

proprietary uranium shield that was fabricated 
41

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

at Mallinckrodt. And so I don't think it's 

appropriate to simply back-extrapolate from the 

scale and scope of production, non-destructive 

testing inspection work, back to experimental 

research and development work.

And so, my simple comment, which I 

have expanded upon a lot in the paper I just 

wrote, my critique of Appendix BB, Rev 2, and 

said that I really think it's incumbent on 

NIOSH to calculate a dose that's specific for 

that 1952 period.

I think it's going to be very 

difficult because you don't really know the 

source term. You don't know exactly what was 

done. You don't know how many shots were 

fired. They used billets instead of ingots, 

dingots, and slices. And we really don't know 

what was done exactly for that experimental 

work.

But in any case, I wanted to point 

that out. I think that's an error that occurs 

throughout the tables in those documents. And 
42

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

anyway, I just wanted to leave it at that.

Otherwise, I've tried to be fairly 

specific about this. Comments I made about 

Appendix BB, Rev 2, there are some substantial 

comments. I'm sure a lot of them will be 

thought of as editorial. But I think they're 

substantive, and I encourage and hope you all 

will read that paper. And at least consider it 

for inclusion in Appendix BB, Rev 3. And 

possibly if any of those ideas make any sense 

to you, bring it up in the subsequent TBD-6000 

Work Group meetings.

And I guess with that, this may be 

the last time that I talk to this Work Group 

before the new administration, and many changes 

could take place by that time. I would like to 

say that I am quite concerned for the GSI 

workers who now are -- have been waiting since 

2007 to resolve all the issues for Appendix BB.

It seems like all the issues that 

SC&A and NIOSH and the Work Group can --

believe are important have been resolved by 
43

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

today. Now the full Board meets to sign off. 

You will see from my paper, 58 errors that I 

cite there, I don't think they've all been 

resolved.

But anyway, it concerns me greatly 

that we've gone on so many years without 

resolving these issues. And I remember 

distinctly that several people on the Board, 

and Mr. Allen told the full Board back in 

December of 2011 -- 2012, pardon me -- when the 

GSI SEC was denied by a 9 to 8 vote, that 

basically all the Site Profile dose 

reconstruction issues were solved. And those 

numbers would be plugged in, and everything 

would be fine.

And here we are many years later, 

about four to be exact. And all the issues 

have just gotten solved today by the Work 

Group. So I'm concerned about that, and I'm 

doubly concerned because the jury is still out.

One jury is still out on the

accuracy and the appropriateness and so forth 
44

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

of lots of issues that I raised in my comments 

about the appendices, and that takes the form 

of the administrative appeal that Petitioner 

Jeske and I sent to HHS in April, April 17th of 

2013.

That was accepted by HHS in May of 

2013 and has been under review constantly by an 

independent three-member HHS panel since that 

time. And again, now this will make GSI the 

longest running SEC that's ever considered by a 

review panel. Even Hooker took less time than 

this.

But that review panel, I'm assuming, 

of three senior HHS scientists is having a 

problem dealing with all of the 44 errors that 

we mentioned in our administrative review 

application. So we'll have to see how that all 

turns out. But the time that this is taking is 

really unbelievable to me. And I just, I feel 

quite sorry and badly for the GSI workers.

And I would just add the other 

feature that I'm very concerned and unhappy 
45

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

about, and that is, so we're talking about will 

another PER be issued for Rev 3? And I would 

comment that the PER-057 based on Rev 1 has not 

been resolved yet or reviewed by SC&A.

It's in that process, and it's still 

before Wanda Munn's Procedures Review 

Subcommittee. They'll meet January the 10th, 

and hopefully some of that review will take 

place. But it concerns me again that that PER 

was issued on March the 11th, 2015 by NIOSH, 

who identified 100 compensable cases based on 

their recalculated POCs based on Appendix BB, 

Rev 1.

At this point, 90 people have been 

paid, but there's still a number of cases that 

were flagged by the Department of Labor as 

being deceased, no survivors. And as having 

the wrong employment, never been employed at an 

eligible site. So there seemed to have been 

major errors in selecting cases for that PER as 

well.

So all those things add up to 
46

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

serious concern on my part. I don't really 

feel that you're making much progress on 

solving any of those things. We just have to 

wait and see how it works out in time. But I 

urge everybody to increase their sense of 

urgency in getting all this stuff resolved in 

any way that we can. Realizing that the full 

Board has to take the most responsibility, as 

well as NIOSH.

So anyway, I do thank you all very 

much for, and Dr. Ziemer, for giving me so much 

opportunity for input. I appreciate it. I've 

enjoyed the back and the forth. It's a very 

interesting site. I agree with that. And I 

appreciate all the work you've done on it, and 

for letting me be part of the decisions, 

inputting, tremendously public. Thank you, 

very much.

MR. KATZ: Paul and other Board 

Members, are you there? Dan, thank you.

CHAIR ZIEMER: I wanted to ask you, 

Dan -- yes, thanks for your time. Is there a 
47

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

new set of comments this year issued, or are 

you referring to your previous --

COURT REPORTER: Dr. Ziemer, I'm 

sorry, this is the Court Reporter. Can you 

switch phones again?

MR. KATZ: Right, Paul asked --

while he's switching phones -- Paul asked if 

there's a new set of comments or we'll use 

older comments? And Dr. McKeel was referring 

to and then had submitted new comments. I 

think we received them today. And they should 

have been sent to Board Members but I don't 

think Board Members have had a chance to review 

them yet, but we'll do that right?

CHAIR ZIEMER: I wasn't sure if I 

sent them. I'll have it sent.

DR. McKEEL: I'm sorry, Dr. Ziemer, 

this is a full-scale review --

CHAIR ZIEMER: Okay, got you --

DR. McKEEL: -- of Appendix BB and 

the SC&A review and the DCAS response to SC&A. 

It's a 21-page paper, so --
48

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

CHAIR ZIEMER: Okay.

DR. McKEEL: So, and I understand 

that nobody will have a chance to read it, but 

I hope you will read it. That's the point.

CHAIR ZIEMER: I will read the 

review, thank you, Dan.

DR. McKEEL: Thank you, very much.

Path Forward/Plans for March Board Meeting

CHAIR ZIEMER: Okay. Path forward, 

Ted, do we -- we need full Board action on 

this, right? Or do we?

MR. KATZ: I think we do need, yes, 

we need to close the loop with the full Board -

-

CHAIR ZIEMER: Okay.

MR. KATZ: -- on this review.

CHAIR ZIEMER: Okay, so that we've 

scheduled for the next, the March Board meeting 

then, right?

MR. KATZ: Yes, right. And also 

Paul if you want, if you want to do your own 

preparation, if you want any support from SC&A 
49

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

or Dave --

CHAIR ZIEMER: Yes, I think what 

I'll do is I'll prepare a summary. And I'll 

have both Dave and Bob take a look at it and 

give input. Also, we'll make sure that Dan's 

comments get distributed to the Board as well.

DR. McKEEL: Sure. I would 

appreciate that.

CHAIR ZIEMER: Okay. Any other 

items to come before us today, anyone?

MR. KATZ: No, I think that takes 

care of it for today.

Adjourn

CHAIR ZIEMER: Okay. Thank you all 

very much. We stand adjourned.

(Whereupon, the above-entitled 

matter went off the record at 3:54 p.m.)
50

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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