NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

145th Meeting

Wednesday, April 27, 2022

The Advisory Board convened via VideoTeleconference at 1:00 p.m. EDT, Henry A. 

Anderson, Chair, presiding.
2 

Present: 

Henry A. Anderson, Chair

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member

David Kotelchuck, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member 

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Rashaun Roberts, Designated Federal Official

Also Present: 

Adams, Nancy, NIOSH Contractor

Barrie, Terrie

Barton, Bob, SC&A

Behling, Kathy, SC&A

Black, Finn, SC&A

Blaze, D'lanie

Buchanan, Ron, SC&A

Burgan, Arthur

Burgos, Zaida, NIOSH

Calhoun, Grady, DCAS

Cook, Madeline, DCAS

Crawford, Chris, DOL

DeGarmo, Denise

Dressman, Kevin, DOE

Fitzgerald, Joe, SC&A

Gheen, Angelica, DCAS

Gogliotti, Rose, SC&A

Griego, Regina, DOE

Hand, Donna

Lewis, Greg, DOE

McCloskey, Pat, ORAU Team

Mcgolerick, Robert, HHS

Nelson, Chuck, DCAS

Rafky, Michael, HHS

Rutherford, LaVon, DCAS

Taulbee, Tim, DCAS
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 145th Meeting 

Wednesday, April 27, 2022 1

Welcome 4

NIOSH Program Update 6

DOL Program Update 13

DOE Program Update 17

Procedures Review Finalization/Document 

Approvals 21

Update on review of SEC-00253 Reduction 

Pilot Plant, Huntington, WV: Jun. 7, 1976-Nov. 

26, 1978 61

Public Comment 77

Adjourn 86
4

(1:00 p.m.)

Welcome

Dr. Roberts: It's about 1:00 p.m. Eastern and it's 

time to officially open the meeting. Good afternoon 

and welcome everyone, I'm Rashaun Roberts, the 

Designated Federal Officer for the Advisory Board on 

Radiation and Worker Health. 

I'd like to welcome you to Board Meeting 145 for the 

Board, this is the first session of that meeting. 

All the materials for both days, we're meeting both 

today and tomorrow, the meeting agenda, 

presentations, and other documents are posted on 

the NIOSH website for the program under the 

schedule of public meetings.

You go to the April tab for calendar year 2022 to find 

those materials. If you are participating by 

telephone, you can go to the website to access all the 

materials and you can follow along with the 

presentations.

The materials were provided to Board Members and 

to Staff prior to this meeting. On the website as well, 

there's a Zoom link which will enable you to hear and 

watch the presentations through Zoom if you prefer.

If you've chosen to receive audio through Zoom, you 

should be able to speak to the group and hear the 

presentations. But if you're not speaking, please be 

sure to select and stay on mute by muting the 

microphone on the lower left-hand corner of your 

screen.

If you dialed in you'll only be able to speak and hear 

the presentations through the telephone line. Please 

make sure that your phone stays muted unless of 

course you need to speak.

If you don't have a mute button press *6 to mute, if 

you need to take yourself off, press *6 again. 

Also, if you're only participating by telephone and 
5

we're unable to see you, please identify yourself 

before providing your comments or questions. 

With that, let me move into roll call. As Board 

Members and Staff register attendance, please 

acknowledge sites where you have conflict of 

interests if any. 

I will note there may be a vote today concerning 

reduction pilot plant and those conflicted will be 

asked to disconnect from the meeting for that agenda 

item and to rejoin for the public comment period 

scheduled at 5:00 p.m.

Let's go ahead and start with taking the roll call for 

Board Members and let's start with our Chair 

Anderson.

(Roll call.)

I think that's pretty much it, hearing no other folks 

from the public who want to register. So, let's go 

ahead and move further into the agenda. 

Again, please periodically check Zoom or your phone 

to make sure you're on mute so we have minimal 

disruption of the meeting. On Zoom the mute button 

is located on the lower left-hand corner of your 

screen.

If you're on by telephone but don't have a mute 

button press *6 to mute. If you need to take yourself 

off, press *6 again. With that, without any further 

delay, let me turn the floor over to our Chair, Dr. 

Henry Anderson.

Chair Anderson: Thanks a lot, Rashaun, and I want 

to welcome everybody. We've had a busy past month 

the last two weeks with Committee meetings and 

things and we'll talk a little bit about that when we 

have our work session.

That is an unusual set of occurrences that really 

pressed the Board Staff and all to get materials 

together and approved and ready to go, but I think 
6

we've got it all covered for the meeting today.

With that, I'd like to introduce Grady Calhoun to give 

us a NIOSH program update. 

NIOSH Program Update

Mr. Calhoun: Let me see if I can share my screen 

here. 

NIOSH program update, you can see that? Excellent, 

for some reason I can't get the individual slides off 

the other side there or else it goes to all three of my 

screens and I can't see you all. 

I'm glad to be here and I'll let you know a little bit 

about what's going on with us here in DCAS. 

We are in the process currently of hiring a health 

physicist and we also will be hiring -- we're in the 

process of hiring a replacement health physicist to 

replace Toms, if you remember him.

And Dave Allen also left us, he was a health physics 

team lead and so we're going to looking to replace 

him as well. IT update, the good news is we're now 

able to process all cases manually.

We can pretty much claim victory on achieving 

steady state again, and what I mean by that is that 

we're processing cases as quickly as we're receiving 

them from the Department of Labor, and our goal 

that we've had for many, many years is that all cases 

are completed within five months of receiving the last 

piece of information required for that dose 

reconstruction.

So, we're back at the point that we were prior to the 

pause, which is good. We're still continuing to work 

on some data management systems such as the site 

research database.

I continue to mention to folks that are in Work Group 

meetings and Subcommittees that if there's anything 

that the Board or the contractor needs to contact me 

or Lori Marion-Moss and we will try to get that into 
7

the virtual volume so that it is accessible to Members 

of the Board and the contractor. 

We haven't had any in-person workshops, town halls, 

or outreach meetings since 2020. We have supported 

DOL in a couple of virtual events but the great news 

is we're going to start doing them again.

So, DOL has planned a couple of outreach meetings 

and we certainly will support those and one of our 

contractors is also in the process of organizing some 

authorized representative workshops like we used to 

back in the old days.

Those will also be in-person meetings. As far as 

record requests to the Department of Energy, this is 

from a couple of weeks ago when I filled this out, we 

had 343 outstanding.

That doesn't mean they're all late, as you can see 

from the statistics there. There's 62 of them which 

means 60 and 100 days basically, there's 20 of them 

out there, 121 to 180 days. And there's 4 cases that 

are greater than 180 days to get data back. 

As of a couple of weeks ago, April 18th it looks like, 

we've received 54,516 cases from Labor. 52,449 

have been returned. We still had at that point 1165 

for dose reconstruction and a little over 900 have 

been administratively closed.

We've submitted 47,022 to Labor with the dose 

reconstruction and 1754 have been pulled for some 

various reasons by Department of Labor and 3673 

have been pulled for special exposure cohort 

qualification. 

Probability and causation summary, overall, 47,022 

dose reconstructions sent. Those that are less than 

50 percent, there's about 73 percent of the total 

which is 34,356. 

Those greater than 50 percent are 12,666, which is 

27 percent of the total. That pretty much falls into 

the bands that we've been seeing for quite some 
8

time. As of 4/18, there's been 1165 active cases at 

NIOSH for dose reconstruction, 444 were in DR 

process, 292, the draft reports are to the claimants 

awaiting an OCAS-1 form returned and there's 429 

cases that are being prepared for dose 

reconstruction, mostly with ORAU.

And that is all I have. Questions on that?

Member Kotelchuck: Grady, what's the difference 

between the 429 cases preparing and 444 in the 

process? What accounts for the difference of 15?

Mr. Calhoun: 429 cases preparing for dose 

reconstruction are those cases for which we have 

asked for data and are in the process of receiving that 

data, whether that's from the Department of Energy 

or additional data from DOL.

The 444 are cases, we have all that data, and we're 

in the process of starting the dose reconstruction. 

Chair Anderson: Thank you. I see Dave Richardson's 

hand raised.

Member Richardson: Thank you. You pointed to the 

IT issues and the progress that you've made with 

handling cases manually. 

I was wondering if you have comments or thoughts 

about how this would potentially impact the work of 

the Subcommittee on Dose Reconstruction in terms 

of when there's a process change, whether we should 

be focused on impacts on changes in completeness 

of information that are used in dose reconstruction 

as the process has changed. 

Do you have thoughts on that? 

Mr. Calhoun: Yes, sure, I think Dr. Kotelchuck will 

probably weigh in too, but all of the actual 

calculations, workbooks, et cetera, that we had used 

in the past are still being used so none of that has 

changed.

The same number of peer reviews and other reviews 
9

and approvals has not changed. Really, when I say 

manual, what happens is generally speaking, ORAU 

completes the dose reconstructions as they always 

have, they send them over to us and that's a manual 

process.

We no longer have an instant replication as we used 

to. And so then they'll go to the first level of review 

over here and it's manual, and so somebody literally 

has to copy one file and put it into another place.

And then there's another level of review and then 

ultimately that will get approved and sent back to 

ORAU manually. So, that's what's manual about it, 

the actual calculations and reviews are the same as 

they've always been.

Chair Anderson: Other questions?

Member Clawson: Andy, this is Brad. Grady, when do 

you think we'll be able to see the SRDB back for 

access? 

I know that Lori has been real good if we have 

anything, she tries to get in there but a lot of times 

we're looking for information and really don't know 

what we really need and it's hard to explain to Lori 

what we're looking for. 

I understand and unfortunately, we're in the same 

boat with you but I can't say there's an actual date. 

But I know we've got the actual application that we 

used to have and some of our IT people are looking 

through it and trying to see are there really any 

significant vulnerabilities here and maybe we can 

place that application back into the virtual volume 

and get that working. 

I know that's one of about five applications that 

they're looking at right now, same with the BRS, 

remember that one? The Board Review System that 

we used to track things on. So, we're looking at three 

or four or five of those applications and trying to get 

them in there.
10

I can't give you any dates just because they've got 

to find out if there are any vulnerabilities still and 

which ones need to be fixed or if we have to start 

over with a new search mechanism.

So, I'm sorry about that but we'll still continue to try 

to help as much as we can.

Chair Anderson: I appreciate that, thank you for the 

update. 

Ms. Colley: I'd like to ask a question, I haven't been 

on for a while so I don't know if this is appropriate 

time to ask if you're talking about the SEC slides. 

My name is Vina Colley and I'm from the Vina Colley, 

Portsmouth Gaseous Diffusion Plant.

And in the beginning, Congress had put Paducah and 

Oak Ridge as an SEC site so they don't have to do 

dose reconstructions. What's going on here is they 

are redosing family members that have passed away.

I'm just wondering why that's happening.

Dr. Roberts: Hi, I'm Rashaun Roberts, I'm the 

designated federal officer. There is a public comment 

period built into the agenda so public comments and 

questions really are raised at that time. 

Ms. Colley: Like I said, I haven't been on this for a 

while and I missed the first part. 

Chair Anderson: Public comment period will start at 

5:00 p.m. Eastern Time.

Member Clawson: Andy, is there a sign-up for them 

in public comment to be able to make public 

comment speaking in our regular meetings? I've had 

several people ask me how do I get set up to be able 

to speak.

Chair Anderson: Rashaun?

Dr. Roberts: You can pass that, whoever you have on 

to me. Typically, those requests come to the DFO 
11

and/or Chair prior to the meeting so we can get 

people on the list.

Chair Anderson: I just wanted to make sure because 

they've just mentioned how do we do that? I'll make 

sure to pass that onto them. If they haven't done it 

in advance, that doesn't mean they can't comment.

We'll ask for comments at the end but it's nice to 

know how many would like to talk so we can allocate 

the hours. 

Member Clawson: And I also told them when they do 

to put what they're wanting to speak of too to make 

sure the right people are there to be able to listen to 

it. 

Chair Anderson: Other questions?

Member Beach: Andy, I have a question for Grady or 

maybe Lori, but Grady can probably answer it. 

If you request SRDBs to be posted in the virtual 

space, can you give us a timeframe? I know I gave 

Lori a pile and she had them in there within a couple 

of weeks. 

But if you're just requesting one or two can you tell 

them what the timeframe is to get the access to

those?

Mr. Calhoun: It depends on what Lori's doing, 

basically, but I'll ask her. I can shoot her a message 

while we're speaking here but I would imagine she 

could do that a few days depending on what's going 

on.

It's not going to be instantaneous I'm sure but if she 

got a pile of them in a couple of weeks, I would 

imagine she could get a few of them done in a few 

days. 

There is actually somebody that can do it for her in 

her absence too. 

I think it's basically the size of the documents but 
12

again, if it's something you're really chomping at the 

bit at, just let me know and I'll try to make it go as 

quickly as we can given everything else we're doing. 

Member Beach: My next question is we do have some 

members that issues with their laptops and can't get 

into the virtual space. Is there a way to have access 

to SRDBs when you don't have access to the virtual 

space? 

Mr. Calhoun: No, absolutely not. I know that's an 

easy answer on that one.

Member Beach: I suspected that was the answer, I 

just wanted to see if there was any other 

workaround. 

Member Clawson: Josie, let me ask on this question 

to Grady. 

Before, there was a lot of times that we had certain 

documents and stuff that we actually needed for and 

when we were having troubles with our computers 

and so forth like that, you guys can actually burn 

them on a CD to us. 

Can you guys still do that? 

Mr. Calhoun: Probably not. They would have to be 

completely through the redaction process and 

everything. I can check but we don't do that 

anymore, we don't do fire straws or anything 

anymore. 

So, they really cracked down on any environmental 

media as well. 

Member Clawson: If you remember, a lot of times we 

used to get a lot of that information, especially when 

they were PA-cleared and everything else like that. It 

was just informational.

Mr. Calhoun: Hey, if we run into any of that and we 

can do it, we will and also, we'll try to post stuff that's 

completely applicable. We don't want to start posting 

everything to our website, rather than trying to get it 
13

to you.

But if you run into something like that, like I said, 

just call me, we're trying to be flexible on these 

things and get things done. 

Member Clawson: I just wanted to know if we had 

that availability and we'll go from there. 

Chair Anderson: Other comments? We can talk a bit 

more about the computer issue when we go to our 

discussion area. I just got my new computer and it 

works like a charm, it only took me three days to get 

it set up.

The poor support center, they really helped and it 

works like a charm now. 

So, if you have one of the older computers, they're 

hopefully going to swap all those out so you should 

be able to get a new one because the old ones, the 

software on it isn't so good either. 

With that, let's move on to the DOL program update. 

DOL Program Update

Mr. Crawford: Hello, this is Chris Crawford from DOL. 

Grady has graciously volunteered to present the 

slides for me as usual. Let me know when --

Mr. Calhoun: Can you see the slides?

Mr. Crawford: No, I'm not on Zoom at the moment.

Mr. Calhoun: Can you see the slides, Dr. Anderson?

Chair Anderson: Yes. 

Mr. Calhoun: I'm on Slide 1, Chris.

Mr. Crawford: Thank you, let's go to Slide 2, our 

compensation paid slide. 

We have $7.4 billion paid already on Part B 

compensation, $5.9 million on Part E compensation, 

$7.8 billion on medical bills for a $21 billion total 
14

compensation plus medical bills paid sum on 223,828 

cases filed. 

In smaller categories we have expended $1.69 billion 

on dose reconstruction cases with 15,880 payees and 

$180 million approved SEC and a probability of 

causation of 50 percent or greater cases combined. 

There are a few cases like that, we have 1390 payees 

under that category. Next slide. 

Mr. Calhoun: I've been talking on mute, Chris, it's 

there. 

Mr. Crawford: The NIOSH referral case status and our 

figures are as of March 31st so they won't align with 

Grady's anyway but we showed 55,326 cases 

referred to NIOSH for a dose reconstruction, of which 

53,490 cases have been returned at DOL from 

NIOSH.

The 6819 at DOL with the dose reconstruction, 6671 

have been withdrawn from NIOSH with no dose 

reconstruction. These show 1836 cases currently at 

NIOSH as of March 31st again. 

We have Part B cases with the dose reconstruction 

and final decision. 37,156 cases with dose 

reconstruction and a final decision. Of those, 34 

percent are final approvals amounting to 12,714

cases. 

And 66 percent are final denials, amounting to 

24,442 cases. Next slide. Here we have Part B cases 

filed. The largest category is always other, as you see 

in the note other refers to beryllium sensitive, chronic 

beryllium disease, and chronic silicosis. 

NIOSH gets 30 percent of the cases, 13 percent of 

the cases are never sent to NIOSH, they're SEC 

cases. 12 percent are SEC cases that are sent to 

NIOSH and 7 percent are RECA cases. 

Here we have Part B cases with a final decision. This 

would include SEC cases. So, we have 109,627 such 
15

cases of which 53 percent were approved and that's 

58,607 under Part B and 47 percent were denied, 

that's 50,950 cases denied under Part B.

Next slide. 

The top four work sites for the first quarter, calendar 

quarter, of this year generating new Part B cases are 

about a test site, Savannah River site, Hanford, and 

K25. 

So, the usual suspects I think. Grady, I'm going to go 

back and forth between this slide and the following 

one. The SEC sites being discussed at this meeting 

today and tomorrow, Huntington Pilot Plant and 

Sandia National Laboratory, Albuquerque. 

Huntington Pilot Plant we have 888 cases, part of 

which 84 cases have been returned by NIOSH with a 

dose reconstruction and we have 483 cases with a 

final decision. Let's move on to the next slide and 

we'll come back. 

Still Huntington Pilot Plant, we have approved 22 

cases, Part B, we have approved 33 cases under Part 

E, and we have paid a total compensation in medical 

bills of $11,060,204. 

Let's go back one slide. Now we're talking about 

Sandia national laboratory, from which we have 

received 4492 cases. NIOSH has returned 772 cases 

with a dose reconstruction. We have final decisions 

under Part B of 2100 cases, the same with Sandia, 

you have approved 1410 cases under Part B and 

1333 cases under Part B. We have paid out 

$468,651,163 through March 30th. 

Next slide. Now, we're going to speak briefly about 

the outreach events. These are now virtual so far. I 

guess we're going to in-person meetings later this 

year we hope these are the meetings that have 

already been held. 

In March, we had a RECA Case, Radiation Exposure 

Compensation Act, 258 attendees at the webinar. In 
16

February we had NIOSH dose reconstructions and 

stakeholder updates webinar with 170 attendees.

In January we had a webinar of national office roles 

and responsibilities with 124 attendees. Next slide. 

We're going to look at the upcoming webinar series.

We'll be discussing former worker medical screening 

programs, worker health protection programs, 

eligibility and services available for former and 

current workers from 14 DOE sites, a full review of 

the building trades national medical screening 

program conducted by CPWR. 

Let's go to the next slide. In an upcoming outreach 

event, June 2nd of this year at Savannah River Site 

town hall in Aiken. Next slide. We have a RECA town 

hall June 28, 2022 in Farmington, New Mexico. 

Next slide. The very next day we're having a RECA 

town hall June 29th at Shiprock, New Mexico. Then 

we're having a RECA town hall at Kayenta, Arizona, 

June 29, 2022, same day. 

The last listed one is an Oak Ridge off-rise 

representations workshop August 30th and 31st at 

Oak Ridge and a town hall also at Oak Ridge on 

September 1st. 

That's the final slide except on the website you will 

see further information about eligibility and that sort 

of thing, which we don't present to the Board. Are 

there any questions?

Chair Anderson: I can't see hands, if people have 

questions go ahead and ask. Josie, did you?

Member Beach: I originally had a question on Slides 

9 and 10 but I was just reviewing and my question 

was answered with you going back and forth with that 

so I appreciate it. I don't have anything else to ask, 

thanks. 

Chair Anderson: Any other questions? Thanks very 

much, Chris and we'll move on to DOE and Greg 
17

Lewis.

DOE Program Update

Mr. Lewis: Hi, everyone, can you hear me?

Chair Anderson: Yes. 

Mr. Lewis: I'm going to turn it over Mr. Kevin 

Dressman in just a moment to introduce himself. He 

is the new, or relatively new I guess, early fall he 

started, Director of Office of Health and Safety at 

Department of Energy.

He replaced Pat Worthington, who retired last year. 

So, I believe I had shown his bio during the last 

Advisory Board meeting but Kevin had another 

commitment and wasn't going to be able to speak to 

you all but he is here today.

I think he's traveling down at the Los Alamos site but 

he was able to take time out talk to you folks, so he's 

just going to get a little bit of an introduction and turn 

it back over to me and I'll go through the rest of our 

presentations.

Kevin, do you want to take it away?

Mr. Dressman: Yes, can you hear me okay?

Mr. Lewis: I sure can.

Mr. Dressman: Excellent, good morning, everyone. 

As Greg mentioned, my name is Kevin Dressman, I'm 

the new Director of the DOE Office of Health and 

Safety, Greg's program is within our office. 

I've been with DOE for about 15 years. Until joining 

this organization six months ago, I was working in 

the Department's Enforcement Program and among 

the enforcement programs the Department has, one 

is related to worker safety and health. 

And so I've spent most of my career in a role that in 

many ways advocates for DOE workers, both 

primarily current workers but in some of the 
18

enforcement matters that we dealt with involved 

former DOE workers. 

I've had a 30-year federal career that spanned 3 

different federal agencies and in all the roles that I've 

been involved in, it's had some impact on federal and 

non-federal workers and health and safety matters. 

So, as Greg mentioned, I'm relatively new to the 

program, Greg and Gina and their team have been 

very patient and have done an excellent job in terms 

of bringing me up to speed on our role in this process. 

And unfortunately, I won't be able to send more than 

just about 20 minutes participating in the call today 

but I look forward continuing to learn more about the 

program and various roles and responsibilities that 

the various organizations have in executing this 

program on behalf of the formal workers from the 

Department of Energy. 

So, thank you again and I look forward to hopefully 

some day in the future getting to meet some or many 

of you in a non-virtual environment. Thank you. 

Mr. Lewis: Okay, this is Greg again. Thanks, Kevin. 

Grady, would you be able to pull up my presentation 

if possible?

Mr. Calhoun: Can you not see it? Let me start and 

stop over. I tried to do it, let me stop and start over.

Mr. Lewis: It may just be me but I was still seeing 

the agenda.

Mr. Calhoun: How about that?

Mr. Lewis: That's perfect. I guess if you could go a 

couple slides down because the second slide is 

Kevin's information and he just introduced himself. 

I'll go to the responsibilities and this is our usual 

presentation, but again for those who aren't familiar, 

we support the program and Department of Labor 

and NIOSH by providing records, both for individual 

claims as well as for site characterization efforts like 
19

SEC research and then of course the cover facility 

designations as well. 

If you can go to the next slide?

For individual records, we go to many different 

locations. These aren't just a one worker, one file for 

a worker that had a 30-year career. 

We could have to go to multiple different databases, 

different types of records, hard copy records, 

microfilm, microfiche, databases, location print-outs, 

that kind of thing, to try to pull together a records 

package.

Sometimes, unfortunately, if a subcontractor was 

there for a short time we may be able to find very 

little information but if it's a career, 30-year 

employee, some of those record packages can be 

over 1000 pages long.

I've seen 2000 and 3000 pages in extreme cases but 

the volume of records really can vary. Next slide. 

Recently, we are constantly supporting NIOSH and 

DOL research efforts.

I just went back through my notes and emails and 

since the last Board Meeting some of the sites we've 

been working with NIOSH and the Advisory Board on 

are the Oak Ridge GDP or K25 Hanford Site, a few of 

the different legacy management sites or sites that 

legacy management handles, those are the closure 

sites.

Los Alamos National Lab and the Savannah River 

Site. Next slide. 

We are continuing to do the classification reviews on 

NIOSH final documents, as well as documents that 

are requested from sites, like the five that I 

mentioned on the previous slide as NIOSH's or the 

Advisory Board or contractor are requesting 

documents. 
20

We're reviewing those for classification and making 

sure those are available and useable in a timely 

fashion to NIOSH. Next slide. Facility research is a 

smaller responsibility but extremely important.

There are particularly AWE sites where we continue 

to research either the covered time period or whether 

the new facility should be covered or existing facilities 

are appropriately covered. 

Next slide. The formal worker screening program, I 

always put a few slides in on the formal worker 

program. 

This is also a program that my office funds and 

supports, it's separate from the compensation 

program but serves many of the same people or is 

almost a gateway into the compensation program for 

some folks.

We provide free medical screenings to all formal 

workers from all DOE sites are eligible for a screen 

medical screen. Not all take advantage of it, of 

course, although we'd love it if they did.

We are actually, as Chris Crawford mentioned, to this 

afternoon the next Department of Labor virtual 

outreach series is featuring our formal worker 

programs, so for those of you that are interested, you 

could always hop over to that.

I think the link is on the Department of Labor website 

but we're going to be providing information about our 

formal worker programs, what they offer, who's 

eligible, how the program works, all of that good 

stuff, and taking questions. 

And then while I'm talking about outreach, I'll also 

mention we are supporting the other DOL outreach 

activities during outreach task group activities, so I 

know we'll be participating and presenting at the 

authorized rep meeting that I think is late August and 

early September. 

We'll be there and we also look forward to getting 
21

back to supporting the various in-person outreach 

events as we start to get back to that. 

On the slide there is a link to some more information 

about our formal worker program and with that, I 

think that's my last slide.

I'll take any questions for me or Kevin, if he's still on 

the line.

Chair Anderson: Board Members, any questions? 

Welcome to Kevin. 

Mr. Lewis: No questions, thank you for having us.

Procedures Review Finalization/Document Approvals

Chair Anderson: We'll let you off the hook, thanks 

very much. Let's move on to now to the Procedures 

Review Work Group, Josie Beach is the Chair. 

Welcome, Kathy will be presenting today and our 

Subcommittee Meeting was in February.

We continue to work through our carryover issues 

and concerns along with keeping track of all the work 

that the Subcommittee is doing. It's a little more 

difficult because, like Grady said, we don't have the 

BRS. 

So, Kathy has put together many charts for us and is 

keeping track so that when we do have access to that 

program, hopefully we won't be in a situation where 

the BRS is not going to be available to us. 

That will be interesting I'm sure. But we are going to 

close out, or Kathy is going to present seven 

procedures for closeout that the Subcommittee has 

already reviewed and we're going to pass those onto 

the Board.

Kathy, are you set and ready to present?

Ms. Behling: Yes, I am. Let's see if I can share my 

screen. Do you see the first slide?

Member Beach: Yes, we do.
22

Ms. Behling: Let's get started. As Josie mentioned, 

today we're going to discuss seven documents that 

have already been approved by the Subcommittee. 

There's going to be one OTIB report and five PERs 

that are listed here.

We will start with OTIB-0066 and this OTIB is the 

calculation of dose from intakes with special tritium 

compounds. 

This document provides guidance on calculating best 

estimate doses from intakes of tritium bound to 

organically bound tritium and tritium bound to stable 

metal tritides.

Rev. 00 was issued in April of 2007 and SC&A 

reviewed Rev. 00 of this OTIB and we submitted our 

report in November of 2008. 

And as a result of that review, we identified four 

findings and we presented our findings to the 

Subcommittee at the March 2009 meeting and then 

Revision 1 was issued in October of 2020. 

We had four findings and we'll station Finding 1. This 

matrix shows a summary of the finding and its 

resolution and Finding 1 states that OTIB-0066 uses 

methodology in OTIB-11. 

OTIB-11 is tritium calculated and missed dose 

estimates for assessing dose to intakes of organically 

bound tritium. We considered that methodology is 

not claimant-favorable. 

In January 2009 NIOSH responded and said they 

agreed and they stated that there's a correction 

factor of 1.4 that is used in OTIB-11. And they 

indicated that is correct for Type 1 calculations and 

I'll just explain, Type 1 calculations represent a linear 

interpolation between two urine sample 

measurements that are taken less than 40 days 

apart.

However, they indicated that the adjustment is larger 

for Type 2 and Type 3 calculations. Type 2 is an 
23

exponential extrapolation between a first 

measurement and a second measurement that's 

performed greater than 40 days apart.

And Type 3 is an exponential extrapolation to infinity 

to account for the tail of the last measurement. 

And initially, NIOSH indicated they were going to 

revise OTIB-11 but actually, what happened is when 

they revised OTIB-0066 they actually removed the 

recommendation to use OTIB-11, and they specified 

that the dose reconstruction they should use for the 

calculation. 

SC&A did go in and do a focused review of OTIB-0066 

Rev. 1 and we confirmed that the appropriate 

changes were made and we recommended to the 

Subcommittee that the finding be closed. 

At the November 2021 meeting, the Subcommittee 

did agree to close that finding.

Member Beach: Kathy, do you want to pause after 

each of the findings and just ask for questions? 

Otherwise, we may get lose.

Ms. Behling: I was going to pause after each 

document and ask for questions but we can do it after 

each finding if you like.

Member Beach: I think at the end of the document 

would be fine too and if somebody has a question and 

they want to break in, I think that would be 

appropriate after the finding. 

Ms. Behling: Just flag me to stop talking whenever. 

Member Beach: Go ahead.

Ms. Behling: We will move on to Finding 2. 

Finding 2 states that the bounding techniques 

proposed in OTIB-0066 cannot be developed without 

understanding the special tritium compounds that 

were handled, the material quantities, the locations 

in time periods of the exposure, and the physical 
24

behavior of tritium in the environment. 

NIOSH responded indicating that this type of 

information actually should be provided in the site 

profile and it's really outside of the scope of OTIB0066. 

And SC&A agreed with that and the Subcommittee 

closed the finding based on NIOSH's response. 

Moving onto Finding 3, Finding 3 asserts that OTIB0066 does not ensure that the doses are based on 

adequate monitoring data and recommends using 

particulate air monitoring. 

However, we even had some questions with the use 

of that data. 

And NIOSH agreed that the monitoring data that 

argues full evaluating of stable metal tritides, 

however, the air monitoring when it's not available, 

urinalysis data can be used to bound the intakes.

NIOSH indicated that they would add guidance on the 

practical interpretation and shortfalls of the urine 

bioassay result to a revised OTIB. 

And again, SC&A performed a focused review of Rev. 

1 of the OTIB-0066 and confirmed that NIOSH did 

include appropriate information and based on that, 

the Subcommittee closed this finding. 

Moving onto Finding 4, Finding 4 identifies that the 

OTIB does not provide guidance on how to distinguish 

between intakes of special tritium compounds, 

elemental tritium, and tritiated water.

NIOSH acknowledged that this is not potential to 

identify the compounds responsible, however, the 

most claimant-favorable models are designed to be 

consistent with the source terms.

And again, SC&A agreed with that and the 

Subcommittee closed this finding. That sums up our 

review of OTIB-0066 and I'll try to take any 

questions. 
25

Member Clawson: Kathy, this is Brad. Back on Slide 

2, I've just got a question on that. What they're 

saying is that we will use the site profiles supposed 

to cover all of this tritium, what was used when it was 

there?

Ms. Behling: That is their response, yes. This is a sitespecific issue and it should be incorporated into the 

TBDs or the site profiles, yes.

Member Clawson: My question comes back to these 

site profiles are ever-developing and changing so 

maybe that would be for Grady or whoever else, if 

you have done a site profile issue and then the site 

profile changes, what is this going to do to the dose 

reconstructions that you have performed?

Ms. Behling: To some extent I could answer that 

question because when there are changes to a 

technical basis document or an OTIB or a report, 

NIOSH generally issues the program evaluation 

report, a PER.

And it does that if there are changes that increase 

the dose and would impact any of the claims that 

were previously adjudicated and less than 50 

percent. So, that should be covered under the PER if 

I understood the question correctly.

Member Clawson: I understand when we do that with 

procedures and with OTIBs and everything else like 

that, but I was wondering about site profiles because 

they're an ever-living document and they're always 

changing.

Ms. Behling: Yes. 

Mr. Calhoun: This is Grady, I think I answered the 

question correctly but anytime that we have a change 

in any of our technical documents, whether they're 

technical basis document TBD, TIB, if it increases the 

dose, we will go through all non-compensated cases

to make sure that change wouldn't cause that case 

to flip the compensatory.
26

Member Clawson: I just wanted to make sure 

because I thought that's why we made a lot of these 

OTIBs, just technical data, so that we had everything 

in one spot. 

Because I know that a site profile, new information 

comes in and changes and stuff, so this is tied to one 

specific item like tritium and stuff, and the 

requirements that are needed, I just wanted to make 

sure I understood how this was going to feed back. 

Ms. Behling: And in fact, Brad, several of the PERs 

that we'll be discussing today have to do with 

changes in the site profile, so we will see examples 

of those today. 

Member Clawson: Thank you for that, thanks, Grady.

Member Beach: It's a good question, Brad. Any other 

questions on OTIB-0066? Rashaun, what would be 

the proper procedure here, take a verbal vote to 

agree with the Subcommittee on closing this OTIB?

I think if we go through each one of them individually 

it might be better. 

Dr. Roberts: Sure, I think what you could do is make 

a motion and go ahead and do it that way. 

Member Beach: I think these are all motions, unless 

you need it as an official motion. So, the motion from 

the Subcommittee is to close ORAUT-OTIB-0066. 

Member Clawson: I second it.

Member Beach: Thanks, Brad. Any discussion? And 

then Rashaun, can we just say all in favor?

Dr. Roberts: That will be fine. 

Member Beach: All in favor say aye?

(Chorus of aye.) 

Any opposed? We'll say that ORAUT-OTIB-0066 is 

officially closed and Kathy, I'll turn it back over to 
27

you. 

Member Ziemer: Just a point of information or maybe 

a point on procedure, Josie, this is Paul, two things. 

Number one, recommendations from Subcommittees 

or from work groups do not require seconds under 

Robert's rules.

And number two, I think the Board action has to be 

under the purview of the Chairman of the Board. 

Member Beach: That's why I was asking, because I 

wasn't sure. 

Member Ziemer: If you want the Board to take action 

on recommendation of the Subcommittee, Andy 

should actually call for the vote.

Member Beach: Andy, would you like to --

Chair Anderson: I will call for the vote. Do we have a 

motion to close out OTIB-0066? All in favor say aye?

(Chorus of aye.) 

Any opposed? The motion passes.

Member Clawson: I take back my second then. 

Member Beach: Thanks, Paul, for getting that 

straight and clarifying.

Ms. Behling: Sounds like we're ready to move on to 

RPRT-0086?

Member Beach: Yes. 

Ms. Behling: RPRT-0086 is internal dosimetry 

coworker completeness test and this report provides 

generic discussion of statistical methods that can be 

used to select a sample of workers from --

It used to be we'd select a sample of workers from 

NOCTS and they would use their data to estimate the 

missing data portion for the population of all 

monitored workers at the site. 
28

And site-specific data are dependent on how the data 

sets are structured for a given site and those 

methods are included again in site-specific reports. 

So, just as a backdrop, this report is more of a 

generic nature. 

Rev. 1 was issued in September of 2017 and SC&A 

submitted its review of Rev. 00 in January of 2018 

and we identified three observations. 

We presented our findings to the Subcommittee at 

the February 13, 2019 meeting and I put all these 

dates and things in in case anyone wants to go back 

and look at transcripts, you have the information 

available to you. 

Observation 1, there are four RPRT-0086 parameters 

that are variable and dependent on the selection of 

their value will determine the required sample size

and they may affect the outcome of the analysis.

And these parameters are one which is a producer's 

risk alpha, two is a consumer's risk beta, and three 

is unacceptable error rate. And so SC&A said in the 

PNL that these are variable and their selection can 

alter the outcomes.

NIOSH's response was they stated they'll note this 

observation as incorporate appropriate wording when 

the report is revised. But the observation really 

doesn't change any of the methodology. 

And based on that, the Subcommittee accepted 

NIOSH's response and they closed this observation. 

Member Kotelchuck: Kathy, I don't understand what 

producer's risk and consumer's risk, how that plays 

into the calculations here, I don't understand what it 

means in this context.

Ms. Behling: In this particular case I'm going to have 

to refer to NIOSH to give a better explanation of that. 

Is there anyone from NIOSH?

Member Kotelchuck: I don't know what's being 
29

consumed.

Dr. Taulbee: This is Tim. 

Basically, this has to do with what kind of risk 

tolerance we have as the -- I'm struggling here for 

words -- of an acceptable type of error. 

Does we have one of the statisticians from ORAU on 

the line that could help out here?

I'm fumbling on the words here. I guess not. All right, 

there's two different parameters here, the alpha and 

the beta. One of them is referred to as the individual 

who is producing the actual data that is coding it and 

so forth. 

And so the second part is the person who is using it, 

in a sense, that's where the producer and consumer 

is coming from. That's where that terminology is. 

You're shaking your head?

Member Kotelchuck: That gives me a sense of what 

those are. Those are names for those parameters?

Dr. Taulbee: Effectively, yes.

Member Kotelchuck: I was just trying to think who is 

consuming what, but now I see. It's a label for a 

process that's used in general in statistical 

calculations?

Dr. Taulbee: That's correct. 

Member Kotelchuck: That's fine, thank you.

Ms. Behling: If there's no other questions I'll move 

on to Observation 2. Observation 2 is simply an issue 

of terminology. 

SC&A felt the term original data set, which is used 

throughout the report, is referring to the computerreadable data set in electronic format that's been 

transcribed from hard copy records. 

And since original really refers to origin or first, we 
30

felt that adopting a different term for this data set 

would be less confusing. Again, NIOSH agreed they 

could make a note of this observation and include 

appropriate wording changes in the next revised 

report.

But since it doesn't really impact the methodology 

described in this report, they felt that we could move 

on and close it. The Subcommittee accepted NIOSH's 

response and closed this observation. 

Moving onto Observation 3, there is actually a 

paragraph on Page 11 that refers to Figure 5-3 that 

erroneously states that the critical value for n equals 

25, however, the caption of Figure 5-3 and the values 

in 5-3 are actually that n equals 24.

So, just a minor typographical error. The 

Subcommittee accepted NIOSH's response. NIOSH 

said they agreed there was a typo and they would 

make a change when there was a revision to this 

report. 

The Subcommittee accepted that and closed this 

observation. That sums up our review of RPRT-0086. 

Chair Anderson: I think this comes to vote to close it 

out, the recommendation from the Committee is that 

the Board accept your recommendation and close out 

the 0086 review. 

Member Beach: Yes, unless there's additional 

questions, Andy.

Member Kotelchuck: No further questions.

Chair Anderson: Thanks, Dave. With that, I'll call for 

a vote. All in favor of closing out ORAUT-0086 signify 

by saying aye?

(Chorus of aye.) 

Any opposed? Unanimous and ORAUT-0086 is closed. 

Member Beach: Thank you, Andy, we will move right 

along. 
31

Ms. Behling: Now, we'll move into our first program 

evaluation report and as we said, this is generally 

issued when there's a change to a site profile or to a 

guidance document that increases those. 

I'm sorry, was there a question?

Dr. Roberts: Yes, someone on Carolyn's iPhone, 

please mute.

Ms. Behling: Thank you. In general, when there is a 

change to site profile or to a guidance document that 

increases dose and has the potential to impact 

previously adjudicated cases, NIOSH issues a PER.

In this particular case, this is PER-57 and it was 

issued due to changes to the General Steel 

Industries, GSI, TBD. The PER was issued in March of 

2015 and it assesses the effect of Rev. 1 to the GSI 

site profile.

The GSI site profile methodology is in Appendix BB of 

the Battelle TBD-6000. The revision included 

extensive changes to dose estimates for all 

operational and residual period years and just as a 

little refresher, I want to explain SC&A's review 

process.

We have five tasks, really it usually refers to them as 

four, Subtask 4 evaluates the circumstances that 

necessitated the need for the PER. And under 

Subtask 2 we evaluate NIOSH's methods for 

corrective action. 

And it's under this section that if there were 

documents, supporting documents, for this PER that 

have not previously had a formal review by SC&A, it's 

in this section that we have the opportunity to review 

any revised OTIBs, site profile.

If there's a white paper involved that we haven't 

looked at, we do that under our Subtask 2. Under 

Subtask 3, we look at NIOSH's approach for 

identifying the universe of potentially affected claims.
32

And under Subtask 4, we provide criteria under 

Subtask 4 for selecting a sample set of cases that 

would be impacted by the PER. And there's Subtask 

5, which is actually are our report, our written 

Subtask 4 report that gives the results. 

And it contains the results of our case audit.

Member Kotelchuck: Are the slides moving? 

Ms. Behling: They're not, I just thought about talking 

about this today and didn't include a separate slide, 

I apologize. I'm ready to move on. Sorry, I should 

have included that as a separate slide. 

Member Kotelchuck: No problem. 

Ms. Behling: SC&A's review of the DR methodology 

in Appendix BB Rev. 1, we reviewed that in December 

of 2014 and that review identified nine findings, 

which were resolved under the TBD-6000 Work 

Group. 

They were presented to the Board at the November 

18, 2015 meeting. I apologize for this. Under the 

Subcommittee's purview, the PER-57 review just 

consisted of evaluating a sample set of impacted 

cases. 

So, SC&A reviewed based on our recommended 

selection criteria, SC&A reviewed five cases and our 

selection criteria included various employment 

periods and job categories and cancer types. 

We submitted our Subtask 4 report in December of 

2016 and we identified four findings and seven 

observations, and we presented our review at the 

January 10, 2017 Subcommittee meeting. 

Finding 1, in one of the selected cases, SC&A did not 

agree with NIOSH assigning the EE, or the energy 

employee, to the administrative category based on 

information that we found in the CATI report.

And as a result, SC&A reviewed all of the GSI cases, 

the administrative cases that were assigned as 
33

administrative cases, to ensure this is not a systemic 

issue. And based on that review, it was determined 

this was just an isolated case.

And NIOSH responded by saying after they reviewed 

the CATI, they probably shouldn't have been 

classified as an administrative worker, however, 

since the EE was not employed at the site, there's 

really not a lot of corrective action that could be done.

What had happened here is early on there was some 

confusion between employees that were employed at 

GSI or employed at the Granite City Steel Company, 

and in this particular case, this person happened to 

be at the Granite City Steel Company, but initially, 

the dose reconstruction was done under the GSI TBD. 

We just followed through and just looked at this case 

anyway because we were looking at whether it was 

performed in accordance with PER-57, not whether

the person was actually employed there. 

The Subcommittee closed the finding since it appears 

that this was an isolated case for assigning this 

person as an administrator. Finding 2, NIOSH used 

the CADW, the Chronic Annual Dose Workbook, and 

entered pro-rated intakes to account for partial years 

of employment.

And this approach is actually considered an efficiency 

approach or measure that for cases that are 

considered best-estimate and close to the 50 percent 

PoC, SC&A felt it should not have been used.

And we recommended that in the BEs for these 

calculations. And NIOSH also agreed and said that 

typically, they do use IMBA when they're working 

with best-estimate cases. They did recalculate the 

internal dose for this case using IMBA, and they reran 

IREP.

This resulted in just a modest change in the PoC, 

which did not impact the compensation decision. 

During this discussion, NIOSH also indicated that the 
34

CADW program had also been modified to allow for 

partial-year intakes.

And the Subcommittee requested that NIOSH 

formally document this. That was done and based on 

that response, the Subcommittee closed the finding. 

Finding 3, NIOSH calculated uranium intakes using 

an additional intake year and although this resulted 

in a slight overestimate, it does represent a QA issue. 

And NIOSH acknowledged this error but stated that 

it did not impact the case.

Based on that information, the Subcommittee closed 

the finding.

Finding 4, again, this is for one of the additional 

selected cases, SC&A questioned whether the EE for 

the selected case should be classified as a plant 

worker rather than an administrative worker.

However, NIOSH indicated that they also went back 

and looked at all of the administrative GSI cases to 

ensure that's the classification they belonged under. 

And so they felt that classification for this particular 

case was correct and the Subcommittee agreed with 

that and closed the finding. 

Now, moving onto our observations, SC&A noted that 

NIOSH used a fixed DCF value for assigning dose to 

the administrative worker and this is inconsistent 

with the guidance in Implementation Guide 001, 

which is our external implementation guide.

And SC&A assessed the DCFs using different 

approaches and found the triangular distribution 

produced the highest value and was likely the most 

claimant-favorable POC.

NIOSH indicated that they had made some changes 

to the GSI Appendix and some of the tools and 

techniques and based on those revisions, they felt 

this observation would be resolved. 

So, the Subcommittee asked SC&A to -- as part of 
35

that, they issued another PER for GSI, which is PER80. And as a result, the Subcommittee asked SC&A 

to just do a focused review initially of PER-80 and 

confirm that the revision did resolve the concern.

SC&A was able to do that so the Subcommittee 

closed this observation. Observation 2, external 

photon dose should have been entered into IREP as 

a chronic exposure as opposed to an acute. 

NIOSH indicated that they selected acute versus 

chronic based on dose rate efficiency factors and that 

generally, they select exposure modes that will 

produce the highest PoC. 

Now, in cases of best estimates, they may select the 

chronic exposure rate just because it's more 

reasonable exposure. So, based on that explanation, 

the Subcommittee closed this observation. 

Observation 3, dose distributions for operators during 

the years 1952 through 1961 were derived by 

incorrectly assuming that exposure rates and DCFs 

are totally correlated.

And again, NIOSH's response was there had been 

changes since this observation was dated to the GSI 

site profile and tools. And so those changes were 

issued in PER-80, and SC&A did go into the site 

profile and confirm this issue was resolved with that 

revision.

And based on that, the Subcommittee closed this 

observation. Observation 4, guidance in the GSI 

Appendix cannot be used to assign neutron dose, was 

SC&A's observation. 

And again, NIOSH's response was that the changes 

that were made to the GSI site profile should correct 

this issue and SC&A did confirm the revision results 

our concern. 

And so the Subcommittee closed the observation at 

the February 2021 meeting. Observation 5, this 

observation has to do with entering beta dose into 
36

IREP as a chronic dose, which we previously 

discussed for photon dose under Observation 2.

And again, NIOSH responded by saying that the 

chronic exposure rate is more claimant-favorable, 

however, for best-estimate cases, they may use a 

more realistic chronic exposure rate. 

Onto Observation 6, this is where SC&A observed 

that NIOSH again is using the CADW program as an 

efficiency measure to estimate the internal dose for 

one of the cases of concern. This is similar to our 

Finding 2 previously discussed. 

And NIOSH documented their response in a memo. 

The Subcommittee asked us to look at that memo 

again and just convince ourselves that this issue was 

resolved. 

SC&A did respond in an August 17, 2021 memo and 

determined that since NIOSH agreed to use IMBA for 

best-estimate cases, this issue was resolved.

 Based on that, the Subcommittee closed the 

observation. Lastly, Observation 7, SC&A she said 

that NIOSH assigned medical X-ray dose to a worker 

who stated that --

Dr. Roberts: Excuse me, Kathy, I'm hearing some 

interference in the background. If people could mute, 

please. 

Ms. Behling: Again, NIOSH's response is they had 

made changes to their site profile for General Steels 

Industries and this issue should be resolved. And 

based on SC&A's review of the site profile, we were 

able to confirm that.

Based on that, the Subcommittee closed this 

observation. That concludes the review of PER-57. 

Chair Anderson: Any questions by Board Members or 

the Committee?

Member Kotelchuck: Not I, Dave.
37

Chair Anderson: No questions, the Subcommittee has 

recommended that the Board accept their 

recommendations related to the findings and 

observations and close them out.

I would just say that in all of these, as we have in 

others, when we close out the review of them, they're 

still not fully implemented, so we'll wait to hear from 

NIOSH or get a notice from them when the 

documents ultimately get revised. 

But it's all set to move forward only on the timeframe 

that's needed to do so. So, we have a motion from 

the Committee to close out these reviews. All in favor 

say aye?

(Chorus of aye.) 

Any opposed?

We can move on. 

Ms. Behling: Now, we'll move on to our second PER 

that we've been talking about for General Steels 

Industries and that's PER-80, which addresses 

revisions to Rev. 2 and 3 of the GSI Appendix. 

This PER was issued in August of 2017 and the 

revisions resulted in inhalation intakes increasing 

during 1966 and at least one external organ or skin 

dose increased in each of the operational years for 

radiographers. 

Since Revision 2 and 3 of the GSI site profile were 

reviewed under TBD-6000 Work Group and we also 

performed the focused review of issues identified due 

PER-57. 

Under the Procedure Subcommittee, PER review just 

consisted of evaluating a sample set of impacted 

cases.

This sample set included five cases which were 

selected based on specific employment periods, job 

categories, and cancer types. SC&A submitted its 

report on July 19, 2018 and this review resulted in 
38

the identification of one observation. 

We presented our review to the Subcommittee at the 

February 13, 2019 meeting. Observation is actually a 

repeat of Finding 2 and Observation 6 from the PER57 review, which again states that CADW was used 

for calculating internal dose for a best-estimate case.

And we really recommend that IMBA be used for 

these calculations. It was just noted that at the 

February 2019 meeting NIOSH corrected a previous 

statement where they indicated that the revision to 

CADW would assess doses on a daily intake.

CADW was actually modified to just incorporate the 

prorating approach for partial years so it's still 

considered an efficiency measure. This issue was 

resolved by NIOSH instructing the dose 

reconstructors to use IMBA for all cases with PoCs 

between 45 and 52 percent. 

And based on that response, the Subcommittee can 

close the observation. That was a quick one. We are 

done with PER-80. Any questions? 

Chair Anderson: Hearing no questions, the 

Subcommittee has recommended that PER-80 be 

closed and I'll call for a vote on that. All in favor of 

accepting the Subcommittee's recommendation say 

aye? 

(Chorus of aye.) 

Any opposed? As we move forward, I just want to 

recognize that as a new Chair, I might designate Paul 

to be our parliamentarian to keep us on track with 

our appropriate Robert's rules if that's okay with you, 

Paul. 

Member Ziemer: That's okay, we don't have to vote 

on that I guess. 

Chair Anderson: I know, I just don't want people to 

hear you break in and it's important that we follow all 

the various appropriate procedures.
39

Member Beach: He's been doing it for years, Andy.

Chair Anderson: I know, we all accepted it and 

recognize it.

Member Beach: Much appreciated.

Chair Anderson: We'll give him a pat on the back for 

appreciation. Next, PER-063.

Ms. Behling: PER-063 evaluates cases impacted by 

changes that were introduced into Revision 1 of the 

Aluminum Company of America in Pennsylvania, 

ALCOA. 

The site profile, the dose reconstruction guidance for 

ALCOA Pennsylvania is actually described in 

Appendix R of the Battelle TBD-6000 document.

The PER was issued in June of 2015 and the Rev. 1 

changes include incorporating changes to the TBD6000, which resulted in adding external beta dose 

from surface contamination.

The revision also eliminated the job categories of 

operator, general laborer, supervisor, and clerk, and 

everyone gets a job title of operator. It also 

incorporated the OTIB-70 depletion factors during 

the residual period. 

This resulted in an increase to inhalation and 

ingestion intakes and internal dose increases during 

the operational period. In addition, some residual 

period doses through 1980 also increased. 

SC&A's review of PER-63 was submitted on July 17, 

2017 and there were no findings. The review was 

presented to the TBD-6000 Work Group in 

September 2017 and for our case review, there was 

one case selected where the EE was assigned both 

internal and external dose during the operational and 

residual periods.

The case review report was submitted in September 

2021 and it was presented to the Subcommittee in 

November of 2021. There were no findings but as we 
40

initially or previously agreed to, we would go through 

all of this.

And in fact, I think I tried to spend a little bit more 

time describing the process and the DR methodology 

for these sites so that if maybe the Board Members 

have a finding or a question that SC&A perhaps didn't 

identify.

So, I'm going to spend a little time, there's a little 

history of the ALCOA, Pennsylvania operations. 

They used welding process to can and seal uranium 

slugs produced at other facilities and the work was 

performed under 15 purchase orders and resulted in 

canning of approximately 100,000 slugs.

The AWA operational period was from 1943 through 

1945 and the residual period was from 1946 through 

1991. 

To assess NIOSH's corrective actions in PER-63, it 

was not necessary to evaluate the source documents, 

namely TBD-6000 and OTIB-70 since our review for 

those documents were performed separately. 

So, for this assessment, SC&A just compared the 

elements of the original site profile and the revised 

Appendix R. 

And that included operational period external dose 

rates for whole-body, hands and forearms and other 

skin locations, also operational internal doses 

including inhalation and ingestion intakes. 

And for the residual period, we compared the 

derivation of the floor contamination levels, photon 

and beta dose rates, source depletion rates, and 

calculated the internal and external doses based on 

the source depletion. 

And based on that assessment, SC&A was able to 

confirm that appropriate parameters from the revised 

TBD-6000 and OTIB-70 were applied. SC&A was also 

able to match the Revision 1 operational external and 
41

internal values. 

We verified the accuracy of the calculation of the floor 

contamination levels and source depletion rates and 

finally, we were able to match the revised residual 

dose rates and internal intakes. 

Under our Subtask 3 protocols, SC&A evaluated 

NIOSH's approach to evaluating potentially impacted 

dose reconstructions. For PER-63 NIOSH initially 

included all cases with employment at ALCOA, 

Pennsylvania with PoCs of less than 50 percent.

That resulted in 44 cases, however, 2 were 

eliminated because the dose reconstructions were 

completed using Revision 1 of the Appendix. 5 were 

completed using guidance designed to overestimate 

dose. 

These were completed earlier and so Revision 1 

would result in lower doses than these 

overestimating guidance. Two cases had already 

been returned to NIOSH and reworked under Rev. 1 

and therefore, there were 35 cases remaining that 

NIOSH reworked. 

And so under SC&A Subtask 3, we agree with 

NIOSH's selection strategy and with your screening 

criteria. 

Under Subtask 4, SC&A reviewed a sample set of 

reworked cases, determined if NIOSH properly 

implemented the revisions in Appendix R. 

And our selection criteria included the exposure 

pathways that were impacted by the revision, and 

therefore, we asked for one or two cases where the 

EE was assigned internal and external doses and 

worked during both the operational and residual 

periods. 

NIOSH was able to find one case that met all those 

selection criteria. And SC&A noted that NIOSH 

reworked the case with all of the applicable and 

current dose reconstruction tools. 
42

They recalculated annual doses and they re-ran IREP. 

And in this particular case, because it was a best 

estimate, the IREP was run 30 times at 10,000 

iterations per run. 

It was not necessary to send the formal DR report 

back to DOL since the compensation decision did not 

change. Some generic background about this case, 

the EE worked for approximately three decades at the 

ALCOA, Pennsylvania site. 

He worked throughout the plant, throughout the 

facility, the EE was not monitored for radiation 

exposure and the cancer diagnosis was made 

approximately 20 years after employment 

termination. 

Slide 4 shows a percent difference between the 

reworked and the original dose. External dose 

increased significantly which obviously resulted in a 

large increase in the total dose and the PoC, and 

there was a minor decrease in the external dose.

For these cases, we review the original, we compare 

the original and the worked doses and for the original

dose reconstruction the EE was assumed to fall into 

the category of plant floor high, which is a job 

category where he was expected to get up, it had a 

higher potential of exposure. 

The whole-body dose rates were calculated and taken 

from Table R3 of Appendix R Rev. 00 for the 

operational and residual periods. A DCF of 1.244 was 

applied using the bladder as a surrogate organ.

Those DCFs come from IG-001. And this resulted in 

the assignment of a dose of approximately 500 

millirem. For the reworked external dose, whole-body 

and operational and residual dose rates were taken 

from Table R2 of the revised Appendix R.

As with the original DR, the same DCFs were applied 

and this resulted in a revised dose of greater than 9 

rem difference. 
43

Occupational medical dose, the original DR calculated 

occupational medical dose based on assuming that a 

pre-employment and annual chest X-ray during the 

operational period.

And the doses were associated with a urinary bladder 

as a surrogate organ, and the doses were taken from 

OTIB-6, Rev. 3, Page Change 1. And this resulted in 

an occupational medical dose of 0.1 rem, less than 

0.1 rem.

And now we'll compare what the rework did for the 

occupational medical data. They assigned a chest Xray dose for pre-employment plus annually during 

the operational period.

At that point, the OTIB-6 was revised to a Rev. 6 and 

they used the urinary bladder as a surrogate organ. 

They came up with approximately the same 

occupational dose, less than 100 millirem. 

Going onto internal dose, in the original, again, the 

EE was assigned a job category of plant floor high. 

Uranium inhalation and ingestion intakes were taken 

from the Appendix R Rev 0 and used to calculate 

internal dose.

IMBA was used to calculate the inhalation and 

ingestion doses, and the solubility types M and S 

uranium were compared with Type M resulting in a 

higher dose.

And based on these parameters, a dose of 0.3 rem 

was assigned. For the reworked internal dose, they 

used inhalation and ingestion intakes from Table R1 

of the revised Appendix for both the operational and 

residual periods.

They also used IMBA to calculate the dose and 

compared to the two solubility types with Type M 

generating the higher dose. And a reworked dose was 

assigned for the internal dose of approximately 0.3 

rem. 

In our assessment, we found that external doses 
44

were calculated correctly with the exception of one 

year where NIOSH inadvertently selected the wrong 

dose from the table. This resulted in a slightly higher 

dose for external.

NIOSH select the appropriate surrogate organ in DCF 

values for occupational medical dose. They were 

assigned using appropriate years of employment and 

the correct doses from the applicable tables in OTIBs.

Internal doses we found were calculated based on the 

intake values from Table R1 with the exception of 

again of one year where NIOSH selected a slightly 

lower dose and Type M did result in the higher dose 

as we looked at it. 

And just to elaborate a little on these one-year 

inaccuracies, it's a table and they just selected the 

table from the wrong row and column. The error was 

just selecting the wrong number from the table.

But in the external dose case, the doses are slightly 

higher for internal and slightly lower. SC&A also reran 

IREP 30 times at 10,000 iterations and we were able 

to confirm the POC was less than 50 percent. 

That concludes our review of PER-63. 

Member Beach: Thanks, Kathy, any questions?

Chair Anderson: Is there a recommendation here?

Member Beach: Yes, all of these we're presenting 

today have gone through the Subcommittee and are 

being recommended for closure. 

Chair Anderson: With that, the Subcommittee has 

recommended that after this review, PER-63 be 

closed and the review was successfully completed. 

That is a motion from the Committee. All in favor say 

aye? 

(Chorus of aye.) 

Opposed, no? No nays so the review is closed. Thank 

you all for a very comprehensive approach to 
45

reviewing these cases and I'm glad to see it worked 

out this well. Next. 

Ms. Behling: PER-065 was issued due to revisions due 

to the Anaconda site profile. This PER was issued in 

November of 2015 and it determines the effect of 

Rev. 1 to Appendix G of TBD-6000. That's where the 

Anaconda site profile information resides. 

The revision incorporated the changes to TBD-6000 

which is the beta doses and it also made dose 

estimates more consistent with the current 

techniques. 

This resulted in an increase in external doses for all 

job categories for all years of operation and although 

it was not explicitly stated in the PER, the revision 

also incorporated the OTIB-70 depletion factors.

And there was an update to the occupational medical 

dose guidance, which was used because of the timing 

of this change. SC&A's review, we submitted our 

review of PER-065 on June 15, 2016. 

Because we had not previously looked at the DR 

methodology for Anaconda, under our Subtask 2 we 

did review that methodology. There were no findings 

and the review was presented to the TBD-6000 Work 

Group in September of 2017. 

For the case review, there was one case selected 

based on the criteria again that the EE was assigned 

external dose as an operator during the operational 

period and was also assigned occupational medical 

dose.

Our Subtask 4 report was issued on August 25, 2021 

and it was presented to the Subcommittee at the 

November 3, 2021 meeting. There were no findings 

identified with a review of this reworked phase. 

A little history of Anaconda, 1956 pilot project was 

done at Anaconda where uranium billets were 

extruded to evaluate extrusion procedures to 

manufacture uranium fuel. 
46

And in March of 1957, about 50 billets were extruded 

and additional extrusion activities were performed in 

October of 1959. 

So, SC&A's review of the Anaconda DR methods 

included comparing the original and revised version 

of the TBD-6000G to determine if the revised 

Appendix accurately describes the operation and 

residual AWE activities. 

If the revised reflects site-specific information and 

data necessary for performing the dose 

reconstructions, and if the revision properly 

incorporates current guidance from TBD-6000, OTIB70 and TBD-006, which is our occupational medical 

TBD.

And to ensure the Appendix uses all applicable 

information, data, and guidance in a scientifically 

sound and claimant-favorable manner.

SC&A found the Appendix accurately extracted and 

interpreted the reference data source. In addition, 

SC&A looks at sources of data that were not 

referenced in the site profile and they were able to 

find that the data corroborated cited information 

sources.

SC&A agrees with NIOSH's assumptions and the 

derivation of external and internal doses. The only 

inconsistency that was found is there was an 

incorrectly cited DOL URL, but it's a minor 

inconsistency. 

For identifying potential cases that were affected by 

PER-065, NIOSH searched all Anaconda cases with 

PoCs less than 50 percent and this search identified 

10 cases and they reworked all 10 cases, and SC&A 

is in agreement with that selection strategy.

Under Subtask 4, SC&A recommended that a case or 

cases selected have external dose assigned for 

operator and laborer or job category, and that the 

employment be during the period of 1956 through 

1959 and that there be occupational medical exams 
47

dose included in the dose reconstruction. 

NIOSH did identify one case that met the selection 

criteria. 

Again, NIOSH reworked the case using the 

appropriate tools and recalculated the annual dose 

and reran an IREP. Since the rework case resulted in 

a PoC of less than 50 percent, it was not necessary 

to send a revised DR report to the DL.

SC&A's case review is typically limited to those 

pathways addressed in the PER and for the Anaconda 

site profile, the revision only increased the external 

doses. 

However, when we looked at the case and we realized 

that the internal doses significantly decreased 

between the original and reworked, we decided it 

would be of interest to the Subcommittee and Board 

for us to look at the reason for that change. 

Again, some generic background for this case, the EE 

worked for three decades at the Anaconda site. 

The EE's job classification indicated that he worked 

throughout this site and the EE was not monitored 

and was diagnosed with a qualifying cancer several 

years after employment termination.

This table presents a dose percentage again of the

differences between the reworked and the original 

dose. And as shown, the external dose decreased by 

95 percent and the internal dose also decreased by 

nearly 100 percent.

Only the occupational medical dose increased. So, in 

looking at the original external dose calculations, 

these calculations were actually done prior to the 

issuance of TBD-6000 Appendix G using Scherpelz 

2006.

This guidance was conservative in assuming that the 

EE was exposed at one foot from a rectangular 

uranium slab for three days in 1956 and 30 days in 
48

1959 for a 10-hour workday at 2.08 millirem per 

hour.

Doses were calculated based on a bladder being the 

surrogate organ, and therefore, applying a photon 

DCF of 1.523 and this resulted in the assignment of 

greater than 1 rem of external dose. 

For the reworked, obviously, the reworked used Rev. 

1 of Appendix G and external doses were taken from 

Table G2 for each of the operational years. 

The bladder was assumed as the surrogate organ in 

accordance with OTIB-5, Rev. 5, and therefore a DCF 

of 1.064 was applied.

This resulted in an assigned dose of about 50 

millirem. Occupational medical dose for the original 

dose reconstruction, the dose reconstruction 

assumed an annual X-ray for each year of 

employment.

The urinary bladder was assumed as the surrogate 

organ and the doses were taken from OTIB-6, Rev3, PC1, and this resulted in the assignment of 

approximately 100 millirem of external dose, 

occupational medical dose. 

For the reworked medical dose, also an annual X-ray 

was assumed for each year of employment. In this 

case, they used the gall bladder as the surrogate 

organ, that's based on guidance in OTIB-5. 

Doses were taken from OTIB-6, Rev. 4, and this 

resulted in an occupational medical dose of a little 

more than 300 millirem. 

Internal dose, the original internal dose calculations 

assumes uranium intakes during the extrusion 

operation of nearly 3000 picocuries per day and 

during the rolling operations of more than 10,000 

picocuries per day in 1956 and 1959 using operator 

data from Table 7.8 of Scherpelz. These intakes were 

derived from -- I wanted to give you an 

understanding of how they derived these data. They 
49

used air sample data from several AWE metal 

working sites and as we'll see in the revised, I explain 

where they got their intakes. 

And they assumed a 30-day intake for each process 

for each year. In addition, the intakes for recycled 

uranium for plutonium-239 and neptunium-237 were 

scaled based on uranium intakes, and IMBA was used 

to calculate the dose.

It was based on the claimant-favorable Type M 

solubility. Both inhalation and ingestion intakes were 

applied as an inhalation which is another claimantfavorable assumption.

And this resulted in the assignment of approximately 

0.25 rem. Now for the rework, NIOSH used inhalation 

and ingestion values from Table G1 of the revised 

Appendix G and the inhalation values range based on 

year of operation.

And that range was from 0.66 to 3.74 DPM per day. 

And I wanted to make note, as I said, the intake rates 

specified in Table G1 were derived from the highest 

air monitoring reading of 39 DPM cubic meter in the 

Anaconda work area in 1956 and 1959. 

Doses were calculated for each year of operations 

and again, IMBA was used to calculate the dose and 

Type M was found to be the most claimant-favorable 

solubility. This resulted in an internal dose 

assignment of approximately 1 millirem. 

SC&A reviewed the PER-065 case and found the 

reworked external doses were appropriately assigned 

based on Rev. 1 of Appendix G. Appropriate 

surrogate organ was selected from OTIB-5.

The doses were correctly entered into IREP and I just 

wanted to note that if this dose reconstruction or the 

original dose reconstruction would have been 

performed using Rev. 0 of Appendix G, the reworked 

external doses would have increased. 
50

Since we were comparing external doses to the 

Scherpelz document in 2006, the external dose is 

actually decreased. For the reworked occupational 

medical dose, again, appropriate doses were based 

on OTIB-6.

The selection of a surrogate organ was appropriate 

based on OTIB-5 and doses were correctly entered 

into IREP. 

And finally, for the internal dose the reworked 

internal doses were calculated based on intake values 

specified in Rev. 1 of Appendix G and not Rev. 0 as it 

states in this slide, I apologize.

The input data was correctly entered into IMBA and 

the assumptions were claimant-favorable so SC&A 

has no findings with the selected reworked case 

impacted by PER-065. 

Are there any questions? A lot to digest here.

Member Kotelchuck: Yes, this is Dave, it was a pretty 

thorough job that you did and it seemed to me a good 

job.

Chair Anderson: It gives us a good historical look at 

how things have evolved over the years and I think 

that was very helpful. Any other questions people 

had? They're recommending that the Board close our 

PER-065.

All in favor say aye?

(Chorus of aye.) 

Any opposed? With that we'll close out PER-065 with 

a big thank you to SC&A and NIOSH for reworking 

these.

Ms. Behling: Okay, we'll move on to PER-064. PER064 addresses revisions to the DuPont Deepwater 

Works site profile. And this PER was issued in 

November of 2015 and it determines the effect of 

several changes to the DuPont Deepwater DR 

methodology. 
51

Initially, the dose reconstructions were done under 

Appendix B from TBD-6001 but due to the 

cancellation of TBD-6001, NIOSH created a 

standalone document for the DuPont Deepwater site 

profile in 2011. 

And that resulted in some operational period doses 

increasing while others decreased and then in 2013, 

Revision 1 was issued of the TBD and this revision

increased operational inhalation intakes, operational 

external dose rates, and residual ingestion intakes.

And then finally, in 2015, Rev 2 was issued and this 

revision corrected an error in the ingestion intakes 

and increased all ingestion intakes during the 

operational period. 

In this case again, SC&A had previously reviewed the 

DuPont Deepwater TBD and therefore, under the 

Procedure Subcommittee purview, the PER-064 

review consisted of just evaluating a sample set of 

impacted cases. 

We reviewed two cases under our Subtask 4, one 

case that resulted in a PoC between 45 and 50 

percent, it was a best estimate case and one case 

with external and internal dose assignments during 

the operational and residual periods.

We submitted our review of those cases December 

12, 2016. We presented our findings to the 

Subcommittee at the October 31, 2018 meeting and 

there were no findings, but we will go through them.

For Case 1, this is our best estimate case, the EE 

again worked for approximately three decades, the 

EE worked throughout the site and was not 

monitored. 

Several years after employment termination the EE 

was diagnosed with two qualifying cancers.

As shown here in Slide 73, external doses decreased 

and there were modest increases in the internal and 

occupational medical dose, and I also have to note 
52

that under our internal dose for Cancer 2, that value 

should be 0.4 percent.

Again, I apologize for that mistake. Original external 

dose for Case 1. External doses were calculated 

assuming that this person fell under the plant floor 

low category. 

And the operational doses were based on Table B3 of 

Appendix B Rev. 00. That guidance specifies that 

operational dose for 1942 is 642 millirem per year 

and for years 1943 through 1948, 1161 millirem per 

year.

Annual doses for the residual period are listed as 40 

millirem per year. Again, the IG-001 exposure to 

organ DCF value was applied and a dose of 

approximately 3 rem to Cancer 1 and 5 rem to Cancer 

2. And these doses were entered into IREP as 

constant values.

The reworked external dose, the operational dose, 

the individual was classified under the job category 

of laborer and the guidance specifies an operational 

dose of 672 millirem per year, and recommends that 

the photon energies be split 50-50 between 30 to 250 

KEB and greater than 250 KEB. 

Again, they used the IG-001 exposure to organ DCF 

value, but in this case, the data was entered into IREP 

as a log normal distribution with a geometric 

standard deviation of 5. 

For residual doses information, our doses come out 

of Table 8, and annual doses are 7.3 millirem for all 

workers. It's assigned as 100 percent, 30 to 250 KEB 

photons and again, DCF values from IG-001 and the 

data is entered as a constant for the residual doses. 

This resulted in the assignment of approximately 2 

rem for Cancer 1 and 1.5 rem for Cancer 2. 

And again, using the laborer doses from the revised 

TBD and the appropriate DCF values and energy 

fractions, SC&A was able to match the NIOSH-
53

derived doses for the operational and residual 

periods.

SC&A was also able to verify that the annual doses 

were entered into IREP in accordance with the TBD 

guidance. And so we had no findings with the 

calculation of external dose. 

Internal dose, for the original dose reconstruction 

guidance recommends for the operational intake 

inhalation intakes of 1428 DPM per day and ingestion 

of 25 DPM per day. 

And that comes from TBD-6001 Appendix B. For the 

residual period, Appendix B guidance specifies 0.329 

DPM per day for inhalation and 0.00385 DPM per day 

for ingestion. 

IMBA was used to calculate the dose and Type F was 

considered the more claimant-favorable for uranium234. 

This resulted in the assignment of a dose of 2 rem for 

Cancer 1 and approximately 7 rem for Cancer 2. The 

doses were entered into IREP as a constant. 

For the reworked internal dose for the best-estimate 

case, NIOSH assumed a job category of supervisor 

and laborer.

The operational intake values were taken from Table 

1 of the revised TBD and those intakes, the inhalation 

intakes were 1428 DPM per day and 27 DPM per day 

per ingestion. 

For the residual period, Table 10 also specifies an 

inhalation of 0.329 DPM per day but the ingestion 

changed to 30.1 DPM per day. All solubility types 

were compared, assuming 100 percent uranium 234 

with Type F resulting in the highest dose. 

For the residual period, solubility types M and S were 

compared and Type M was more claimant-favorable. 

This resulted in a total assigned dose for Cancer 1 of 

approximately 2 rem and approximately 7 rem for 
54

Cancer 2.

Again, all doses were entered into IREP as a constant 

value. For Case 1, SC&A evaluated the internal doses, 

SC&A compared the appropriate solubility types for 

the operational and residual periods. 

We ran IMBA using the inhalation and ingestion 

intake values and compared all the solubility types. 

We found the annual doses were correctly entered 

into IREP and in accordance with the TBD. 

And again, we reran IREP and we were able to 

determine the PoC approximated NIOSH's PoC.

And I will note here that although the doses

decreased, the PoC increased for this case, and this 

was primarily due to the changed guidance which has 

the doses for the operational period being entered 

into IREP as a log normal distribution with a GSD, 

geometric standard deviation, of 5.

That's what prompted that increase in PoC. We'll 

move on to Case 2 and Case 2 is the EEO who worked 

at DuPont Deepwater for the operational and residual 

periods and was assigned both internal and external 

doses.

This individual worked for more than three decades. 

The individual was not monitored for exposure and 

was diagnosed with one qualifying cancer several 

years after termination of employment. 

Our comparison table here shows that external doses 

decreased while internal doses and occupational 

medical does slightly increased. However, the PoC 

increased. 

The original external dose, the worker was assumed 

to have a high exposure potential and was therefore 

included in the plant floor high job category. 

Operational doses were taken from Table B3 of Rev. 

00 of Appendix B and again, just citing there under 

the third bullet, the operational doses that are 
55

included in the Rev. 00 Appendix B doses during the 

residual period, again 40 millirem per year. 

NIOSH originally applied an exposure to organ DCF 

value from IG-001 and used the bladder as a 

surrogate organ and this resulted in the assignment 

of approximately 10 rem of dose and the doses, the 

annual doses, were entered into IREP as constants. 

For the reworked external dose, the doses were 

calculated by assuming that the job category was 

operator. 

Again, same values used for the operational doses, 

672 millirem per yea, the photon energy in this case, 

50-50, between 30 to 250 KEB and greater than 250 

KEB.

Same DCF values were applied, however, again, the 

annual doses were entered into IREP as a log normal 

with a GSD of 5. And this is what impacts our POC 

calculation. For the residual doses, again they used 

Table 8 and 7.3 millirem per year for all workers.

Photon energy is assumed to be 30 percent, 30 to 

250 KEB, applied appropriate DCF values and entered 

the data into IREP as a constant. This resulted in an 

assignment of a dose of approximately 5 rem. 

Now, for SC&A's conclusion, again, we used the 

guidance, the update guidance for the DuPont 

Deepwater site profile and we were able to match 

NIOSH's operational and residual external doses. 

We also confirmed that the doses were entered into 

IREP in accordance with the guidance and we had no 

findings with the external dose calculations. 

Lastly, internal dose for the original DR, I have listed 

here in the first bullet which we discussed before, 

these are the operational intakes from TBDs-6001 

Appendix B.

And residual intakes for inhalation, same as we 
56

discussed before, 0.329 DPM per day and ingestion 

of 00.00385 DPM per day. IMBA is always used to 

calculate the dose and they assumed 100 percent 

uranium-234 with a Type F solubility.

And that resulted in an assignment of approximately 

45 rem of internal dose. That was entered into IREP 

as a constant. For the rework, again, pretty much all 

of the same parameters.

The rework assumed the job category was operator 

and again, the only thing that really changed here 

was the ingestion intake of 30.1 DPM per day as 

compared to 0.003. 

Again, a comparison of the solubility types F, M, and 

S were done for uranium-234 for the operational 

period with Type F representing the most claimantfavorable dose.

For the residual period, Types M and S were 

compared and Type M was the more claimantfavorable. And this resulted in a dose of 46 rem that 

was entered as a constant. 

Finally, SC&A again looked at all the data, we looked 

at NIOSH's assumptions, we found them to be 

reasonable and claimant-favorable, we ran IREP and 

determined that the PoC approximated NIOSH's PoC.

And just to note again, the doses decreased but the 

PoC increased and that was due primarily to entering 

the operational data as a log normal distribution with 

a GSD of 5.

That concludes PE-64. I'm sure you're going to be 

ready to have me stop talking. 

Chair Anderson: Are there any questions? Go ahead, 

Josie.

Member Beach: I was going to say same thing, 

questions, but Kathy, you have presented a very 

thorough discussion on all of these and it's much 

appreciated by the Subcommittee. You've also kept 
57

it very timely. 

Ms. Behling: Thank you. I will ask, is this too much 

information? 

Would you recommend in the future -- I actually, as 

I stated, wanted to give a little bit more information 

about the information that was in the DR 

methodology when we didn't have findings just so 

that the Board would have an understanding of that. 

I hope I didn't overdo it and if I did, I'm open to 

suggestions as to how to better present this data in 

the future. 

Member Kotelchuck: Kathy, I would say as I was 

going over the 45th of 89 slides the other day, I said 

to myself, couldn't you please spread this out over 2 

meetings? And therefore, what I suggest is that it 

was really an awful lot of information.

Very well put, very clear and concise but there was 

so much of it. So, I would just say if you could give 

it to us in slightly smaller doses it would be --

Ms. Behling: I'm going to have to blame Josie for that 

one. 

Member Beach: I was going to step up, Kathy, and 

take full responsibility. During our Subcommittee 

meeting, we discussed if we should have five or 

seven because we have such a large backlog.

And most of these I thought would go faster because 

there was no findings, however, I think it's important 

to be clear about what was discussed and how SC&A 

proceeded.

So, there might be more information than is 

necessary, it's a balance. And I guess that's why 

Kathy's asking. We would like to get through the 

backlog and spreading it out between the meetings.

We have after this maybe 25 backlogs still, Kathy.

Member Kotelchuck: I see.
58

Member Beach: We're going back through a lot of 

history. 

Member Kotelchuck: Okay, because it seems to me 

there was no case where you gave us too much 

information, it was just so much of it at once. 

But I understand the problem and with our 

Subcommittee on Dose Reconstruction reviews, we 

started with a backlog a couple of years ago. 

And I know it was awkward in putting a lot of 

information at once, but if you have to do it you have 

to do it and I accept it. But it was quite clear what 

was done and it was reasonably concise for each one 

of them.

Member Beach: And Dave, moving forward, the sites 

that have a lot of findings and a lot of discussion, 

those will be presented in 1s or 2s, and I don't know 

how to say it. Kathy, you can probably state it better 

than I can.

Ms. Behling: You're saying it perfectly fine. I present 

to the Subcommittee a table that lists, okay, here's 

what we have in the backlog, here's how many 

findings. 

And I also include a comment column that makes sort 

of a recommendation as to whether I even think this 

is geared to doing what we did today and putting 

these things in a matrix-type format and 

summarizing them.

In some cases, OTIB-52 comes to mind, there's so 

much associated with that, there's such a history, we 

may have to do that as one single presentation.

We were a little bit overzealous maybe here. When I 

realized I had 88 slides, I thought, oh, but we will 

give that thought I think in the future. 

Member Beach: Yes, we do have a meeting in May on 

the 25th and we will discuss the next step for the 

following Board Meeting. We'll keep that in mind. 
59

If anybody has any other discussion, if you just send 

an email to me or Rashaun we'll get it to the 

Subcommittee and we can use that to move forward 

with how many to present at a time. 

Member Clawson: This is Brad, I wanted to 

compliment you guys actually. I know there's a lot 

there, I understand about the backlog. Kathy, I want 

to tell you how much I appreciate how you put this in 

and some of the detail that's in there.

Because as I was reading them the other day, it really 

helped me follow what the process was and what you 

did. I just appreciate what you guys have done and 

it helped me follow along and go through all this.

I know there's a lot there but sometimes coming back 

to it, it makes it a little bit harder too. 

Ms. Behling: The other thing I will make mention of. 

In the presentation, if you saw things that were in 

blue and underlined, that would lead you back to that 

document. 

And so unfortunately for a lot of the PER Subtask 4 

cases, because there's obviously a lot of sensitive 

information, they do not get published. There's no 

PA-cleared version typically of those. 

So, that's why I spend a little bit more time 

discussing them. 

But I did present in the slides when we gave the 

presentation to the Board so you could go back to 

transcripts perhaps if you had questions or if you 

were interested in getting additional information. 

Member Clawson: Kathy, I really appreciate you 

putting that in there. We understand with privacy 

acts and everything else but it makes it very clear for 

me to be able to understand where I can go and so 

forth. 

I appreciate that. 

Ms. Behling: I appreciate everyone's feedback. Thank 
60

you. 

Member Beach: If we get to a conversation that is 

something we can't answer, we will not close out that 

item until we've answered the question and we would 

definitely move that to the next meeting. 

So, we don't want to push these on anybody but we 

are attempting to clear out some backlogs.

Chair Anderson: Let's vote on this last one here. We 

have a recommendation to close our PER-064. All in 

favor say aye?

(Chorus of aye.) 

And any opposed? And I would just add to the 

comments that were made that I think it's important 

that all of the information that you present, get it in 

the public record because I think not everybody can 

attend or listen to the meetings. 

And it really shows how exhaustive we do the reviews 

and how careful it is and how well, actually, the 

historical record stands out. So, we're not identifying 

a lot of problems.

Some changes need to be made but it's change-over 

time, importantly. So, I don't think they've lost 

anything but, yes, there is a lot but it also now is 

formally in a record.

You only have to go through it once. 

Member Beach: That's correct, and some of these 

look like they were closed but we're not sure so we're 

going to make sure that we have the discussion and 

officially close them in the proper way moving 

forward.

Chair Anderson: Okay, we're just three minutes over 

here so I think it's time to take a break and we'll

come back at 4:00 p.m. Eastern Time to take up the 

Reduction Pilot Plan SEC.

Member Beach: Thank you for your time.
61

Chair Anderson: Thank you for your presentation. 

(Whereupon, the above-entitled matter went off the 

record at 3:33 p.m. and resumed at 4:06 p.m.) 

Chair Anderson: Okay, we'll begin. Just to give you a 

real quick background, NIOSH presented their 

Evaluation Report to the Board a while back and the 

Board tasked SC&A to review it and assign the ARWE 

Subcommittee to review it as well. 

And we met, SC&A completed their review, on 

February 17th so it's been moving fairly rapidly and 

we're bringing now the discussion and review to the 

full Board.

Ron, take it away.

Update on review of SEC-00253 Reduction Pilot 

Plant, Huntington, WV: Jun. 7, 1976-Nov. 26, 1978

Dr. Buchanan: Thank you, this is Ron Buchanan and 

today I'll be presenting SC&A's review of NIOSH SEC253, Petition Evaluation Report for the Reduction 

Pilot Plant in Huntington, West Virginia. 

And I thank Rose for running the slides, please open 

the next one. 

We've got a little overview of the RPP. It's also known 

as the Huntington Plant, it occupied about four fenced 

in acres in addition to a larger nickel plant operated 

by the International Nickel Company.

The RPP was built by the EC in 1951 to supply nickel 

powder. 

Nickel powder was used to make the gaseous 

diffusion barriers for the gaseous diffusion plants in 

Paducah and Portsmouth and it employed from 20 to 

25 employees in its peak operation.

In 1956 the facility began using contaminated feed 

material and that was nickel with low-enriched 

uranium. Next slide. Here's a 1963 photograph of the 

reduction plant and you see the tall building is 
62

actually a processing plant.

The smaller building is a compressor plant and then 

there's some storage tanks associated with it. Next 

slide. 

A little bit of history in the SEC period, the operational 

period was 1951 through April 30, 1963 and it went 

into standby May 1, 1963 through November 26, 

1978. 

The D&D of classified and contaminated material took 

place in November 27, 1978 through May 18, 1979 

and the special exposure cohort 253 evaluation 

period was June 7, 1976 to November 26, 1978. 

This SEC period was during the latter part of the 

standby period and the standby period wasn't initially 

covered by the act and it was added in November 

2019 and there's no other SECs that have been filed 

for this facility.

The conditions during the standby period was that 

the operational activity ceased in 1962, the building 

was put in standby condition thinking it might be 

used again, but it never was. 

It was estimated that the entry by the security guard 

was once per shift, which would be three times daily, 

to check the processing compressor rooms and 

maintenance check to maintain operational 

capabilities ceased in 1975 in Oak Ridge.

Operations determined they would no longer need 

the nickel production and during some of that time, 

there was infrequent inspections on a biannual basis.

Next slide. This is the long history of the TBD for the 

RPP and some of the other documents. It started out 

TKBS-004, Revision 00 in October 2003 by Oak Ridge 

associating adversely, and OCAS took it over and 

then DCAS took it over.

And you go down that list and the important part is 

the TBD Revision 2 of November 2018 and then the 
63

SEC-253 qualified in December of 2019. So, that's 

what we'll be discussing today, the current SEC-253. 

Next slide. 

NIOSH issued an Evaluation Report for this SEC in 

April of 2020. The class evaluated was all 

international nickel company security personnel who 

worked at any location within the RPP facility during 

the period of June 7, 1976 to November 26, 1978. 

And NIOSH's ER concluded that all external and 

internal doses for security personnel can be 

adequately constructed during a 60-feet barrier.

Next slide. Some of the internal monitoring and 

potential exposure sources at this facility would find 

that there's no individual internal monitoring data 

during this SEC period since it was in a standby 

period.

And the process building was surveyed in January 

1975, found very little removable contamination and 

the highest amount of fixed contamination was found 

in the residual systems in the residue and perhaps 

some of the files and piping. 

Low-enriched uranium was assumed at 1.4 percent 

enrichment and recycled uranium contaminants were 

assumed present. The standard plutonium, uranium, 

and neptunium is listed there. 

And all major material for the dose reconstruction 

was considered as alpha contamination assumed to 

be uranium and the contamination ratio then for the 

impurities were assumed using the K25 barrier 

material in the dose reconstruction assessment. 

Next slide. 

The external is similar there, no individual external 

monitoring during the SEC period. 

A 1975 survey determined that the dose rate was in 

the background of most places with a maximum of 

250 micro-R per hour contact reading on some of the 
64

equipment assumed to be beta for dose 

reconstruction. 

A 1980 survey taken post demolition found a 

maximum of 35 micro-R per hour at three feet 

assumed per gamma dose reconstruction and 45 

micro-R per hour for the maximum contact reading. 

The site profile medical X-ray information of course 

was not identified so dose reconstruction used the 

generic annual medical exams when dose 

reconstruction is done for this facility. 

Next slide. So, SC&A reviewed the Evaluation Report 

that was passed in September 2020 with a review for 

the focus group of security personnel. And we issued 

a review in April of 2021. 

And NIOSH responded to that review in a 

memorandum very quickly after that, April 29, 2021, 

addressing any concerns we had. Next slide. When 

we reviewed the ER, we did two major steps.

Number one, we verified the survey information from 

Oak Ridge operations and found that it was correct. 

And the second step was we did claim reviews. 

SC&A reviewed the seven claim records in the NOCAS 

files associated with this facility to identify any 

further information that might help us determine the 

feasibility of dose reconstruction for this security 

personnel during this SEC period.

We found that 44 claimants worked for a portion or 

all of that period at that facility. Next slide. Our 

results were that SC&A did not identify any 

information that would impact the feasibility of dose 

reconstruction during the SEC period for the security 

personnel.

When we evaluated this, a key facet of the proposed 

DR process, including exposure times, that was 

something that was somewhat unknown and 

exposure time was the time spent inside the facility 

by the security guards with residual contamination 
65

graphs present.

And the estimation of that time for the activities 

needed to be characterized and bounded for the 

affected workers. Next slide. Okay. So, when we did 

this evaluation, and did come up with an observation 

that the exposure time could use further refinement, 

because the CATI interviews indicated that exposure 

time might be longer than the original 15 minutes a 

day.

Claimant A had to check all seven floors and a 

parameter was stated. And Claimant B estimated it 

took him about 30 minutes per day.

So, SC&A recommends NIOSH attempt to contact 

and to interview with security guards or other 

workers with knowledge to get a better bounding 

estimate of the walk through time.

And however, we'd like to emphasize that the 

assumptions made about the exposure time should 

not preclude DR feasibility and be considered site 

profile issues for the SEC issues. Next slide.

Okay. So, NIOSH responded to observation in April 

of 2021 with a revised estimate of time spent in the 

facility was 52 minutes per day, six days a week, 250 

days per year, for a total of 260 hours per year.

The previous estimate was around 93 hours per 

years. So, it was still about a factor of three greater.

And they estimated this by estimating it took about 

five minute per floor, multiplied by the seven floors. 

And then the parameter walked about 4.4 feet per 

second for a parameter check.

And like I say, this increased exposure time by a 

factor of three. Next slide, please.

And so, NIOSH's response was to assume for the ER, 

they assumed that the maximum dose rate of 0.035 

millirem per hour to complete the ER in a timely 

manner. That's the maximum dose rate that was 
66

measured, or calculated.

And NIOSH will evaluate all of those rates to obtain a 

better realistic value. In other words, more of a best 

estimate, considering all the dose rates and the 

maximum that was used for the ER evaluation.

And that the TBD will re-revise and consider all the 

various dose rates throughout the plant. And they'll 

add the standby period of 63 to 78 through to TBD. 

We can go to the next slide.

And NIOSH wanted to emphasize that their overall 

annual doses maybe lower then what the ER had, 

because even using the longer exposure time, if you 

consider all the lower, the dose rates and make a best 

estimate, the average maybe lower and may result 

in a lower total assigned dose, but more realistic. 

Next slide.

Okay. We evaluated NIOSH's response, and we 

looked over their reasoning and calculations, and we 

concur with NIOSH's reevaluation of the potential 

exposure time, and find it reasonable.

We concur with NIOSH using their maximum dose 

rate to facilitate the completion of the ER. And we 

also find it appropriate to consider all the applicable 

dose rates for a best, a more realistic dose exposure 

rate in the revised site profile.

So, we recommend that Observation 1 be designated 

as an abeyance, pending a revision of the site profile 

and our review of it. Next slide.

Now, we had another observation in the ingestion 

intake was not addressed in the ER during the SEC 

period. Now, in the site profile, Tables 3 and 4 list 

ingestion intake values for the workers during the 

operation and -- and D&D period.

However, the ER did not address potential ingestion 

intakes for the SEC period. And however, we realized 

it would be relatively small, but it should be 

addressed. Next slide.
67

NIOSH responds to Observation 2, that the ingestion 

dose for the security guards be estimated based on 

contamination levels.

Since the ER used an alpha contamination value of 

19 dpm per 100 square centimeters, to estimate the 

inhalation intake, they used Reg Guides to derive a 

potential ingestion intake of 0.19 disintegrations per 

hour of alpha for this group.

And the details for assigning ingestion intakes will be 

included in the revised site profile. And next slide. 

Rose, can we have the next slide?

Okay. So, we evaluated Observation 2. Okay, we 

concur with NIOSH's recommendation, that they 

address ingestion intakes. That's a pretty standard 

procedure.

And we recommend that Observation 2 be in 

abeyance pending the changes in the site profile and 

our review of it. Okay. Next slide.

Okay. So, summary of the SEC review. We came up 

with likely site profile issues. Observation 1 was the 

concern with the exposure time.

And we concur with NIOSH's reevaluation of the 

potential exposure time and all applicable dose rate 

data. We recommend again that they be in abeyance 

until we review the site profile.

And the same way with Observation 2, ingestion 

intakes, we concur with NIOSH's recommendation. 

And recommend that be in abeyance until we review 

the site profile. Okay, next slide.

So, in conclusion, we concur with NIOSH that upper 

bounds can be established for internal and external 

exposure. And we concur that dose reconstruction is 

feasible for security personnel during the SEC period.

And this presentation was brought before the URAWE 

work group, and discussed on February 17, 2022. 

And concur that the DR is feasible for security 
68

personnel during this SEC period. Okay. Next slide.

Okay. So, that's the summary of our presentation. 

And any questions?

Member Kotelchuck: If I may say, Dave Kotelchuck. 

First, if you'll go back to slide 14, there are a number 

of typos on that slide it seems to me. Fourteen?

Right. If there are 52 minutes a day, and 250 days a 

year, then the number has to be less than 250. It's 

in fact 217.

But, you also said that they work six days a week. 

So, there would be more than 250 days per year. Six 

times 52, there are 312 days that they work if they 

work a six-day week.

And then at 52 minutes a day, it's 270 hours per year. 

So, it's just arithmetical little things.

But, that should be corrected. I think it's in error.

Dr. Buchanan: Okay. I'll check into it. But, 260 is 

correct. I'll check into the other items that you 

mentioned. Thank you.

Member Kotelchuck: Okay.

Dr. Taulbee: This is Tim. If I could interject here. You 

are correct, Dr. Kotelchuck. It should actually be, if 

you go by the six days a week times 50 days, or 50 

weeks per year, allowing for two weeks of vacation, 

times the 52 minutes per day, you end up with 260 

hours per year.

Member Kotelchuck: Ah, okay. And you're right, and 

I used 52 week per year, even though they take a 

few, a couple of weeks' vacation. Fine.

So, there's -- there is no error actually. Thank you.

Chair Anderson: Are there other Board questions? 

And while you're thinking, I believe the Petitioner is 

on the line.
69

And I would like to let her speak for a minute. And 

you may have some questions of her as well.

I'm trying to look through my list on here. Was she 

able to get on? I don't see Rashaun.

Dr. Roberts: No, I'm here. And I think there might be 

a little bit of confusion. The person that I know of, 

was going to speak for the public comment session.

Chair Anderson: Oh.

Dr. Roberts: And that's Dr. DeGarmo. I don't know if 

the Petitioner was here for our meeting.

Chair Anderson: Okay. Okay. I thought she was. 

Well, if not, are there other questions that people 

have?

Sort of an unusual, in that there's no individual 

measures. But, there is a whole area of 

characterization.

Member Kotelchuck: Well, Andy, I mean the -- the 

activities are uniform, regular. And the background 

radiation levels are known. And they're not going to 

change because there's no operations going on there.

So, this is to me an unusual case where we don't have 

individual measurements. But, we have a process 

that's so clear cut with the area, you know, with the 

area exposures that it seems to me one can evaluate, 

properly evaluate the exposures.

And therefore, not -- an SEC is not needed. It's not 

appropriate.

Chair Anderson: We're in agreement. Yeah. One --

one thing we need the, as our small subcommittee of 

three, in reviewing the transcript, found that we did 

not make a formal recommendation to the Board that 

we accept NIOSH's determination.

Member Kotelchuck: Oh.

Chair Anderson: And so, we really need that. So, I 
70

would ask Dave, you or Bill, make such a motion and 

our committee can --

Member Kotelchuck: Right.

Chair Anderson: Vote to pass it onto the Board as a 

recommendation to accept NIOSH's --

Member Kotelchuck: Absolutely. So moved.

Chair Anderson: Follow through.

Member Kotelchuck: So moved.

Chair Anderson: So Bill, or if you're still on, are you 

in agreement? You've got to take it off mute, Bill.

Member Kotelchuck: I mean, that was a formality. 

We --

Chair Anderson: Yes.

Member Kotelchuck: We absolutely agreed in the 

meeting that the -- at the recommendation at this 

point.

Chair Anderson: Well, I -- I agree with moving it on 

complete. Two out of three is okay if Bill is unable to 

get on. He may have stepped away.

Member Kotelchuck: Yes. Exactly.

Chair Anderson: So, then the motion to the Board is 

to accept NIOSH's recommendation that we agree 

with their recommendation that a class not be added 

to the SEC.

So, that's the motion before the Board If others have 

any comments they would like to make?

I would call for a vote, and all those who are in favor 

of accepting NIOSH's recommend --

(Simultaneous speaking.)

Dr. Roberts: Actually --
71

Member Kotelchuck: No. No. Wait a minute. And we 

need to have a roll call.

Dr. Roberts: Yeah. We have to do --

Chair Anderson: Yeah, okay. Do a roll call. Rashaun, 

you're on mute.

Dr. Roberts: Oh, I'm sorry, yes. I was trying to say 

that yes, we need to do --

(Simultaneous speaking.)

Chair Anderson: We need to do a roll call vote.

Dr. Roberts: Yes, correct. So, and you would come 

up last, Andy. So, starting with Beach?

Member Clawson: She just texted me, Rashaun. She 

just cut off from the meeting.

Dr. Roberts: Okay. Nothing like --

(Simultaneous speaking.)

Member Clawson: She was going to -- she's trying to 

get back in. So, you'll have to go to me next.

Dr. Roberts: Okay.

Member Clawson: Okay.

Dr. Roberts: Okay, what's your weigh in for that?

Member Clawson: Yes.

Dr. Roberts: Okay. And I can --

Member Beach: Rashaun, this is Josie. I just had to 

call in, because I got dropped and I can't get back on 

Zoom.

Dr. Roberts: Okay.

Member Clawson: Now you know how I feel, Josie.

Dr. Roberts: So, do you feel like you can -- I don't 

know at what point you got cut off from this. But, we 
72

are taking a vote.

Member Beach: We can't -- yeah, Andy was 

speaking. So, I didn't hear any of the -- any of the 

vote, or the discussion.

Chair Anderson: There really were no questions --

Dr. Roberts: Yeah.

Chair Anderson: Josie. And there had, only thing was 

procedural in reviewing the transcript of our 

committee meeting.

We did not have a formal recommendation to the 

Board to accept NIOSH's determination. So, we 

discussed it, and we all agreed, we did not do a 

formal motion.

So, that's what we just did.

Member Beach: Okay.

Chair Anderson: And the committee has now made a 

recommendation that we accept NIOSH's 

recommendation that a class not be added to the 

SEC.

Member Beach: Okay. Did that get seconded?

Member Kotelchuck: Yes.

Member Beach: Okay. Thank you.

Dr. Roberts: Okay. So -- so, Josie, would you like to 

register a vote for that?

Member Beach: I agree with the recommendation.

Dr. Roberts: Okay. And Brad?

Member Clawson: Yes.

Dr. Roberts: Okay. Bill, are you on?

Member Field: Yes. Yes, I am. Yes.

Dr. Roberts: Okay. Kotelchuck?
73

Member Kotelchuck: Yes.

Dr. Roberts: Lockey?

Member Lockey: Yes.

Dr. Roberts: Richardson?

Member Richardson: Yes.

Dr. Roberts: Roessler?

Member Roessler: Yes.

Dr. Roberts: Schofield?

Member Schofield: Yes.

Dr. Roberts: Valerio?

Member Valerio: Yes.

Dr. Roberts: And Ziemer?

Member Ziemer: Yes.

Dr. Roberts: Okay. And actually, Andy?

Chair Anderson: Yes.

Dr. Roberts: Okay. Great.

Chair Anderson: So, the motion passes. And since we 

need to do a letter, we just happen to have drafted a 

letter to go onto the Secretary, which we can't really 

circulate it here for people to look at. But, I will read 

it.

And I think we could probably leave it open if we have 

some grammatical things that may need to be 

changed. But, I think we got it. So, let me read it into 

the, into the record here.

Dear Mr. Secretary: The Advisory Board on Radiation 

and Worker Health Board has evaluated Special 

Exposure Cohort, SEC, Petition 00253, concerning 

workers at the International Nickel Company, INCO, 

Reduction Pilot Plant, RRP, in Huntington, West 
74

Virginia, under the statutory requirements 

established by the Energy Employees Occupational 

Illness Compensation Program Act of 2000 and 

incorporated into 42 CFR 83.13. Next paragraph.

The National Institute for Occupational Safety and 

Health, NIOSH, has recommended that the individual 

dose reconstructions are feasible for all International 

Nickel Company, INCO, security personnel who 

worked at any location within the Reduction Pilot 

Plant, RPP, during the period from June 7, 1976 

through November 26, 1978.

NIOSH found that it has access to sufficient exposure 

monitoring and other information necessary to 

estimate with sufficient accuracy the radiation dose 

received by members of this group. And therefore, a 

class covering this group should not be added to the 

SEC.

The Board concurs in this determination. Based on 

these considerations, and the discussion at the April 

27-28, 2022 Board meeting held by conference call, 

the Board agrees with the NIOSH recommendation 

that this class not be added to the SEC. Sincerely, 

Henry Anderson, Chair.

Any -- any questions?

Member Ziemer: It sounds good from here Henry.

Chair Anderson: Okay.

Member Ziemer: This is Paul.

Chair Anderson: Paul, you're the guy that I need to 

sign off.

Member Ziemer: Well, no I -- it's -- it follows our 

standard format.

Chair Anderson: Yeah.

Member Ziemer: I think it's appropriate.

Chair Anderson: That's a format we've used before. 
75

So, I thought that it would be okay. Thanks Rashaun, 

for putting it together.

Dr. Roberts: And thanks to Nancy for drafting that 

with us.

Chair Anderson: Okay. So, are there other questions?

(Simultaneous speaking.)

Member Ziemer: I assume you've had legal counsel 

look at that already? Or have you?

Dr. Roberts: Yes. They have reviewed it.

Ms. Gheen: Am I off mute?

Dr. Roberts: Yes.

Ms. Gheen: Oh, great. Sorry. I had to fix my audio. 

This is Angelica Gheen from DCAS. Just real quick, 

Dr. Anderson, what was the date at the bottom of 

that letter? Was that the 28th or the 27th?

Chair Anderson: We don't have a date. It's just May 

XX on the draft letter. But, it would be today, the 

27th.

Ms. Gheen: Okay. So sorry. I thought I heard you say 

the 28th. And I was like, I don't know if that's an 

important distinction that --

(Simultaneous speaking.)

Chair Anderson: All I said was discussion at the Board 

-- I said the discussion at the Board meeting April 27-

28.

Ms. Gheen: Okay.

Chair Anderson: But, the letter would be on the 27th.

So, we could add -- we could just make it the 

discussion on the 27th, I guess, because that's when 

we discussed it.

But, it's the Board meeting on the two days.
76

Ms. Gheen: Great.

Ms. Adams: Andy, this is Nancy Adams. There's also 

a typo in it. It should be RPP at the top instead of 

RRP.

Chair Anderson: Oh, jeez. Thank you.

Ms. Adams: Reduction Pilot Plant.

Chair Anderson: Yeah. Yeah. We got it RPP the 

second time in this.

Ms. Adams: That will -- that will get fixed before it 

goes out.

Chair Anderson: Yeah. Okay. So, that closes out that. 

We're a little early here.

Dr. Roberts: Yes. And Andy, I think we can go ahead 

and take a break.

Chair Anderson: Okay.

Dr. Roberts: I'd like to remind everyone that we will 

go right into a public comment period right at 5:00 

p.m. So, hopefully that will start at 5:00 and we won't 

have any more technical difficulties.

But, I would encourage those folks in the public 

who'd like to comment, to be ready at 5:00 p.m. 

Eastern time, because the period will end once 

everyone who would like to comment, has done so. 

And that maybe before 6:00 p.m. Eastern.

So, please join us at the beginning of the public 

comment session at 5:00, so that you're assured to 

have your opportunity to speak.

And also so that you're aware, comments during the 

public comment session is limited to about five 

minutes. And don't worry, as Andy said earlier, if you 

did not sign up or anything, you can still speak.

Okay. So, if people would just return a couple of 

minutes before 5:00. Okay.
77

(Whereupon, the above-entitled matter went off the 

record at 4:38 p.m. and resumed at 5:01 p.m.)

Public Comment

Dr. Roberts: Okay. All right, great. Well, we have 

mostly everybody, so we can go on and open the 

public comment session.

And again, you know, you have about five minutes if 

you wish to register a comment. But, let me turn it 

over to you, Andy.

Chair Anderson: Go ahead.

Dr. Roberts: I know that we had Dr. Denise DeGarmo 

who wanted to make some comments during this 

period. Is she here?

Dr. DeGarmo: I am here.

Dr. Roberts: Okay. Great. Please make your 

comments.

Dr. DeGarmo: Okay. Thank you so much. Good 

afternoon everyone, and thank you for the 

opportunity to make a statement on behalf of SEC 

00256, the Pinellas Plant Petition.

My name is Denise DeGarmo. I am the author and 

authorized Petition Representative for 00256.

It is my understanding that there has not been much 

headway made on the Petition at this time, because 

you are still waiting for the results of the review being 

conducted by SC&A. But, we did want to touch base 

with you.

While we have been in this state of pause, Petitioners 

have continued to work diligently within imposed 

restrictions, to find information and data relevant for 

your consideration.

As such, you should have received several 

documents from me prior to this meeting. The first is 

a memo addressing the continued failure of the 
78

Department of Energy to acknowledge and respond 

to our FOIA request for documents in their possession 

that were cited in reference in the evaluation report.

The second is information received from the 

Department of Veterans Affairs confirming the receipt 

of several Pinellas employees' entire personnel file, 

including medical records and dosimetry, and the 

refusal of General Electric and the federal 

government to accept those documents when the VA 

attempted to return them.

Third, a reference regarding a new device, which was 

constructed at the Pinellas Plant and not mentioned 

previously that we, the Petitioners, are aware of, 

including the Petitioner site expert, who has no 

knowledge of those designs.

And four, new data regarding the construction of 

neutron generators and the discussion of radiologic 

material at the temporary plant. And a request for 

reconsideration of this addition to the SEC as part of 

the coverage authority.

The Petitioners have in good faith complied with all 

aspects of the SEC process, and yet we continue to 

experience roadblocks and distractions from the 

various government agencies involved in this 

process, the Department of Energy, Department of 

Labor, and DCAS/NIOSH.

The Petitioners still do not have that list too, of critical 

documentation that formed the basis of the 

evaluation report.

And this lack of the access and transparency 

continues to make it impossible for us to fully analyze 

the foundation upon which the assertion that all 

doses at the Pinellas Plant can be reasonably 

reconstructed. We continue to ask, what is the basis 

of this assertion?

Why it is -- why is it that when missing medical 

records were discussed with NIOSH, and this has 

been several years ago, but I think it's still relevant, 
79

this information was totally ignored.

The mistrust and frustration of the claimants 

impacted by the lack of their personal data being 

available for review, has left them wondering if the 

process is even capable of providing an accurate 

picture of their exposure history.

This frustration and mistrust are not only limited to 

the former workers with no records, it seems to be 

characteristic of most former workers at this facility.

I think I need to mention perceived bias. Since we 

had no access to documents or data, we have no idea 

how certain selection processes were made, and how 

different selection biases were avoided.

Additionally, I have not been privy to the history of 

the former Pinellas Petition filed. But, I can say that 

there has been an atmosphere of perceived bias 

towards this facility and its workers based upon years 

of back and forth between workers, petitioners, and 

government agencies.

So, I ask, should the new Petitioners be subjected to 

the problem and perceived biases of the past? We 

think not, and think you would probably agree with 

us.

We still have no idea what data has been used to 

provide the basis of NIOSH's assertions. And when 

we have provided or told NIOSH that we have new 

information, it has been dismissed.

Given that there has been so little progress made 

since the last time we spoke, and I realize that this is 

not directly related to you, but I understand a lot has 

to do with the acquisition of documents.

We the Petitioners are requesting a formal response 

from the Advisory Board and NIOSH to the four newly 

presented issues, as well as to the questions we 

raised at the prior Board meeting in December of 

2021.
80

I also would like to remind you that you made a 

commitment to visit Pinellas in the near future. And 

we really hope that you will honor that commitment.

The Petitioner and former workers really look forward 

to your visit. And as we stated before, the Petitioners 

are more than happy to help make any arrangements 

that you find necessary.

We thank you for your time and consideration, and 

all the devotion you have for this program. Thank 

you.

Chair Anderson: Thank you. Do the Board Members 

have any questions?

I can tell you, I did get the four documents. So, 

everybody has received those as email attachments.

Member Beach: When did that go out? I was just 

going to ask that question, because I don't recall 

getting that.

Was that just recently?

Chair Anderson: No, it just -- it just came.

Member Beach: Oh, today. Okay.

Chair Anderson: Yeah. It came today.

Member Beach: Okay. Thank you.

Dr. DeGarmo: And if I -- and if I -- okay, and if I can 

add one more further thing. If there's anything within 

that documentation that you would be interested in 

discussing, please let me know. And I'd be happy to 

talk about it at a later date.

Chair Anderson: Fine. Thank you. Okay. Any other 

comments that the public has?

Dr. Roberts: I still have --

(Simultaneous speaking.)

Ms. Colley: This is --
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Dr. Roberts: I'm sorry. Go ahead.

Ms. Colley: This is Vina Colley from the Portsmouth 

Gaseous Diffusion Plant. I'm President of the National 

Missing Workers for Justice.

We're really concerned because we were an SEC site. 

We were not supposed to go through those dose 

reconstructions.

Portsmouth, Paducah, and Oak Ridge, all three were 

a spatial cohort site because Congress said we 

couldn't prove, nor you could provide our exposure.

But, for some reason, NIOSH is making all these 

people who have relatives that have passed away, go 

through a dose reconstruction.

One guy, his mother has breast cancer, she had lung 

cancer, and one other cancer that I'm not -- I can't 

remember right now. And they had him to have his 

mom go three times.

The first times she got 39 percent. The second time 

she got 19, and I'm not for sure what they got on the 

third one.

But, this is a criminal act, because Congress didn't 

mean for us to have to go through the dose 

reconstruction. These people are all dying now.

And they should have been compensated when they 

were still alive, for their cancer. Because they had 

one or two of the 21 cancers on that list.

And this is really a criminal act against these family 

members and the widows of these workers that 

passed away.

Hello? Are you still there?

Dr. Roberts: Yes.

Member Beach: Yeah. We're still here.

Ms. Colley: The Ombudsman was aware of this. 
82

NIOSH, Denise -- Denise was aware of what's going 

on with some of these workers. And she agreed that 

the Piketon site is a special cohort site designated by 

Congress.

No need to give any of these workers a dose 

reconstruction. The benefit of the doubt goes to the 

workers.

Chair Anderson: Other comments?

Member Clawson: No, I was -- I was just going to 

say, this sounds like more of a, that NIOSH needs a 

response on this.

Chair Anderson: Yes.

Mr. Calhoun: This is Grady. And we -- we don't 

generally respond during public comment.

Dr. Roberts: No.

Mr. Calhoun: That's not how that works.

Dr. Roberts: No. It does not. It's just a period for 

public comment.

Ms. Colley: Well, can I get them to send it to me in 

writing, their comments? Or email me their 

comments?

Because this is a criminal act. And we're not going to 

sit back and just take this now. We're going to take 

this further.

Mr. Calhoun: We respond to all public comments. We 

record those and we'll -- we provide those to the 

Advisory Board prior to the next meeting.

Chair Anderson: We go through those when we have 

the Board work sessions too. From the previous, and 

NIOSH's responses.

So, your comments will get responded to, but not 

immediately.

Dr. Roberts: Right. And just to be clear, it would be 
83

the next full Board meeting, not tomorrow when we 

do the Board work session.

Chair Anderson: Right. Okay. Are there any other 

comments or discussion items that Board Members 

have before we say goodnight and reconvene 

tomorrow after 1:00 p.m.?

Rashaun, do you have anything else?

Dr. Roberts: No. I'm not hearing any other public 

comments. So, I think -- I think we're okay.

Ms. Hand: This is Donna Hand. Can you hear me?

Dr. Roberts: Yes. There you are.

Ms. Hand: Okay. Can you hear me? Okay. I had sent 

an email to the Board. Hello?

Dr. Roberts: When did you send an email?

Ms. Hand: Yesterday.

Dr. Roberts: Yesterday?

Ms. Hand: This -- okay, to the Board.

Dr. Roberts: I didn't --

(Simultaneous speaking.)

Ms. Hand: Regarding -- regarding the application of 

the ICRP clarification of the tritium, which was done 

in 2004.

And also again, the -- or I had requested that the 

Advisory Board discuss the metal tritides.

I also, in that email, went back through the Technical 

Basis Document, and informed that the highest 

individual external dose was 1,760 millirems, and 

with 512 millirems being the average. But yet, NIOSH 

says that for the Pinellas Plant, it's only 100.

Again, the methods and the guidelines used are 

regulations at 42 CFR 81, 42 CFR 82. If you are 
84

changing the guidelines and the methods, you have 

to do notice and comment. That was not done.

So, NIOSH can only address the application of the 

methods and the guidelines. They cannot change the 

methods, the methodology, or the guidelines, unless 

they have notice and comment. And that was not 

done.

Also, the actual facts have been omitted from this 

Technical Basis Document for Pinellas Plant for 

several years now. And the two previous SECs that 

did not qualify, used the same NIOSH -- these are 

the kind of reports that NIOSH said were wrong.

So, there seems to be a disconnect as far as being 

equal justice and consistency in the decisions. Again, 

I would address that the tritium dose, according to 

NIOSH, is only for the workers in certain areas.

But, the tritium dose, and specifically metal tritide 

doses, was anywhere where that neutron tube went, 

and where the neutron generator went. So, this dose 

was never addressed to the actual workers.

And the tritium would be in contaminated oil and in 

the seals. So, the maintenance workers would be 

exposed there. Again, that was not addressed.

The UA -- and then in the RTGs, the guards' desk has 

a sampling of radiation on the guards' desk.

But yet, NIOSH has said that for the people that's 

worked with the RTGs gets zero dose. We had 

radioactive generating devices. Again, zero doses to 

those workers.

So, there seems to be inconsistency with the Pinellas 

Plant and the actual material facts, as opposed to the 

professional judgments that have implied and 

omitted facts.

In fact, several years there has been -- there's data 

that's completely missing. So, you can do the dose 

reconstruction, but it's a default value.
85 

It's not -- it's not based on the data. It's based on a 

default. And I'd just like to address that the legal 

standards, you know, it needs to be addressed as 

well that it should be uniform and consistent.

And if the metal tritides -- and to stop the year from 

1990 when [identifying information redacted]

in the March meeting, when the Advisory Board was 

in Tampa, everybody stated that they do not have 

any data for the D&D period at the Pinellas Plant.

But yet you stopped the SEC at 1990. It should go to 

1997, because that's when the last shipment was 

sent to Sandia.

Thank you very much.

Chair Anderson: Thank you.

Dr. Roberts: May I ask a --

(Simultaneous speaking.)

Chair Anderson: Any comments?

Dr. Roberts: May I ask a clarifying question? To 

whom did you send the email? I've checked my 

email, and I don't have anything from you.

And I just want to make sure if you sent something 

for the Board that I'm -- I receive it.

Dr. DeGarmo: This is Denise DeGarmo. The copy of 

the email that I received from Donna was addressed 

to DCAS.

Dr. Roberts: I see. Thank you.

Dr. DeGarmo: Unless she sent a different one. That's 

the only one I'm aware of.

Chair Anderson: Other comments? Last chance. So, 

Rashaun, should we adjourn?

Dr. Roberts: Yes. It seems that the -- I don't hear 

any other folks --
86

Chair Anderson: Yeah.

Dr. Roberts: Wanting to comment.

Chair Anderson: It's hard with a lot of people on the 

phone, because they can't raise hands.

Dr. Roberts: Right. And sometimes people have audio 

difficulties.

Chair Anderson: Yeah.

Dr. Roberts: Thankfully everyone who wanted to 

speak did have an opportunity to do that.

Chair Anderson: Okay. All right. So, we will adjourn 

until tomorrow at 1:00. And it's the same link?

Member Beach: Okay.

Chair Anderson: Is that correct, Rashaun?

Dr. Roberts: Yes. I believe it is.

Chair Anderson: It's the same Zoom link, I think.

Dr. Roberts: Okay.

Chair Anderson: Yeah, it came to my calendar as two 

full days. So, all night and 1:00 a.m., 2:00 a.m., so. 

Okay. See you tomorrow everybody.

Adjourn

(Whereupon, the above-entitled matter went off the 

record at 5:19 p.m.)