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

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Subcommittee for Procedures Review

Thursday, February 18, 2021 

The subcommittee convened at 10:30 a.m., Eastern 

Daylight Time, via Video Teleconference, Rashaun 

Roberts, presiding. 
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2 

Present: 

Josie Beach, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Dave Allen, DCAS

Bob Anigstein, SC&A

Bob Barton, SC&A

Kathy Behling, SC&A

Elizabeth Brackett, ORAU

Ron Buchanan, SC&A

Grady Calhoun, DCAS

Doug Farver, SC&A

Rose Gogliotti, SC&A

Megan Lobaugh, NIOSH

Lori Marion-Moss, DCAS

Jenny Naylor, HHS

Matthew Smith, ORAU

Tim Taulbee, DCAS
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3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Subcommittee for 

Procedures Review Thursday, February 18, 2021 1

Roll Call/Welcome 5

ORAUT-OTIB-0001 (Maximum Internal Dose 

Estimates for Savannah River Site (SRS) 

Claims) 10

ORAUT-OTIB-0049 (Estimating Doses for 

Plutonium Strongly Retained in the Lung) 16

ORAUT-OTIB-0066 (Calculation of Dose from 

Intakes of Special Tritium Compounds) 22

ORAUT-OTIB-0024 (Estimation of Neutron 

Dose Rates from Alpha-Neutron Reactions in 

Uranium and Thorium Compounds) 26

DCAS-PER-047 (Grand Junction Operations 

Office) 29

ORAUT-OTIB-0006 (Dose Reconstruction for 

Occupational Medical X-ray Procedures) 35

Continuation of DCAS-PER-057 (General Steel 

Industries) 49

DCAS-RPT-0005 (Alternative Dissolution 

Models for Insoluble Pu-238) 92

ORAUT-OTIB-0029 (Internal Dosimetry 

Coworker Data for Y-12) 96

Discussion regarding potential review of 

newly-issued guidance document and 

Battelle-TIB-5000 113
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4 

Preparation for April 2021 Full ABRWH 

Meeting 124

Next Subcommittee Meeting/Plans 128
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5 

Proceedings

(10:30 a.m.) 

Roll Call/Welcome

Dr. Roberts: So we're going to go ahead and get 

started if that's okay with everybody. But good 

morning, everybody. Welcome to the Advisory 

Board on Radiation and Worker Health.

This, of course, is a meeting of the Subcommittee 

on Procedures Review. I'm Rashaun Roberts and I'm 

DFO for the Advisory Board. Before I do roll call, I 

am hearing a little bit of interference so if everyone 

could make sure that their phones are muted or 

their microphones are muted, that would be great.

So before I do roll call, let me start with addressing 

conflict of interest for this meeting. This 

Subcommittee, I've learned, deals with a lot of 

different documents.

I don't think that the documents we're dealing with 

today relate to a Subcommittee Member's conflict of 

interest, but just in case, let's just review the 

conflicts.

So for Josie, who is Chair of this Committee, any 

documents related to Hanford would be a conflict, 

correct, Josie?

Member Beach: Yes, that's correct.

Dr. Roberts: Okay and then for Loretta, any 

documents related to the New Mexico site and 

Pantex?

Member Beach: That is correct.

Dr. Roberts: Okay. Great. And for Paul, ORNL would 

be a conflict and perhaps LANL after the year 2000.
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6

Member Ziemer: Correct. And there is one Oak 

Ridge document. It's identified as X-10 in the list, so 

that's Oak Ridge.

Dr. Roberts: Okay. Great. Thank you for clarifying 

that. So if any conflicts come up, of course, and if 

you do have a conflict, like you, Paul, then you 

would recuse yourself because of the conflict. So 

you would --

Member Ziemer: Right.

Dr. Roberts: -- recuse yourself from the discussion. 

Okay.

Member Beach: Rashaun --

Dr. Roberts: So it sounds like -- yes?

Member Beach: -- Rashaun, I have a quick question 

on conflicts. When I was reviewing the Peek Street 

information, that does talk about some Hanford 

numbers. Does that count as a conflict or not? Do 

you know?

Dr. Roberts: I would think that it does. You know, 

maybe just to be conservative about this, if you 

would recuse yourself --

Member Beach: Yes.

Dr. Roberts: -- from those portions --

Member Beach: Yes --

Dr. Roberts: -- of the discussion.

Member Beach: -- I'm thinking maybe Paul can 

handle that if you don't mind, Paul, that discussion 

when we get to Peek Street and if that's not the 

case, it's kind of a grey area I think, but just 

something to be aware about.
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7

Member Ziemer: I'll be glad to do that. I don't recall 

how we handled that before because we're not 

specifically making a determination on what should 

be done at Hanford. They are taking --

Member Beach: Right.

Member Ziemer: -- values that have already been 

established for Hanford and applying them to Peek 

Street. So I don't know if counsel is on the line, but 

she might be able to help us. Is Jen on the line?

Ms. Naylor: I am on the line, hi. Sorry. I am on the 

line and I tried to pipe in here, but Josie, I'm happy 

to have an offline conversation with you, but Dr. 

Ziemer is right.

There is actually not a conflict for you. So just to 

recap, your conflict of interest actually arise out of 

both the regulation governing the government 

ethical conduct as well as the appearance of biased 

policy under the -- for the Dose Reconstruction 

program.

And both of which really is addressing any sort of 

appearance issues that might influence your interest 

which is sort of whether you would have a 

susceptible claim under the Part B program.

And so your participation in the Peek Street really is 

not affecting how any of your claim or your interest 

under Hanford will be adjudicated and so there 

really isn't a conflict of interest issue here so, but 

I'm happy to have an offline conversation with you 

in more detail if you'd like to. Because as of now --

Member Beach: No, Jen, that's, I just wanted to 

make sure and I'm fine with that. Thank you. So 

we're --

Ms. Naylor: Okay.
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8

Member Beach: -- so that's good. Thanks a lot.

Ms. Naylor: Okay.

Member Valerio: So just to clarify, because -- this is 

Loretta, I'm sorry -- so just to clarify, because they 

do reference LANL in there, the same would go for 

me. It's not really a conflict of interest. Is that 

correct?

Ms. Naylor: So the LANL data that they're using has 

already been predetermined by the LANL Working 

Group and so it really is not affecting your financial 

interest that is derived from your employer, right, in 

the State of New Mexico.

So no, it really isn't a conflict for your either. But 

you do need to refrain from commenting on the 

LANL data only because the reason for Josie's 

conflict is different than, Loretta, your -- the reason 

for your conflict. So you shouldn't take what I said 

about Josie as applicable to you. Does that make 

sense?

Member Valerio: Yes.

Ms. Naylor: So you do not have a conflict to sort of 

deliberate over the Peek Street document, but the 

reason why you do not have a conflict is for a 

different reason.

Member Valerio: Right, right. Okay. That makes 

sense. Thank you.

Dr. Roberts: Yes, and thanks, Jenny, for clarifying 

those issues. Are there any other questions about 

conflict of interest for the Subcommittee Members?

Okay, so it seems that we have all three Members 

of the Subcommittee so we do have a quorum. So 

we can move forward with the meeting. Josie's the 
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9

Chair, as I mentioned before.

So let me finish the roll call since we've established 

the attendance of the Subcommittee Members and 

conflicts of interest. So if folks would, of course, 

register your attendance and be sure to 

acknowledge or make any conflicts you might have 

known, that would be great.

So, let's start with NIOSH and DCAS.

(Roll call.)

Dr. Roberts: Okay, I just want to go over a couple 

of additional items. In order to keep things running 

smoothly and so that everyone speaking can be 

heard clearly, please make sure that your phone is 

on mute.

It's important that you periodically check that. If 

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

to unmute. If you're on Skype, the mute button's at 

the bottom of your screen although I think people 

are speaking through the phone line.

The agenda and the presentations and background 

documents that are relevant to today's meeting can 

be -- are on the NIOSH DCAS website. And of 

course, all of these materials were made available 

to Board Members and to other staff prior to this 

meeting.

So with that, let's go ahead and get started and, 

Josie, I'm going to give the floor to you.

Member Beach: Okay, thank you, Rashaun. And it's 

been two years since we last, the Subcommittee 

last met. It was almost to the day, so we have a lot 

of time has passed since our last meeting.

I want to thank Kathy for putting together that 
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10

memo. That was very helpful to me and hopefully it 

was to other Subcommittee Members, having a lot 

of some of our background in one memo, White 

Paper.

So our first item is the ORAUT-OTIB-0001. Is SC&A, 

are you going to start on that?

ORAUT-OTIB-0001 (Maximum Internal Dose 

Estimates for Savannah River Site (SRS) Claims)

Ms. Behling: Yes, this is Kathy Behling.

Member Beach: Okay.

Ms. Behling: And Josie, if you would like, I can 

address OTIB-0001.

Member Beach: Okay, that would be great. Thank 

you.

Ms. Behling: All right. If you don't mind, I will just 

briefly summarize the 13 findings that are in 

abeyance for this OTIB. And first of all this OTIB is 

maximum internal dose estimates for the Savannah 

River Site.

And we reviewed this document, it's a very old 

document that has since been cancelled and I'll 

summarize very quickly the findings and if the 

Board Members or if NIOSH want to interject at any 

time or ask any questions, or comments, please do.

But in general, our findings had to do primarily with 

focusing on like lack of clarity in the document, 

insufficient data to reproduce some of the intakes.

We felt that the doses due to the organically bound 

tritium were ignored. There were some nonclaimant-favorable issues among these 13 findings 

and NIOSH has responded to all of the findings with 
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11

the same comment.

And that comment is that OTIB-1 has been 

cancelled and site-specific hypothetical intakes are 

no longer assigned and that OTIB-18 and OTIB-18 

is the internal dose overestimate for facilities with 

air sampling program OTIB or co-exposure values 

are used in place of this OTIB.

From my perspective, this seems like a reasonable 

approach. That was their response to all of the 

findings. The only question that came to my mind 

that perhaps someone from NIOSH could answer, I 

know OTIB-18 is a very, very claimant-favorable 

OTIB and typically it has been used as coupled with 

OTIB-33.

And OTIB-33 is application of the internal dose 

based on claimant-favorable assumptions for 

processing best estimate cases. And I know we've 

had this discussion several times in the past, but I 

believe that OTIB-33, even though the title suggests 

that it's used for best estimates, I believe NIOSH is 

not doing that.

That they still, even if they apply the OTIB-33 

correction factors or percentage of doses that are 

generated in OTIB-18, it's still used as an 

overestimate. Is that still the case?

Is there someone from NIOSH that could answer 

that? We, SC&A, when we do our dose 

reconstruction reviews, are typically looking at best 

estimate cases and don't encounter this OTIB quite 

as often as we used to, so it's just a question that 

came to my mind.

Ms. Marion-Moss: This is Lori --

Ms. Brackett: This is Elizabeth Brackett.
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12

Ms. Marion-Moss: Sorry.

Ms. Brackett: Go ahead.

Ms. Marion-Moss: This is Lori. We have some ORAU 

people on the line. Scott, are you there?

Ms. Brackett: This is Elizabeth Brackett. I'm the 

internal dosimetrist for the team. I was going to 

speak up.

Ms. Marion-Moss: Go ahead, Liz. Sorry about that.

Ms. Brackett: Yes, that OTIB, in spite of its name, it 

is not used for best estimates. It is used for 

overestimates. At the time it was written, that was 

the intent, but that's not how it ended up getting 

applied so it is an overestimate.

Ms. Behling: Okay, because the answer to these 

findings were associated with an OTIB that was a 

maximum internal dose estimate so that was an 

overestimate and so I assume that a lot of this will 

be handled under the Savannah River Site specific 

data.

So I know that in NIOSH's response, they're 

recommending closing these findings and I believe 

from SC&A's perspective, we agree with that based 

on their response.

So, Josie, I guess it's up to the Subcommittee to 

decide if you are in agreement.

Member Beach: Yes, thanks, Kathy. So in looking at 

OTIB-18, there -- and I know it's not on our agenda 

today, but since this is being transferred or 18 is 

being used instead of OTIB-1.

There were some issues with 18 and I don't know if 

this is the time to bring those up and go through 
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13

those, because that's also a very old document, but 

there's some of the findings that aren't very clear.

So, I guess it's a two-part question so first I'll ask 

the Subcommittee, do you have any problems with 

closing out the 13 findings with OTIB-1?

Member Ziemer: Josie, this is Paul. I'm okay with 

that. I think though, if we do that, we need to make 

it very clear that normally when we close a finding, 

we're indicating that the issue has been resolved. In 

this case --

Member Beach: Right.

Member Ziemer: -- we're indicating, we're not 

indicating the issue's been resolved, we're indicating 

that those findings don't apply simply because the 

document is no longer used. Am I hearing that 

whistle or what?

Member Beach: Yes, I heard it too, but it's gone, so.

Member Ziemer: Okay. Anyway, if we close this, it 

seems to me we need some kind of a notation in the 

main database that indicates that the reason that 

it's being closed is the fact that the document is no 

longer in use.

Member Beach: Okay.

Member Ziemer: The only thing I'll add is that we 

may want to look at those unclosed findings in 

OTIB-18. But that's actually not on our agenda and 

I don't think we've -- we probably should carry that 

forward or something.

Member Beach: Yes --

Member Ziemer: I mean, I don't know if NIOSH or 

SC&A are prepared to discuss those today in any 
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14

event, but we should make a note at least that 

there are still some issues on those -- well, we don't 

call it best estimate then, it's the claimant-favorable 

approach. Right?

Well they're all supposed to be claimant-favorable, 

but the bounding approach.

Member Beach: Yes, and that document was looked 

at I believe in my notes, 2008 and there's some 

recommendations of closing, but there's -- and the 

findings actually in '18 say close.

But the Subcommittee never actually closed them, 

unless it just wasn't written in. So yes, there's some 

work to be done there. Loretta, comments on OTIB1?

Member Valerio: I'll agree with Paul that we can 

close them, but you know, and again, we should 

have some kind of a notation that, you know, they 

will continue to be reviewed under OTIB-18.

Member Beach: Okay, thank you.

Member Ziemer: Well, I'm not sure --

Member Beach: Kathy, would you like --

Member Ziemer: -- these findings won't specifically 

be reviewed, will they, under the other -- under 

OTIB-18?

Member Beach: No.

Member Ziemer: We're closing them for --

Ms. Behling: Okay, I'm --

Member Ziemer: -- a very different reason than we 

normally close, is what I'm saying.
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15

Member Valerio: Okay. All right, but I'm good with 

closing them under OTIB-1.

Member Beach: Okay, thanks Loretta. So Kathy, or 

Lori, who would make the notations in 1?

Ms. Behling: I can do that. This is Kathy. I can 

make those, the notations in the BRS.

Member Beach: Okay, thank you.

Ms. Behling: Sure.

Member Beach: And I agree with closing those as 

well, if the document's no longer used there's no 

point in carrying them forward. However, we do 

need to make a note that 18, OTIB-18 would need 

to be looked at and then review those.

I think there's just three findings that are not clear. 

Did you get a chance to look at that at all, Kathy, in 

your preparing for this meeting?

Ms. Behling: No, I didn't go into the findings 

associated with OTIB-18, but I will certainly do that 

after the meeting. As I said, OTIB-18 is a very, very 

claimant-favorable OTIB.

And so if that was used, it would definitely be only 

used to -- for non-compensational cases. So, but we 

will, I will look at that.

Member Beach: And I don't think there's much 

work. We transferred one item to 9 and then there's 

another, the finding seven says to transfer it, but 

it's not clear where so I think it just needs to be 

cleaned up from our earlier --

Ms. Behling: Okay, yes. In fact, I am showing one in 

progress and one in abeyance and then two items, 

two findings that were transferred, but I will look 
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16

further into --

Member Beach: Okay.

Ms. Behling: -- that after the meeting.

Member Beach: Okay. So I'll write that down as a 

carry-over item and if -- as long as everybody's in 

agreement with that? Okay, so if there's no other 

discussion, those items are all closed.

Kathy's going to make the notation. Any more 

discussion?

Member Ziemer: That sounds good to me, thank 

you.

ORAUT-OTIB-0049 (Estimating Doses for Plutonium 

Strongly Retained in the Lung)

Member Beach: Okay, sounds good to me too. I 

think we can move onto OTIB-49.

Ms. Behling: Okay, and this is Kathy again and I'm 

ready to address these findings. OTIB-49 is 

estimating doses for plutonium strongly retained in 

the lung.

It's this Super S plutonium and we had two findings. 

Again, this was reviewed back in 2008 and our first 

finding was again there's this ambiguity and lack of

some detail in this OTIB and we felt that there may 

be, you know, additional judgment needed and 

Finding 2, again there was a lack of clarification on 

how to apply correction factors.

Well NIOSH has responded to those findings, 

indicating that the adjustment factor system has 

been replaced by a new model. They are now using 

ICRP 130 which is the respiratory tract model and 

publication 67 for the systemic organs.
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17

And apparently they are using a software, IDOT, 

which I was not familiar with until I read the 

response. And so the rewrite of OTIB-49 Rev. 2 of 

OTIB-49, that was published in September of 2020.

SC&A has not reviewed that and so I'm suggesting 

to close this out as -- the response from SC&A is 

that we be tasked to review OTIB-49 Rev. 2 based 

on this being a completely, it's a total rewrite, 

there's new models that are being used, and there's 

new software being used that I don't think the 

Advisory Board has looked at yet.

If you have, I'm not familiar with that. So that's 

SC&A's suggestion for continuing on follow-up 

actions for OTIB-49.

Member Beach: Okay and just to be clear, you're 

not suggesting closing out the two findings that 

were currently in progress?

Ms. Behling: No.

Member Beach: You're talking about -- okay, good. 

Okay.

Ms. Behling: Correct, yes. And apparently like I said 

--

Member Beach: Okay.

Ms. Behling: -- the software, I guess there's a 

user's guide and we may need some assistance 

from, if we are tasked to do this, we may need 

some assistance from NIOSH to just point us in the 

right direction with regard to the software looking at 

these models.

Member Beach: Okay, I'm in agreement with that. 

It's also a part of your list in a table further -- Table 

Two recommending some --
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18

Ms. Behling: Yes.

Member Beach: -- reviews, so --

Ms. Behling: Yes.

Member Beach: -- other Subcommittee Members?

Mr. Allen: Josie, this Dave Allen. Could I speak up 

real quick?

Member Beach: Oh, please. Please do, I'm sorry.

Mr. Allen: As far as those findings, they're findings 

for Revision 0 of OTIB-49 and, there's two of them 

and one is that the document was ambiguous and 

the second was that it lacked clarification on how to 

apply correction factors.

I think Kathy can tell you right now that -- well I 

think she already mentioned the correction factors 

are gone and as far as the document being 

ambiguous, as she said, it was a complete rewrite 

so it really seems like we can close those two out.

They're irrelevant at this point and if any findings 

come from a review of Rev. 2, you know, they will 

obviously be put into the BRS and be a whole 

different ball game then.

But it doesn't seem like there's any reason we can't 

close out the two findings in OTIB-49 right now.

Ms. Behling: I agree with that. This is Kathy. I do 

agree with that. He's correct.

Member Beach: Okay. That makes sense.

Ms. Behling: These findings will still be listed in the 

BRS. If we are tasked to review Rev. 2, we'll just 

add on any findings that we may encounter during 

that review. But this will be documented and I will 
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19

explain why we felt that way.

Member Ziemer: (Audio interference.)

Member Beach: Paul, we're only getting a little bit. 

Hello?

Member Ziemer: -- I recently (audio interference).

Member Beach: Paul, we only got like two words out 

of what you were saying, so I'm not sure what the 

problem is. And we're not hearing anything. Are you 

speaking still?

Member Ziemer: No, no.

Member Beach: Okay, Loretta, any comments?

Member Valerio: So we are closing Findings 1 and 2 

for OTIB-49. Is that what I'm hearing?

Member Beach: That is exactly what you're hearing, 

based on what Dave said and Kathy agreed.

Member Valerio: Right, right. And I'm in agreement 

with that. I'm good.

Member Beach: Okay. And Paul, are you in 

agreement with that as well? Okay. Can anybody 

else hear Paul? Are you there?

Dr. Roberts: No, I can't hear him, Josie. This is 

Rashaun. I sent a note in Skype to let him know 

that he is breaking up and asked if it would help if 

he would call in again.

Member Beach: Okay. Yes, I hate to, I felt like he 

was -- had a comment.

Dr. Roberts: Yes, me too. It looks like he's still on 

Skype, but the audio --
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20

Member Beach: Yes.

Dr. Roberts: -- isn't working. Yes.

Member Beach: Is he on a phone or was he on his 

computer, do you know?

Dr. Roberts: I think most people call in on the 

conference line. Nancy or Zaida, can anyone, you 

know, try to call him and help with this?

Ms. Adams: Yes, I'll try to give him a call and see. 

Although, if he's on the phone, I'll let --

Ms. Roberts: I know.

Ms. Adams: -- I'll see about the chat box.

Member Beach: He probably has a cell phone that 

he could, you could text him on. Okay, we can --

well, shoot. I guess we can move forward.

Dr. Roberts: Perhaps, assuming that he can get 

back on, but without him on --

Member Beach: Yes, we'd better wait.

Dr. Roberts: -- I mean, because.

Member Ziemer: I'm back.

Member Beach: Oh, okay.

Member Ziemer: Can you hear me now?

Member Beach: Yes.

Member Ziemer: I don't know what happened.

Member Beach: Yeah, we felt like you were making 

a comment on closing out OTIB-49, but then we 

didn't get to hear what you were commenting on.
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21

Member Ziemer: Well okay, the comment was that 

I, even though those are irrelevant now, wouldn't 

we automatically look at them if they're reviewing 

OTIB-49 Rev. 2 anyway and rule them out then, or 

-- I'm okay if we just declare them irrelevant now 

as long as we make a proper notation again and 

indicate that any issues would be covered in the 

review of the other.

Member Beach: Okay, then that makes sense. 

Kathy will take that on I think -- I believe she said, 

to make the proper notifications on those two 

findings.

Ms. Behling: Yes, I will do that.

Member Beach: Okay.

Member Ziemer: But I agree with the tasking. We 

have to formally task SC&A on this?

Member Beach: Yes, and I was going to wait until 

we get to Table Two. There's several --

Member Ziemer: Oh, sure. Yes.

Member Beach: -- tasking items. I mean we can 

task them individually now or go through it. Either 

way, it's fine.

Member Ziemer: Your call.

Member Beach: Okay, I say we should go ahead 

and wait because there's actually several today in 

this document that I feel like we'll be tasking as we 

go, so.

If we're ready, so I'm showing that OTIB-49, we're 

going to close those two findings, Kathy will make 

the notations in the BRS and then we'll look at the 

tasking when we get through this and we can move 
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22

on to OTIB-66.

Ms. Behling: Okay, this is Kathy again.

Member Ziemer: Sounds good.

ORAUT-OTIB-0066 (Calculation of Dose from 

Intakes of Special Tritium Compounds)

Ms. Behling: And I'm willing to start the discussion 

on OTIB-66. This is Cancellation of Dose from 

Intakes of Special Tritium Compounds.

And, again, SC&A reviewed this back in 2009, and 

there are two outstanding findings. Finding 1 

discusses the fact that OTIB-66 refers to OTIB-11 

for assessing dose to intakes of organically bound 

tritium and we felt that that was not claimantfavorable.

NIOSH's response to that is that they have issued a 

Rev. 1 of OTIB 66, and in Rev. 1 they have removed 

the reference to the OTIB-11. It now specifies that 

they must run IMBA.

And Finding No. 3, we, our findings stated that 

OTIB-66 does not ensure that result and doses are 

based on adequate monitoring data. And NIOSH had 

agreed with this finding and they indicated now that 

in a purpose of their Rev. 1 document, they have a

discussion on the limitations of urine sampling for 

stable metal tritides.

So now when I went in to find OTIB-66 Rev. 1, I 

couldn't find it. It is not posted on the NIOSH 

website yet. But I did ultimately find it on the 

ORAUT on the Z-drive or the O-drive or whatever 

drive everybody has there, but I only saw it listed 

somewhere around the 26th of January.

So we -- I initially didn't have the opportunity to 
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23

look at it. When I wrote this table for you, I hadn't 

looked at it at that point in time. I did take notice 

that it constituted a total rewrite. 

Since then I have looked over the document. And it 

seems to me, I was initially going to suggest that 

we do a full review of the OTIB, but when I 

compared Rev. 0 to Rev. 1, side by side, it seems 

like there's a lot of similarities.

And I am now going to suggest that probably SC&A 

only needs to do pretty much of a focused review to 

ensure that these two findings that we cited in Rev. 

0 were addressed in this Rev. 1.

Because, like I said, side by side comparison looks 

like even though it indicates it was a total rewrite, 

there's quite a bit of similarities, and I think a fairly 

quick focused review would suffice to resolve these 

findings.

Member Beach: Okay, that makes sense. Any 

comments on that, Subcommittee?

Member Ziemer: Yeah, I agree. That makes sense. 

A quick question, Kathy. On the column, follow up 

actions taken, you refer to Finding 2. I think that 

you intended to refer to Finding 3, I assume.

Ms. Behling: I did. Thank you for that correction.

Member Beach: Yeah.

Ms. Behling: I apologize.

Member Beach: And then I have a question on 

OTIB-11. For -- this is for NIOSH. Is that --are you 

still using that? I understand it's not being used in 

this document, but is it still an OTIB that's being 

used?
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24

Ms. Brackett: Yes. This is Liz Brackett. Yes, that's 

used for tritiated water assessment, HTO.

Member Beach: Okay. Thank you. And so back on 

that as a carry over, when I went in and looked at 

OTIB-11, it shows that the BRS, it shows that 

there's items that are closed, but the verbiage 

doesn't say the Subcommittee closed them.

So is that -- how did you guys used to do that back 

in the early days? Did you just close them or did 

you write in the verbiage that the Subcommittee 

discussed and closed?

Ms. Behling: Well, this is Kathy. I know Steve 

Ostrow used to update the BRS quite a bit, and I 

have listed here that the Subcommittee closed 

those.

We -- it wouldn't have been closed without a 

discussion in the Subcommittee, but I can go back 

and research that further for you and look at some 

transcripts and ensure that that was done.

Member Beach: Yeah, that's just -- and I don't know 

how much work you want to put into that. Like the 

first one says not explicitly addressed at this 

meeting, but given discussion held at previous

meetings, it is recommended that this issue be 

closed.

So that, to me, isn't really a clear indication that the 

Subcommittee agreed to close.

Ms. Behling: Okay, I'll look into that --

(Simultaneous speaking.)

Member Beach: So, anyway -- and the only reason I 

looked at it was because it was associated with this 

66, so that might be something to look at and make 
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25

sure that it's clear that those findings were actually 

addressed, so.

Ms. Behling: Okay, I --

Member Beach: Paul and Loretta, what do you --

how do you feel about those?

Member Ziemer: Yeah, well, I would spot check on -

- in this case if it's not clear. I don't think they 

would have been closed without Subcommittee 

action, but sometimes we get on these calls and we 

think everybody's agreed to something.

And, you know, we don't always formally vote and 

depending on how the -- you'll have to double check 

those transcripts, I guess.

Member Beach: Okay. All right, Kathy. So if you 

don't mind noting that as one to go back and look at 

also.

Ms. Behling: Will do. Not a problem.

Member Beach: And I think -- is this -- I think we 

can go ahead and task this OTIB-66 for a focused 

review. Is everybody in agreement with that? 

Loretta? Paul?

Member Valerio: I'm in agreement.

Member Ziemer: Yes. I'm in.

Member Beach: Okay, so, Kathy, you are hereby 

tasked to do a focused review on OTIB-66.

Ms. Behling: Okay, very good.

Member Ziemer: And, Kathy, when you guys get 

into it, I mean, laying them side by side, you 

thought they looked pretty parallel and similar.
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26

If you get into it and find that that's not the case, it 

seems to be that -- just let -- perhaps let Josie 

know, and I'm okay with, you know, changing the 

task if it's necessary.

Ms. Behling: Okay, very good.

Member Ziemer: Yeah, you know, if you just say 

you know what, these aren't as similar as I thought 

they would be so.

Ms. Behling: Okay. Yes, good suggestion. Thank 

you.

Member Ziemer: Yeah.

ORAUT-OTIB-0024 (Estimation of Neutron Dose 

Rates from Alpha-Neutron Reactions in Uranium and 

Thorium Compounds)

Member Beach: Yeah, I agree with that too, Paul. 

Thank you. Anything else on OTIB-66? Okay, 

hearing none, we can move on to OTIB-24 and is --

Ms. Behling: Yes.

Member Beach: -- Ron on that one, Kathy, or are 

you going to take us through that --

Ms. Behling: Actually, yeah, this is --

Member Beach: -- as well.

Ms. Behling: -- Bob Anigstein. And, Bob, did you 

join us?

I know that we were going to contact him prior to 

the discussion of OTIB-24.

Mr. Barton: Yeah, hi, Kathy, this is Bob Barton. I 

gave him a call about 5 or 6 minutes ago. Let me 

try him again.
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27

Ms. Behling: Okay.

Member Beach: Yeah, we're moving through these 

quickly.

Ms. Behling: That's good because we have a lot of 

items on this agenda.

Member Beach: Yeah.

Ms. Behling: I think Bob has quite a few findings 

here, and I know he has spent some time reviewing 

these findings, and I believe he wants to discuss 

each -- or at least summarize each one of these 

findings. Hopefully we will --

Member Beach: Sure.

Ms. Behling: -- get him on the line.

Member Valerio: We could always move on and 

come back to it.

Member Beach: Well and then I was thinking since 

we've tasked OTIB-6, how does the Subcommittee 

feel about going ahead and tasking OTIB-049? Is 

there some discussion on that?

Member Ziemer: You mean just tasking it now? You 

were going to wait initially, right?

Member Beach: Yeah, just tasking it now since 

we've had the discussion and we're waiting for Ron.

Member Ziemer: Well, I'm fine in doing the tasking 

business whenever you're comfortable.

Member Beach: Okay.

Member Ziemer: As I say from -- it's your call if you 

want to go ahead with it. I'm -- I think we sort of 

agreed we should task it, but a key question, doing 
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28

them all -- doing all of the --

Member Beach: Yeah.

Member Ziemer: -- tasking at one time or as we go.

Member Beach: I'm okay with --

Member Ziemer: Maybe as we go works because we 

know what we're tasking more specifically at that --

before us older ones forget it all.

Member Beach: Okay, so as we're waiting for Ron to 

come on, we'll go ahead and go back, Kathy, back 

on to the tasking of OTIB-49 Rev. 2 for a complete 

review. Correct?

Ms. Behling: Correct. Yes, because --

Member Beach: Okay.

Ms. Behling: -- there have been a lot of changes 

there.

Member Beach: Okay, so you are so tasked on that 

item now.

Ms. Behling: Okay.

Member Beach: And then -- I don't really want to 

jump around too much. I think OTIB-6 is going to 

take a while. PER-047, Grand Junction, that one 

may not take too long if we wanted to start on that 

while we're waiting for Ron.

Ms. Behling: Yeah, we're actually --

Member Beach: What do you think?

Ms. Behling: -- waiting for -- we're waiting for Bob 

Anigstein.

Member Beach: Bob Anigstein. Sorry, I had Ron in 
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29

my brain for some reason.

Ms. Behling: Yes, Ron's OTIB-6, so he's next.

Member Beach: OTIB-6, yes.

DCAS-PER-047 (Grand Junction Operations Office)

Ms. Behling: If you'd like, I can discuss PER-47.

Member Beach: Okay, is that -- that would be fine. 

Let's do that.

Ms. Behling: Okay. All right, PER-47 was for Grand 

Junction operation office. And there was one 

outstanding finding, Finding 4. And in this particular 

case, we realized that the intake rates for radium226 and thorium-230 were overestimated by about 

a factor of 2.

Because I believe NIOSH inadvertently did not apply 

the activity fractions. And so when I went to look at 

this, NIOSH agreed, and they indicated that they 

have -- at the time we reviewed this, it was one of 

those documents that did not have a Site Profile.

The dose reconstruction methodology was 

embedded in the dose reconstruction report. It's 

something we call a template. Just like Peek Street 

that we'll be hearing about later.

So the response was that the template -- the old 

template was updated, and now they've actually --

they have a Site Profile that has been published for 

the Grand Junction operations office.

So I reviewed that, and it just so happens that the 

finding that we had here had to do with the time 

period before -- between 1975 and 1984. That's 

where the error was introduced into a table.

Since then, there's an SEC for that period, so this 
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30

doesn't even apply anymore. And we had no other 

issues with this particular template, and I saw that 

things were incorporated into the Site Profile 

appropriately.

So I would recommend closing this finding, and I 

will make the appropriate notations to the BRS.

Member Beach: Okay, and that new -- it's OTIB-60 

Rev. 2, is that correct?

Ms. Behling: Its new TBD is TKBS-60 and that's 

Rev. 0. That's a new --

Member Beach: Okay.

Ms. Behling: Okay.

Member Beach: All right.

Ms. Behling: We, now I believe there is, there's a 

Work Group for Grand Junction, isn't there? I'm not 

sure. So I'm not sure.

Member Beach: I'm not sure if there is.

Dr. Roberts: It's retired.

Ms. Behling: That's what I --

Member Beach: Yes.

Ms. Behling: Okay. I guess it would be appropriate 

then maybe for SC&A to look at this and compare in 

full the template to this new Site Profile.

What I looked at just very briefly, just in and able to 

answer the question for the Finding 4, it looked like 

things were similar, but I didn't look at any level of 

detail.

But perhaps that's something that the 
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31

Subcommittee would want to task us to do. Because 

that's --

Member Beach: Yes, I wrote it down in Table 2 as 

one, but so that is not a Rev. 2, that is a Rev. 0 or

what is it? Because I don't know where I went and 

looked for that document.

Ms. Behling: The Site Profile, okay, the Site Profile 

that I'm looking at on the NIOSH website shows 

Rev. 0. Because in fact, well, and what's the date on 

this? Oh, 2018.

If NIOSH has another Rev. out, please correct me, 

but that's what I'm seeing on the website.

Ms. Marion-Moss: The active, this is Lori Moss. The 

active document for that Site Profile is Rev. 0.

Member Beach: Okay. So I don't know where I got 

Rev. 2, but thank you, Lori. Okay, so one other 

thing on your follow-up action column, it said that 

NIOSH updated the BRS responses on 2-1-2021.

It was actually updated on 1-27-21. I know that's a 

minor technicality there.

Ms. Behling: Okay. Thank you. Sorry about that.

Member Beach: And I'm in agreement with closing 

Finding 4 and with tasking SC&A to review the 

ORAU-OTIB-60. Rashaun, are you in agreement that 

that should stay with the Subcommittee since that 

workgroup is not, is closed or not functioning at this 

point?

Dr. Roberts: Yes, let's keep it with the 

Subcommittee right now.

Mr. Allen: Josie, this is Dave Allen. Can I say 

something?
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Member Beach: You sure can.

Mr. Allen: I am not sure so I'm talking out of school 

here, but I don't think we have anybody that's real 

familiar with Grand Junction on the phone today, 

unfortunately, but --

Member Beach: Yes.

Mr. Allen: -- that Work Group did exist for quite a 

while and I could be wrong, but I'm pretty sure they 

reviewed the revision, the TBD that was created.

Member Beach: Okay.

Mr. Allen: I may be wrong on that, but it seems like 

this should be something for SC&A to look into and 

decide, you know, look at the transcripts from the 

Work Group and decide whether or not it's already 

been reviewed.

Member Beach: Maybe sort of a focus review?

Mr. Allen: Well, I mean, they may have done a 

detailed. I'm not sure --

Member Beach: Yes.

Mr. Allen: -- but if it's already been done by the 

Work Group, whether the Work Group still exists or 

not, is kind of irrelevant and --

Member Beach: Yes and I don't know when that --

(Simultaneous speaking.)

Member Beach: -- because this was issued in 2018. 

Correct? And --

Ms. Behling: Yes.

Member Beach: -- so maybe a little research into 
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33

that. When the last meeting --

Mr. Allen: Okay.

Member Beach: -- was held and if they did review 

it. That's a good comment, Dave, so.

Mr. Allen: Yes, that's --

Ms. Gogliotti: This is Rose Gogliotti. The last 

meeting of the Grand Junction was August 7th of 

2017.

Member Beach: Correct. I'm, yes.

Mr. Allen: Okay. That'll answer that then.

Member Beach: Okay. Thanks both Rose and Dave. 

All right. So back to the Subcommittee, what are 

your thoughts on reviewing OTIB-60?

Ms. Behling: And that's TKBS. It's a Site Profile.

Member Beach: Oh, I'm sorry. I got it, I must have 

just wrote down the whole thing wrong.

Member Ziemer: Is it TBS?

Member Beach: No, it's TKBS. I keep saying it 

wrong.

Ms. Behling: Yes, it's a Site Profile rather than a 

technical information bulletin.

Member Beach: Yes.

Member Valerio: Josie, this is Loretta. So it is 

closing out Finding Number 4 --

Member Beach: Right.

Member Valerio: -- and tasking SC&A to review the 

Site Profile for Grand Junction. Correct?
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Member Beach: Correct.

Member Valerio: Okay, I'm good with that.

Member Ziemer: So my call just dropped and I got 

back. What's the recommendation for SC&A?

Member Beach: The recommendation for Grand 

Junction is to close Finding 4.

Member Ziemer: Yes.

Member Beach: And task SC&A with reviewing the 

Site Profile for Grand Junction.

Member Ziemer: And is that TBS-60?

Member Beach: It's TKBS-0060 Rev. 0, yes.

Member Ziemer: TKBS.

Member Beach: Yes.

Member Ziemer: Yes, 60. Right. Got it. Yes, I'm 

good.

Member Beach: Okay, so Kathy, you are tasked to 

do the notifications and the BRS closing Finding 4 

and then for reviewing Grand Junction TBS.

Ms. Behling: Okay. Very good. Thank you. So, did 

Bob Anigstein join us? Bob Barton, are you on the 

line? Did you communicate with Bob and if so --

Mr. Barton: Yes, hi, Kathy. I gave him a couple of 

calls. Unfortunately, I have been only getting his 

machine, but I'll keep at it.

Ms. Behling: Okay. All right. I apologize. Is, would 

the Subcommittee be okay with us moving on to 

OTIB-6?

Member Beach: I'm fine with that.
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35

Ms. Marion-Moss: This is Lori Moss.

Member Valerio: I'm fine with that.

Ms. Marion-Moss: I have a question before we move 

on.

Member Beach: Okay, Lori.

Ms. Marion-Moss: Could you repeat, is that a focus 

review for the Grand Junction TBD or is that a full 

review of the TBD?

Member Beach: That would be a full review.

Ms. Marion-Moss: Okay. Thank you.

Member Beach: Yes.

Ms. Behling: Okay, I believe Ron Buchanan is on the 

line.

Mr. Buchanan: Yes, everybody hear me?

Ms. Behling: Okay.

Member Beach: Yes.

Ms. Behling: Go ahead, Ron. Thank you.

ORAUT-OTIB-0006 (Dose Reconstruction for 

Occupational Medical X-ray Procedures)

Mr. Buchanan: Okay. This is Ron Buchanan with 

SC&A. And I'll be presenting our focus review of 

OTIB-6, revision 6 for resolution of these issues that 

we identified in revision 5.

This is for Occupational Medical X-ray Procedures. 

This is fairly lengthy book of 140 pages, very 

complex, a lot of tables, a lot of references and 

such.
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36

But it's underwent six revisions now so I think we're 

getting it worked out.

Dr. Anigstein: Bob Anigstein here.

Mr. Buchanan: Okay, do you want to continue on?

Ms. Behling: Yes. Hi, Bob.

Dr. Anigstein: Hi.

Ms. Behling: We started with OTIB-6. I'm not sure 

what the Subcommittee wants to do, if they want to 

go back --

Member Beach: If, yes -- that doesn't sound good. 

If Ron doesn't mind postponing 6 and go ahead and 

let Ron, or I'm sorry, Bob Anigstein go ahead and 

go through his, is that okay with the rest of the 

Subcommittee?

Member Ziemer: Sure.

Ms. Behling: Or have you both --

Member Beach: Okay.

Dr. Anigstein: So --

Member Beach: So let's go ahead and Ron, thank 

you, and sorry for doing that to you.

Mr. Buchanan: That's fine. No problem.

Member Beach: Okay.

Ms. Behling: And, Bob, excuse me, this is Kathy. I 

just had one more question. Will you still be on the 

line to perhaps discuss the PER-57, the General 

Steel Industries?

Dr. Anigstein: Yes.
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37

Ms. Behling: Okay.

Dr. Anigstein: I'm ready for that too.

Ms. Behling: Okay, thank you.

Member Beach: And we can go out of plans, Kathy, 

and do both back-to-back if Bob's okay with that.

Ms. Behling: Okay, very good.

Dr. Anigstein: It'll be fine.

Ms. Behling: Bob?

Dr. Anigstein: Okay. So we have OTIB-24 which is 

the calculation of neutron emission from the alpha, 

well neutron emission from uranium and thorium.

And there were seven findings. I'm going to go over 

them briefly. Shall I just keep going or shall I pause 

and ask for NIOSH comments each time?

Member Beach: I think, what does NIOSH think? Do 

you feel like you'll have a lot of comments you'll 

want to make comments in between or just when 

Ron's done? Or when Bob's done. Sorry.

Dr. Anigstein: Okay, I'll just go ahead. Okay, the 

first --

Member Beach: Okay.

Dr. Anigstein: The first one is more of a procedural 

issue and probably should have been an observation 

rather than a finding. And that's the dose rates are 

expressed in terms of per gram of source isotopes 

rather than per gram of compound.

It just seems that it's much more likely that the 

dose reconstructor would know, say how much 

uranium oxide there is. You would then have to 
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38

calculate how much uranium, how much of that 

oxide is uranium to be able to use the tables that 

NIOSH provided.

However, that's a procedural matter and it's really, 

either way, it's correct. I just thought that 

expressing it in terms of the compound would be 

more convenient.

So that's, I would calibrate that into an observation. 

The second one, the second finding is that the 

original OTIB-24 only listed neutron generation from 

the alpha end reaction which is when the alpha 

particle strikes a light atom and generates a 

neutron.

But it's also the same material that uranium and 

thorium undergoes spontaneous fission and that 

was omitted. And NIOSH's response is that they're 

going to be using the sources 4C code which does 

include and incorporate the contribution of a 

spontaneous fission.

However, and also there's also a new code that is 

apparently unique to NIOSH but its source is 4C-m 

as in Mary. So our response is that in principle, that 

should solve the problem.

However, we have not had the opportunity to 

actually review the NIOSH results and particularly 

we have not had the opportunity to examine the 

sources for M code, because it's not a, it's not 

widely available.

We'll have to get that from NIOSH directly. So we 

will hold all judgment until we have a chance to do 

an in-depth review. So in principle that solves the 

problem, but in practice --

Mr. Smith: Okay.
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39

Dr. Anigstein: -- withholding judgment. The third --

Mr. Smith: And, Bob, this is Matt Smith with ORAU 

Team and for the whole group, that is correct. 4C-m 

is a code that was developed within ORAU Team to 

address the limitation that sources 4C have in terms 

of the upper bound on the alpha energy limit I 

believe around 6 MeV.

And so yes, we'll take a look at what we can do to, I 

can't make a direct promise over the phone, but I'll 

work with management accessing that software.

Dr. Anigstein: Okay. Were we going to --

Member Beach: That is also, I'm sorry. This is Josie. 

Is that being used anywhere else or is it just new to 

this revised OTIB?

Mr. Smith: It was new to this OTIB. It was part of 

our process of dealing with this entire issue. So --

Member Beach: Okay.

Mr. Smith: -- yes, once we get these formal 

comments come over, we'll then address them 

formally backwards to you.

Member Beach: Okay, thank you.

Dr. Anigstein: Okay, the third finding is that the 

doses are, they don't deal with a full progeny for the 

U-238 series and U-235 series and one reason they 

couldn't is because the response, NIOSH response 

that they will be addressing the progeny or they did 

reduce progeny in Rev. 1.

However, again, this is undocumented so we don't 

have the documentation for 4C-m code so until we 

have had a chance to examine that, we can't really 

comment on whether this is a principle that should 
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40

solve the problem.

But we have some, we have to withhold judgment 

on that because the progeny exceeds that 3.5 

energy limit for sources 4C.

Then Finding 4 is, again, no longer relevant if you 

use the original OTIB-24 used for outdated 

experimental results. And, of course, the use of the 

forces 4C will, again, it's the same thing.

So solve that problem, but first we have to review 

the calculations, but more important, we have to 

review the sources 4C-m code.

The fifth finding is, okay, refers again to the 

calculation of the neutron emissions and also the 

use of an older of 1971 NCRP for quality factors.

And we recommended that at that time that they 

use ICRP 74 and NIOSH responded that they are 

inside. They have in fact revised OTIB use on ICRP 

74 for the ambient dose calculations so we agree 

with that as a technique, but again, we have not 

had a chance to do a detailed review on how ICRP 

74 and more important how sources 4C were 

implemented. So we're waiting for that.

Participant: It's getting harder and harder for me to 

hear you.

Member Beach: Yes, I was just going to say the 

same thing.

Dr. Anigstein: Excuse me?

Member Beach: You're fading out just a little bit, 

Bob.

Dr. Anigstein: Oh, sorry. I'll try to talk more 

directly. Is this better?
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41

Member Beach: Yes, thank you.

Dr. Anigstein: Okay. So do I need to repeat 

anything? Do I need to repeat what I said or --

Member Beach: No, I think you're okay.

Dr. Anigstein: Is that, okay. And, oh yes, okay, 

Finding 6, is again a procedural matter where for 

this purpose for the OTIB, original OTIB-24 and the 

revised OTIB-24 Rev. 1, the consultation presented 

distances of one foot and three feet for a point 

source. And just pointing out that there is a, most 

of the dose calculations that I've seen used the 

scenarios in, described in TBD-6000 and that 

specifies the two categories.

Among the categories that work are, one category 

that where the storage that is one foot away from 

the worker's body and another category, which is 

the general labor, the source is one meter away.

And those, many dose reconstruction, the many 

such TBDs and prescriptions, use the one-meter 

distance rather than a three-foot distance. Threefoot distance is unusual. So there's only a difference 

of 10 percent in the distance which translates to 

what is particularly a distance of 20 percent in the 

dose rate.

But it does seem to us that the consistency in the 

various types of dose scenarios, however, I say it 

again, it is an observation because certainly the 

calculation at three foot can't be done correctly.

So we are not saying it is a technically incorrect 

assessment. This assessment might be more 

consistent than the other at one meter.

And finally, the seventh one is similar to we spoke 

to an earlier one that we talked about the how do 
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42

we handle the progeny where there are energies.

Alpha energy is greater than 6.5 MeV and again, it's 

this new code that was developed with sources 4Cm than we would have to examine it and see if we 

can confirm the validity of that.

So we would hold off comment on that until we 

have a chance to make a more thorough review. So 

any questions before we go on to PER-57? Okay, so 

PER-57 --

Member Ziemer: NIOSH has already agreed with 

your findings in a sense. Right? And they are 

stating, I think, that Rev. 1 addresses those and 

you simply haven't had a chance to review Rev. 1 

yet. Correct?

Ms. Behling: This is Kathy. That is correct. And, let 

me also ask a question based on a comment made 

by Matt. Do you want, would it be helpful for SC&A 

to put together either a memo or a White Paper 

discussing or reiterating these findings?

Is that what I understood NIOSH is looking for? 

Matt can --

Mr. Smith: This is Matt Smith with ORAU Team. I 

can't speak for NIOSH or my management, but 

certainly, from my perspective, just a memo 

outlining what Dr. Anigstein just ran through 

verbally would be helpful.

I know where Dr. Anigstein is coming from in terms 

of his request here today, but I think it's proper to 

get it into writing and then we can respond to it 

formally.

Dr. Taulbee: This is Tim. I would agree with that. If 

you would just kind of summarize. It looks like most 

of these findings, you're wanting sources 4C-m in 
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43

order to verify and so that would just kind of trigger 

for us to make sure that we get that code over to 

you all so that you can evaluate it.

Dr. Anigstein: Hello, I was thinking of posting these 

on the BRS. Or do you prefer a memo?

Ms. Behling: Bob, excuse me, this is Kathy. It 

sounds to me that perhaps a memo would be 

appropriate in this particular case.

Dr. Anigstein: Will do.

Ms. Behling: Is the Subcommittee in agreement 

with that? I don't want to speak for the 

Subcommittee. Josie, are you okay with that?

Member Beach: Sorry, I was talking into my muted 

phone. So would this review come before your 

review of the new Rev., the memo or would you 

review the Rev. first and then see that all apply?

Ms. Behling: Good question, Bob, what would you 

do to make --

Dr. Anigstein: It would seem to me that it would be 

more useful to review the Rev. first.

Ms. Behling: Right.

Dr. Anigstein: Which in this way, not a small job.

Member Beach: It sounds to me like we need to 

task SC&A to review the Rev. and then they need to 

go back to each one of these findings and determine 

if that was corrected.

In addition to that, NIOSH needs to make available 

the new M code before you do the review. Is that 

correct?

Dr. Anigstein: That is correct.
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44

Member Beach: And then I think we do need to talk 

about Finding 1. Bob has recommended that that be 

reduced to an observation. And is the Subcommittee 

in agreement with that?

Member Ziemer: It seems --

Member Valerio: I am, Josie.

Member Ziemer: -- like it's more appropriate as an 

observation. I think there was one other one that 

Bob thought might be an observation. Was it six 

maybe?

Participant: Yes, Finding 6.

Dr. Anigstein: The one of the, one second, let me 

think something through. Which one was that?

MParticipant: The one with the distances.

Dr. Anigstein: Thanks.

Member Beach: Yes, that was it.

Dr. Anigstein: Number 6 is an observation. So it's --

Member Beach: Is that --

Dr. Anigstein: -- three foot versus one meter 

distance.

Member Beach: So are you recommending that one 

be reduced to an observation as well?

Dr. Anigstein: Yes.

Member Beach: Okay, and I --

Dr. Anigstein: Yes.

Member Beach: -- am in agreement with that.
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45

Member Ziemer: Didn't SC&A discuss these in some 

detail many years ago in the original review?

Member Beach: I --

Dr. Anigstein: So the original review said the same 

thing about the distance.

Member Ziemer: Yes, well, I mean, Tim you were 

asking for kind of a summary memo or something, 

but are you thinking there's different information in 

what Bob said today from what they said a number 

of years ago when they did the initial review?

Dr. Taulbee: This is Tim. No, I don't think so. I think 

more of what I was interested in is the kind of the 

documentation of the downgrading of the two 

findings into observations as well as just getting a 

better clear picture here.

But it looks like Bob hasn't completed his review yet 

of Rev. 1 and he's needing sources 4C so I think we 

can just provide sources 4C and then we can wait 

for Bob's full review of Rev. 1 and then respond to 

any questions that he has about these findings and 

perhaps any other new ones that he may come up 

with.

Does that sound appropriate?

Dr. Anigstein: Yes, by the way, it's 4C-m. The 4C 

we have.

Dr. Taulbee: Yes, I understand. It's the modified 

version of 4C.

Dr. Anigstein: Okay.

Member Beach: Okay so that, it seems like it would 

be smarter to go through Rev. 1 so I agree with 

that. Bob, did you want to go ahead and go through 
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46

Finding 7 or are we okay to task --

Dr. Anigstein: Okay. Finding 7 is very similar to the 

earlier finding. I mean, it was, basically Finding 7 is 

that the original calculation excluded high energy 

alpha particles which are emitted from the project.

Not from the uranium and thorium isotopes on their 

progeny. And again, NIOSH has addressed this 

using the 4C-m code. So it's in abeyance because 

until we review the 4C-m code.

Member Beach: Okay. All right. So anything else, 

Bob, before I recap?

Dr. Anigstein: Oh, yes. So I'm ready to go on to 

PER-57.

Member Beach: Okay, so give us a minute to finish 

this up and then we'll move to 057. So, Kathy and 

Bob, for the BRS to update for Findings 1 and 6, we 

can go ahead and change those to observations.

Or do you, would you prefer to wait until after the 

review of Rev. 1 is complete?

Ms. Behling: I would suggest that we make them 

observations now and assign them to Rev. 0 and if 

there are additional findings that's typically what we

do.

We will note that in the BRS that this is Rev. 1 

findings and we'll add on to that. So I'll make that 

change.

Member Beach: Okay. So then, so you'll just need 

to document moving those from findings to 

observations --

Ms. Behling: Yes.

Member Beach: -- and then Subcommittee, are you 
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47

agreeable to tasking SC&A with reviewing OTIB-24, 

Rev. 1?

Member Ziemer: Yes, I am, Josie.

Member Valerio: Yes, I am, Josie.

Dr. Anigstein: So --

Member Beach: Okay, so --

Dr. Anigstein: -- should we put anything in the BRS 

about the others, the other five findings or should 

we just wait?

Ms. Behling: The, all --

Member Beach: I think --

Ms. Behling: -- the findings will be added. If they're 

not in the BRS, I think they are, but --

Member Beach: They are. There's not much 

information on them, but they're there.

Ms. Behling: Okay and I will note, I'll add to it that 

we've discussed it during this meeting and I'll 

embellish the BRS to capture what we've talked 

about today.

Member Beach: Okay, that sounds good. NIOSH, 

any other comments on that?

Dr. Taulbee: This is Tim. None for me. Thanks.

Member Beach: Okay and so at the earliest 

convenience, you'll be able, you'll get that new code 

info so that Bob knows where to find it. I'm 

assuming you'll let the Subcommittee know when 

that takes place?

Dr. Taulbee: Yes, we will.
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48

Member Beach: Okay, thanks Tim. Okay, anything 

else for OTIB-24? Okay, I'll note that you're tasked 

and, Kathy, your work is getting longer here.

Ms. Behling: Okay.

Member Beach: We okay to move on or, so --

Ms. Behling: I think Bob is ready.

Member Beach: -- I was going to see 

Ms. Behling: I think --

Member Beach: -- if anybody needed a break, but I 

think we'd better go ahead and finish up. We are 

near --

Member Ziemer: I have a quick question, general 

question. I'll ask either Rashaun or maybe Josie, 

you'll know the answer. I know many times in the 

past, we've really put it to the DFO to do the 

tasking.

In terms of some knowledge of budgetary issues or 

restrictions, are we okay, just having the subgroup 

do the tasking today? Rashaun, is that okay or --

Dr. Roberts: Yes, good question. I think it's okay 

just to move forward with the Subcommittee doing 

the tasking.

Member Ziemer: If there are any budgetary 

restrictions, I'm wondering if, Josie, would it be 

okay if Rashaun worked with you to on timing with 

tasking if it was necessary? In other words --

Member Beach: Yes.

Member Ziemer: -- if something had to be delayed, 

we need to decide, you know, which of these is 

most important.
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49

Member Beach: All right.

Member Ziemer: But I'm comfortable leaving that to 

you guys. But I know that sometimes in the past, 

there's been some issues that come up with 

budgetary restrictions that sometimes appear.

Probably not so much this time of year, but, yes, it 

could be. Who knows?

Dr. Roberts: Yes. Certainly. And, yes, if anything 

comes up with regard to that, I could certainly be in 

touch about it. But I think it's okay for now to move 

forward the way that we have been.

Member Ziemer: Good. Okay.

Member Beach: All right. Thanks, Paul. Appreciate 

you bringing that up.

Continuation of DCAS-PER-057 (General Steel 

Industries)

Dr. Anigstein: Okay, so I should go on to 57, PER57?

Member Beach: Yes, please.

Dr. Anigstein: Okay, the purpose of PER-57 is, this 

was a review of the original append or Rev. 1 rather 

of Appendix BB which is the TBD for General Steel 

Industries.

And quite a while ago, NIOSH had already prepared 

a Rev. 2 and then a Rev. 3 and there was a PER-80 

for those which we are not, which has not come up.

So the seven observations, there are seven 

observations on PER-57. Several of them have been 

resolved so they're no longer, they're closed.

And the remaining ones, with one exception, have 
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50

been resolved, but I'll just go over it very, very 

quickly, the outstanding ones.

Observation one which is a question of how to apply 

the exposure to organs. Those conversion factors 

have been resolved. It was that they use a fixed 

value and we agree in the revision that that is 

appropriate.

Observation three was that there was an error in 

the way NIOSH calculated the doses and that has 

been resolved in the revision two.

But that is no longer valid, that can be closed. Then 

there's Observation 4 and there are no neutron 

doses in the Rev. 1 and Rev. 2 has corrected that so 

that's been resolved.

Observation five, we don't know the status because 

that was during the performing the PER-57 subtask 

four. We count one of the cases we were reviewing 

was a skin dose case.

And our comment on that was that the skin dose 

should have been resolved, but it was years 1964 to 

1966 where the maximum exposure was to operate 

to a worker called the layout man who spent all of 

his time, eight hours a day in close contact with 

freshly irradiated steel castings.

So he's getting a chronic skin dose and NIOSH has 

find to be an acute dose and the, we're just quoting, 

this was directed to look up the IREP user's guide 

which says that they would, that anything less than 

600 millirem per hour over one day should be 

considered to be chronic.

And this is certainly much less than 5,200 millirem 

per year and it's every day, every workday of the 

year. So and we do not know whether that's been 

resolved or not because we haven't seen another 
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51

skin dose case since then.

But we don't know how NIOSH is applying this. No 

direction in the actual TBD on that. And the seventh 

observation was a question of assigning medical xrays that we agree that it should be done uniformly 

whether or not we had a comment that one worker 

said, no there were no x-rays.

So, but that was the last of these uniformly 

assigned x-rays. And that's it. All exactly the 

findings. So that's the end of the comments on PER57. Any questions?

Mr. Allen: Well this is Dave Allen. If I can respond to 

that one observation, Observation 5 was beta dose 

and whether it should be assigned as chronic and 

that is true.

I think anything with a model unless it's modeled as 

a split second or, you know, a very short time, it 

should be modeled as a chronic.

Dr. Anigstein: Okay.

Mr. Allen: Our typical approach, however, is with 

the many dose reconstructions on many different 

sides is to automatically assume acute for protons 

and electrons and chronic for neutrons since that 

gives us the higher POC and it's not, as long as we 

don't have, you know, huge doses, you know, big 

incidents, that's usually not a big factor.

So our dose reconstructors are used to assigning 

acute for protons and for electrons even though 

they didn't have to in this case. That was discussed, 

I don't have the date.

That was discussed in the previous meeting back 

when Wanda was Chair and she closed Observation 

2 based on that. But you'll see Observation 2 is 
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52

exactly in protons instead of electrons.

Observation 5 is the exact same story. And, I think 

it should just be closed. It's an observation. It's a 

small effect and it's something very, we're typically 

used to doing even though it is, we're typically used 

to doing as a favorable approach even though Bob 

is correct and chronic would be the more accurate 

means.

Dr. Anigstein: Very good. So we can close that 

based on that comment.

Ms. Behling: Okay and this is Kathy Behling. I just 

wanted to ask a question of Bob. Did you discuss 

Observation 6 or was I looking at something else? I 

don't remember hearing you talk about Observation 

6.

Dr. Anigstein: I only printed out the ones that -- I 

believe Observation 6 was closed previously.

Ms. Behling: Okay, then that was my mistake. The 

other question that I have is, because the BRS did 

not get updated until I believe after I or it was very 

close to the time that I prepared this document, I 

simply put that SC&A would attempt to look at 

these responses.

Based on what you're telling me, I took some notes 

here, but for me to update the BRS, either I could 

ask that Bob update the BRS or that you provide me 

with a little bit more information.

Because your, I see it appears that both the 

observations are closed and correct me if I'm wrong 

here, they are resolved because of revision one and 

revision one has addressed these observations. Is 

that correct?

Dr. Anigstein: Okay, are we talking about PER-57 or 
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53

about OTIB-24?

Ms. Behling: No, PER-57.

Member Beach: Fifty-seven.

Ms. Behling: Yes, PER-57. And I will also make 

mention, subtask four, just as a reminder, that is 

when we, we've already reviewed the General Steel 

Industries PER.

And now our protocols indicate that we have to pull 

out some representative cases and review those 

cases and that subtask four and these observations 

are associated with the fact that Bob looked at some 

cases and in reviewing those cases, these 

observations came to light.

Dr. Anigstein: I'm a little confused. PER-57 referred 

to revision one of, which I think revision one goes 

back quite a number of years to something like, 

Dave, you can probably remember better than I 

can.

Mr. Allen: No, I can't really remember the dates, 

but I think Bob's just going to tell you, Kathy, that 

you said they were fixed as a result of revision one 

and it really should be as a result of the revision 

two.

Dr. Anigstein: Right.

Ms. Behling: Revision two.

Dr. Anigstein: It was also a revision --

Member Beach: Well and just for the record, 

Observation 6 is, shows open in the BRS. It does 

not show closed.

DR ANIGSTEIN: Oh, then that's my fault. I thought 

it was closed.
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54

Member Beach: Yes, and Bob, you went through 

that very fast so it was hard to kind of keep track of 

where we were as we were going through.

Member Ziemer: Did you include Observation 3 and 

I thought you skipped one before. What about 

three? Did you all, did I miss that?

Dr. Anigstein: Three?

Member Ziemer: Observation three.

Dr. Anigstein: Observation three was a question 

that the, sent over the same distribution assigned to 

the DCF. There was also a triangular distribution, I 

believe, assigned to the doses to the exposure rates 

and the two, one was multiplied by the other which 

was assumed that it was a perfect correlation.

The lowest ECF would always correspond to the 

lowest dose. And NIOSH agreed that that was 

incorrect and that was corrected in subsequent 

calculations. So --

Member Ziemer: The matter was resolved, I just 

hadn't marked it then.

Member Beach: Yes, that one was closed actually.

Member Ziemer: All right.

Member Beach: It looks like back in 2017.

Dr. Anigstein: I have a printout. I'm not on the 

computer right now. I have a printout from January, 

dated January 3rd, 2017 and the status is open.

Member Beach: Oh, yes, you're right. Bob, I was 

looking at the findings, not the Observation 6s. 

Pardon me. The findings are all closed.

Dr. Anigstein: The findings are all closed?
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55

Member Beach: That is correct.

Ms. Behling: Okay, this is Kathy. And please correct 

me here if this is not the way you want to approach 

it, Subcommittee members. From my perspective, I 

think it might be useful and forgive me, Bob, but 

could we go through each one of the observations 

one at a time and after you discuss one Observation 

1, let's have a discussion among the Subcommittee 

members to determine should we close this or 

shouldn't we?

I don't know if Subcommittee members are ready to 

blanketly close all of these based on Bob's 

discussion or if you need, if we need to go through 

these one at a time.

And, that's maybe for my benefit. I don't know.

Member Beach: No, no, Kathy. I agree. That was 

too fast for any of us to really make a decision and 

yes, sorry, Bob. You're very thorough, but very 

quick.

So in order for us to document these and close 

them correctly, I think we do need to just go back 

and just briefly go through each one independently.

Other Subcommittee members, are you okay with 

that?

Member Ziemer: Sure.

Member Valerio: Yes, Josie.

Member Ziemer: I'm fine with it.

Dr. Anigstein: Okay, let me pull something out. Hold 

it, give me one second.

Member Beach: Kathy, do you have the BRS open?
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56

Dr. Anigstein: Yes.

Ms. Behling: I do not.

Member Beach: Okay.

Ms. Behling: I was attempting to do that. I 

apologize. I am not as good with this. Especially on 

CITGO.

Dr. Anigstein: Okay.

Member Beach: Yes, I, all of --

Member Ziemer: Are there NIOSH responses in the 

BRS?

Member Beach: Yes, I was going to say in --

Ms. Behling: There we go.

Member Beach: -- January 29th, 2021, Dave Allen, 

put, I think they're all the same aren't they, Dave, 

that the Appendix tools and some techniques were 

revised and the new PER, PER-80 performed the 

new revisions and PER-80 were reviewed by SC&A 

and all the findings and observations were closed.

And NIOSH is recommending closing all 

observations for PER-57. And, Dave, is that the 

same on all of them?

Mr. Allen: Yes, it's the same on all of them. We did 

the same thing. Bob did his and just kind of brushed 

through it all to say that everything's okay now.

Member Beach: Yes. And that's okay except for 

whoever has to type it up and make sure it makes 

sense. Then we don't have to go back and try to 

figure out why we did it so.

Mr. Allen: Okay.
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57

Ms. Behling: And I do have this whole, this is Kathy 

again. Excuse me.

Member Beach: Yes.

Ms. Behling: I do have PER-57 pulled up now and 

starting with Observation 1, subtask four.

Member Beach: And, Bob, I don't think you have to 

open it, if you would just slowly go through each 

one, we could just take care of them.

Dr. Anigstein: Okay, I'll do that. So, Observation 1 -

-

Member Beach: Okay.

Dr. Anigstein: -- is that NIOSH used a fixed value of 

the exposure to organ DCF for assigning doses to 

administrative personnel which is inconsistent with 

the directions in OTIB-1.

And on further review, when we were reviewing 

OTIB, excuse me, PER-080, SC&A concluded that 

given the limiting nature of that assessment, the 

bounding nature I should say, of that assessment of 

administrative personnel, the fixed value of the 

exposure to organ DCF was appropriate.

It was claimant-favorable and it was appropriate. So 

we agree with NIOSH that that has been resolved 

when we were, by our review of PER-80. Okay, 

should I go on?

Member Beach: Okay. That sounds reasonable to 

me to close that finding. Others? Loretta, Paul?

Member Ziemer: Yes. Well, observation, right? Is it 

a finding or an ---

Member Beach: Observation.
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58

Member Ziemer: Yes.

Member Beach: Observation.

Member Ziemer: Yes.

Member Beach: All observations.

Member Ziemer: Yes. I agree. It should be closed.

Member Valerio: I agree. It should be closed, Josie.

Member Beach: Okay. Thank you.

Dr. Anigstein: And Observation 2 was previously 

closed. Observation 3 was a error in the way the, 

this arose again, out of PER-057, review of one of 

the cases that was an error on NIOSH's part in the 

way the doses were assigned.

That there was a triangular distribution assigned to 

the dose conversion factor. Another triangular 

distribution assigned to the actual doses.

And they all supplied the two in the sense that the 

lowest DCF was always, was multiplied by the 

lowest dose.

The highest DCF by the highest doses, so forth in 

between. And that is the detail random disputes and 

these are the typical uncorrelated distributions that 

should not have been done.

And NIOSH agreed with that and that error did not 

reoccur when we were looking at the reason, at the 

per PER-080. So PER-080 really superseded this.

So we recommend that it be closed. And I run after 

it's going to be closed and SC&A agrees with that.

Member Beach: Okay. And I have no problem with 

that. I agree as well. Loretta, Paul?
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59

Member Ziemer: Yes. I agree --

Member Valerio: I agree.

Member Ziemer: -- as well.

Member Beach: And Kathy, chime in if you need any 

more information, please.

Ms. Behling: I will. Thank you.

Member Beach: Since we're going to be --

Ms. Behling: Yes. Thank you.

Member Beach: Yes, please if --

Ms. Behling: Okay.

Member Beach: -- you're going to be up after us.

Ms. Behling: Yes. I'm good. Thank you.

Member Beach: Okay. So Bob, I think we're ready 

for 4.

Dr. Anigstein: Observation 4 is that the attended DB 

Rev. 01 does not assigned neutron doses. Usually in 

the way it was silent on neutrons. It's ignoring 

neutrons.

And the Revision 2 and Revision 3 gave bounding 

values for neutron dose conversion factors used for 

all organs and neutron doses were assigned based 

on a MCNP analysis.

So the Rev. 03 contains the directions for how to 

assign neutron doses. So therefore we recommend 

that that observation be closed.

Member Beach: Okay. Agreed here.

Member Ziemer: And also agreed --
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60

Member Valerio: Agreed.

Member Beach: Loretta, Paul?

Member Ziemer: Yes, also --

Member Valerio: I agree.

Member Ziemer: -- agree.

Member Beach: Okay. Observation 5?

Dr. Anigstein: Yes. Observation 5, we just had this 

back and forth between myself --

Member Beach: Yes. And?

Dr. Anigstein: -- and Dave Allen. And even though 

there is no documentation, I am not aware of any 

documentation. Okay. I'm sorry, I should back up.

The Observation 5 is that the beta doses that were 

assigned to the skin during the period of 1964 to 

1966. 1964 and 1966 is unique because when the 

GSI got what is called the new betatron.

So the betatron was located right next to the main 

building and the person. So there was a very short 

distance between the betatron room and the room 

where the testings' were marked up and cleaned up 

and repaired and sent back for more radiation.

And during this period you had heavy activity, not 

radio activity, heavy industrial activity. And you had 

this layout, it was not always the same man, but we 

assumed for the purpose of doses, I mean, that is 

the same person.

He was constantly exposed so that the exposure to 

the skin took place over an 8-hour day. And it was 

not in bursts, like when beta, which was from the 

activated, the radioactive steel that was activated 
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61

through the betatron radiography.

And consequently, the chronic exposure had been in 

the one skin dose case, so it was entered as an 

acute exposure. I'd say that one just increased and 

I also eventually will be using a chronic exposure for 

this scenario.

So we haven't seen that document, but we accept 

the assurance that it will be done.

Member Beach: Okay. So you're okay to close this 

with NIOSH's agreement and stating that they're 

going to use this as a chronic. Is that correct?

Member Ziemer: I thought the resolution was that 

acute would be used since it's more claimantfavorable even though admittedly the exposure is 

chronic.

I thought that's what NIOSH planned to do and that 

SC&A had agreed on that. Did I misunderstand 

that?

Dave Allen was suggesting that they typically use 

acute for skin dose simply because it's more 

claimant-favorable.

Mr. Allen: Yes. This is Dave. I can only hear part of 

what Bob was saying there. It was a little statically 

and stuff, but I said before chronic would be the 

right way to go.

We often use acute as a favorable, the dosage 

instructors are used to using acute as a favorable 

and often will do that and it doesn't make a lot of 

difference.

Member Ziemer: So I guess I'm asking, is the 

resolution that NIOSH is agreeing to use acute or is 

the resolution that SC&A is agreeing that's it's fine 
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62

to use, did I say it backwards?

Member Beach: Yes. Good --

Member Ziemer: Is SC&A saying it's okay to use 

acute?

Dr. Anigstein: Well, if NIOSH claims that it's, I 

haven't investigated this. If NIOSH claims that the 

acute is more claimant-favorable, we won't object to 

that.

And that's why it's an observation anyway and not a 

finding. Because it's not a, the skin dose during 

those years is relatively small and whether you use 

the acute or the chronic, I don't think will make 

much of a difference.

Member Beach: Okay. So --

Member Ziemer: May not affect outcomes anyway, 

but I wasn't sure what was being agreed to on this 

one.

Member Beach: Well, yes. Sounds like NIOSH or 

Dave said that chronic is the correct way, but acute 

is more favorable. So it sounds like SC&A is okay 

with that?

Dr. Anigstein: Yes.

Member Beach: And Dave, you're not agreeing to 

change anything in the documents, correct?

Mr. Allen: Correct. I think the documents silent on 

this, honestly.

Member Beach: Yes. Okay. So the most claimantfavorable will be used. Is that what I'm hearing? 

And --

Mr. Allen: Well, I mean, we can always, we 
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63

generally say we can always go more favorable. 

When we get to the best estimates and stuff, we 

might have to use the chronic. You know, like I 

said, that is the correct one.

Member Beach: Okay. Bob, where are you at with 

this? Are you agreeing to close?

Dr. Anigstein: I'm agreeing it to close.

Member Beach: Okay. Subcommittee, agree with 

this also?

Member Ziemer: Yes. I agree with it. Just the 

transcript will include our discussion on this anyway. 

As Dave Allen said, if they use best estimate, they 

may actually end up using chronic anyway.

But for most of those --

Member Beach: Yes.

Member Ziemer: -- General Steel people, that's not 

going to make much difference.

Member Beach: Right. Right. And this will have a 

twice the conversation. So okay, we're agreeing to 

close Observation 5 and Bob, if you move on to 6. 

Unless there's a comment?

Dr. Anigstein: 7, we simply were being --

Member Beach: So we're on 6, right?

Dr. Anigstein: 6 was closed.

Member Beach: No. 6 is actually still open in the 

BRS. It's NIOSH's Used Deficiency Measures to 

Estimate Internal Doses to the Kidneys. Is that one 

we're not ready to look at then if you didn't get a 

chance to look at it?
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64

Dr. Anigstein: That must have been an error on my 

part that I didn't, let me see if I can pull it. It's 

going to take; I don't want to hold the meeting up.

Member Beach: Maybe if we take a break, you can 

take a quick look at that Bob, what do you think? 

But, let's go on to 7.

Dr. Anigstein: Okay.

Mr. Allen: Josie, this is Dave Allen. I think some of 

the confusion might be that this observation is 

identical to Finding No. 2 --

Member Beach: Oh, that's right. Yes.

Mr. Allen: And Finding No. 2 -- and that was closed 

four years ago or whatever.

Member Beach: Correct. You're right. So just to be 

sure, when you get a chance if you'd look at that 

Bob, and then maybe get back to us after a break?

And just so you're okay with closing six. I don't --

Dr. Anigstein: Okay. I will --

Member Beach: I'm sure it's -- I'm sure it's probably 

okay. But let's look at 7 and then.

Dr. Anigstein: Seven. Seven we can handle. Seven 

we were just being, the Observation 7 was that 

there was a interview, the CATI of a worker, if I 

remember correctly, who stated that medical X-rays 

were not, it was asked were medical X-rays required 

and they said, no.

So my observation then was, then why assign him a 

medical X-ray if he's not, if he said it was not 

required? And we can see since then, a lot of water 

has gone under the bridge, and NIOSH has made a 

uniform policy of assigning medical X-rays unless 
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65

proven otherwise.

And we agree with that. The claimant-favorable, 

then consistent. Everyone's treated the same way. 

So that observation can be closed.

Member Beach: Okay. Everybody in agreement with 

that?

Member Ziemer: Yes. Let's close that one.

Member Beach: Okay.

Member Valerio: Yes.

Member Beach: And there is a document on Finding 

2 that Dave Allen, it's on the BRS from February 

15th, 2017. I guess we can close all of those except 

maybe 6 and then Bob, if you could look at that 

briefly and determine if you're comfortable with 

that?

Dr. Anigstein: I will do that.

Member Beach: And then how's everybody doing? 

Are you guys ready for a lunch break or a comfort 

break? I know this is East coasters lunchtime.

Member Ziemer: I'm okay with going along for a 

while, but whatever works for the others.

Member Beach: Okay. Anybody else need a break, 

or not? I'm okay with going on as well.

Ms. Marion-Moss: Josie, this is Lori. I need a break.

Member Beach: Okay. Should we just take a quick 

break, a ten minute, 15 or are you looking for a 

lunch break, Lori? I'm okay either way.

Ms. Marion-Moss: 15.
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66

Member Beach: 15. Okay. Rashaun, shall we go 

ahead and take a 15-minute break?

Dr. Roberts: Yes. Do you just want to call it about 

12:30, 12:35?

Member Beach: Just say 12:35.

Dr. Roberts: Okay. All right, back at 12:35, then.

Member Beach: Okay. Thank you. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 12:19 p.m. and resumed at 12:37 p.m.)

Dr. Roberts: Okay. Well, I think everybody's on at 

this point. Court reporter's set up to get going. So 

it's yours, Josie.

Member Beach: Okay. Thank you. And I'm going to 

circle back to PER-57 and Bob, did you get a chance 

to look at 6?

Dr. Anigstein: I did.

Member Beach: Okay. What do you think?

Dr. Anigstein: Okay. The observation was that they 

use the efficiency method, which was that 

essentially the intake was spread out uniformly over 

the entire year.

And then if the employee in question did not work 

an entire year, then it's simply the total intake, the 

intake rate was reduced, not the intake duration.

The intake duration remained a year and his rate 

was reduced. So if he's only employed for six 

months, he only took in 50 percent of the intake 

that was assigned to a worker that was there all 

year. But it was still for the whole year. And the 

problem with that is, like uranium has a long period 
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67

of residence in the body.

So if, in fact, he worked during the first six months 

during the year, he would've taken in the uranium 

and it would have been a higher dose rate 

subsequently then if had simply taken it over a 

period of a whole year because he would have taken 

more uranium for a longer period of time.

Let me check I'm getting this straight. Yes. If it 

came, I mean, think of it as if it were an acute 

intake. So if he, it makes a big difference whether, I 

mean, I'm just giving a, not the real case, 

hypothetical case.

It's easier for me to grasp and make observation as 

exposure.

Member Beach: Sure.

Dr. Anigstein: If he had a single take, an accidental 

intake, it would make a big difference to the 

second-year dose if the intake took place in January 

or took place in December because the dose would 

have been distributed over a longer period of time.

And this was not resolved. There was a CAD tool 

that Dave Allen called attention to and I'm looking 

at my review of PER-057 and also my review of 

PER-080 where the same thing came up.

And even though we were able to match for a 

period, I'm sorry. When in fact, the exposure was 

uniform, we were able to match NIOSH's numbers 

very closely.

But the hypothetical case of an interrupted 

exposure, there could be some cases where -- I'm 

sorry. I'm having trouble. One second, please.

Okay. I'm back. Hypothetically, could be a case 
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68

where a worker worked earlier in the year and his 

dose would be understated as a result.

So that, to my knowledge, has not been resolved. I 

made an observation because the effects would be 

small, but they just, you know, since we calculate 

the PoC to two decimal places, there conceivably 

could be cases where compensation could be 

affected.

Member Beach: So Bob, this is Josie. I have a 

question. So Dave said that Observation 6 is the 

same as Finding 2. The Subcommittee closed 2 

before we got the response from NIOSH.

So I'm wondering if that was closed prematurely or 

are you only basing this on Observation 6?

Dr. Anigstein: Give me one second. I've got it on 

my screen, let me look it up.

Member Ziemer: Yes. These are findings on a PER --

Member Beach: Right.

Member Ziemer: -- and so that's for a specific 

worker or for the general approach for the PERs. I 

don't remember.

And since those PER --

Member Beach: Yes. And if you look at Finding 2 in 

January 10th of 2017, the workgroup closed Finding 

2, but we hadn't gotten NIOSH's response.

And NIOSH's response came in, I believe, after the 

fact, which is posted on the BRS. I'm just going 

back to that to see what the date is.

Ms. Behling: March 3rd, 2017.

Member Beach: February 15th. Yes. And the only 
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69

reason I bring that up, of course, is because it was 

stated that those were the same. So --

Dr. Taulbee: This is Tim. I mean, if you look this 

part of our response here is that we've modified the 

tool to account for partial years of employment.

So --

Member Beach: Right.

Dr. Taulbee: -- and that's what I'm reading as to 

why it was closed and so I'm not, I don't see any 

reason why --

Member Beach: Yes.

Dr. Taulbee: -- it shouldn't be closed.

Member Beach: Okay. And then --

Member Ziemer: So let me ask Bob a question. I 

don't recall it because I was involved with GSI, but I 

don't recall on the intakes if for internal organs if we 

were assigning a daily intake over the year?

Bob, do you remember that?

Dr. Anigstein: I'm sorry. Say again, please?

Member Ziemer: Were we assigning daily intakes 

over the year for internal?

Dr. Anigstein: Yes.

Member Ziemer: And maybe Dave Allen might 

remember. But it seems to me if we have partial 

year that's not that hard to calculate.

Dr. Anigstein: But the thing is IMBA has the, I'm not 

an expert on IMBA, Kathy could probably help me 

better.
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70

I believe IMBA allows you to have regimen of less 

than a year. Whereas, NIOSH uses it's CAD tool, 

which everything is by a year. It's put out over a 

year. I just adjusted for, break adjusted.

And by the way, I agree, I'm not quite sure how this 

looks, looking at my original review of PER-057, 

there was a finding, the Finding 2 and Observation 6 

apparently are overlap.

I think the reason that they, I was assigning 

findings case-by-case, there were five cases. And 

then I, yes, it was a number of years ago, I really 

don't know how it came about.

But the observation has not been fully responded to 

by NIOSH.

Member Beach: Okay. So Bob, can you write 

something up and either on the BRS or in a memo 

form? I don't know what NIOSH would need to 

answer your concerns with 6.

Dr. Anigstein: I think a memo would be more 

convenient in this case, more effective.

Member Beach: Okay. NIOSH, any comments?

Member Valerio: Bob, this is --

Mr. Allen: Yes. This is Dave Allen. I mean, that 

memo is in Finding 2.

Member Beach: Your memo, but Bob's got 

concerns. So maybe Bob, you can look at the memo 

in Finding 2 and then take some more time and 

then we'll come back to this at the next meeting.

Dr. Anigstein: Okay. Will do.

Member Beach: I mean, is that reasonable? And if 

you have more to add, of course, get that memo 
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71

out to the Subcommittee.

Dr. Anigstein: Yes.

Member Beach: Okay. Is everybody in agreement 

with that?

Member Ziemer: That's fine with me. I'm trying, 

again, ask Dave Allen if he can remember but, is 

this just specific to these PERs or does it go back to 

the Site Profile?

Mr. Allen: Okay. This is Dave. It doesn't affect the 

Site Profile. The Site Profile's okay. It's a question of 

the tool we were using.

The tool, the CADW could only estimate dose in 

full-year increments. So we would prorate a partial 

year, you know, the total intake for a partial year to 

spread it out over the full year.

That way the total dose was correct. And in that 

memo, I pointed out that that makes the first year 

off, but then second and subsequent years are off 

the opposite direction and it's --

Member Ziemer: Yes, and now it's a --

(Simultaneous speaking)

Mr. Allen: After about five years you have the right 

total intake.

So it only really affects the PoC significantly if you 

had, well, it could only affect the dose significantly if 

you had a diagnosis within a year or two of that 

prorated year.

And if you did, the latency would mean the risk 

factors are insignificant. So it would never affect the 

PoC, not significantly.
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72

Since that time I've told our dose reconstructors 

they could still prorate and use that for most cases, 

but if it gets into the 45 to 52 percent range, the 

best estimate range, they should use IMBA, which is 

what they've been doing since then.

And this was discussed under PER-080, I believe, 

and closed out there too. I'm not sure if it was, 

actually, I'm not sure if there was a finding or an 

observation, but it was discussed during that and 

closed out.

Dr. Anigstein: Okay. What I would suggest is that I 

prepare, I don't want to take the committees time 

now. As earlier instructed, yes, I'll take into account 

what I just heard from Dave and I'll prepare a 

memo responding to this.

Actually Dave, would it be useful if you were to 

prepare a memo first summarizing what you just 

said?

Mr. Allen: Yes. That's in Finding 2.

Dr. Anigstein: Yes.

Mr. Allen: It says that. But it's --

Member Beach: It's already in Finding --

Mr. Allen: -- goes off one day.

Ms. Behling: Yes. I have it posted on this screen 

right now. And it is embedded, it is attached to 

Finding 2 in the BRS, Bob.

Dr. Anigstein: Finding 2 on PER-057?

Member Beach: Yes.

Ms. Behling: Correct.
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73

Member Beach: It's in that last in Finding 2 the last 

box.

Dr. Anigstein: Okay. Okay.

Member Beach: But I think Kathy can probably just 

send it to you too --

Ms. Behling: Yes.

Member Beach: -- if that works.

Member Ziemer: Yes. The details are there. It's --

Member Beach: Yes.

Member Ziemer: -- it's posted on the Skype right 

now.

Dr. Anigstein: I mean, I did not look at it when now 

because everything was closed so I wasn't confining 

myself to open.

Member Beach: Yes. We can just close all of the 

observations and leave 6 open with you having a 

chance to review that. I think that's fine.

Subcommittee agree?

Member Ziemer: Yes. That's good.

Member Beach: Okay. And it'd just be a carry-over 

for the next meeting. Just a quick discussion, I'm 

sure.

Dr. Anigstein: So I --

Member Beach: Okay. Anything else on PER-057?

Dr. Anigstein: So just to confirm, I'm still supposed 

to prepare a memo, right?

Member Beach: Yes. Yes. Look at it and if you feel 
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74

like it warrants a memo, please do if you're not 

satisfied with the finding memo that NIOSH put out 

in February that's associated with Finding 2.

So yes, please.

Dr. Anigstein: Okay. So I'll prepare a memo in 

either case. Either --

Member Beach: Okay.

Dr. Anigstein: -- agree or disagree.

Member Beach: Yes.

Dr. Anigstein: Okay.

Member Beach: All right. Anything more? If not, I 

think we can circle back to Ron and OTIB-6.

Mr. Buchanan: Okay. I'm on.

Member Beach: Thanks for your patience, Ron. We 

really appreciate it.

Mr. Buchanan: That's fine. So Kathy will run the 

slide projector and I will try to call out the page 

numbers as I review this.

Let's briefly recap. This is a focus review of OTIB-6, 

or patient six to see if the issues were resolved we 

identified in Revision 5 and this is for occupational 

medical X-ray procedures.

And we see on page 1, we list the documents 

pertinent here. It's OTIB-6, Revision 5 of 2018. We 

did a review of that and issued that in 2019.

And then NIOSH issued Revision 6 in 2019. And this 

is what this document memo is, is to look at these 

issues and see if they are resolved by Revision 6.
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75

Now, when we reviewed Revision 5, we did not have 

any findings. We had six, I mean, excuse me, seven 

observations with minor issues that didn't affect 

dose or we wanted clarification on.

And in addition, this is a very thick document, 140 

pages, lots of tables, lots of references and such. So 

we had some documentation issues at the end that 

we'll talk about.

So that's on page 1, we'll start out with Observation 

1. It said, need clarification for DCF units in 

Attachment B. Tables B, 1, 2, and 3 in Revision 5 

had a very complex set of units there that didn't 

quite make sense.

And we commented on that and asked for 

clarification. See that at bottom of page 1, status of 

Observation 1. We find that in Revision 6 then those 

tables have a different heading on it and they list 

the simple correct units of rim per centigrade.

And so we feel that that's been resolved and 

recommend that that observation be closed.

Member Beach: Okay. Let's take these one at a time 

and any discussion on Observation 1 and SC&A's 

findings and recommendation to close?

Member Ziemer: I think that's very straight forward. 

Ron, it's helpful. I'm good for closing that.

Member Beach: Okay.

Member Valerio: I'm good for closing that, Josie.

Member Beach: Okay. I am too. Thanks. Thank you 

and so we're closing Observation 1 and you can go 

ahead and move forward, Bob.

Mr. Buchanan: Okay. So this is page 2, Observation 
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76

2 and this was the only one that remained open and 

it was a need clarification for changing chest 

thickness.

A little background to this, in Revision 5 they listed, 

in Revision 4, they listed chest thickness as 24 

centimeters. In Revision 5 they had changed it to 24 

centimeters.

And we asked for clarification on that because we 

looked at some of the references and they list 

anywhere from 20 to 25 centimeters.

And while we had no problems with using 24 

centimeters, we wanted to know where that came 

from, the reference for it. And so in Revision 6, they 

provide a reference of ICRP, 110 of 2009. That's an 

84-page document.

I looked it up in the ICRP files and did some 

searches in it and I could not find where chest or 

thickness or 24 centimeters was listed.

And, like I say, we had no problems really. We just 

need the referencing page number for that. So 

that's the reason we have that recommended open.

Member Beach: Okay. NIOSH have any comments 

on that?

Dr. Lobaugh: Hi, Josie. This is Megan Lobaugh.

Mr. Allen: This is Dave Allen -- go ahead, Megan. I 

didn't know you were on.

Dr. Lobaugh: Oh, yes. Sorry, Dave.

Member Beach: Hi, Megan.

Dr. Lobaugh: Hi. So I just wanted to provide an 

additional clarification there. So we did use ICRP 

110, but specifically we were using the voxel 
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77

phantom that's described in ICRP 110.

So to come up with the 24-centimeter thickness we 

actually made a measurement of that voxel 

phantom using the MCNP visual editor.

So when we made that measurement it was 

approximately 23.9 centimeters so that's how we 

rounded up to 24 centimeters.

So the reference we have in there, I believe, is 

correct, you know, it is correct, but we could 

provide additional information as to the fact that we 

measured that using the phantom as described in 

110.

Mr. Buchanan: Okay. That would be helpful because 

I couldn't find where it stated that in 110. So if you 

could just provide information of how you came up 

with that from whatever, you know, values they 

provide, I appreciate that.

Member Beach: Okay. Is that one we should leave 

open until that is addressed in the BRS?

Member Ziemer: That's so simple. I'm wondering if 

we can just agree to have them add that 

information and we can close this out?

Member Beach: Okay. Ron, you okay with that?

Mr. Buchanan: Yes.

Member Ziemer: It's just a couple sentences, right?

Member Beach: Okay.

Member Ziemer: I think Megan can provide the 

wording on the --

Member Beach: Okay.
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78

Member Ziemer: I'm okay with, if that's the 

clarification that makes sense.

Member Beach: And Megan, I think you can 

probably just send an email to if that works and 

then when Kathy's updating the BRS. I don't know, 

or NISOH, whoever does that can just add that.

Ms. Marion-Moss: This is Lori --

Member Beach: Okay.

Ms. Marion-Moss: We'll get that updated.

Member Beach: Okay.

Ms. Marion-Moss: The BRS and I'll send an email to 

the Subcommittee.

Member Beach: Okay. That sounds great. Thanks, 

Lori. And Loretta, you okay with closing 2, as well?

Member Valerio: Yes. I'm fine with that. Yes. 

Perfect. Thank you.

Member Beach: All righty. Ron, I think we're ready 

for you to move forward.

Mr. Buchanan: Okay. Good. We're on page 2, we're 

on Observation 3 now. That's differences in source 

to image distance SID for various X-ray procedures.

And we found that the reference listed, well, the 

recommendation in Table 3-1 was 72 inches, which 

is 183 centimeters SID for the lateral cervical spine. 

And the ICRP lists 102 centimeters.

And so we was questioning why that was chosen. 

And we see that the status of this observation is 

that the revisions provided two references.

And we looked those up and they both recommend 
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79

the 72 inches, which is 183 centimeters as Revision 

5 and 6 had in it. And so we consider that 

satisfactory and that's resolved and we recommend 

closure.

Member Beach: Okay. I'm agreement with that. 

Paul and Loretta?

Member Valerio: I'm in agreement.

Member Ziemer: Yes. I agree on that.

Member Beach: Okay. Pretty straight forward and 

you can keep going, Ron.

Mr. Buchanan: Okay. Page --

Member Beach: Thanks.

Mr. Buchanan: -- bottom of page 2 and top of page 

3 and we look at the Observation 4.

Observation 4, we needed references and 

derivations to some of the KIRMA values in Table 4-

3. 4-3 is a very assignments table with lots of 

references, lots of footnotes, and a lot of PDF files. 

And these are rather large files, a couple hundred 

pages some of them.

And so --

Member Beach: Ron, can I, did you say Table 4-3 or 

4-1?

Mr. Buchanan: 4-1.

Member Beach: I thought I heard you say three.

Mr. Buchanan: If I said three that's incorrect. I 

might have been --

Member Beach: Okay.
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80

Mr. Buchanan: I might have said it wrong. It's 4-1. 

Okay. So 4-1 --

Member Beach: Okay. Thanks.

Mr. Buchanan: 4-1 has a lot of values in it, lot of 

references, lot of footnotes.

And so we checked some of those and we couldn't 

find really where the origin was and how it was 

derived.

And so what we found in Revision 6, then of OTIB-6, 

they provided additional page numbers and 

references. So we went back and spot checked it 

some of the many values in table 4-1.

And traced them back to the origin and to the cited 

references and found that they were correct. And so 

we feel that this is been documented and the 

observations been resolved and recommend closure 

on Observation 4.

Member Beach: Okay. And I agree with that.

Member Ziemer: Yes. I agree with that and --

Member Valerio: I --

Member Ziemer: -- Ron, let me make an 

observation on your observations here. Top of page 

3, your fourth line, look at milliroentgens. You see 

it?

Member Beach: Oh, yes.

Member Ziemer: Do you know what I'm asking?

Mr. Buchanan: Right, I'm going to get there.

Member Ziemer: You got a new spelling for.
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81

Mr. Buchanan: Yes.

Member Ziemer: Okay.

Mr. Buchanan: Okay, that was in, I copied and 

pasted that out of the original one, right? Yes, 

you're correct.

Member Ziemer: I can't help picking out stuff like 

that. Sorry about that. I don't expect you to revise 

the document, I just want to make sure we're 

talking about the same units.

Mr. Buchanan: Yes. Yes, that might be in BRS that 

way. I have to go back and check.

Member Ziemer: Okay. Thanks.

Mr. Buchanan: Okay. So that brings us to 

Observation 5 on page 3. This was thoracic and 

cervical spine dose assignments after 1970 needed 

clarification.

And what brought this back about was table B-1, 

dose conversion factors for those two views were 

listed up through 1970, but nothing after that.

And OTIB-6 listed dose conversion factors for other 

exposure views after 1970. And so our question 

was, was any taken after 1970?

And we see that the status of that observation is 

that the footnote on table 4-1 of Revision 6 

indicates that the procedures were not used after 

1970.

And so we see that that's clarified and resolved and 

recommend closure on that.

Member Beach: Okay. I agree with that as well.

Member Ziemer: Yes. I agree.
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82

Member Beach: Okay.

Member Valerio: I agree.

Member Beach: Great.

Mr. Buchanan: Okay.

Member Beach: Okay. You're moving right along, 

Ron.

Mr. Buchanan: Okay. Observation 6 was the dose, 

breast dose reference need clarification. And that 

was in Table B-3. The footnotes and on also Table 

B-13, footnote F lists several references for the 

derivation of the dose to the breast.

And is said derived, and then didn't really know how 

it got from there to the next table where it was 

actually used. And we see that in Revision 6 that 

has been removed.

There's no derivation, derived in there and they put 

actual numbers in. And so we agree with that and 

we had no issues with that in the revision.

And think that that should be closed.

Member Beach: Okay. Agreed here.

Member Ziemer: Yes --

Member Valerio: Agreed here.

Member Ziemer: -- sure.

Member Beach: Okay.

Mr. Buchanan: Okay.

Member Beach: Thank you.

Mr. Buchanan: So moves on to page 4, which is 
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Observation 7. Now, this is kind of overlaps with 

Procedure 61. And it doesn't really strictly apply to 

OTIB-6.

But I wanted to put it in there because they are 

somewhat connecting. Okay. Procedure 61 in 2010 

edition of Revision 3 provides some equations and 

stuff in the back in Attachment C-3 and C-4.

Now, NIOSH has those in their workbooks. And so 

they don't have a problem with it, but when SC&A 

reviews cases, especially blind cases, we need some 

information occasionally.

Now, some sites provide all the skin dose 

information. This is concerning skin dose. Provides 

all the information. Fine. Don't need it.

Some of them don't provide any. So we use OTIB-6 

as the default. However, some of them provide a 

little information like inter-skin dose for their 

particular unit and stuff, but it doesn't provide all 

the other information.

Such as exit dose, remote skin dose, entry near but 

outside the primary b and that sort of thing. So we 

need information in table C-3 and C-4, Procedure 

61.

And the reason I bring this up in OTIB-6 review is 

that because Revision 4 of 2017 of Procedure 61 

makes a statement, revisions initiated to ensure 

consistency with OTIB-6, Appendix C on the 

calculation of skin dose deleted.

As duplicate of OTIB-6. And so what we recommend 

is that Procedure 61 retain that information in Table 

C-3 and C-4 of Procedure 61.

And so this really wasn't directly applicable to OTIB6, but we wanted to reiterate that.
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84

And so the status for our review of this OTIB is that 

we've done that and so we wanted to emphasize 

that and we recommend that it would be closed for 

OTIB-6 at this point.

Member Beach: Okay. Thanks, Ron. Any comment 

from NIOSH on that?

Dr. Lobaugh: This is Megan again. I can say, so I 

put together actually a crosswalk of the information 

that was in PROC-61, Attachment C to where it's 

located in OTIB-6.

Specifically, for Table C-3 and C-4, those are 

actually copied directly from NCRP 1989, which I 

don't have the whole name of that NCRP, but that's 

the reference in OTIB-6 is NCRP 1989.

And those are discussed in section 6.4 of OTIB-6, 

Rev. 6 and that's where it provides the reference to 

these values that we're using.

So that's specifically for those tables. I can provide 

that to Lori and the BRS if that's helpful.

Mr. Buchanan: Right.

Member Beach: Yes. I think that would be helpful.

Mr. Buchanan: Right.

Member Beach: Agree, Ron?

Mr. Buchanan: Right. It would be great. It would be 

helpful if that was done in writing in the BRS so that 

I could review it.

Dr. Lobaugh: Great. I'll do that.

Member Beach: Oh, thanks, Megan. Appreciate it. 

Okay.
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85

Mr. Buchanan: Okay.

Member Beach: Agreed to close 

Member Ziemer: Would that eliminate the need for 

carrying this table? How does that impact on your 

recommendation?

Mr. Buchanan: I would have to look at it and see. I 

would have to, you know, I think I couldn't say right 

now. I'd have to look at it and see if that's resolved.

Member Ziemer: Really --

Mr. Buchanan: It's really Procedure 61.

Member Ziemer: It sounds like Megan is suggesting 

that everything needed is actually already there. Did 

I understand that correctly, Megan?

Dr. Lobaugh: Yes. That's correct, Dr. Ziemer. Yeah. 

So everything that was in Attachment C is discussed 

in OTIB-6 in certain sections and the equations and 

everything are copied there.

So this table that I have goes through each thing 

specifically, though. So that you can see, you know, 

where Table C-3 in Proc 61 is discussed in Section 

6.4.

And, again, is just actually a copy from the NCRP 

1989 reference. So that's not -- it's reference values 

that we happen to copy into Procedure 61.

Mr. Buchanan: Okay. Now, this is -- and this would 

be applicable to cases -- sites that just provide 

inter-skin does, but that doesn't tell you what to use 

for the exit-skin dose and all that.

You're saying that this information is available in 

OTIB-6?
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86

Dr. Lobaugh: Yes, this is -- all of the information is 

available in OTIB-6 to recreate those calculations for 

the sites that don't have the specific information in 

there.

As a side note, as I review medical TBDs that are 

coming in, that's something I'm asking and, you 

know, requesting ORAU actually include all that 

information within the TBDs as they're getting 

revised.

Member Ziemer: So --

Dr. Lobaugh: The sites that --

(Simultaneous speaking.)

Member Ziemer: Josie, maybe it would be good if 

Ron took a close look at that and see whether or not 

it's necessary to carry this Attachment C along or 

whether it really is sufficient. As Megan has 

described.

Member Beach: Yeah, because I know Ron 

recommended closing the observation. However, 

SC&A performed a focused review of OTIB-6.

Do we need to do a fuller review based on this 

observation, or would Megan's memo capture it and 

we wouldn't need to do more review on this?

Mr. Buchanan: Well, the changes in Revision 6 were 

not -- well, that was Revision 5 that that comment 

was made on. And so and Revision 6 just addressed 

minor issues. I don't think we need to do a full 

comparison of 5 to 6, just the issues we've 

addressed so far.

Member Beach: Okay. So --

Mr. Buchanan: I just --
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87

(Simultaneous speaking.)

Member Beach: So, Paul, I agree. If we just carry 

this as open and then let Megan add and then Ron 

can review it, and then we can simply go back and 

close it out making sure that it's clear. Does that 

make sense?

Member Ziemer: Sure. I think let Ron have a 

chance to review that again and taking into 

consideration any information Megan's provided 

here.

Mr. Buchanan: Okay. That works.

Member Beach: Okay. That makes sense. Loretta, 

you okay with that?

Member Valerio: Yes. So this will actually be held in 

abeyance? Or just open?

Member Ziemer: I think it's still open till 

something's agreed to, right?

Member Beach: Yeah. That's correct.

Member Ziemer: Abeyance implies that we've 

resolved it but just hasn't -- well, I'm not sure. I 

forget.

Member Beach: I think you're right. I think we can 

just leave it open until -- and carry it over to our 

next meeting.

Member Valerio: Okay.

Mr. Allen: Just so you all are clear, nothing is --

we're not changing anything in OTIB-6 --

Member Beach: Correct.

Mr. Allen: -- this is just Megan showing the 
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change.

88

crosswalk of all of the information from Attachment 

C is already in OTIB-6.

Member Ziemer: Right. Right.

Member Beach: Correct.

Mr. Allen: Yeah.

Member Beach: Yes. Agree with that.

Ms. Marion-Moss: This is Lori. Wouldn't that status 

change to in-progress instead of open, remaining 

open?

Member Beach: Sure. Sure, that would be okay too. 

Yes.

Member Ziemer: Yeah. That probably is more 

correct.

Member Beach: You're right. Okay, so --

Member Ziemer: So the ball -- the ball is in SC&A's 

court then, Ron?

Member Beach: No, it's actually in Megan's and then 

SC&A's. NIOSH first to add that comment and then 

SC&A to review. Correct?

Ms. Marion-Moss: This is Lori. Again, we'll update 

the BRS and send an email to the Subcommittee 

and SC&A.

Member Beach: Perfect. Thank you. Okay. Do we 

want to go through the documentation issues or?

Mr. Buchanan: They're very simple. I can go 

through those pretty fast.

Member Beach: All right.

Mr. Buchanan: Yeah. If you don't mind.
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89

Member Beach: I don't at all.

Mr. Buchanan: Yeah. Evaluation of the -- this is on 

page 5 of the memo. Evaluation of the resolution of 

documentation issue. Okay.

As I say, this is a very long complicated document. 

Lots of tables, lots of references. And so what we 

went through, I went through and pointed out 

anything that stood out that needed correcting that 

didn't really affect dose.

But, you know, needed corrected or addressed or 

commented on in Revision 5. And so I have found 

that in Revision 6 they addressed all those. All those 

were corrected except for a few.

And so Table 5, 6, 7, and 8 list those, and I don't 

think we need to go, as far as I'm concerned, go 

through each one in detail other than to say they 

was all addressed and corrected in Revision 6 

except for a couple.

And so we see that on page 9 there I list the 

documentation issues that remained open. And 

really there was only one out of all of those that 

remained open. And that was on page 3 where they 

list the table of reference, which is called, I think, 

the publication record.

It seems that the table numbers from, well, actually 

from Revision 4 were copied into 5, and then that 

was copied into 6. And it would appear that those 

numbers should change as they revise them.

If they add a table or take away one, well then that 

makes the table numbers different. And so that was 

one documentation error that I still felt was open. I 

don't know if NIOSH wants to comment on that at 

this time?
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90

Dr. Lobaugh: This is Megan. I don't have anything 

specific except that the revision summary, I think, 

typically uses the previous revision table numbers.

So that's why they would seem outdated. I don't 

know that we would normally update those, so 

that's where I'm not sure what to say what we will 

do.

Maybe Lori can speak to whether the revision 

summary typically gets updated to table numbers if 

they should get moved around.

Ms. Marion-Moss: This is Lori. It varies depending 

on what's going on with the revision, but we'll look 

into that.

Mr. Buchanan: Okay. Because Revision 6 really 

should have referred to Revision 5's table numbers 

not Revision 4 table numbers.

And so it's kind of confusing to read through and 

see what was changed and wasn't changed. So 

okay. So you'll -- page 3 you'll address that?

Ms. Marion-Moss: Yeah, is that an observation in 

the BRS?

Mr. Buchanan: No, that wasn't under an observation 

--

Ms. Marion-Moss: Oh.

Mr. Buchanan: -- that was under documentation 

issues. Because I wasn't sure what your policy was, 

but I wanted to point out that the tables seem to be 

carried on without updating.

And so I felt that it really should be updated for the 

reader to understand what you're referring to, but I 

wanted to point that out and see if that was correct 
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91

or incorrect.

Ms. Marion-Moss: You're right, Ron, it should be 

updated --

Mr. Buchanan: Okay.

Ms. Marion-Moss: -- accordingly. I don't know how 

the Subcommittee would like us to respond to this 

or the list --

Member Beach: Since it's not an official finding or 

an observation just -- I don't know how you -- how 

you would let us know if it got updated at some 

point?

Ms. Marion-Moss: Okay.

Member Beach: I don't think it requires an official 

response. Anybody else?

Member Ziemer: How are you going to keep a 

record of what occurs?

Ms. Marion-Moss: I don't --

Member Beach: Is that something that should be 

added? Well, I don't know. Because it's not really a 

finding. How do we keep record of that?

Mr. Buchanan: It won't be changed until we do a 

Revision 7. If and when they do a Revision 7, you 

know, it can't.

Member Beach: Right. And, NIOSH, don't you -- or, 

Lori, don't you guys usually keep track of that stuff 

for when you get into the revisions?

Ms. Marion-Moss: Yes, we do.

Member Beach: Okay. So that's kind of an action for 

you then, correct?
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92

Ms. Marion-Moss: Yes. Yes, it is.

Member Beach: Okay. And I'm not sure how to --

Ms. Marion-Moss: I'll let you --

Member Beach: -- to keep track of it, so.

Ms. Marion-Moss: I'll let the Subcommittee know 

the next time we revise it.

Member Beach: Okay.

Mr. Buchanan: Okay.

Member Beach: Is that a note that can be made in 

the BRS, Kathy, when you update these other 

findings as to their status just to -- or that's 

probably not the appropriate place.

Ms. Behling: Yeah. Whatever --

Member Beach: Okay.

Ms. Behling: -- I can update. Yes, I'm not sure, but 

I can -- trying to think, we can add something to 

the BRS. I'm sure Lori and I can work together and 

come up with something.

Member Beach: Perfect. Okay.

Ms. Marion-Moss: Sounds good to me.

DCAS-RPT-0005 (Alternative Dissolution Models for 

Insoluble Pu-238)

Member Beach: Thanks, you guys. Appreciate it. All 

right. Are we ready to move on to the DCAS-RPT0005? And not expecting anything from NIOSH 

unless you guys had a chance to look at this, but we 

know these were late add-ons. 5 and then 29. So.

Ms. Behling: Okay. Yeah, this is Kathy. And I 
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93

apologize for not displaying on Skype. Some reason 

I lost -- had a connection interruption.

So trying to get back on there. But we can discuss 

this DCAS Report 5. Actually, this was a carry-over. 

During the Subcommittee meeting two years ago, 

we were asked to follow-up with a memo.

And we did, SC&A, Joyce Lipsztein did submit a 

memo on February 26th, 2019. And in there we 

discussed there was one observation for Report 5 

where we were questioning the justification for 

using Mound case number 13 for the dissolution 

parameters as a default for all Mound workers.

And NIOSH did revise Report 5 and SC&A reviewed 

that, and based on that revision we concluded that 

there was appropriate or adequate justification for 

using that case 13.

And so we agree that this issue was resolved, and 

we recommend that this observation be closed.

Member Beach: Okay. Comments from anyone?

Member Ziemer: I'm kind of in the dark here. This is 

Paul. I'm kind of in the dark as to what was the 

problem with that case and how, you know, they 

said they shouldn't use it and it says here that it 

was okay, but what was the issue on it?

Mr. Allen: This is Dave Allen. I can briefly describe 

the provision report lists and graphs several 

different Mound cases and then picked Mound 13 as 

representative with no basis described as to why 

that was representative.

So essentially a few -- about a paragraph was 

added to describe why one particular case might 

have had two different intakes and another one had 

a different incident.
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94

That sort of thing as to eliminate a couple and 

describe why Mound 13 was the most 

representative. And SC&A apparently reviewed that 

and agreed that that was a sufficient explanation.

Member Ziemer: Okay. Yeah. Okay, I got you. Just 

wasn't sure what the -- sort of what the original 

problem was and let alone the resolution.

So you had several cases, some of which were more 

atypical, and you're saying that the one they used is 

a more typical one? Am I understanding that 

correctly?

Mr. Allen: Yes.

Member Ziemer: Thank you.

Member Beach: And on the BRS there is a 

document that's attached to that finding that Dave 

attached, I think back in 2017.

Any other comments or questions on this one? Are 

we in agreement to close?

Member Valerio: Josie, this is Loretta. I'm in 

agreement to close, and I appreciate the 

explanation because I was a little lost on that as 

well. So thank you for that, and I agree to close.

Member Beach: Okay. Paul, you okay with that as 

well?

Paul, we didn't hear your answer if you did answer. 

Sorry.

Rashaun, I think we might have lost him again.

Member Ziemer: No, I can hear you.

Member Beach: Okay.
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95

Member Ziemer: Can you hear me?

Member Beach: Yes, we can hear you now.

Dr. Roberts: Yes. Now, we can.

Member Ziemer: Okay. I can hear. Yeah, I was --

I'm satisfied with that. I'm good. Thanks. Appreciate 

the explanation.

Member Beach: Okay. So thank you. And, Kathy, 

you'll go in to the RPT-005 and just that first finding 

that's in abeyance, change that status to closed I'm 

assuming with the write-up?

Ms. Behling: Yes. And that's Observation 1.

Member Beach: Yes. Oh, it's listed in the BRS as 

Finding 1. It's not listed as an observation.

Ms. Behling: Okay.

Member Beach: And that's in RPT-005 --

Ms. Behling: Five, yeah.

Member Beach: -- maybe I'm --

Ms. Behling: I'll go in and check. I had it listed on 

our table here as an observation. I don't know if it 

got changed to an observation or if that's just an 

error on my part.

Member Beach: Yeah. Neither one of those are 

actually listed as findings or observations. So there 

was 1 and 2 was closed. So yeah. Anyway, if you 

wouldn't mind checking that as you go through this.

Ms. Behling: Okay. I will do that.

Member Beach: Thanks. Thank you.

Ms. Behling: Yes.
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96

Mr. Allen: This is Dave Allen. In the BRS it looks like 

Kathy made an entry July 16th of 2018 that said it 

was changed to an observation.

Member Beach: Okay. Okay. Thank you. Yes, it's 

normally right on that -- oh, you're right. She sure 

did. So it's normally up at the top, but it wasn't in 

that case.

So thanks for that, Ron. I mean Dave. I'm going to 

get my names straight sometime today.

Okay. Are we ready to move on to OTIB-29?

(Simultaneous speaking.)

ORAUT-OTIB-0029 (Internal Dosimetry Coworker 

Data for Y-12)

Member Beach: I don't know if everybody got the 

memo. This was a February 26th, 2019 memo that 

was sent out from SC&A on both of these items.

So it's -- yeah. Okay. So that was sent around?

Ms. Behling: I included it. Did I include it in this 

document?

Member Beach: It wasn't in the stuff that Rashaun 

provided.

Ms. Behling: Okay.

Member Beach: I did not --

Ms. Behling: No.

Member Beach: I do not --

Ms. Behling: No, I did not -- I did not forward this 

around. I think I sent it to you, Josie, and to Lori.

Member Beach: Yeah.
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97

Ms. Behling: Okay.

Member Beach: I don't think the next one we're 

going to solve here because I think there's going to 

be an action for NIOSH. But I think we can go 

ahead and review it and then go from there, Kathy.

Ms. Behling: Okay. All right. We're talking about 

OTIB-29, and this is the Internal Dosimetry 

Coworker Data for Y-12. And the outstanding 

finding is Finding No. 4.

This was put in progress back in 2009, and it goes 

back to this issue of the Monday morning sampling 

and questioning if NIOSH is taking into account that 

there was a minimum of 48-hours absence from the 

work area.

And in 2012 at one of the meetings -- no, in 2012 

OTIB-29 was cancelled, and the technical 

information was incorporated into the Y-12 TBD Rev 

3.

SC&A was tasked to look at that, and we reviewed 

the Y-12 TBD, and we did not feel that this issue 

was adequately addressed.

Thereafter, in 2018 NIOSH said that they would 

prepare a White Paper on the issue, and at our last 

meeting in 2019, NIOSH said they -- they said what 

else are we supposed to say about this?

And they wanted SC&A to reiterate our question 

about this Monday morning sampling, and so we did 

that in this February 26th, 2019 memo.

And I'll just briefly summarize. What we're saying is 

that it was determined that NIOSH did not consider 

that routine urine samples were collected after a 

minimum of 48 hours of absence from the 

workplace.
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98

In addition, NIOSH didn't show that for all time 

periods, 40 percent or more of the samples were 

not collected on Mondays.

And Joyce went on to specifically identify some 

paragraphs in the OTIB Rev. 3 on Section 5.3.1.2, 

page 23, the first paragraph states the primary 

urine collection method was a spot sample 

submitted Monday morning before entering the 

work area.

And the last paragraph of that same section says 

since 1989 routine samples have been collected 

over a 24-hour period, typically while the employee 

was on a scheduled break from the workplace.

Then in the Attachment B of the Internal Dosimetry 

Coworker Data for Y-12, that does not take into 

account Monday morning sampling schedule.

And as a result, this -- for type F compounds this 

would underestimate the intakes by about an order 

of four lower and two lower for solubility types M 

and F.

So what SC&A is asking NIOSH to do is to, number 

one, demonstrate the impact of the 48-hour 

absence from the work area in the intake 

calculations and, number two, show that 40 percent 

of the samples were not collected on Monday 

mornings.

So, as I said, this memo was submitted back in 

2019, but we resurrected it for this meeting, and I 

don't know that NIOSH had an opportunity to 

follow-up.

And I don't know if we're still going to request a 

White Paper or just what the Subcommittee would 

request from NIOSH.
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99

Mr. Allen: This is Dave Allen --

Member Beach: I think --

Mr. Allen: I'm sorry.

Member Beach: No. Go ahead. I was just going to 

ask you if you had a comment. So thank you.

Mr. Allen: Okay. Yeah. This is Dave Allen. I was 

going to respond to that. That this one is in -- on 

my court, on my desk, and I know that, and I think 

it does require a White Paper or memo or some type 

of written response like that.

My efforts to do that got overcome by other events 

over the last couple years here. But Liz Brackett will 

definitely not let me forget. She pings me from time 

to time on this one.

So I don't have a whole lot more to say. I don't 

have a whole lot more to say other than I -- it is an 

action item for NIOSH. It's in our court, and we 

know it.

Member Beach: Okay. So I'm going to just put this 

as a carryover to our next meeting, and hopefully 

some of this stuff we can just take -- clear off the 

deck for the next meeting, some of these items, 

based on your schedule, of course.

So is there any questions or comments from 

Subcommittee members? Clarifications needed?

Member Valerio: None here, Josie.

Member Ziemer: I think we got to carry it forward, I 

think.

Member Beach: Yes. I agree. Okay. Everybody 

doing okay? Need a break or are we ready to go on 

SC&A's presentation on Peek Street Facility?
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100

Ms. Behling: Josie, I apologize, but I am having a 

connection issue here, and so I am not able to 

display. If you want to continue on, Rose, could you 

display on Skype for me, or should we take a break?

Ms. Gogliotti: Yeah. I absolutely can do it. Can you 

just email me what you want me to put up?

Ms. Behling: Okay. Yes.

Ms. Gogliotti: Thanks.

Ms. Behling: No, I can't, because I don't have an 

internet connection. Everything naturally, would 

happen -- everything is down. It was -- I guess you 

were not included in the -- Bob, can you forward 

that to her? Bob Barton?

Member Beach: It's all in Rashaun's meeting prep 

stuff that -- can Rashaun send that to Rose or?

Ms. Behling: Yes.

Member Beach: Or I can.

Dr. Roberts: Yeah --

Ms. Behling: Yeah.

Dr. Roberts: -- let me try to find it.

Ms. Behling: Thank you so much. I apologize. I 

don't know what's going on here.

Member Beach: Oh, not your fault. I actually have it 

up. So, Rose, I'll just send you what Rashaun sent 

out.

Ms. Gogliotti: Okay. Great. Thank you.

Ms. Behling: Thank you, Rose.

Member Beach: Okay. You should get that 
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101

momentarily.

So while we're waiting for Rose to be able to put 

that up, Rashaun, I have a question for you. Kathy 

sent us a Table 2, guidance for stuff that the 

Subcommittee should consider for review.

Okay. Are we limited on what we can task SC&A on 

this list? I don't know if you've had a chance to look 

at the list.

Dr. Roberts: No. I haven't gone over the list in any 

depth, but after this meeting, you know, I'll take a 

look at what's been tasked within the meeting and 

that table and get with you offline.

Member Beach: Okay. And maybe, Kathy, if you can 

maybe let us know what some of the priorities 

might be or what -- because I obviously marked all 

of them to be tasked.

So that's how I roll. So we'll have to --

Ms. Behling: Like you said.

Member Beach: Maybe between all of us we can get 

that in.

Ms. Behling: Okay. The other -- what I was going to 

suggest is there are six subtasks for review. We've 

already reviewed the PER, and now we need to look 

at one or two cases.

And I -- then we could close those PERs out --

Member Beach: Okay.

Ms. Behling: -- and so we -- I could provide, excuse 

me, I could provide you with the selection criteria 

for those six if you're willing to proceed with the 

subtasks for those.
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102

Member Beach: Okay. Yeah, and we'll talk about it 

after this, but I think that sounds like a fair thing to 

move forward on. So after this -- when we get to 

that.

Okay. Thanks, Kathy, for that. I appreciate it.

Ms. Behling: Sure.

Member Beach: Rose, can you make that any --

well, never mind, maybe I can do it here. Ah, okay.

So it looks like, Rose, thank you so much for 

jumping in.

Ms. Gogliotti: No problem.

Member Beach: And I guess Doug is going to 

present. Is that correct?

Mr. Farver: That's correct. I'm ready whenever you 

are.

Member Beach: Are you ready? Okay. Go ahead.

Mr. Farver: Okay. So I'm going to talk about our 

report for the Dose Reconstruction Template Review 

for the Peek Street Facility in New York. Next page.

We did a review of the Peek Street Facility dose 

reconstruction template and methodology. There 

are no Technical Basis Documents developed by 

NIOSH for the Peek Street Facility.

Instead they developed a dose reconstruction 

methodology document, and then they have a 

template. and those two documents contain the 

facility-specific information, assumptions, and 

references for their calculations.

Now, I'll mention now that there is a third 

document. It's not a NIOSH document, but it's an 
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103

excerpt from the KAPL Radiological History Report.

And so between those three documents you can get 

a pretty good handle on what their protocols were 

at Peek Street.

In December of 2018, SC&A was tasked to review 

the template. At the end of January 2019, we 

submitted our review, and this was for the template 

3.0 version.

And then in December of 2020, there was a revised 

template issued. This is the 4.0 version. And as near 

as I can tell it was really just an update of the 

references at the end of the document, updated to 

current references.

The actual technical content was not updated, and it 

does not affect our findings or observations from 

our report. Next.

So it's located in New York. It was the temporary 

location for Knolls Atomic Power Laboratory until the 

actual facilities were constructed in Niskayuna, New 

York.

Two purposes was to design an intermediate 

breeder reactor concept, which was later converted 

to the design of the submarine reactors for the 

Navy.

And number two, to design a chemical process for 

the recovery of uranium and plutonium from 

irradiated fuel. And it operated from 1947 to 1954. 

Next.

First finding, the assumption of 100 percent 30 to 

250 keV photon energy distribution is -- it's really 

not supported by anything, any reference in either 

the template or in the DR -- or the methodology 

document.
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104

The template states that there was -- and also the 

methodology states that there was more than one 

photon energy distribution, and it also talks about 

the Hanford -- they used the Hanford two-element 

film dosimeter.

So I looked at the Hanford document just to see if 

they had energy, what kind of energy distribution 

they used. They used kind of a broken-up 

distribution.

And in both the technical, the template and the DR 

Guide, or the methodology, they state that because 

there was more than one photon energy distribution 

associated with the radiation source, and that they 

couldn't determine a source term for the individual 

employee, they used the claimant-favorable 30 to 

250 keV.

Now, the only statement I could find was in IG-001, 

it's towards the bottom of page 12, and it talks 

about using the 30 to 250 keV group for unknown 

fields.

And what it -- it specifically refers to the twoelement film dosimeter, and it says if individual 

energy distribution information is not available for 

two-element film dosimeters, the open-window dose 

should be used as a claimant-favorable estimate of 

30 to 250 keV.

So if you take the open-window dose and apply it as 

30 to 250 keV that would be claimant-favorable. It 

is not clear if that was the process incorporated into 

this template because they don't discuss using the 

open-window dose and applying it as 30 to 250 keV 

photon dose.

So anyway, that's the basis for the first finding. 

Next.
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105

Second finding. A dosimeter uncertainty factor of 

1.3 for penetrating photon dose is also not reported 

and is not consistent with the Hanford TBD.

So the PSF guidelines states if there's no specific 

information on dosimeter limits of detection or 

uncertainty or bias and therefore they should follow 

the Hanford site information.

The Hanford TBD specifies a systematic uncertainty 

of two-element film dosimeter as 1.2. So unsure 

where the 1.3 came from.

And of course, there's much more detail in the 

report. This is just the highlights. Next.

Finding 3. SC&A unable to verify the neutron-tophoton ratio of 1.2 using the references.

So the template states that the neutron-to-photon 

ratio was determined from looking at similar 

facilities with similar neutron producing activities.

I believe they looked at the TBDs for eight different 

sites, and four of those sites had actual NP ratios. 

And that was Hanford, Savannah River, Oak Ridge, 

and Los Alamos.

Those are all tabulated in the report. And when I 

calculated the average it came up to 1.29. So 

unable to tell where they got the 1.2 from. Next, 

please.

Finding 4. The template does not specify a 

dosimeter LOD. Neither the template nor the 

methodology state what the LOD was used in their 

calculations when they're calculating the missed 

dose.

Based on the calculations that are in the template, 

where they determine the maximum number of zero 
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106

dosimeter cycles and then they calculated those, if 

you divide that dose by the dosimeter cycles that 

they determined, it comes out to be about 24 

millirem, which would be the LOD over two.

To which means it looks like they're using an LOD of 

50 millirem. The Hanford TBD information shows a 

LOD of 40 millirem. So once again, it really -- you 

just can't really tell where they got their values 

from. Next, please.

Finding 5. Unable to verify the annual maximum 

ambient dose of 423 millirem using the references.

So the template states that the ambient dose is 

based on radiation levels at sites with similar 

activities and cites PROC-60.

So we took a look at the tables in the back of PROC60 for Hanford, ORNL, and Idaho. Calculated an 

average of 342 millirem from the three sites. And if 

you just use the two sites, it's 433 millirem.

So once again, I just can't really tell how they came 

up with their values. And it's not contained in the 

template, it's not contained in the methodology 

document. Next, please.

Finding 6. The template's occupational medical dose 

basis is incorrect. So it looks like they used the -- it 

says that the doses are based on Table 6-5 of OTIB6 Rev. 4, except Table 6-5 is not contained in Rev. 

4, it's contained in Rev. 3.

And apparently now there's even more newest one 

up to Rev-06, which also does not have Table 6-5. 

So that's incorrect.

It also states that the X-ray doses incorporate a 1.2 

-- a 1.3 uncertainty factor multiplied by the dose, 

which was contained in PROC-61 Rev. 3, but is not 
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107

consistent with the current guidance in PROC-61 

Rev. 4.

So all that would need to be changed and updated. 

Next, please.

Finding 7. Fission product information is not current. 

They used the intakes and they're tabulated in the 

template. The intakes from Rev. 0 PC-1 of OTIB-54. 

That's one of the first revisions to it or the first 

changes to it. And what that does is it takes, like, a 

single value and those values are contained in the 

template.

The current version OTIB-54, Rev. 04, does not 

contain the information that's used in the template 

mainly because the process has changed over the 

years.

They now base it on about nine different reactor 

configurations and it's much more complex. So all 

that information about the Fission product is 

outdated in the template. And this also pertains to 

the current revision 4.0 template. Next, please.

Recycled uranium activity fractions. So it contains --

the template contains the list, a table of the RU 

activity fractions. It doesn't provide a reference or 

any kind of basis for those. They are just stated.

So I took a look at the Hanford TBD, Fernald TBD, I 

couldn't come up with those values. The 

methodology document cites OTIB-54 as the basis. I 

did not find, I mean OTIB-53, I did not find an 

OTIB-53.

I don't believe OTIB-53 was issued. So anyway, I 

was not able to verify where those recycled uranium 

activity fractions came from. Next, I think we're in 

the observations.
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108

Observation 1. There is a note contained, when they 

discussed the photon doses, it's about the less than 

30 keV photon doses and to use the less than 20 

keV plutonium photons that they should use DCF 

from Table 4.1A of IG-001.

And there's a little statement at the bottom that 

says, that these values have been preprogrammed 

into the tool that was created for the Peek Street 

Facility.

I didn't find any tool or workbook for the Peek 

Street Facility. So that's just the basis for that 

observation. Next, Observation 2.

The physically significant level, which is essential 

similar to an MDA, for their natural uranium that 

they state in the template is not consistent with the 

values that are contained in the history report from 

KAPL.

The template states a PSL of 5 microgram per day 

and it cites the reference as the KAPL Rad History 

Report, but when you go to that report, the KAPL 

Report uses 3 microgram per day for natural 

uranium.

So I couldn't verify their value for the natural 

uranium. Now, I believe there are four other PSL's 

that they used like for plutonium and Fission 

products and tritium and so forth.

And all those came straight out of a table that's 

contained in the KAPL report. So those were easy to 

check. But the natural uranium one just didn't 

match up. Next.

And then I believe the last one is the, oh, yes. This 

is the plutonium mixture information in the 

template. The actual mixture information in the 

template is correct.
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109

The reference is incorrect and the current reference 

is now up to Rev. 07. And instead of Table 5-4, 

which I believe is what the template references, it's 

now a new table, it's 5-5.

So all that information would just need to be 

updated. And I believe that's it. If anyone has any 

questions?

Member Beach: Thanks Doug. NIOSH, any 

comments, questions?

Hearing none, how about -- oh, go ahead.

Dr. Taulbee: This is Tim. You know, we will develop 

a response to each of these findings.

Member Beach: Yes. Understand that. I just was 

wondering if there was any clarifications that 

needed, but if not, Subcommittee members, any 

questions for Doug or?

Member Valerio: Josie, I just have a quick question 

on page 13, the second bullet.

Member Beach: Okay.

Member Valerio: It says PLS of 3, is that supposed 

to be PSL? Is that a grammatical error?

Member Beach: Are you talking about the report or 

on the slides?

Member Valerio: It's in the Observation 2 on the 

slides. Sorry.

Mr. Farver: That's a typo.

Member Beach: Gotcha.

Mr. Farver: That's a typo.
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110

Member Valerio: I missed that. Okay. Just doublechecking. Thank you.

Member Beach: Okay. So the Subcommittee will 

wait for NIOSH's response. Kathy, will you put this 

into the BRS?

Ms. Behling: Yes, I will.

Member Beach: Okay. All right. Yes, I noticed that 

Peek Street wasn't in, but now it is but without the 

findings. So perfect.

Nothing else on Peek Street? Thanks, Doug.

Mr. Farver: Thank you.

Member Beach: Yes. Good reporting. So we are 

ready to move on to the Table 2 in the memo that 

Kathy sent, SC&A sent around. And that would be 

addressing new reviews.

And just to recap, we've tasked the first three OTIB49, -24, and -66 already. And the OTKBS-0060, 

those are all four tasked for review.

And then with our previous discussion on the 

subtask 4. There's six of them and Kathy, any other 

comments or from Subcommittee members on 

tasking those six subtask 4 assignments?

Ms. Behling: No. I just would like to go through 

those. I didn't do that until we, you know, until had 

this discussion, but I will provide you with selection 

criteria for those provided you want us to continue 

on with the subtask 4 work.

Member Beach: Okay. So we'll talk about tasking 

those, but once we task them you will send us the 

selection criteria, correct? Or do we need the 

selection --
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111

Ms. Behling: Correct.

Member Beach: -- criteria first?

Ms. Behling: I was just waiting for your permission 

to go ahead with the subtask 4 reporting and then I 

can provide you and NIOSH with the selection 

criteria so that we can pick out a few cases --

Member Beach: Okay.

Ms. Behling: -- to use.

Member Beach: Loretta, Paul, comments on those 

six? And if you don't have it right in front of you --

Member Ziemer: It's on the whole table or just on 

those?

Member Beach: Right now just on the subtasks 4's. 

That would be PER-045, 52, 59, 62, 63, and 65. 

Those are all subtasks 4's. Is that correct, Kathy?

Ms. Behling: That's correct. Yes.

Member Beach: Okay.

Member Ziemer: I'm good on those.

Member Valerio: I'm good on those, Josie. I was 

just taking some notes.

Member Beach: Nope. That's okay. So we are 

tasking SC&A with all six of those. Rashaun, you 

okay with that?

Dr. Roberts: Actually, I was just about to weigh in. 

And there was a suggestion earlier that I think is 

advisable and perhaps the Subcommittee can have 

some dialog via email just to prioritize these tasks 

since there's so many of them being tasked.
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112

I think there needs to be some exchanges in 

thinking about what the priorities are.

Member Beach: Okay.

Member Ziemer: Well, Josie, were you talking about 

all the PERs on the list here?

Member Beach: No. At this point we've already 

tasked those original four that I talked about and 

then these are subtask 4 case reviews. And there's 

six of those.

Dr. Roberts: And there is --

Member Beach: And that would close out those 

PERs once those subtasks are complete.

Dr. Roberts: Correct.

Member Ziemer: Yes. Gotcha.

Member Beach: Okay. So Rashaun, you want to do 

this via email, is that was I'm hearing for the rest of 

these?

Dr. Roberts: Yes.

Member Beach: Kathy, can you kind of just give a 

brief -- I don't know if Rashaun is familiar with 

what's involved in the subtask 4 reviews. Unless I'm 

incorrect, Rashaun. Kathy, if you could just quickly 

give us what's required there.

Ms. Behling: Okay. Specifically, this is the last 

portion of the procedure that SC&A has developed 

for reviewing PERs. We've already gone through the 

process of reviewing all of the technical issues 

associated with the PER. If we hadn't already done 

analysis of, say, Norton Company, we would do that 

in subtasks 2 and 3. 
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113

In subtask 4 we simply say, okay, NIOSH can come 

in and rework so many cases and we give certain 

selection criteria that we think are important for 

that particular PER. They pull cases for us and then 

we look at -- we don't rework them but we review 

those cases and ensure that they were done 

appropriately based on the changes that were 

introduced in the PER. 

It's not always a full review of the dose 

reconstruction. We look primarily at and we focus 

on those changes that were introduced as a result 

of issuing this PER. It's not quite as complex as a 

full review of a dose reconstruction. Does that help?

Dr. Roberts: Yes, thank you. Is there anything else, 

Josie?

Member Beach: Sorry, I was talking on mute. So 

would it be appropriate, and I'm asking Rashaun, if 

Kathy sends out a memo highlighting priorities? We 

have these six and then there's one, two, three --

let's see, three other recommendations for reviews. 

Would that start the dialogue? And, of course, 

copying Lori on the memo or email.

Dr. Roberts: Yeah, that sounds like a plan.

Member Beach: Okay.

Member Ziemer: I have a question.

Dr. Roberts: Sure.

Discussion regarding potential review of newlyissued guidance document and Battelle-TIB-5000

Member Ziemer: A question on Battelle TIB-5000. 

Who has the action on that right now? There's a 

note here that it's never been tasked for review. Is 

that correct?
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114

Member Beach: That is correct and I brought it up, 

oh, I don't know, quite a while ago asking about 

that. I was going to ask NIOSH how much that TIB 

was used. I was going to go to that next. If 

somebody in NIOSH's court knows, is that a 

document we use frequently?

Mr. Allen: This is Dave Allen. I can say we never use 

it directly in a dose reconstruction. There are some 

default factors in there that are used in appendices 

and TBDs.

It gets to be a strange situation if those -- if you 

decide those default factors don't work when you 

decide the TBD was okay. I'm not sure how to deal 

with that. It ends up being a large document that 

not that much has ever really been used out of. 

Does that help you at all, Josie?

Member Beach: Not really. Maybe a little. Maybe it 

just needs a focus review, but I'm not sure. I guess 

I'll have to take that under advisement from 

someone who might know if that's a good resource 

or a use of resources.

Member Ziemer: Let me ask Dave a question. This 

is Paul again. Dave, since it's not used directly but 

some of the items in it or tables are used by other 

documents, does it end up if there's a problem, the 

problem shows up in the review of the other 

documents? Is that a fair statement or does that not 

occur?

Mr. Allen: I don't know if it's ever really been 

decided to be a problem but the numbers have been 

reviewed in other documents. These are things like 

default assumptions in some of these appendices of 

an operator and how close he is to the operation, 

for how long each month -- each day compared to a 

supervisor compared to a clerical. 
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115

Those four categories come from OTIB-5000 -- I'm 

sorry, TIB-5000. Also, the assumption that the 

standard work week is 40 hours after 1956 and 44 

in the early '50s and 48 before that. That comes 

from OTIB-50 -- TIB-5000.

Member Ziemer: I was going to say, if SC&A was 

reviewing a different document that made use of 

those particular assumptions and they had some 

problem with it, they would call it out and it would 

trace back to that, I assume. Right?

Mr. Allen: I would assume so, yeah. They've been 

reviewed and discussed. I don't think they've ever 

been called out as a problem.

Member Beach: I don't recall anything ever being 

called out for that TIB-5000.

Mr. Allen: My assumption is it would be called out if 

there were a problem.

Dr. Taulbee: This is Tim. That is my impression, too, 

that in the review of another TBD that is using TIB5000, if there was an issue or a concern with a 

particular site for using some of those values, that's 

where it would be identified is in that other TBD 

where it is being used. As Dave pointed out, this 

information isn't being used directly from --

actually, I shouldn't say it that way. In dose 

reconstructions, it is, but it's being used through 

other TBDs.

Member Beach: Yeah, that makes --

Member Ziemer: That was my point. Is there any 

point in reviewing it directly? If there's a problem, it 

will show up at some point when it's being used. It 

will show up in some other review.

Mr. Allen: I believe it would show up, yeah.
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116

Member Beach: Yeah, and I don't unless SC&A. Can 

anyone identify if that's ever shown up? I don't 

recall that myself.

Dr. Barton: This is Bob Barton. I might be able to 

help out a little bit here. If we're talking about 

things like, for example, the number of work hours 

during the week, that would be something that we 

have called out in the past for individual sites in 

which we have claimants' statements about 

overtime and things like that. 

I can't comment on everything that's in this TIB that 

has been ported to other documents, but if it's 

generic things like the time spent in a certain task 

or, again, like the length of the work day or the 

work week, number of hours per year, generally 

that would be included but with the caveat that we 

don't expand it to other documents necessarily to 

specifically review other documents to the TBD. 

We might check the value stated comes from TIB-5. 

But, again, if it's a site-specific parameter like the 

number of hours worked extra, it has come up in 

individual TBD reviews.

Mr. Allen: Yeah, this is Dave again. I mean, that 

kind of thing has as far as people working overtime 

but this TIB-5000 is complex by default is what it 

amounts to. If there's site-specific information, then 

you don't use defaults.

It obviously would not deal with overtime unless 

with overtime there was some default for it, which 

maybe you could get for a site but I don't think you 

would get that complex-wide. I'm not sure what 

else I was going to say.

It has come up as far as how close people were and 

everything at other sites, how many hours a week 

they did a particular task. Again, that is site-specific 
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117

information. It's not a complex-wide issue.

Member Ziemer: Yeah, that takes precedence over 

the default values anyway.

Mr. Allen: Right. If it did come up where some of 

these default values were in question, then SC&A 

might not have reviewed TIB-5000 but NIOSH's 

response would have been we got that from TIB5000.

Member Ziemer: Right, right.

Mr. Allen: We would have been the ones to bring it 

up if that was the situation. I don't think as a 

default -- you know, the defaults have never been 

questioned in the individual sites. 

Member Beach: Okay, thanks. Good discussion. 

We'll just leave it on the list and leave it to Kathy 

when she prioritizes this list. In looking at the other 

two that we happened to have signed, OTIB-0088 

looks like a real brief discussion just identifying if all 

the observations, in which there were only two of in 

the original document, were covered. I really didn't 

get to 87 to the Medina if that was a more 

cumbersome review or not.

Member Ziemer: There was no action recommended 

on that one.

Member Beach: No, not right now. I was just simply 

stating that those looked fairly quick. Okay. If 

everybody is happy, we'll just wait for SC&A to send 

out that memo and then we'll work offline with 

Rashaun to complete any tasking. Unless you're 

okay, Rashaun, with tasking the subtask 4s.

Dr. Roberts: Yeah, if we could just talk offline, that 

would be great.
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118

Member Beach: Okay, okay. Then I had one more I 

wrote down, the OTIB-6, Rev. 6. I know we just 

covered 6, and I know that Ron went back and forth 

between 5 and 6 so that one does not need 

reviewing. Is that correct?

Ms. Behling: Ron, are you still on the line? This is 

Kathy.

Mr. Buchanan: Yes. Right, Rev. 6 had some changes 

made but I didn't see that it was a rewrite. I 

focused on whether our issues were answered from 

Rev. 5 so I don't -- I could go back and see if 

there's any new material but that wasn't what I was 

focused on when I did this focused review. 

Ms. Behling: Okay.

Mr. Buchanan: Before I say whether it needs to be 

done, I'd have to do a quick comparison.

Member Beach: And maybe when you're answering 

the '06 earlier -- oh, where am I? So you're still 

going to review the BRS so maybe in conjunction 

with that review of 7 maybe you can just take a 

quick gander and let Kathy know if that needs to be 

a focused review or not, or if it's okay.

Mr. Buchanan: Yeah, okay. I can --

Member Beach: Does that work?

Mr. Buchanan: I can see if it looks like there's a lot 

of changes or if it's pretty much a rewrite with some 

corrections.

Member Beach: Okay. That sounds great.

Mr. Allen: Josie, this is Dave. I hate to interject here 

again.

Member Beach: Go ahead.
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119

Mr. Allen: As far as OTIB-6, Rev. 6, I think you 

ought to know before you sign in to review that one 

that there is a planned revision that will be Rev. 7. 

Member Beach: Okay, that's good information.

Mr. Allen: We're struggling finding time to get to 

that and get it all resolved and everything but there 

is a handful of issues in there we know of that we 

want to get it all fixed in one shot. We knew about 

this during Rev. 6 but we needed to get the ICD-10 

codes in there published so we could continue using 

that when everything switched over to ICD-10.

Member Beach: Okay. Well, then we'll just leave 

that alone.

Mr. Allen: Okay. 

Member Beach: Okay, thanks. Appreciate that. 

Mr. Buchanan: Excuse me, Josie. This is Ron. So 

you're saying, don't do a comparison between 5 and 

6 at this point?

Member Beach: I would say no, unless you see 

something that is based on what you've reviewed 

that needs to be included in their 7 but it sounds 

like they have a good handle on that. Does 

everybody agree to not do that review on 6?

Member Ziemer: Yeah.

Member Beach: Yeah, I think we should wait on 

that. You're still going to take care of that finding 7 

in the BRS but that would be the extent of that at 

this point. Thank you.

Then the last item on our agenda is the preparation 

of reporting out to the full Board. Hopefully 

everybody had a chance to look at that document, 
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120

Table 3, which is quite a long list. Then on Table 4, 

Kathy made a recommendation to the 

Subcommittee on how to maybe present those to 

the full Board.

What I noticed was that most of the findings were --

I guess we have to determine if the matrix that she 

presented would be a good tool to use to be able to 

report out to the full Board. Maybe I'll leave it at 

that. 

Kathy, if you want to say something on this before 

we get into discussion on how to move forward with 

these.

Ms. Behling: Okay. See, when I was putting 

together this Table 3, it just occurred to me that for 

a lot of the work groups they prepare an issues 

resolution matrix which is sort of a final document 

that is a chronology of what happened and what 

were the findings, how were they addressed, and 

what was the final resolution. 

It occurred to me, at least for some of these 

documents that are on this Table 3 list, that are not 

super-complex -- and a lot of these are older 

documents also -- that perhaps this would be an 

approach. The Board Members, I think everyone on 

the Board, is familiar with this resolution matrix. 

It just seemed to me to be a concise approach that 

captures what went on during these meetings and 

the resolution. It was just fleeting so I thought I 

would throw it out there to you to give you 

something to think about. Perhaps there are better 

options. 

In the past what we have done, I know you Josie 

and Wanda, in order to get a final approval for the 

Board, you've actually had to make a full-blown 

presentation whenever there was time at the full 
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121

Board meetings. Then there would be a discussion 

and the Board would agree to close these 

documents. 

I don't know if that is necessary. That's a more 

formal approach to presenting this information to 

the Board as necessary for all of these documents 

so that's why I suggested the matrix.

Member Beach: Yeah, and I really appreciated the 

matrix. Right now we have a total of 41 that are 

ready to be closed out basically just waiting for a 

presentation to the full Board. Most of these are 

under 10 findings.

Some of them -- actually, most of them, two or 

three findings with the exception of two of them 

that have rather large numbers of findings. So do 

others have thoughts on this, if this looks like a 

good way to present?

Member Ziemer: Are you talking about like one 

page per item? Forty-one items for the Board to act 

on is a lot.

Member Beach: No, Paul, what I'm simply stating is 

there are 41 procedures. I would not even say that 

we do all of them at one time. We choose based on, 

like Kathy said, the complexity and maybe create a 

matrix if we agree with this method. 

Maybe we do a pilot to see how it works at the next 

Board meeting in an effort to get the information to 

the Board with the backup documents that go with 

each document and then proceed with a couple to 

start with and see how it goes. I'm just trying to 

close out some of these items that we, the 

Subcommittee, have already closed out.

Member Ziemer: On the matrix, it's sort of like what 

we had today except she's talking about dates and 
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122

so on. For example, let me go to the front end of 

things. On OTIB-1, would that be a slide that 

indicates what the document was, what the findings 

were, and that we've closed them or recommended 

closure? How much detail?

Member Beach: Paul, do you have the memo that 

Kathy sent out that shows the tables? Table 4 has 

an example of OTIB-34 and then the findings 1 and 

2, and how she would lay it out.

Member Ziemer: Yeah, Table 4. I have that. For 

example --

Member Beach: Yeah.

Member Ziemer: That works for one issue. I mean, 

not one issue, one document. Right?

Member Beach: Yeah.

Member Ziemer: Right. So even if -- so out of the 

41 documents, if we had like ten crucial ones, that 

would be plenty for the Board to absorb, I would 

think.

Member Beach: I wasn't even -- I wasn't even 

thinking ten but if you're looking at some of these 

older documents, yeah, you could essentially do ten 

if the findings are few. Or maybe even start off with 

five or one or whatever, you know, to see how the 

Board -- if they find it helpful. If we did go to the 

OTIB-34 as Kathy has given us an example --

Kathy, were you thinking of background documents 

as well made available in case Board Members have 

questions or would that come later? What were you 

thinking there?

Ms. Behling: At this point I wasn't thinking about 

attaching other documents but that could be done. 

This example that I gave you, this was one that had 
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123

already been prepared for OTIB-34. It's not even on 

our list. To expedite putting this together, I just 

selected one that we had already looked at. 

I was going to suggest the same thing that you just 

did, Josie. If you all think that this is an option is 

maybe providing to you just a few examples, one or 

two examples, and you can look it over to feel if it's 

adequate, and then forward that to the full Board 

and have a discussion with them on one or two to 

see if this is something that they feel is appropriate 

and is enough information for them to close out 

these documents. 

And I would do it, as I said, with those that are not 

as complex where they are older documents that 

are maybe not used as much. For those more 

complex ones, I would suggest that you still give a 

presentation to the full Board when we feel that's 

appropriate and necessary.

Member Beach: Okay, yeah. It would be a way to 

pare down this list a little bit on the less complex 

ones.

Loretta, what do you think?

Member Valerio: I like using the matrix. I think that 

it's helpful for all Board members to know where we 

are with each review that we're doing. I do worry, 

with as many as we have moving forward, how 

everything is going to be documented, I guess.

Member Ziemer: Let me insert one other question 

at this point. On Table 3 we have some pretty old 

documents listed. They go back to -- I'm looking 

here, 2006.

Member Beach: Yeah, exactly.

Member Ziemer: Now, how important is -- is there 
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124

some way we could take a look and -- we have a 

backlog we ought to clear out it seems to me. It's 

almost like old cases. We don't want to carry these 

along for decades. Is there a way to clear out some 

of the old stuff pretty fast?

Preparation for April 2021 Full ABRWH Meeting

Member Beach: Yeah, that's kind of what I was 

suggesting also moving forward, or going to 

suggest. Start with some of the older ones, the less 

complicated ones, and then maybe have time at the 

April Board meeting, if Kathy feels like she can be 

ready with a couple of these, to move forward and 

then just get a sense of how the full Board feels 

about us moving forward in this way.

Member Ziemer: Some of these older ones just 

have one or two findings anyway. It seems to me 

you might be able to go through a number of those 

fairly quickly and get them off the platter.

Member Beach: Yeah, I agree.

Ms. Behling: Yes, I will make sure that I can put a 

few of these together for you prior to the April 

meeting.

Member Beach: Rashaun, what do you think?

Dr. Roberts: Yeah, I like the idea of piloting this 

approach. I was going to ask, though, about how 

much time would you want on the agenda to do 

this? As I'm understanding it, start with older 

documents that are not as complicated. I don't 

know how many. It sounds like one or two, but it 

could be more depending on the level of complexity. 

How much time on the agenda would you want to 

do this?

Member Beach: I think we should start with just a 
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125

couple of the real old ones. While I'm looking 

through, I see 2007, 2009, 2008. Kathy, maybe you 

can give us a better sense, but I don't want to 

overwhelm the Board in this new process either, so 

maybe just start off with a couple and see how it's 

received?

Ms. Behling: That's what I would suggest, yes.

Member Beach: And how much -- I think that would 

-- the timing would depend on the -- I don't think 

they're very complex so probably no more than an 

hour. Don't you agree?

Ms. Behling: I would say probably 15 minutes per 

document. Like I said, we're going to collect ones 

that are not complex just to determine a feel for 

this and whether the Board agrees with it. I would 

say maybe 15, 20 minutes per document, if that.

Member Beach: Okay. And then maybe have some 

background stuff embedded in it in case somebody 

wants to click on the link and look at more or --

Ms. Behling: Okay.

Member Beach: I know there's a lot to each one of 

these so I'll have to -- you'll have to use your 

judgment on, maybe, that.

Ms. Behling: Okay. Good idea.

Member Beach: Okay. So is that something you can 

kind of get put together for the April meeting then?

Ms. Behling: Yes, it is. Yes, I will certainly do that.

Member Beach: Okay. That sounds great. 

So Rashaun, are you okay -- I don't know how 

much time can we use up? Do you have a sense of -

- can we have an hour?
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126

Dr. Roberts: I think you're on there now for at least 

an hour but, again, that was just a guesstimate. We 

can certainly adjust the time.

Member Beach: Okay, that's perfect.

Member Valerio: So, Josie, this is Loretta. Does that 

hour include if Board Members have discussion?

Member Beach: Yes.

Member Valerio: Or just the presentation?

Member Beach: That would have to include the 

presentation and discussion, I would assume, 

depending on how tight the schedule is.

Dr. Roberts: Okay. So I currently have you on for 

about an hour and 15 minutes.

Member Beach: Oh, that's fine. I think that's 

workable. Don't you think, Kathy?

Ms. Behling: Yes, I do. The other thing, in the past I 

have prepared a presentation for Wanda where we 

had four presentations ready to go and if they got 

into discussions on one OTIB and we didn't get to 

that last presentation, it was just carried over to the 

next meeting. Just as long as we have enough to fill 

in that time frame, I would think.

Member Beach: I think, Kathy, if you would 

prepare a presentation on using this matrix that we 

just talked about and then going through however 

many we determine is going to be about the 

appropriate amount of time then go through those 

during that hour and 15 minutes. Would that work?

Ms. Behling: Okay, yes. We'll talk about the 

approach that we would like to present to the Board 

to determine if they feel that this is adequate for 
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Subcommittee, has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and 

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127

resolving some of these documents that are on the 

list. There's going to be more coming. This list is 

going to grow.

Member Beach: Yeah, so we really do need to start 

moving forward on the list. I don't think we've 

presented since December of '18? That was our last 

--

Ms. Behling: Yes, I think you're right.

Member Beach: Okay.

Member Ziemer: One other point to keep in mind is 

that the things that we will be presenting to the 

Board, there's already agreement between NIOSH, 

SC&A, and the Work Group, or the Subcommittee 

basically on what we'll be presenting so I don't think 

we're going to get into lengthy discussions on these 

like we would on some of the issues like we have 

had on Savannah River, for example, where there's 

a lot of uncertainty about what direction to go. 

I think the Board will be fairly comfortable with 

most of these anyway. We should be able to get 

through them in a fairly timely fashion, I would 

think.

Member Beach: I agree, especially if the 

presentation ahead of starting to go through the 

matrix that we've decided on, if the presentation is 

clear, I think that will be real helpful also.

Member Ziemer: Right.

Member Beach: Kathy, you're going to be busy the 

next couple months.

Ms. Behling: That's okay.

Member Beach: Okay. So any other comments or 
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128

questions? I know -- I don't think I need to go over 

what's going to be ready for the next meeting or 

carry-overs. Does everybody have their notes or do 

we need to recap?

Member Ziemer: I don't think we need to recap.

Member Beach: Okay.

Member Ziemer: Everybody's got their action items 

delineated, right?

Next Subcommittee Meeting/Plans

Member Beach: They should. Okay, thank you. Let's 

see. Future meetings. It's probably way too early to 

try to plan a future meeting. I'm hoping we don't 

have to go two years before we have another 

meeting, though.

Dr. Roberts: Yeah. So, Josie, it seems like we kind 

of need to determine, you know, what's happening 

with the tasking and when it would be appropriate 

to come back together, is my sense of this.

Member Beach: Yeah.

Dr. Roberts: So maybe that's something we can 

work out.

Member Beach: Yeah. So as far as getting ready for 

the April meeting, we can do that over email, 

correct?

Dr. Roberts: Yes, absolutely.

Member Beach: And the rest of the tasking. Okay, 

so we won't wait too long on the future tasking. We 

just need your approval, correct, for any future 

tasking or does the Subcommittee have to vote on 

that? I would say no.
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Subcommittee, has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and 

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129

Dr. Roberts: Yeah, I think we can just kind of work 

it out by email.

Member Beach: Okay. So any other comments, 

questions, or are we ready to adjourn?

Member Ziemer: Sounds like we're ready to 

adjourn.

Member Beach: Okay. Thank you. Thank you, 

Loretta, Paul, everybody. Good meeting.

Member Ziemer: Thank you, Josie.

Member Valerio: Thank you.

Member Beach: All right. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 2:32 p.m.)