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1

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U.S. DEPA`RTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

+ + + + +

CARBORUNDUM WORK GROUP

+ + + + +

THURSDAY

NOVEMBER 17, 2016

+ + + + +

The Work Group convened via 

teleconference at 11:00 a.m. Eastern Time, 

Genevieve S. Roessler, Chair, presiding.

PRESENT:

GENEVIEVE S. ROESSLER, Chair

BRADLEY P. CLAWSON, Member

R. WILLIAM FIELD, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

BOB BARTON, SC&A

BOB ANIGSTEIN, SC&A

JENNY LIN, HHS

JIM NETON, DCAS

MUTTY SHARFI, ORAU Team

JOHN STIVER, SC&A

TOM TOMES, DCAS
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Contents

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

Surrogate Date Use DCAS Evaluation and SC&A Review.............................7

Petitioner Comments......................................................................................39

Next Steps and/or Recommendations to the Board........................................43

Adjourn...........................................................................................................50
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P-R-O-C-E-E-D-I-N-G-S

(11:00 a.m.)

Welcome and Roll Call

MR. KATZ: This is the Advisory Board 

on Radiation and Worker Health, and this is the 

Carborundum Work Group. 

The Work Group's meeting -- it should 

be a very brief meeting today, because there's only 

one issue at this point, the surrogate data use for 

Carborundum. And the materials that are being 

discussed today should be posted on the NIOSH 

website under the compensation part of the website, 

the Board section, scheduled meetings and today's 

date.

So, you folks who are not internal to 

the Agency or the Board can go there and follow 

along in the documents that we're discussing today. 

And there's an agenda there too, but there's not 

much to it.

So, let's do roll call. And for that, 
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again, if people at a specific site could please 

speak to conflict of interests.

We have -- I'll just cover the Board. 

We have all the Board members. Dr. Roessler is the 

Chair, and none of the Board members have 

conflicts, so we'll move onto the NIOSH team.

(Roll call.)

MEMBER LOCKEY: Hey, Ted?

MR. KATZ: Yes.

MEMBER LOCKEY: Jim Lockey. Can I 

just ask you one quick question? I might be 

mistaken here.

But am I on this -- am in on this subgroup?

MR. KATZ: Yes. Yes, you are.

MEMBER LOCKEY: Because I looked at the 

Work Group Members, and I'm not listed. So, I was 

concerned.

CHAIR ROESSLER: This is Gen. That 

was my question too. When I heard you say Jim, I 

went on the website and looked and --
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MEMBER LOCKEY: I don't think I am.

MR. KATZ: Oh, you're not listed? 

Okay. Let's see.

MEMBER LOCKEY: I don't think I'm on 

this group.

MR. KATZ: Okay, I have Gen and I have 

Bill Field and Brad Clawson and John Poston. 

You're right, you're not. 

(Simultaneous speaking.)

MR. KATZ: So, for that matter, you're 

still welcome to stay on if you want to.

MEMBER LOCKEY: That's okay. I 

appreciate it. 

(Simultaneous speaking.)

MR. KATZ: Okay. Bye, Jim. Okay, so, 

anyway, I think we've covered everything. The one 

other thing I can say. For everybody, please mute 

your phones, except when you're addressing the 

group. 

If you don't have a mute button on your 
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phone, like for the members of the public, the 

petitioners, you press *6. That will mute your 

phone for this conference call. And then when you 

press *6 again, it will take your phone off of mute. 

But if you all mute your phones, that will improve 

the audio quality so that people can hear each other 

properly.

And please don't pull the call on hold 

at any point, but hang up and dial back in if you 

have to get off for a piece.

Alright, and then with that Gen, it's 

your meeting.

Surrogate Date Use DCAS Evaluation and SC&A Review

CHAIR ROESSLER: Okay, well, our Work 

Group plans to present our recommendations on SEC 

Petition 00223 at the November Board meeting. 

We have a slide presentation ready to 

go, and I thank Bob Anigstein for helping me put 

that together. This is based on our August 

meeting.
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However, we have one item left to 

resolve, and that's what we're going to do today. 

And as Ted says, what we need to do is answer the 

question, if the use of surrogate data at the 

Carborundum Company conforms to the Advisory 

Board's criteria.

So, to do this, we have two memos, and 

we'll present those in their order. First, Tom 

Tomes will present NIOSH's approach to the use of 

surrogate data in this particular situation. And 

then I assume Bob will report on his and John 

Mauro's SC&A report with their conclusions.

Now, I only found one of them on the 

website. Let me look at that; and that's the SC&A 

memo. But the other one we got from Tom somewhat 

earlier. So, everybody should have that. 

So, we have the report, but we'll ask 

Tom and Bob to present what they deem is necessary 

from their reports to summarize their reports and 

conclusions. So, we'll start with Tom.
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MR. TOMES: Thank you, Dr. Roessler. 

The Carborundum Evaluation Report relies on 

surrogate data as a means to estimate doses for the 

experimental grinding work done in 1943. That 

uses Battelle TBD-6000 to use for dose rates from 

the uranium metal and also for intakes to the 

uranium. And for the second AWE period at 

Carborundum, which was from 1959 through 1967, the 

ER relies on the external dose rates from TBD-6000 

for external doses. All of the other doses in the 

ER do not rely on surrogate data.

So, I went through the methods 

specified in the ER and put together a memo 

discussing the use of that data and the criteria. 

And I referred to Implementation Guide 4, which 

specifies criteria that needs to be met for using 

surrogate data. And I will just briefly go through 

the extent of the work that we're using that data 

for.

In 1943, Carborundum did experimental 
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grinding on 10 uranium, natural uranium, slugs. 

This was a brief operating period of doing that, 

for work that consisted of approximately four 

weeks, that we know of. But we do know that the 

slugs were onsite for a period of approximately 

four months.

That work consisted of selecting a 

grinding, an abrasive that would grind the uranium. 

They found a few that would work and a few that would 

not work. One that would work and a few that would 

not work. And they determined how the machine can 

be set to do the grinding, and then they went 

through a series of passes on the slugs to prove 

that it would work.

For the external doses of those 

operations, the NIOSH relies on TBD-6000 dose 

rates. The TBD-6000 has dose rates provided from 

various shapes of uranium metal, and one of those 

shapes is uranium slug. There's also other 

shapes, such as rods and ingots, provided in 
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TBD-6000.

And I believe that we have -- the 

example we provide to the Board actually uses a 

default dose rate, which I believe Dr. Anigstein 

may want to discuss when he presents his review.

So we've taken the dose rates derived 

in TBD-6000 and estimate that that is the same 

source term, which is one of the criteria. They're 

both the TBD-6000, the Carborundum work involved 

natural uranium metal.

Another criteria for using that was 

that the facility and the process needs to be 

similar. The grinding, centerless grinding is one 

of the operations specifically evaluated in 

TBD-6000. There are other considerations, such as 

temporal consideration such that the internal 

doses could be different from one area to the next, 

depending on how the facility is designed and laid 

out.

For that, we looked at the evaluation 
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of the centerless grinding intakes that we were 

provided by TBD-6000. They come from a document 

written by Harris and Kingsley. That particular 

document goes into quite a bit of detail discussing 

airborne concentrations of uranium that's released 

to the operator of a centerless grinder.

There was also data provided on the 

maximum observed concentration which an operator 

is exposed to. There's also data on daily weighted 

average concentrations. They provide these daily 

weighted average concentrations for an operator 

who was basically exposed to an uncontrolled 

system, no ventilation applied. And they also 

provide a much lower concentrations for an 

operations in 1950 that had applied ventilation.

The numbers in TBD-6000 are actually 

for the unventilated work, and those are the ones 

that NIOSH considers to be appropriate for 

Carborundum.

The Carborundum work in 1943, as far as 
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we know, has no particular engineering controls to 

control the airborne radioactivity. So we assume 

that the unventilated exposure is appropriate. 

As far as the data evaluation, that's 

another criteria that we have to look at. The 

TBD-6000 data had been previously reviewed by NIOSH 

and the Board, therefore we did not think it 

necessary to do that this particular evaluation.

Finally, plausibility is a criteria 

that has to be applied to using the surrogate data. 

While there are a couple situations here that goes 

into plausibility, one is actually the air 

concentrations of the dose rates we'd be 

estimating. And in this particular case, it also 

has to do with the amount of time that the operator 

was exposed.

We have no definitive information to 

adjust the number of hours that was exposed at 

Carborundum in 1943. But we do know that the slugs 

were onsite for four months. So we assume that an 
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operator and other people were exposed for four 

months. 

We believe that to be reasonable, 

because we do know that when they were doing to the 

actual testing, they would have been exposed up to 

a significant amount of airborne concentrations, 

as well as significant dose rates from inhaling the 

metal. And the plausibility issue is another 

thing that I believe SC&A is going to discuss.

Okay, that was my evaluation for the 

1943 work. The 1959 through 1967 AWE period is a 

completely different source term.

The 1959 through 1967, Carborundum did 

some experimental synthesis of uranium nitride, 

uranium carbide and uranium silicide. The initial 

work involved developing the methods to actually 

synthesize those compounds. They started with a 

few different sources of uranium. They were all 

small batches of uranium. UO2, U3O8 and uranium 

shot were identified as three different sources 
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they used. And they fabricated those into a few 

small pieces, different shapes, and those shapes 

were subsequently used to test the properties of 

the compounds and the fabricated pieces.

They also, once they determined the 

method to synthesize these compounds, they 

fabricated them into small parts that were 

subsequently used for testing in reactors.

For surrogate data use, we rely on 

TBD-6000 to estimate the external doses from those 

particular compounds and pieces that were 

fabricated.

The source term is similar to the source 

term provided in TBD-6000, but not completely 

identical because some of the compounds at 

Carborundum are unique, not specifically 

evaluating TBD-6000. However, TBD-6000 provides 

dose rates of several different uranium compounds, 

as well as uranium metal, and the uranium metal is 

higher and more dense than those particular 
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compounds, and so we believe that using the uranium 

metal dose rate is sufficiently similar and would 

bound the dose rate from the particular compounds 

used at Carborundum.

The facility and process similarities 

had little impact on the dose rates. The 

significant issue for this particular aspect of it 

is the distance and time a worker would spend near 

the material. And TBD-6000 assumes that a worker 

that was exposed at a distance of one foot for 50 

percent of the work year. And we reviewed the 

processes they used and the various reports that 

Carborundum did.

They basically took small amounts of 

uranium, grams to a few pounds, processed it in 

batches. These batches of material would be held 

in furnaces, be held in mills and grinding for a 

number of hours. The work was all done in glove 

boxes and their atmospheres, and we believe that 

the assumption of 50 percent of the time at one foot 
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is a sufficient method to estimate the exposure.

We have no definitive information to 

provide an exact time that we believe would bound 

the exposure.

For the temporal considerations, that 

would have little impact on the use of the data. 

It was just an issue, we think, of the proximity 

that the worker is to the material and the amount 

of time. The data evaluation is the same as in the 

previously, the TBD-6000 data has previously been 

reviewed. 

And lastly, I reviewed the bounding 

exposure models, and as I just mentioned under the 

process similarities, we believe that the 50 

percent exposure time is reasonable and provides 

a bounding model.

That was the extent of the -- that was 

just a summary of going through my memo that I 

issued to the Work Group. And with that, we 

concluded that the surrogate data used is 
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appropriate and meets the criteria provided in the 

NIOSH IMP 4.

CHAIR ROESSLER: Okay, Tom. Thank 

you. Are there any questions or additions at this 

point? 

If not, there will be time left to ask 

any after SC&A's presentation. So, I think we 

ready next for SC&A's response to that. Bob, are 

you ready?

DR. ANIGSTEIN: Yes, I am. Can you 

hear me? Hello?

CHAIR ROESSLER: Yes. I can't hear you 

real well. I don't know about anybody else. 

DR. ANIGSTEIN: How is this? Is this 

better?

CHAIR ROESSLER: That's better.

DR. ANIGSTEIN: Okay.

CHAIR ROESSLER: Yeah, that's good. 

Go ahead.

DR. ANIGSTEIN: Okay. Alright. So, 
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I have a slide show to present on Live Meeting. I 

hope everyone is connected to it.

CHAIR ROESSLER: Oh, I didn't know about 

that. I'm not connected. 

DR. ANIGSTEIN: Oh, there was an 

invitation put out.

CHAIR ROESSLER: Oh, I missed that, I 

guess. Well, go ahead. I can follow. I don't 

know, are others on Live Meeting?

MEMBER FIELD: This is Bill. I was on, 

but there was nothing there, so I got off. It's 

easy to get back on.

DR. ANIGSTEIN: I'm putting it on now.

MEMBER FIELD: Okay, thanks.

CHAIR ROESSLER: I can follow. Your 

report is very clear. I can follow from that.

DR. ANIGSTEIN: Okay, the slide show is 

slightly different. I'm sorry, I should have 

emailed is to you also but -- so, for those who have 

it, does everyone who has Live Meeting see my first 
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slide?

MR. TOMES: This is Tom. I can see it.

DR. ANIGSTEIN: You can see it, good. 

So, this is -- John Mauro helped me prepare this, 

but he's not available today.

Okay, since Tom used the NIOSH -- the 

OCAS criteria for surrogate data, since we're a 

contractor to the Board, the Advisory Board, it 

would be more appropriate if we used Advisory Board 

criteria. They're not in conflict with the NIOSH 

criteria, but they're organized a little bit 

differently.

So I just went to a very formalistic 

procedure of verifying. So let me just go very 

quickly through the Advisory Board criteria.

The first criteria is the hierarchy of 

data. In other words, don't use surrogate data if 

you've got better data. And so the hierarchy is 

-- the first item of hierarchy is individual worker 

monitoring data. Okay, the second would be 
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coworker data. The third would be workplace 

monitoring data and the fourth would finally be 

process and source term data. 

The second is exclusivity constraints, 

which is simply: are the data that you're going to 

be using exclusive or are there other 

possibilities? 

And the third one -- and this is the 

important one -- site or process similarities. 

And it can be broken down to a similarity of 

production processes, conditions that might affect 

exposure and selection the surrogate data used for 

dose reconstruction.

Item four is the temporal 

considerations. A is the surrogate data should 

belong to the same general period as the operations 

in question, unless it can be shown that the working 

conditions and procedures are comparable. 

And then the final one is plausibility. 

First, there is scientific plausibility. Are the 
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models scientifically appropriate? And then B are 

workplace plausibility. Are the assumed 

processes and procedures plausible for the 

facility in question?

So, then how is the surrogate data used 

in the SEC Evaluation Report for Carborundum? 

So, we'll start off with the intake of 

the uranium aerosols during the first operational 

period, which is the period during which the 

surrogate data is used for intake.

Okay, according to the TBD-6000 model 

that was adopted by NIOSH in this instance, intake 

is 43,632 dpm per calendar day. So, this is, for 

those who may not be familiar with that, for the 

dose evaluation program, it's necessary to average 

the intake for each calendar day, meaning the seven 

days a week, 365 days a year, even though the 

workers don't actually work every single day.

So you take the total intake and you 

average it out. So this is the median intake with 
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a geometric standard deviation applied. And from 

this distribution, you can calculate, using 

standard statistics, that the arithmetic mean 

comes out to about approximately 159,000 dpm per 

calendar day.

So, if you back-calculate that with 

actually -- multiply that to get the weekly intake 

and then divide by the number of hours per week, 

and divide by the breathing rate of 1.2 cubic meters 

per hour, you end up that there is 20,192 dpm per 

cubic meter in the worker's breathing zone. That 

is the value that I calculated from the data that 

is being used by NIOSH with TBD-6000.

Now, does this satisfy the criteria? 

Well, it satisfies the hierarchy of data because 

there is no better data. There is no site-specific 

airborne concentrations for the uranium machining 

operations at Carborundum in 1943.

By the same token, they satisfy the 

exclusivity constraint because there are no other 
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data. 

Site and process similarities. Well, 

both the Harris and Kingsley report -- which covers 

a large number of processes that they studied. 

These two authors worked for the Atomic Energy 

Commission, the Health and Safety Laboratory, 

which is located here in New York, and they would 

use -- so in this particular instance, they cite 

the concentration for centerless grinding.

Centerless grinding, again, something 

that is probably not a familiar term. If you put 

something, a piece of metal in a lathe, and turn 

it and use a tool to grind it down in a grinder, 

that's using a center. And centerless is when your 

work simply lies there between two rollers, one of 

which is abrasive, and it just passively turns and 

grinds away as it's turning.

So, this creates a great deal of dust. 

It's a very, very, very -- even though they use 

water to cool it, the water sprays and forms 
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droplets, and the droplets evaporate and they cause 

a great deal of uranium dust.

So, similar in that sense, also the 

Harris and Kingsley report cites different 

measurements; they cite one measurement taken in 

the absence of ventilation where the rate becomes 

much, much higher. And since we don't know 

anything about -- you know, NIOSH doesn't know 

anything about whether there was ventilation at 

Carborundum, they assume there wasn't. And quite 

frankly, that's probably plausible. This was a 

short-term operation. It's plausible to think 

that they didn't bother setting up special exhaust 

fans and hoods and so forth.

Okay, so the similarity -- it passes 

site and process similarity criteria. Next, 

temporal consideration. Well, it doesn't pass the 

temporal consideration because the Harris and 

Kingsley report that they did their site visits and 

measurements in the late 1950s. So, this is maybe 
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15 years later than the Carborundum work.

However, not much has changed. It's 

similar, because the only difference would be, 

well, there might have been, by the time they 

visited the site in the late 1950s, improvements 

in health and safety, improvements in realization 

of the hazards of uranium, improvements in 

ventilation. But since they reported on a 

particular place where there was no ventilation, 

there is no reason to believe that time would have 

changed anything.

So, we can say that it passes -- we noted 

on the first one there was an exception -- temporal 

consideration because of this fact. Had there 

been an exception, if the working conditions were 

comparable, you could still use it even if it was 

for a different time period.

Then, finally, the plausibility. 

Well, as I point out on the top of this slide, the 

breathing zone, the mean breathing zone, 
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back-calculated was about 20,000 dpm per cubic 

meter. Harris and Kingsley reported up to 13,000; 

20,000, 13,000, it's the same general ballpark.

So this is claimant-favorable, a 

conservative assumption. It's a little higher 

than the highest measurement, or the measurement 

that was reported. But it's not out of the 

ballpark. It's a reasonable comparison.

So, given the uncertainty and the 

variability between those, we can say it passes the 

plausibility criteria. Therefore, it passes --

also using the Harris and Kingsley measurements of 

the uranium aerosols from centerless grinding --

passes all five of the Board's criteria.

Next is the external exposure to 

penetrating radiation from uranium metal, in other 

words photon radiation, during the first operation 

period, the 1943 period.

There, we do have a problem, because we 

know, and NIOSH has reported based on the available 
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documentation, that Carborundum received a total 

of about 30 pounds of uranium in the form of natural 

uranium metal slugs. Thirty pounds is like 13.6 

kilograms. And the dose rates that are reported 

in TBD-6000, and in the paper by Harry Anderson, 

who was a NIOSH Board Member for a period of time, 

and Nolan Hertel, a professor from Georgia Tech 

collaborated on it, showed that using a model --

a computer program called MCNP, that the dose rate 

from it -- they modeled several different shapes, 

and I'm not reporting on all of the data; they're 

not relevant.

Now, the ingot was a big block, probably 

the largest block you can imagine of uranium metal. 

It's 16 by 24 inches by 4 inches thick. And they 

calculated the dose rate right above the center 

along the large -- opposite the large surface at 

one foot away. And they found that there was a dose 

rate of approximately 2.08 millirem per hour.

Whereas the slug that they modeled, 
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which is a little larger than the slug -- and I'll 

come to that in the next slide -- a little larger 

than the slug that was assumed by NIOSH. NIOSH used 

Clinton's slugs. Clinton Engineering was sort of 

the code name for the Oak Ridge facility during 

World War II.

And the dose rate of the slug, which had 

a mass of two kilograms -- and I mean, this is not 

the Clinton slug, this is the slug that was modeled 

by Anderson and Hertel -- it had a dose rate of 

.0524.

So we're talking about a difference 

between two millirem per hour and .05 millirems per 

hour. So this is a difference of about two orders 

-- almost two orders of magnitude.

Then even if you say, okay, they had 

13.2 kilograms, so let's assume that they had --

that this would be equivalent to seven of these 

slugs. So, seven slugs would have a mass of 14 

kilograms, which is very close to that. So even 
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if you take the dose and you arrange these slugs 

in an array so that the worker was exposed to all 

seven simultaneously, you will get a dose rate of 

.367, which is, again, about 1/6 or 1/7 of the dose 

rate from the ingot. So the ingot way overstates 

the exposure rate.

Then we look at, do they satisfy the 

criteria? Okay, hierarchy of data. Yes, there 

are no site-specific are no measurements that can 

cover this for Carborundum. Exclusivity 

constraints, yes, for the same reason.

Site and process similarities is not 

fulfilled, because the source term is much larger. 

It's 477 kilograms versus a maximum of 13.6 

kilograms. 

The temporal considerations are 

irrelevant because it's based on a computer model. 

Temporal doesn't have anything to do with it. 

And plausibility again is not 

fulfilled, because source term, for the same reason 
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as the site and process similarity.

So, our suggestion is that NIOSH might 

wish to consider using the seven slugs, which would 

have the same mass as the amount of uranium onsite 

and still give a conservative -- all seven as 

opposed to one, so it's conservative, 

claimant-favorable, but plausible.

Next, the second operational period. 

Again, NIOSH uses the same ingot. I have to say 

that in the SEC Evaluation Report, and in Tom's 

memo, they don't say which shape they used, but the 

supporting documentation that came with the SEC 

Evaluation Report, there were a couple of files 

that are on our restricted website that are called 

the Carborundum Methodology, or something like 

that. They do cite the exposure rate, dose rates 

from the large ingot.

Now, here during the second operational 

period, you're dealing with even less. There was 

a table in the SEC Evaluation Report that cites 
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various quantities, various in-process, and at the 

end of that list the largest quantity of uranium 

mentioned is that Carborundum had made a request 

for 10 pounds of uranium shot, little pellets, 

little BBs, and that comes to 4.5 kilograms. The 

actual batches that are reported are batches 

anywhere from 30 grams to six pounds; six pounds 

is 2.7 kilograms.

So, again, this is completely different 

than the 477 kilogram ingots. And again, I repeat 

part of the same table, but here I mention -- I cite 

the slug, and after the slug is the 477 kilograms 

ingot. The slug is the same slug as before. And 

another shape is a plate.

So, this is a fairly thin, extended 

sheet of uranium, which was, again, modeled by MCNP 

and reported in TBD-6000. And that has a mass of 

3.1 kilograms, and that seems like a very plausible 

surrogate. Of course, it wasn't in the shape of 

a plate, but the reason it's a good surrogate is 
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it's quite similar in mass. The batch, the largest 

batch was 2.7 kilograms; this is 3.1. It has a dose 

rate much higher than the slug, four times as high 

as the individual slug. And more important, I 

calculated a specific dose rate, which is simply 

the millirem per hour per kilogram of metal.

Now, the slug -- the ingot, because it 

is so compact, actually has a lower specific dose 

rate. And of all the shapes that I looked at --

not just these, but at all the ones listed by 

Anderson and Hertel -- the plate has the highest, 

.07. And common sense will tell you that's 

expected, because if you take the uranium and 

spread it out in a thin plate, you have less 

self-shielding. In the early days there's a lot of 

self-shielding. So, the back part of it furthest 

away from you doesn't contribute very much. So, 

this seems like a more plausible shape to use. 

So, again, does it satisfy the 

criteria? It satisfies the hierarchy of data and 
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the exclusivity for the same reasons we said 

before: there is no other data, and again, the 

exclusivity likewise. The site and process 

similarities, again, are not fulfilled because 

you're modeling 477 kilograms and the largest 

single batch is 2.7 kilograms. Again, more than 

two orders of magnitude smaller. 

Again, temporal considerations don't 

factor into it. Plausibility, again, is not 

fulfilled because the source term -- hello? Is 

there a question? Was there a question? 

MR. KATZ: No, Bob. Carry on. I 

think one of the petitioners' phones is not muted. 

That's all.

DR. ANIGSTEIN: Okay. So the source 

term is larger. So, again, we would suggest that 

the plate, which has a similar mass to the largest 

batch of 3.1 versus 2.7 kilograms, would be more 

plausible. It would be claimant-favorable, and we 

can't really get much higher than that.
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So, the conclusion is the uranium 

intake -- intake of uranium dust during the first 

operational period used by NIOSH do satisfy the 

Advisory Board's surrogate criteria.

The external dose rate do not satisfy 

two of the criteria, the site and process 

similarity and the plausibility because the source 

is very large.

However, this is not an SEC issue 

because all that is needed is for NIOSH to 

demonstrate that they can model and they can 

calculate the doses, and by making these --

MR. KATZ: I'm sorry, but is anybody 

else having trouble hearing Bob at all?

CHAIR ROESSLER: I'm having trouble, 

but then I have hearing problems.

MR. KATZ: No, no, no. I think -- Bob, 

I think you need to get closer to your phone.

DR. ANIGSTEIN: Okay, is this better?

MR. KATZ: Yeah, much better. Thanks.
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DR. ANIGSTEIN: Okay. Sorry, my mouth 

tends to wander away from the phone. Okay, sorry 

about that. 

So, we feel it's not an SEC issue 

because if they follow our suggestions, or some 

alternate strategy, they can, in fact, model the 

doses in such a way that they satisfy the criteria. 

So, that's it.

CHAIR ROESSLER: Thank you. Am I off 

mute?

MR. KATZ: Yes, you are.

CHAIR ROESSLER: Thank you. I had a 

little trouble hearing, but, Bob, I did get on Live 

Meeting and your slides did do a nice job of 

summarizing your report.

I think maybe we should start with any 

questions from the Work Group. And then we'll go 

to NIOSH to respond to the suggestions that were 

made by SC&A.

MEMBER CLAWSON: This is Brad. I 
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don't have any questions at this time.

MEMBER FIELD: I don't have any 

questions either. This is Bill.

CHAIR ROESSLER: Okay. John, as you 

still on?

MEMBER POSTON: John doesn't have any 

questions.

CHAIR ROESSLER: Okay, then I think, 

Tom, it's up to you to respond.

MR. TOMES: Okay, this is Tom. Yes, I 

have looked at Dr. Anigstein's memo and some of the 

underlying data, and I do agree that NIOSH needs 

to re-evaluate the appropriate dose rate. As a 

matter of fact, that is specifically not included 

in the memo I wrote, because I do believe it needs 

to be looked at in closer detail.

The example, to be honest with you, the 

example DR that we sent to the Board and that was 

reviewed was kind of rushed. It was prepared with 

the ER that we sent, and some of this information 
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we received when Carborundum came in shortly before 

the ER was approved. So we attempted to put 

together a dose reconstruction methodology and we 

didn't get all the doses refined as much as we 

probably could.

So, I do believe we need to go back and 

look at the facility -- the methodology basically 

was the default TBD-6000, and I do believe that it 

would be appropriate to go back and look at a more 

appropriate factor from the tables in the document.

CHAIR ROESSLER: Okay, and I 

understand it, this discussion is not an SEC issue, 

but it's a Site Profile issue.

MR. TOMES: I believe it is.

CHAIR ROESSLER: We'll see if Bob 

concurs with that.

DR. ANIGSTEIN: Yes, I do.

CHAIR ROESSLER: Okay, is there 

anything -- does anyone else have any comments or 

questions? Ted, before we go back to the Work 
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Group, should we get petitioners' comments? 

MR. KATZ: Yeah, this would be a good 

time to welcome them and to say if they have 

comments, to provide them.

Petitioner Comments

PETITIONER 1: Well, we can say that --

this is [redacted]. And for us to understand a lot 

of this stuff while we're listening in, really, 

it's hard for us to really -- and I don't know how 

my brother feels -- but it's hard for us to 

understand the whole thing.

Now, is this still for the SEC? Are you 

still --

MR. KATZ: Yeah, so this is -- just to 

explain it a little, the Advisory Board has these 

Work Groups, like this one here, to just have more 

focused discussion to prepare the full Board for 

when it picks up a petition.

So, the Advisory Board tasked this Work 

Group to effect the details and then come back and 
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speak to the Advisory Board. That's what it's been 

doing. It did at its last meeting, and what it's 

doing today. And then it will report -- I think 

you know from Josh that on November 30th, the whole 

Board will pick up this petition, and Dr. Roessler 

will present.

So, this is -- and I perfectly 

understand, this is all crazy, technical 

discussion for most people, lay-people, even 

people who work in other science fields, this is 

not familiar territory.

PETITIONER 1: Right.

MR. KATZ: So, that's understood. But 

this is an opportunity, and you'll have another one 

at the full Board, to really to present whatever 

it is that you might want say on behalf of your 

petition, whatever details you might want to give 

about how work was at Carborundum or whatever else 

you might want to say on behalf of your petition. 

It's just an opportunity to do that, both now, and 
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then before the whole Board, you know, by telephone 

or in person at the end of the month.

PETITIONER 1: Okay. Okay, and that's 

coming up November 30th, you said? 

MR. KATZ: Yeah, so that will be 

November 30th. I believe in the morning is 

Carborundum.

PETITIONER 1: Okay.

PETITIONER 2: This is [redacted]. I 

wanted to ask if, is it -- is NIOSH coming up with 

another dose reconstruction, or did I 

misunderstand that. I couldn't understand what 

you were saying.

MR. TOMES: This is Tom with NIOSH. 

Yes, there are -- during the course of the review 

of the petition, NIOSH wrote an Evaluation Report. 

SC&A reviewed that and provided a number of 

comments, and those comments basically consisted 

of two different types of comments.

One of them considered whether we had 
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an SEC issue, or we just had an issue where the doses 

need to be improved or corrected to allow for 

certain aspects that were not properly evaluated.

So we have some issues to go back and 

re-evaluate the doses. So those are in progress. 

And the issues before the Board, I believe, 

initially will be the SEC issues. But NIOSH does 

have to refine the dose estimates.

PETITIONER 2: Like my sister said, 

it's hard to understand for us, you know. But 

anyway, it might be like my dad had, you know, lung, 

liver and bone cancer, and they come up with a dose 

reconstruction. How does that -- that's all done 

by computer, right?

MR. TOMES: Computers are involved 

with the work, yes, sir.

PETITIONER 2: But you're going to redo 

that, though? I mean, coming up with another dose 

reconstruction?

MR. TOMES: Yes, if there's any changes 
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made in our method that result in an increase in 

dose, the claim would be re-evaluated.

PETITIONER 2: Okay, thank you.

PETITIONER 1: Thank you.

Next Steps and/or Recommendations to the Board

CHAIR ROESSLER: Okay, at this point, 

after our last Work Group meeting, the Work Group 

came up with the conclusion that, with appropriate 

adjustments, NIOSH can reconstruct doses for the 

proposed SEC Class. Therefore, at that point, the 

Work Group was ready to present a motion that the 

SEC Petition 00223 be denied.

So, with this discussion today, and 

after Tom's presentation and Bob's very thorough 

evaluation, we need to bring this up again to the 

Work Group as to whether the Work Group still agrees 

with that conclusion.

MEMBER FIELD: Gen, this is Bill. I 

still agree with that conclusion.

CHAIR ROESSLER: Brad, are you --
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MEMBER CLAWSON: Gen? Yeah, Gen, this 

is Brad. This hasn't changed anything with my 

decision on that. You know, like they said, this 

is just a Site Profile issue. I think that they 

can still do it. So, it hasn't changed my point 

at all.

CHAIR ROESSLER: Okay, John?

MEMBER POSTON: I'm the same.

CHAIR ROESSLER: Okay, then I think 

we're ready to go to the Board with our presentation 

on the 30th. We will need to -- we do have the slide 

presentation that we put together, and I sent that 

around previously to the Work Group, and everybody 

approved of it, to that point. But we will need 

to add one more slide, and I'm hoping, Bob, you'll 

be able to prepare that for us.

DR. ANIGSTEIN: Sure, what would you 

like to show on it?

CHAIR ROESSLER: Well, if you can take

your presentation you did today, and hopefully 
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reduce it to one slide.

DR. ANIGSTEIN: Will do.

CHAIR ROESSLER: And readable, make 

sure that there's not too much detail on it. That 

will be a challenge, but I think you can do that. 

DR. ANIGSTEIN: Sure.

CHAIR ROESSLER: And then I'm 

thinking, if you look at the presentation we have 

so far -- let me go back to this slide. I think 

it's -- see if you agree with this. I was thinking 

it would come after slide 16. Previously, we had 

reported on the seven findings that SC&A had. And 

it seems like it would go after that and before the 

Work Group conclusion.

Ted, you might weigh in on that also.

Is anybody there?

MR. KATZ: No, I'm here. I'm not 

looking at the presentation right now, so it's hard 

for me to weigh in on exactly where it goes. But 

I'm sure that's easy to figure out, the appropriate 
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place. 

And I'll just say to Bob, I mean, it's 

really make the slide at a very macro level, because 

there's no reason to wade into the fine details, 

which I will share with the whole Board, and it will 

be at the Board meeting, in the SC&A report, so they 

can have the details about what was agreed upon.

But really you just need to give the 

results of this. And you may -- if you take two 

slides, that's fine too, whatever. But I think 

that's easy to do, and we do actually need to get 

that in this week. 

CHAIR ROESSLER: So, I think, Bob, if 

you can take your conclusion paragraph and reduce 

it to maybe just a few lines and --

DR. ANIGSTEIN: I'll work on that 

Thursday. Yeah, I can get it to you tomorrow.

CHAIR ROESSLER: Okay, I'll take a look 

at that. And then, Ted, okay, what should we --

from that point --
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MR. KATZ: Yeah, if you get that, if you 

agree upon that extra slide or whatever it is, slide 

or two, and send that to me this week, then I'll 

get that in the hoper so that it can -- because it's 

got to be put in -- well, if it's a simple text 

slide, really that's very quick, and then we can 

get this transferred into a pdf form that works for 

posting and so on.

CHAIR ROESSLER: Okay. It'll be a 

text slide, right, Bob?

DR. ANIGSTEIN: Yeah.

CHAIR ROESSLER: Yeah, and then we'll 

copy the Work Group on it. I'll copy the Work Group 

after I get the slide from Bob and make any 

adjustments that I think we might need, and as I 

send it to you, Ted.

MR. KATZ: Sure, sure.

CHAIR ROESSLER: Okay, so I think we're 

ready to go on this, unless anyone has any questions 

or further comment.
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MEMBER CLAWSON: Gen, this is just 

Brad. Now, you know, I still agree on everything 

that we've just agreed to. But what type of a 

timeframe are we looking at for NIOSH or ORAU to 

be able to redo this and give us some information 

back on it? Can anybody give me a time or so?

MR. TOMES: This is Tom. I don't have 

a schedule for that. We have several issues, and 

some of them are relatively simple, but there are 

a couple of them that are difficult. And we'll 

have to come up with a schedule for that.

SC&A comments on our Pu modeling, the 

MCNP modeling and- that's a little bit of work, and 

we have to discuss that internally and assuming 

make some kind of presentation to the Board with 

what our plans.

MEMBER CLAWSON: Okay, that's kind of 

what I -- I was kind of just trying to look at a 

path forward and what we are looking at for 

timeframe and all. And I understand where you're 
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at, but if you just keep us appraised, we'd 

appreciate it.

MR. TOMES: Okay.

CHAIR ROESSLER: Okay. I think since 

that's a Site Profile issue, though that doesn't 

deter us from making a presentation at the Board 

meeting.

MEMBER CLAWSON: That's correct.

CHAIR ROESSLER: Okay, so we'll follow 

up on that. Okay, is there anything else we need 

to consider?

MR. KATZ: I think that takes care of 

it, Gen.

CHAIR ROESSLER: Okay, thank you, Tom 

and Bob, for a very clear and nice report.

MR. TOMES: Thank you.

MR. KATZ: Thanks, everyone, and 

thanks to the petitioners, too, for attending. We 

appreciate that and we hope to hear from you at the 

Board meeting, as well. 
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Adjourn 

CHAIR ROESSLER: Okay, we're 

adjourned.

(Whereupon, the above-entitled matter 

went off the record at 11:53 a.m.)