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

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

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

Work Group on TBD-6000 

Thursday, April 1, 2021

The Work Group convened via Videoconference, at 

10:30 a.m. EDT, Paul L. Ziemer, Chair, presiding. 
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally 

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reader should be cautioned that this transcript is for information only and is subject to change.

2 

Present: 

Paul L. Ziemer, Chair

Henry A. Anderson, Member

Josie M. Beach, Member

R. William Field, Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Ron Buchanan, SC&A

Zaida Burgos, NIOSH

Grady Calhoun, DCAS

Nancy Chalmers, DCAS

Rosanna Gogliotti, SC&A

Megan Lobaugh, NIOSH

John Mauro, SC&A

Pat McCloskey, ORAU Team

Jenny L. Naylor, HHS

Lavon Rutherford, DCAS

Mutty Sharfi, ORAU Team

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

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Work Group on TBD6000 Thursday, April 1, 2021 1

Roll Call/Welcome 4

Meeting Business and Agenda planned by Dr. 

Paul Ziemer 5

Response to SEC-00247 ER Review -Finding 

#1 6

NIOSH Presentation by Megan Lobaugh

6

SC&A Presentation by Rosanna Gogliotti

24

Workgroup discussion 31

Work Group Recommendation for 

Closure-Finding #1 34

Path Forward Report on Finding #1 at next 

full Board Meeting 35

Adjourn 37
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4

Proceedings

(10:30 a.m.)

Roll Call/Welcome

Dr. Roberts: Good morning, everybody. I'm 

Rashaun Roberts. I'm the Designated Federal 

Official for this Advisory Board on Radiation and 

Worker Health. If you're not aware, this is a 

meeting of the TBD-6000 Working Group.

We, today we have a three-item meeting agenda, if 

you've seen it. If you haven't, you can find the 

agenda on the NIOSH website under schedule of 

meetings for today's date, along with the meeting 

materials which has been disseminated to this 

Working Group in advance.

So again, I want to officially welcome all of you to 

this video conference, or teleconference. First off, I 

want to address conflict of interest, of course, and I 

will speak to that with regard to Members of this 

Board, who sit on this particular Working Group. 

They should not have any conflict of interest.

So with that, let me move into roll call for Members 

of the Board who are on this Working Group, 

starting with the Chair, Dr. Paul Ziemer.

(Roll call.)

Dr. Roberts: So at any rate, thank you, all, and 

welcome again.

Before we officially move into the meeting, I just 

want to cover a couple of items. Of course in order 

to keep things running smoothly and so that 

everybody can be clearly understood, I'd ask each 

of you just to make sure that you mute your phone, 

unless of course you need to speak.
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5

So, if you're on the phone, you press *6 to mute, 

*6 to unmute. For those on Zoom, the mute button 

is on the lower left-hand side of your screen. Please 

periodically check your phone and your computer to 

ensure that you're remaining on mute if you're not 

speaking, as we have occasionally had some 

interference here and there.

As I mentioned before, the meeting for today's 

agenda, the agenda for today's meeting rather, can 

be found on the NIOSH or DCAS website. Access to 

the other materials was provided to the Board 

Members and to staff prior to the meeting.

For the rest of you, the agenda, presentations, 

background documents, et cetera are posted on the 

website. So, with that we can move into the main 

part of the agenda. So, I will now turn the meeting 

over to the Chair of the TBD-6000 Working Group, 

Dr. Paul Ziemer.

Dr. Ziemer?

Meeting Business and Agenda planned by Dr. Paul 

Ziemer

Chair Ziemer: Thank you, Rashaun, and good 

morning, everybody. Good to see at least some of 

your faces. About half of you just look like black 

boxes to me, but I assume there is somebody 

behind the black box and you'll contribute as 

necessary, so thank you.

The meeting agenda for today is rather brief. We 

have one principal item to take care of. We're 

focusing on Superior Steel and we had an item that 

goes back to about a year or two to kind of close 

out the Site Profile types of issues.

So, we're -- and it's Finding 1 in the original group 

of findings that we reviewed. This finding we have 
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6 

updated, and we have reviewed it before, but the 

Work Group had asked NIOSH to go back and clarify 

some additional details based on some of the 

comments made by SC&A. So, we're going to go 

through that this morning.

Megan Lobaugh will begin and review what NIOSH 

has to present. And then, Rose, I think you'll have 

an opportunity to discuss the Evaluation from SC&A 

on this latest item.

So, let's begin and, Megan, if you're ready to go, 

are you going to put some things on the screen for 

us as well?

NIOSH Response Paper-Additional Information in

Response to SEC-00247 ER Review -Finding #1

NIOSH Presentation by Megan Lobaugh

Dr. Lobaugh: Yeah, I can share the presentation 

that I put together.

Chair Ziemer: Good, and I think, as Rashaun has 

already mentioned for others listening in, if you're 

not on Zoom, these documents are on the NIOSH 

website. I think the, certainly the Work Group 

Members have all received copies of them in 

advance as well. So, okay good, and I see it on my 

screen now as well. So, let's proceed.

Dr. Lobaugh: Great. Just so you guys know, I have 

two screens so if I'm not looking at the camera it's 

because I'm looking at other screen.

As Dr. Ziemer said, I'm Megan Lobaugh. I work with 

DCAS and this presentation here provides a quick 

overview of the findings. So, if you would like me to 

do that, Dr. Ziemer, I can go through kind of the 

history of the responses that we've had and then go 

into our actual response paper that we sent in 
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7 

March of 2020.

Chair Ziemer: Yeah, I think that would be good. 

Make sure everybody is up to speed on that. Thank 

you.

Dr. Lobaugh: Great, yes. So, let me back out of 

here. So, as I said I'll go through a quick summary 

of the Evaluation Report, the SC&A review, and then 

the responses and Work Group discussion that we 

had for Finding 1. And then I'll go through the more 

specifics that we provided in our March 2020 NIOSH 

response to that request for additional information.

So, we'll start with the summary. And I'll try and 

make this quick, but feel free to jump in, Rose, if 

there's anything additional you want to add when 

I'm talking about the SC&A review or the responses.

So, as Dr. Ziemer said, we're talking specifically 

here about Finding 1, that was established after the 

review of the ER for SEC-247. 

So this finding is specific to or affects internal and 

external dose, and it's specific to the exposure time 

that we're assuming for the rolling hours. So, 

Superior Steel was on a contract with the AEC so 

their full-time work was not with uranium. Their fulltime work was with non-radioactive materials.

So, their AEC contract was a part-time kind of job 

that they had. And so we needed to determine a 

specific set of rolling hours, or how often they were 

actually working with uranium.

So, in the ER, we proposed to use a surrogate 

billing rate approach where we used the Vulcan 

Crucible billing rate. And I'll remind you, through 

the discussions, if you remember, this, we actually 

ended up finding the Superior Steel contract or a 

version of the Superior Steel contract that gave a 
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8

specific Superior Steel rate.

So, some of this early discussion, became kind of 

null once we found that, found that billing rate. But 

our initial proposal was to use this Vulcan Crucible 

billing rate of $132 per mill-hour. And using the 

Superior Steel specific contract payments. And the 

approach we specifically provided was to use that 

19 -- the fiscal year 1957 payment.

With those numbers we came up with 414 millhours, and proposed basically rounding that up to 

500 hours. The SC&A finding initially questioned, 

you know, a selection of the surrogate billing rate, a 

Vulcan Crucible bill, for Vulcan Crucible billing rate. 

And said that we provided no rationale for why this 

billing rate would be a reasonable surrogate.

In that same finding, they also mentioned a Joslyn 

Manufacturing Company mill rate of $80 per hour, 

which would have resulted in a higher number of 

rolling hours.

Our initial response was provided in October of 

2019, and at that time, we reviewed the five criteria 

in the NIOSH Implementation Guide, for using 

surrogate data, surrogate information in dose 

reconstruction. So, this is Implementation Guide 4, 

the use of data from other facilities in the 

completion of dose reconstructions under the 

EEOICPA.

So, in that there, like I said, there was five criteria 

that we looked at and provided justification for why 

Vulcan Crucible was similar to Superior Steel. So, 

the first three are listed here on this slide, source 

term, facility and process similarities, and timing. 

So, in all cases we found that Superior Steel was 

similar to Vulcan Crucible.

The fourth criterion was data evaluation, and this 
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9

criterion wasn't directly applicable based on the 

description in that implementation guide that we 

have. And that is because the implementation guide 

specifically talks about the quality of exposure data. 

And this data that we're talking about here is not 

direct exposure data. This is the rolling hours, which 

would be used to calculate an exposure for a year.

So, the exposure rate would be determined from 

the actual source term at Superior Steel, not from 

this data directly, if that makes sense.

I hear a little bit of an echo, I'm not sure if someone 

is unmuted. I think it's a little better now, thanks.

So, the data evaluation, how we looked at this was 

we actually considered the fact that this was type 2 

data, so not direct exposure data. And we basically 

looked at this as reviewing other available billing 

rates and their applicability or their effect on the 

exposure hours calculation that we were doing with 

this data.

So, we did searches of the SRDB with our current 

holdings at the time, as well as additional data 

captures using source terms like rolling rates, rolling 

hours, hours milling, pieces per uranium, thorium 

and typical sites that we know rolled uranium. So 

those included Fernald, Hanford, some of the other 

AWEs.

In those searches, we found these four billing rates. 

So, let me scroll down a little bit --

Dr. Roberts: Wait.

Dr. Lobaugh: -- so the Simonds Saw --

Dr. Roberts: I'm sorry to interrupt Megan, it looks 

someone with the number ending in 137 is not 

muted. If you could check and mute, please, your 

telephone. Sorry about that.
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally 

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10

Dr. Lobaugh: That's okay, thank you. So, let's talk, 

I'll talk briefly about each of these rolling rates and 

the conclusion that we provided in our responses.

So, the first one here is Simonds Saw and Steel at 

$110.53 per rolling hour. So this, our calculation if 

we looked at this with the Superior Steel contract 

payments, we found that this was very similar to 

the 500 mill-hours that we calculated and provided 

in the ER.

For the Joslyn rate of $450 per rolling hour, we 

found that this was actually for different processes. 

So Joslyn, this rate was for taking 4.25 inch rounds 

down to 1.5 inch rounds and had very strict quality 

control on the temperature for the processing of 

that uranium.

So, we found that since these were different 

processes, and a lot stricter controls were based on 

the rolling at Joslyn, this would not be applicable to 

Superior Steel, given the process that we know 

Superior Steel followed.

The second Joslyn rate here of $88.03 per hour, or 

$0.11 per pound is what was brought up in the 

SC&A finding. And in our review of it, we actually 

found that this reference discussed, this estimate 

was actually for Simonds Saw and Steel and was 

never implemented due to the strict medical and 

security requirements that were placed on Simonds 

Saw and Steel.

So, they decided not to go through with that 

contract. So, we didn't find that that was 

appropriate to use since that contract was never 

actually implemented.

The fourth one was the Superior Steel contract 

actually. So, we located Modification No. 5 to the 

Superior Steel contract and it gave $1.01 per 
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11

pound. It also discussed additional payments per 

pound for additional services like planing and 

pickling of the slabs. So, it was kind of nice, that 

was nice because it laid it out directly in the 

contract.

So, the last criterion in the implementation guide 

was review of the bounding scenario. Again, this 

isn't directly applicable to -- the discussion in the 

implementation guide isn't directly applicable to the 

data that we're looking at here, because the 

discussion in the implementation guide is specific to 

exposure data.

And again, we're not talking about exposure data 

here, we're talking about the type 2 data that would 

be used with an exposure rate that's based on the 

source term. So, what we did in order to look at this 

criterion was actually compare our calculation using 

the billing rate approach to other information that 

we had available that told us estimates of rolling or 

mill-hours.

So, one of those things, one of those parts, or 

points of information was Table 7 in the ER. So, in 

Table 7 we provided compilation of rolling 

information that we found from several SRDB 

references.

And if we look at that with the, look at the number 

of dates that are provided in there, and come up 

with a conservative estimate of the time spent 

rolling, we came up with about 60 hours per year of 

rolling exposure, just looking at that data.

The second piece of information here we talked 

about, was that Modification No. 5 to the Superior 

Steel contract. And if we look at the $1.01 per 

pound calculation, with the similar information we 

used in the initial approach, we came up with about 

510 hours for the entire contract.
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12

So, one thing that we were initially concerned about 

was, in order to use the Superior Steel Company, or 

Corporation contract, we had to incorporate two 

additional pieces of information that from what we 

could tell had a lot of variability. So, two additional 

inputs that we didn't have direct references for, and 

from what we could tell, had a lot of variability in 

the information that was available in the SRDB.

And that would be the weight of the slabs as well as 

the number of slabs rolled per year. So, our initial 

response in October of 2019 stood by that approach 

of using the Vulcan Crucible billing rate to determine 

the number of hours.

In January of 2020, SC&A provided a response to 

our response that the billing rate in the Superior 

Steel contract really should take precedence over all 

other billing rates because it's site-specific. And 

they provided the following inputs that they would 

suggest using to calculate the number of hours, the 

number of milling hours of uranium using the 

approach, including slab weight and process, the 

slabs processed per year.

So, here are the numbers that were suggested in 

the initial SC&A response. That billing rate, that is 

basically a constant, no question about that based 

on the contract itself, $1.01 per pound. The slab 

weight, which would be based on the multiple SRDB 

references we have that discussed slab weights that 

came to Superior Steel and chose 216 pounds, 

which looked like the smallest known weight.

The number of slabs processed per day were 25 is 

what they chose. And then milling hours per day 

was ten, which again was agreed upon by the Work 

Group that that's a typical number of hours per day 

spent rolling for AWEs. That's our normal 

assumption, I would say. And then using the highest 

billing rate to maximize this approach.
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13

So, here's how that calculation actually falls out in 

the SC&A response. Using that highest billing rate 

per year of $138,246 divided by the contract 

payments, the $1.01 per pound, gives us 136,877 

pounds per year. And that's a maximum given the 

choice of the annual payment.

And then multiplying the pounds per slab, the 216 

pounds per slab by the 25 slabs per day, gives 

about 5400 pounds per day that was rolled. Dividing 

those two numbers, gives us 25.3 days per year or 

253 hours per year. So, the final conclusion that 

SC&A provided was that the assumptions are 

believed to place a plausible upper bound on the 

number of rolling hours.

In February 2020 was the last Work Group, and at 

that time the Work Group agreed that the intakes 

could be bounded and closed the SEC aspect of the 

issue. And so the discussion that they really focused 

on, this variability that we're seeing in the input 

numbers using that rolling calculation.

So, at the time NIOSH agreed to provide a 

summary of that available data for the rolling hours 

calculation. So, that's what we're going to talk 

about today. And that's the response that NIOSH 

provided in March of 2020 was to that request for 

additional information for Finding 1.

So like I said, we sent it March 27, 2020. And it 

reviews the history of the finding, like we just did 

here, this quick summary. And it provides a 

summary of the available information that we have 

regarding slab weights, slabs processed per day, 

annual payments, all of those input parameters to 

that calculation, we provided a summary of what we 

see available for Superior Steel.

It also provides an approach that uses all of this 

available data in the uranium rolling hours 
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14

calculation. So, we'll step through each of these 

kind of individually here.

So, to start with, SC&A and NIOSH, we both agreed 

on the formula for the rolling time. So how will we 

actually calculate it? How will we actually calculate 

the number of hours spent rolling uranium based on 

the information that we have available?

So, let me see, I don't think I can turn it.

Can you guys see my mouse at all?

Maybe not, I'll talk you --

Dr. Roberts: Yes, we can see it.

(Simultaneous speaking.)

Dr. Roberts: No, we can see it.

Dr. Lobaugh: Okay, so I'll try and point to what I'm 

talking to, too, just to help it out. So, looking at this 

equation, the numerator here is the annual 

payment, dollars per year.

So, what we're trying to calculate here is pounds 

per -- or hours per year, and we have to do some 

conversions, so that's why this looks a little 

overwhelming with the number of inputs here.

So, we have the annual payment dollars per year, 

divided by the billing rate and dollars per pound, 

times the slab weight and pound per slab, and the 

slabs rolled and number per day. And then, we 

multiply that entire equation by the time and hours 

per day. So, we can get that rolling hours and hour 

per year.

So, looking at this equation specifically, I did some 

color coding. The annual payments, slab weight and 

slabs rolled, are those three input parameters that 
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15

we talked about that had variability to them, that 

we're seeing different numbers, with a fairly wide 

range in the SRDB documents.

The brown inputs here are what are considered 

constants or things that we've agreed on. So, if we 

look at the actual calculation itself, that's what's in 

the table below.

First thing we did was we looked at minimizing this 

number and maximizing this number for rolling 

hours, and hours per year. So, to maximize the 

number, we need a large numerator and small 

denominator. So, the smallest slab weight, small 

slabs rolled per year.

To minimize this equation, we need a small annual 

payment and a large slab weight and a large slabs 

rolled, because the other inputs here are constant.

So, if you see here in the table below, you'll see 

that that's how we did these calculations, was 

maximizing the numerator, minimizing the 

denominator, to come up with the maximum 

number of rolling hours at 691 hours per year.

To minimize that, we again, made the smallest 

annual payment and the highest slab weight, and 

slabs rolled, and we got 14 hours per year. So, 

we're seeing a range here of 14 to 691 hours per 

year.

What I'm going to do next is step through each of 

these input parameters and discuss the kind of 

information that we were seeing, and how we go 

forward.

So, before I step through those parameters though, 

I want to kind of just discuss this approach that I 

talked about before. How are we going to look at 

this in a way that we can represent all the data?
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16

And so, the best approach that we came up with 

was actually trying to simulate that distribution for 

the rolling time. So, by looking at these input 

parameters, we can come up with a way to describe 

them and then make this calculation multiple times 

to come up with a distribution for that rolling time in 

hours per year.

So, I'll talk more specifically about each of those 

parameters and what we decided would represent 

those parameters well in that simulation.

So, first is the annual payment, this was in the 

numerator. The annual payment, we have one 

specific SRDB reference that gives us all of the 

payments given to Superior Steel, and it's fiscal 

years 1954 through '57.

So, you'll see here this table that I put together with 

each of the amounts paid to Superior Steel for those 

years. I do want to note that 1955, we summed in 

this table because the SRDB reference actually 

provides two payments for that year because the 

payments are based on where they originated, 

which operations office they originated from. And in 

1955 there were two operations offices paying 

Superior Steel.

In 1956, this number here of $130,246 is not the 

specific number you see in SRDB reference and 

that's because the payment in the SRDB reference 

is larger.

And what we agreed upon in the discussions, I 

haven't mentioned yet, is that this payment is much 

larger than the other payments seen to Superior 

Steel, and there's no indication that there was 

additional rolling that year.

But what the modification to the contract, 

Modification No. 5, shows us is that Superior Steel 
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17

was actually approved to receive payments for 

equipment upgrades, or make purchases for 

equipment upgrades.

And so, that year, in the Modification No. 5, you see 

an estimated, it's called Schedule A. In the Schedule 

A, there's estimated cost for what this equipment 

would be, you know, basically what their request 

was for the equipment.

So, for the 1956 payment, we actually took the 

payment for that year, seen in the SRDB reference 

quoted here, and subtracted the estimated money 

that they would receive for that equipment.

So, for this simulation that I mentioned, how we're 

going to go forward, is that we would randomly 

sample these four annual payment values. So, 

basically each of these annual payment values is 

considered equally, in terms of how we would 

simulate them. And they would -- it would be 

sampling with replacement.

The second input parameter here would be slab 

weight. And in Table 2 of our March response, we 

provide 56 average slab weights based on 

information in several different SRDB documents.

These documents, we had to use several references 

because there was no one reference that discussed 

the typical weight of slabs received by Superior 

Steel Company, or the typical weight of slabs that 

they would be rolling.

And there was no slab weight information in any of 

the references that we used for the next parameter 

either. So, this was a compilation of customs and 

shipping documents.

So, we have several customs and shipping 

documents that show total box weight with the 
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18

number of slabs in them. And so, that's what was 

used to complete Table 2 with the average slab 

weights.

What I would note is these would be weights at 

receipt, and not necessarily weights at, you know, 

while they were working with them, or what was 

leaving Superior Steel.

So, the simulation input, we assumed a log-normal 

distribution. So, you can see to the right, this 

histogram has average slab weight on the x-axis 

and frequency on the y-axis, so we looked at all of 

those average slab weights, binned them, and then 

determined a log-normal distribution for those slab 

weights.

So, the geometric mean was 234.2, and the GSD 

was 1.073. I would also like to note that this 56 

average slab weights covers a total of 606 slabs.

So, the last input here that was variable is the 

number of slabs rolled. In the March 2020 response, 

this information is provided in Table 1 and it's a 

compilation of different SRDB documents, again.

And these types of documents would be the Hassell 

Air Monitoring Data documents, where they mention 

how many slabs were rolled during the air sampling 

campaign, or we had one SRS technical report that 

discussed the rolling campaign that they had 

contracted with Superior Steel, and it gave number 

of slabs rolled.

As well as, a letter from Superior Steel to the Oak 

Ridge operating office, discussing specific rolling 

data, like temperatures that were -- temperatures 

they did the rolling at, thicknesses of the slabs, and 

different technical data for the actual rolling itself. 

Where we had numbers of slabs that we rolled 

during a specific time period.
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19

So, the simulation input for this data point here. 

Somebody isn't muted, if somebody could mute, 

that would be great, thank you.

Chair Ziemer: I think we're hearing sounds from a 

phone ending in 321, needs to mute.

Dr. Roberts: Yes.

Dr. Lobaugh: Thank you. So, the simulation input 

here was a triangular distribution. So, given the 

small amount of data that we had, triangular 

distribution seemed to be the best approach.

So, the lower limit of that distribution, we chose to 

use the minimum average number of slabs rolled 

per day, which was ten. And the upper limit we 

chose to use the maximum, which is 50. And the 

mode became the weighted average of the number 

of slabs rolled in a day, which was 28.14.

So, the simulation itself. So, how the simulation 

works is we want to calculate the number of rolling 

hours multiple times. So, here you'll see we 

repeated this calculation ten to the six times.

And what we do for each calculation, we're going to 

randomly sample from each of those input variables 

that we have variability in. So, we're going to 

randomly sample from the annual payments.

And that's going to be, like I said, we're going to 

count each of those equally, and we're just going to 

randomly sample the four payments themselves. 

For the number of slabs, were going to randomly 

sample that triangular distribution to come up with 

an input.

And then for the slab weights, we're going to 

randomly sample the log-normal distribution, and 

we're going to put those into that formula that I 

showed you before, to calculate the number of 
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20

rolling hours. And like I said, repeat this a million 

times.

So, what do we get? We get this histogram here. 

So, along the x-axis is the rolling time in hours per 

year, and the y-axis, again, this is frequency.

So, what this represents is the number of -- each of 

these bins represents 20, basically, hours per year 

broken up across the x-axis. And each time we got 

a number within that bin, we put, we made a bar 

graph, right, so we put a result in that bin.

So, what we can see here is this simulated 

distribution for that rolling time. The blue line, the 

first line here, the blue line, represents the 50th 

percentile of our distribution, which was 78 hours 

per year.

The next line, the dashed line, is the SC&A estimate 

that they provided. The red line is the 95th 

percentile of the rolling time distribution that we 

calculated, which was 267 hours.

The next dashed line, is the NIOSH proposal in the 

ER, which was 500 hours per year. And the pink line 

here, or magenta line is the maximum that we 

calculated when we maximized that equation and 

that's at 691 hours per year.

So our conclusion was, given the variability in those 

input values that we talked about, we really ended 

up having a large range of possible calculated rolling 

time in hours per year.

So, we thought the best approach would be 

simulating this rolling time, the rolling hours per 

year distribution, using all the available data and 

determining which parameter within that 

distribution was best.

So, our proposal was the 95th percentile of that 
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21

distribution at 267 hours per year, is what we would 

propose to use for the exposure time, that would 

then feed into our calculation of the internal and 

external dose, specific to the rolling time.

So with that, that is the end of my presentation.

Chair Ziemer: Thank you very much Megan. Very 

good discussion. Before we hear from Rose, let me 

ask the Work Group Members if any of you have 

any questions, any clarification on any of the slides, 

or other questions?

Member Beach: None here, Paul.

Chair Ziemer: Josie? Josie, okay.

Member Beach: I'm okay, thanks.

Chair Ziemer: Andy?

Member Anderson: No, my only issue is somewhat 

with the statistics that you used. There remains 

quite a tail on your distribution. So, the geometric 

mean and all, for -- that does help make it more of 

a normal distribution, but there's still quite a tail on 

that distribution.

So, I'm just wondering from your statistical people, 

are they comfortable on, this is the best you can 

do? Most of your statistics depend on a normal 

distribution, and you try to improve it by using a 

geometric distribution, but that doesn't shorten it all 

that much.

So, it adds, it just adds so much --

Chair Ziemer: So, was that a question or a 

comment?

Member Anderson: No, no, I'm just saying, that's 

my concern that we sort of routinely assume that 
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22

what we've done has been able to normalize the 

data distribution so that all the other parameters 

that are based on the assumption and normality are 

still adequate estimates.

I mean, if this is the best that you can do, but at 

some point, the distribution has to be remembered 

that it is really quite skewed.

Chair Ziemer: For the slab weights, you had the 

actual weights, so was that not correct? Yeah, the 

previous slide there?

Dr. Lobaugh: This one, on the -- oh, sorry, the slab 

one --

Chair Ziemer: Well, the diagram itself. Weren't 

those actual slab weight distributions?

Dr. Lobaugh: So, these were average slab weights 

based on the customs document information. So --

Chair Ziemer: Now, for example, at about where the 

mean is 234, it looks like there were like 30-some 

slabs of that weight? Is that, do I understand that 

right?

Dr. Lobaugh: Yes, yes.

Member Anderson: But on --

Chair Ziemer: So, in a sense --

Ms. Gogliotti: Average.

Chair Ziemer: -- in a sense those are actual values 

and that looks --

Dr. Lobaugh: Yes, I hear -- I think I just heard Rose 

say that they're average.

Chair Ziemer: It looks a little bit like a geometric, 

but the main bulk of those are pretty much a 
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23

normal distribution.

Dr. Lobaugh: Yes so, again, I will reiterate that 

these are average weights. So, we really only had 

total weight for a whole box, which would have 

multiple slabs in them.

So, we didn't have individual slab weights, but we 

would have weights for, say, nine slabs, weights for 

ten slabs, and so this represents actually represents 

average weight, yes. I think I heard Rose say that.

Member Anderson: But I would, on your bottom 

scale there, if the geometric mean is 234, okay, I 

see. Okay, fine. I'm just, I mean that's just 

something to keep in mind when you look at that: 

how confident are we in that because it impacts all 

of the subsequent modeling that's done, but that's 

okay.

Ms. Gogliotti: It does. If you want me to go through 

my evaluation of it, maybe I can give you more 

confidence in it?

Member Anderson: Okay, that's fine, yeah.

Dr. Lobaugh: I'll stop sharing now.

Member Anderson: If that's the best you can do, 

and I'm comfortable with it, I'm just raising the 

issue, because you got to keep in mind when we're 

very heavily dependent upon modeling, and random 

sampling, and all this kind of thing, we have to look 

at what are the underlying assumptions on the 

distribution of the data.

And that's just a caution I always look at.

Chair Ziemer: Okay, thank you. Let's see, Bill Field, 

did you have a question? Was Bill on the line?

Dr. Lobaugh: I don't think he's on the line.
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24

Chair Ziemer: Oh, okay. I thought I saw his name 

here before. Okay, good. Are we ready to go on and 

hear from Rose?

Now, Rose had asked me before whether she should 

prepare a PowerPoint. And we made the decision 

that what could be done here rather handily since 

SC&A's in -- pretty much aligning with the NIOSH 

approach, that she just might use the matrix itself.

Now, the matrix is pretty extensive it has all the 

other things that we've done over the years on 

Superior Steel, but I think we're going to start, I 

think Rose -- oh, I see it on the screen now. Rose, 

you're going to start with your response which is 

SC&A response for, in March 2021, which is the 

response to what we just heard, is that correct?

Ms. Gogliotti: That's correct.

Chair Ziemer: Okay, why don't you proceed then?

SC&A Presentation by Rosanna Gogliotti

Ms. Gogliotti: Okay. Well, as you know SC&A, we 

really initially just proposed a value of 253 hours 

per year rolling. And that was based on a really 

quick calculation, common sense values, to try and 

bound the number of rolling hours that could have 

possibly taken place in a single year.

And NIOSH came back with their simulation that 

Megan just, did actually a really great job of 

summarizing a fairly complicated simulation.

And their simulation came back with 267 hours per 

year, which right of the bat, we're very close. That's 

somewhat to be expected since we're using the 

same data to estimate the same value.

So, I was happy with that. And first off, I thought it 

was important to try and replicate their calculations 
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25

by using the values that were presented in the 

NIOSH, March of 2020 response.

I attempted to recreate their simulation and I got a 

very close value, but it wasn't the same exactly. So, 

I questioned Megan, and she very quickly sent me 

their R files, as well as their CSB files that were 

done to support their calculation.

And when I looked at those it was clear that the 

only difference was really a minor difference. 

They're modeling a log-normal distribution and seed 

value, the random seed that was chosen for the 

simulation.

So, that gave me confidence in their numbers. 

However, I did go through and look at each of the 

parameters independently, because I think that's 

important since they're the basis for the simulation, 

it's important that we establish that the right 

numbers line up.

And Megan had up previously her Slide 13, which is 

the equation that was used in the simulation. Here I 

broke down by each parameter in it, first being the 

annual payments.

As Megan mentioned, there were four annual 

payments that were known, these are the values 

from 1954 through 1957 with the modification that 

she mentioned.

For 1956, for the Schedule A reimbursable expenses 

were subtracted out. I will mention that the contract 

also stipulated that they were eligible for 

reimbursement for 50 percent of a slab furnace, as 

well as security costs.

And since we don't really have a good way of 

estimating those values, and they weren't 

specifically stated in the contract, we just ignored 
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26

them, which essentially gives you a higher value in 

the calculation.

So, that's a higher value that ultimately calculates 

more rolling time than perhaps was possible. So, 

that's a conservatism immediately built into the 

model, and I think that that's appropriate.

I will note that we do not have values for 1952 and 

1953, which are the first two years of the covered 

period. We don't have any reason to suspect that 

they were doing more rolling at that time than they 

were in the later years.

And actually, the core values that we have, sum to 

the known contract expenditures that were reported 

in later reports and AEC. So, I think that, in all 

likelihood, that those two years' payments were 

covered by the prior year, or previous year's 

payments. So, that also builds a level of 

conservatism into the model, and I think they're 

easily bounded by those four numbers.

Moving on, the cost per pound. NIOSH has seen a 

constant cost per pound of $1.01 per pound of 

uranium. That value comes from Contract 

Modification 5, that we've discussed.

As we know, the contract allowed for additional 

services provided that could add up to 13 and a half 

cents per pound of uranium. We don't know how 

often those services were provided. I think it's 

reasonable to assume that they were provided to 

some scale but what proportion would really just be 

a guess.

So, using the lower value, I think, is appropriate 

here. That is the numerator in the equation, so if we 

were to add those values in, it would actually 

decrease the projected rolling hours.
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27

So again this, this just helps to make sure that we 

are really bounding the number by not using that 

additional.

Okay, and the next parameter would be the number 

of slabs rolled. And what NIOSH did here was they 

used a triangular distribution of the known values 

from Table 1. And Megan showed those previously. 

And there was a minimum of ten slabs rolled and a 

maximum of 50, based on that table.

I did go in and look at the table in detail and look at 

the references that were contained in it, to make 

sure, one, that they were accurately represented. 

And two, to make sure that it was all-encompassing 

of the data that we have, the known data that we 

have available. And I did feel that that was 

appropriate.

I do note that one of the values, the maximum, the 

50 slabs rolled per day, I believe that is likely 

referring to multiple slabs being rolled at that time, 

based on looking at the data.

There are time stamps on it that indicate that 

multiple things were happening at the same time, 

which doesn't really seem possible given the 

parameters that we know at the site. But since it 

was referred to the August 3rd rolling, I think it's 

reasonable to assume that they were all from the 

same day.

For the sake of this, leaving it in actually increases 

the rolling hours, if we were to remove it; as the 

denominator, it would lower the denominator again, 

and reduce a smaller estimate of, of hours.

So, for a bounding calculation, it's very reasonable 

to leave this value in. I think there is some 

uncertainty with it. I also think it was very 

reasonable that they selected the triangular 
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28

distribution, given the limited number of data points 

that we have available.

For daily rolling time, as Megan mentioned, they use 

constant ten hours' rolling time per day. I could not 

find any clear documentation indicating the number 

of hours that were spent rolling at any given time.

I think it's safe to assume that that number 

probably fluctuated based on throughput of that 

individual day, but NIOSH just used a constant.

I did do some digging and I found that the contract 

does stipulate that no one supporting the contract 

was allowed to work in excess of eight hours per 

day, unless they were compensated for a rate of 

one and a half times that base rate of pay.

And I believe that might have been incentivized 

completing work within a standard eight-hour day, 

but again there is no definitive evidence. So, I think 

it's very reasonable to select ten hours, and that's 

consistent with what's selected for other AWE 

facilities.

Okay, an average slab weight. This one as you could 

probably tell from Megan's graph was the most 

complicated by far. And the data that they had 

available was 56 groupings of slabs. So really, they 

only knew the total weight of the grouping and the 

number of slabs in that.

And so, NIOSH used that to calculate the average 

slab weight. And because there was a fair amount of 

variability in that data, they fit it to a log-normal 

distribution, and then the fitted distribution was 

sampled from in the simulation.

Now, to evaluate this, I had to go to their R code. 

And in their R code, which I wish they would have 

included the plot here, but they included the QQ-
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29

plot that showed representation of their simulated, 

or fitted data, with their real data.

And if you're not familiar with the QQ-plot, it's 

essentially a visual, or graphical representation of 

how well your data fits a theoretical distribution. In 

this case it would be a log-normal distribution.

So essentially, it's just a scatterplot, plotting two 

sets of quartiles against each other, and if the 

points form, essentially, a straight line, it tells you 

that they're in good fit. But if they don't form a 

straight line, it tells you it's not really a good fit for 

your model.

And overall, looking at the data, it does look like it's 

a very great fit. As Andy pointed out, though, there 

is a long tail on the data, such that the upper points 

weren't very well modeled by the log-normal 

distribution.

There's not to say that's a problem, but because 

that existed, I thought it was important to dig a 

little deeper. So, I remodeled the simulation data 

that Megan provided, saving the inputs, to see how 

this simulation was actually performed, or how this 

data came out in the simulation.

What I found is that it actually modeled a minimum 

of 169 pounds and a maximum of 325 pounds, and 

that's a little bit different than the data that we had, 

which estimated a maximum -- or a minimum of 

198 and a maximum of 533.

And so, what that means is essentially six of our 56 

averages fell outside of the window that were being 

modeled, or 70 of the 606 slabs. So, roughly 12 

percent of our data fell outside of what was 

modeled.

And initially, I think that sounds somewhat 
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30

alarming, but then I thought, looking at the data, 

it's important to keep in mind what it actually 

represents.

We have data on average slab weight at receipt, 

and it's being put into the equation as if it is the 

same as the average daily rolling weight per year.

Now, based on the Central Limit Theorem, we know 

that essentially irrespective of the distribution of the 

actual population of slabs, we know the distribution 

of samples. In this case, the average annual slab 

weights should approach normality.

In other words, we know that when we're sampling 

at multiple times, the average of averages are going 

to eliminate, essentially, the really high extraneous 

values. So, the high end's very low values are 

essentially going to be muted once you're doing the 

average of an average.

And so, in order to test this, I did my own 

simulation. This is a cursory test of their values. 

Using the simulated slab weight data from Table 2, I 

essentially simulated 606 slabs -- excuse me, 

assuming that each line in the data represented 

weights.

So essentially, I simulated a normal distribution, for 

each line, assuming the number of slabs equaled to 

the number of slabs, and the mean of the normal 

distribution equal to the total weight at receipt, 

divided by the standard -- divided by the number of 

slabs, with a standard deviation of five.

From that simulation, I generated 606 simulated 

slab weights, and I sampled from that, repeatedly, 

using the same distribution that NIOSH suggested, 

which was a triangular distribution for the number 

of slabs that were rolled per day.
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31

And from that average, I found that there were a 

range of 214 to 341 pounds of uranium, which is 

not really that far off from what NIOSH simulated. 

169 versus 325, max.

So that suggests that there is a much smaller range 

than the data initially shows. So I think it's very 

reasonable, the range that NIOSH went with in this 

particular instance.

So putting all of this all together, NIOSH suggested 

that the annual range should be from 14 to 691 

hours. When I looked at the simulation, it actually 

predicted 26 to 715 hours. I think that's very 

reasonable, and you would expect so much of a 

difference, looking at how the values were 

simulated that went in.

I think these differences are very modest and 

reasonable, given the large uncertainty in the data. 

You can keep trying to polish it, but I don't think 

you're going to get a better number at the end of 

the day.

So in conclusion, if NIOSH wants to use this 95thpercentile value, I think it's bounding and 

reasonable for all years of operations. So, I would 

recommend accepting this number.

Workgroup discussion

Chair Ziemer: Thank you very much, Rose. I 

appreciate your review of that and, let me again, 

open it to the Work Group for questions or 

comments, or anything need clarification on this 

information? Josie?

Member Beach: I do not have any questions. I 

thought I did, but I went through my notes as Rose 

was talking, and clarified the answer. It was on that 

surrogate data slide of NIOSH's, but I'm -- so, I'm 
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32

good Paul, thanks.

Chair Ziemer: Oh good, okay. And how about Andy? 

Further clarification or comments?

Member Anderson: No, I think it's very -- I didn't 

get a chance to read this all before the meeting 

here. So, yes, I bet, this is good, it's very helpful to 

have that. Again, it's just the uncertainty, there is a 

fair amount of uncertainty in the data. And I think 

this is the best one can do.

Chair Ziemer: Okay. And again, I appreciate the 

analysis that both groups have done, and actually 

although, although perhaps we would like further 

detail on the data, we do have data. And we do 

have the information on the average slab weights, 

we have the information on the spread of the hours.

So, we have data from the site, so it gives more 

assurance that we're really not doing a surrogate, 

complete surrogate thing here, we're actually using 

site data. So, that's very helpful and fairly 

reasonable.

And I think when all is said and done, and using the 

95th percentile, gives us good confidence that we 

have bounded the data. Particularly with the 

assumptions that are made and built into the final 

number.

The recommendation from SC&A is that we accept 

the NIOSH proposal to use, what's my own number 

267, 267 rolling hours for bounding. And I would 

ask if any of the Work Group Members object to 

accepting this recommendation?

Member Beach: Just a quick question. So, the 267 -

-

Chair Ziemer: Sure.
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Member Beach: -- the 267 hours, that is going to go 

from 52 to 57, is that correct? Is it going to be a 

steady all the way across?

Dr. Lobaugh: Yes, that's what we proposed. To use 

267 for each of those years during the contract, 

mm-hmm.

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

you.

Chair Ziemer: Yes. So, that any -- let me ask you a 

quick question Megan or maybe Tim Taulbee, how 

many claims have been processed already for 

Superior? I have that somewhere, but it's not before 

me, or do you know off hand?

Dr. Lobaugh: At the time of the ER, it was about 52, 

if I remember correctly. I have not checked recently 

to see if there's been additional.

Chair Ziemer: And do we have a number of these 

that we have to go back and redo them?

Dr. Lobaugh: Well so, through the PER process --

Chair Ziemer: Yes.

Dr. Lobaugh: -- once the TBD is updated, it would 

be each of the claims that were not compensated 

would be reviewed to see if this would affect their --

Chair Ziemer: Yes. So, we have a number of them, 

probably, that will be re-reviewed then on the 

process.

Dr. Lobaugh: Yes, yes.

Dr. Taulbee: Yes.
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally 

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

34

Work Group Recommendation for Closure-Finding 

#1

Chair Ziemer: So, I hear no objections from the 

Work Group to accepting the recommendation from 

NIOSH, and I personally agree with that as well. 

And so, we'll let the record show that the Work 

Group recommends closure of Finding 1, and I 

believe that completes all our issues on this 

particular matrix.

Member Beach: I think, I think --

Chair Ziemer: Oh, do we --

Member Beach: -- Observation 1 --

Chair Ziemer: We have any -- oh, do we have 

some, yes we do have some observations.

(Simultaneous speaking.)

Ms. Gogliotti: Observation 1 is still open, but it's 

kind of a moot point, and we left it open just in case 

we were not able to resolve Finding 1. But now that 

we have resolved Finding --

Chair Ziemer: Right, we can actually -- yeah, you're 

pulling it up here now.

Yeah, that was -- that issue of using the source 

term based on contract billing data.

Ms. Gogliotti: From another site, correct.

Chair Ziemer: And yeah, and whether the Board 

should weigh in on that? Now, actually what we're 

using, we're determining working hours and work 

time, which is a valid thing.

We're not using the (audio interference) we're using 

the billing. But at least to me, using that to 

determine work hours is like other documents we 
This transcript of the Advisory Board on Radiation and Worker Health, TBD 6000 Work Group,

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

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

35

use on other sites and sometimes from contracts, to 

establish worker work times.

I think we've done that at other places, certainly did 

some of that even at General Steel, but any of the -

-

Ms. Gogliotti: Well, I think that this observation had 

to do more that they were using Vulcan Crucible 

billing rate.

Chair Ziemer: Yes, but --

Ms. Gogliotti: They're not using that anymore.

Chair Ziemer: -- that's not really an issue anymore, 

so.

Member Anderson: It's now moot.

Chair Ziemer: Yes, moot point.

Member Beach: Rose, Rose, when I looked at the 

BRS yesterday, I didn't notice that observation in 

the BRS. So, when it was in your paperwork, so you 

might check --

(Audio interference.)

Path Forward Report on Finding #1 at next full 

Board Meeting

Chair Ziemer: Are there any other issues related to 

Superior Steel that we need to discuss? If not, I'll 

ask Rashaun Roberts, do you want us to report on 

this at the upcoming full Board meeting?

Dr. Roberts: Hi, Paul.

Chair Ziemer: I don't think it takes any Board 

action, but we can report on it.

Dr. Roberts: Sure. We can certainly do that. The 
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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally 

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

36

question is how would you prefer to do that. Do you 

want it to be a part of the Board work session, 

where you just do a report out, or an item on the 

agenda?

Chair Ziemer: I think I can report on it. This is 

simply closing a final finding on the Site Profile. I 

don't think the Board has to take action on it. So I 

think, since it's just a single finding, I think it would 

be simple for me just to report it out at that time, it 

wouldn't have to be an agenda item.

Dr. Roberts: Okay.

Chair Ziemer: Let me ask if the other Board 

Members are comfortable with that, other Work 

Group Members?

Member Beach: Yeah, Paul, I am. That should work.

Chair Ziemer: You're okay on that, Henry?

Ms. Gogliotti: I think we lost him.

Chair Ziemer: Okay. I see you there, Henry, but 

you're --

Member Beach: He gave you a thumbs up.

Chair Ziemer: A thumbs up, okay, very good.

Member Beach: It's the new yes.

Chair Ziemer: Okay. My grandfather clock is 

chiming in the background. I guess that's a 

reminder that we're almost done with the Work 

Group here.

Okay, Rashaun, I believe we're done, if you have 

any final comments or items you need to present 

before we sign off here?

Dr. Roberts: No, that does it for me. I just wanted 
This transcript of the Advisory Board on Radiation and Worker Health, TBD 6000 Work Group,

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

identifiable information has been redacted as necessary. The transcript, however, has not been 

reviewed and certified by the Chair of the TBD 6000 Work Group for accuracy at this time. The 

reader should be cautioned that this transcript is for information only and is subject to change.

37

clarity on how you wanted to deliver your report on 

the, to the Board and we've resolved that. So, I 

think we're good to go.

Adjourn

Chair Ziemer: Okay. Thank you, everybody, and 

thanks to the other staff members who've provided 

support to both to Megan and to Rose, and the work 

for today. And we will look forward to seeing or 

hearing from you all in the upcoming Board 

meeting. So we are adjourned.

(Whereupon, the above-entitled matter went off the 

record at 11:32 a.m.)