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

Uranium Refining AWE Work Group

Thursday, January 30, 2020

The Work Group convened telephonically at 9:30 

a.m. Eastern Time, Henry Anderson, Chair, presiding.
2 

Present: 

Henry Anderson, Member

William Field, Member

David Kotelchuck, Member

Also Present: 

Ted Katz, Designated Federal Official

Nancy Adams, Niosh Contractor

David Allen, NIOSH ORAU

Matthew Arno, NIOSH ORAU

Robert Barton, SC&A

Elizabeth Brackett, NIOSH ORAU

Ronald Buchanan, SC&A

Rose Gogliotti, SC&A

Karen Kent, NIOSH ORAU

Matthew Smith, NIOSH ORAU

John Stiver, SC&A

Timothy Taulbee, NIOSH ORAU

Thomas Tomes, NIOSH ORAU
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Uranium Refining AWE 

Work Group Thursday, January 30, 2020 1

Welcome and Introductions 4

Accuracy and Completeness of Records 6

Insufficient Uranium Intake Data 14

Plutonium Doses Are Not Consistent With the 

SEC 16

Lack of Neutron Dose Assignment 29

Adequacy of Environmental Dose 41

Observations and Secondary Findings 49

Report to Board 51

Adjourn 56
4

Proceedings

(9:30 a.m.)

Welcome and Introductions

Mr. Katz: Well, it's 9:30, and I know all my Board 

Members are here, the three. Let me get the 

preliminaries rolling here. So welcome, everyone. 

This is the Advisory Board on Radiation and Worker 

Health. It's the Uranium Refining AWE, which is 

Atomic Weapons Employers Work Group.

And our Work Group today is discussing the review, 

its review of a Site Profile for W.R. Grace in Erwin, 

Tennessee. So, which has been in progress for a 

while.

So the three Board Members, Henry Anderson, Dr. 

Henry Anderson is the Chair, and he's here. And then 

I have Dr. Bill Field and Dr. Dave Kotelchuck, and 

they are both here, Members.

We're speaking about a site so we always address 

conflict of interest where there may be for members 

of the staff and Board Members. The work groups 

don't by definition have conflicts or they wouldn't be 

on the work group. So I don't need to address that 

for them. But let's go on to then the staff for this 

Work Group, and please address conflict of interest 

as we go. So let's begin with NIOSH ORAU staff and 

see who is here.

(Roll call.)

Mr. Katz: Then let me just remind everyone, except 

when you're speaking, please mute your phones for 

everyone else's benefit. If you don't have a mute 

button, use *6 to mute your phone, *6 to come off 

of mute. And please no one use hold. Hang up and 

dial back in if you need to.

Okay, so, Andy, are you back?

Chair Anderson: I am back.
5

Mr. Katz: Okay, great. So we sort of have 

arrangements between NIOSH staff, Tom and Ron 

Buchanan, about presenting, but, Andy, you want to 

get this rolling?

Chair Anderson: Yeah, basically this is not a review 

of the SEC, but rather to bring really the 

determinations and information in the SEC into -- to 

be consistent where the TBD is consistent with the 

information that's being used for the SEC.

So there were a number of reviews back and forth, 

and so we're, I would hope we're pretty near the final 

conclusion, or at least that's the hope. SC&A and 

NIOSH have been communicating back and forth. 

We've had some White Papers and some other 

responses, so let's begin to go over their -- finally I'm 

up and running here.

So I think, Ron, which of you I guess --

Mr. Katz: Tom starts for this one.

Chair Anderson: Okay, Tom starts for this one?

Mr. Katz: Yeah, Accuracy and Completeness of 

Records.

Chair Anderson: Okay.

Mr. Stiver: Hello, this is Stiver. I just got on a little 

late.

Mr. Katz: Welcome, John.

Dr. Taulbee: Hey, Tom, are you still on?

(Simultaneous speaking.)

Mr. Katz: Might be on mute.

Participant: He's talking to himself.

Mr. Tomes: I was talking away on the mute button. 

Sorry about that.

Dr. Taulbee: Okay.
6

Mr. Tomes: Okay. I thought I would start with a little 

background on the facility just briefly, just to, since 

we haven't met in quite a while, just to review that.

W.R. Grace is an Atomic Weapons Employer facility 

from 1958 through 1970. The residual contamination 

period is from '71 through March 2011. And the listed 

period is for their work, contract work with the AEC 

to recover enriched uranium from unirradiated scrap.

In the listing it also mentions that they did work for 

the civilian nuclear reactor industry. And they did 

Naval Reactors Program work. The site is currently 

called Nuclear Fuel Services, which is presently 

owned by BWXT.

Some of the work they did in the 1960s, besides the 

AEC contract work, was mixed oxide fuel work for the 

Shippingport reactor, which involved thorium and U233 mixed oxide fuels. They also used some U-233 

zirconium oxide fuels.

And the SEC from 1958 through 1970, the facility is 

based on the inability to reconstruct thorium doses. 

And the thorium doses are not applicable in the 

residual period since it has not been identified as a 

weapons related program.

Accuracy and Completeness of Records

Okay, I'll move on to Finding 1. And I'll just read the, 

briefly the wording of the Finding here on the 

accuracy and completeness of bioassay records not 

being addressed.

"The accuracy and completeness of the recorded 

bioassay data have not previously been addressed by 

either DOE or NIOSH as part of a routine verification 

and validation database review. SC&A performed a 

preliminary scan of the DOE files and found -- for a 

small sampling of claimants and did not identify any 

outstanding issues."

"However, a broader and more detailed survey 

should be conducted that would determine if workers 
7

who should have been monitored because of job title 

and/or location have recorded bioassay data for the 

corresponding periods when working in these areas."

During a previous Work Group meeting in August 

2015, this was discussed. And at that time NIOSH 

responded that we have no bioassay records from the 

site until late 1964. So that's known to be deficient 

in that period. And we have no bioassay data for 

thorium, which was the basis for the SEC.

We do have some plutonium bioassay data available 

for claimants starting in 1967. And so at that time we 

decided that we needed to do more evaluation to 

determine if the data we have in later years is 

sufficient.

And specifically, we determined that we needed to do 

another evaluation to see if the workers' bioassay 

data in 1991 and later was sufficient to reconstruct 

intakes of uranium.

That -- the basis for the 1991 date is the fact that 

during the residual period the TBD has default intakes 

from residual contamination calculations, but in 1991 

the TBD requires us to reconstruct intakes from 

workers who were exposed during remediation of 

burial grounds.

The assumption there is that the material in the burial 

grounds was commingled with covered and 

uncovered materials, and there's no means to 

distinguish between the two.

And we also determined that we needed to do a 

review to see if the plutonium bioassay data is 

sufficient for reconstruction of plutonium intakes. 

This we'll be discussing in more detail with Finding 3 

later.

So specifically this paper that we issued in August of 

2019 is the results of our review of the bioassay 

records in NOCTS. That was issued after we reviewed 

all claimant records.
8

First, I'd like to provide an overview of what we found 

out from review of the records. Most of this 

information comes from our observations out of the 

database. But we did supplement that with 

information from the Site Research Database on the 

site.

Starting in the fourth quarter of 1964, most workers, 

most claimants in NOCTS had multiple bioassay data 

for uranium in all years through 1993. 1993 we see 

a change in the way workers were monitored for 

uranium.

And this, there was a few workers who did not have 

bioassay, but they are -- it's just a few, and they 

were -- and their job titles indicate they were 

typically office workers and not expected to be 

routinely exposed.

And there are a few claims for which you would 

expect the workers to have bioassay data in NOCTS, 

but they do not. And I'll discuss those here in a few 

minutes.

For the -- the reason we do not need plutonium 

bioassay data prior to 1990 -- I mean excuse me, 

uranium bioassay data prior to 1991. The TBD has, 

besides the residual contamination intakes, also has 

default intakes of uranium, so for the operational 

period. So we have a means to assess intakes of 

uranium all the way through that period.

I'll go on to the other, the rest of the monitoring 

program -- excuse me here for a second. I have to 

get my thoughts together.

As I mentioned the data for 1993 shows that most 

workers were monitored with multiple records in 

every year. In 1993 the routine program appeared to 

have ended. And I believe that was due to a scaleback in work at the site. And there, however, there 

were -- some work continued.

From -- and then starting in 1994, we see a 

resumption of a bioassay program. The bioassay 
9

program that was resumed in -- excuse me, 1997, 

was more selective. Not all workers were monitored. 

That's apparent from reviewing our claims in NOCTS.

However, we do not really know the criteria they 

applied to determine whether an operator would get 

monitored or not. So we found out that 

approximately 43 percent of the claimants have 

bioassay data for uranium in that period.

Whereas earlier it was nearly all workers who were 

exposed with the exception of some office workers 

who would typically not be exposed. So that was just 

an overview of the uranium bioassay program.

The plutonium bioassay program, the data starts in 

1997. And there are multiple claimants with data 

starting in 1967 and that data's scattered pretty 

evenly throughout through 1973 when the plutonium 

operations ended.

Past 1973 we do not see any routine programs for 

plutonium bioassay. However, we do see some 

bioassay, plutonium bioassay for workers who, or at 

least one worker who was on a routine long-term 

monitoring program due to an incident earlier.

So basically our Pu bioassay program on a routine 

basis ended with the end of plutonium production. 

And plutonium production never resumed at the 

facility. It was in standby for many years prior to 

D&D.

We also looked at in vivo monitoring programs. We 

noticed that many workers have in vivo chest count 

data starting early 1970s. It was performed by a 

contractor and used a phoswich detector. NFS 

constructed a modern facility with germanium 

detectors, an array of four detectors, I believe it was, 

that became operational in 1987.

And from 1987 forward most all workers have annual 

chest counts. And this period would cover the period 

of the plutonium facility D&D, as well as the period of 

remediation of the burial grounds.
10

That system was an on-site system ran by Canberra. 

And all the claimants have detailed reports of their 

examinations, which include P search results. 

Identifies the nuclides they were looking for and the 

detection limits for the various nuclides, including 

plutonium, americium, uranium, the nuclides that 

were of interest in this review.

In addition to the chest count data and the urinalysis 

data, claims we received has other monitoring data. 

Starting in 1994, which coincides with the end of the 

prior uranium bioassay program, all of our claimants 

have NRC Form 5 dose reports sent to us.

And many of those, quite a few of those have intakes 

on various radionuclides and units of microcuries 

listed -- reported to NRC. These are supplemental 

data that may be useful. But our primary data will be 

the bioassay and in vivo data.

In addition to that we do have some personal air 

sampling data for some of the claims. Some of them 

quite a few. Some of them are sparse. They're just 

some, there was not a complete database of all 

workers being tracked. But we do have a number of 

supplemental data in the files for that in case they 

are useful for dose reconstructions.

Based on all of that data, we went to look specifically 

at that data and see if we could verify that it was 

sufficient for our purposes for dose reconstructions. 

The most obvious data that was the most, broadest 

conclusion, the most people was our in vivo data.

We had a number of, most of the workers had 

uranium bioassay through '93, but there was that 

period when there was no uranium bioassay. And 

then the later period there was only partial bioassay 

data. But we determined that the in vivo data for 

chest counts was sufficient to reconstruct intakes or 

bound the intakes of uranium.

And likewise for the plutonium work, the in vivo data 

has chest count NDAs for americium-241. However, 

those could be useful, but however, for the workers 
11

on the plutonium D&D project from '90 to '93 they 

had quarterly fecal/urine bioassay data for 

plutonium, thorium, and uranium. So there is a 

substantial amount of monitoring during the D&D 

period for workers who were exposed.

So based on these reviews, and there are statistics 

I've provided in the White Paper which I will not go 

into unless that's requested, but we determined that 

the data on -- the in vivo data alone is sufficient to 

determine that we can reconstruct -- that the 

workers who should have been monitored, were 

monitored. And it's sufficient for us to reconstruct 

doses.

In many cases, the other bioassay data will be more 

sensitive and used. And so we concluded that this 

finding can be resolved by that review that we have 

done.

And I would say that this review was done, actually 

this review of the bioassay records started a few 

years ago and it was gradually added onto it when 

more claimants became in the system. So we cut off 

in May of last year, looking at claims. This is all the 

claims that we had in NOCTS as of May of last year.

So it's a pretty extensive amount of records, 200 and 

something records. I don't have the number, 200 and 

-- I have it here somewhere, 200 and something 

claimants that we've reviewed in detail. And the files 

are typically a hundred pages or more long. Some of 

them are just a few depending on how long the 

people worked there.

And after we submitted that SC&A reviewed our 

reports. And they spot checked records to verify our 

methods, conclusions, and concurred that the -- with 

our conclusions. They noted that three -- oh, this is 

one I mentioned earlier. SC&A noted in their report 

that there were three claimants that records in 

NOCTS appeared to be lacking.

During that review of all the workers that indicated 

to us they should have been monitored, we found 
12

three workers who did not have bioassay data in the 

period under review in NOCTS. And based on looking 

at those claims, it appeared to us that those workers 

may not have had complete data sent to us from the 

NFS.

And one of them, there was an indication that he was 

monitored but for some reason only a special form 

was in there, not the actual bioassay data itself.

So we sent a special request back to NFS on those 

three claims. They responded back to us, two of 

those claims, they found the files and sent extensive 

data that was sufficient for estimating intakes for 

those workers.

On the third one, they failed, they responded back to 

us saying that the worker was monitored, but they 

couldn't locate the file. And so I looked at that claim. 

And this was a claim that we have a few bioassay 

results.

This is the one where we had a form in the file that 

showed some bioassay results where they evaluated 

him. But there was no typical forms that they send to 

us that had all the results.

And I read the CATI, and the worker indicated that 

he was monitored. This particular claim did not need 

further work because he was compensable based on 

the values in the Technical Basis Document.

And the other two claims that they found data for, 

they will eventually get reworked once the TBD issues 

are resolved.

And that's all I really have about Finding 1.

Chair Anderson: Any questions?

Member Field: No.

Member Kotelchuck: No. This is Dave.

Chair Anderson: Okay, let's move on then.
13

Dr. Buchanan: Okay. This is Ron Buchanan of SC&A.

Mr. Katz: Well, Ron -- Andy, do you want to -- I mean 

so we have the --

Chair Anderson: So do we want to close it out?

Mr. Katz: Yeah, do we want to, I mean -- Ron, unless 

there is, is there anything you want to add to Tom's 

summary?

Dr. Buchanan: Yes, I just wanted to say that we went 

through this data. And it's pretty length; we can't 

present it all here. But we went through and verified 

and spot checked, and verified their conclusions and 

agree with it. And so we recommend that we -- we're 

satisfied, would recommend closure.

Mr. Katz: Okay. So then I think --

(Simultaneous speaking.)

Mr. Katz: -- decide if you want to close this or not.

Chair Anderson: Okay. So I think everything's been 

covered. One of the other Board Members want to 

make a motion that we close this?

Member Kotelchuck: So moved, Dave.

Member Field: Second.

Chair Anderson: Okay, so we're all set then. Anyone 

object, speak up, if not, thanks to both groups. I 

think we went over this pretty thoroughly. There was 

a lot of information there to discuss.

Okay let's move onto question two.

Dr. Buchanan: Okay. Again this is Ron, and I'm going 

to present some slides, but I haven't tried this before. 

So I -- it says here presenting. Now someone can tell 

me how I get that slide I want loaded on here.

What do I click to share my PowerPoint presentation?

MS. GOGLIOTTI: Ron, you should be able to just 
14

share your screen. And that would show up for 

everyone.

Dr. Buchanan: Okay. Share screen, I've got that. And 

then if I click on my presentation, now do you see an 

SC&A slide?

Dr. Taulbee: Yes, we do.

Dr. Buchanan: Okay.

Participant: Yeah.

Insufficient Uranium Intake Data

Dr. Buchanan: Okay, good. Okay so this is current 

status, W. R. Grace TBD Finding 2. And so we see 

that we reviewed the TBD in -- 43 in 2013. And the 

Finding 2 was insufficient uranium bioassay/intake 

data. And this kind of dovetails with Finding 1. But at 

the time we reviewed this it was somewhat two 

separate issues.

One was V&V and the other was the data that was 

hinged mainly on, we questioned the use of a 1961 

air concentration for the entire operation period. And 

so we recommend additional investigation of the 

1961 data for the '58 to '70 era. And plus there was 

a residual era after that.

And so there are two periods, '58 to '70, and then 

residual '71 to 2011. And NIOSH's approach to 

resolve the intakes for these two periods was 

discussed during the Work Group on -- during the 

teleconference in 2015 and accepted.

However, it was a bounding approach, and so the 

Work Group recommended that NIOSH further break 

down the intake by worker category because this was 

a bounding, that would be the maximum. So they 

wanted to break it down to other, such as office 

workers and such.

So NIOSH issued a paper in July of 2019, and they 

called it NIOSH Resolution of W. R. Grace Site Profile 

Findings 2 and 7. So we'll see this again when Tom 
15

covers Finding 7. They incorporated their White Paper 

-- incorporated both Findings.

And the White Paper provided for inhalation and 

ingestion intakes by the worker's category, such as 

operators, office workers, or laborers and such. And 

so we see that Table 1 of their White Paper covers 

the first period. And Table 2 covers the residual 

period form '71 to '11.

So SC&A reviewed their White Paper and issued an 

evaluation report November 2019. We analyzed the 

derivation of NIOSH's intake values in conjunction 

with TBD-6000 of 2011 to determine if it was based 

on the right assumptions.

And we evaluated the first period, '58 to '70. And we 

concurred with the values derived, which is in Table 

1, Page 6 of the White Paper, which would be -- was 

the final results of that analysis. And we checked 

those calculations and assumptions and agree with 

that.

And the residual period '71 to 2011, again we 

analyzed this data in conjunction with TBD-6000 and 

agree with the values listed in Table 2, Page 7 and 8 

of the White Paper for the residual period. And in 

conclusion, SC&A found that NIOSH sufficiently 

addressed Finding 2 concerning uranium bioassay 

and intake data.

And we had no further issues concerning this Finding. 

So we would recommend that this would be closed 

since it's been satisfactorily addressed. Open for 

discussion and questions.

Chair Anderson: Any comments from NIOSH or the 

Board Members?

Mr. Tomes: This is Tom. I have no additional 

comments. I believe he covered our position on that 

fairly well.

Chair Anderson: That's what I thought too. So, Board 

Members, so everyone comfortable closing this out?
16

Member Field: Yes, I think that's fine. Make a motion 

to close, Bill.

Chair Anderson: Okay. Need a second? I'll second it, 

and I think we're all in agreement, so officially we'll 

close this, consider it completed.

Okay. So now let's move on to -- let's see what do 

we have?

Mr. Katz: Plutonium. This is Tom Tomes again.

Chair Anderson: Yeah.

Plutonium Doses Are Not Consistent With the 

SEC

Mr. Tomes: All right, Finding 3, this is a White Paper 

issued for Finding 3 that is fairly detailed. It's a 41 

page paper, and it has our coworker analysis in it. 

This was to address assigning --

(Simultaneous speaking.)

COURT REPORTER: Sorry to interrupt, this is the 

Court Reporter. Excuse me, who is speaking right 

now?

Mr. Tomes: Yes, this is Tom Tomes, speaking.

COURT REPORTER: Thank you very much.

Chair Anderson: Sure, Charles. Okay, go ahead.

Mr. Tomes: Finding 3 was the plutonium doses during 

either period are not consistent with the SEC.

A little background on some more information on this 

particular finding. It was discussed in the previous 

Work Group meeting. The TBD, our Technical Basis 

Document has instructions to assign plutonium based 

on bioassay if they are available in the AWE 

operational period from 1958 through 1970. And it 

doesn't -- and it did not consider that plutonium is 

covered in the residual period.

So as I mentioned earlier, the plutonium was 
17

commercial fuel projects. And it was questioned 

whether they should be covered or not. We did an 

extensive review of the information and, with 

counsel, determined that we should cover those in 

those in the -- the plutonium exposures in the 

operational and residual period. So that was what we 

discussed in the previous Work Group meeting.

So to implement that we needed to do additional 

research. For all of these findings, actually we did 

additional data capture efforts. ORAU gathered quite 

a bit of data. And we reviewed it, and we went back 

and got more data. And we exhausted the efforts to 

be sure we had all available information that we could 

use.

And so this paper actually summarizes information on 

the plutonium work they did. There was a table in 

there, Table 1, that -- or 2, that lists the projects. 

There's a timeline of plutonium works provided in 

Table 1. Then there's projects listed in Table 2.

And then there's a summary of the plutonium work 

in Table 3. So this gave us a basis to assume that 

plutonium work was -- went from 1965 through the 

end of it in -- early 1973 when it ended.

So we know we have bioassay data for some workers 

in that period. There was really no way to determine 

that we had sufficient bioassay data for all workers. 

So we developed a coworker database to estimate 

intakes for unmonitored workers, or workers whose 

data may not be sufficient.

We know that the period like prior to 1967 it's 

insufficient because there is no data. So we 

developed this database. What we did, we went 

through the NOCTS, looked at the 200 and something 

claims we had. We found enough bioassay data to do 

intakes for each year from 1967 through '73.

And that data was analyzed according to our 

established methods for analyzing coworker intakes. 

And we presented intake rates in the table in the 

White Paper and -- for both Type M and Type S 
18

materials. Type Super S will be addressed according 

to OTIB-0049 instructions.

So our intake rates provide through 1967 through 

1973. We extend that intake rate back to the start of 

operations in '65. Due to no other means to assess 

data, we thought that was our best available data.

And that was one of the observations on this paper 

that we presented from -- by SC&A. SC&A, one of the 

observations they noted was that there was no strong 

support in our White Paper for doing that.

So I went back and just to try to describe what 

information we have on that. If you look at the 

projects that were going on at the site -- the timeline. 

The timeline shows that the, on Table 1 of our White 

Paper, shows the timeline of '64 to '65; '64 is not 

known to be an area -- that was just the timeline for 

when they were constructing facilities.

The first known Pu project was in 1965. And we don't 

really have much details on that. It's identified by 

NFS as a project that involved 16 kilograms of 

plutonium for a DuPont/Savannah River contract for 

MOX fuel rods, the mixed oxide fuel rods.

We don't really know any other information about 

that particular contract, and we don't have 

monitoring records. Our White Paper used the 

nominal start date for intakes of 1965 because we 

couldn't confirm the actual start date.

There is one other piece of information for 1965 that 

possibly is an indication of when it started precisely. 

There's a January 1966 annual report to Congress, 

AEC reported that a contract was signed with W.R. 

Grace in Erwin to recover 16.5 kilograms from scrap 

being stored at Hanford.

This is in November of 1965. It sounds like the same 

project that NFS lists for DuPont/Savannah River. But 

we really have no details of the exact start date. So 

our TBD just nominally gives a 1965 start period 

without a precise day or month.
19

So we determined that the use of 1967 default 

intakes from our coworker study, and plotted 

backwards to cover this period. There's another 

reason to believe that it may be sufficient to bound 

that is the amount of material thought processed at 

that time. Both the early project and the work being 

done starting in 1967 were manufacturing MOX fuel 

rods.

The early project in '65 to '66 only involved 16 

kilograms of plutonium. The work from '67 through 

'71 involved 746 kilograms. Nearly an order of 

magnitude higher for throughput if you were to 

calculate this. So we just assumed that this likely is 

a bounding. We have no way to give an accurate 

accounting of '65 to '66 intakes because we have no 

bioassay data.

We believe this was a reasonable method to extend 

it backwards and favorable, because we're using 

basically the highest intake rate we calculated from 

bioassay data to do so.

That was my response to Observation 1 on that data 

that I just mentioned being extended back. Because 

we believe that that is, given the lack of any other 

data, that that seems to be a reasonable approach.

And Dr. Buchanan noted that this lack of data is 

somewhat mitigated by the fact that this is also an 

SEC period for thorium -- an inability to reconstruct 

intakes of thorium. Now that gets us through the 

period of being able to reconstruct intakes of 

plutonium through 1973.

Starting in 1974 we have no bioassay data other than 

long-term monitoring. But the facility was idle for 

many years awaiting D&D. The D&D was delayed 

many years partially while they were looking for a 

place to dispose of the waste.

And they instituted a continuous air sampling 

program in the facility in the idle period. But the data 

from that is not available in 1974. The data for that 

starts in 1976. So we have a period there where we 
20

have no data.

So what we did, we took the air sampling data from 

the idle period, which ran from '74 through 1990. And 

we estimated intake rates from the ambient air in the 

facility for all those years based on a favorable 95th 

percentile intake rate. And we've applied that to each 

year from '75 through '90, when the facility started 

D&D.

And as I mentioned previously on the findings, 

starting in 1990 when they did D&D, we have 

bioassay data for the workers involved with that.

So we have this period from after the bioassay ended 

and before the air sampling started, that we have no 

data. So we looked at the intake rates. The intake 

rates based on the bioassay data was higher than the 

air sampling data taken a couple years later, which 

would be expected.

So we basically just did an exponential decrease of 

the intake rates from the bioassay data during 

operations down to the years when the air sampling 

data is available. And we just did the annual intakes 

based on that, which is basically just dropping the 

intakes every year until the two data points meet.

And we did that for both Type M material and Type S 

material because the intake rates are different 

depending on the solubility types used in the 

urinalysis. And so therefore we come up with an 

intake rate for the facility from 1967 through the end.

What we've done for the end, we've extended the air 

sample data at the end also for ambient intake rates, 

although we have workers who were exposed during 

D&D, we also have monitoring data for the air sample 

locations.

So that's also published in the White Paper for 

incidental entries for people who were not necessarily 

working on the plutonium project, we do have air 

sample data just for the ambient air in the facility. 

But that -- but like I said, plutonium workers 
21

themselves will be done -- intakes based on bioassay 

data.

And we concluded that the combination of the data 

provided in this White Paper and the bioassay data, 

that we can reconstruct the intakes of plutonium. And 

SC&A did have some comments on the paper. One of 

them I previously discussed, which was the -- they 

had no findings but they had some observations.

One of them was the -- give me just one second here. 

Well, maybe I should hand this over to Dr. Buchanan 

and let him mention his issues he may have had with 

the paper, and see if I've represented their faults on 

it correctly.

Dr. Buchanan: Okay. This is Ron Buchanan with 

SC&A. And thank you, Tom, for that good, detailed 

presentation. We went over this White Paper fairly 

thoroughly and evaluated it on assumptions and data 

and did some calculations and such. And we also 

evaluated it when they developed the coworker data 

in light of NIOSH's 2015 guidance for developing 

coworker.

And we give a summary of that in our report there 

and believe that they did follow its guideline. And so 

we had no problems with the White Paper itself. We 

did have a couple of comments, observations.

One Tom had already talked about was that 

extending it back to '65. And our main question 

there, had they looked at that? And apparently they 

had looked at it and had, I think, gathered what data 

was available for that period, '65/'66. And there does 

not seem to be any indication that there was greater 

use of material during that time than later times. So 

we have no further questions or problems with 

Observation 1.

We did have Observation 2 and 3. And that was more 

questions than anything. Observation 2, Tom, was 

you used the 30th percent and 3.9 percent factor is 

somewhat unclear. Had you had time to look at that?
22

What it looked like is maybe the results of, in the 

tables from the plots, were multiplied by a factor of 

250 divided by 365 when they was put into the table, 

when they was taken from the plots to the table to 

compensate for the number of work days in a year. 

Is that true, or was that the explanation for those 

difference in values?

Mr. Tomes: Yes, that was, well a minute ago when 

you started speaking, I had misplaced my notes for 

this as -- yes, you're correct, exactly correct. When 

that information is incorporated into the TBD, we will 

make sure that is apparent. And note the units that's 

counted -- that units.

Dr. Buchanan: Okay, so that addresses Observation 

2. Observation 3 was we noticed that it's kind of in 

the wording, in Nuclear Fuel Services' 1989 PDF page 

170 states that bioassay frequencies, at a minimum, 

will be quarterly for urine/fecal samples and annually 

for in vivo lung counting.

It's not clear, because we did not find many in vivo 

lung counting during this period. It's not clear 

whether it required both, or. I know we found quite 

a few urinalysis. Do you know if this was meant to be 

"or" or "and" in their requirement on that?

Mr. Tomes: I don't know. I looked at the wording. 

And I think it's probably subject to interpretation.

However, I can, I did look at the records that we 

have, that we get from the site, and it looked like to 

me that, of the ones I saw, I can identify plutonium 

workers because they have quarterly fecal and urine 

results in -- from 1990 through 1993, which is was 

the exact period of the D&D project. And they also 

have lung counts. So it looked like to me, we have no 

problem as I mentioned in the previous finding -- we 

have no problem reconstructing -- have sufficient 

data for those workers. But it looked like to me that 

they did quarterly fecal, urine, and chest counts, all 

three.

Dr. Buchanan: They did annual chest scans, okay.
23

Mr. Tomes: Yes, yes.

Dr. Buchanan: Okay. Well, I just wanted to clarify 

that. That really wasn't a real important point. All 

those we assumed were correct, but we just wanted 

to verify that. So as far as SC&A was concerned, we 

had no further issues with Finding Number 3 and 

would recommend closure on that.

Chair Anderson: So, Board Members, there's a lot of 

documents in this particular file. And are we --

(Simultaneous speaking.)

Chair Anderson: -- especially understandable that, 

especially on the coworker model that that's been 

covered adequately to be consistent with the 

guidelines?

I think you've reviewed it. And I would agree that it 

follows the guidelines, but I just want to be sure that 

in the documentation all of this can be found. I tried 

to go through it, but there's so many different 

documents it's a bit hard. But any questions from the 

other Board Members?

Member Kotelchuck: We're discussing Finding 2, 

right?

Chair Anderson: Yeah.

Member Kotelchuck: Yeah, right. I had a little 

question if we can go previously, on that White Paper, 

the NIOSH White Paper on that Table 1 on Page 6. 

The operational period uranium intake rates. I --

Mr. Katz: Wait, wait. Dave, we're discussing Finding 

3.

Chair Anderson: Three, we just --

(Simultaneous speaking.)

Member Kotelchuck: That's what I'm wondering. 

That's, I don't -- okay, I don't. And that's --
24

Mr. Katz: Plutonium.

Member Kotelchuck: I'm having problems here, but I 

don't see anything -- we have Findings 2 and 4 that 

Ron's -- okay. That's, I've been wandering, forget 

about it. But where is the -- I'm trying to find where 

Finding 3 is in our --

Chair Anderson: It wasn't a PowerPoint.

Member Kotelchuck: Right.

Dr. Buchanan: It's Number 4 on --

Mr. Katz: Well, so, Dave, Finding 3 is addressed in 

the reports from -- the NIOSH/ORAU report from 

March and the SC&A report from August.

Member Kotelchuck: Okay, all right. I --

Member Field: I'm glad you're having the same 

problem I am.

Member Kotelchuck: There is no -- and I -- in the 

agenda there -- it's items 1, 2, 3, 4. The findings 

numbers are different. And I --

Mr. Katz: Yes, yes the numbers in the agenda are just 

item numbers, not the finding numbers.

Member Kotelchuck: And I thought I was in sync and 

I was trying to find -- okay.

Mr. Katz: Yeah, I'm sorry. That's my fault. They're 

just the item numbers and not the finding numbers 

in the agenda.

Member Kotelchuck: I was out of sync, and I'm sorry, 

and that's okay. And I was looking around trying to -

-

Mr. Katz: Yeah.

Member Kotelchuck: -- figure out what was going on. 

So we are on Finding 3.

Mr. Katz: Correct, which is plutonium doses.
25

Member Kotelchuck: Yeah, yeah.

Mr. Katz: Yeah.

Member Kotelchuck: Okay. Well.

Chair Anderson: But I think all the documentation we 

need is there. It's just --

Mr. Katz: Yeah.

Chair Anderson: -- is it adequately organized so you 

can find what it'll be, whether there's going to be a 

lot of references when you revise the TBD and pull it 

all --

Mr. Katz: So, yeah. So, Andy, I think once the TBD 

gets updated, it'll all be easy to follow. I think it's the 

-- the White Paper process of course is a little bit of 

cats running around all over the place. But --

(Simultaneous speaking.)

Chair Anderson: That's really -- I don't have any 

objections or problems, as neither -- as SC&A didn't 

either.

Mr. Katz: Yes, right.

Chair Anderson: I'm only wanting to be sure that 

when the TBD gets redone if somebody, especially in 

the public side, wants to go in and has a question like 

this, that it in fact all gets incorporated and crossreferenced in the TBD so that it's easier to find and -

-

Mr. Katz: Yeah.

Chair Anderson: -- our own process here, once it's 

dragged out over quite a period of time. And I think 

we have it all and getting up to speed here has been 

--

Mr. Katz: Yeah.

Chair Anderson: -- been a helpful exercise, so I'm --
26

Mr. Katz: Well, yeah, it is, I mean there's no question 

it's, you know, for the public to go back and 

reconstruct the discussions is always a challenge. We 

go through that when we have to brief the Secretary 

on SECs. So --

Chair Anderson: Yeah.

Mr. Katz: -- we have to reconstruct the whole 

storyline, which is a lot of work. But the TBD should 

be pretty, you know, will be laid out in a 

straightforward fashion, I think. So they should be 

okay with what is actual for now, what the procedure 

is.

Chair Anderson: I think it was helpful to have SC&A 

go through and look at the coworker criteria because 

most of this began before we had the coworker 

criteria.

Mr. Katz: Yeah.

Chair Anderson: Just need to be sure whenever we 

now sign off on a coworker approach to be used that 

in fact it is consistent with the criteria. And I think 

SC&A did that pretty well, so.

Mr. Katz: Yeah, and now this is, I guess, this is 

actually the first coworker model that we've said so 

with. So that's good.

Mr. Tomes: Dr. Anderson, this is Tom. Maybe I'd like 

to add one little comment on the organization being 

able to -- for the TBD, being able to understand. For 

the White Paper it is -- there is a lot of information in 

that. And we tried to -- and some of that can't be 

made simple just because it is detailed.

So but what we did in the White Paper, we have the 

-- basically a -- a basic section of the paper where we 

summarize what -- the intake rates and provide 

intake tables. And then the more details, that gets 

really heavy into the details and the statistics and 

everything, are actually in attachments.
27

You know, we could do that in the TBD to -- that was 

done just to make it easier to understand what we're 

doing. And then if you need more details, we go to 

the attachments to see the details, if that helps any.

Chair Anderson: Yeah, no I'm sure it'll get done. I 

just want to raise the issue so that we be careful that 

we don't close things out and then it remains shuffle 

through the papers for what you're looking for.

But, and again as a coworker model, I'm not sure it's 

comparable to the other coworker models that have 

been developed. It's basically looking for -- I'm not 

sure we have coworker data involved more than 

trying to extend where we don't have data. And then 

utilize earlier data in the same population that -- so 

it may be the first one we've signed off on. But I don't 

think it's as complicated a coworker model. We're not 

really looking at going to other companies and things 

like that at least on this component.

Mr. Katz: Yeah, there are a lot of flavors of coworker 

models, but yeah.

Chair Anderson: Yeah, I mean it's, yeah, I mean it's 

a broad definition of a coworker model --

Mr. Katz: Yeah.

Chair Anderson: -- I guess. So any other comment, 

Board Members?

Member Field: No comment. I agree there were some 

tracking issues, but I think all the information is 

there. It's just being able to describe where it's at.

Chair Anderson: Yeah.

Mr. Katz: Do we have a motion?

Chair Anderson: Yeah, somebody or someone want 

to make a motion?

Member Field: I'll make a motion.

Chair Anderson: -- to close it. Fine.
28

Member Kotelchuck: Right, this is one. Look I got out 

of sync here. And I really -- I'd like to abstain on this 

vote because I was not following properly. And I, for 

whatever reason, I have no problem with the other 

colleagues, you know, responding and were 

following, but I wasn't.

And I just don't think it's best for me to vote on 

something that I read briefly, but --

Mr. Katz: Dave, that's fine because this will come 

again to the full Board at some point for the Board to 

close out the procedure too.

Member Kotelchuck: Good, okay.

Mr. Katz: But you can go ahead and close it as a Work 

Group. And, Dave, you can vote on it --

(Simultaneous speaking.)

Mr. Katz: -- at the full Board.

Member Kotelchuck: -- and I will abstain, and that's 

fine.

Mr. Katz: That's fine.

Member Kotelchuck: And I'm sure, I trust --

Mr. Katz: It's not a problem, not a problem.

Member Kotelchuck: Okay, sorry.

Chair Anderson: So we're going to close it, and 

clearly when we close it, the understanding is we're 

not expecting any more work to be done. And we 

don't have any --

Member Kotelchuck: Right, right.

Mr. Katz: Right.

Chair Anderson: You know, so that's different than 

final sign-off by the full Board. But I -- I'm beginning 

to worry about how we're going to present all of this 

in a clear and concise manner to the full Board --
29

Mr. Katz: And we've done these with other Site Profile 

reviews. It's manageable actually because we don't 

go into all this detail with the full Board. But they 

have access to the records; if any of them want to 

plunge into the gory details, they can.

Chair Anderson: Okay, so we're closing out three. 

Let's move on to the lack of neutron dose 

assessment.

Mr. Katz: Correct. And that is Ron Buchanan.

Ms. Gogliotti: For the record, can we --

Chair Anderson: SC&A is --

Ms. Gogliotti: -- those observations are also closed, 

associated with that?

Mr. Katz: Yeah, yeah.

Chair Anderson: Yeah.

Mr. Katz: They're -- it's all closed. Because they were 

only I think -- the Finding's closed, right, and the 

observations are closed, three. Thank you. Thank 

you, Rose.

Lack of Neutron Dose Assignment

Dr. Buchanan: Okay. We ready for Finding 4, lack of 

neutron dose assignment?

Chair Anderson: Yeah.

Dr. Buchanan: Okay, says I'm presenting, so I'll try 

to see if my --

Chair Anderson: Try to get your PowerPoint loaded 

up.

Dr. Buchanan: Right, okay, is that screen --

Chair Anderson: There you go, we got her.

Dr. Buchanan: Okay. This is the current status of 

Finding 4.
30

Okay, and this was concerned with lack of neutron 

dose assignment. When we reviewed the TBD in 2013 

the question of lack of neutron dose assignment, and 

we did not locate any recorded neutron doses in the 

claimant files that we'd reviewed.

So we suggested further investigation into potential 

neutron exposure and methods to assign appropriate 

neutron doses was needed. And the response to our 

concerns was that NIOSH agreed that further 

investigation was necessary.

And this Finding was discussed during the Work 

Group on August in 2015. And NIOSH presented a 

proposed method. And we agreed to that proposed 

method and would evaluate it when it became 

available.

Now NIOSH issued a White Paper in May of 2017 

entitled Neutron Dose Assignment for Plutonium Fuel 

at W.R. Grace. In that White Paper NIOSH had 

analyzed N-P ratios at other DOE sites that processed 

plutonium in a similar manner and a similar 

composition as we used at W.R. Grace.

And so we evaluated this paper and issued an 

evaluation report in September of 2017. And for that 

evaluation we reviewed the N-P ratios used at other 

DOE sites that processed plutonium and found them 

to range from 0.2 to 1.1 for non-glovebox workers, 

and from 1 to 1.7 for glovebox workers.

We also reviewed Nuclear Materials and Equipment 

Corporation, NUMEC, TBD in 2017 and concurred at 

that time with the N-P ratio of 0.34 for non-glovebox 

workers and 1.0 for glovebox workers. And this 

seemed to be similar physical exposure that could be 

similar to W.R. Grace. So we concurred with their 

selection of those values.

And we still had finding -- remaining concerns though 

with this. Although we agree on the N-P ratios, we 

found that it was difficult at W.R. Grace to determine 

who may be exposed. And NIOSH recommended in 

the White Paper, Page 6, in conclusion that we use 
31

the guidelines from, I think it was Savannah River 

Site.

But we, the problem with that was that they depend 

upon neutron measurement ratios before and after 

the period. And at W.R. Grace there wasn't any 

significant neutron monitoring. So we can't hardly 

look at previous or post period N-P ratios to 

determine -- or neutron monitoring to determine that 

that person should have been monitored during the 

non-monitored period.

And we already decided on the N-P ratios. And also 

at the recommendation, they used the 17 keV film 

badge data to look at possible plutonium exposure. 

However, W.R. Grace Finding 5, we went into quite a 

bit of detail back in previous years to determine their 

dosimetry program. And talked to Landauer and 

some of the dosimetrists there and such.

Could not find any detailed information on W.R. 

Grace dosimetry that would give us an indication of 

the lower energy exposures. So we can't use that as 

criteria for selecting the people that should be 

assigned neutron dose using the N-P ratio.

So I guess -- and our conclusion was unless there's 

consistent DOE records for W.R. Grace workers 

indicating that they did work or did not work in the 

plutonium facility -- it's a little different at W.R. Grace 

in that there was only two buildings, Building 234 and 

Building 110 that actually processed plutonium. And 

that was an active area, then an inactive area, 

standby, and then a decommissioning area -- era.

And so it would be difficult to determine which ones 

were in and out of there perhaps and were exposed 

and not exposed. So almost anybody that signed in 

and signed out would almost have to be assigned 

neutron dose.

And so we -- our conclusion is that we need to know 

how -- when you're going to assign neutron dose to 

the plutonium workers, how you're going to know 

that. And also the storage phase in '73 to '87 and the 
32

decommissioning phase from '87 to '94 was not 

covered.

And also in TBD 43, Page 28, they talked about 

neutron exposure from uranium; however that 

wasn't covered in the White Paper and is yet to be 

addressed. So that is our concerns at this point, those 

three points.

And so I'll turn it over to Tom to see if he has any 

response at this time on those concerns.

Mr. Tomes: Thank you, Ron. This is Tom. We -- at 

the time of the neutron paper that was issued in 2017 

we had another document under development that 

was not issued yet that gives us neutron dose ratios 

from highly enriched uranium at the facilities and the 

gaseous diffusion plants.

And we believe that would be sufficient to provide a 

ratio for highly enriched uranium for the AEC contract 

work from '58 through '70. So, we do believe we have 

a method to assign neutron dose for those workers.

We also looked at the ratios and job descriptions of 

how we may apply the neutron-photon ratios to 

plutonium work. We have a 0.34 ratio for non-glove 

box workers and a 1.0 ratio for glove box workers.

We -- our internal dose evaluation puts workers into 

four categories, whether it be operator, laborer, 

supervisor, or clerk. 

And we believe that the operator should be assigned 

a glove box ratio because they would be the ones 

with material, handling material that was in the glove 

box.

We believe the other workers should be assigned the 

lower ratio, the laborers, supervisors, and clerks. 

They would not be expected to be handling plutonium 

in the glove boxes. So we believe that we can split 

them up based on job categories.

The job categories from the records I've reviewed in 
33

NOCTS indicates that we have a pretty good handle 

on job categories. They don't necessarily match the 

exact descriptions of the four categories in TBD-6000 

that we modeled that after.

However, the operators are called operators, but 

there are numerous categories. So we select, for 

example, we have office workers and other people 

who have various different titles which would fall in 

the clerk category that we would not expect to 

receive neutron dose.

But then we have other workers that we would 

default to assigning the dose if we don't have 

information of where they worked. And so that would

be our proposed method of how we determine who 

gets assigned which ratio rather than using the 

Savannah River method that was mentioned.

Dr. Buchanan: Okay.

Mr. Tomes: And the other --

Dr. Buchanan: Yes, go ahead.

Mr. Tomes: Ron, can you put your slide back to the 

other? There we go. In regard to your first bullet 

there on that slide that said there was no significant 

neutron monitoring before, during, or after, I just 

wanted to clarify one thing that we have found in 

going through all these records recently.

We've identified plutonium workers in the D&D period 

and I believe they were kind of obvious. When they 

modified the decommissioning plan they submitted to 

NRC that we mentioned earlier about requiring 

quarterly monitoring.

We went back and looked at some of those claimants 

and all the ones I looked at who had that quarterly 

monitoring, they were working on a plutonium 

project. A number of those people have neutron 

monitoring data from 1990 to 1993.

I only saw one that actually had a recorded positive 
34

result which was very low, 20 millirem. But we do 

have some neutron monitoring data that is available 

in the D&D period. I have seen no records -- I agree 

with the rest of it, there's no records prior to that that 

I've seen in the personal monitoring records.

But we do have some dosimetry data used in the D&D 

period. And I would expect based on the 

requirements they had that the workers who were 

potentially exposed to neutrons in that period have 

neutron data, is the indication I got from looking at 

the records.

It's different from the entire workforce because when 

I look at all the bioassay data and identifying 

plutonium workers, the sites in general do not have 

that quarterly bioassay data that the workers in the 

D&D did. There was three different programs going 

on there during that period.

I believe -- I may want to turn this over to Matt Smith 

from ORAU. He may have some questions on the 

clarification of -- I think we understand your points, 

Ron. But he may have -- maybe you can tell us what 

-- I think he wanted to clarify what issues you still 

have that may not be addressed by what I was just 

discussing with our response to that.

Mr. Smith: This is Matt Smith with the ORAU team. 

And I think Ron clarified it as he went through the 

slides. I believe if we back up to, I believe it was slide 

number 6.

In the slide we were wondering if it was dovetailing 

and agreeing with the memo from 2017 which 

affirmed the N-P ratio choices. And verbally you said 

that as you went through the slide presentation. It's 

just that as we read the slide presentation we didn't 

get that same affirmation.

But it states that in the memo and you repeated it 

verbally during this presentation. So it sounds like 

we're okay with 0.34 and -- for the general workers 

and a value of 1 for glove box workers, correct?
35

Dr. Buchanan: Yes, that's correct.

Mr. Smith: Okay. And the only other thing I'd add is 

information that came from Mutty Sharfi just for 

everyone on the record. It's SRDB-150887. And page 

15 is where the indication is given that during the 

D&D period that dosimetry capable of gamma and 

neutron measurements was required.

Dr. Buchanan: That was 150887?

Mr. Smith: Yes, 150887. And it's PDF page 15. And 

again thanks to Mutty for referring us to that. That's 

all I have right now.

Dr. Buchanan: Okay, so what is the next step? Are 

you going to reissue a neutron White Paper or are 

you just going to incorporate this in the TBD changes, 

or what's the next step at this point?

Mr. Tomes: This is Tom. Well, I believe I'd have to 

ask the Work Group that question. If we can -- if 

there's a transcript of this record we can resolve this 

based on, when we write the TBD according to what 

we determine here during the meeting if all the issues

were satisfactorily resolved.

If not we can follow up and issue another White 

Paper. We can do either one.

Dr. Buchanan: SC&A can review another White 

Paper, or of course we'll review the TBD when it's 

issued. So whatever the Work Group would prefer.

Mr. Katz: Ron, it's probably helpful to the Work Group 

if they just hear your reaction to the discussion that 

Tom just gave.

Dr. Buchanan: Okay. Well, as far as SC&A's 

concerned, like I stated, we agree with the N-P ratio. 

Our main concern was what workers do you apply 

this to since you didn't have some information that 

would have been handy.

And it appears that they were applied to everyone 

that was potentially exposed in the plutonium facility. 
36

So, I would like -- I agree with that approach. Just 

like previously, I agree with their approach. I think 

it's claimant-favorable.

We would -- I'd like to see it in writing before I sign 

off on it. Either in the TBD or in a White Paper.

Dr. Taulbee: This is Tim. Is the best thing to do if 

other Board Members agree to put it in abeyance?

Mr. Katz: That's the normal -- this is pretty 

straightforward. It's not really complex in a technical 

sense. So that would be -- abeyance would be the 

terminology, right. It's pretty much it.

Or, actually I think close it, either. I mean abeyance 

we normally do when there's like a lot of details to 

sort out, but we agree in principle.

In this case sort of the answer is pretty well explained 

and it's just a matter of wanting to see it in print. But 

agreeing with it so the Work Group can close it, they 

can put it in abeyance, but either is fine in a sort of 

rather simple situation like this. It's up to the Work 

Group.

Chair Anderson: Other Work Group Members? It 

seems to me the only actual measurement data we 

have is from '90 to '93 for neutron monitoring. 

Member Kotelchuck: I think that's correct, yes.

Chair Anderson: And so for the other periods we're 

using the alternative data and the ratio to assign a 

value.

Mr. Tomes: This is Tom. That is our understanding of 

how we would do it.

Chair Anderson: My question is when you look --

when you don't have much data, you said there was 

only one positive monitoring value from '90 to '93, 

does that fit with your application of the ratio?

(Simultaneous speaking.)
37

Chair Anderson: -- what you expect based on the 

decay curve and everything that the values between 

'73 and '87, during the standby, and then the earlier 

part of the decontamination phase. There are 

assigned values there that are consistent with what 

was then observed in '90 to '93?

Mr. Tomes: In '90 to '93 they basically were not 

removing material or handling material. There would 

only be any holed-up material they may have 

encountered. So they were basically just 

decontaminating and removing glove boxes in the 

facility.

So we wouldn't expect to see a lot of neutron dose. 

And I don't have -- I can't say for sure that we only 

had one positive result because this was just a partial 

look at the data. I haven't examined every single 

record.

But I have seen enough of them to know that 

typically there was no recorded neutron dose except 

for that one case I mentioned. And from my 

discussions with other people this would be expected 

that we would not see very much neutron dose.

I don't know if other people would agree with that, 

but that is what I have -- my understanding.

Dr. Buchanan: Yes. This is Ron. I think you have two 

different situations. So in one place you're handling 

plutonium. In another place you're just removing 

equipment that had plutonium in it.

So, I don't think we can correlate between the earlier 

period and the '90 to '93 period. I wouldn't expect 

there to be a lot of correlation there.

Chair Anderson: Okay. The concern I have is in fact 

our understanding of this facility, that it's quite 

typical for the other data we're using.

So that it wouldn't be -- the concern would be is there 

some unusually -- is this an outlier, unusually high 

potential here, or is it really quite typical and 
38

therefore we really don't have any monitoring data. 

So we're applying the ratio that we're trying to make 

that claimant-favorable and things like that.

So that's my only concern. How comfortable are we 

that we are adequately characterizing this based on 

this other information. 

I would say it's almost like we don't really have any 

ground-truthing data to suggest yes, it fits with what 

we -- how we will be using this. Probably not making 

myself terribly clear here, but that's the only issue 

I'm concerned about. 

You're left with what you have to work with, and this 

seems to be everyone is in -- I assume everyone is 

in agreement that this seems to be a reasonable 

approach to it.

But the reasonableness of how you manage assigning 

a dose is that it is consistent with the type of activity 

here, and that it wasn't particularly unusual.

Mr. Smith: This is Matt Smith from ORAU team. I'll -

- again, I'm addressing the selection of the N-P ratios 

that SC&A has agreed with.

We focused in on another facility called NUMEC 

because they were doing this same plutonium fuel 

fabrication work. And in addition to that the values 

came from an analysis of worker dosimetry.

So rather than survey values, this was really based 

on worker-specific data, in fact, the workers that 

were assigned to do the plutonium fuel fabrication 

process. 

So, again we feel we found a process at another

facility that closely aligns with what was going on 

here at W.R. Grace.

Chair Anderson: And SC&A agrees with that? I don't 

know, I haven't looked at anything from any other 

facility, that's all. I just want to be confident that 

when we don't have data at all, that we're hunting 
39

around here.

Mr. Katz: So the only thing I could add, Andy, is that 

this is something we've done at many facilities with 

this -- using these ratios, finding analogous operation 

at another facility and applying the ratio accordingly.

So it's not uncommon at all in this situation.

Chair Anderson: Right.

Member Kotelchuck: This is Dave. I mean, I feel 

comfortable that NIOSH and SC&A agree on the N-P 

ratios, and I see where they're using the NUMEC 

data.

So, I'm comfortable with the way it's being handled. 

I still don't know administratively how we -- what we 

should do. 

It doesn't seem to me -- I don't think it needs to 

come back to our committee, but -- and I don't have 

questions to say answer this question and come back 

to us.

So, it is clear that it's, you know -- I'm comfortable 

with the procedure. I don't know. Ted, you 

mentioned before in abeyance would be a proper way 

of doing it.

Mr. Katz: Well, so, yes. So, I mean, abeyance or 

closing the finding. What I was saying about the 

difference between abeyance and closing the finding 

is normally we put things in abeyance when there's 

sort of technical details to work out. We agree in 

principle, but there are technical details that we really 

want to see how those get worked out before we 

finally close it.

In this case there's really no sophisticated details to 

work out. It's all sort of settled matter. 

But I think the Work Group can close it. And of course 

when you present it to the Board, the Board can take 

another -- ask questions again about is this 

application here analogous with the site it's being 
40

compared to.

And it sounds like nobody seems to have any 

questions about whether it is indeed analogous. And 

like I said, the Board has approved many of these 

applications, the ratio from a similar operation at 

another site. This is not uncommon.

Member Kotelchuck: So Henry, I feel comfortable 

closing it.

Chair Anderson: Okay, well, that's what I wanted to 

hear as well. I think I am as well. It's really finalizing 

the write-up as it gets into the TBD. But I think we 

work through and discuss back and forth how it is so 

we've kind of got it verbally, and now it's just a 

matter of finalizing that.

So, other comments?

Member Field: Yes, this is Bill. I'm confident, I think 

we can close it. It's mainly a matter of getting the 

write-up completed, and I trust that will be done.

Chair Anderson: So let's just formally decide to close 

it.

Member Kotelchuck: That's fine. Bill, are you okay?

Member Field: Yes, I'll make a motion on that.

Chair Anderson: Okay, good. Okay. So I think we're 

all in agreement. So we will close this rather than put 

it in abeyance. And just keep it in mind so when we 

put the presentation together we mention that.

Member Kotelchuck: Very good.

Mr. Katz: So the next one is Tom Tomes again.

Mr. Tomes: This is Tom. The next one is Finding 7. 

We're at Finding 7, is that right?

Mr. Katz: That's adequacy of environmental dose.

Mr. Tomes: Yes. 
41

Mr. Katz: Yes. Finding 7.

Adequacy of Environmental Dose

Mr. Tomes: NIOSH reviewed that. We went back to 

the site and gathered as much data as is available. I 

think we're confident we got all the data that's 

available from NFS. And so we did a thorough review 

of that data to address these issues.

The issue is that TBD does not provide environmental 

doses. I've separated it out into issues that we 

identified based on discussion that SC&A had in their 

reports.

One is that the burial ground remediation may have 

exposed unmonitored workers to airborne reactivity. 

As you recall we said we were going to use bioassay 

data to estimate intakes of uranium from those 

workers so that workers who may not have been on 

the project, such as people in the main part of the 

site may have been exposed. That was one issue.

The other issue is that the TBD methods do not 

account for plutonium intakes of unmonitored 

workers. And we responded to that in Finding 3 a few 

minutes ago. We addressed the environmental 

plutonium issues in this paper.

And another issue identified in SC&A's write-up is 

that, it says the TBD says some office workers were 

not assigned dosimeters in later times. So we 

addressed that issue.

And another issue identified by SC&A is it says, in 

general, the Technical Basis Document does not 

provide an adequate assessment of the 

environmental intakes and external environmental 

doses for all years, operational and residual.

So this White Paper that was issued by NIOSH in July 

of last year addresses all those issues. It was the one 

that was titled Resolution of Site Profile Findings 2 

and 7. Dr. Buchanan discussed Finding 2 earlier so 

we'll discuss the remaining part of that paper, Finding 
42

7, now.

Our review of the records that we received from NFS 

indicates that they had an independent 

environmental monitoring program that began in 

1968. As you recall the operations for AC work 

started in 1958.

And we have a few records available from 1968 

through 1970, but these data were for all offsite 

locations that were -- by themselves were not useful 

for estimating onsite environmental doses.

But we also found records from the NRC that 

described the rigorous environmental monitoring 

program that began in 1978. And we have records 

from that program starting in 1979 continuing 

through 1995.

Records are available after that, but they're 

somewhat different, which I will discuss here in a 

minute.

Associated with those records the White Paper 

presents images of the site showing the site layout 

and the locations of the environmental monitoring 

stations. There were several of them placed around 

the site.

The site was relatively small, the production area. 

And they strategically placed at these locations so 

that the entire site is fairly well characterized.

And so we have that data from all years from 1979 

through 1995. And we've estimated intakes based on 

-- we've taken all that data and we've analyzed each 

location.

And Table 3 of our White Paper has the results of that 

-- the annual intakes. These were continuous 

monitoring done by the site for each year.

So Table 3 provides annual environmental intakes as 

gross alpha results for 1979 through '95. And the 

paper highlights in bold the location that results in 
43

the highest intake, highest concentration there. That 

covers 1979 through 1995.

Starting in 1996 there's less data available. We only 

have -- the reports we got included more offsite 

monitoring -- onsite monitoring, but we do have 

some data from 1996 through 2000. 

We only had one location that was monitored in --

the burial grounds area was the area they monitored 

onsite at that time that was reported.

There's other data. The site had another program, a 

work area monitoring program that was very 

extensive. It had hundreds and hundreds and 

hundreds of data that we have in our database.

However, these are not really indicative of 

environmental exposures because they were work 

area exposures and no way to really differentiate 

which is which. But we do have burial grounds area 

monitoring in those later years.

Then we have some results available even in later 

years than that. From 2007, 2008 we have a few 

results.

All these results in these later years were relatively 

low, very low. And so what we've done since there's 

limited data in those later years, we've used the 

highest value of all those results to estimate intakes 

from 1996 forward. And those are provided in the 

TBD.

So that gives us -- those two methods there gave us 

environmental intakes from 1979 through 2011 

which is the end of the residual period for the site.

So we had to have a method to estimate 

environmental intakes prior to 1979 when we have 

the data. So we -- the paper provides part intake 

rates to substitute for environmental intakes. Per our 

earlier discussions we've set the plutonium default 

intakes and worker category, and we had the same 

thing for the uranium intake worker categories.
44

To substitute for environmental intakes we're going 

to use the clerk data. That's what we propose using, 

to substitute. That data is higher than we would see 

in the environmental monitoring in later years. That 

is the data that we would use.

However, we did some adjustments because some of 

the residual -- starting in 1971 when the residual 

uranium intakes were calculated, and then we had 

environmental intakes in '79.

Some of the residual intakes were lower than we 

calculated from the later data, environmental data. 

So we've recalculated and have a table in the TBD 

that recalculates the worker categories based on 

higher of environmental or residual contamination 

level intakes. 

And that is provided in Table 7 of the White Paper 

which is basically a combination of either the highest 

of the occupational intakes or the environmental 

intakes for workers in all years.

That provides the means to estimate uranium intake, 

either environmental or occupational in all years at 

this site.

For plutonium we have a similar approach using the 

clerk intake rate for environmental plutonium 

exposures. As you recall the environmental air 

sampling data was gross alpha.

For interpretation for the TBD and for assigning 

environmental intakes for a worker instead of 

occupational intakes, we would assign the 

environmental intakes as either alpha uranium or 

alpha plutonium, whichever provides the highest 

dose to a particular claim. We have no way of 

differentiating which would be which on a particular 

air sample.

That gives us a means to estimate environmental 

plutonium in years that we have environmental data 

starting in 1979. And for the earlier years we have 

taken a similar approach and used the clerk intake 
45

rate from plutonium coworker table, that was Finding 

3. We've taken those clerk intake rates from that 

analysis and applied it for the plutonium 

environmental intakes in those years prior to 1979.

And those two methods give us a means to estimate 

plutonium intakes and uranium intakes in all years. I 

would say that these environmental intakes and 

plutonium intake rates are provided for those 

workers who are presumably not having dose 

reconstructions based on bioassay.

If there are dose reconstructions based on bioassay, 

these intake rates would not apply because they 

would be redundant intakes. But this does give us a 

means for anyone who was exposed in the general 

area of the facility, but not necessarily inside the 

plants.

That is the summary of how we assess the 

environmental intakes at the site. And there are a few 

comments SC&A had in their response to this paper. 

I will just briefly mention --

Chair Anderson: Let me break in. Is there supposed 

to be something up on Skype?

Mr. Tomes: I did not prepare a presentation for this. 

I can put the paper up there if you'd like.

Chair Anderson: Okay, no. Because my screen is 

blank and I am now shuffling my papers to track 

through your document. Okay. Go ahead. Sorry. 

Continue.

Mr. Tomes: Okay. SC&A had some observations on 

this particular internal dose assessment. They 

thought the -- one section of the paper was hard to 

understand. And that was specifically pages 16 

through 20.

I think that primarily was little small sections in that 

paper on environmental intakes and dose 

reconstruction notes. There was some miscellaneous 

information that I placed in that paper in case there 
46

was questions that arise on interpretation of the data, 

and that's the reason that's in the paper.

And Dr. Buchanan correctly noted that these were 

not well organized, and I would have to agree 

because I had someone else look at this to make sure 

there were no errors in it prior to NIOSH issuing the 

paper.

But what we can do to simplify this, some of this 

information in the TBD is normally in footnotes. So 

what we can do to resolve this observation, some of 

this information would simply be moved into a 

footnote in the TBD and to make it more clear and 

more organized.

And in some cases some of these comments we will 

look at this wording and make sure that it's clear 

during review for a dose reconstructor.

Because I think for us the bottom line is that the dose 

reconstructor who's using this TBD understands what 

we wrote. And so we will re-look at the organization 

of those notes to make sure that they're understood. 

That was the observation they had on the internal 

intakes that I think we can address adequately during 

the TBD writing.

The other part of this finding concerns external doses 

in -- environmental external doses. The finding noted 

that some workers in later years did not have badge 

monitoring.

There are a few claims of office workers who did not 

always get monitored in those later years. 

So we've analyzed this environmental data that I 

mentioned. It included not only air sampling. It 

included environmental TLDs.

And the locations are around the perimeter of the site 

similar to what the air samples were. They appeared 

to be in approximately the exact same locations, or 

at least very close by.
47

And so we've taken all that data and we've analyzed 

that data to determine the highest dose rate in any 

one year. Those were provided in Table 13 of the 

White Paper. The highest year was 114 millirem in 

1979 and through 1995 when the highest result was 

9 millirem in a year. So we have that for 

environmental TLDs on the site.

There was another set of data that we analyzed for 

this issue and that was burial grounds 

characterization data. The site had a large burial 

ground area and they had a small burial ground area.

In 1987 ORAU had a contract to characterize both 

those areas prior to remediation work being done a 

few years later. And they performed dose rate 

measurements. They scanned the areas and they 

also did a 20 meter gridded readings in both areas.

And so we've analyzed all that data as separate 

areas. And the large burial ground area gave us the 

highest dose based on -- we used the 95th percentile 

of all that data. 

And the result of that is in Table 14 of the White 

Paper. Ninety-fifth percentile dose is 54 millirem per 

year. So that was based on some areas of the burial 

grounds had elevated dose rates found in the survey.

So what we've done for reconstructing doses, we're 

saying that we're going to use the highest of either 

the environmental doses for people who do not have 

dosimetry. We would use the higher of either the 

burial grounds dose rate surveys, or the 

environmental TLD surveys. And those results are 

provided side by side in Table 15.

And as I said, this was all data from 1979 through 

1995. So, we're recommending that we apply this 

1979 data which was the highest year of the 

environmental TLDs back to all previous years 

starting in 1958.

And then we provide -- do the same approach for 

1996 forward, the burial grounds dose rates, 1996 
48

forward.

The burial grounds, the basis for that is the burial 

grounds were basically idle. The material was 

deposited in there in the sixties up into the midseventies. Then they didn't have a remediation 

project until 1991 to restore those areas. 

So we believe that it was fairly static during those 

years, and we believe that that should provide an 

adequate means to assess ambient external doses to 

the site.

And I believe SC&A had no concerns with our 

methods to estimate the external environmental 

doses, but I will leave that to Dr. Buchanan to verify.

Dr. Buchanan: Yes.

Chair Anderson: Ron?

Dr. Buchanan: Yes. We went through all this data, 

analyzed the tables and did the calculations and feel 

that -- I had visited the site personally and feel that 

this is a reasonable dosage to assign people that 

weren't badged because it was a pretty tight 

operation and pretty compact. So I think this is a 

reasonable amount of dose, if not very claimantfavorable.

Chair Anderson: It is claimant-favorable you're 

saying?

Dr. Buchanan: Yes. I say it's very reasonable if not -

- it's claimant-favorable, yes.

Chair Anderson: It's a reasonable approximation.

Dr. Buchanan: Right. Well, yes. They used the 

highest of the readings and such so I think that it 

probably covers it pretty well.

Chair Anderson: Other Board Members' comments?

Member Kotelchuck: Looks good to me, Dave.
49

Member Field: I agree.

Chair Anderson: I didn't hear you, Bill.

Member Field: I said yes, I agree.

Chair Anderson: Okay. So shall we close this one out?

Member Kotelchuck: Yes.

Chair Anderson: Okay.

Member Field: Agree.

Chair Anderson: So all in agreement, we'll close out 

this one. Any other comments on that? And are there 

other -- now we're on 7 on our agenda. Observations 

and secondary findings that we need to address. 

SC&A? 

Observations and Secondary Findings

Dr. Buchanan: Yes, this is Ron again. On the 

secondary findings which we'd call observations 

today, I guess. Yes, that was under 7. 

We had A, B, C, and D secondary findings. And now 

NIOSH did address finding D in their response to 

finding 2 and 7. D was at the end of it.

And what this consisted was originally our question 

in the TBD was Table 5-5 was not detailed. We didn't 

know what method they used to get the doses in 

Table 5-5. And so we asked for some clarification. 

And since that time they've reworked Table 5-5. 

That's the beta dose from the residual contamination 

from '71 to 2000 and forward. And so NIOSH did 

provide some detailed information on that table and 

its rework. They gathered some more data.

And so we went through those references, went 

through the calculations, went through the table. The 

final Table 16 on page 27 are the response to Finding 

2 and 7.

And so for secondary finding D we concur with their 
50

recommendations and their calculations and methods 

and such. Did NIOSH want to add anything to that?

Chair Anderson: How about A, B and C?

Mr. Tomes: This is Tom. I think I can respond to 

those. I've got a couple of notes here in front of me. 

Let me make sure I get which one. The secondary 

finding A concerns Table 3-15, 5-2 in the TBD. There 

were some questions in the original finding on the 

intake rates in those tables.

And during a previous Work Group meeting we 

discussed that and provided the calculations, that 

these are in fact intake rates and units of activity per 

calendar day intake.

And we -- and I thought we had resolved that. There 

is some --

(Simultaneous speaking.)

Dr. Buchanan: I think finding A, B, and C was going 

to be changes in the TBD, the wording in the TBD.

Yes, we discussed these previously at other Work 

Group meetings and we agreed on them. And I think 

that there was going to be changes in the TBD. So, D 

has been addressed to our satisfaction. We'd 

recommend you can close that. And A, B, and C, we 

agree with the method, we just are going to evaluate 

the TBD of course when the changes appear. More 

clarification than anything.

Chair Anderson: Okay. I view those as kind of cleanup.

Member Kotelchuck: Yes, agree.

Chair Anderson: Okay. So did we close those out 

before? I don't know if those kind of --

Mr. Katz: Those are observations. I think we can just 

-- we can consider them closed and of course look at 

them to make sure -- SC&A will look at the TBD when 

it comes out to make sure that those are cleaned up.
51

Chair Anderson: Yes, okay.

Mr. Katz: So, I'm a little foggy about timing with 

respect to the next step because we had a path 

forward, sort of. Everything is I think clear. This has 

been nice work on behalf of both staffs. Thank you 

from the Work Group.

But as far as reporting to the Board TBD, getting the 

TBD ready. Tom, what sort of sense do you have now 

that you know where the Work Group stands on this? 

I think we have enough clarification that I think you 

guys can go to work on the TBD. But of course, are 

you kind of feeling sort of held hostage until the 

Board actually closes this out entire? Tim, Tom?

Dr. Taulbee: This is Tim. Can you hear me?

Mr. Katz: Yes. Now I can.

Report to Board

Dr. Taulbee: Okay. Sorry about that. I think we can 

go ahead and update the TBD based upon what the 

Board has indicated here. I don't think we need to 

wait for the formal close-out of everything there. It 

sounds like once we do that SC&A will give a quick 

pass to make sure we've incorporated everything and 

we're good to go.

As far as timing, that's something we've really got to 

look at our resources and see from a schedule 

standpoint. We're not prepared to do that right now.

Mr. Katz: Okay. So I think then as far as reporting 

out to the Board though, I think it's just a question 

of pulling together a good summary. And I think I 

would leave that -- I think traditionally we have SC&A 

take the lead on that and then pass that summary, 

once it's developed, to the DCAS crew to go over and 

add to as necessary to make it good and clear and 

full.

And then just reference the background documents 

for the Board so they can -- anyone who wants to 
52

take a deeper dive can. But let me just go ahead and 

I guess at this point we can pass that to SC&A. And 

of course I think this teleconference will be useful. It 

takes about a month for the transcription, sometimes 

shorter. I don't think we need to expedite it really at 

this point.

But you'll have the transcript, Ron, and whoever 

helps you with that to pull together a summary. I 

would make this a pretty detailed summary since 

there are a lot of important details through these 

findings.

For our presentation, we have lots of models for 

these presentations to the Board. If you folks would 

do it, whoever is going to take care of that for SC&A, 

I think that would be great. Is that okay with you, 

Andy?

Chair Anderson: Yes, that's fine. My only question 

was do we want to kind of view this as an interim 

report that we've done the review and we're all in 

agreement on it? Now, we're just waiting for the --

(Simultaneous speaking.)

Chair Anderson: I mean, do we need to do much, or 

do we wait for the final TBD and then --

Mr. Katz: So no, Andy. So you don't need to wait for 

the final TBD. This would be the report of the Work 

Group out to the Board on its review of the Site 

Profile.

The Board of course can do whatever with it once it 

hears the report, but this would be the final report of 

the Work Group unless the Board has some concerns 

and sends their feedback to deal with something.

Chair Anderson: Okay. So then we would have --

when the TBD is finished we would have another --

Mr. Katz: So you don't have to go back to the Board. 

Assuming that the Board doesn't have any issues 

then when the TBD comes out, whenever that is, 
53

you'll check to make sure that it's all in order. If there 

were an issue of course you'd follow up on that. But 

it doesn't need to come back to the Board unless 

there's some great surprise which there generally 

never is. 

Chair Anderson: Okay, that was just --

Mr. Katz: Yes.

Chair Anderson: -- if we would do a two-step here in 

which case we could shorten it.

Mr. Katz: There's no two steps. And as far as the 

presentation, I mean generally we don't lay it on the 

Chair of the Work Group to make the presentation 

when it's a detailed sort of thing like this.

We normally have a lead staff, so for example Ron 

could make the presentation. You can introduce it 

and then you can govern the discussion at the Board 

level of it. 

But you don't have to do the detailed presentation 

unless you want to. And of course it's your 

prerogative to do the presentation yourself. But 

they'll prepare it in either event for you.

Chair Anderson: Do you think we can get this ready 

by April?

Mr. Katz: I think so. That's still -- we're just entering 

February here, so I think so.

Chair Anderson: Okay.

Mr. Katz: And no matter because if for whatever 

reason it's not April then absolutely by August, which 

is the next meeting.

Chair Anderson: Yes. Okay. Anything else people 

have?

Member Kotelchuck: Not me.

Mr. Katz: For the good of the order.
54

Chair Anderson: It's been long and arduous, but it's 

worked out well I think. And there were a surprising 

number of issues we had to deal with for this kind of 

a facility. So I think we've advanced things here and 

are ready to close it all out and chalk another one up.

Mr. Katz: Yeah, I think everyone has done good work. 

So thank you, everybody. It's really appreciated.

Dr. Buchanan: Could I ask a question, Ted?

Mr. Katz: Of course.

Dr. Buchanan: So SC&A to provide a summary, a 

slide presentation for the Advisory Board?

Mr. Katz: Yes. So what we'd have -- we actually need 

two things for the Board. We need a summary slide 

presentation of a fairly detailed fashion. So that they 

understand the substance, not just findings were 

closed. And then it's usually helpful to take the BRS.

I think Rose has been taking notes as things get 

closed, but take sort of the BRS material and make a 

sort of matrix document that goes into a little bit 

more detail than actually gets presented to help 

Board Members who want to go back and look at a 

particular issue to understand it better, and have that 

document available, that matrix available for the 

Board to review. And we can actually make that --

PA-clear it, make it available to the public too.

So those are I guess two pieces that aren't currently 

available that you'd prepare for the meeting. The 

Board meeting is April 21, I think. It's only going to 

be a day. And if for whatever reason we can't do it 

then and it's not critical that it happen in April then 

we have a meeting in August as well.

Dr. Buchanan: Okay. And you want me to do the slide 

presentation for the Board?

Mr. Katz: I'm not making -- assigning to SC&A as to 

who does it. But typically it's the lead staff person so 

typically it would be you. But someone else from 
55

SC&A could do it as well. Unless Andy wants to do it 

and Andy will let you know. 

Dr. Buchanan: Okay.

Chair Anderson: No. I mean, if you put it together I 

can look at it and if I'm comfortable doing it, but I 

don't feel compelled to make the presentation. But 

I'll certainly introduce it, be there to help you defend.

Mr. Katz: Just to remind you, SC&A will prepare 

these, share it with the NIOSH folks so that they can 

make sure it covers everything correctly from their 

view, and then we'll get that finalized, share it with 

also the Work Group Members at the same time and 

then we'll get that finalized for whichever Board 

meeting it gets presented at.

Dr. Buchanan: Okay, thank you.

Mr. Katz: Yes, thanks Ron, so much.

Chair Anderson: So we're going to have it on the 

21st, the meeting in April?

Mr. Katz: Yes, that's my --

Chair Anderson: I have it marked here --

Mr. Katz: Is that the correct date? I don't have it in 

my head, but yes, I think that's right.

Chair Anderson: Okay, so travel on the 21st. Okay. 

(Simultaneous speaking.)

Chair Anderson: I want to be sure I don't have any 

conflicts. Okay. And that's out at Hanford, right?

Mr. Katz: Correct. I think the only hotel we could find 

is in -- and we haven't contracted yet. There's some 

issues. But anyway, for now that's the plan. And it's 

out at Pasco, not in Richland.

Chair Anderson: Right, yes. Okay. Any other 

comments by Board Members or others?
56

Member Kotelchuck: No, thanks.

(Simultaneous speaking.)

Adjourn

Chair Anderson: Thanks a lot for everybody calling in 

and those who were listening, I hope you were able 

to follow us. So, thank you very much.

Mr. Katz: Yes, thank you. Have a good day.

(Whereupon, the above-entitled matter went off the 

record at 11:24 a.m.)