Draft 

SC&A’S RESPONSE TO NIOSH’S SUBGROUP 10A IMPACT ANALYSIS 

DATED NOVEMBER 1, 2011 

Contract No. 200-2009-28555 

Prepared by 

John H. Stiver, MS, CHP 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

February 2012 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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Document No.: 

SC&A’s Response to NIOSH’s 

Subgroup 10A Analysis 

Effective Date: 

 Draft – February 6, 2012 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 (Draft) 

SC&A’s Response to NIOSH’s Subgroup 10A Impact 

Analysis Dated November 1, 2011 Page 2 of 13 

Task Manager: 

______________________________ Date:____________ 

John H. Stiver, MS, CHP 

Supersedes: 

N/A 

Project Manager: 

______________________________ Date:____________ 

John H. Stiver, MS, CHP 

 

Peer Reviewer(s): 

 Robert Barton III 

 

Record of Revisions 

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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4 

1.0 Introduction..........................................................................................................................5 

1.1 Historical Milestones Leading Up To This Report..................................................5 

2.0 SC&A’s SEC Issue #3 – Recycled Uranium.......................................................................7 

3.0

.........................................................................................................7 

NIOSH’s November 1, 2011, Evaluation of the New Proposed Defaults as Applied 

to Group 10A Workers

4.0 References..........................................................................................................................12 
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health or Advisory Board 

DOE U.S. Department of Energy 

GDP Gaseous Diffusion Plant 

kg kilogram 

LEU Low Enriched Uranium 

MCA Materials Control and Accountability 

MgF2 magnesium fluoride 

MT metric tons 

NIOSH National Institute for Environmental Safety and Health 

NLO National Lead of Ohio 

PGDP Paducah Gaseous Diffusion Plant 

POOS Plutonium Out Of Specification 

ppb parts per billion 

RU Recycled Uranium 

SC&A S. Cohen and Associates 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TRU transuranic 

UNH Uranyl nitrate hexahydrate 

UF4 uranium tetrafluoride 

UO3 uranium trioxide 
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1.0 INTRODUCTION 

Recycled Uranium (RU) is uranium that had been previously used as reactor fuel or as target 

material in plutonium production reactors. After irradiation, the uranium was chemically 

purified to remove fission products and plutonium and other transuranics (TRU), and then 

shipped to the uranium enrichment, fabrication, and production plants for re-use. Because it is 

not possible to attain 100% product purity in chemical separation processes, quantities of several 

non-uranium isotopes remained following the uranium processing and posed a source of 

potential exposure to workers at Fernald. 

On November 1, 2011, in response to tasking by the Fernald Work Group, the National Institute 

for Occupational Safety and Health (NIOSH) provided a focused analysis of the one remaining 

point of discussion regarding RU at Fernald. That analysis, entitled Rationale for 400 ppb U Pu 

for 10A Process Stream at Fernald, Rev. 01 (NIOSH 2011c), is intended to provide quantitative 

evidence that the new proposed RU defaults provide a plausible upper bound for the group of 

workers who handled the most highly contaminated RU feed materials. This report provides 

SC&A’s response to the NIOSH analysis. It is important to note that this report provides 

SC&A’s final technical position on the RU issue at Fernald.

1.1 Historical Milestones Leading Up To This Report 

The issue of worker exposures to contaminant radionuclides in RU at Fernald has involved 

several work group meetings and many white paper exchanges. To orient the reader, a brief 

historical summary of the discussions and white paper exchanges regarding the RU issue at 

Fernald is provided. 

During the Fernald Work Group meeting held on October 28, 2008, SC&A was tasked with 

reviewing the NIOSH white paper on RU entitled, Dose Reconstruction Considerations for RU 

Contaminants at Fernald (NIOSH 2008). The direction provided by the Advisory Board on 

Radiation and Worker Health (ABRWH or Advisory Board) stated that SC&A should focus on 

the appropriateness of the default values selected for RU contaminants [Pu-239/240 (referred to 

herein as Pu-239), Neptunium-237 (Np-237), and Technecium-99 (Tc-99)], and whether the 

selected values are bounding for all workers for all time periods. SC&A’s white paper on this 

issue, entitled SC&A’s Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald: Commentary on the NIOSH White Paper (SC&A 2009), 

identified 11 deficiencies (findings) in the NIOSH white paper, which were the subject of 

extensive discussions at the January 29, 2010, Work Group meeting. During the January 2010 

Work Group meeting, NIOSH stated that it was not prepared at that time to address the various 

issues raised, but agreed to prepare a response. 

Prior to the November 9, 2010, Work Group meeting, NIOSH submitted the report, Response to 

SC&A Findings related to the White Paper on Recycled Uranium at Fernald – October 2010, 

(NIOSH 2010), which provided NIOSH’s position on each of the 11 findings in SC&A (2009). 

The 11 findings and NIOSH’s responses to those findings were the subject of intensive 

discussions at the November 9, 2010, meeting (ABRWH 2010). Two principal unresolved issues 

that emerged from that meeting prompted the Advisory Board’s request for a second white 
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paper. First, SC&A provided a compelling argument as to why the 19 subgroup process means 

derived in the U.S. Department of Energy (DOE) Ohio Field Office Report (DOE 2000) and 

reported in Table 5 of NIOSH (2008) do not provide a firm basis for bounding defaults for TRU 

and fission products. Second, SC&A’s preliminary review of the dust collector data reported in 

Appendix B of NIOSH (2008) indicated that the NIOSH default values may not be bounding for 

some classes of workers in some facilities during the proposed Special Exposure Cohort (SEC) 

period. 

SC&A’s second white paper on recycled uranium, SC&A Review of Issues Related to 

Reconstruction of Doses for Workers Exposed to Recycled Uranium at Fernald – A Second 

White Paper (SC&A 2011a), was transmitted to the Work Group prior to the February 9, 2011, 

Work Group meeting. That paper identified nine new findings that supported our position 

regarding the questionable basis for NIOSH’s proposed RU defaults, and that some categories of 

workers were exposed to TRU and fission product levels in excess of the NIOSH defaults. The 

issues were discussed in detail at the February 9, 2011, Work Group meeting. At that meeting, 

NIOSH was tasked to respond to SC&A (2011a) prior to the next Work Group meeting, 

scheduled for April 19, 2011. SC&A (2009) and SC&A (2011a) thoroughly describe SC&A’s 

concerns regarding RU. 

On April 13, 2011, SC&A transmitted Revision 1 of our second white paper on RU at Fernald 

(SC&A 2011b). That revision contained editorial corrections and a revised Table 2 that limited 

comparisons of organ doses from intakes of RU constituents to specific absorption classes. Note 

that Revision 1 did not result in changes to the findings in SC&A (2011a). Thus, unless 

otherwise indicated, all references in this document to SC&A’s second white paper are to SC&A 

(2011b). 

On April 17, 2011, NIOSH provided a response to SC&A (2011a) entitled, NIOSH Response to 

Draft SC&A Review of Issues Related to Reconstruction of Doses for Workers Exposed to 

Recycled Uranium at Fernald – A Second White Paper – February 2011 (NIOSH 2011a). 

Because SC&A did not have time to prepare a detailed response to NIOSH (2011a) prior to the 

April 19th Work Group meeting, we prepared preliminary observations for discussion at the 

meeting. It is noteworthy that at the April 19th meeting, SC&A was not tasked to respond to 

NIOSH (2011a) or perform any additional work on the RU issue. 

At the Advisory Board meeting held in St. Louis, Missouri, May 24–26, 2011, SC&A presented 

the status of our six main SEC findings regarding Fernald. Part of that presentation focused on 

our preliminary observations on NIOSH (2011a). At the conclusion of the presentation, SC&A 

was tasked by the Advisory Board to provide a formal response to NIOSH (2011a). On August 

4, 2011, SC&A provided a response to NIOSH (2011a) entitled, SC&A’s Evaluation of NIOSH’s 

Response Dated March 31, 2011, to SC&A’s Second White Paper on Recycled Uranium (Sec 

Issue #3) at Fernald (SC&A 2011c). On August 5, 2011, NIOSH submitted a paper entitled, 

Issues Related to the Ability to Bound Internal Dose from Recycled Uranium Trace Level 

Contaminants at Fernald, Draft 01 (NIOSH 2011b), which outlined their position on RU default 

values. 
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On August 11, 2011, the Fernald Work Group met and again discussed the RU issue, including 

the concerns raised in SC&A (2011c) and the position outlined in NIOSH (2011b). At that 

meeting, the Work Group agreed that the new proposed defaults for RU constituent radionuclides 

presented in NIOSH (2011b) probably provide plausible upper bounds for the most highly 

continuously exposed subgroup of workers, the Plant 5 metal production workers and associated 

Plant 1 millwrights during the period 1973–1989 (ABRWH 2011b). However, SC&A continued 

to express concern that another group of workers, those who handled the most highly 

contaminated feed materials on the front end of processing operations (Subgroup 10A in DOE 

2000), might have experienced exposures at levels higher than the new defaults. NIOSH 

indicated that they believed that those workers were exposed to the highest concentrations only 

for brief intermittent periods and would, therefore, be covered by the new defaults. At the 

conclusion of the August 11, 2011, meeting, the Work Group tasked NIOSH to provide 

quantitative evidence that the new proposed RU defaults provide a plausible upper bound for the 

Subgroup 10A handlers and downblenders. On November 1, 2011, NIOSH provided their 

analysis (NIOSH 2011c). This report provides SC&A’s response to the analysis in NIOSH 

(2011c) 

2.0 SC&A’S SEC ISSUE #3 – RECYCLED URANIUM 

SEC Issue #3 can be summarized by the following statement: Default concentrations (on U 

mass basis) of Pu-239, Np-237, and other isotopes associated with RU at Fernald may not 

be bounding for some classes of worker activities, buildings, and time periods. 

3.0 NIOSH’S NOVEMBER 1, 2011, EVALUATION OF THE NEW PROPOSED 

DEFAULTS AS APPLIED TO GROUP 10A WORKERS 

NIOSH 2011c is a focused analysis of the processes and time periods during which workers may 

have been exposed to the highly contaminated unblended subgroup 10A tower ash materials. 

The paper provides some processing data gleaned from the SRDB (Site Research Database) and 

assumptions based on those data, which are then used to justify the default contaminant values as 

bounding for all workers. Table 1 provides the NIOSH default values of Pu-239, Np-237, and 

Tc-99 for periods of time that generally correlate with levels of contaminants present in RU that 

could have exposed workers at Fernald. Note that for the period 1953–1960, prior to the 

introduction of RU into the process stream, NIOSH proposes defaults of zero. While SC&A 

believes that the exposure potential to RU at that time was low, we do not believe that defaults of 

zero represent a claimant-favorable position. 

Table 1. Summary of Proposed NIOSH RU Default Values (1973–1989) 

Radionuclide 1961–1972 1973–1989 Basis (DOE 2000) 

Pu-239 100 ppb U 400 ppb U Subgroup 8; MgF2

Np-237 3,500 ppb U 11,000 ppb U Subgroup 11; Waste Residues 

Tc-99 9,000 ppb U 20,000 ppb U Subgroup 6B; LEU* products 

*low enriched uranium 

The reader is referred to NIOSH 2011a, NIOSH 2011b, and SC&A 2011c for details regarding 

the basis for the default values in Table 1. SC&A wishes to reiterate that at the time of this draft 
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report, the only remaining RU issue to be resolved is whether the new defaults in Table 1 for 

1973–1989 provide plausible bounding values for subgroup 10A handlers and downblenders. 

The applicability of the proposed defaults for periods prior to 1973 has been agreed upon by the 

Fernald Work Group and is not addressed herein. Similarly, details regarding concentrations of 

contaminants in shipments of RU to Fernald over the operating life of the facility and the 

chemical processes that concentrated contaminants are described in SC&A 2011b. 

The most highly contaminated subgroup 10A feed materials were received at Fernald in June 

1980 from the Paducah GDP in 16 T-hoppers with a total mass of about 22.5 metric tons (MT). 

This material introduced about 25 grams of plutonium into the Fernald process stream, which 

essentially doubled the Pu inventory at the facility. Historically, this material was referred to as 

Plutonium Out Of Specification or “POOS.” Table 2 is taken from a National Lead of Ohio 

(NLO) memorandum (NLO 1985a) and provides data on the amounts and plutonium 

concentrations in the 16 hoppers of most highly contaminated POOS feed materials. 

Table 2. Recycled Feeds (Paducah Ash) 

June 1980 Hopper Uranium Mass 

(Kg) 

Pu ppb 

(Uranium basis) 

Pu ppb sample 

basis (MCA) 

Pu ppb sample basis 

(NLO) 

T-339 1,080 67 37 37 

T-392 2,888 534 377 382 

T-346 3,118 468 341 345 

T-322 2,849 253 181 184 

T-103 1,477 880 522 528 

T-293 1,233 210 116 117 

T-453 630 644 217 220 

T-122 1,615 445 283 286 

T-221 1,046 1,073 566 573 

T-439 1,080 145 73 73 

T-118 414 111 33 33 

T-449 1,405 7,005 940 2,789 

T-256 1,350 346 174 176 

T-334 684 94 34 34 

T-058 896 7,757 3,118 3,156 

T-171 765 211 94 95 

It is evident from Table 2 that the Pu content was highly variable among the hoppers (67 to 

7,757 ppb Pu on a uranium mass basis), and that in at least one hopper (T-449), measured 

quantities varied by a factor of 3. The variability and uncertainty in these data were discussed in 

detail at the April 19 and August 11, 2011, Work Group meetings (ABRWH 2011a, ABRWH 

2011b). 

This 1980 shipment of 22.5 MT was sampled and stored primarily to develop blending material 

inventories and processes to accommodate this unusual shipment. It is important to note that this 

material was not immediately downblended upon receipt. After approximately a 2-year period, 

in April and May of 1982, five of the T-Hoppers with high contaminant levels were repackaged 

into large drums in Plant 4 to facilitate process needs in Plants 8 and 2/3 (Weidner 1982, Air 

Sampling at Plant 4 During Repackaging of PGDP Wastes, SRDB 33730). That is, repackaging 
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into drums allowed for remote and semi-remote handling of the material during subsequent 

processing steps. Air sampling records associated with this repackaging are recorded, as well as 

the time required. Table 3 contains data on repackaging times from Weidner (1982). 

Table 3. Repackaging Data – Subgroup 10A 

Date Shift Hopper PU ppb 

(U mass)* 

Mass 

(Kg) Shifts 

4/19/1982 1 346 468 3,118 3 

4/20/1982 1 346 468 

4/21/1982 1 346 468 

4/21/1982 2 392 534 2,888 8 

4/21/1982 3 392 534 

4/22/1982 1 392 534 

4/23/1982 1 392 534 

4/26/1982 1 392 534 

4/27/1982 1 392 534 

4/28/1982 1 392 534 

4/29/1982 1 392 534 

4/30/1982 1 122 445 1,615 2 

5/1/1982 1 122 445 

5/2/1982 1 449 7,005 1,405 4 

5/3/1982 1 449 7,005 

5/4/1982 1 449 7,005 

5/5/1982 1 449 7,005 

5/6/1982 1 322 253 2,849 2 

5/7/1982 1 322 253 

Totals 11,875 19 

Though the information in Table 3 provides quantitative information on the time required to 

repackage some of the POOS material from hoppers into drums, neither NIOSH nor SC&A were 

able to locate quantitative information on the times required to process the subgroup 10A 

material after repackaging. NIOSH indicates that because the five hoppers identified in Weidner 

(1982) were those with the greatest concerns and difficulties, the times of repackaging could be 

used to estimate the repackaging times of other hoppers. They further assume that because 

subsequent processing steps such as calcining and blending involved semi-remote handling, the 

repackaging times would provide a sufficiently accurate and plausible bound on the time that any 

worker would have been exposed to unblended POOS material. NIOSH 2011c provides the 

following instructive excerpt regarding post-repackaging processing of the POOS material (NLO 

1985a, pg. 50): 

Paducah Feed Plant Ash was prepackaged from hoppers into drums in Plant 4. 

Drummed material was later blended with sump cake in the rotary kiln operation 

in Plant 8 producing seven lots of calcium uranate, which was used as feed for the 
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s 

erations. 

refinery. Most of this material was converted to UO3; a quantity remains as 

UNH in the refinery. UO3, which was contaminated with the plutonium, remain

on inventory at NLO. The remainder of the UO3 was converted to UF4 and 

blended with three parts of UF4 produced from Hanford UO3 in the metal 

reduction op

The quote above indicates that the blended calcium uranate (now below the 400 ppb Pu (U) 

default level) was dissolved in Plants 2/3, resulting in liquid UNH. Again, the materials were 

stored until appropriate processing to UO3 was available. 

The next reference to processing of the subgroup 10A material is found in a 1985 NLO 

document entitled, Processing 168 MTU of UO3 Containing Recycle Contaminants, (NLO 

1985b). This document is instructive on several levels. First, it indicates that Pu and Np-237 

concentrations in materials processed to UO3 were about 34 and 662 ppb (U) respectively. This 

material was to be further blended with “clean UO3” prior to fluorination to UF4 in Plant 4, and 

again downblended prior to reduction to metal in Plant 5 with clean UF4. 

NLO 1985b also indicates that unblended POOS materials were occasionally processed through 

to metal: 

...This represents a 26-fold increase in concentration, or a Pu content of 676 ppb. MgF2

analyses to date have not yielded any results that high even though materials with 

similar Pu content have been processed without conscious attempts at blending. 

[Emphasis added.] 

This last statement is important because it indicates that pathways other than chemical 

concentration mechanisms resulted in the high concentrations observed in MgF2 in the 

1980s. The topic of whether the original defaults (e.g., 100 ppb Pu) would adequately bound 

Plant 5 metal production workers and associated Plant 1 millwrights who were exposed to high 

constituent concentrations in MgF2 in the pre-1973 period was discussed in the April and August 

2011 Work Group meetings (ABRWH 2011a, ABRWH 2011b). At that time, SC&A contended 

that if chemical concentration of downblended material was the sole mechanism that resulted in 

the high concentrations in MgF2 documented in DOE 2000, then the higher defaults (e.g., 400 

ppb Pu) would apply during the entire period of metal production employing RU, and not just 

after POOS receipts began in 1973. The discovery of NLO 1985b among the 49 new references 

identified in NIOSH 2011c was a key factor in SC&A’s acceptance of the original defaults for 

the 1961–1972 timeframe. SC&A was also concerned about the high dust concentrations 

reported in Plant 1 mill areas that were reported in Appendix B of NIOSH (2008), because they 

may have resulted from milling of unblended materials in addition to recycled MgF2. Given that 

unblended POOS materials were occasionally processed, SC&A’s concerns in this regard appear 

to have been warranted. 

Based on the information in Table 3 and several somewhat subjective assumptions, NIOSH 

concluded that any given worker continuously involved in POOS handling would have spent no 

more that about 8% of a year’s work exposed to materials with concentrations greater than 

400 ppb Pu. Thus, they determined that in aggregate, 400 ppb was inclusive for all workers. 

Assumptions included a 5-hour shift to account for documented respiratory protection and 
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protective clothing, and that only the hoppers with Pu concentrations over 400 ppb were of 

concern. 

SC&A used the data in Tables 2 and 3 and applied more conservative assumptions to calculate 

that about 14% of a worker’s annual time could have been dedicated to unblended POOS 

handling, and that the weighted average Pu concentration experienced by the workers was less 

than 400 ppb. Our calculations were based on the following facts and assumptions. 

 Average plutonium concentration in the 16 hoppers on a U mass basis was about 

1,122 ppb (Table 2) 

 Assumed baseline concentration for other than Plant 5 metal workers = 100 ppb 

 Shift time = 8 hours (no reduction for protective measures and respirators) 

 Average mass processed per shift = 11,875 kg/19 shifts = 675 kg/shift (Table 3) 

 Given 8 hours per shift, it would take about 288 hours in 36 shifts to process all 16 

hoppers 

 Maximum percentage of annual time allotted to POOS handling = 288/2,080 = 13.86% 

Weighted average Pu concentration over a year (Puavg): 

Puavg = [(1,792 hours × 100 ppb) + (288 hours × 1,122 ppb)]/2,080 hours = 242 ppb

In summary, SC&A agrees that the repackaging intervals provided in Table 3 can probably be 

used in conjunction with conservative assumptions regarding shift intervals to reasonably 

estimate a period during which workers could have been exposed to unblended POOS. While we 

may disagree with NIOSH over the choice of particular assumptions in determining the 

timeframe, our own calculations suggest that the new NIOSH defaults in Table 1 for 1973–1989 

adequately bound exposures experienced by subgroup 10A workers. 

Given that this was the last remaining Fernald Work Group issue to be resolved regarding RU 

exposures, we believe that the topic of RU exposures at Fernald can be moved to site profile 

discussions. 
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4.0 REFERENCES 

ABRWH 2010. Transcript of the Advisory Board on Radiation Worker Health Work Group 

Meeting on Fernald, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

November 9, 2010. 

ABRWH 2011a. Transcript of the Advisory Board on Radiation Worker Health Work Group 

Meeting on Fernald, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

April 19, 2011. 

ABRWH 2011b. Transcript of the Advisory Board on Radiation Worker Health Work Group 

Meeting on Fernald, National Institute for Occupational Safety and Health, Cincinnati, Ohio. 

August 11, 2011. 

DOE (U.S. Department of Energy) 2000. Recycled Uranium Project Report, DOE 00-0001, 

Ohio Field Office. May 15, 2000. 

NIOSH 2008. Dose Reconstruction Considerations for RU Contaminants at Fernald, White 

Paper, Bryce L. Rich and Paul E. Ruhter, National Institute for Occupational Safety and Health, 

Cincinnati, Ohio. March 2008. 

NIOSH 2010. Response to SC&A Findings related to the White Paper on Recycled Uranium at 

Fernald - October 2010, National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. 

NIOSH 2011a. NIOSH Response to Draft SC&A Review of Issues Related to Reconstruction of 

Doses for Workers Exposed to Recycled Uranium at Fernald – A Second White Paper – 

February 2011, Rev. 0, March 31, 2011. National Institute for Occupational Safety and Health, 

Office of Compensation Analysis and Support, Cincinnati, Ohio. 

NIOSH 2011b. “Issues Related to the Ability to Bound Internal Dose from Recycled Uranium 

Trace Level Contaminants at Fernald, Draft 01” August 5, 2011. National Institute for 

Occupational Safety and Health, Office of Compensation Analysis and Support, Cincinnati, 

Ohio. 

NIOSH 2011c. “Rationale for 400 ppb U Pu for 10A Process Stream at Fernald, Rev. 01.” 

November 1, 2011. National Institute for Occupational Safety and Health, Office of 

Compensation Analysis and Support, Cincinnati, Ohio. 

NLO (National Lead of Ohio, Inc.) 1985a. Letter with attachments to J.A. Reafsnyder (DOE) 

from J.A. Spencely (NLO) entitled, Joint Task Force on Recycle Material Processing. April 29, 

1985. SRDB Ref ID: 95213. 

NLO (National Lead of Ohio, Inc.) 1985b. DOE Contact Report, Processing 168 MTU of UO3

Containing Recycle Contaminants, July 31, 1985. SRDB Ref ID: 33901. 
Effective Date: 

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

SC&A 2009. SC&A’s Review of Issues Related to Reconstruction of Doses for Workers Exposed 

to Recycled Uranium at Fernald: Commentary on the NIOSH White Paper, SC&A, Inc., Vienna, 

Virginia. March 2009. 

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