. 

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

135th Meeting

Thursday, August 27, 2020

The meeting convened at 1:15 p.m., Eastern 

Daylight Time, via Video Teleconference, Rashaun 

Roberts, presiding. 
2 

Present: 

Rashaun Roberts, Designated Federal Official

Henry Anderson, Member

Josie Beach, Member

R. William Field, Member

David Kotelchuck, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Registered and/or Public Comment Participants: 

Adams, Nancy, NIOSH Contractor

Barton, Bob, SC&A

Barrie, Terrie, ANWAG

Burgos, Zaida, NIOSH 

Burns, Bob, ORAU

Buchanan, Ron, SC&A

Calhoun, Grady, NIOSH 

Cardarelli, John, NIOSH 

Cisco, Jeanne, Worker Health Protection 

Program

Crawford, Chris, DOL

Fitzgerald, Joe, SC&A

Gogliotti, Rose, SC&A

Hughes, Laura, NIOSH 

Lobaugh, Megan, DCAS

Naylor, Jenny, HHS

Nelson, Charles, NIOSH 

Rutherford, Lavon, DCAS

Sundin, Dave, NIOSH 

Taulbee, Tim, DCAS

Tomes, Thomas, NIOSH
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 135th Meeting 

Thursday, August 27, 2020 1

Roll Call/Welcome 4

Hanford SEC Petition 57 6

Board Work Session 13

Work Group and Subcommittee Reports 21

Josie Beach, Metals and Controls 21

David Kotelchuck, Dose Reconstruction 

Reviews 22

Genevieve Roessler, ORNL X-10 22

Paul Ziemer, Update on Lawrence 

Berkeley 26

Henry Anderson, Sandia and URAWE 26

Review of Comments from December 32

SEC Update 37

Idaho National Laboratory Update 44

Reduction Pilot Plant SEC Reduction 253 58

Adjourn 87
4

Proceedings

(1:15 p.m.)

Roll Call/Welcome

Dr. Roberts: Good afternoon and good morning, and 

welcome everyone. I am the designated federal 

official for the Advisory Board on Radiation and 

Worker’s Health. And I would like to welcome you 

all to the second and final half-day of Board Meeting 

135.

So like yesterday, let me just go through some 

preliminaries for this meeting to keep things 

running as smoothly as possible. So, if you’re just 

on the telephone, all the materials for today -- the 

meeting agenda, presentations and other 

documents are all posted and you can find them on 

the NIOSH website for this program under Schedule 

of Meetings for August 2020.

So can go there, read all the materials and you can 

also follow along with the presentation. And all of 

the materials were provided to the board members 

and to other staff prior to this meeting.

If you look at the agenda on the website -- and, 

again, for today, we have a fair bit of content to 

cover, there’s at least one break built into the 

agenda for each day. And as time allows, we can 

take more comfort breaks, if time permits.

At the top of the agenda, there’s a Skype link which 

will enable you to watch the presentation through 

Skype. But just to advise you, you will only be able 

to speak to the group through the telephone lines 

and hear the presentation through the telephone 

lines.

So in order to keep everything running smoothly 

and everyone speaking can be clearly understood, 

you’ll need to please mute your phones unless, of 

course, you are speaking.
5

If you don’t have a mute button, press Star 6 to 

mute. If you need to take yourself off mute, press 

Star 6 again.

And because we are unable to see each other for 

this meeting, please identify yourself before your 

comments or questions. 

So let me, before we start getting into the agenda, 

let me speak to the conflict of interests. We have 

two agenda items that relate to conflict of interest. 

One is for the Hanford SEC petition. And Josie Beach 

is conflicted for that.

The other is for the update on Idaho National 

Laboratory Site Profile Review, and Brad Clawson is 

actually conflicted for that one. But I don’t expect 

that Brad will join us for today.

So Josie, you will need to abstain from the Hanford 

discussion and any voting or casting matters 

concerning this site by disconnecting from the call 

between 1:15 and 2:45 Eastern.

When we get to that agenda item I will note that 

you’re abstaining for the record and remind you to 

disconnect.

There appear to be no other conflicts to address for 

this meeting. So let me do roll call now. I’ll start 

with the board members in alphabetical order.

(Roll call)

Dr. Roberts: Okay. Well, thank you so much. And 

let’s go ahead and move further into the agenda. 

Again, if you would please check your phone and 

make sure that it’s muted. If you don’t have that 

mute button, press Star 6 to mute and Star 6, 

again, to take yourself off. 

So, with no further ado, let’s get started, so, Josie, 

if you would go ahead and disconnect from the call 

now and plan to rejoin us after the Hanford agenda 

item, that would be great. And I’m noting your 
6

disconnection for the record at this time.

Member Beach: Okay, thank you.

Hanford SEC Petition 57

Dr. Roberts: Thank you. Okay, so for Hanford, Mr. 

Brad Clawson is the chair of the Hanford Working 

Group, but he was unable to attend this meeting. 

So I believe that Dr. Paul Ziemer agreed in our last 

Work Group meeting to present on the Work 

Group’s behalf with some help from SC&A. So, Paul, 

I’ll go ahead and turn the floor over to you.

Member Ziemer: Okay, thank you very much. And 

the slides that we’re using today were prepared, 

actually, by SC&A, by Joe Fitzgerald and I think Ron 

Buchanan were both involved in that, and both are 

on the line today so they can help out when I run 

into difficulties.

The SEC history of Hanford is pretty complex and I 

can’t go through all of the background details here, 

but I do want to point out you can get a good 

summary of what has transpired, starting with SEC 

00057 and the subsequent study into parts of that 

SEC as well as subsequent SEC petitions. 

You can find a good summary of these in the NIOSH 

white paper that we’ll be talking about today. It’s 

entitled, Assessment of Hanford SEC Issues, and it’s 

dated January 7th, 2020.

Here on the slide before you, you see an 

abbreviated version of this. And you’ll note that our 

discussion today focuses on a portion of the SEC 

evaluation for SEC 00226. That petition was actually 

an 83.14 type of petition initiated by NIOSH. And 

they recommended adding a Class for contractors 

and sub-contractors who were not employees of the 

prime contractors during the period of January ‘84 

through December ‘90.

And as a part of the evaluation of this SEC, NIOSH 
7

has evaluated or carried out an evaluation of 

individuals who are employees of the named prime 

contractors.

That January 7th white paper that I just referred to 

provides the status of the NIOSH assessment for 

the remaining SEC issues. And the Work Group has 

met twice since that paper to review issues raised 

by SEC from its review of the NIOSH white paper.

SEC provided its review to the Work Group in an 

April 2020 meeting and provided an additional 

memorandum on June 24th that summarized the 

actions of the April meeting and went over the 

remaining actions that were required.

So let’s go on to the next slide. This slide presents 

the overall conclusions to the NIOSH white paper. 

And you’ll notice here -- let me start on the left side 

-- you’ll notice the reference to SEC 00201.

That was an 83.14 petition also which added a class 

for July ‘72 through December ‘83. And the basis for 

the class established by 00201 was that NIOSH 

lacked sufficient information to allow it to estimate 

with sufficient accuracy the internal exposures to 

purified highly enriched uranium, U-233, 

neptunium, and thorium.

And the Evaluation Report for 00201 was approved 

by NIOSH in June 2012. It was accepted by the 

Board in July of 2012. And that evaluation report 

determined the dose reconstruction was feasible 

from ‘84 onward for employees of the prime 

contractors.

The overall conclusions for the assessment are 

shown on the right side of the slide. And you can 

read those there, starting with radionuclides of 

concern with no evidence of large-scale use of the 

radionuclides of concern or any cases of potential 

chronic sources of intake were present.

On the issue of lack of routine monitoring data for 

nonchronic sources, NIOSH has pointed out that this 
8

does not equate to dose reconstruction infeasibility.

Then on programmatic incident reporting, if it’s 

clear that bioassay methods were available for all 

the radionuclides of concern. And those -- or that 

bioassay was used when needed. And finally, on 

workplace monitoring, the workplace monitoring 

was backed up by a routine bioassay program.

Let’s go on to the next slide. So this slide is a 

listing of issues that have been the focus of the 

Work Group meetings this year, starting with 

radionuclides of concern, and you see them listed 

here. Then let me elaborate a little bit on each one 

of those. And the SC&A issue numbers are listed 

beside the radionuclide identifications.

On thorium-232, that issue had to do with potential 

thorium exposures during remediation, the use of 

thorium in fuel fabrication in the 300 area and the 

possible use of thorium in some of the other 

Hanford areas.

SC&A has agreed that there’s no evidence of 

process use --

Dr. Roberts: I have one --

Member Ziemer: I’m sorry -- in operations involving 

thorium-232.

Dr. Roberts: Please, just a reminder to put yourself 

on mute, please.

Member Ziemer: SC&A agreed there’s no evidence 

of process use and operations involving 232 in the 

1984 to 1990 timeframes, nor were there any 

incidents involving intakes of that.

The HEU, highly enriched uranium issue, SC&A had 

questions on whether or not NIOSH had sufficiently 

confirmed lack of operations involving HEU in the 

308 building, particularly given that it was unknown 

how frequent the operations involving enriched 

uranium took place.
9

However, SC&A agrees that routine bioassay would 

have presumably detected any enriched uranium 

incidents. 

The issue on Uranium-232, SC&A had questioned 

whether or not NIOSH had investigated scrap 

solutions of U-233 in the Plutonium Finishing Plant 

and possible applications in experimental work in 

the 300 area.

And after all was evaluated, NIOSH -- or SC&A 

agreed that NIOSH had done a broad review which 

included interviews and -- area-specific records. I 

think we’re getting interference here again, but I’ll 

go ahead.

NIOSH had reviewed or had a broad review that 

included interviews and area-specific records and 

material control and accountability records, so SC&A 

agreed that they had covered that well.

And then on neptunium-237, the issue of intakes for 

Hanford, SC&A agreed that there was no evidence 

of potential chronic intakes of neptunium-237. And 

the incidents were limited to one in ‘89 that 

involved chemical separation work and there had 

been adequate bioassay follow-up, so that 

neptunium issue was also resolved.

There were also some programmatic issues here, 

one dealing with special tritium compounds and, in 

particular, a concern about the possibility of metal 

tritides, one that we’ve run across in other facilities, 

whether or not that could be potentially present.

But SC&A agreed that there’s no evidence of any 

post-irradiation examinations of irradiated tritium 

target rods and any potential exposures to such 

tritiated compounds could be addressed if NIOSH 

does, in fact, identify an exposure source of metal 

tritides.

Let’s go on to the next slide. It really summarizes 

those resolutions. I mentioned the radionuclides of 

issue. The -- and I mentioned the tritium. The other 
10

issues, the N Reactor skin contamination issue, that 

was resolved by demonstrating that there were 

adequate monitoring records.

Closed monitoring related to minor incidents were 

handled by review of the incident reporting system 

and bioassay records. And the possibility of Building 

324 leaks was resolved by review of the incident 

reports.

So the Work Group has closed all of those issues, 

the ones we’ve just summarized. But there are 

some remaining issues that are broader, looking 

forward, that relate to the SEC in the Site Profile.

One enumerated Issue, 14, and Issue 23 -- Issue 

14 deals with estimated plutonium intake and Issue 

23, the adequacy of the REX database. These are 

SEC-related issues. And they’re also some coexposure model issues that will have to be dealt 

with, and the issue numbers are there.

These are non-SEC related and they deal with the 

site profile matters that will have to be dealt with 

going forward. There’s an issue related to intake 

estimates for recycled uranium at Issue 8 and 

another one on external exposure geometries, a 

generic issue that might have to move to the 

broader database of how we deal with 

programmatic issues.

So, finally, well, let’s see. Is that the last one? One 

more slide? Oh, yes, the Work Group and NIOSH 

agreed that NIOSH would take several actions. 

They’re enumerated here.

One is to complete the co-exposure models based 

on Implementation Guide and that is scheduled for 

later this year. Hopefully, this, within a couple 

months -- oh, not this year -- couple years off if this 

slide is correct. 

I’d forgotten it was showing as 10-22. Is that the 

correct estimate date on that? I’ll have to ask the 

NIOSH people that in a minute.
11

And then once the SEC issues a result or revised the 

site profile, then those changes will have to be 

evaluated in the Program Evaluation Report.

So that completes the slides. I did want to clarify 

that October date. Was that the correct date 

estimated by NIOSH?

Mr. Nelson: Dr. Ziemer, this is Chuck Nelson. That’s 

the completion date. The project start date is the 

end of this year, December 2020, but this slide 

involved to do a co-exposure evaluation --Member 

Ziemer: Right.

Mr. Nelson: -- that have been involved. So that is 

the correct completion date. But it’ll be getting 

started here in just a few months.

Member Ziemer: Right. So there’s still a lot of work 

to do. So, this is basically a status report. There’s 

no action needed by the full board at this time, but 

it’s appropriate to ask some the questions and both 

SC&A and NIOSH are the folks to answer the 

questions, probably.

Dr. Roberts: So any questions on the presentation?

Member Valerio: So this is Loretta. I have a 

question. Can you hear me all right?

Member Ziemer: Yes, go ahead, Loretta.

Dr. Roberts: Yes.

Member Valerio: Okay, so the SEC remaining issues 

on the plutonium intake and the database, the 

SC&A completion date on those two issues will be 

2022 as well since they’re part of the co-exposure 

model?

Mr. Nelson: That’s correct. The --

Member Ziemer: I believe that’s correct.

Mr. Nelson: -- something else in NIOSH?
12

Member Ziemer: Yes.

Mr. Nelson: Yes, that is correct.

Member Valerio: All right, thank you.

Member Ziemer: Any others? And, Joe or Ron, do 

you have any additional comments or clarifications?

Mr. Fitzgerald: Yes, this is Joe Fitzgerald. I think 

that covered it pretty comprehensively. The only 

comment I would offer is that I think NIOSH and 

SC&A were able, through quite a bit of data capture 

and interviews, to settle out the nuclide-specific and 

facility-specific issues.

I mean, as Dr. Ziemer enumerated, there were 

quite a few of those at Hanford, as you can imagine, 

with that long history. So the question of adequate 

data for all these force terms and operations, I 

think, did take a considerable amount of effort.

I think that is what we’re reporting can be -- and 

the Work Group did close out. So that leaves 

essentially the co-exposure model as the remaining 

item. And -- but I think that is quite a lot of work 

that has been accomplished to settle out those 

issues.

So I think this, again, is a status that says that we 

await the co-exposure model to be developed. And 

that should address whatever remains as identified 

in those two items.

Mr. Nelson: Yes, this is Chuck Nelson from NIOSH. I 

guess one thing I did want to add is that during the 

review of this co-exposure model and the evaluation 

of such, if we find any dose reconstruction 

infeasibilities during this evaluation, NIOSH will kick 

into action a 83.14 and make a suggestion to 

designate a SEC class.

So just wanted to make that clear that this was 

going to be an ongoing effort, quite involved, in 

fact, and it will take some time. And anybody here 
13

with the advisory board that’s been involved with 

these co-exposure evaluations, they know that 

involves a lot of work.

So it’ll be looking closely at all this data to see if we 

can reconstruct dose for these unmonitored workers 

and make sure the models we have in place are 

adequate to do such.

Dr. Roberts: Any other questions or comments 

about this presentation? Okay, hearing none for the 

time being, I believe there is a, you know, there’s a 

space on the agenda for any petitioners to present 

or to comment on Hanford.

Okay, I’m not hearing any. And so, Paul, you said 

that, at this point, there’s no action or anything like 

that.

Member Ziemer: No, we -- the Work Group 

specifically talked about whether action is needed. 

We regarded this mainly as an update, even though 

we’ve closed a number of items here. 

But as you see, there’s still a lot of work going 

forward, so there’s no action needed at this time.

Dr. Roberts: Okay. Great. So you were right in your 

assessment that we’re about an hour ahead of --

Member Ziemer: Right, right.

Dr. Roberts: -- had planned in terms of these 

agenda item.

Member Ziemer: Right.

Board Work Session

Dr. Roberts: So I’m wondering how best to proceed. 

We do have the board work session. And I believe 

it’s permissible for us to, you know, go to that 

session, unless other people have ideas for what we 

need to do next.

I know the SEC petition’s update is next. What are -
14

- what’s preferenced?

Member Ziemer: Probably, I think doing some work 

group activities or board activities would be 

probably a good way to do it.

Dr. Roberts: Okay.

Member Kotelchuck: Sounds

Dr. Roberts: Great. Okay. Then why don’t we do 

that? And then we can get started with the Board 

Work Session.

Member Beach: Rashaun, this is Josie. I’m back on.

Dr. Roberts: Perfect. Thank you, Josie. And what we 

talked about was that, since we’re so -- about an 

hour ahead of the end time for that agenda item, 

we were going to do the Board Work Session. Does 

that sound agreeable to you?

Member Beach: Yes, it does. Sounds good.

Dr. Roberts: Okay, great. Well then let’s jump right 

in. So the first thing under the Board Work Session 

is that, you know, we need to schedule some 

meetings to get some clarity around a few items 

with regards to upcoming meetings.

So we’ll just take it from there. So let’s start with 

what’s up and coming. Let me just say that there is 

an October 27th teleconference planned for the 

Board where we will -- the primary focus will be 

planning for our full board meeting in December.

And that’s currently scheduled for October 27th at 

11:00 a.m. Eastern Time. And that will just be a 

regular teleconference.

And then the full board for December is planned for 

December 8th and 9th with a start time of about 

1:15 p.m. Eastern Time. And what we’re trying to 

do for that, since there hasn’t been any clearance or 

word that travel is in order, we’re going to just plan 

to do that full board meeting via Zoom.
15

So that’s just to kind of give you an update on 

where those two meetings stand. Are there any 

questions about those? Okay, hearing none -- so 

let’s move on to April of 2021.

And I believe at -- it might have been the June 

teleconference I might have indicated that that 

meeting would be tentatively scheduled for April 

21st and 22nd. And I need to revise that because 

we’re going to need to move that date up about a 

week.

Zaida has an important commitment that she has to 

attend to. So the alternative date would be April 

14th, which is the previous Wednesday, and April 

15th. Is that doable for you all?

Member Beach: Zaida, this is Josie. It’s good for 

me.

Member Lockey: Jim Lockey, good for me.

Dr. Roberts: Great.

Member Valerio: Loretta, good for me.

Member Roessler: This is Gen, good for me.

Dr. Roberts: Okay. Is there anyone it’s not good 

for? Okay, well, assuming that we can move 

forward with that, we’ll go ahead and plan for the 

14th and 15th of April 2021 for an in-person full 

board meeting.

So now that we’ve had that established, let’s talk a 

little bit about potential locations that might be 

appropriate for that meeting. So let me just open 

that up to you all.

I know that we were supposed to have something in 

Washington State at one point. Then it was Idaho 

Falls. Are those two locations contenders for this? 

Or, you know, what are the thoughts?

Member Beach: I’m curious where we’ll be with 

Savannah River by then.
16

Dr. Roberts: I know. And that Work Group doesn’t 

meet until November 17th and the 20th, so it would 

be a while before that Work Group would come 

together.

What about other thoughts or ideas for location?

Member Kotelchuck: It’s hard to think about what 

will be -- what our situation will be. So, and to 

foresee where we’ll be finished or what we’ll be 

finishing. So, to my mind, it’s rather hard to decide 

now on any location. 

Maybe I’ve just been house-bound too long, but it’s 

just a big world out there.

Dr. Roberts: Yes, yes it is hard to forecast that far 

into the future. Would a better approach for now be 

just to throw out say three potential locations and 

then assess them later? Would that be helpful?

Member Kotelchuck: It would be. It would be. 

Member Beach: Yeah, this is Josie. I agree with that 

approach.

Dr. Roberts: Okay. So, one potential would be 

where the Savannah River site is located. And what 

about others?

Member Beach: I think Idaho should definitely stay 

on the list.

Dr. Roberts: Mm-hmm. Okay. Yeah, that makes 

sense. What about where -- I forget the city, but 

the Washington State location? Would it --

Member Ziemer: Well, that would be Richland, 

Washington. And the only reason for going there 

would be if we had anything in Hanford that’s 

critical and I’m not sure we’re at that point.

Dr. Roberts: Okay.

Member Ziemer: Well, where do we stand on Y-12? 

Anybody know? Anything going on there that we 
17

need to meet at Oak Ridge?

Member Beach: There is a meeting coming up for 

that.

Member Kotelchuck: Yeah.

Dr. Roberts: Yeah, there’s a meeting up and coming 

for that one.

Member Beach: And we are doing --

Member Ziemer: Yeah, I can --

Member Beach: Oak Ridge documents are being 

reviewed in May, may be ready soon, but I bet 

LaVon has some ideas.

Mr. Rutherford: Yes. I was just going to say, we are 

working on an addendum that covers the ‘87 to --

1987 to 1994 period. I expect that addendum will 

probably be out around October timeframe.

And as Josie indicated, we have other documents 

that are being reviewed as well, including the 

additional document that we actually received a 

week or two ago that we spoke about last night.

I think the only thing that we would probably be 

ready for would be an update that we could provide 

if it was done at Y-12 at that time.

Member Ziemer: When did we last meet in Oak 

Ridge? It’s been a couple years, right?

Member Roessler: It’s a couple years, I think. We 

have a --

Dr. Taulbee: August. This is Tim Taulbee. We met in 

Oak Ridge last August, so it was one year ago.

Member Ziemer: Oh, just a year? Okay. Time flies. 

What about Savannah River? How long’s that been?

Member Beach: Now that one’s been a few years 

ago.
18

Dr. Taulbee: Yeah, I’m thinking it was three -- this 

is Tim Taulbee again. I believe that was about three 

years ago. But that’s already on your potential list 

of Savannah River, Idaho and here in Oak Ridge 

here, so.

Member Kotelchuck: Yeah, I believe that’s correct, 

Dave. 

Member Ziemer: Would we have enough material 

that we could have a good update for Savannah 

River at that point, in April?

Dr. Taulbee: This is Tim again. We’d certainly have 

enough material for an update. That’s pretty much 

guaranteed, especially after the two-day Work 

Group meetings that we’re going to be doing in 

November.

So an update would fully be in order, from that 

standpoint. As far as having the SEC wrapped up, 

that’s a bit questionable to me at this point, and it 

depends upon how those November meetings go, so 

I don’t know the answer to that.

Member Ziemer: Well, so --

Dr. Taulbee: Who’s speaking?

Member Ziemer: Yeah, Ziemer again. I’m sort of 

asking, do we have to wait till it’s wrapped up or is 

it important to give an update?

Dr. Taulbee: We can certainly do an update. That’s 

not a problem. 

Member Beach: Yeah, and I think it’s important to 

give the update, not necessarily do the wrap-up, in 

the location that we’re meeting.

Ms. Adams: The last -- this is Nancy Adams. The 

last time we were in Augusta was March of ‘13 and 

then followed up again in March of ‘14.

Member Ziemer: That’s a long time.
19

Ms. Adams: I’m sorry, April, April of ‘14.

Member Ziemer: It’s been six years. Ms. Adams: 

Since Augusta, right.

Member Anderson: Yes, that’s a long time.

Member Ziemer: Sounds like we’re due.

Member Kotelchuck: Yeah. And that’s a nice time of 

year down in Augusta, in the springtime. Weather’s 

pretty good.

Dr. Roberts: Okay. So it sounds like, so far, just to 

summarize, we have Augusta for the Savannah 

River site; also Idaho Falls, possibly, and Oak Ridge.

Member Ziemer: Mm-hmm.

Dr. Roberts: Okay. Should we add any other 

locations to this list of candidates?

Okay, not hearing anything, let’s talk a little bit 

about the teleconference that would follow that 

face-to-face meeting. And I have here that should 

be scheduled for the week of June 21st, 2021.

And it seems like the Board -- Wednesdays or 

Thursdays seem to be the best days for people. 

Would there be a preference that week for 

Wednesday, the 23rd, or Thursday, the 24th?

Member Beach: This is Josie. I’m good with sticking 

with Wednesdays.

Dr. Roberts: Okay.

Member Ziemer: Ziemer here. Wednesday’s good 

for me also.

Dr. Roberts: Okay.

Member Kotelchuck: I’m fine with Wednesday.

Member Schofield: Yeah, I’m okay too.

Dr. Roberts: Any -- okay, perfect. Anyone --
20

Member Valerio: This is Loretta. Either day works 

for me.

Dr. Roberts: Okay. All right, anyone else want to 

weigh in? Okay, so it looks like we’ll go for 

Wednesday, June 23rd for the teleconference.

And then we need to identify a date to meet faceto-face. My understanding is that these things are 

planned a year out. So, we need to at least get a 

rough time for the face-to-face meeting that is 

supposed to occur next August.

And I have here that the week of August 23rd, 2021 

would be the candidate week for this. Are there any 

folks who would not be available to tentatively 

schedule this?

Member Beach: Rashaun, can you give those dates 

again? August --

Dr. Roberts: That would be August 25th, which I 

think is a Wednesday, and August 26th.

Member Beach: Yes, it is.

Dr. Roberts: Okay, will be the Thursday. So how do 

those look for people?

Member Beach: Sounds okay. 

Member Kotelchuck: That’s okay with me.

Dr. Roberts: All right now. Should we book this now 

so nothing else comes in?

Member Kotelchuck: Well, we can hold it. 

Member Ziemer: Yeah, let’s pencil it in.

Dr. Roberts: Okay. Great, okay, so we will hold, 

again, August 25th and 26th, 2021 for a potential 

face-to-face meeting.

Okay, so does anyone want to -- have any 

questions or anything about scheduling any of these 

meetings at this point? Or are we all on the same 
21

page?

Member Ziemer: We’re good.

Work Group and Subcommittee Reports

Dr. Roberts: Okay. Okay, perfect. Well, if 

everybody’s okay with that, we can start going into 

the Work Group and subcommittee reports.

And so I will basically turn the floor over -- if 

someone could mute their phone? I can hear 

something in the background. Thank you. 

So if we want to just move ahead with the Work 

Group and subcommittee reports, I’ll hand the floor 

over to the chairs of those groups and 

subcommittees. Who would like to start?

Josie Beach, Metals and Controls

Member Beach: This is Josie. I’ll go ahead and start 

off. So you already mentioned Metals and Controls. 

We have a Work Group scheduled for September 

2nd, and so that one -- none of my other Work 

Groups have anything new to report.

But procedures, I will mention that SC&A compiled a 

list of technical guidance and PERs that have 

outstanding findings and observations. This was 

sent out to myself. 

I don’t know if it went out to the rest of the 

Subcommittee, but it went to myself and NIOSH in 

July. We are waiting for a response from NIOSH 

looking at those outstanding items, to give us an 

indication of when they’ll be ready for another 

subcommittee meeting.

I don’t remember offhand when the last 

Subcommittee meeting was, which tells me it’s been 

a very long time ago. So, hopefully, we’ll hear 

something from NIOSH and we’ll be able to move 

forward with scheduling another meeting for 

Procedures. And that’s all I have, Rashaun.
22

Dr. Roberts: Great. Who’s next?

David Kotelchuck, Dose Reconstruction Reviews

Member Kotelchuck: The Subcommittee on Dose 

Reconstruction Reviews, we had a meeting, as you 

know, on July 29th, a very useful meeting. And we 

reviewed cases from Set 25, continuing our review 

on that set.

And then we went into review cases for Set 27, a lot 

of Category 1 cases. Now we have our next meeting 

set, I understand, for November 4th. I don’t -- we 

had -- that was our first choice, and I’m not sure --

we had to check whether everybody could make it.

And I’ll come back to that in a second, Rashaun. But 

we, at that meeting, it’s either November 4th or the 

week previous, October 20-something -- we will go 

over the three of the six blind cases that we 

selected from Set 26.

And then we’ll go back to finishing further on Sets 

25 and 27. And, Rashaun, I wondered -- we had 

originally had the two dates with November 4th, the 

preferred one. And I don’t remember who had to be 

-- who you had to check with or who we had to 

check with.

Dr. Roberts: Yes, we did hear back from everyone. 

So November 4th is the date.

Member Kotelchuck: Good.

Dr. Roberts: And just for your awareness, I’ll be 

sending the Federal Register notice package on 

Monday.

Member Kotelchuck: Excellent, excellent. Okay, so 

November 4th it is. And that’s fine. Good. That’s it.

Dr. Roberts: Okay. Who would like to go next?

Genevieve Roessler, ORNL X-10

Member Roessler: This is Gen. I don’t know if we’re 
23

-- oh, I guess there are a couple of us talking? 

Anyway, I don’t know if we’re going alphabetically 

or according to Work Group or people, but I would 

like to make a report on ORNL X-10 work.

Member Kotelchuck: Great.

Dr. Roberts: Sure.

Member Roessler: Okay. We -- I think we had a 

change in our Work Group. I think our Work Group 

was named about eight years ago and at that time I 

was named the chair. 

And I think Josie was put on the Work Group at that 

time. And if I’m right, I think Bill Field and Loretta 

Vallerio had been added just recently.

Anyway, we haven’t met yet, but much work is 

being done. I thought I’d go into, just a reminder, a 

little bit of background. If we go back to September 

2012, at a Board meeting, at that meeting, Dr. 

Taulbee presented NIOSH’s Petition Evaluation 

Report of SEC-00189 for Oak Ridge National Lab X10 to the Board.

And that was a 60-slide presentation, if I remember 

right. But it was excellent. He gave great 

background -- pictures, maps. As most of you know, 

this is a very complex site. So that was very helpful.

His presentation included determinations, external 

and then with regard to dose reconstruction. And 

then internal on plutonium, uranium, thorium, and 

fission products.

It did not include the, what we call the exotic 

radionuclides, or at least not all of them. Now this 

was a huge undertaking. As Joe Guido said in a later 

report, and I’ll put this in quotes, as a wide array of 

radionuclides.

And I think -- I’ve forgotten the exact count, but I 

think there were over 200. So it’s a huge 

undertaking. And it’s not just the fact that there’s so 
24

many that have to be dealt with, but if -- those of 

you who are familiar with that site know that there 

was overlap with Y-12 in production and with regard 

to exotic radionuclides.

So a lot of work has gone in during that time. Then 

in -- let’s see, if we go up about six years, in April of 

2018, NIOSH came out with a report. And that one, 

let’s see, was called Monitoring Feasibility: 

Evaluation for Exotic Radionuclides Produced by the 

ORNL X-10 Isotopes Division.

This was presented, given to the Board. This report, 

again, was fairly long. And it included a general 

update on all Oak Ridge facilities. So at this point, 

then, with that report or Work Group, tasked SC&A 

with a review of the report.

So then, in October of 2018, SC&A submitted their 

review, as requested, turned over to NIOSH. And 

just recently, in June of 2020, NIOSH responded 

with a White Paper. The title’s NIOSH: Response to 

SC&A Evaluation of SEC-00189 ORNL X-10 Report 

0090.

Now this was a big step forward and so you’ll see 

why we’re reporting today because we’re excited, at 

this point. And in August, August 10th, we got a 

memo from Joe Fitzgerald that SC&A has begun 

review of NIOSH’s response.

So that’s where we are. We’re awaiting word now 

from SC&A. And I guess at the point we get that, 

then maybe the Work Group will really have to get 

to work. So that’s where we’re at.

Dr. Roberts: That sounds great. Any questions? You 

can --

Member Beach: My only question -- this is Josie. 

Sorry, Rashaun. Does SC&A have any timeline on 

when their report’s going to be ready?

Mr. Fitzgerald: Maybe Ron might want to chime in 

too, but we’re probably midway through our initial 
25

review and have already drafted some materials. So 

I think we’re probably talking toward the end of the 

-- maybe October or November timeframe.

Dr. Buchanan: This is Ron. I agree. We have the 

rough drafts started. We’re waiting for some inputs.

Dr. Roberts: So, again, seeing -- Member Roessler: 

I’m sorry. Go ahead, Rashaun.

Dr. Roberts: I was just going to say, if that’s the 

timeframe, then maybe we’re looking at something 

like the beginning of the year for a Work Group 

meeting, maybe?

Member Roessler: Yeah, we were both thinking the 

same thing. So, yes, I think that’d be a good idea 

that, to kind of keep that tentatively in mind.

And I don’t know. I assume we’re still planning on 

doing Work Group meetings like this by telephone?

Dr. Roberts: Probably Zoom. We’re slowly kind of 

making that transition to doing more and more 

Work Groups and things via Zoom, so --

Member Roessler: To Zoom?

Dr. Roberts: Yeah, I would think a video conference 

of some sort.

Member Roessler: Yeah, I don’t know if I’ll have my 

new hip by then or not. I sure hope so. But I’m not 

looking forward to traveling so that Zoom meeting 

sounds like a good plan.

Dr. Roberts: Okay, great.

Member Roessler: Okay, thank you.

Dr. Roberts: Sure. Any other questions or 

comments for Gen? Okay. Are there any other Work 

Group or Subcommittee reports that people want to 

present?
26

Paul Ziemer, Update on Lawrence Berkeley

Member Ziemer: This is Ziemer. I can give a quick 

update on Lawrence Berkeley. Not too much to 

report, but the Work Group last met in November of 

this past year.

And after that then -- the Work Group is mainly 

focusing on issues on the Site Profile, a number of 

open issues or findings, really findings.

And since that time, NIOSH has done a data 

capture, I think, in January of this year and also 

done some interviews at Lawrence Berkeley. And so 

they are going through those materials.

I think it’ll be a while before we get an update from 

NIOSH on that, but we’re sort of in a holding 

pattern at the moment until we get the next 

analysis from NIOSH on the outcomes of data 

captures and the interviews as they relate to the 

Site Profile.

Dr. Roberts: Thanks for that update. Any questions? 

Okay, hearing none, are there any more reports 

people would like to share?

Henry Anderson, Sandia and URAWE

Member Anderson: I think a little summary of the 

status that you emailed out seemed, at least from 

my end, to be up to date. Sandia, we’re moving 

forward with the -- finally got the go-ahead on the -

- to use the interviews with the guards, so we 

should have some action on that, hopefully, before 

the end of the year.

SC&A is reviewing that. My other group, the 

URAWE, you heard our update on that earlier with 

the W.R. Grace.

Dr. Roberts: Right, right. So just to clarify, which 

Work Group were you referring to with the 

interview? Are you talking about INL with the 

interviews?
27

Member Anderson: I think so.

Dr. Taulbee: Actually, that was -- I think it was --

that was Sandia

Member Anderson: It was Sandia. Right, that’s what 

I said.

Dr. Roberts: Okay. I’m sorry, I didn’t hear you. 

Okay.

Mr. Fitzgerald: And just to follow up on what Henry 

was saying, we did get a go-ahead from the 

interviewees to use the summary that we had given 

them a few months ago for review. So that enables 

SC&A now to pretty much complete its report.

We prepared a report with everything but that one 

reference, so we’re relatively close to being able to 

issue a report on Sandia, probably the next month, 

maybe five, six weeks.

Dr. Roberts: And so would we anticipate doing a 

Work Group meeting sometime before the end of 

the year for Sandia?

Mr. Fitzgerald: Certainly after the Work Group, but 

we will certainly be able to provide our input on 

Sandia relatively soon now that we have this goahead.

Member Anderson: Yeah, I would think we would do 

a Work Group call.

Dr. Roberts: Okay, great. Thank you. Okay, any 

questions? What about any more updates?

Mr. Calhoun: Rashaun, this is Grady. Before you 

close up the --

Dr. Roberts: Hi, Grady.

Mr. Calhoun: -- Work -- the Board’s Work Group 

session here, we just got some information. We 

may have some difficulties with that Board Meeting

August the 25th. We have at least two people that 
28

have pre-paid-for vacations that are going to be out 

for that week.

So if you pencil that in, pencil it in really lightly. 

Let’s see if we can think of something, a potential 

option for that August 25th meeting.

Dr. Roberts: Okay. How would people feel about an 

alternative, either pushing it a week up or pushing it 

-- well, I guess it would have to be a week up if we 

wanted to keep it in August.

But what is availability like for that? I don’t -- let me 

open the calendar up. 

Member Beach: The 18th and 19th works for me.

Dr. Roberts: That would be 18th and 19th?

Member Beach: That’s pushing it up, yeah.

Member Kotelchuck: Oh, that’s pushing it back, if 

you will.

Member Beach: So August -- okay, sorry, that’s 

back.

Member Kotelchuck: No, the reason I -- I was alert 

to that because we typically have our family 

vacation when, the last week before the kids go to 

school, the grandkids.

So that second week in August is generally bad for 

me. I will not say it’s impossible, but --

Member Beach: Dave, that’s the third week, the 

18th and 19th is the third week in August.

Member Kotelchuck: Yeah, it’s the third week. It’s 

the third week.

Member Beach: Yeah, 11th and 12th is the second 

week.

Member Kotelchuck: Okay. I don’t have my calendar 

right in front of me.
29

Member Beach: Yeah.

Member Kotelchuck: For a number of reasons. 

Okay, well, I can handle that. Okay, I can handle 

that, personally. Other -- I don’t know what other 

folks --

Dr. Roberts: Okay. Yeah, how about other folks? 

Does that work for you, Wednesday the 18th or 

Thursday, the 19th?

Member Ziemer: Okay, for Ziemer.

Member Valerio: Okay for Loretta.

Member Anderson: It’d be okay. Again, it’s -- that is 

how --

Dr. Roberts: Okay for Jim?

Member Lockey: Yeah, okay for Jim Lockey.

Dr. Roberts: Okay for --

Member Schofield: Okay for Phil.

Dr. Roberts: Okay, someone else was speaking. I 

couldn’t hear.

Member Beach: That was Henry.

Dr. Roberts: Hi, and, Henry, what were you saying? 

I’m sorry, I didn’t hear you.

Member Anderson: I’m saying that’s -- August is 

always vacation time, but right now that would look 

good for me.

Dr. Roberts: Okay, thank you.

Member Schofield: This is Phil. Right now, that’ll 

look good for me too.

Dr. Roberts: Okay, great.

Member Kotelchuck: Let me ask -- Dave -- how, 

you know, we always met in August. And that 
30

always seemed problematic to me. I’ve managed to 

make all the August meetings because our family 

events are a week before or a week after.

But why not July, which is not quite as heavy a

month for traveling -- for vacation, since we’re 

talking about it this long in advance? Why not meet 

in July? 

I mean, June is easier for people. July is harder. 

August is hardest. And then, September, we’re all 

back. 

So is July -- I wondered what others thought, so 

starting with other board folks -- well, starting with 

all folks, what would a mid or late July be like for 

people compared to August?

Member Beach: This is Josie --

Member Anderson: Wasn’t part of the problem the 

end of the fiscal year and --

Member Kotelchuck: So August is -- end of and 

we’re out the Labor Day holiday.

Member Anderson: -- for some states on June 30?

Dr. Roberts: I’m sorry, a couple of people were 

talking at the same time. Dave, you want to finish 

up your comments and then we can open it up to 

the other comments?

Member Kotelchuck: Okay. I heard Josie and Andy. 

So just say -- Andy was saying that we’re the end of 

the fiscal year is the end of July, I believe, did you 

say?

Member Anderson: No, in June.

Dr. Roberts: Yeah.

Member Anderson: June 30th.

Dr. Roberts: Well, I guess it depends on whose 

fiscal year because the end of the fiscal year for the 
31

government is the end of September.

Member Kotelchuck: The end of September?

Dr. Roberts: Yeah.

Member Kotelchuck: So July would not interfere 

with that. What do others think about July? Just 

broadly.

Dr. Taulbee: This is Tim. If I may speak -- this is 

Tim Taulbee. The Health Physics Society typically 

meets in July. And next year, the meeting, the 

annual meeting is July 25th through the 29th. The 

following year, it is July 16th through the 21st.

So, as you know, in this program, both NIOSH and 

ORAU have a lot of health physicists that --

Member Kotelchuck: Yeah.

Dr. Taulbee: -- are typically busy here in that 

particular month. And so that’s one of the reasons, I 

believe, we avoided July in the past.

Member Kotelchuck: Got it. Okay. Well, that’s --

those are important meetings.

Dr. Taulbee: Yes.

Member Kotelchuck: And so, in my mind --

Mr. Rutherford: This is LaVon Rutherford. I wanted 

to add another thing too. The reason we’ve switched 

it, we actually, prior to this, if you guys remember, 

we had one more board meeting on the calendar, 

and we did do it in July and we bounced around the 

Health Physics Society meeting.

But when we dropped one of our board meetings, 

just the spacing set perfect where we went 

December, April, August. And so that kind of spaced 

the board meetings out.

I mean, it doesn’t matter to me, one way or the 

other. I was just kind of giving you a little history of 
32

why we stayed with August.

Member Kotelchuck: Right. Right, okay, well that’s 

helpful. And it sounds like there were problems. And 

so, sounds like we -- it might be better to stick to 

the August and work our family vacations around it.

So, okay, well good. Thanks for considering it and 

clarifying why we don’t meet in July.

Dr. Roberts: Great. Well, thank you for your 

flexibility, Dave. So, Grady, August 18th and 19th, 

that’s more doable for folks in the program?

Mr. Calhoun: Absolutely, that works fine.

Dr. Roberts: Okay. Great.

Mr. Calhoun: Thank you for that, by the way.

Review of Comments from December

Dr. Roberts: Sure, absolutely. I think the last bullet 

on the work session is reviewing public comments 

from December, which, of course, I was not present 

for that, but I did receive a log of the comments 

and some responses.

So it looks like most of the responses, I think 

maybe there were ten in December. It looks like 

most of them were related to a specific SEC petition 

or a generic comment regarding SEC petitions or 

their consideration by DCAS, the Board, NIOSH, or 

HHS.

And it looks like there was a person who 

commented primarily in regards to the Savannah 

River site. And there were questions about needing 

definitions for what’s meant by sufficient accuracy,

comments about the need to stratify populations for 

coworker modeling because of the heterogeneity of 

the population.

Some comments about imputation and a warning 

against relying on work permit to establish whether 

a person had been working in a particular location 
33

or on a particular task.

And that, I guess, a work permit is -- lists an 

unrealistically low number of laborers. So that looks 

like the first set of comments. And this coding, I 

think something like no response required, I believe 

is what that means, for those comments because 

they are regarded in a particular way. Let me go 

back. 

Because they are more rhetorical type comments or 

generic type comments is what I understand from 

that. But if anyone wants to weigh into this, I’m just 

kind of going off, not really knowing the comments.

Does anyone want to chime in with anything on that 

set of comments? Okay. And then there was 

another set of comments that were offered. It looks 

like that was -- those were mainly in regard to the 

Santa Susanna and DeSoto sites.

And it looks like one comment pertained to the 

presence of americium, thorium, and associate 

progeny at Santa Susanna and DeSoto outside of 

the current SEC period, until 1999.

And there was a comment that NIOSH and SC&A 

have advised the Board that there’s nothing of real 

significance in the documentation and the 

documentation that a person had submitted that 

they have some -- they have to fully explain their 

documentations.

And then there were some questions about stack 

emissions data there. And there’s been a response. 

There’s a response on this offered by Lara Hughes.

And that is the stack emissions issue has been 

explained to the Work Group and the Board. It was 

a panel analysis of composite samples and does not 

indicate emissions of operational quantities.

The americium -- I’m not sure if I’m pronouncing 

that right or reading that right -- found in the mass 

spec lab is something that needs to be investigated 
34

further but also doesn’t indicate processed levels of 

materials.

So that was the response there. And is Dr. Hughes 

on the line? Or would there be any questions in 

regards to this response?

Dr. Hughes: This is Lara Hughes. I’m on the line. 

Sorry, hold on.

Dr. Roberts: Okay. I mean, is there anything further 

that you wanted to say about this?

Dr. Hughes: No, not at this time.

Dr. Roberts: Okay. Any questions from anyone 

about it? 

Okay, the next comment from that person is that 

NIOSH has confirmed we can’t track worker 

movement between worker areas or between the 

work sites themselves and can’t tell which work site 

a worker was at while monitored or exposed, as to 

radiation of course.

And this has been accepted as a standalone reason 

to accept an SEC at other sites. And again, the 

response was from -- submitted, it was by Hughes.

And the response is worker assignment to sites is 

really a DOL issue. Any further elaboration or 

question about that?

Member Ziemer: This is Paul. Could you clarify, 

where these responses made to the petitioner -- to 

the commenter or to the Work Group or -- maybe 

Lara can tell us a bit --

Dr. Roberts: Comment? Yeah, I would put it to her.

Dr. Taulbee: This is Tim Taulbee. What we typically 

do in this particular case is we will provide a 

response that you’re reading through here now.

And it’s for the Board’s information of what or how 

we kind of break down the responses and what our 
35

response to that is.

We generally don’t go through these individually, 

like is currently being done, but we certainly can, 

the materials, product here, to, but I did want to 

mention that, from that standpoint.

When there is something, because these are active 

open petitions that is particularly being responded 

to here, these particular issues are typically raised 

during the public comment, as noted, for the 

Board’s consideration.

And then we are responding to that and further 

discussions then typically happen with the petitioner 

present from that particular standpoint when we do 

a presentation to the Work Groups, et cetera.

Does that help?

Member Ziemer: Yeah. This is Ziemer again. Yeah, 

that’s helpful. I’m looking for the responses. Are 

they in with the public comments document?

I’m looking at the comments.

Dr. Roberts: Yeah.

Dr. Taulbee: No, the comments are sent just to the 

Board. We have not -- in the past, we have not 

typically published these, I don’t think.

Mr. Rutherford: No.

Dr. Taulbee: Bomber, would you agree?

Mr. Rutherford: Yeah. Yeah, these are not 

published. We do provide the responses back to the 

Advisory Board and then normally the Designated 

Federal Official will distribute the comment with the 

responses by NIOSH to the other Board Members.

Dr. Roberts: Right, and that was done. It was 

distributed in the materials for this meeting.

Member Beach: Well, I think that --
36

Dr. Roberts: So --

Member Beach: This is Josie, that the chairs of the 

various Work Groups will look at those and 

determine if they need further discussion during a 

Work Group. Isn’t that --

Member Ziemer: Right, right.

Member Beach: Oh, okay.

Member Rutherford: That’s correct. 

Dr. Roberts: Okay, well since we’ve started down 

this path, what I’ll just say is, you know, there were 

several other comments provided by the commenter 

on Santa Susanna and DeSoto.

And there have been responses, I guess, that the 

Board can review and the Work Group chairs can 

decide what they think should happen with this.

So how about if we leave it at that?

Member Anderson: That sounds good.

Member Ziemer: Yeah.

Dr. Roberts: Okay.

Member Ziemer: Yeah, this is Paul. I think we don’t 

need to read them all through. I think just knowing 

they’ve been handled is the main thing here.

Dr. Roberts: Okay. Yeah, and it certainly looks like 

there were responses for the remaining comments. 

So you all can review that as appropriate.

So that, I think, ends the Board work session. And 

we have, I think we can do the SEC Petitions 

update, I want to say, on the schedule for about 

2:45 -- I lost my agenda.

Member Beach: That’s correct on that schedule 

you’ve got.

Dr. Roberts: Okay. Did you want to take a break 
37

until then and then we can come back and get 

started again at 2:45?

Member Beach: So do that one and then just take a 

little longer break, because our --

Member Ziemer: A little longer break?

Member Beach: Yeah, our schedule’s right --

Dr. Roberts: Anyone? Okay. Is there any objection 

to going into the --

Member Anderson: As long as LaVon is on, let’s do 

it. Yeah.

Mr. Rutherford: Yes, I’m on. 

Member Anderson: Sounds fine to me.

Mr. Rutherford: Dr. Melius, if you remember, used 

to just pick times and just throw me up there, so 

I’m certainly ready.

Dr. Roberts: Okay. Well, the floor is yours.

SEC Update

Mr. Rutherford: All right, this is LaVon Rutherford. 

I’m the Special Exposure Cohort Health Physics 

team leader for NIOSH. And I’m going to give you 

the SEC update.

Okay, Slide 2, I see Grady’s got that up there 

already. We provide that update to the Advisory 

Board to prepare for future Work Group meetings, 

Board meetings, such and such.

During this presentation, I’ll talk about petitions and 

qualification, under evaluation currently under 

Advisory Board review and potential 83.14 SEC 

petitions. Next slide. Okay.

A little summary, to date we’ve had 257 petitions. 

That included 5 petitions we received prior to the 

rule being promulgated. We have 2 petitions in 

qualification and we have no new petition 
38

evaluations going on right now.

We do have evaluations going on, but no new ones. 

We have 11 reports with the Advisory Board. Next 

slide, please. 

Okay, petitions in qualification: Pinellas Plant. We 

actually received this petition prior to the pandemic 

kind of kicking in. And during that process, the 

petitioner, actually, in response to some clarification 

and deficiencies that were noted, had scheduled 

some interviews and ended up asking us for a 

couple of extensions.

So we granted those extensions, obviously. Back 

up, Grady. You shot forward on me. And, however, 

she did just respond to the final thing, and so we do 

anticipate qualification determination to being done 

in September.

This is for all employees and it covers the entire 

covered years at Pinellas, so 1957 through 1997. 

Next slide.

The Rocky Flats petition, we have this one in 

qualification. This is for the 1984 through 1989 

period. We did make a determination. However, as 

you may have heard yesterday during public 

comments, that an administrative review has been 

requested.

We do anticipate that, just based on the 

requirements set before that administrative review 

panel that we will get a decision on that sometime 

later in September.

Okay, petitions under evaluation: Lawrence 

Livermore National Lab. This is a petition that 

actually addressed the remaining years of a 

petition. We’re going to complete an addendum that 

covers the 1990 through 2014 period.

We anticipated having this done some time ago. We 

actually did our internal, face-to-face on the 

evaluation where we kind of go over our thoughts. 
39

And, Grady, that’s moving forward on me again.

And during that time period, we identified an issue 

that we wanted to review a little further. So we 

actually requested a set up to do a data capture at 

Lawrence Livermore.

However, during the pandemic, things got shut 

done and we have not been able to get on site yet. I 

put up the date of December 2020 only because 

that’s the next Board meeting date and I have no 

idea, really, for sure, when we’re going to be able to 

get back on the site to complete this.

Next slide please. Y-12 Plant, we heard a little bit 

about that in last night’s public comment. And we 

have been evaluating the 1987 through 1994 

period. We did -- we had hoped to have that 

addendum ready for this meeting.

However, as I mentioned during the Board 

conference call and it was noted again during public 

comment last night, we did have a data issue that 

we needed to address. We have addressed that data 

issue and we’re moving forward with the evaluation. 

And we anticipate that the -- to have that 

completed in October, ready for the December 

Board meeting.

Next slide. All right, these are petitions that are 

under Advisory Board review. Hanford, we just 

heard about that one. 

And Savannah River site, yeah, we’ve been working 

for some time back and forth, groups working to 

resolve issues with SC&A and the Work Group, and 

that continues.

Los Alamos National Lab, this is the site that we 

have kind of been stuck with the issue with the 

pandemic as well. We had developed a couple of 

approaches. 

We’re reviewing an RWP analysis and analyzing 

mixed fission and activation products. The RWP 
40

analysis required us to retrieve RWPs from the site. 

We had a number of RWPs in-hand and started 

coding that data and downloading that data.

However, we’ve been waiting for RWPs and some 

survey data to finalize both analyses. We’ve been 

back and forth, talking with DOE, not only DOE 

headquarters but also DOE representatives at LANL 

trying to get this moving forward.

But I can’t really give you a good date when that’s 

going to happen. Their staff is kind of backlogged 

and the problem that Greg Lewis mentioned 

yesterday with the Classification Office seems to be 

the major issue.

Sandia National Lab, as you just heard from the 

Work Group updates, we did get the finalized 

interviews and that one can move forward. Next 

slide.

INL, I think an update’s scheduled for later today. 

I’ll leave it at that.

ANL-West, we’ve been working to resolve issues 

with SC&A and the Work Group.

Area IV Santa Susanna, this is -- we did receive 

some additional information. We have reviewed 

that. SC&A is reviewing that information as well, 

has been tasked by the Work Group.

Metals and Controls, as Josie had mentioned, we do 

have a Work Group meeting next week. Next slide. 

DeSoto Avenue Facility, again, SC&A is reviewing 

information submitted by the petitioner. We have 

already looked at that information and we’ll be 

ready for a Work Group meeting to discuss that. 

And we’re also working to provide some clarification 

on a few remaining issues.

Superior Steel was discussed yesterday. 

And Reduction Pilot Plant, this is a new petition 

evaluation that we just completed. We will make our 
41

presentation later today.

All right, these next couple of slides are just 

identification of the years that are remaining. If you 

look at Hanford, Hanford covered from the 

beginning of operations all the way up to 1990, so 

that was a very broad petition evaluation.

Savannah River site was basically the same thing. 

That’s why those two have been on this for such a 

long time.

LANL, we’ve ultimately added classes all the way up 

through, up to ‘96 and we’re still evaluating that ‘96 

through 2005 period.

Sandia, we still have the remaining four or 

remaining 1997 through 2011. We’re working 

through INL. It’s a pretty large period. Next slide.

No apologies necessary, Grady. I must have put a 

timer on there for something and I didn’t even 

realize I did it.

Lawrence Livermore National Lab, you can see the 

remaining years there.

ANL-West, again, all of these -- these are the 

remaining years to be addressed by that petition. 

And that’s good. Next slide.

All right, those will remember that West Valley, we’d 

actually added a Class from 1969 through 1973 at 

West Valley. And we had left the 1966 through 1968 

period open because we had identified a significant 

number of data during that period that we 

questioned whether we should be adding a Class 

there.

We committed some time ago, when we added that 

Class, to continue our evaluation of that period. 

We’re about done with that evaluation. I anticipate 

we’ll be able to make a decision one way or the 

other on that very soon.

We do not have any other 83.14s really set up at 
42

this time. And that is all I’ve got. Questions?

Member Ziemer: This is Paul. I have a question on 

Pinellas. 

Mr. Rutherford: Yes.

Member Ziemer: Did we have a previous SEC 

petition for Pinellas?

Mr. Rutherford: We have had a number of petitions 

for Pinellas that had not qualified. We also had --

yes, actually, roughly, off the top of my head, four 

or five.

We have also had a Site Profile review that was 

done by SC&A. The review went through, all the 

way through to completion to the advisory board 

approving that Site Profile.

Member Ziemer: Is --

(Audio interference)

Mr. Rutherford: There’s some differences in this 

petition. I will say there’s a number of things that 

are the same, but there are some differences that --

Member Ziemer: Oh, okay.

Mr. Rutherford: -- we’re taking a look at right now.

Member Ziemer: Okay.

Mr. Rutherford: And there were some additional 

interviews that were done for this one as well, so.

Member Ziemer: Okay. Thank you. 

Mr. Rutherford: Mm-hmm.

Ms. Naylor: Hi, this is Jenny Naylor with HHS OGC. I 

just have one correction for the record, that the 

administrative review for the Rocky Flats SEC 

petition 257 will likely be done by late October if not 

late September.
43

Mr. Rutherford: Thank, Jenny. I was putting 

pressure on them, wasn’t I? 

Dr. Roberts: Any other questions or comments? 

Okay, I don’t hear anything. Thank you, LaVon.

Mr. Rutherford: Okay.

Dr. Roberts: So it looks like there was a desire for a 

longer break, and it looks like that wish is going to 

be met. 

So taking everything in, I’m wondering if we could 

take a longer break from 2:45 to about 4:10 p.m. 

with the idea of picking up with INL at 4:15. How 

does that sound?

Member Anderson: Sounds good.

Member Ziemer: Well, I’d like to ask whether we 

need that long of a break. Do we have petitioners 

that are tied into the 4:15 time for that or for 

Reduction Pilot Plant? Because if we don’t, I don’t 

see a reason why we shouldn’t go ahead with it 

after maybe a 30-minute break.

Dr. Roberts: Okay, for INL --

Member Ziemer: Go ahead.

Dr. Roberts: -- we’re going to take -- okay, I didn’t 

see anything on the agenda for the petitioners. It’s 

an update on INL.

But for RPP, yes. I think we would need to wait for 

the petitioners on that one, potentially.

Member Kotelchuck: Well, yeah. If we have to wait 

for petitioners, then it doesn’t matter whether we 

start at 4:15 with INL or 5:30 with Reduction Pilot 

Plant. 

So, the question is to take the big break now or 

later, after INL. I would just say let’s take the 

longer break now and come back at 4:15 for INL.
44

Because really because of the reduction plant 

petitioners. What do others think?

Member Anderson: Sounds good.

Dr. Taulbee: That was what I was going to 

recommend as well because we do try -- well, active 

SEC petitions, we try to stick to the schedule in case 

petitioners wanted to dial in at that particular time.

Member Anderson: Even if they haven’t pre-signed 

up, so, yeah.

Dr. Taulbee: Yeah, that’s true.

Dr. Roberts: Okay, great. Okay, so we’ll take a 

break now and I would just ask just a couple of 

minutes before 4:15 so I can do a quick roll call and 

then we can start right at 4:15 for INL. Sound 

good?

Member Kotelchuck: Good.

Member Beach: Sounds good.

Dr. Roberts: Great. See you soon. 

(Whereupon, the above-entitled matter went off the 

record at 2:47 p.m. and resumed at 4:17 p.m.) 

Dr. Roberts: Okay. All right. Great. I think we can 

go ahead and move on. And Phil, for those of you 

who may not have heard, needed to disconnect 

from the meeting. He’s having some issues. And he 

had asked Mr. Bob Barton to present on his behalf. I 

see that the slides are up, so without further ado, 

I’ll hand it over to you, Bob.

Idaho National Laboratory Update

Mr. Barton: Thank you, Dr. Roberts. Good afternoon 

everyone. As mentioned, Phil asked me to step in. It 

was more like I begged him to be able to give this 

presentation. So it’s all good.

So we’re basically doing an update here for the 
45

INL/ANL-West Work Group. We all met last month 

on July 16th, which was the first work group since, I 

believe, March of 2019. And what we’re all going to 

discuss right now is a V&V study that SC&A did 

related to the 83.14 definition for the Chemical 

Processing Plant, which is 1975 to 1980.

And this is really the, there were discussions on 

multiple fronts during that July meeting, but this is 

really what I guess would be considered an 

actionable item by the Board, if that’s the correct 

terminology. So I’ll be giving this presentation and 

hopefully you can all see the title slide, it should be 

up there.

And I’m going to move onto the first slide, which is 

the background. Hopefully all of you can see that. 

So, I think a little bit of history to the site and, in 

particular, the Chemical Processing Plant might be 

helpful to put this in a little bit of context. This 

83.14 period again, goes from 1975 to 1980, is 

actually the third SEC period established for the 

Chemical Processing Plant.

The first two periods, the first one was from 1963 

into early 1970. The second period was from early 

1970 through 1974. And of course the period we’re 

discussing right now is from 1975 through 1980. 

Now, the reason it’s split up into these three 

periods, they’re really delineated by what the 

external badging requirements were associated with 

being included in the Class.

That very first period, which again, the first two 

periods were part of SEC 219, required that you had 

a specific dosimetry badge for the Chemical 

Processing Plant at the time at INL, essentially you 

could work in one area, say Test Area North, or 

Central Facilities, and if you left that area, you 

would leave your dosimetry badge at that area. And 

then as you entered another area, such as the 

Chemical Processing Plant, you would have to pick 

up a specific badge for that area.

And that’s very similar to the period we’re 
46

discussing now, this 83.14 period. So keep that in 

mind as sort of a precedent. Now in that middle 

period from ‘70 to ‘74, policies changed at the site 

briefly. So that window where you could actually 

take your badge from Central Facilities and enter 

any other facility at INL. You didn’t have to leave 

your badge and pick up a new one. So that’s why 

it’s sort of split up.

It’s all the Chemical Processing Plant from ‘63 

through ‘80, but it’s split up into three periods 

based on that badging requirement. So a lot of what 

we’re going to be talking about today is the fact 

that, for this period, it switched back to where you 

had to have a specific dosimetry badge for the 

Chemical Processing Plant to be included as part of 

the Class.

Now, this Class has already actually been approved 

by the Board. It was back in 2017. So there’s 

nothing being held up by this discussion, but really 

the question was the Class definition itself and that 

requirement that you had to have a specific badge 

associated CPP to be considered as part of the SEC 

Class.

Moving on. So again, for the first SEC period that 

we looked at, and this, again, was a number of 

years ago. It’s that badging requirement that 

initially gave the Work Group and the Board as a 

whole some pause because it’s somewhat unusual 

to require that you have to have that specific 

dosimetry badge. And this includes not only a 

regular routine badge, but also temporary badges or 

visitor badges. Any sort of dosimetry badge would 

get you included in the Class, but the Work Group 

wanted to make sure that, really, that no one would 

get inadvertently excluded.

Now, we’ve learned some things from that first 

evaluation, which again, is very similar to what 

we’re discussing today. It was discovered that if you 

were issued a temporary badge or a visitor badge, 

unless you actually accrued a positive dose on that 
47

badge, at the time the site INL was not actually 

indexing that badge so that it could be correctly 

associated with the Energy Employee.

So essentially what would happen is you’d make a 

request, as we usually do through this program, for 

dosimetry records for an individual and unless those 

temporary badges had a positive reading, they 

weren’t being correctly included in the claimant’s 

file. Now obviously this is a problem from a dose 

reconstruction standpoint because those would 

represent missed doses. But even more problematic 

from an SEC adjudication standpoint, because if 

we’re missing, we’re not associating those 

temporary badges with the claimant, they could be 

inadvertently missed. And obviously that would be a 

terrible thing.

So this is going back a number of years but back in 

2016 after this was discovered, that these 

essentially zero badges were being excluded, DOE 

and INL went back and they actually performed a 

massive coding and indexing effort to take all those 

temporary badges, all the ones that were zeroed 

out, even if they didn’t have positive entries, and 

indexed them into their system so that now, when 

you made a request for a given claimant’s 

dosimetry record, all those badges should be 

included. So they wouldn’t be missed and if you 

were looking to find that badge, to make sure that a 

specific worker could be included in the Class, 

because they entered the Chemical Processing 

Plant, those should all be correctly ascribed to the 

claim.

So all that kind of happened back in 2016. The 

Work Group still had some concerns about that 

though because back then, and we’re talking about 

in the 60's, that first SEC period, the temporary 

badges were mostly handwritten on little cards that 

were a little bit smaller than a credit card. And 

really the only identifying information at that time 

was generally just the name of the Energy 

Employee and their employer.
48

Now fast forward to this period where, again, we’re 

still requiring that you have that CPP-specific badge, 

things got a little bit better. The temporary badges 

were actually typed out on these little cards instead 

of being handwritten. So you, a lot of the legibility 

issues were lessened. And also during this period, 

they were using what’s called an S number, a 

Security Number, which is just another piece of 

identifying information.

So during the period we’re talking about now, a lot 

of the original concerns with the class definition, 

again, back in the evaluating SEC-00219, were 

certainly lessened. Legibility issues were down but 

there’s still some concerns about, you know, you 

might have people with the same name that might 

get confused. You know, other types of human 

error. Hard copy records are scanned and 

sometimes the typing might be faded, or other 

types of legibility issues. Name misspellings, et 

cetera. So these are sort of the concerns that 

brought about this verification and validation study.

And again, the key question here is, is it possible or 

what is the potential that we could inadvertently 

exclude someone from the Class due to the badging 

requirement that is part of the Class definition?

Moving on. So to this end, SC&A developed a V&V 

strategy for this period. Again, we’re talking now 

about ‘75 to 1980. That is very similar to the one 

performed, again, earlier, for the earlier period 

under SEC-00219. And it’s pretty simple in concept. 

We identified claimants who had temporary badges 

that were currently missing from their dosimetry 

file. And they were missing from the dosimetry file 

that had been sent to us prior to this massive 

coding and indexing effort that DOE and INL did, 

again, back in 2016.

So how do we know that they’re missing? Well, 

NIOSH and SC&A together went out to Idaho Falls. 

This was back in the fall of 2018, and we actually 

captured all these hard copies of visitor badges. We 
49

scanned them all in and again, they’re kind of small 

cards. A bit smaller than a credit card. And once we 

had all those, it was simply a matter of going in and 

cross-referencing them against the claimant 

population that we had.

So we have the hard copy visitor cards and can say, 

all right, we know this person entered CPP on such 

and such a date. Let’s look in their claim file to see 

what DOE had sent us prior to this massive coding 

effort in 2016 and we’ll see if it’s missing. And if it’s 

missing, then that person could potentially become 

part of this group of workers on which we’re going 

to do this V&V evaluation.

And once we had the group of workers, essentially 

it’s just a question of re-requesting dosimetry 

records from the site. And these should be updated 

now to include all those temporary badges that had 

previously been excluded because they had shown 

no measurable dose.

So our V&V population consisted of 37 claimants 

with a total of 736 temporary/visitor badges 

between them. You might be asking why 37. It 

seems like rather an odd number. Well, seven of 

those were actually claims that we used in the 

earlier V&V evaluation, under SEC-00219. We just 

hadn’t evaluated them for this later period. So it 

was a question of simply going back and checking 

those records on our end. We didn’t require DOE to 

actually go and do any further research.

So that’s why there’s the seven extras and 30 

claims were selected as new claims that we would 

send back to DOE/INL to have their dosimetry files 

researched.

Now, the only thing that’s slightly different about 

this evaluation from the previous V&V evaluation is 

this one is really a twofold evaluation. We’re not 

only going to test what comes back from DOE and 

INL, and what they’re sending us with the updated 

dosimetry files, but we also have a secondary 

source that we checked. And this is known as 
50

NIOSH hot-linking, or at least that’s how we know it 

at SC&A.

And essentially what this is, and I hope I don’t 

bungle this too much, but hot-linking is essentially 

the process where when NIOSH captures records 

out at a given data cache or at a site and they have 

a claimant’s name associated with it, and the 

document is germane to dose reconstruction, it’s 

essentially automatically linked to the claim file so 

that it can be used in the DR process.

So this is a secondary sort of mode of applying 

these records to a claimant. You can look at it as 

almost a safety net, if you will. So even if DOE 

happen to miss a record in the updated file, there’s 

a very good chance that it would be picked up 

through this hot-linking process. And thus, the claim 

would have the requisite evidence to be included in 

the SEC.

So we evaluated both those avenues as separate 

entities, but then also sort of the combined effect of 

all of them. So again, the question here is what is 

the potential that we might miss somebody because 

of this dosimetry requirement.

So what we’re looking at now is the actual results of 

the V&V analysis. As you can see, we have our 736 

total badges that SC&A identified for checking. 

Again, these were originally omitted from the claim 

files we had to look at. And so we’re going to go 

back in and look at the updated files and see, well, 

how many of them are now correctly included?

So this second row here. It says V&V badges 

identified by INL/DOE. So that’s the standard 

request process. We found our group of workers 

who we really wanted to test out through this V&V 

exercise, and we sent requests back to the site for 

an updated dosimetry file. And the results were that 

out of those 736 badges that we had identified to 

check, 602 came back as correctly included, which 

is roughly 82 percent. So that’s about an 82 

percent, I guess, a positive rate, if you will.
51

Now that’s actually somewhat low compared to 

what we found for the previous V&V evaluation, 

which is surprising for the reasons I stated. In the 

previous period, there were handwritten records. 

They didn’t have that third piece of information, the 

S number.

In the first V&V evaluation, we actually had more, 

close to 95 percent success rate. So this is, this is a 

little bit lower. But as you’ll see, as it washes out in 

the end, it’s actually very close to what was found 

to be acceptable for SEC-00219.

The row below that is the hot-linking process that 

NIOSH does automatically. They did not do this 

specifically for INL or for this V&V application, it’s 

just a standard process that they’ve instituted 

programmatically. And again, we evaluated that 

separately and that one came out slightly higher 

than the DOE request. We had 613 of the 736 

identified badges, which is about 83 percent success 

rate overall.

Now, if you take them in combination, in other 

words, if we look at both of them, what DOE 

returned and what NIOSH has hot-linked into the 

file, the combined effort for both of those was about 

93 percent. So 682 out of 736. So that 93 percent 

could be compared to the previous V&V study that 

was done for SEC-00219, which again, I think it was 

94.5 percent success rate in the previous effort.

Now, some key take-aways from here, when you 

look at the group of 37 as a whole, three of the 

claims came back in which it did not get any of the 

temporary badges from DOE. Now this first bullet 

talks about two of them. Where DOE, again, did not 

return any of the badges that we had identified as 

associated with the claimant. For those, for two of 

them, we really could not determine what the root 

cause was. Why we were getting files back from 

DOE that just didn’t contain those temporary 

badges we had identified.

However, that secondary source, the NIOSH hot-
52

linking process, which again, is a separate entity in 

itself, for these two cases, correctly identified 90 

percent and 100 percent of the badges for those 

two cases. So even though DOE seemingly missed 

it, the NIOSH hot-linking process, again, was that 

sort of safety net. So the claim would still qualify 

just based on that because the NIOSH system itself 

identified the badges to allow for the claimant to be 

included in the SEC Class.

And that was for two of them. As I mentioned, three 

of them came back from DOE without the identified 

badges. The one additional claim I show here in this 

second bullet, you know, we were able to trace the 

mistake an incorrect Social Security number that 

was used in the research done by the site. The 

request was correctly made and assigned NIOSH 

with the correct information and the correct Social 

Security number, but when the site went in to do 

the research on the claim, they found, essentially, a 

claimant with the same name but a different Social 

Security number, and thus sent back the wrong 

dosimetry file.

And I guess the third real key take-away to this 

entire exercise is that for those 37 claims that we 

included in this entire V&V study, 36 out of 37 

contained at least one of those SC&A identified 

badges shows that they would not have been 

inadvertently omitted from the SEC Class, were this 

not just an exercise, but the real functioning of the 

program.

And again, that one case that we identified that was 

a problem with the Social Security number used to 

search for that claim. And unfortunately, for that 

specific claim, the NIOSH hot-linking process had 

not been performed. And I believe that was 

probably because of the age of the claim. In other 

words, this hot-linking process has sort of 

developed over the years in the program and I think 

this case itself had already been decided prior to 

this process really being implemented. So it just --

it had never, the hot-linking process had not been 
53

associated with this claim, likely because it had not 

been active at the time. That is my own supposition 

but I think it’s a logical step to make.

So in conclusion, at that July 16th meeting, last 

month, we presented the results of this V&V study. 

Again, we have about a 92 percent or 93 percent 

success rate between the NIOSH hot-linking process 

and DOE record searches as a whole. And based on 

that, the Work Group determined that the process is 

sufficient and that claimants are unlikely to be 

inadvertently missed by the class definition.

And again, all you need is a single badge. It doesn’t 

have to be a badge covering 250 days of 

employment. You do need 250 days of employment 

at the site, but only a single dosimeter badge for 

the Chemical Processing Plant to be included in the 

Class.

So the Work Group recommends that the SEC00238 dosimetry requirement that’s part of the 

Class is sufficient and does not need modification. 

And as I stated earlier, this Class has already been 

approved by the Board. It was just a question of 

whether any modification needed to be made 

because of that dosimetry requirement that was 

part of the criteria.

So the Work Group recommends that things stay as 

they are and that the dosimetry requirement is 

okay. And that the chances of inadvertently missing 

someone are small enough. So any sort of 

expansion of the Class, which the only expansion 

you could really make is to say, well, anyone who 

had a badge at INL. That would be the next step 

beyond what is currently in the Class definition. The 

Work Group recommends that things simply remain 

as they are.

So that is my presentation regarding the V&V 

activities for SEC-00238, which was again, at 83.14, 

which means NIOSH initiated the SEC Class 

themselves after seeing a deficiency, or an 

infeasibility in monitoring for the Chemical 
54

Processing Plant from ‘75 up through 1980. That’s 

the end of my presentation. If there are any 

questions, I’d be happy to field them.

Member Beach: Bob, this is Josie, you’ve stunned us 

into silence. Good job on the presentation.

Mr. Barton: Thank you, Josie. I thought I might 

have got disconnected there. Talking to myself.

Dr. Roberts: Any questions for Bob?

Member Valerio: This is Loretta, I have a question. 

Can you hear me all right?

Mr. Barton: Yes, please.

Member Valerio: So when you were going through 

these records, these index cards, did -- by chance, 

did you come across any visitor badges for someone 

who was visiting from a different site other than 

INL? Do you recall?

Mr. Barton: I’m quite sure, I’m quite sure we did. I 

don’t think the visitor badge itself would have 

necessarily indicated that, unless it was perhaps the 

employer might have indicated that the person was 

visiting from another site. But I can’t say offhand.

I can say that before we even undertook this 

exercise, before even designing the V&V and coming 

up with this group of 37 markers, we took a close 

look at those visitor cards, including seeing if there 

were any temporal gaps, you know, if you had a 

couple of months where there’s just no visitor cards. 

That would be a big red flag that we hadn’t actually 

captured the full set. Unfortunately, you know, if 

you’re going to do a completeness study, the 

primary reference that you’d like to have would be a 

health physics report, or something of that that 

actually lists the number of temporary badges given 

in a certain period. We didn’t have that information.

But again, we looked at it on a temporal scale by 

month and it was fairly consistent. And they issued 
55

a lot of temporary badges at the Chemical 

Processing Plant in some months, you know, over 

1,000 visitor badges in a given month. There were a 

lot of people coming in and out including, I mean, 

even the worker restocking the Coke machine got a 

temporary badge and you can see that. Or someone 

doing maintenance on the telephone lines. They all 

got temporary badges.

So it really did run, as far as identifying specific --

circle back to your question. Identifying specific 

workers from other sites that certainly came 

through to visit the Chemical Processing Plant. I 

can’t say specifically how many, or really give you 

any more information on that.

I can say that the policy at the time would have 

dictated that, for example, if somebody was coming 

from a different site, they wouldn’t be able to just 

take their site film badge and walk into the 

Chemical Processing Plant. They would have had to 

stop at the guard gate and gotten a visitor badge. 

That was just the policy at the time.

(Simultaneous speaking.)

Member Valerio: All right. Thank you.

Dr. Taulbee: This is Tim Taulbee --

Member Valerio: Thank you.

Dr. Taulbee: Oh. Loretta, just to follow on just 

briefly here. We have looked at some of those and 

Bob is correct. We haven’t done any study as to 

how many people came from other sites. But I have 

seen other sites listed that they came from, Y-12 or 

from Los Alamos or from other sites. It depended 

upon what they put down in their contractor, or 

their employer spot on that particular badge. So we 

do see that sometimes on those badges.

Member Valerio: All right. Thank you for the 

clarification.
56

Dr. Roberts: Any other questions? Okay. I don’t 

hear any. I don’t know if someone was getting 

ready to ask something but I realize this is on the 

agenda as an update on INL. But I’m wondering if it 

would be a appropriate if there were, you know, 

people who want to make comments or petitioners 

who may be on the line who want to present or 

discuss anything.

Okay. Hearing none, my next question, I know Phil 

is not here, but I wanted to ask the Work Group, 

was there a motion you wanted to bring?

Mr. Barton: This is Bob Barton. Maybe I might have 

misspoke. I did say actionable item. I think, I mean 

really, the SEC Class as currently written has been 

accepted. So I guess if there was a motion, it would 

be a motion of no action, really. Because the task 

here was to look into whether the class definition 

needed to be changed, and the recommendation 

from the Work Group is that it does not.

So I’m not sure, and Dr. Ziemer, you might know 

the Robert’s Rules on this, if we need a motion of no 

motion. Or I’m not sure how that works. But the, 

again, the Work Group recommendation was to 

essentially leave the class definition as is.

Member Ziemer: Under Robert’s Rules, if there’s no 

change, you don’t need to take any actions.

Dr. Roberts: Okay. So we’ll just leave it there then. 

Is that agreeable to the Work Group?

Member Beach: Yes. It is. This is Josie.

Dr. Roberts: Okay. Great. Well, it seems like we 

have another gap in time with the RPP being 

presented at 5:30. Would we like to take a break 

until then?

Member Kotelchuck: Okay.

Dr. Roberts: Why don’t we go ahead and, you know, 

maybe just come in a few minutes before 5:30 so 
57

that we can open up that agenda item at 5:30. All 

right? So see you soon.

(Whereupon, the above-entitled matter went off the 

record at 4:43 p.m. and resumed at 5:39 p.m.)

Dr. Roberts: Okay. Since you’re here, Andy we’re 

going to go ahead and move into our final agenda 

item.

Member Kotelchuck: Hello.

Dr. Roberts: And -- okay. And that is for RPP so 

since we’re a little bit delayed, I’ll just turn it over 

to you.

Member Kotelchuck: Hello. Hi.

Dr. Roberts: Oh, hi. You’re here.

Member Kotelchuck: Hi.

Dr. Roberts: Hi Dave.

Member Kotelchuck: I’m terribly sorry. I’m so glad 

you got in. Thank you for waiting as long as you 

did. Someone called me and I’m so sorry I’m late. 

Please go ahead.

Dr. Roberts: Not at all. Thank you so much. I was 

just turning the floor over to Tom. Is it Tomes? Am 

I saying that correctly? I’m sorry?

Member Anderson: No, we’ve lost him.

Dr. Roberts: Oh no.

Member Ziemer: He may be on mute.

Dr. Roberts: Okay. Tom, if you’re on mute, you 

need to come off. We can’t hear you.

Mr. Calhoun: Oh bot, this is not good.

Dr. Roberts: We were doing so well. Tom?

Dr. Taulbee: Tom, if you’re trying getting him on 
58

through Skype? Through Skype and you selected 

Don’t Join Audio, you need to dial in on the, on the 

cell number that was provided.

Mr. Tomes: Hello, Dr. Roberts. Can you hear me?

Dr. Roberts: Yes. I can hear.

Mr. Tomes: I’m sorry that --

Dr. Roberts: Wonderful.

Member Kotelchuck: Hello.

Mr. Tomes: I tried to unmute my phone but I guess 

--

(Simultaneous speaking.)

Dr. Roberts: Yes. That happened to me earlier. Well, 

it’s your floor. Thank you so much for presenting in 

advance.

Reduction Pilot Plant SEC Reduction 253

Mr. Tomes: Okay. Thank you. I’m here to present 

the high oxidization of SEC petition 00253 to add a 

class of employees in the Reduction Pilot Plant to 

the Special Exposure cohort.

Next slide, please. The presentation here is divided 

up into five sections. First I’ll go through the 

overview of the site and the petitions. Then I’ll go 

through the information that NIOSH used in the 

evaluation of the petition. Then I’ll go through the 

basic operations of the Reduction Pilot Plant, 

followed by the method that we can use to 

reconstruct doses. And lastly, I conclude with the 

feasibility summary.

The Reduction Pilot Plant, which I’ll refer to as RPP 

throughout the presentation, is located in 

Huntington, West Virginia. That’s a picture of the 

site there from the operations period in the 1960s. 

The site was operated by International Nickel 

Company, also known as INCO. The facility was 
59

owned by the Department of Energy, which built the 

facility on the ground adjacent and surrounded by 

the nickel company.

INCO was also known as Huntington Alloy Works, 

which you’ll see in various documents that we 

researched. INCO ran the company and later sold it 

to Special Metal Products. I believe that was in the 

90s where you’ll see all those names and various 

records.

The RPP manufactured nickel powder for use in the 

gaseous diffusion plants. Covered periods of the 

facility is 1951 to May 18th, 1979. The period of 

November 27th, 1978 through 1979 for 

remediation, in which time the period, the facility 

was demolished. And Cleveland Wrecking Company 

was the contractor for the demolition.

The facility was located on approximately a three 

and a half acre fenced area adjacent to the INCO 

plant. INCO acquired the property and so did the 

DOE, and then DOE subsequently contracted INCO 

to build and run the facility. The facility started 

operations in 1951. The facility was separated from 

the rest of INCO’s operations by a security fence 

and security clearances were required for entry. And 

it was manned by government guards at the time.

The operations included the use of low enriched 

uranium-contaminated nickel scrap, which was 

supplied by the Department of Energy. The facility 

operated until 1963, at which time it was shut down 

and placed into Standby. The facility remained in 

Standby until 1978 through ‘79, when it was 

demolished.

Next slide. NIOSH received SEC Petition 00253 on 

June 25th, 2019. The requested SEC Class is all 

INCO security personnel who worked at any location 

within the Reduction Pilot Plan during the period 

from June 7th, 1976 through November 26th, 1978. 

As noted on the previous slide, the period is fully 

within the Standby period. This was significant 

because the Standby period was not listed as a 
60

covered period under EEOICPA when NIOSH 

received the petition.

NIOSH talked with the petitioner and reviewed the 

records from the petitioner, and at the request of 

the petitioner, we contacted Department of Labor 

and provided more information to the Department 

of Labor, and asked them to review, at petitioner’s 

request, that facility should be covered during the 

Standby period. There were records provided by the 

petitioner of security personal who had security 

clearance at the time, who made daily entries for 

inspection purposes.

NIOSH also had information in this database that 

INCO’s was contracted for maintenance during the 

Standby period. Subsequently, in November, the 

Department of Labor notified NIOSH the Standby 

period was being added to a covered facility period. 

And NIOSH qualified the petition in December of 

2019 on the basis that we had no radiation 

exposure records for the requested class so it 

qualified on the F-1 basis. 

NIOSH subsequently evaluated the plant as they 

requested and issued an ER, Evaluation Report, on 

April 24th of this year. NIOSH concluded that we 

have sufficient information to reconstruct doses with 

sufficient accuracy for members of the requested 

class.

Now we’ll go into some details on the source of the 

data for this evaluation. There’s a Site Profile for the 

RPP, however that Site Profile was written before 

the Standby period was added to the Class, to the 

covered period. But the Site Profile does provide 

information on operations of the plant and some 

information on the ventilation for all of the Standby 

period.

We also looked at the Site Profiles for Atomic 

Weapons Employers that worked uranium metal, 

TBD-6000. That was consulted for source of 

exposure from uranium. And we also used the Oak 

Ridge Gaseous Diffusion Plant, legal basis document 
61

for a reference for recycled uranium components 

and uranium that would have been present in the 

RPP.

Next slide. NIOSH also looked at the claims in our 

tracking system, NOCTS, as of March 17th. There 

were 77 total claims submitted for dose 

reconstruction for the site. Excuse me, there were 

92 claims submitted to dose reconstruction, 15 were 

pulled by the Department of Labor, and so we 

completed 77 of those. Of those 77, 76 had found 

dose reconstructions and one was pulled.

Next slide. The number of claims that was 

submitted for energy employees who worked during 

the period under evaluation was 42 and 42 claims 

had employment from June ‘76 to November ‘78. 

And there were four claims of workers who started 

during that period. NIOSH looked at all those 

records. We found no claims that had radiation dose 

records, for either internal or external doses.

Next slide please. NIOSH reviewed documents 

provided by the petitioner. Petitioner submitted 

documents supporting the claim of the security 

personnel and the RPP during the period in 

question. And they were not monitored for radiation 

exposures. Documentation was provided by INCO 

via the petitioner to show the determination of 

security clearance for those workers after the RPP 

had been demolished.

NIOSH also made attempts to find workers who 

worked in the period during the time, and we found 

only one worker who we could interview to try to 

get information. The interview of that worker. The 

information he could provide was that he had a 

concern that workers entered into the building and 

were not monitored.

Other sources of information was (Audio 

interference) NIOSH site research database, existing 

documents for review, and then an extensive search 

was performed for the various records that we 

typically search and that data search record is 
62

documented in the ER in Attachment 1. In total, 

between the records that we had and the new 

records we obtained during the search, 287 

documents were reviewed.

Next slide. I’ll discuss the RPP operations. We have 

some background on the period under the 

evaluation. The RPP employed 20 to 25 people 

during the production period, including operators on 

the various shifts and security personnel. The 

facility consisted of a process building, a compressor 

building, and storage tanks. The facility had initially 

used nickel oxide supplied by INCO as the feed 

material to produce nickel powder for the AEC. 

Contaminated nickel scrap was later introduced as a 

starting material starting in 1956.

And this is a picture of the facility. There’s a sketch 

that shows the layout of the RPP facility, and there’s 

a picture of the facility from 1963, which is the 

same picture that was included in Slide 4. Just to go 

through what these pictures represent, the layout 

and the sketch. The large rectangle area is a 

Process Building where the radioactive material 

would have been processed and that is the large 

five story building seen in the background of the 

picture.

The other large rectangular building near the center 

of the sketch was the compressor building, with no 

radioactive materials entered that building. There’s 

a gas cracking plant in between those two large 

buildings to produce carbon monoxide and hydrogen 

gas using the process. And on the right side of the 

sketch are the four holding tanks that you see in the 

picture on the right, which were used to hold carbon 

monoxide, used in the process.

Next picture. I’ll briefly discuss the process that 

INCO used to produce nickel just for some 

background on the facility. Nickel oxide is combined 

with hydrogen gas to produce nickel metal and 

water. This was a starter material that was used up 

through 1950 through ‘56, approximately. When 
63

INCO switched from using nickel oxide that they 

supplied, they were using scrap metal from the AEC 

in 1956 to ‘57 era. Step one had to be changed. 

They made a modification to this step as that 

process result was the same.

The nickel was then combined with carbon 

monoxide to produce nickel carbonyl gas, which is a 

very poisonous gas. And then the nickel carbonyl 

gas is distilled to separate contaminants, heated, 

and then decomposed into pure nickel and carbon 

monoxide. That is the basic process that’s probably 

not in the scope of the presentation here, but I just 

wanted to give you some background on what the 

facility did.

Next slide, please. The AEC had a large supply of 

scrap nickel that had been building over a period of 

years and starting in 1956, they began 

experimental steps, introduced that nickel into the 

RPP as a source of feed. They initially started using 

small quantities for test purposes. The facility was 

set up in parallel lines so there could be multiple 

batches at the same time.

They initially started with one line, but the scrap did 

up the process and they eventually converted all the 

lines, starting in 1957, to use exclusively the AEC 

material. The nickel supplied INCO by AEC was 

guaranteed to have no more than 0.0870 grams per 

pound of U-235, and no more than 500 parts per 

million total uranium. Later data showed that the 

actual numbers were much lower than that.

The AEC also notified INCO that the material would 

have trace quantities of typical contaminants that’s 

found in recycled uranium. Because this material 

had -- some of this material was contaminated, had 

been through the enrichment process at the 

gaseous diffusion plants.

Next slide. During the process, the uranium does 

not form a carbonyl. There are other contaminants 

in the nickel, such as iron principally, that is 

removed in the distillation process. The uranium 
64

does not form any carbonyl compound that’s 

removed in the second step, and falls out at the 

residue. When INCO converted their systems over 

to handle the scrap, they also upgraded their 

residue handling system to catch the ash in the 

receivers in the residue system. This was a inert 

system. It was handled inertly through vacuum and 

the residue that resulted from each batch that was 

processed was collected in drums and sent back to

AEC.

The facility operated until 1963. I don’t have the 

exact amount of material processed through there, 

but at one point in 1960, they recorded over nine 

million pounds of scrap nickel had been processed in 

the facility. When they started to shut down in 

1963, the intention was to keep in condition so it 

could be reopened if it was necessary. The systems 

were purged. INCO was contracted, contract 

modification with INCO and they performed -- was 

scheduled to perform routine maintenance during 

the Standby period. There was a list of scheduled 

maintenance items, as well as security inspections.

In the latter part of the Standby period, the AEC did 

a security inspection and radiation survey. This was 

performed in January of 1975. Following that, the 

AEC terminated all maintenance requirements for 

the facility in March.

Next slide, please. Following shortly thereafter, the 

AEC gave permission to dispose of the facility and 

the buildings were disposed of by contractor, 

Cleveland Wrecking Company, between November 

1978 and May 1979. The facility and all the 

equipment was segregated into contaminated and 

potentially contaminated materials and was sent to 

DOE sites for burial. There was a final survey after 

the demolition in 1979 followed by a more detailed 

survey after that.

Next slide, please. This is the timeline of the 

operation shown here on this slide. It may be hard 

to read but I’ll summarize what this slide shows. It 
65

shows that the RPP began operations in 1951. 

Contaminated scrap was introduced in the facility 

starting in 1956. The RPP was shut down in 1963 

and maintained in Standby condition. In 1975, 

there’s a mark on this timeline that shows when a 

survey was performed and maintenance was 

terminated at approximately the same time. It also 

shows the dates of the demolition and the surveys. 

And you’ll notice that the two vertical dotted lines at 

the end is the period of the SEC requested Class 

which is after the surveys, the initial survey was 

performed and after maintenance was terminated.

The period under evaluation goes up through the 

end of, to the day before the V&V started. V&V was 

started on, I got my dates mixed up here. The 

requested Class fell through November 26th, 1978, 

and the demolition started the following day.

Next slide, please. The radiation exposures for the 

evaluated Class include potential internal exposure 

from alpha dose from uranium and also from 

contaminants from recycled uranium. And records 

indicate that the material was low-enriched 

uranium. And then records that we have after they 

processed nine million pounds of nickel scrap, they 

reported that the total uranium content of the 

residues, of the materials processed through there, 

was one percent with a U-235 content of about 0.9 

percent.

And the recycled uranium components, we have no

specific data on those so we relied on data from 

gaseous diffusion plants for that. External sources of 

dose, or photon dose, beta dose, there was no 

significant dose marked in view of references in 

TBD-6000 from the sources used at that site. We 

assume that medical x-rays are required because 

there’s a lack of information specifically on x-rays.

Next slide, please. There’s the data we have on the 

facility. This is results from the survey that was 

taken just a few months before the requested class. 

In January of 1955, there was a survey done of the, 
66

specifically, the residue handling system and the 

areas that were known to have contacted uranium 

contaminants during the processing years. The 

alpha readings, the contact readings was the 

highest at 96 DPM/100 cm2. That was a direct 

reading. And the highest smear on those areas was 

19 DPM/100 cm2.

Gamma dose readings taken in the Process Building, 

they were taken three feet above the floor and they 

found no elevated gamma readings without 

background. We should note that these, this 

particular survey was done in the winter, and they 

did not do outside areas at the time. They only did 

the buildings partly because of the weather. There 

was some snow, three inches of snow on the ground 

during the survey.

Well this particular survey just did the Process 

Buildings, and they called on INCO to identify areas 

where the material was actually held. The gamma 

dose readings that I already mentioned was not 

above background. It did do a beta-gamma dose 

rate readings on contact with the process residue 

system, and a couple of the phalanges, they had 

found in there, had a contact reading at 0.25 

mR/hr, beta-gamma dose rate readings. And those 

smears were none detected for the beta-gamma.

Then upon demolition more detailed surveys were 

performed to include other areas of the site besides 

the Process Building. They confirmed the Process 

Buildings and they did surveys around the site. They 

found contact with the ground, with the floor 

surface at 45 microR/hr per contact reading. They 

subsequently sampled that and detected elevated 

levels of Ra-226, which they attribute to the 

naturally occurring radium materials.

They also found some elevated gamma readings at 

three feet in the Compressor Building. The highest 

readings were actually in the stairwell. They did 

some samples of those materials and included that 

those were elevated Ra-226 in the building where 
67

material was used.

Next slide. NIOSH believe that estimating the 

intakes of uranium based on the smear data that 

contamination was found. We assume that the alpha 

activity is from uranium, so they calculated the 

uranium intake based on that result. They used that 

maximum smear result of 19 DPM/100 cm2, 

combined that with a factor of, resuspension factor 

10 to the -6 per meter, and a 1.2 m3/hr breathing 

rate over a time period of exposure. We assumed 

that a worker would spend 15 minutes per day in 

the facility every day of the year to come up with 

91.3 hours per year.

This is a, just an estimate of what he likely could 

have spent and that makes the intake of uranium 

0.208 dpm/yr.

To allow for intakes of contaminants in the recycled 

uranium, we consulted with the K-25 ED Site Profile. 

It has values for uranium and the various 

contaminants in the recycled uranium, which is 

shown here in the table on this slide for low 

enriched uranium. These ratios were taken from 

internal intakes of the various nuclides.

Next slide. And this is the result from that table 

from the previous slide. They’ve taken 0.208 

dpm/year of uranium and applied those ratios 

across these intakes of the radionuclides for 

inhalation.

Next slide. I’ll go through the method here of how 

we estimate external photon dose for security 

personnel during the evaluated period. They had 

results of 8-10 microR/hr at three feet above the 

surface in the Process Building from the 1975 

survey. It also had a high gamma reading on 

contact on the driveway from the 1980 survey. That 

was a contact reading, not a hold by exposure 

reading. But we also had a high gamma reading at 

35 microR/hr in the Compressor Building in the 

1980 survey. So these would be taken the highest 

three feet reading and multiplied it times the 91.3 
68

hours estimated for time in the facility for the 

guard. It came out to 3.2 mR/yr gamma dose 

readings.

We’ve taken a similar approach for beta dose. In the 

1975 survey, a full cassette survey for beta-gamma 

readings on the areas where the residue system 

was collected. And I had mentioned earlier that the 

highest contact reading was 0.25 mR/hr. That was 

the beta-gamma reading (Audio interference) data. 

And we took that value with hours estimated per 

year to come up with an annual beta dose of 23 

mrad/year for contact. These are considered to be 

damaging doses, not necessarily those in the body.

Finally, I’ll get to our summary of our findings. 

We’ve concluded that we can estimate internal dose 

from the uranium with sufficient accuracy, and the 

recycled contaminants as well. And we can estimate 

doses, gamma and beta dose with sufficient 

accuracy, as well as the medical x-ray dose. And 

that is it. Are there any questions?

Member Beach: Yes. Tom, this is Josie. I have a 

question. There -- I looked through the ER. There is 

not any claims for the operation or production 

period. Is there? This is the only SEC petition for 

this site. Is that correct?

Mr. Tomes: That’s correct. Yes. And our evaluation 

was just for the period that was requested.

Member Beach: Yes. Did you look for any other 

claims or anything for this site?

Mr. Tomes: We’ve looked at every single claim. We 

reviewed every claim for data and for information. 

That table you saw in the slide was the number of 

claims, and I think the ER points this out, that that 

table doesn’t consider the fact that during this 

evaluation process, the Class was extended to 

include the Standby period. So that data at some 

point, that data is dated already because at some 

point, DOL would return claims to us because of the 

period that was added to the Class.
69

Member Beach: Okay. That just seems unusual. And 

then I have one more question on, I think it was 

Slide 30, when you were talking about the 

Compressor Building.

Mr. Tomes: Yes.

Member Beach: Earlier in your presentation, you 

mentioned that there was nothing, no 

contamination or process in that building. I thought 

you were pretty clear about that. But then you 

talked about the three feet above the ground, that 

last bullet. Can you explain that a little bit? Or is 

that background? Or what’s going on there?

Mr. Tomes: It’s building materials background. That 

was the conclusion of the people who did the 

surveys and it was checked out by a couple of 

people at the time. And they sampled it and did an 

analysis of it and found slightly elevated Ra-226 in 

the building materials. And Ra-226 would not have 

been a contaminant concern in the scrap uranium 

that was sent to them from AEC. So there was no 

indication that it was from any process activity other 

than the building materials itself.

Member Beach: Thank you.

Mr. Tomes: Yes.

Member Field: Bill Field. I have a question on Slide 

25. You’re talking about alpha contamination 

readings, there was contact readings of 960 and the 

smears were 19. So what you’re saying there is that 

the, there was contamination but it wasn’t 

removable?

Mr. Tomes: Yes sir. It was contact with the alpha 

scintillation detector and then they smeared the 

locations of those.

Member Field: And then the other slide Estimating 

Internal Dose from Uranium, you have the 

maximum swipe sample of 17 DPM to estimate 

airborne radioactivity. How is the removable used to 
70

predict airborne?

Mr. Tomes: The assumption is that is entirely -- it 

can become airborne from casual walking through 

the facility. And that material’s there could 

potentially be resuspended in the air.

Member Field: Okay. I’m just, you know, there’s 

just a lot of difference between removable and nonremovable contamination. That’s just -- I guess 

once it played it out, or deposited, the dosing is all 

removable over time. It just seems like it’s funny 

that it’s a static thing but it could be removed now. 

But it could have been removed a month ago. Just, 

you know, it’s a small difference. I was just curious 

about that. Okay. Thank you.

Mr. Tomes: I will point out that most from this 

facility, that most of the smears were nothing. You 

know in single digits and they’re very, very low.

Member Field: Right.

Member Field: Okay. Thanks.

Member Kotelchuck: Tom. Yes. Tom?

Mr. Tomes: Yes.

Member Kotelchuck: Dave Kotelchuck. On Slide 27, 

you said that the security inspection took 15 

minutes a day. What was the basis of that? Was 

that the interview with the one person?

Mr. Tomes: There were several descriptions in that 

ER. I didn’t write that down to include in the 

presentation. It was an assumption that we made of 

how long a person would logically spend going, 

walking through the facility. It admittedly, is not a 

firm number. It is a, I think we can down the doses. 

Admittedly 91.3 is a what we’re just looking for as a 

reasonable number.

Member Kotelchuck: Yes. I just may not, but how 

did you come to the 15 minutes estimate? Did you 

talk to somebody walking through the building? Or 
71

did you look at some records of -- you didn’t have 

records, I guess, of then. I mean, it doesn’t sound 

unreasonable. But --

Mr. Tomes: I don’t remember the exact, I can’t look 

it up while I’m talking to you but basically, someone 

looked at how long somebody would actually walk 

through, spend walking through the facility casually 

during an inspection.

Member Kotelchuck: And that was told to you by 

whom? Or how did you -- I mean, you didn’t walk 

through it. So somebody reliable said to you that it 

should be, I mean, you know, I don’t -- it comes 

from somewhere, I assume.

Mr. Tomes: I can read what’s the in the Evaluation 

Report. That’s probably going to give you a better 

idea of what the basis of that is than what I can tell 

you. Because I just don’t --

Member Kotelchuck: Right. I know it’s hard for you 

to do as you’re doing a slide, and there are many, 

many pieces of data in there. And it’s a reasonable 

number but a reasonable number still has to have 

some sort of basis. Some sort of objective basis in 

records, in reports by individuals. And I know you 

can’t look it up now, but I would like to just get a 

handle on how you got that.

Mr. Tomes: I do have that in front of you.

Member Kotelchuck: Oh. Okay. Good.

Mr. Tomes: I can tell you. It says using a typical 

walking speed at three miles per hour, or 4.4 feet 

per second, a person could walk the length of the 

process building in about 34 seconds. The line for 

deviation and stops, NIOSH is saying that no single 

walk through would take more than five minutes. 

This was a debate on our side when we did this and 

we thought it was a, probably a reasonable number.

Member Kotelchuck: Yes.
72

Mr. Tomes: But I would point out that there are 

some unknowns here. For example, we assumed 

that this is the amount of time that a person was 

actually exposed to the highest levels. In many of 

these areas, there was actually minimally elevated 

dose rates, and no contamination. So it’s a, it is a, 

just an matter of debate of what the number of 

hours should be.

Member Kotelchuck: Could I ask, I didn’t quite catch 

the last part of what you said. Is there -- this is a 

flat area? There are no ladders to walk up to a 

second floor to look at something? It’s just --

Mr. Tomes: The Process Building’ a five story 

building and there would be -- I don’t have the 

pictures of the entire inside of the building, but 

there were large, large vessels. Some of them 24 

feet tall. So there would be catwalks and things like 

that, I’m assuming. Like it would be in a typical 

chemical plant.

Member Kotelchuck: Yes. I would think. But that 

takes time to walk up if there was a need to walk 

up. That’s not --

Member Anderson: This was while it was on 

Standby.

Member Kotelchuck: Pardon?

Member Anderson: It was on Standby. Yes. I mean, 

is there anything written as to what the security 

inspection was supposed to involve? Were there 

things they were supposed to have padlocks on 

them that they’d have to check? See things are 

closed? Was it just a walk through and see if there’s 

been a leak somewhere? Or what?

Mr. Tomes: I have not seen any details of what this 

security inspection involved. But the security people 

were not the people who went checking for leaks 

and maintenance type activities. There was 

designated, they had a designated protocol for that.
73

Member Anderson: Yes.

Mr. Tomes: Which, as I mentioned earlier, that that 

ended in 1975. The maintenance did. But that does 

not involve security people. That involved the 

maintenance personnel.

Member Kotelchuck: So they, I mean, with the 

security, was the focus of their security that there 

was no intruders in the site?

Mr. Tomes: The way I understood, it was just a 

typical security inspection to make sure the facility 

is secure and locked up, as it should be, and no 

intruders. That’s all I’ve read about and not seen 

any other, I have not seen any other details of what 

their responsibilities would be.

Member Kotelchuck: Okay. I’m not entirely 

comfortable. It sounds perfectly reasonable but I 

wish there were more definitive basis for that.

Mr. Tomes: Now what I think we proposed, I think 

what we have is, we have a means to bound the 

dose. I think what we may have a failure on is what 

is that number that we’re going to use. Because I 

think we had a pretty good means to bound the 

exposure rates depending on just a matter of the 

hours they were exposed.

Member Kotelchuck: Oh, yes. Absolutely. I’m quite 

comfortable with that. I mean, there’s perfectly, you 

know, there were these measurements made just 

before the period that the people requested claims 

for. But to be absolutely sure and 91, you know, 

truth is, if it were 30 minutes a day, I don’t think it 

would put the people in, you know, in, well, it 

doesn’t, I mean, it’s not unreasonable at all but 

maybe I would, maybe we listen to other folks on 

the Board, if they are, if that is concerning to them. 

But I’m not disputing it. I’m just asking for --

Mr. Tomes: I should point out that our technical 

basis document, the Site Profile, will need to be 

revised to incorporate the Standby period and this 
74

new information we found. And I don’t think that we 

would have a problem adjusting the hours if we 

have if that means a more rational approach to do 

that.

Member Kotelchuck: Yes. Yes. So are we, and I 

don’t know, this is the introduction. Are we being 

asked to vote on the, accepting this as an SEC, or 

not today?

Member Beach: Dave, no. It usually --

Member Anderson: For committee. Yes.

Member Kotelchuck: Oh, okay. Fine.

(Simultaneous speaking.)

Member Kotelchuck: Oh, fine. Excellent. Okay. So 

there’ll be a chance to look at that number and all 

the other numbers. Okay. Good. Then I’m quite 

comfortable with that.

Member Ziemer: This is Paul. I think we have to 

probably formally assign this for review to SC&A or 

to task them. Tom, I have a couple other questions. 

On the internal dose, those numbers you calculated 

so far, are you just mainly looking at lung dose for 

the internal? Of course, it’s going to vary. You’d 

have to calculate it for the dose a particular cancer 

if you have a claimant. But it looks like typically, the 

lung would be the main organ of interest here. And 

with these numbers you’re talking about, it’s 

probably a really small, even the bounding dose.

What I’m getting at, it looks to me like the main 

exposure to an individual annually here is going to 

be the medical.

Mr. Tomes: I’m going to say you’re likely correct.

Member Ziemer: Yes.

Mr. Tomes: The 0.208 dpm/year of uranium, even 

for the lungs, is not going to be a very large dose.
75

Member Ziemer: No. Regardless of which organ you 

chose, it looks like most of these -- but you are 

regarding them right now as bounding as far as you 

made these initial calculations and of course, I 

assume it’s going to be reviewed by SC&A or we 

need to task them to do that.

Mr. Tomes: Yes, we can. What we probably see here 

is the bounding. That’s the reason we selected the 

highest radiation measurements to be bound.

Member Beach: Paul, this is Josie.

Mr. Calhoun: This is disintegrating and one thing 

that is interesting to note here on the alpha 

contamination is both the pick and the removal for 

pretty much it’s pretty releasable levels.

Member Ziemer: Pretty much what?

Mr. Calhoun: An unrestricted release level for 

uranium.

Member Ziemer: Yes. Right. Right. So that building 

could, in essence probably have been completely 

released to the public.

Mr. Tomes: Yes. That was the recommendation from 

the survey, but there were other considerations 

they had for the nickel and possible if they found 

more contamination in the residue system, which 

they made sure they had radiation technicians on 

staff when they did the demolition for that. There 

may have been some chemical toxicity issues 

anyway.

Mr. Calhoun: Yes. So arguing 15 minutes for a site 

that’s essentially prereleasable and, I don’t know, I 

don’t know how much time to put into that.

Member Ziemer: Well this is one of those cases 

where the doses are so small you can tolerate a 

high level of uncertainty. You can double the 

number and it’s not going to change much.

Mr. Calhoun: Right. Yes. I agree, Dave.
76

Member Kotelchuck: Okay.

Dr. Roberts: Okay. If I could break in here. I’m not 

sure if there are any petitioners that may be on the 

line, but I do want to make sure that they had an 

opportunity to comment or present. Okay. I’m not 

hearing any. Now I understand with this site, we 

need to set up a Working Group. Have I got that 

right?

Member Beach: Rashaun, I have a question to you 

and Paul. Would this one fall under TBD-6000?

Member Ziemer: Well, I wondered about that 

myself. It’s in many ways quite different. I mean, 

we’re talking about, they’re not really, they’re really 

not rolling or doing uranium, per se. But it looks like 

a chemical process just to produce nickel. It doesn’t 

look like any of the TBD-6000 processes are similar. 

Andy, what about your group? Same issues?

Member Anderson: Yes. I would say the same thing. 

I mean it’s, they were rolling -- yes, I’m not sure if 

it would fit with what, you know, the typical facilities 

that we’ve reviewed do.

(Simultaneous speaking.)

Member Ziemer: I’m certain about the opinion that 

we should task it to SC&A and have them write their 

report, and see whether it’s worth having a full 

Work Group effort if there really aren’t significant 

findings that need handling.

Member Kotelchuck: I think that sounds like, that 

sounds like a good idea.

Member Beach: Yes. I would agree with that also.

(Simultaneous speaking.)

Member Ziemer: If we can avoid another Work 

Group, we probably should. We’re shorthanded 

anyway right now on the Committee. I don’t see 

this being a big effort.
77

(Simultaneous speaking.)

Member Ziemer: Can we put on something really 

substantial.

Member Anderson: Dave, you seem, it looks like 

you seem kind of interested in this and you’re of --

Member Kotelchuck: I’m on AWE, am I not.

Member Anderson: Yes. I mean, if you’re interested, 

I mean.

Member Kotelchuck: Yes.

Member Anderson: It isn’t exactly, but I’m not sure 

I would, if you said, gee, why don’t you guys take it 

on, I think we could do that. Rather than have to go 

and create a whole new group.

Member Kotelchuck: Right. I think we could. That’s 

my feeling too.

Member Anderson: Let’s --

Member Kotelchuck: Have one more member of our 

group.

Member Anderson: Yes.

Member Kotelchuck: But for the moment, really, we 

don’t have to decide that.

Member Anderson: No.

Member Kotelchuck: For the moment, SC&A will 

review and after their review, we’ll decide what to 

do with it. But you’re right. I’m disposed as an AWE 

member to saying, good chance it would come to us 

if need be.

Member Anderson: All right. As a home of last 

resort.

Member Kotelchuck: Right. Okay.

Member Anderson: We would do it justice.
78

Member Kotelchuck: We will. We do, we will do 

justice to all.

Member Ziemer: This is Paul again. I’m trying to 

recall if we need to formally make a motion to task 

this or just leave it up to the DFO to task it.

Member Beach: I think just the DFO. Isn’t that all it 

requires?

Dr. Roberts: Yes.

Member Kotelchuck: I think it’s all that’s required.

Dr. Roberts: Yes. I think that’s it.

Member Kotelchuck: I think that’s automatic. It’s 

standard procedure.

Dr. Roberts: Yes. Okay, very good. So it sounds like 

once we hear back, get the SC&A report, then we 

can decide about whether or not a group needs to 

be formed. It sounds like that’s not likely but we’ll 

assess that after the SC&A’s report.

Member Kotelchuck: Exactly.

Dr. Roberts: Okay. Fantastic. Well, were there any 

further comments on this presentation? Or are we 

ready to kind of wrap it up?

Member Beach: I have one more question. During 

Terrie Barrie’s comments yesterday afternoon, she 

mentioned forming a Work Group on looking at the 

petitions. And I’m not suggesting we form a Work 

Group for that, but I thought we might. Was there 

anybody that thought that might be something that 

the Board should look into?

Member Lockey: Jim Lockey. We used to have a 

Work Group in the past did that. And we last did 

that about, what, ten years ago.

Member Beach: Yes. I thought that was --

Member Lockey: So we can reinstitute that work 
79

group, but there’ll be, I don’t remember who was on 

it besides myself.

(Simultaneous speaking.)

Mr. Rutherford: I could tell you who was on it. It 

was Jim, Dr. Lockey, it was Dr. Roessler, Dr. Munn, 

or Wanda Munn, and Dr. Melius.

Member Lockey: We could just, if you think there’s 

a need to do it, we can just reinstitute that group 

and replace Dr. Melius and Dr. Munn with two other 

members.

Member Kotelchuck: I am open to that. I did not 

comment when Ms. Barrie spoke. But I was also 

favorable impressed with anything that would help 

claimants put in an appropriate claim if they were 

claiming an SEC. So it’s always, if we can help, it 

would be nice. I don’t know if we can. I don’t know 

if every issue she raised would have been 

appropriate. But I would certainly be happy to be on 

such a committee to think about that and see what 

we could do.

Ms. Naylor: Hi. This is Jenny Naylor with (Audio 

interference). As I recall, the Work Group that was 

instituted to look at the difficult occasions of SEC 

petitions was actually specifically looking at whether 

the NIOSH procedures and policy were consistent 

with the rules and regulations. And that’s very much 

in line with responsibility delegated by the President 

to the Advisory Board, due to Executive Order, 

13.179. And so if we wanted to have a conversation 

about whether to reinstitute that, and also to look at 

the process or looking at specific disqualified SEC 

petitions, then I think maybe a more nuanced 

conversations about whether that is consistent with 

the Advisory Board’s charters and it’s delegated 

responsibility, you know, that’s in line with that 

request.

Member Kotelchuck: Oh, good.

Member Beach: So Jenny, who would have that 
80

conversation? This is Josie.

Ms. Naylor: Well, so in the past, it would have been 

the Chair of the Advisory Board. And also with the 

DFO. And I think leadership at NIOSH would also be 

involved. Because you know, the Advisory Board, it 

is the Federal Advisory Committee, and so all those 

tasks and responsibilities falling under this specific 

Federal Advisory Committee is charter and is also 

reflected in the executive order with statutory 

responsibilities.

So I think we could have more offline discussions 

and then looking at some of the, you know, the 

statutory provisions, as well as the regulation in 13, 

I think it’s 42 USC, I’m sorry. 42 CFR. It might have 

been 13.15. That’s where he outlines how the 

Board, when I should review the SEC petitions. So 

I’m moving that definitely do more conversations --

have more conversation about that and, you know, 

if it’s a request from the Board, then we can submit 

it to the DFO and the Office of General Counsel will 

definitely look at that issue with you guys.

Member Lockey: How did it happen ten years ago? 

What was the -- how is that different than what 

we’re asking for today?

Member Ziemer: This is Paul. I think Jenny is saying 

before we reopen that Work Group that we have 

General Counsel and DFO, and probably NIOSH 

examine what the legal implications are and biases. 

Is that what, did I understand that correctly?

Ms. Naylor: Yes. I think that is. Because I wanted to 

go back to look at the transcript to see exactly what 

is asked for. And also, what’s really the scope of the 

Board’s responsibility here in this task. As I recall, I 

think the Work Group, the charge of the Work 

Group to review the SEC petitions that do not 

qualify for evaluation. It’s actually to look at 

whether the SEC final rule is reflected in the 

legislation. So in this provision, how the SEC 

petition should be evaluated.
81

And so that review was at a higher level review in 

terms of making sure that the procedures and 

policies are consistent with the regulatory, with the 

regulatory provision. And so if the Advisory Board is 

not satisfied with the prior Work Group’s evaluation, 

then that’s something that we can talk about. But if 

today, the request from the Advisory Board is that 

they want to specifically review all petitions that did 

not qualify for further evaluation, then I think that’s 

a different line of conversation where we have to 

really look at what’s the statuary responsibility 

delegated by the President to the Secretary, and 

also with the delegation from the President, to the 

Advisory Board through the Executive Order.

And also what’s the Advisory Board’s charter. So 

that’s really the thinking that needs to go in, more 

than just establishing the Work Group.

Member Kotelchuck: Right. Also, Jenny, I’m a little, 

I didn’t think it was a question of turning down 

SEC’s, or reconsidering the process by which we 

accept or turn down. I’m thinking more that the 

request was by a claimant or a claimant’s counselor 

to look at the process of giving information to 

claimants, how we help claimants, advise them in 

terms of improving, or giving us a claim that fits 

into what we’re doing.

So I’m not thinking we’re overturning something. I 

really understood the request to be assisting 

claimants by giving them information, or more 

information about our process.

Member Lockey: David, this is Jim Lockey. I agree 

with you. I agree with you. That’s what I heard in 

that request. We’re not trying to double think what 

NIOSH has determined, just whether the procedures 

are followed and getting back to the claimant to 

explain to them what was missing, or why it wasn’t 

qualified.

Member Ziemer: This is Paul. I wonder if I could, I 

know that we don’t have public comment right now, 

but I hope the attorney is on the line. I wonder 
82

about if it would be appropriate to ask Terrie to 

provide all the Board Members the exact wording of 

that. I think it would be helpful to us to have the 

wording of that request.

(Simultaneous speaking.)

Ms. Barrie: This is Terrie.

Member Ziemer: -- general counsel also take a look 

at it and see if there’s any issues we have to worry 

about.

Ms. Barrie: Hi Dr. Ziemer. This is Terrie and I’d be 

happy to, well actually, I submitted my written 

comments on the NIOSH docket but I’d be happy to 

send it to Dr. Roberts, again, to circulate it to the 

Board and to Jenny, if that’s what you’re asking.

Member Ziemer: That’s what I would like to see as 

a starting point. I sort of have a general idea of 

what it was but before we set up a Work Group, or 

reopen one, maybe we can take a look at that. I’m 

happy, if once we look at it, we can ask that the 

Work Group be initiated. We need to do that right 

away once we have the reading -- or the material, I 

think.

Member Kotelchuck: And I think we could --

Ms. Barrie: Dr. Robert --

Member Kotelchuck: Sorry. I’m sorry, go ahead.

Ms. Barrie: Dr. Robert, do I need to resubmit this or 

can you just send that to the Board Members?

Dr. Roberts: No, I can send it. I have them.

Ms. Barrie: Okay. Thank you.

Member Kotelchuck: Okay. So in fact, let’s consider 

this. It’ll come up and we can discuss it further at a 

future meeting. I mean, I did have some favorable 

views about what was said but let’s find out exactly 

what’s requested, and then discuss it ourselves, 
83

whether we want to initiate some changes, some 

modifications, which would, of course, have to be 

checked through by legal counsel.

Dr. Roberts: Of course.

Member Lockey: LaVon, are you still on the phone?

Ms. Barrie: If any of you have questions, I’d be

happy to answer them.

Member Beach: Thank you, Terrie.

(Simultaneous speaking.)

Mr. Rutherford: Yes, yes.

Member Lockey: So when we did this originally, one 

of our concerns was that when we got back to the 

petitioners was made clear as to why my request 

was turned down. I think we went through that and 

I was reassured at that time that it was put in 

language that the people could understand, as to 

why a petition didn’t meet the qualifications. Is that 

still going?

Mr. Rutherford: Yes. Well, I can tell you that there 

has been actually changes made much beyond that, 

even to the point where we’ve tried to pull in plain 

language, we’ve tried to do a lot of different things. 

We took the findings from the Work Group. We 

implemented the changes. One of the biggest

findings from that Work Group was that 

communications back to the petitioner.

I did hear Terrie’s discussion last night and her 

discussion yesterday was that apparently that it was 

not readable or understandable, and so on, so 

maybe we need to look back at that. I’m not sure.

Member Lockey: Can you share that with us too, 

LaVon? Can you share along with Terrie, her 

concerns? Or LaVon, do you have that? Do you have 

that on this petition?

Ms. Naylor: Dr. Lockey?
84

Member Lockey: Yes.

Ms. Naylor: This is Jenny. I will direct your request 

to Dr. Roberts because she does have access to the 

documents submitted to the docket. And I also just 

want to note that Ms. Berrie’s replies to have a 

panel of three HHS personnel who are not involved 

in the SEC petitioner evaluation are not really, are 

not employed by the dose reconstruction programs 

currently reviewing the decision not to qualify the 

petition.

So the due process that’s outlined in 42 CFR 83.11 

is actually in place right now. So I would --

Member Lockey: I got you.

Ms. Naylor: -- respectfully ask the Board to also 

give that, give the time and space for the panel to 

conduct its administrator review and be able to 

respond appropriately to Ms. Berrie’s request.

Member Lockey: That sounds good. That’s 

additional information. Great.

Member Kotelchuck: Good.

Dr. Roberts: Okay.

Member Lockey: So maybe we can look at this at 

the next conference call.

Member Kotelchuck: Yes.

Member Anderson: Or the next Board meeting.

(Simultaneous speaking.)

Member Lockey: Yes.

Member Anderson: There’s a lot --

(Simultaneous speaking.)

Member Anderson: Maybe a presentation 

summarizing what’s actually in place now after the 

committee. We don’t often see that (Audio 
85

interference) forgotten about that issue about 

outside HHS staff review as well.

Member Lockey: I agree with Andy. That would be 

helpful. That would bring us up to date on the whole 

process and how it has evolved over the last several 

years.

Member Beach: Is that something, this is Josie, 

NIOSH would do? LaVon is your hand up? I can’t 

see.

Mr. Rutherford: I was waiting for my boss to jump 

in but he didn’t. Yes. That would be something that 

I would do if my director decides that’s what I need 

to do.

Member Anderson: Let’s first look at the document 

and then we can see if we want to go to that extent.

(Simultaneous speaking.)

Mr. Rutherford: I really don’t have a problem doing 

a presentation on how the qualification process 

works.

(Simultaneous speaking.)

Member Anderson: I mean, I don’t want to make a 

lot of extra work if we don’t need it, but I think that 

would sort of set everybody at the same point of 

what would we like that a reconvene committee 

would ever do. What would be (Audio interference).

(Simultaneous speaking.)

Member Anderson: We don’t want to try to come up 

with something that’s actually already in place.

Mr. Calhoun: This is Grady. And my understanding 

would be that if we decide that this is, this needs to 

be looked at again, we wouldn’t be looking or, you 

know, asking the Board to be looking at qualification 

reviews for each petition. I think you’re looking at 

the overall process to see if the process is okay.
86

Member Lockey: That’s correct.

Mr. Calhoun: And because of what Jenny just 

mentioned, was that, you know, we do have that 

independent review committee that’s available 

every single time the petition is reviewed, you 

know, during the qualification process. So, yes, just 

to look at the overall process and not a look at each 

one as it comes through because that would really 

belabor the entire process and it just wouldn’t work.

Mr. Rutherford: Right.

Member Lockey: LaVon, what would be helpful for 

me is if you did give a presentation how, you know, 

how it’s evolved over the years. So that brings us 

up to date to where you stand now so we have a 

good idea about that.

Mr. Rutherford: Right. I can go through all the way 

back from 2007, I believe, is when that Work Group 

actually last made this, their determination, and I 

could -- the findings from that, what we changed, 

and then what’s changed even beyond that up to 

this point.

Member Lockey: That would be wonderful. I think 

that would bring everybody up to date and then we 

can make a decision after that.

Mr. Rutherford: Right.

Member Anderson: Is the external review group 

always the same people?

Mr. Calhoun: No.

Mr. Rutherford: Jenny could actually get into this 

more than I can. But it’s three people picked by Dr. 

Howard, independent people that are not involved in 

the program. Jenny can add to that.

(Simultaneous speaking.)

Member Anderson: I know it’s done but I don’t 

remember how it’s done or what, you know.
87

Member Ziemer: This is Paul. I suggest that we 

have this discussion at the next phone meeting after 

we learn from Jenny what -- any legal limitations 

and what we can do. And we can answer all these 

questions then. This isn’t on today’s agenda and we 

have a starting point. So let’s answer all these other 

questions when we have more time and have it on 

the agenda.

Member Kotelchuck: Agreed.

Member Ziemer: I guess I’m moving for 

adjournment.

Adjourn

Dr. Roberts: And I will go ahead and circulate 

Terrie’s comments that she posted in the docket for 

your review. So are we at a point where we can 

kind of wrap this up? Is there anything else before -

- okay. Okay. So we’re at the end of the meeting. I 

want to thank all the people who presented and 

prepared documents and presentations for today. 

It’s been a very productive meeting from my 

standpoint. And really appreciate the participation of 

folks from the outside, from the public, and their

comments.

And in general, thank you all for your attention and 

your engagement. And also your understanding 

since this is my first meeting, and I’m sure there 

were a few rookie mistakes in there. So thank you 

so much. You’ve been very gracious.

So with that, with no further ado, we’ll go ahead 

and adjourn.

(Whereupon, the above-entitled meeting went off 

the record at 6:48 p.m.)