TBD-6000 Work Gro

Recommendations on

SEC Petition 00105 fo

General Steel Industri

Paul L. Ziemer, WG Chair

June 20, 2012
Background information o

SEC Petition 00105

 Submitted February 25, 2008  Qualified for evaluation May 15, 200 Evaluation Report issued by NIOSH 

October 3, 2008 

 SC&A Review of NIOSH Evaluation R

of SEC Petition 00105 issued July 22009 
Proposed and Evaluated SEC C

 Petitioner proposed class definition: 

“All individuals who worked in any location a

General Steel Industries site, located at 141Street, Granite City, Illinois, from January 1through December 31, 1966, and/or during residual period from January 1, 1967, throuDecember 31, 1992.” 

 Class evaluated by NIOSH: 

“All individuals who worked in any location a

General Steel Industries site, located at 141Street, Granite City, Illinois, from January 1through June 30, 1966, and/or during the reperiod from July 1, 1966, through Decembe1992.” 
Review of the SEC Petit

 Since the time of the ER and the 2009 review by 

there has been a great deal of additional informaobtained about the GSI site. This includes a subamount of information provided by the Co-petitioMcKeel) through FOIA requests and other meanwell as information from former workers and site 

 The NIOSH web site includes a number of white 

issued by NIOSH and SC&A, as well is specific information and critiques from the Co-petitioner. 

 The Work Group has met 12 times since the ER 

issued in 2008, with most of its focus being on G(Appendix BB of TBD-6000 and SEC petition 00
Format for Today’s WG Rep

 NIOSH will review its proposed models fo

reconstructing dose at GSI in support of irecommendation to deny an SEC class a(Dave Allen) 

 SC&A will provide a summary of its findin

position on the NIOSH dose models (BobAnigstein) 

 The Work Group recommendations will b

presented (Paul Ziemer) 

 The Co-petitioner will present his issues a

concerns with the NIOSH proposal and Wrecommendations (Dan McKeel) 
Reports from 

NIOSH and SC&A
Time Line for Sources at 

 Jan. 1, 1953: Beginning of Operational P



1st Betatron used to X ray uranium ingots 

 2 radium radiography sources in use (500 mC

 Mar. 7, 1962: Original AEC license appli

 License granted April 18, 1962  2 cobalt-60 sources (260 and 280 mCi) purch

May 5, 1962 



2nd Betatron put into operation in 1963 

 2 portable X-ray units obtained for radiograph

 June 30, 1966: End of Operational Perio
Resolution of SC&A Finding

the SEC Petition 00105 

Evaluation Report

 Earlier this month all Board member

received a copy of the Issues ResolMatrix for the GSI petition with a delof WG actions taken on each item. 

 We will not cover these in detail toda

the issues and their resolution will be summarized briefly 
Issues Resolution

 Issue 1: Lack of radiation monitoring dat

1953 – 1963 

 Concern about specific incidents  Concern about assumptions for reconstructin

from radium sources 

 Concern about training, monitoring, and othe

during the early period 

 NIOSH and SC&A agreed that doses could 

bounded based on source size informatioreasonable assumptions concerning workpractices. 

 WG voted 2-1 not to recommend SEC stat

early period on the basis of this issue. 
Issues Resolution 

 Issue 2: Incomplete Monitoring of

Workers, 1964 -1966 

 Film badges provided only for betatro

workers and radiographers 

 No FB’s used outside the betatron bu NIOSH developed model for bound

doses to individuals working outsidbetatron room. Sc&A accepted this approach 
Issues Resolution Issue

Resolution

 Issue 3: Lack of Documentation 

 Original concern dealt with lack of information 

isotopic radiography sources, lack of informamonitoring data, and lack of evidence of an eradiation safety program 

 After identification of sources and additio

information on practices, SC&A accepted model for reconstructing dose. 
Issues Resolution

 Issue 4: Film Badge Dosimetry

Dependence on Photon Energy andExposure Geometry 

 Concern that FBs under respond for ce

geometries and energies 

 The modeled doses for betatron wor

exceed the maximum FB values, evethe energies and geometries that prothe highest FB readings. SC&A acceNIOSH model. 

 The WG closed this issue. 
Issues Resolution

 Issue 5: Lack of Validation of Mode

Radiation Exposure to Betatron Ope

 Concern that for period when FB repor

available, measured and modeled expdid not agree 

 Later models, normalized to the FB 

provided reasonable agreement. BoNIOSH and SC&A agreed that externdoses could be bounded with sufficaccuracy through the use of MCNPXsimulations. WG closed this issue. 
Issues Resolution

 Issue 6: Underestimate of External 

Exposure to Unmonitored Workers

 Concern based on early models that fo

only on radiographers vs. “non-exposeand office personnel 

 Current models assign exposures to 

workers and include exposures origfrom betatron and isotopic sources as support activities. 
Issues Resolution

 Issue 7: Dose Reconstructions Not 

on Best Available Science 

 Concern was actually an error in calcu

plus a difference in model codes used NIOSH and SC&A 

 Not an SEC issue. Resolved in later 

models used by NIOSH and SC&A
Issues Resolution

 Issue 8: Incomplete Model Used for 

Exposure Assessments 

 Concern was similar to Issue 7 and inv

omission of neutron doses in the NIOSmodel 

 Resolution similar to Issue 7 
Issues Resolution

 Issue 9: Underestimate of Beta Dos

 Concern based on neglecting what is k

as the Putzier Effect as well as omitting dose to those who were not betatron operators. 

 Putzier effect addressed and to be 

included in Appendix BB. Skin doseother workers addressed in most reNIOSH models 
Issues Resolution

 Issue 10: Lack of consistency in 

Assigning External Exposures

 Concern focused on an error in NIOSH 

calculations in its early model. 

 Not an SEC issue. This item was mo

by the WG to Appendix BB in 2010 asubsequently closed. 
Summary of SEC 00105 Iss

 Issue 1: Closed 

 Issue 7: Tran

 Issue 2: Transferred to Appendix B

to Appendix BB 

 Issue 8: Tran

 Issue 3: Transferred to Appendix B

to Appendix BB 

 Issue 9: Trans

 Issue 4: Closed to Appendix B Issue 5: Closed 

 Issue 10: Clo

 Issue 6: Transferred 

to Appendix BB 
Work Group Recommendat

 The Work Group recommends that the 

not take action today on SEC Petition but rather defer action until the next fuBoard meeting. 

 This recommendation resulted from W

discussions on June 14, 2012 relating residual period and the desire of the WGroup to confirm the appropriateness use of the TBD-6000 model of a uraniufacility as a surrogate for the handling uranium at General Steel Industries. Tapplies both to the operational period well as to the residual period.