TBD-6000 Work Group 

Report on 

SEC Petition 00105 for 

General Steel Industries 

Paul L. Ziemer, WG Chair

September 19, 2012 
Time Line for Sources at GSI 

 Jan. 1, 1953: Beginning of Operational 

Period 

 Mar. 7, 1962: Original AEC license 

application 

 June 30, 1966: End of Operational Period 

 July 1, 1966 – December 31, 1992: 

Residual Period 

 Jan. 1, 1993 – Dec. 31, 1993: DOE Cleanup Period 
Board Action at June 2012 Meeting 

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



The Work Group recommended that the Board not take 

action on SEC Petition 00105, but rather defer action 

until the next full Board meeting. 

This recommendation resulted from WG discussions on 

June 14, 2012 relating to the residual period and the 

desire of the Work Group to confirm the appropriateness

of the use of the TBD-6000 model of a uranium slug 

facility as a surrogate for the handling of uranium at 

General Steel Industries. This applies both to the 

operational period as well as to the residual period. 

The Board accepted this recommendation and tasked 

SC&A to review the SD issue. 
SC&A Findings Reported to WG on 

August 28, 2012

 SD Criterion on Hierarchy of Data: “...the use of 

surrogate data does not strictly conform to the hierarchy 

of data.” Also, “appropriate adjustments were not made 

to these surrogate data.”

 SD Criterion on Exclusivity Constraints: “We do not 

agree that the use of the surrogate data was stringently 

justified.”

 SD Criterion on Process Similarities: 

 “...the use of slug stamping as a surrogate for the 

handling of uranium at GSI does not fulfill Criterion 3.” 

 “Alternate sources of surrogate data (e.g., the 124 

work sites for which NIOSH has collected information) 

were not evaluated.” 
SC&A Findings Reported to WG on 

August 28, 2012 (continued) 

 SD Criterion on Temporal Considerations: 

“...need to justify the application of this 

measurement to the entire period of 

operations at GSI.” 

Note: SC&A later concurred with the NIOSH 

justification in the NIOSH response. 
SC&A Findings Reported to WG on 

August 28, 2012 (continued) 

 SD Criterion on Plausibility: 

 Scientific Plausibility: “...the assumption, that 

the deposition abruptly stops at the end of the 

operation, is neither plausible nor claimant 

favorable.” 

 Workplace Plausibility: “...the calculation of 

uranium concentrations described by Allen 

and Glover does not meet the criterion of 

workplace plausibility.” 
SC&A Recommendation 

 Recommended that NIOSH develop a 

methodology for estimating uranium intakes at

GSI that does not rely on surrogate data 

 Suggested a model that uses the exponential 

source-term depletion rate recommended in 

OTIB-0070. For this approach, the 

contamination levels on the floor of the Old 

Betatron Building at the time of the 1993 

cleanup, together with the depletion rate and 

varying hours of uranium handling operations at

GSI, could be used to calculate average surface 

uranium concentrations. 
Other Information of Importance 

 The co-petitioner provided documentation that 

the GSI facilities were cleaned and pressurewashed during three different time periods 

(1978-1981, 1984, and post-1985), all of which 

predated the 1993 reference date for the 

proposed surface contamination level. 

 The WG agreed the back-calculating surface 

contamination levels from the 1993 

contamination data had to be ruled out. 
Further Considerations 

 NIOSH provided its responses as to why it

believed the surrogate data criteria were 

met reasonable well by the handling of

uranium slugs. 

 Both NIOSH and SC&A felt that it would 

make sense to review the other data sets 

involving uranium metal handling to 

ascertain whether there was “better” 

surrogate for the GSI situation. 
NIOSH and Petitioner Responses 

to SG Issue 

 NIOSH will review their position on the 

Surrogate Data matter and indicate how 

they propose to proceed to address this 

matter and come to closure on the GSI 

SEC Petition. 

 The Co-Petitioners will provide their 

comments on these issues and any 

related matters. 
Work Group Recommendation 

 The Work Group agreed to report this 

information to the Board without a specific 

recommendation. 

 The Board can choose to ask NIOSH to 

examine possible alternate surrogate data 

sets (followed by SC&A review), or it can 

choose to act on the SEC petition on the 

basis of the information currently on hand.