TBD-6000 Work Group

Report on

SEC Petition 00105 for

General Steel Industries

Paul L. Ziemer, WG Chair

December 11, 2012
Time Line for Sources at GSI

• Jan. 1, 1953: Beginning of Operational 

Period

• Mar. 7, 1962: Original AEC license 

application (Co-60 Sources procured May 

21, 1962)

• June 30, 1966: End of Operational Period

• July 1, 1966 – December 31, 1992: 

Residual Period

• Jan. 1, 1993 – Dec. 31, 1993: DOE Cleanup Period
Action at September 2012

Board Meeting

• It was reported that both NIOSH and SC&A felt 

that it would make sense to review other data 

sets involving uranium metal handling to 

ascertain whether there was “better” surrogate 

data for the GSI situation. 

• The Board asked NIOSH to examine possible 

alternate surrogate data sets (followed by SC&A 

review) for determination of the internal dose 

component for both the operational and residual 

periods.

• The Board did not take action on SEC Petition 

00105, but rather deferred action until the next 

full Board meeting (December 2012)
Work Group Meeting Nov. 28, 2012

• WG reviewed NIOSH proposal for air sampling at AWE 

sites that represented the handling of uranium in various 

forms.

• WG reviewed SC&A evaluation of the NIOSH proposal. 

• WG received additional comments from site expert and 

the petitioner; also had written comments from copetitioner.

• NIOSH agreed to some modifications suggested by 

SC&A.

• WG acted on the proposed use of the air sampling data 

for the operational and residual periods.

• WG voted on the overall NIOSH recommendation on 

SEC Petition 00105. 

• WG confirmed that all SC&A findings on Petition 00105 

had either been closed or transferred to Appendix BB as 

non-SEC issues.
Recommendations from Work Group 

Meeting Nov. 28, 2012

• WG recommends that the Board accept the NIOSH 

proposal that it can reconstruct internal dose for the 

operation and residual periods and that the surrogate 

data criteria have been met. (Vote: 4 Ayes, 0 Nays)

• WG recommends that the Board accept the NIOSH 

proposal that it can reconstruct dose for the “earlier” part 

of the operational period, January 1, 1953 to April 18, 

1962. (Vote: 3 Ayes, 1 Nay)

• WG recommends that the Board accept the NIOSH 

proposal that it can reconstruct dose for the “later” 

operational period, April 19, 1962 to June 30, 1966 

(Vote: 3 Ayes, 0 Nays, 1 Abstention)

• WG recommends that the Board accept the NIOSH 

proposal that it can reconstruct dose for the residual 

period, July 1, 1966 to December 31, 1992. (Vote: 4 

Ayes, 0 Nays)
Reminders from Presentation at 

Santa Fe Meeting 

June 20, 2012
• Submitted February 25, 2008

• Qualified for evaluation May 15, 2008

• Evaluation Report issued by NIOSH 

on October 3, 2008

• SC&A Review of NIOSH Evaluation 

Report of SEC Petition 00105 issued 

July 24, 2009

Background information on

SEC Petition 00105
Proposed and Evaluated SEC Class

• Petitioner proposed class definition:

 “All individuals who worked in any location at the General 

Steel Industries site, located at 1417 State Street, 

Granite City, Illinois, from January 1, 1953 through 

December 31, 1966, and/or during the residual period 

from January 1, 1967, through December 31, 1992.”

• Class evaluated by NIOSH:

 “All individuals who worked in any location at the General 

Steel Industries site, located at 1417 State Street, 

Granite City, Illinois, from January 1, 1953 through June 

30, 1966, and/or during the residual period from July 1, 

1966, through December 31, 1992.”
Issues Resolution

• Issue 1: Lack of radiation monitoring data for 

1953 – 1963

– Concern about specific incidents

– Concern about assumptions for reconstructing doses from 

radium sources

– Concern about training, monitoring, and other controls 

during the early period

– NIOSH and SC&A agreed that doses could be bounded 

based on source size information and reasonable 

assumptions concerning work practices.

– WG voted 2-1 not to recommend SEC status for early 

period on the basis of this issue.
Issues Resolution

 Issue 2: Incomplete Monitoring of 

Workers, 1964 -1966

 Film badges provided only for betatron 

workers and radiographers

 No FB’s used outside the betatron building

 NIOSH developed model for bounding 

doses to individuals working outside 

betatron room. SC&A agreed that doses 

could be reconstructed during this period.
Issues Resolution

• Issue 3: Lack of Documentation

– Original concern dealt with lack of information on 

isotopic radiography sources, lack of information on 

monitoring data, and lack of evidence of an effective 

radiation safety program

After identification of sources and additional 

information on practices, SC&A agreed with 

NIOSH that bounding can be done
Issues Resolution

• Issue 4: Film Badge Dosimetry Dependence 

on Photon Energy and Exposure Geometry

– Concern that FBs under-respond for certain 

geometries and energies

The modeled doses for betatron workers exceed 

the maximum FB values, even for the energies 

and geometries that produce the highest FB 

readings. SC&A concurred. The WG closed this 

issue.
Issues Resolution

• Issue 5: Lack of Validation of Models of 

Radiation Exposure to Betatron Operators

– Concern that for period when FB reports were 

available, measured and modeled exposures did not 

agree

Later models, normalized to the FB data, provided 

reasonable agreement. Both NIOSH and SC&A 

agreed that external doses could be bounded with 

sufficient accuracy through the use of MCNPX 

simulations. WG closed this issue.
Issues Resolution

• Issue 6: Underestimate of External 

Exposure to Unmonitored Workers

– Concern based on early models that focused 

only on radiographers vs. “non-exposed” plant 

and office personnel

Current models assign exposures to all 

workers and include exposures originating 

from betatron and isotopic sources as well 

as support activities. 
Issues Resolution

• Issue 7: Dose Reconstructions Not 

Based on Best Available Science

– Concern was actually an error in calculation 

plus a difference in model codes used by 

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 involved 

omission of neutron doses in the NIOSH 

model

Resolution similar to Issue 7
Issues Resolution

• Issue 8: Incomplete Model Used for 

Exposure Assessments

– Concern was similar to Issue 7 and involved 

omission of neutron doses in the NIOSH 

model

Resolution similar to Issue 7
Issues Resolution

• Issue 9: Underestimate of Beta Dose

– Concern based on neglecting what is known 

as the Putzier Effect as well as omitting skin 

dose to those who were not betatron 

operators.

Putzier effect addressed and to be 

included in Appendix BB. Skin doses to 

other workers addressed in most recent 

NIOSH 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 moved 

by the WG to Appendix BB in 2010 and 

subsequently closed.
Summary of SEC 00105 Issues

• Issue 1: Closed

• Issue 2: Transferred 

to Appendix BB

• Issue 3: Transferred 

to Appendix BB

• Issue 4: Closed

• Issue 5: Closed

 Issue 6: Transferred 

to Appendix BB

 Issue 7: Transferred 

to Appendix BB

 Issue 8: Transferred 

to Appendix BB

 Issue 9: Transferred 

to Appendix BB

 Issue 10: Closed