TBD-6000 Work Gro

Report on

SEC Petition 00105 fo

General Steel Industri

Paul L. Ziemer, WG Chair

September 19, 2012
Time Line for Sources at 

 Jan. 1, 1953: Beginning of Operatio

Period 

 Mar. 7, 1962: Original AEC license 

application 

 June 30, 1966: End of Operational  July 1, 1966 – December 31, 1992: 

Residual Period 

 Jan. 1, 1993 – Dec. 31, 1993: DOE 

up Period 
Board Action at June 2012 Mee

 The Work Group recommended that the Board n

action on SEC Petition 00105, but rather defer auntil the next full Board meeting. 

 This recommendation resulted from WG discuss

June 14, 2012 relating to the residual period and desire of the Work Group to confirm the approprof the use of the TBD-6000 model of a uranium facility as a surrogate for the handling of uranium General Steel Industries. This applies both to thoperational period as well as to the residual peri

 The Board accepted this recommendation and t

SC&A to review the SD issue. 
SC&A Findings Reported to W

August 28, 2012

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

surrogate data does not strictly conform to the hof data.” Also, “appropriate adjustments were nto these surrogate data.” 

 SD Criterion on Exclusivity Constraints: “We do 

agree that the use of the surrogate data was strjustified.” 

 SD Criterion on Process Similarities: 

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

handling of uranium at GSI does not fulfill Cri

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

work sites for which NIOSH has collected infowere not evaluated.” 
SC&A Findings Reported to W

August 28, 2012 (continued

 SD Criterion on Temporal Considera

“...need to justify the application of tmeasurement to the entire period of operations at GSI.” 

Note: SC&A later concurred with the 

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

August 28, 2012 (continued

 SD Criterion on Plausibility: 

 Scientific Plausibility: “...the assumptio

the deposition abruptly stops at the enoperation, is neither plausible nor claimfavorable.” 

 Workplace Plausibility: “...the calculati

uranium concentrations described by Aand Glover does not meet the criterion workplace plausibility.” 
SC&A Recommendation

 Recommended that NIOSH develop a 

methodology for estimating uranium intakGSI that does not rely on surrogate data 

 Suggested a model that uses the expone

source-term depletion rate recommended OTIB-0070. For this approach, thecontamination levels on the floor of the OBetatron Building at the time of the 1993cleanup, together with the depletion rate varying hours of uranium handling operatGSI, could be used to calculate average uranium concentrations. 
Other Information of Import

 The co-petitioner provided documentation 

the GSI facilities were cleaned and presswashed during three different time period(1978-1981, 1984, and post-1985), all of predated the 1993 reference date for the proposed surface contamination level. 

 The WG agreed the back-calculating surf

contamination levels from the 1993 contamination data had to be ruled out. 
Further Considerations

 NIOSH provided its responses as to 

believed the surrogate data criteria wmet reasonable well by the handling uranium slugs. 

 Both NIOSH and SC&A felt that it wo

make sense to review the other data involving uranium metal handling toascertain whether there was “better” surrogate for the GSI situation. 
NIOSH and Petitioner Respon

to SG Issue

 NIOSH will review their position on t

Surrogate Data matter and indicate they propose to proceed to address matter and come to closure on the GSEC Petition. 

 The Co-Petitioners will provide their 

comments on these issues and any related matters. 
Work Group Recommendat

 The Work Group agreed to report th

information to the Board without a sprecommendation. 

 The Board can choose to ask NIOSH 

examine possible alternate surrogatsets (followed by SC&A review), or ichoose to act on the SEC petition on basis of the information currently on