McKeel part 2 response to Allen ADD-3 March 2012

(c) Co-petitioner McKeel reminds NIOSH, the Board and SC&A that the
advocacy group he founded, the Southern Illinois Nuclear Energy Workers (SINEW),
with the assistance and support of SimmonsCooper law firm of East Alton, IL and
SINEW member and SimmonsCooper staff attorney obtained
notarized releases for dosimetry and medical information from almost all living GSI
Betatron employees and presented them to both Landauer and NIOSH in order to
facilitate petitioner review of the complete Landauer GSI program 2084 film badge data
set.

Sinew and McKeel have repeatedly pointed out that radiation monitoring data

and similar types of data that does not directly affect living persons) from deceased
individuals is not protected by the Privacy Act of 1974. In spite of this background,
NIOSH and HHS OGC refused to honor these legally valid worker releases that were
obtained by an experienced and well respected Illinois litigating law firm. We believed
this position was wrong then and McKeel still holds this view. The GSI petitioners were
denied legal due process by HHS, OGC, NIOSH and OCAS with respect to seeing the
complete set of Landauer program 2084 GSI film badges.

(d) Most importantly, and the point addressed in this response to Allen
Addendum 3, is that both NIOSH and SC&A have analyzed the GSI weekly film
badge data in a claimant adverse way. First, as pointed out previously, the complete
film badge data set has not been presented to McKeel and the SEC-00105 petitioners.
Second, the complete GSI film badge data set with all values above “M” listed has not
been presented to the Board. The previous film badge white papers stopped short of
this necessary step.

SC&A produced “evidence” that the very highest GSI film badge readings had
been retracted by GSI workers through their supervisors. This “evidence” was
established by conversations and activities that were conducted in private, a non-
transparent process, between two SC&A employees, one of whom formerly worked for
SC8&A. Co-petitioner McKeel and former workers have strongly challenged the validity of
these retractions and have never had access to the unredacted letters to see the names
of persons involved, all of whom except one we believe to be deceased and whose



McKeel part 2 response to Allen ADD-3 March 2012

McKeel believes the standard should be +10 to 20% agreement between model values
and real world measured data. Formal uncertainty analysis has not been applied to
these GSI new exposure models. Allen and SC&A admit the MCNPx code base is
changing constantly, and the results achieved vary with the “build (version)” of the
software. Modeled New Betatron and Layout worker external photon, neutron and beta
values by NIOSH and SC&A changed dramatically between 2007/8 and 2012 as shown
in a Summary dose Table McKeel presented at the 3/15/12 TBD-6000 work group
meeting in Cincinnati. Layout worker values should increase in the new scenario where
workers doing layout work on hot castings in the tunnel just outside the steel ribbon roll
up door of the New Betatron building that was known to exist in 1966 as a now
established fact.

Comment on Residual Radiation from the Betatron in the OFF condition:

Petitioners strongly disagree with David Allen's assertion that “magnetic
interference” is the most parsimonious explanation for the residual radiation from the
Betatron cone. was a paid consultant for NIOSH when he issued his
report that documented the residual radiation phenomenon. At the 3/15/12 TBD-6000
meeting McKeel offered new : interview information gathered by
that Scheutz had removed a Betatron donut tube within seconds of being shut off and
had again measured and confirmed the presence of residual photon radiation. Ergo, the
residual radiation emanated from the Betatron itself. This second test could easily be
verified by a call to Scheutz from Mr. Allen. Co-petitioner McKeel suggests following the
already established procedure where SC&A participates in the interview and McKeel
and are allowed to be silent observers to the conversation.

Reducing the residual Betatron radiation factor to 5 mR/hr is not claimant
favorable, nor is the rationale for doing so scientifically defensible in McKeel’s view. At
the 3/15/12 work group meeting McKeel offered added Betatron operator testimony and
showed photos that show the backs of operators were spaced only 1 to 2 feet away
from the Betatron cone during set up procedures for shots. The inverse square law
therefore suggests that the actual residual radiation based on the original Scheutz



MckKeel part 2 response to Allen ADD-3 March 2012

enhance readability of the report. Many pages were too dark to read. Only 21 records on this
weekly 4/25/1966 Landauer report were “M.” Twelve other values ranged between 10-2470 mrem.

The next illustration is a page of 5/29/1966 film badge data from the same GSI
clerk, the first to handle weekly film badges in the New Betatron facility. This page
differs from the 4/25/1966 page in one important respect, a value of 300 mrem appears
for another worker. This appears therefore to be a relatively newly incurred dose that
was not listed on the 4/25/66 report from a month earlier. It implies an incident has been
recorded.

Details such as this need to recognized, analyzed across time in detail, and
brought before the TBD-6000 work group and the full ABRWH before they attempt to
make a final recommendation on SEC-00105 or revise Appendix BB.

photon dose values of 2470 mrem (top yellow dot in red square) and
below values of 20 mrem and 40 mrem (red dots in yellow squares)
that also appeared on the same workers 4/25/66 film badge report.
The new value of 300 mrem appears within the second lighter band
from the top (also marked by a red circular dot in a yellow square.
This image has been enlarged approximately 2-fold. One can also
see 5 values of 10 mrem and 6 clear “M” values.

Further Comments on Part 1 McKeel Comments:

-5-


McKeel part 2 response to Allen ADD-3 March 2012

names therefore should not have been redacted. We hold our position despite DR.
Ziemer acting a “referee” in this matter between SC8&A and the petitioners and workers.
At the 3/15 meeting McKeel recounted that one of the “highest dose” workers (DB)
recently again disputed that he had never been informed he had a high badge reading.
Below is an example of film badge data that GSI Betatron clerk Don Piper

obtained as part of his NIOSH case file. The weekly data printout pages each contained
33 records and in the tow examples shown from 4/25/66 and 5/29/66 there was 12 and
13 values ranging between 10 and 2470 mrem with only 21 records showing an “M” for
the Cumulative photon total:

.LEGEND. The Landauer report page has been slightly enlarged, name column has been omitted
at left, and one lighter bar has been outlined in yellow (with dot) to indicate a Cumulative dose of
2470 photons had been received. Page image has been changed from black lettering to white to

-4-



McKeel part 2 response to Allen ADD-3 March 2012

PART 2. NEW MCKEEL INFORMATION

New Betatron Exposure Scenario For Layout Workers:
Former Betatron operator offered the following testimony to Betatron
operator who forwarded the e-mail to McKeel on 3/25/12:
[ affidavit here]

reminded me that, on a hot castings, layout
work was done on transfer car of the casting, in the
Betatron tunnel, by workmen getting the casting ready
to bring it in to the Betatron for radiograph.”

«

The import of this new information is profound because of the close
proximity to the New Betatron shooting room, and because virtually all

Betatron operators filled in as Layout workers in order to get overtime pay.

Interpretation of Landauer Program 2084 (GSI) Film Badge Data:

The petitioner's views are the GS! Program 2084 film badge data has not been
presented in entirety to the Board or the petitioners. The badge data pedigree is open to
challenge as to destroyed and blackened badges, availability for only 3 of the 13 year
covered period, absence of badged females, and badge data is confined only to 89
Betatron employees who included operators, clerks, photographers and others out of a
total work force of 3,000 (to 4,000 by some estimates, exact figures are not available).
There is uncertainty about “control badges” and .CTL001 badges, what they
represented and how these values should be used.

The pre-3/15/12 NIOSH and SC&A model values and the Allen Addendum 3
recalculated NIOSH model values still do not agree within acceptable limits with real
data or themselves. NIOSH and SC&A appear to accept 2-fold agreement, whereas

-7-


Dragon, Karen E. (CDC/NIOSHIEID)

From: DanMcKeel2@aol.com

Sent: Monday, May 21, 2012 4:25 PM

To: NIOSH Docket Office (CDC)

Ce: danmckeel2@aol.com

Subject: Docket 140 GSI: PETITIONER DOCUMENTS 3-8
Attachments: McKeel_ADD3.pdf+.zip

Dear NIOSH Docket 140 (GSI) Office:

Attachment: DOCUMENT 3: <McKeel_ADD3.pdf> (288 KB)

Attachment: DOCUMENT 4: <MCNPx_memo_3.22.12.pdf> (73 KB)

Attachment: DOCUMENT 5 <McKeel_Comment_Allen2_ADFD3.pdf> (477 KB)
=> Attachment: DOCUMENT 6: <McKeel_Part2_Allen_ADD-3.pdf> (411 KB)

Attachment: DOCUMENT 7: <McKeel_Comment_3.28.12.pdf> (76 KB)

‘Attachment: DOCUMENT 8: <DWM_GSI_email_Katz_4.26.12.pdf> (36 KB)

Please accept this submission to GSI Docket 140 for posting on the DCAS website. There are 6 small PDF files
representing 6 separate communications from myself to the TBD-6000 work group and full Board.

Descriptions:

MCKEEL PETITIONER DOCUMENT 3. FILE: McKeel_ADD3.pdf (288 KB), dated March 19, 2012. Covers unresolved
SC8&A "SEC Issues" 5 and 6 as well as more realistic and time period-accurate surrogate concrete induced radioisotope
activation data by the GSI Betatrons.

MCKEEL PETITIONER DOCUMENT 4. FILE: MCNPx_memo_3.22.12.paf (76 KB); McKeel Email dated 3/22/12 to Ted
Katz to distribute to TBD-6000 work group, DCAS and SC8&A containing John Ramspott information about MCNPx with
Dan McKeel comments.

MCKEEL PETITIONER DOCUMENT 5. FILE: McKeel_Comment_Allen2_ADFD3.pdf (480 KB) dated 3/23/12. 2 page
initial reaction to mistaken calculations in David Allen's Addendum 3 action items white paper following the 3/15/12 TBD-
6000 work group meeting.

MCKEEL PETITIONER DOCUMENT 6. FILE: McKeel_Part2_Allen_ADD-3.paf (411 KB) dated 3/26/12. A critically
important document showing that layout worker photon and neutron external radiation doses should be increased based
on new knowledge they worked immediately outside the GSI new Betatron shooting room shielded only by a thin steel
ribbon door that offered scant protection to them.

MCKEEL PETITIONER DOCUMENT 7. FILE: McKeel_Comment_3.28. 12.pdf (80 KB) dated 3/28/12. McKeel read into
the record of the 3.28.12 TBD-6000 work group meeting. Very important rebuttal to the DCAS and SC&A presentations at
the same meeting.

MCKEEL PETITIONER DOCUMENT 8: FILE (PDF of email): DWM_GSI_email_Katz_4.26.12.pdf (40 KB) dated 4/26/1 2.
McKeel added comments about the TBD-6000 work group 2 Yes (Ziemer, Munn), 1 No (Josie Beach, 1st ten years of
covered period) recommendation on 3/28/12 to support NIOSH and to deny the GSI SEC-001085 petition for the entire
covered period of 1953-June 1966.

Sincerely,
-- Dan McKeel May 21, 2012

Daniel W. McKeel, Jr., MD
GSI SEC-00105 co-petitioner
Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com
US Mail: P.O. Box 15, Van Buren, MO 63965-0015



McKeel part 2 response to Allen ADD-3 March 2012

B. Five of 6 SEC-00105 listed by SC&A have not been resolved. An updated
SEC issues matrix is awaiting from SC&A (as of 3/25/12 when this is written).

C. There is no real measured 1953-1966 covered period neutron data for either
Betatron unit that is based on appropriate film badges or “gold standard” Bonner
spheres. Extant GSI badge program 2084 Landauer reports lack neutron dose values.
MCNPX models for neutron exposures at GSI cannot therefore be ascertained with
sufficient accuracy for GSI. There is no coworker data or surrogate data that is plausible
and scientifically defensible for the GSI AWE site.

D. There is no valid real surrogate or coworker inhalation and ingestion intake
data for GSI during the covered period. ORNL cleanup data cannot be reliably back
extrapolated to the covered period. Urine bioassay data for uranium do not exist for GSI
during any part of the covered period.

E. NIOSH cannot possibly define with sufficient accuracy the uranium source
term at GSI 1953-66: (a) Purchase orders do not exist for 1953-58 and cannot be
“guesstimated” (not scientifically acceptable); (b) The mix MCW and Weldon Spring
sent to GSI cannot be defined as Destrehan Street or Weldon Spring plant, as to
Betatron slice versus ingot versus dingot; (c) Weldon Spring produced ingots and
dingots composed of uranium alloys that have not been accounted for: (d) Zero film
badge data exists for the years when MCW Uranium Division uranium shipments to GSI
were highest, that is 1962; (e) MCW uranium shipments to GSI sharply declined during
4964-66 when scant film badge data was available for a tiny subset of the total GSI
work force. (f) Mr. Allen's and DCAS assertion that uranium usage at GSI was highest

during 1964-66 was wrong (incorrect factually) as proven by Tables in Appendix BB.

Respectfully submitted,

'

Daniel W. McKeel, Jr., M.D.
GSI SEC-00105 co-petitioner

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

Mail: P.O. Box 15, Van Buren, MO 63965
Street address: #7 CR 301A

-10-



McKeel part 2 response to Allen ADD-3 March 2012

observation should be 60 mRV/hr rather than 15 mR/hr (1.5 ft. versus 6 feet distance).
Allen’s 5 mR/hr residual radiation factor is therefore even more claimant adverse.

Also, Allen in his Addendum 3 restates that dose reconstructors would use the
higher dose assigned to layout persons during real world dose reconstructions.
However, there is no quarantee that such practice always has been followed in the past
or necessarily will be followed in the future for dose reconstruction “reworks.” Such
occurrences surely will follow once a revised Appendix BB has been issued and many
denied GSI claims are requested to be reopened.

McKeel Summary Comment on David Allen’s Addendum 3 to his January 2012
Betatron operations white paper.

David Allen and DCAS have not addressed their Path Forward For GSI goals
as | have tried to point out at the 3/15/12 TBD-6000 work group and in my follow up
comments, These concerns are amplified in Parts 1 and 2 of this response to David
Allen's Addendum 3, where many points put on the record by McKeel, former workers
giving eye witness testimony, and site expert _ have been ignored.

A. There is no new exposure model or OCAS-IG-003 complaint external dose
calculations for the following known and now proven GSI radiation sources:

(1) The GSI Old Betatron 24 Mev x-ray unit,

(2) For either 250 KVP industrial x-ray portable source that had no
safety locks,

(3) No new exposure model for Radium-226 and the fishpole
technique in the roofless 6 building radiography facility that we have now
conclusively shown lacked steel plate and extra concrete shielding before
Jun/July 1962, when the Ra-226 were used dating back to at least January 29,
1957 inside this facility.

(4) No new exposure model for the GSI owned 10 to 20 curie iridium-
192 NDT source that was used in the late 1950s according to worker affidavit

inside the 6 Bldg. radiography facility minus the steel plates and extra concrete
block wall shielding.



McKeel part 2 response to Allen ADD-3 March 2012

Part 1 of the McKeel SEC-00105 co-petitioner comments dealt with two
perceived errors made by David Allen in his Addendum 3 to the January 2012 Betatron
Operations white paper issued after the 3/15/12 TBD-6000 work group meeting.

The first error cited in McKeel Part 1 in his response to Allen Addendum 3.

The door at the end of the GSI New Betatron railroad track tunnel was a ribbon
steel roll up door rather than a double leaf metal door with no lead shield. | have two
further comments on that matter: (1) Mr. Allen and DCAS need to modify the MCNPx
parameters accordingly. This will be difficult, because the exact metallic composition of
the ribbon steel roll up doors and the double leaf doors are not known. (2) the precise
input parameters, including the programmed HVL (half value layer) used to model the
steel roll up ribbon door should be stated explicitly when results of the modified
exposure model are made known.

The second error cited in McKeel Part 1 in his response to Allen Addendum 3.

The Allen analysis of racked film badges failed to acknowledge or model
corrected information on the location of racked Betatron employee film badges in the
GSI New Betatron facility. Specifically, McKeel offered a new worker affidavit on 3/15/12
that showed there were two locations, not one, as DCAS and SC&A stated. Location (2)
was farther away from the console control room, and the Betatron shooting room, than
was location (1) modeled by Allen in Addendum 3.

Below is new former Betatron employee affidavit about the exact location of the
second film badge rack, the composition of the GSI New Betatron building in the rack
area, and the presence of an x-ray pass-through port in the console room:

[ affidavit #1 here]

Dr. Dan—The darkroom —- contro! room wall in the NEW
BETATRON, according to - and Myself,

. , was two concrete blocks wide. Between the control
room door to the hallway, and the end of the shooting console, was
a FILM TRANSFER BOX-mounted in the wall. This box,
accommodated 14 x 17 film cassettes. Film was transferred from
the box, to both the control room and darkroom. | estimate the
transfer box to be about 20 inches high and 16 inches wide. We
estimated wall thickness to be 16 to 18 inches thick. Film was
transferred, directly to the darkroom, and received, through the
transfer box.

-6-



McKeel part 2 response to Allen ADD-3 March 2012

reminded me that, on a hot castings, layout work
was done on transfer car of the casting, in the Betatron
tunnel, by workmen getting the casting ready to bring it in to
the Betatron for radiograph.” - 3/24/12 to

This person ( ») is well known to the Board, to NIOSH and to SC&A as he
was an active participant in the Anigstein-SC&A satellite meeting that NIOSH attended ,
recorded and summarized held in Collinsville, IL on October 9, 2007. The new Layout
worker information for the New Betatron tunnel activity did not emerge until 3/24/12.

[2] Interpretation of McKeel-Landauer Program 2084 (GSI) Film Badge Data:

The co-petitioner’s analysis of his interactions with Landauer and the GSI
film badge data he has obtained differs in important aspects from the NIOSH and
SC&A experience with Landauer GSI film badge data. McKeel has reviewed his total

experience from 2006, when he first learned that GSI film badge records existed at
Landauer, to the present time. Several facts have emerged about these critical data that
by now have become central issues in NIOSH revising Appendix BB Rev 0 of June
2007 (issued before the GSI film badge data was obtained or analyzed by NIOSH and
SC&A).

(a) The complete GSI film badge data set has not been shared with the
petitioners. Dr. on behalf of the TBD-6000/6001 and Appendix BB work
group asked McKeel to share his quarterly therefore limited Landauer film badge data
set he had obtained 13 months before NIOSH obtained its weekly GSI film badge data
set. McKeel declined unless and until SC&A and/or NIOSH reciprocated and shared
their weekly film badge data, which they were not willing to do even though McKeel was
the one who brought the existence of any GSI film badge attention to NIOSH and
SC8&A.

(b) There has not been a complete explication of all details of the NIOSH-SC&A
film badge weekly data set in which each and every badge reading above “M"” is set
forth. This needs to be done in the name of transparency of the NIOSH dose
reconstruction and SEC evaluation process.



McKeel part 2 response to Allen ADD-3 March 2012

Daniel McKeel GSI Co-Petitioner Comments, Part 2:

David Allen January 2012 Betatron White Paper, ADDENDUM 3:
New Betatron Scenario For Layout Worker Exposures;
Interpretation of McKeel-Landauer Program 2084 (GSI) Film Badge Data
(March 25, 2012)
by

Daniel W. McKeel, Jr.
Introduction

Highlights of McKeel Part 2 Comments on Allen Addendum 3:

[1] New Exposure Scenario For New Betatron Layout Workers:
| would flag this information as urgent highest priority for members
of the TBD-6000 work group to read. New affidavit information has

emerged from a living Betatron operator that some Betatron shots were
performed while Layout men were working on “hot castings” on transfer
rail cars in the tunnel area, between the shooting room and Building 10, of
the New Betatron facility at General Steel Industries. In this real world
exposure scenario, Layout workers working on castings would be located
just outside of a thin ribbon steel roll-up door that closed off the railroad
tunnel in 1964 to 1966. Even without modeling, it is obvious this scenario
would expose Layout team workers to much higher x-ray and neutron
photon doses compared to Layout workers who would be at least 100 to
200 feet away (or more) in Building 10 that was separated from the New
Betatron Building by a causeway (railroad tunnel and break area). The
importance of NIOSH modeling this scenario cannot be overemphasized.
NIOSH should arrange to have an interview with this worker if that should
be felt necessary in order to verify this testimony, which is replicated
below. SC&A should participate and McKeel asks to be a silent observer.