TBD-6000 Work Group

Recommendations on

SEC Petition 00105 for

General Steel Industries

Paul L. Ziemer, WG Chair

June 20, 2012
Background information on

SEC Petition 00105

 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
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.”
Review of the SEC Petition

 Since the time of the ER and the 2009 review by SC&A, 

there has been a great deal of additional information 

obtained about the GSI site. This includes a substantial 

amount of information provided by the Co-petitioner (Dr 

McKeel) through FOIA requests and other means, as 

well as information from former workers and site experts.

 The NIOSH web site includes a number of white papers 

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 was 

issued in 2008, with most of its focus being on GSI 

(Appendix BB of TBD-6000 and SEC petition 00105)
 NIOSH will review its proposed models for 

reconstructing dose at GSI in support of its 

recommendation to deny an SEC class at GSI 

(Dave Allen)

 SC&A will provide a summary of its findings and 

position on the NIOSH dose models (Bob 

Anigstein)

 The Work Group recommendations will be 

presented (Paul Ziemer)

 The Co-petitioner will present his issues and 

concerns with the NIOSH proposal and WG 

recommendations (Dan McKeel)

Format for Today’s WG Report
Reports from 

NIOSH and SC&A
Time Line for Sources at GSI

 Jan. 1, 1953: Beginning of Operational Period

 1

st Betatron used to X ray uranium ingots

 2 radium radiography sources in use (500 mCi each)

 Mar. 7, 1962: Original AEC license application

 License granted April 18, 1962

 2 cobalt-60 sources (260 and 280 mCi) purchased 

May 5, 1962

 2

nd Betatron put into operation in 1963

 2 portable X-ray units obtained for radiography, 1963

 June 30, 1966: End of Operational Period
Resolution of SC&A Findings for 

the SEC Petition 00105 

Evaluation Report 

 Earlier this month all Board members 

received a copy of the Issues Resolution 

Matrix for the GSI petition with a delineation 

of WG actions taken on each item.

 We will not cover these in detail today, but 

the issues and their resolution will be 

summarized briefly
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 accepted this 

approach
 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 accepted NIOSH 

model for reconstructing dose.

Issues Resolution 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 accepted 

NIOSH model.

 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 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.

Issues Resolution
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 
Work Group Recommendation 

 The Work Group recommends that the Board 

not take action today 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.