Page 23 clearly identifies the 7 GSI "Non-compliances”

10196
OVEREXPOSURE UNREPCRTED BECAUSE OF UNRELIABLE READINGS :

GENERAL TESTING COMPANY, LISBGNs CHEC
1 PAGE, ATOMIC ENERGY CLEARING HOUSE, 12{20}, PAGE 351 (MAY Loy 1966)

GARORSY FILM BADGE SERVICE SHOWED A 3.5-REM EXPOSURE FOR ONE INDIVIDUAL, WHILE THE CGNTROL BADGES
FOR FOUR INOLVIDUALS SHOWED NC EXPOSURE. THIS WAS NOT REPORTED BECAUSE IT WAS THOUGHT IN ERRCR.

Here is the “earlier” McKeel FOIA reference to GSI’s Non-compliance ..... 1963 :

1/13/15, 6:03 AM

© MLO93431298 - Letter to Eber R. Price from Gordon McMillin Regarding a Registered Letter, Directed to Mr.
C. P. Whitehead, Calling Attention to Noncompliance on Certain Regulations. (4 page(s), 1/18/1963)

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Page 2 of 2



Page 23 clearly identifies the 7 GS! "Non-compliances" 1/13/15,

From: john ramspott ;

To: Daniel McKeel <_

Cc: john ramspott oe i

Subject: Page 23 clearly identifies the 7 GSI "Non-compliances"
Date: Mon, Jan 12, 2015 5:50 pm

Page 23 below identifies the 7 GSI"Non-compliances” (1970 )

PAGE = 23

41534 @cONTINUEDS
INTO POSITION BOTH OISCOVERED SOURCE WAS EXPOSED. A RECEIVED 3 REM WHOLE BODY, 600 REM RIGHT
HANO AND FOREARM, AND 45 REM TO LEFT HAND AND FOREARM.  CPERATOR A AND THE RADLOGRAPHER IN
CHARGE WERE SUSPENDED FOR 4 DAYS WITHOUT PAY,

AVAILABILITY - USAEC PUBLIC DOCUMENT ROOM. LTL7 H STs+ WASHINGTON, 0. C. 20565 (25 CENTS/ PAGE)

*INCIDENTs EXPOSURE + FAILURE, OPERATOR ERROR + SURVEY, RADIATION + PERSONNEL EXPOSURE, RADIATION * #INCLDENTy
HUMAN ERROR + #CPERATING EXPERT EKCE

37698
ELECTRIC BOAT OI VISION CITED BY AEC FOR OVEREXPOSURE OF RAOTOGRAPHY PERSONNEL
GENERAL DYNAMICS CORP.y ELECTRIC BOAT DIVISION, GROTON, CGNN.
L PAGE, ATOMIC ENERGY CLEARING MOUSE, 15137}, PAGE 17 ISEPTEMBER 15, 1969)

hoe BECAUSE OF A MISUNDERSTOOD ORAL REPLY A RADIOGRAPHER AND HELPER WERE OVEREXPOSED TO AN IRIDIUM-192
SOURCE, THE SOURCE WAS CONSIDERED TO BE IN ITS SHIELOED CONTAINER, AND THE SOURCE TUBE ASSEMBLY
WAS DISCONNECTED WHEN IT WAS CISCOVEREO THAT THE SOURCE WAS NOT SEATED IN ITS SHIELD. IF THE :
FOLLOWUP SURVEY HAO TAKEN PLACE, THE EXPOSURE COULO HAVE BEEN PREVENTED.

SFATLURE, QPERATOR ERROR ¢ *PERSONNEL EXPOSURE, RADIATION © *SHIFLNING + IRIOIUM

61907
OVEREXPOSURE OF EMPLOYEE AT GENERAL CYNAMICS

GENERAL DYNAMICS, ELECTRIC BOAT DIVISION, GROTON, CONNECTICUT

4 PACES, LETTER - GENERAL DYNAMICS TO GIVISION GF COMPLIANCE (AEC) - DECEMBER 22, 1970

CONSTRUCTION WAS PROCEEDING NORMALLY. THE SOURCE MAS CRANKED IMs ANO THE STOREO LIGHT WAS
OBSERVED BY 2 WORKERS. ONE OF THEN THEN PROCEEDED [NTO THE REACTOR COMPARTMENT TO CHECK THE
CAMERA, HIS SURVEY MEYER WAS SET ON THE X-1 SCALE INSTEAD OF THE X-10. WHEN PLACED AT THE SIDE
OF THE CAMERA, IT PEGGED, GUT THE MAN FAILED TO RECOGNIZE THIS AS ABNORMAL, HIS EXPOSURE MAS
S455 NR. CHECKS OF EQUIPMENT INDICATED IT WORKED PROPERLY. WORKERS INSTRUCTED IN PROPER USE OF
SURVEY EQUIPMENT.

RADIOGRAPHIC OPERTIONS TN THE REACTOR CCMPARTMENT OF A SUBMARINE UNDER CONSTRUCTION MAS PROCEEDING NORMALLY.
AVAILABILITY DATA

INCIDENT, EXPOSURE + FAILURE, EQUIPMENT + SFAILURE, OPERATOR ERROR + SOURCE, RADIATION + *PERSONNEL EXPOSURE,
RAOTATION

60008
GENERAL STEEL INDUSTRIES CITED FOR NONCOMPLIANCE

U.S. ATOMIC ENERGY COMMISSION, DEVISION CF COMPLIANCE

2 PAGES, LETTER - DIVISION OF COMPLIANCE (AEC? TO GENERAL STEEL INDUSTRIES - DECEMBER 18, 1970

GENERAL STEEL INDUSTRIES WAS CITED FOR 7 ITEMS OF NONCOMPLIANCE. SOURCE STORAGE ROOHS WERE NOT
PROPERLY PCSTEC. COPY OF LICENSE WAS NOT POSTED. A SOURCE WAS STORED IN AN UNRESTRICTED ARES.
UTILIZATTON LOGS WERE INCOMPLETE. RADIOGRAPHIC OPERATIONS WERE CONDUCTED WITHOUT A CALTGRATED
SURVEY INSTRUMENT. SURVEY RECORDS WERE NOT ALWAYS NATNTAINED. RESULTS OF ANNUAL TESTS OF
RADIOGRAPHERS WERE NOY AVATLAGLE,

AVAILABILITY ~ USAEC PUBLIC DOCUMENT ROOM, L717 H STs» WASHINGTON, 0.C. 20545 125 CENTS/PAGE, $1.00-MIN.
CHARGED

*FATLUREs ADMINISTRATIVE CONTROL + SCURCE, RADIATION + FAILURE, OPERATOR ERROR * INFORMATION RETRIEVAL +
INSTRUMENT CALIBRATION * *RECOROS 4 RACLATION EXPOSURE, RECORD KEEPING * SURVEY, RADIATION

41638
CORRECTIVE STEPS TAKEN BY GENERAL STEEL INDUSTRY

GENERAL STEEL INDUSTRIES, INC., TLLINOTS *

2 PAGES, LETTER ~ GENERAL STEEL INDUSTRIES TO OLVISION OF COMPLIANCE (AEC) - JANUARY 7, 1971

THE FOLLOMING STEPS WERE TAKEN TO CORRECT NON-COMPLIANCES. NEW RAOIATION SIGNS WERE OBTAINED.
COPY DF LICENSE WAS POSTED. SOURCES ARE STORED IN A RESTRICTED ROOM, NEW UTILIZATION LOGS WERE
PREPARED. NEW SURVEY METERS WERE PURCHASED AND CALIGRATEO. RECORDS ARE KEPT TO ASSURE THAT THE
SOURCES ARE SHTELOED BEFORE GEING STORED. RADIGGRAPHERS WILL BE TESTED ANNUALLY AND TESTS
FILED.

SADMINTSTRATIVE CONTROL ¢ SOURCE, RADIATION + TESTING * INSTRUMENT CALIBRATION + *RADLATION SAFETY ANC CONTROL

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Dragon, Karen E.(CDC/NIOSHIEID) a _

From: Daniel McKee! < _

Sent: Thursday, January 29, 2015 10:56 AM _

To: Katz, Ted (CDC/NIOSH/OD); pl.ziemeri __ _ ;NIOSH Docket Office (CDC)

Ce: ee 7 ycom 2 “~~ Dragon, Karen E. (CDC/NIOSH/EID);

—~. ‘melius|_ _ Hinnefeld, Stuart L. (CDC/NIOSH/DCAS);

jmauro._ \Sundif, David S. (CDC/NIOSH/DCAS); Allen, David
(CDC/NIOSH/DCAS)

Subject: GSI new evidence of AEC (NRC) Radiation Safety Noncompliance

Attachments: JWR_email_1.12.15gsi7noComply.pdf

Dear Dr. Ziemer, Ted Katz and NIOSH Docket 140 (GSI)

Ted, please circulate this Memo to all members of the TBD-6000 work group and to the Board prior to the TBD-6000 WG
meeting scheduled for Feb. 5, 2015.

NIOSH Docket 140 Office: Please post this Memo to Docket 140 (GSI) on the DCAS website. The suggested title is as
follows:

“Daniel W. McKeel, Jr., MD and John W. Ramspott, “Evidence of GSI Noncompliance with AEC radiation safety
regulations 1963-1971' (Jan. 29, 2015).

Daniel W. McKeel, Jr., MD and John W. Ramspott memo to the
TBD-6000 work group and full ABRWH Board, January 29, 2015;
to be posted on the DCAS website under Docket 140 (GSI)

[1] John W. Ramspott, GSI site expert, provided the following reference to Dan McKeel, GS! SEC-105 co-petitioner, on Monday,
January 12, 2015, as follows:

Reference source document #1 -- Abstracts from ORNL-NSIC-53 (1972) (information from John Ramspott to DW McKee! Jr on
January 14, 2015. See attached PDF.

suromc)
R. L. Scott Operations Division
R. B. Gallaher Reactor Division

‘TILE OF THEREFOR

RADIOGRAPHY INCIDENTS AND OVEREXPOSURES

ORNL-NSIC-53

PusuicaTion YEAR

1972, 12-1

7 ("Part time” radiographer comments)
ewrace
23 (GSI Inc. Non-compliance documentation)

[303 citations (brief abstracts) relating to Radiography NDT incidents 1957-1975]

Page 23

Abstract 60008 - December 18, 1970 AEC letter to GSI 7 noncompliance matters:

1. Source storage rooms were not properly posted

2. Copy of license was not posted

3. A source was stored in an unrestricted area

4. Utilization logs were incomplete

5. Radiographic operations were conducted without a calibrated survey instrument
6. Survey records were not always maintained

7. Results of annual tests of radiographers were not available

Abstract 61438 - January 7, 1971 GSI remedial actions taken:

1. New radiation signs were obtained

2. Copy of license was posted

3. Sources are stored in a restricted room

4. New utilization logs were prepared

5. New survey meters were purchased and calibrated

6. Records are kept to assure that the sources are shielded before being stored

1



7. Radiographers will be tested annually and tests filed

[2] Dan McKeel had provided the initial GSI AEC citation for noncompliance on 4 matters as part of the 1,016 of material released in
NRC FOIA 2010-0012:

Reference source document #2:

+ ML093431298 — Letter to Eber R. Price from Gordon McMillin Regarding a Registered Letter, Directed to C.R. Whitehead, Calling
Attention to Noncompliance on Certain Regulations. (4 pages, 1/18/1963)

Comment by Daniel W. McKeel, Jr., M.D.

These two references considered together provide persuasive evidence that the radiation safety program at General Stee! Industries
(GSI) had serious shortcomings during the entire 1963 to 1966 AEC contract period and beyond (to at least 1971) when the AEC was
still reviewing their isotope NDT radiography By-Products materials license.

SC&A, NIOSH and some members of the TBD-6000 WG, including the chair Paul Ziemer former Board chair, argued to the full Board
that the GSI radiation safety program and film badge programs were robust and in generally good shape after 1963 as a major reason
the GSI SEC should be denied. SC&A even argued it would be unreasonable to question GSI official statements about the
results of a film badge program earlier than 1964 and about the adequacy of safety program implementation. These
arguments were delivered before and just preceding the final SEC 00105 9 to 8 vote to deny on December 11, 2012 in Knoxville, TN.
We believe these arguments were not evidence-based and were, in fact, substantially untrue as we argue in the GSI AR that is under
review: (a) The Neton [Hinnefeld/Craig Yoder-Landauer] memo of December 2013 showed that NIOSH was abandoning
use of GSI film badge data because of the way control badge background was handled; (b) no evidence other than a
letter from a GSI administrator and 1 film badge report supported a pre-1964 film badge program.

The GSI expert/SEC petitioner team, argues, as we did in the pending GSI SEC-105 Administrative Review (AR) submitted
4/17/2013 to HHS, that the GSI AEC By-Products materials license starting in 1962 materially misrepresented the true facts. The 11
AEC noncompliance citations we review above, n=4 in 1963 and N=7 more in 1970, show extremely lax radiation safety failures
continuing at GSI from 1963 through at least early 1971, when GSI claims the latter set of 7 noncompliance citations were remedied.

However, note there is no follow up corroboration on the result of subsequent AEC inspections to show the claimed remedies was
actually carried. It will be important, in our opinion, for NIOSH and the WG/SC&A to both follow up and obtain the seminal reports that
are abstracted above (ABSTRACTS 60008 AND 61348 OF ORNL-NSIC-53).

Certain GSI noncompliance remedial actions are particularly troubling. Note, for example, that GS! does not attempt to telt AEC.
that the allegations of noncompliance were untrue. In fact. the actions taken ALL suggest strongly the noncompliance items cited
WERE true and needed to be fixed. There was no evidence that GSI radiographers were being tested annually as the GSI license
documents and renewals all the way through amendment 8 that extended the license to beyond plant closure date in 1974. Mr.
Ramspott and Dan McKeel and numerous worker affidavits confirm these “annual tests" for radiation proficiency and safety practices as
radiographers were pure mythology — they did NOT happen.

All evidence points to GSI radiographer formal classes with written tests occurred only once, ever. The GSI AEC licenses 1962-74
repeatedly refer to annual proficiency and radiation safety tests and classes taking place at GSI for which there is no other
evidence.

In addition, it wasn’t a matter of simply recalibrating existing survey instruments at GSI; the remedy “purchase new ones and calibrate
them,” strongly indicates the survey instruments named in the numerous GSI Co-60 license renewals beginning in 1962 were false and
spurious. Apparently some survey instruments AEC considered to be mandatory were NOT there.

One AEC 1970 noncompliance item states “a source was stored in an unrestricted area.” The remedy states the source was place in a
“restricted area,” but where was this area at GSI. All drawings indicate the large Co-60 source (80 curies licensed at GSI IL in 1968)
was stored in the Betatron building shooting room. GSI workers, on the other hand, rolling the big Co-60 source over to the metallurgy
lab.

The Betatron shooting room was “restricted” only during active shots when the 24-25 Mev x-ray/neutron containing-beam was ON. At
other times, many GS! workers wandered in and out of the Betatron facilities. Why was this allowed to happen? Because, everyone
assumed incorrectly due to the very poor radiation safety practices at GSI, that the Betatron shooting area was completely safe with
beam off. They had never been told about particle accelerator components or accelerator bombarded concrete (see Carroll) references
becoming chronically activated producing secondary unstable radionuclides that delivered radiation exposure even at “beam off"
periods of time. The GSI SEC team produced persuasive evidence a number of radionuclides resulted that exhibited half-
lives of weeks, months and years.

“Survey records were not always maintained” is a pretty vague statement without some quantitation as to what specific records are
being referred to and what percentage were not found. If the percentage was 2% missing, that fact might be overlooked. If the
percentage was 95%, then remedial action must be more active and oversight must be increased and refocused. Evidence the GSI site
expert and SEC petitioner team has presented since 2005 suggests the records deficits at GSI were massive rather than trivial.

2



None of the relevant GS! shot logs, instrument calibration or leak test results, radiation safety tests or test results or scores, were
ever looked for or found by the Board, SC&A or NIOSH.

In summary, due diligence requires the two ORNL-NSIC-53 (1972) full abstract 60008 and 61348 reports that apply to the GS! site

be scrutinized in detail by the full Board and TBD-6000 WG including NIOSH and SC&A. We plan to use this new evidence to

strengthen our arguments to HHS and others that SEC-00105 should be approved for GSI from October 1, 1952 through the end of
1993. That is, the Board recommendation on 12/11/12 to deny SEC-105 should be reversed.

Thank you for your consideration.
Sincerely,

~ Dan McKeel and John W. Ramspott 1.29.2015
Danie! W. McKeel, Jr., MD

GSI, Dow and TCC SEC co-petitioner
Cofounder SINEW.