Filename: McKeel_SC&A_5.30. 12-paper.doc

prove that there was no residual uranium anywhere on site except the Betatron
facilities. They simply confined their inspection to the Old and New Betatron buildings
where the decommissioned accelerators happened to be stored. That is, don't look,
don't find was the ORNL/DOE policy that has been evident at many facilities the co-
petitioner is familiar with. This is clearly DOE cost containment issue. Congress in 1997
was forced to relieve DOE of remediation activities under the FUSRAP and had to
transfer this function to the Army Corps of Engineers. DOE's FUSRAP function was
thereafter and today relegated to record keeping of previously remediated sites.

The overall NIOSH miscalculation of the total intake during the
residual period would be “to increase the intake from 0.932 to
24.97 dpm per calendar day.” This results in an error of 24.97
divided by 0.932 or 26.8-fold. It is clear this figure, if SC&A is
correct, indicates that NIOSH is unable to calculate and bound
intake doses with sufficient accuracy. NIOSH underestimated

the true dose by this factor (2680 percent)! And this error has
been factored in all 94% of GS! DR completed to date by
ORAUI/DCAS and DOL. Obviously, a significant number of
claims at GSI have been unduly denied based on seriously
flawed NIOSH scientific methodology.

Page 3. of 6

Section [6] External Exposure During Residual Period

1. The first sentence is an excellent example of the scientifically absurd lengths that
both NIOSH and SC&A have used an accepted as valid in order to deny approval of
SEC-00105. The total uranium contamination in the entire GS! building complex during
the residual period was basely solely on a single ORNL analysis of one industrial
vacuum cleaner. NIOSH apparently believes that any single datum (one data point) is
enough to bound residual period doses with sufficient accuracy.

Page 2 last sentence extends to page 3 of 6

2. SC&A concurred saying that “,.we concur that this is a claimant-favorable
assumption; however we observe that, for consistency with other time periods, the
exposure duration should be increased from 2,400 hours to 3,250 hours per year.”

(a) The co-petitioner feels strongly as a fellow scientist with an advanced degree
(M.D., Doctor of Medicine, University of Virginia 1966) with 200 published papers and
abstracts and 36 peer reviewed NIH biomedical grants in his professional C.V., and 31
years (23 tenured) at a major US medical school (Washington University in St. Louis)
that no one should accept such de minimis evidence of “sufficient accuracy,” the gold
standard test for one arm of the SEC test, regardless of the fact this term is still being


Filename: McKeel_SC&A_5.30.12-paper.doc

Petitioner Comments on SC&A Discussion Paper
Dated 5/30/12 titled Update of “Review of ‘Site Profiles
for Atomic Weapons Employers That Worked Uranium

and Thorium Metals - Appendix BB: General Steel

Industries,’ Battelle-TBD-6000, Appendix BB,”
Occupational Internal Dose
by
Daniel W. McKeel, Jr., M.D.
GSI SEG-00105 Co-Petitioner

June 1, 2012
To: All members of the Advisory Board on Radiation and Worker Health (ABRWH):
Comments and concerns are numbered to facilitate future reference to specific points.

Page 1 of 6
Section [1] Background

1. This is a 6 page report dated May 30, 2012, co-authored by David Allen and John
Mauro, that was posted to the DCAS website on May 31, 2012. Co-petitioner first
became aware of this report the same day (yesterday).

2, It appears from the Background section text on page 1 that this paper, in part,
addresses a very unfortunate, decidedly not claimant favorable oversight, with respect
to the already completed 92 page SC&A review of GSI Appendix BB dated April 2008.

>) B NIOSH Program Area - Radiation Dose Reconstruction ~ Advisory Board: Reports |

SC8&A Memo and Draft Report: Site Profiles for Atomic Weapons Employers That
Worked Uranium and Thorium Metals - Appendix BB: General Steel Industries
Battelle-TBD- 6000, Appendix BB, Rev. 0

Contract No. 200-2004-03805

Task Order No. 1

April 2008

J+ PDF 1.7 MB (92 pages)

This previous SC&A Appendix BB review is not mentioned, nor is it referenced on page
6 in the References section. This is a major omission. Why, then, if an SC&A review
had already been completed, was it necessary to (quoting the Background) “...review
Allen and Glover's internal exposure assessment during the period of AEC operations,
as well as the residual period” (end quote)?

3. The current report includes several Findings by SC&A that NIOSH seriously
underestimated internal occupational radiation dose in Appendix BB.


Filename: McKeel_SC&A_5.30.12-paper.doc

criteria and OCAS-IG-004 for NIOSH surrogate data criteria) as to site similarity to GSI.
In fact, the surrogate sites could not be similar enough because of the unique mission
and source terms at GSI. And as site, one real data point of Ur-238 dust mass and
exposure rate in 1989 that was 300 feet from the main plant is plainly insufficient to
bound the entire residual period. Claiming so is scientifically untenable and the Board
should reject this NIOSH and SC&A endorsed premise.

GSI Appendix BB needs to be revised as soon as possible.

Petitioner request for postponement of Board consideration of SEC-00105:
Based partly on these considerations, together with the fact that eight (8) recent

McKeel co-petitioner documents and this document have not been thoroughly
discussed by the work group or posted to Docket 140, | therefore suggest it is
premature, and will be patently claimant adverse, to bring the GS] SEC before the
full Board for a vote at the June 2012 Santa Fe meeting just 18 days from now,

/ request therefore that discussion of the GSI SEC-00105 should be
postponed until (1) all Appendix BB SC&A findings have been resolved by DCAS
and SC&A within the TBD-6000 work group, (2) that all 9 McKeel co-petitioner GSI
documents related to the TBD-6000 work group March 2012 meetings, and this
report, have been thoroughly discussed and the issues raised have been worked
through, and (3) that the GS! SEC-0015 issues related to the residual
contamination period have also been discussed and all pertinent issues have
been resolved with final agreement between all parties—the Board work group,
NIOSH and SC&A, Not until then SEC-00105 be ready to be brought before the full
ABRWH for a final vote.

Respectfully submitted,

(Dewel WM Feaf .

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

GSI SEC-00105 Co-petitioner

Phone; 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

U.S. Mail: P.O. Box 15, Van Buren, MO 63965
Physical street address: #7 CR 301A

=<


Filename: McKeel_SC&A_5.30, 12-paper.doc

advocate team claims this is impossible for NIOSH or SC&A to do with sufficient
accuracy because the physical and chemical parameters of MCW uranium metal
products sent to GSI is not known at all except as noted on the purchase orders that do
not define these parameters at all.

4. This analysis, by ignoring the ingestion component of the uranium intake
pathway during the GSI residual period, suggests this factor was not in play. Former
worker testimony suggests otherwise:

(a) There had been extensive cleanup and repurposing of both the Old (for
battery and parts storage) and New (for offices) Betatron facilities by the time ORNL
surveyed the Betatron facilities at GSI in the late 1980s,

(b) In contrast, during the residual period of the late 1960s when at least one
Betatron was still being used for NDT up until 1973 when active plant operations
ceased, the floors of the Old and New Betatron facilities were covered with dust several
inches deep, suggesting the total amount of uranium available for resuspension was far
greater than NIOSH and SC&A used in their 2006, 2007, 2008 and Appendix BB reports

or in this 2012 report. The surface (surficial) GSI uranium load during the residual

period has always been seriously underestimated.
(c) Similarly, uranium dust along the entire uranium transport pathway from

unloading dock to the Betatron facilities was available for resuspension. Betatron and
layout workers undoubtedly at their lunches in buildings 6 through 10 and in the
Betatron facilities, sitting on castings and on dust that probably did contain uranium.
Again, NIOSH cannot possibly accurately determine the true “surficial uranium load”
that existed either at the beginning of, or during, the GSI residual contamination period.

5. NIOSH has never produced any AEC technical reports about the Betatron NDT
work done for MCW at the GS! AWE site. Therefore the only source of information is
GSI former worker testimony, which is necessarily incomplete and conflicting because
48 year years have elapsed since the end of the covered period at GSI and human
memory fades and makes errors during such a long interval.

6. Certain contaminating daughter products and radioisotopes of thorium build up and
concentrate in the outer crust or “crop” areas of uranium ingots and dingots of the type
supplied to GSI by MCW. Some have termed this the Putzier effect, but there are
descriptions of the process under other terms in the uranium literature,

Page 2, continued

Section [5] Intakes Between Uranium Handling Operations—SC&A Observations
(pages 2 and 3)

1. The text of the first paragraph of this section notes that: “...an RF (resuspension
factor) of... might be low by about an order of magnitude.” (emphasis added)

SC&A notes the NIOSH low figure applied to a surrogate building that had undergone
decontamination and decommissioning, which did not apply to GSI. During 1 week in
the early 1990's ORNL/DOE surveyed and cleaned up some uranium dust from the Old

=5-


Filename: McKeel_SC&A_5.30.12-paper,doc

defined by NIOSH at the present time more than ten years after the start of EEQICPA
dose reconstruction and SEC compensation programs,

(b) That the average GSI worker work week should be changed from 46 to 65
hours, a 35% increase, was agreed to by consensus at a former worker meeting that
SC&A held in Collinsville, IL October 7, 2007. This numerical increase in average hours
worked per week should be a major factor affecting radiation exposures among the
large 3000 person SEC class covered by SEC-00105. NIOSH has accepted this
consensus determination. However, the consensus finding has not yet been
incorporated into a revised Appendix BB document.

2. The Old and New Betatron facilities had both been cleaned and extensively
repurposed under several different new owners by 1989 when the ORNL survey.

3. Former workers testified that much larger industrial vacuum units than the one ORNL
surveyed were used several times daily to clean the Old and New Betatron facility floors
at GSI. However, those vacuum cleaners could not clean up uranium bearing dust from
other surfaces such as the overhead cranes, the Betatron machines, the control room
Betatron operating console, and so forth.

Page 4 of 6

Section [7] Summary of SC&A Observations

Page 4 of 6

1. Bullet points listed in this section underscore 5 essential SC&A findings about
NIOSH methodology, that if resolved by the Board in favor of SC&A, could affect
assigned GSI radiation doses very significantly, as follows:
Bullet 1: Uranium intakes during handling “understated by a factor of 2.22"
Bullet 2: Assigned resuspension factor “inapplicable” to GSI, 10-fold too low
Bullet 3: Model discrepancy assumptions not correct, SC&A: “We recommend
modeling the deposition as persisting during the entire period of
uranium operations.”
Bullet 4: NIOSH purchase order based rationale during the residual period
should be increased from 337.5 h/y to 375 h/y.
Bullet 5: External exposures should be based on 3,250 hours per year

2, Two remedies could be taken by the Board in response to the above SC&A findings.

One approach would be to allow NIOSH to update their calculations to conform
to new SC&A calculations done 5 years after the original Allen and Glover 2007 paper.
Based on the discussions at the 3/15/12 and 3/28/12 TBD-6000 work group, held before
this SC&A report was released, Board and work group members might endorse that
NIOSH be granted the time to modify their models (Bullet 3) and assumptions and
calculations (other four Bullet points), thus ignoring the fact that these steps could have
and should have been taken anytime since 2007.


Filename: McKeel_SC&A_5.30.12-paper doc

NIOSH for the residual contamination period at GSI because the total mass of uranium
metal (dust primarily) at GS! along the entire transport pathway from unloading dock
through buildings 6 through 10, and on the well traveled path beside the long foundry, is
unknown and unknowable.

For that matter, for the record, former worker testimony indicates that uranium
metal was stored at GSI prior to its unloading and return to MCW to the Uranium
Division. No one knows the duration, the exact locations of the storage areas, or
whether in fact all of the MCW uranium metal pieces were ever actually returned to
MCW. No shipping manifests or receipts or Betatron “shot records” of such MCW
uranium materials are known to exist at the present time. Therefore, there is no
confirmatory evidence that the MCW purchase orders were either the complete series
or that they were fulfilled exactly as written. This is all in the realm of conjecture and
surmise; hard scientific evidence does not exist.

Page 6 of 6

Section [9] References

1. The previous SC&A review of Appendix BB is inexplicably not referenced, The entry
from the DCAS website showing the existence of this report on 6/1/12 is shown below:
y ¥ NIOSH Program Area - Radiation Dose Reconstruction ~ Advisory Board) Reports |

SC&A Memo and Draft Report: Site Profiles for Atomic Weapons Employers That

Worked Uranium and Thorium Is ~ ndi : General Steel Industries
lle-TBD- Appendix BB, Rev. 0

Contract No. 200-2004-03805

Task Order No. 1

April 2008

& PDF 1.7 MB (92 pages)

Co-petitioner's Summary Comment and request for postponement of a full Board
presentation and possible final vote for GSI SEC-00105.

Summary comment: This long overdue SC&A report that is oddly tasked and
timed is emblematic of my concerns that have been repeatedly expressed and largely
ignored during the GSI Board deliberations that began in 20085. | find the omission of the
seminal SC&A review of GSI Appendix BB in April 2008 of particular concern. Of most
concern is the present SC&A dose underestimations by NIOSH are first revealed very
late in the GSI deliberative process. Of ultimate concern, the TBD-6000 work group has
not yet scheduled a meeting to resolve the outstanding Appendix BB issues, including
those in the present SC&A review/discussion paper.

Intake Data for the Residual Period at GSI is entirely based on two NIOSH
technical documents that use surrogate data from a slug facility and from TIB-70, and a
single real radiation measurement from a small industrial vacuum in one room of the

Old Betatron building that was separated from the main building complex by 300 feet
measured. The use of these particular surrogate data was not justified (see Board

-10-


Filename: McKeel_SC&A_5.30.12-paper.doc

advocate team claims this is impossible for NIOSH or SC8&A to do with sufficient
accuracy because the physical and chemical parameters of MCW uranium metal
products sent to GSI is not known at all except as noted on the purchase orders that do
not define these parameters at all.

4. This analysis, by ignoring the ingestion component of the uranium intake
pathway during the GSI residual period, suggests this factor was not in play. Former
worker testimony suggests otherwise:

(a) There had been extensive cleanup and repurposing of both the Old (for
battery and parts storage) and New (for offices) Betatron facilities by the time ORNL
surveyed the Betatron facilities at GSI in the late 1980s,

(b) In contrast, during the residual period of the late 1960s when at least one
Betatron was still being used for NDT up until 1973 when active plant operations
ceased, the floors of the Old and New Betatron facilities were covered with dust several
inches deep, suggesting the total amount of uranium available for resuspension was far
greater than NIOSH and SC&A used in their 2006, 2007, 2008 and Appendix BB reports
or in this 2012 report. The surface (surficial) GSI uranium load during the residual

period has always been seriously underestimated.
(c) Similarly, uranium dust along the entire uranium transport pathway from

unloading dock to the Betatron facilities was available for resuspension. Betatron and
layout workers undoubtedly at their lunches in buildings 6 through 10 and in the
Betatron facilities, sitting on castings and on dust that probably did contain uranium.
Again, NIOSH cannot possibly accurately determine the true “surficial uranium load”
that existed either at the beginning of, or during, the GSI residual contamination period.

5. NIOSH has never produced any AEC technical reports about the Betatron NDT
work done for MCW at the GSI AWE site. Therefore the only source of information is

GSI former worker testimony, which is necessarily incomplete and conflicting because
48 year years have elapsed since the end of the covered period at GSI and human
memory fades and makes errors during such a long interval.

6. Certain contaminating daughter products and radioisotopes of thorium build up and
concentrate in the outer crust or “crop” areas of uranium ingots and dingots of the type
supplied to GSI by MCW. Some have termed this the Putzier effect, but there are
descriptions of the process under other terms in the uranium literature.

Page 2, continued

Section [5] Intakes Between Uranium Handling Operations—SC&A Observations
(pages 2 and 3)

1. The text of the first paragraph of this section notes that: “...an RF (resuspension
factor) of... might be low by about an order of magnitude.” (emphasis added)

SC&A notes the NIOSH low figure applied to a surrogate building that had undergone
decontamination and decommissioning, which did not apply to GSI. During 1 week in
the early 1990's ORNL/DOE surveyed and cleaned up some uranium dust from the Old

-§-


Filename; McKeel_SC&A_5.30.12-paper.doc

NIOSH for the residual contamination period at GS! because the total mass of uranium
metal (dust primarily) at GSI along the entire transport pathway from unloading dock
through buildings 6 through 10, and on the well traveled path beside the long foundry, is
unknown and unknowable.

For that matter, for the record, former worker testimony indicates that uranium
metal was stored at GSI prior to its unloading and return to MCW to the Uranium
Division. No one knows the duration, the exact locations of the storage areas, or
whether in fact all of the MCW uranium metal pieces were ever actually returned to
MCW. No shipping manifests or receipts or Betatron “shot records” of such MCW
uranium materials are known to exist at the present time. Therefore, there is no
confirmatory evidence that the MCW purchase orders were either the complete series
or that they were fulfilled exactly as written. This is all in the realm of conjecture and
surmise; hard scientific evidence does not exist.

Page 6 of 6

Section [9] References

1, The previous SC&A review of Appendix BB is inexplicably not referenced, The entry
from the DCAS website showing the existence of this report on 6/1/12 is shown below:
NIOSH Program Area — Radiatian Dose Reconstruction ~ Advisory Board’ Reports

0 and Draft Report: Site Profil ¢ Atomic Wi Nn: ers That
Worked Uranium and Thorium Metals - Appendix BB: General Steel Industries
Battelle-TBD- 6000, Appendix BB, Rev. 0

Contract No. 200-2004-03805

Task Order No. 1

April 2008

+ PDF 1.7 MB (92 pages)

Co-petitioner’s Summary Comment and request for postponement of a full Board
presentation and possible final vote for GSI SEC-00105.

Summary comment: This long overdue SC&A report that is oddly tasked and
timed is emblematic of my concerns that have been repeatedly expressed and largely
ignored during the GS! Board deliberations that began in 2005. | find the omission of the
seminal SC&A review of GSI Appendix BB in April 2008 of particular concern, Of most
concern is the present SC&A dose underestimations by NIOSH are first revealed very
late In the GSI deliberative process. Of ultimate concern, the TBD-6000 work group has
not yet scheduled a meeting to resolve the outstanding Appendix BB issues, including
those in the present SC&A review/discussion paper.

Intake Data for the Residual Period at GSI is entirely based on two NIOSH
technical documents that use surrogate data from a slug facility and from TIB-70, and a
single real radiation measurement from a small industrial vacuum in one room of the

Old Betatron building that was separated from the main building complex by 300 feet
measured. The use of these particular surrogate data was not justified (see Board

-10-


Filename: McKeel_SC&A_5.30.12-paper.doc

prove that there was no residual uranium anywhere on site except the Betatron
facilities. They simply confined their inspection to the Old and New Betatron buildings
where the decommissioned accelerators happened to be stored. That is, don’t look,
don't find was the ORNL/DOE policy that has been evident at many facilities the co-
petitioner is familiar with. This is clearly DOE cost containment issue. Congress in 1997
was forced to relieve DOE of remediation activities under the FUSRAP and had to
transfer this function to the Army Corps of Engineers. DOE's FUSRAP function was
thereafter and today relegated to record keeping of previously remediated sites.

The overall NIOSH miscalculation of the total intake during the
residual period would be “to increase the intake from 0.932 to
24.97 dpm per calendar day.” This results in an error of 24.97
divided by 0.932 or 26.8-fold. It is clear this figure, if SC&A is
correct, indicates that NIOSH is unable to calculate and bound
intake doses with sufficient accuracy. NIOSH underestimated

the true dose by this factor (2680 percent)! And this error has
been factored in all 94% of GSI DR completed to date by
ORAU/DCAS and DOL. Obviously, a significant number of
claims at GSI have been unduly denied based on seriously
flawed NIOSH scientific methodology.

Page 3 of 6
Section [6] External Exposure During Residual Period

1. The first sentence is an excellent example of the scientifically absurd lengths that
both NIOSH and SC&A have used an accepted as valid in order to deny approval of
SEC-00105. The total uranium contamination in the entire GS! building complex during

the residual period was basely solely on a single ORNL analysis of one industrial
vacuum cleaner. NIOSH apparently believes that any single datum (one data point) is

enough to bound residual period doses with sufficient accuracy.

Page 2 last sentence extends to page 3 of 6

2. SC&A concurred saying that “..we concur that this is a claimant-favorable
assumption; however we observe that, for consistency with other time periods, the
exposure duration should be increased from 2,400 hours to 3,250 hours per year.”

(a) The co-petitioner feels strongly as a fellow scientist with an advanced degree
(M.D., Doctor of Medicine, University of Virginia 1966) with 200 published papers and
abstracts and 36 peer reviewed NIH biomedical grants in his professional C.V., and 31
years (23 tenured) at a major US medical school (Washington University in St. Louis)
that no one should accept such de minimis evidence of “sufficient accuracy,” the gold
standard test for one arm of the SEC test, regardless of the fact this term is still being


Filename: McKeel_SC&A_5.30.12-paper,doc

Betatron facility only. ORNL found no uranium residuum in the New Betatron facility that
had been repurposed as offices. No radiological survey was done by ORNL of the main
GSI buildings where uranium was unloaded and traveled by crane and transfer rail cars
to the Old and New Betatron facilities (referred to hereafter as “the transport pathway’).
Thus, the NIOSH RF might be low by far more than 10-fold if all uranium dust
contamination throughout the GSI facility had been surveyed (ever) and recorded. The
fact is, ORNL/DOE and GSI on its own volition had never established uranium
contamination throughout the plant complex that was only demolished in 2012. Based
on this observation alone, NIOSH is incapable of bounding the total residual
uranium dust volume, hence the RF, both of which are unknown quantities that
cannot be established with any degree of certainty. Thus, SC&A has overlooked an
important finding that in and of itself justifies approving an SEC at GSI for the residual
contamination period. SC&A did identifying a dose underestimation of ten-fold in
possible uranium intakes ata time when NIOSH has claimed for years it bound intakes
of resuspended uranium at GS! with sufficient accuracy. Both the SC&A and petitioner
findings indicate this was not possible.

Page 3 of 6

The analysis continues and SC&A concludes by stating that TBD-6000 Rev 1 (Allen
2011) includes the same erroneous RF value as did Rev 0. Thus “/f the RF were
increased by a factor of 10, the airborne dust loading and the consequent intakes would
increase in the same proportion.” This error could and should have been recognized in
2008 in the first SC&A analyses of TBD-6000 Rev 0 and of Appendix BB at the
beginning of GSI dose reconstruction activities that had languished up until then.

Page 3 of 6 continued...

The following paragraph on the next page reports another NIOSH dose
underestimation by a factor of 2-fold or 100%. The error results from an
“inconsistency in the modeled intakes of uranium during the uranium handling
operations and in the accumulation of uranium deposited on floors and other surfaces.”
Again the analysis of this phenomenon is sestricted to Betatron operators, who
represent only a small fraction of the job categories of GSI personnel who handled
MCW uranium that resided at GSI for NDT (nondestructive testing) inspection purposes.
This entire analysis is based on the apparent false premise that the sole handlers of
uranium at GSI were Betatron operators, photography lab technicians who handled the
x-ray film and cassettes, neglecting chain men, crane operators, dock loaders, and
layout workers and probably others as well. This restricted analysis confined to a single
non-representative job category is claimant adverse, not claimant favorable, The
analyses in this section need to be modified.

Also, NIOSH needs to acknowledge that Betatron operators were not the only job
category for which doses need to be bounded during the residual period. Uranium dust
was undoubtedly spread all over the GSI complex all along the transport pathway from
unloading dock to the two Betatron facilities and back, as has been outlined. The
problem is, the full extent of residual uranium at GSI was never assessed. ORNL did not

==


Filename: McKeel_SC&A_5.30.12-paper.doc

Betatron facility only. ORNL found no uranium residuum in the New Betatron facility that
had been repurposed as offices. No radiological survey was done by ORNL of the main
GSI buildings where uranium was unloaded and traveled by crane and transfer rail cars
to the Old and New Betatron facilities (referred to hereafter as “the transport pathway’).
Thus, the NIOSH RF might be low by far more than 10-fold if all uranium dust
contamination throughout the GSI facility had been surveyed (ever) and recorded. The
fact is, ORNL/DOE and GSI on its own volition had never established uranium
contamination throughout the plant complex that was only demolished in 2012. Based
on this observation alone, NIOSH is incapable of bounding the total residual
uranium dust volume, hence the RF, both of which are unknown quantities that
cannot be established with any degree of certainty. Thus, SC&A has overlooked an

important finding that in and of itself justifies approving an SEC at GSI for the residual
contamination period. SC&A did identifying a dose underestimation of ten-fold in
possible uranium intakes at a time when NIOSH has claimed for years it bound intakes
of resuspended uranium at GSI with sufficient accuracy. Both the SC&A and petitioner
findings indicate this was not possible.

Page 3 of 6

The analysis continues and SC&A concludes by stating that TBD-6000 Rev 1 (Allen
2011) includes the same erroneous RF value as did Rev 0. Thus “/f the RF were
increased by a factor of 10, the airborne dust loading and the consequent intakes would
increase in the same proportion.” This error could and should have been recognized in
2008 in the first SC&A analyses of TBD-6000 Rev 0 and of Appendix BB at the
beginning of GSI dose reconstruction activities that had languished up until then.

Page 3 of 6 continued...

The following paragraph on the next page reports another NIOSH dose
underestimation by a factor of 2-fold or 100%. The error results from an
“inconsistency in the modeled intakes of uranium during the uranium handling
operations and in the accumulation of uranium deposited on floors and other surfaces."
Again the analysis of this phenomenon is restricted to Betatron operators, who
represent only a small fraction of the job categories of GSI personnel who handled
MCW uranium that resided at GSI for NDT (nondestructive testing) inspection purposes.
This entire analysis is based on the apparent false premise that the sole handlers of
uranium at GSI were Betatron operators, photography lab technicians who handled the
x-ray film and cassettes, neglecting chain men, crane operators, dock loaders, and
layout workers and probably others as well. This restricted analysis confined to a single
non-representative job category is claimant adverse, not claimant favorable. The
analyses in this section need to be modified.

Also, NIOSH needs to acknowledge that Betatron operators were not the only job
category for which doses need to be bounded during the residual period. Uranium dust
was undoubtedly spread all over the GSI complex all along the transport pathway from
unloading dock to the two Betatron facilities and back, as has been outlined. The
problem is, the full extent of residual uranium at GSI was never assessed. ORNL did not

-6-


Filename: McKeel_SC&A_5.30.12-paper doc

Or, as a contrasting much more claimant favorable approach, the Board could
conclude, as do the petitioners, based on all these findings of demonstrable severe

scientific flawed methodology and inaccurate results as identified by SC&A in 2012,
bolstered by many others addressed in other SC&A and co-petitioner reports (such as
the 8 reports delivered for the March work group meetings), that NIOSH is unable to
assign internal and external doses during the covered and the residual periods with
sufficient accuracy.

In the case of the residual period, NIOSH lacks sufficiently representative
monitoring data about the total uranium source term mass to calculate the total
uranium metal volume throughout the GSI building complex at the beginning of
or at any time during, the residual contamination period. A measurement by
ORNL of a single small vacuum cleaner in one repurposed Betatron building is
patently insufficient to make a plausible calculation. For this reason, the Board
should vote to approve SEC-00105.

Page 4 of 6

Section [8] Further SC&A Observations on Exposure Assessments for the
Residual Period

1. This very brief section is not well developed as to a scientific rationale. It appears to
be an afterthought.

2. The first paragraph suggests NIOSH “could avail itself’ of TIB-70 methodology in
order to “derive an exponential rate of decline from the midpoint of the ‘this period’
Jan. 1, 1962, to March 16, 1989, as follows:”

Page 5 of 6

The analysis of section [8] continues...

3. A formula is stipulated with the following annotation: “The first of the above equations
could be used to calculate the contamination level and hence the intake rate during
each year of the residual period.” The rationale for validating or introducing these
formulae is unstated and is unclear. SC&A is proposing new methodology, a function
the co-petitioner believes is the primary responsibility of NIOSH. TIB-70 has been
available for some time.

4. The rate of change of surficial contamination is apparently a TIB-70 constant, and
thus represents another use of unjustified surrogate data to substitute for a total lack of
actual monitoring data at GSI, The surrogate site is not shown to be similar to GSI.
Again, the proper way to view this suggestion, in the co-petitioner’s view, is that NIOSH
is unable to construct (“bound”) intake or external doses during the residual period.

5, Comment: This report deals mainly with internal occupational radiation dose
assessment, Petitioners also do not accept that external doses can be bounded by

-9-


loft

aolrich://7746531027/

Subj: McKeel: critique of SC&A 5.30.12 report, GSI! intakes update
Date: Saturday, June 2, 2012 10:07:32 AM

From: DanMcKeel2@aol.com

To: tmk1@cdc.gov, paz7@cdc.gov, josiebeach@charter.net, wimunn@aol.com, dka6@cdc.gov,
jfn2@cdc.gov, his8@cdc.gov, melius@nysliuna,org

ce: danmckeel2@aol.com, , eky1 @cde,gov

Dear Ted, Dr. Melius, and members of the TBD-6000 work group and NIOSH colleagues,
Attachment <McKeel_SC&A_5.30.12-paper.pdf> 170 KB

| am enclosing my response to the SC&A 5.30.12 Discussion paper updating their analysis of GS!
occupational intake doses. Ted Katz, please circulate this e-mail and the attachment to all members of
the ABRWH. Thank you.

| am also submitting my new report this morning to NIOSH Docket 140 (GSI) for posting on the DCAS
website.

The final section of my report is a formal request | repeat here to postpone the presentation of GSI
SEC-00105 to the full Board that meets in Santa Fe in 18 days. | consider the presentation to be
premature until the following tasks are accomplished, which they cannot possibly be in the short
time between now and June 20, From my report:

Petitioner request for postponement of Board consideration of SEC-00105: Based partly on these

considerations, together with the fact that eight (8) recent McKeel co-petitioner documents and this
document have not been thoroughly discussed by the work group or posted to Docket 140, |
therefore suggest it is premature, and will be patently claimant adverse, to bring the GS! SEC before
the full Board for a vote at the June 2012 Santa Fe meeting just 18 days from now.

fi sion of I SE 105 sho: until (1) all Appendix
BB SC8A findings have been resolved by DCAS and SC&A within the TBD-6000 work group, (2) that
all 9 McKeel co-petitioner GSI documents related to the TBD-6000 work group March 2012 meetings,
and this report, have been thoroughly discussed and the issues raised have been worked through,
and (3) that the GSI SEC-0015 issues related to the residual contamination period have also been
discussed and all pertinent issues have been resolved with final agreement between all parties—the
Board work group, NIOSH and SC&A. Not until then SEC-00105 be ready to be brought before the full
ABRWH for a final vote.

Sincerely -- Dan McKee} 6.2.12

Daniel W. McKeel, Jr., MD

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

US Mail: P.O. Box 15, Van Buren, MO 63965-0015

6/2/12 10:17 AM


Filename: McKeel|_SC&A_5.30.12-paper.doc

Petitioner Comments on SC&A Discussion Paper
Dated 5/30/12 titled Update of “Review of ‘Site Profiles
for Atomic Weapons Employers That Worked Uranium

and Thorium Metals - Appendix BB: General Steel

Industries,’ Battelle-TBD-6000, Appendix BB,”
Occupational Internal Dose
by
Daniel W, McKeel, Jr., M.D.
GSI SEC-00105 Co-Petitioner

June 1, 2012
To: All members of the Advisory Board on Radiation and Worker Health (ABRWH):
Comments and concerns are numbered to facilitate future reference to specific points.
Page 1 of 6
Section [1] Background
1, This is a 6 page report dated May 30, 2012, co-authored by David Allen and John
Mauro, that was posted to the DCAS website on May 31, 2012. Co-petitioner first
became aware of this report the same day (yesterday).
2. lt appears from the Background section text on page 1 that this paper, in part,
addresses a very unfortunate, decidedly not claimant favorable oversight, with respect

to the already completed 92 page SC&A review of GSI Appendix BB dated April 2008.
m NIOSH Program Area - Radiation Dose Reconstruction - Advisory Board: Reports |

SC&A Memo and Draft Report: Site Profiles for Atomic Weapons Employers That
Worked Uranium and Thorium Metals - ndix BB: General Industries
Battelle- TBD- 6000, Appendix BB, Rev. 0

Contract No. 200-2004-03805

Task Order No. 1

April 2008

J+ PDF 1.7 MB (92 pages)
This previous SC&A Appendix BB review is not mentioned, nor is it referenced on page
6 in the References section. This is a major omission. Why, then, if an SC&A review
had already been completed, was it necessary to (quoting the Background) “...review
Allen and Glover's internal exposure assessment during the period of AEC operations,
as well as the residual period” (end quote)?

3. The current report includes several Findings by SC&A that NIOSH seriously
underestimated internal occupational radiation dose in Appendix BB.


aolrich://774653 1027/

Subj: McKeel: critique of SC&A 5.30.12 report, GSI intakes update
Date: Saturday, June 2, 2012 10:07:32 AM
From: DanMcKeel2@aol.com

To: tmk1 @cdc.gov, paz7@cdc.gov, josiebeach@charter.net, wimunn@aol.com, dka6@cdc.gov,
jfn2@cdc.gov, his8@cdc.gov, melius®nysliuna.org
cc: danmckeel2@aol.com, eky1 @cdc.gov

Dear Ted, Dr. Melius, and members of the TBD-6000 work group and NIOSH colleagues,
Attachment <McKeel_SC&A_5.30.12-paper.pdf> 170 KB

lam enclosing my response to the SC&A 5.30.12 Discussion paper updating their analysis of GSI
occupational intake doses. Ted Katz, please circulate this e-mail and the attachment to all members of

the ABRWH. Thank you.

| am also submitting my new report this morning to NIOSH Docket 140 (GSI) for posting on the DCAS
website.

The final section of my report is a formal request | repeat here to postpone the presentation of GSI
SEC-00105 to the full Board that meets in Santa Fe in 18 days. | consider the presentation to be
premature until the following tasks are accomplished, which they cannot possibly be in the short
time between now and June 20. From my report:

Petitioner request for postponement of Board consideration of SEC-00105: Based partly on these
considerations, together with the fact that eight (8) recent McKeel co-petitioner documents and this
document have not been thoroughly discussed by the work group or posted to Docket 140, |
therefore suggest it is premature, and will be patently claimant adverse, to bring the GSI SEC before
the full Board for a vote at the June 2012 Santa Fe meeting just 18 days from now.

Lrequest therefore that discussion of the GSI SEC-00105 should be postponed until (1) all Appendix
BB SC&A findings have been resolved by DCAS and SC&A within the TBD-6000 work group, (2) that
all 9 McKee! co-petitioner GSI documents related to the TBD-6000 work group March 2012 meetings,
and this report, have been thoroughly discussed and the issues raised have been worked through,
and (3) that the GS! SEC-0015 issues related to the residual contamination period have also been
discussed and all pertinent issues have been resolved with final agreement between all parties—the
Board work group, NIOSH and SC&A. Not until then SEC-00105 be ready to be brought before the full
ABRWH for a final vote.

Sincerely - Dan McKeel 6.2.12

Daniel W. McKeel, Jr., MD

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

US Mail: P.O, Box 15, Van Buren, MO 63965-0015

lott 6/2/12 10:17 AM


Filename: McKeel|_SC&A_5 30, 12-paper.doc

criteria and OCAS-IG-004 for NIOSH surrogate data criteria) as to site similarity to GSI.
In fact, the surrogate sites could not be similar enough because of the unique mission
and source terms at GSI. And as site, one real data point of Ur-238 dust mass and
exposure rate in 1989 that was 300 feet from the main plant is plainly insufficient to
bound the entire residual period. Claiming so is scientifically untenable and the Board
should reject this NIOSH and SC&A endorsed premise.

GSI Appendix BB needs to be revised as soon as possible.

Petitioner request for postponement of Board consideration of SEC-00105:
Based partly on these considerations, together with the fact that eight (8) recent

McKeel co-petitioner documents and this document have not been thoroughly
discussed by the work group or posted to Docket 140, | therefore suggest it is
premature, and will be patently claimant adverse, to bring the GSI SEC before the
full Board for a vote at the June 2012 Santa Fe meeting just 18 days from now.

| request therefore that discussion of the GSI SEC-00105 should be
postponed until (1) all Appendix BB SC&A findings have been resolved by DCAS
and SC&A within the TBD-6000 work group, (2) that all 9 McKeel co-petitioner GSI
documents related to the TBD-6000 work group March 2012 meetings, and this
report, have been thoroughly discussed and the issues raised have been worked
through, and (3) that the GS] SEC-0015 issues related to the residual
contamination period have also been discussed and all pertinent issues have
been resolved with final agreement between all parties—the Board work group,
NIOSH and SC&A. Not until then SEC-00105 be ready to be brought before the full
ABRWH for a final vote.

Respectfully submitted,

Weel WM °hoof,

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

GS! SEC-00105 Co-petitioner

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

U.S, Mail: P.O. Box 15, Van Buren, MO 63965
Physical street address: #7 CR 301A

-11-


Filename: McKeel_SC&A_5.30.12-paper.doc

defined by NIOSH at the present time more than ten years after the start of EEQICPA
dose reconstruction and SEC compensation programs.

(b) That the average GSI worker work week should be changed from 46 to 65
hours, a 35% increase, was agreed to by consensus at a former worker meeting that
SC8A held in Collinsville, IL October 7, 2007. This numerical increase in average hours
worked per week should be a major factor affecting radiation exposures among the
large 3000 person SEC class covered by SEC-00105. NIOSH has accepted this
consensus determination. However, the consensus finding has not yet been
incorporated into a revised Appendix BB document.

2. The Old and New Betatron facilities had both been cleaned and extensively
repurposed under several different new owners by 1989 when the ORNL survey.

3. Former workers testified that much larger industrial vacuum units than the one ORNL
surveyed were used several times daily to clean the Old and New Betatron facility floors
at GSI. However, those vacuum cleaners could not clean up uranium bearing dust from
other surfaces such as the overhead cranes, the Betatron machines, the control room
Betatron operating console, and so forth.

Page 4 of 6
Section [7] Summary of SC&A Observations

Page 4 of 6

1. Bullet points listed in this section underscore 5 essential SC&A findings about
NIOSH methodology, that if resolved by the Board in favor of SC&A, could affect
assigned GS] radiation doses very significantly, as follows:
Bullet 1: Uranium intakes during handling “understated by a factor of 2.22”
Bullet 2: Assigned resuspension factor “inapplicable” to GSI, 10-fold too low
Bullet 3: Model discrepancy assumptions not correct, SC&A: “We recommend
modeling the deposition as persisting during the entire period of
uranium operations.”
Bullet 4; NIOSH purchase order based rationale during the residual period
should be increased from 337.5 h/y to 375 hly.
Bullet 5: External exposures should be based on 3,250 hours per year

2. Two remedies could be taken by the Board in response to the above SC&A findings.

One approach would be to allow NIOSH to update their calculations to conform
to new SC&A calculations done 5 years after the original Allen and Glover 2007 paper.
Based on the discussions at the 3/15/12 and 3/28/12 TBD-6000 work group, held before
this SC&A report was released, Board and work group members might endorse that
NIOSH be granted the time to modify their models (Bullet 3) and assumptions and
calculations (other four Bullet points), thus ignoring the fact that these steps could have
and should have been taken anytime since 2007.


Filename: McKeel_SC&A_5.30.12-paper.doc

Or, as a contrasting much more claimant favorable approach, the Board could
conclude, as do the petitioners, based on all these findings of demonstrable severe

scientific flawed methodology and inaccurate results as identified by SC&A in 2012,
bolstered by many others addressed in other SC&A and co-petitioner reports (such as
the 8 reports delivered for the March work group meetings), that NIOSH is unable to
assign internal and external doses during the covered and the residual periods with
sufficient accuracy.

In the case of the residual period, NIOSH lacks sufficiently representative
monitoring data about the total uranium source term mass to calculate the total
uranium metal volume throughout the GSI building complex at the beginning of
or at any time during, the residual contamination period. A measurement by
ORNL of a single small vacuum cleaner in one repurposed Betatron building is
patently insufficient to make a plausible calculation. For this reason, the Board
should vote to approve SEC-00105.

Page 4 of 6

Section [8] Further SC&A Observations on Exposure Assessments for the
Residual Period

1. This very brief section is not well developed as to a scientific rationale, It appears to
be an afterthought.

2. The first paragraph suggests NIOSH “could avail itself’ of TIB-70 methodology in
order to “derive an exponential rate of decline from the midpoint of the ‘this period’
Jan. 1, 1962, to March 16, 1989, as follows:

Page 5 of 6

The analysis of section [8] continues...

3. A formula is stipulated with the following annotation: “The first of the above equations
could be used to calculate the contamination level and hence the intake rate during
each year of the residual period.” The rationale for validating or introducing these
formulae is unstated and is unclear. SC&A is proposing new methodology, a function
the co-petitioner believes is the primary responsibility of NIOSH, TIB-70 has been
available for some time.

4. The rate of change of surficial contamination is apparently a TIB-70 constant, and
thus represents another use of unjustified surrogate data to substitute for a total lack of
actual monitoring data at GSI. The surrogate site is not shown to be similar to GSI.
Again, the proper way to view this suggestion, in the co-petitioner's view, is that NIOSH
is unable to construct (“bound”) intake or external doses during the residual period.

5. Comment: This report deals mainly with internal occupational radiation dose
assessment. Petitioners also do not accept that external doses can be bounded by

PS


Filename: McKee!_SC&A_5.30 12-paper doc

because there is no real uranium source term data known for 1953 through
February 1958. There is no monitoring data of any kind for this time period,

4. The same paragraph on page 2 also observes that Allen and Glover (2007) “ignore
the terms of the first MCW purchase order from 3/1-6/30/1958." The analysis is then
dropped. The value to the deliberative process of making an observation (finding) in the
absence of a suggested remedy escapes the co-petitioner.

Section [4] Intakes Between Uranium Handling Operations—DCAS Observations
(page 2 of 6)

1. The first paragraph on page 2 lays out the proposition that surface (aka surficial)
uranium becomes airborne and is resuspended between periods of handling.

2. Paragraph two describes affected workers and seems to concentrate only on
Betatron operators. GS! co-petitioner McKeel and GSI site expert have
for years pointed out, supported by worker affidavits, that a variety of people in other job
categories than Betatron Radiographer came near or into contact with MCW uranium
metal and “dust” resulting from the handling thereof. This information has been ignored
by DCAS and SC8&A in their technical reports, including this one. The present analysis
by both DCAS and SC&A Is thus very incomplete and represents a superficial, too
simplified, and thus scientifically indefensible exposition of the facts related to uranium
intakes at GSI.

3, What is also missing from this analysis is the recognition that 3,000 pound uranium
metal ingots and dingots with shaggy Mg-Hexafluoride “crusts” do not magically appear
a few feet distant from the Betatron beam port.

The uranium metal outer surface “crust” is rough and sheds with a different shear
force than pure uranium would do; the resulting ingot/dingot surface dust resuspends In
air differently than would the oxidation layer of freshly cleaved pure uranium. (Also see
note 5)

These uranium metal objects travel along a pathway thought the GSI building
complex that includes at least the following places and job categories of personnel who
handle the uranium metal:

a) Places in the pathway or uranium transport at GSI: the loading dock; storage
areas outside the Betatron facilities; foundry building path through buildings 6 through
10 into the New Betatron facility and the workers in those named buildings.

b) Job categories of persons who handle uranium metal: truck and train
unloaders, dock personnel, storage area handlers, crane operators, chain operators,
layout personnel, Betatron assistants and primary operators, photography technicians
who handled the x-ray film and cassettes that had directly contacted the uranium metal
from MCW (and had not been cleaned off), and clerks who handle the paperwork (shot
lists, NDT findings report, X-ray film) that accompanies the MCW uranium and almost
certainly became contaminated with surface dust.

Obviously NIOSH needed to calculate and bound intake and external uranium
doses for all workers who came into contact or were nearby the uranium. The GSI

eS


Filename: McKeel_SC&A_5.30.12-paper,doc

4. The petitioners have repeatedly pointed out for several years that Appendix BB
needs to be revised to reflect a number of SC&A Findings of underestimated dose to
GSI claimants. By now, more than 94% of GSI dose reconstructions have been
completed since June 2007 based primarily on TBD-6000 Rev 0 and Appendix BB Rev
0. At this point, DCAS and NIOSH have not resolved the previous Appendix BB SC&A
findings of record, and in fact no TBD-6000 work group meeting has been scheduled to
fully resolve them. This inordinate delay in revising Appendix BB is becoming more and
more unacceptable and claimant adverse.

5. This “Updated Review" is oddly tasked by the Designated Federal Official, Mr. Katz,
rather than by the chair of the TBD-6000, Paul Ziemer. That Board work group has
primary responsibility for assessing GS] Appendix BB and SEC-00105. | am unaware
where the DFO derives authority for tasking SC&A directly. The co-petitioner wonders
whether there is a precedent in ABRWH affairs where the Board technical contractor,
SC&A, is directly tasked by the DFO, a CDC employee? Why was tasking done in this
unusual way? Was there off record discussion with the Board that prompted this
tasking? If so, why was tasking not done on the record, when there was ample
opportunity to do so, during the back to back 3/15/12 and 3/28/12 TBD-6000 work group
meetings or at the 4/26/12 Board conference call meeting that preceded the June Santa
Fe full Board meeting?

6. The timing of this tasking is very odd as well, coming 5 full years after Appendix BB
Rev. 0 was first released in June 2007. The current SC&A review references the report
by David Allen and Sam Glover from 2007! Why was there such an inordinate delay?

Section [2] Intakes During Uranium Handling Operations—DCAS Assessment
(page 1)

1. It is erroneous to state that the “parent document” for Allen and Glover (2007) was
the 2011 Rev 1 version of TBD-6000 that was released 6/17/2011. Such an occurrence
would, of course, be an impossibility. The correct citation should have been Rev 0 of
TBD-6000 that was released 12/13/2006.

2. Co-petitioner McKeel has commented in previous DCAS and SC&A technical
document critiques that generic uranium slug facility intake data is not suitable as
surrogate data according to both Board and NIOSH criteria. The equivalence of a
surrogate site needs to be established, and this has not been done for the slug facility
and GSI. Former Director Elliott identified GS! as a truly “unique site,” John Mauro of
SC&A has echoed this statement, and the co-petitioner has amplified these sentiments
with abundant and compelling facts that illustrate many ways the slug facility and GSI
uranium operations, radiation sources, types of uranium metal processed, and other
parameters differed significantly between the slug and GSI sites. The slug facility did not
use a 24-25 Mev Betatron particle accelerators to irradiate and activate the uranium, as
one example. Another example is GSI processed MCW ingots and dingots as well as
recycled uranium metal and Betatron slices, none of which were the same as the
uranium source terms at the slug facility used for comparison in TBD-6000.

Bix


Filename: McKeel_SC&A_5,30,12-paper.doc

because there is no real uranium source term data known for 1953 through

February 1958. There is no monitoring data of any kind for this time period.

4. The same paragraph on page 2 also observes that Allen and Glover (2007) “ignore
the terms of the first MCW purchase order from 3/1-6/30/1958." The analysis is then
dropped. The value to the deliberative process of making an observation (finding) in the
absence of a suggested remedy escapes the co-petitioner.

Section [4] Intakes Between Uranium Handling Operations—DCAS Observations
(page 2 of 6)

1. The first paragraph on page 2 lays out the proposition that surface (aka surficial)
uranium becomes airborne and is resuspended between periods of handling,

2. Paragraph two describes affected workers and seems to concentrate only on
Betatron operators. GSI co-petitioner McKeel and GSI site expert , have
for years pointed out, supported by worker affidavits, that a variety of people in other job
categories than Betatron Radiographer came near or into contact with MCW uranium
metal and “dust” resulting from the handling thereof. This information has been ignored
by DCAS and SC&A in their technical reports, including this one. The present analysis
by both DCAS and SC&A is thus very incomplete and represents a superficial, too
simplified, and thus scientifically indefensible exposition of the facts related to uranium
intakes at GSI.

3, Whatis also missing from this analysis is the recognition that 3,000 pound uranium
metal ingots and dingots with shaggy Mg-Hexafluoride “crusts” do not magically appear
a few feet distant from the Betatron beam port.

The uranium metal outer surface “crust” is rough and sheds with a different shear
force than pure uranium would do; the resulting ingot/dingot surface dust resuspends in
air differently than would the oxidation layer of freshly cleaved pure uranium. (Also see
note 5)

These uranium metal objects travel along a pathway thought the GS! building
complex that includes at least the following places and job categories of personnel who
handle the uranium metal:

a) Places in the pathway or uranium transport at GSI: the loading dock; storage
areas outside the Betatron facilities; foundry building path through buildings 6 through
10 into the New Betatron facility and the workers in those named buildings.

b) Job categories of persons who handle uranium metal: truck and train
unloaders, dock personnel, storage area handlers, crane operators, chain operators,
layout personnel, Betatron assistants and primary operators, photography technicians
who handled the x-ray film and cassettes that had directly contacted the uranium metal
from MCW (and had not been cleaned off), and clerks who handle the paperwork (shot
lists, NDT findings report, X-ray film) that accompanies the MCW uranium and almost
certainly became contaminated with surface dust.

Obviously NIOSH needed to calculate and bound intake and external uranium
doses for all workers who came into contact or were nearby the uranium, The GSI

-4-


Filename: McKeel_SC&A_5.30,12-paper.doc

3. This section leaves out the very important point that MCW-AEC uranium related
purchase orders to GSI for 1953-1957 do not exist, apparently. Thus calculations of
intakes during those years is not based on actual, known uranium source term data.

a) Also needed to be emphasized is the fact the mix of uranium metal products,
that is the percentage and volume that was ingots, dingots, Betatron slices, and
perhaps other alloyed forms that contained trace transuranics (slightly enriched
uranium) or depleted or recycled uranium, all of which were produced at MCW-
Destrehan Street and Weldon Spring Uranium Feed Materials Plant by the MCW
Uranium Division during 1953-1966, is completely unknown.

b) All pertinent records except limited purchase orders from 1958 to 1966 have
been misplaced, hidden or destroyed at GSI, Mallinckrodt, the NRC and U.S. DOE.
shipped from MCW to GS] for Betatron x-irradiation NDT inspection is not known. Those
records would include shipping manifests to confirm the information on the purchase
orders was correct.

c) There is absolutely no confirmatory evidence that DCAS/NIOSH possesses all
of the MCW-AEC uranium purchase orders issued to GSI.

Section [3] Intakes During Uranium Handling Observations—SC&A Observations
(pages 1-2)

1. The first paragraph on page 1 mentions that “...Subsequent dose reconstructions
that were audited by SC&A." The co-petitioner has tried in vain to gain access to these
audited GSI DR reports, and currently has in process a request under FACA, to the
DFO to obtain redacted copies. The co-petitioner has not been able to ascertain who
tasked SC&A to “audit” these GSI cases, given that, according to the DFO, they have
not yet been reviewed by the DR subcommittee, which has primary responsibility for this
function.

2. The last sentence of the section on page 1 states, *...it has a significant impact on the
reconstruction of doses to the lung.” The fact is noted, but not commented upon further.

Page 2 of 6

3. The co-petitioner strenuously challenges the validity of the statement in the
first paragraph on page 2 that “...it is reasonable and claimant favorable to
assume this annual rate for the period January 1, 1953-June 30, 1958.” That
interpretation is adverse to client interests because it supports the untenable
NIOSH position that it can bound doses for this earliest 5.3 year portion of the
GSI covered period, thus supporting NIOSH recommendation that SEC-00105 be
denied. Extrapolating post March 1958 MCW purchase order Ur-238 source data
back to early years, without having the actual P.O.s, is scientifically indefensible;
it is a fabrication of data pure and simple and the flawed rationale should be
declared unacceptable to the Board.

Rather, the “best/good science” claimant favorable interpretation favored
by GSI co-petitioner McKeel would be that GS! SEC-00105 merits approval

ai


Filename; McKeel_SC&A._ 5.30. 12-paper.doc

4. The petitioners have repeatedly pointed out for several years that Appendix BB
needs to be revised to reflect a number of SC&A Findings of underestimated dose to
GSI claimants. By now, more than 94% of GSI dose reconstructions have been
completed since June 2007 based primarily on TBD-6000 Rev 0 and Appendix BB Rev
0. At this point, DCAS and NIOSH have not resolved the previous Appendix BB SC&A
findings of record, and in fact no TBD-6000 work group meeting has been scheduled to
fully resolve them. This inordinate delay in revising Appendix BB is becoming more and
more unacceptable and claimant adverse.

5. This “Updated Review" is oddly tasked by the Designated Federal Official, Mr. Katz,
rather than by the chair of the TBD-6000, Paul Ziemer. That Board work group has
primary responsibility for assessing GS! Appendix BB and SEC-00105. | am unaware
where the DFO derives authority for tasking SC&A directly. The co-petitioner wonders
whether there is a precedent in ABRWH affairs where the Board technical contractor,
SC&A, is directly tasked by the DFO, a CDC employee? Why was tasking done in this
unusual way? Was there off record discussion with the Board that prompted this
tasking? If so, why was tasking not done on the record, when there was ample
opportunity to do so, during the back to back 3/15/12 and 3/28/12 TBD-6000 work group
meetings or at the 4/26/12 Board conference call meeting that preceded the June Santa
Fe full Board meeting?

6, The timing of this tasking is very odd as well, coming 5 full years after Appendix BB
Rev. 0 was first released in June 2007. The current SC&A review references the report
by David Allen and Sam Glover from 2007! Why was there such an inordinate delay?

Section [2] Intakes During Uranium Handling Operations—DCAS Assessment
(page 1)

1. Itis erroneous to state that the “parent document" for Allen and Glover (2007) was
the 2011 Rev 1 version of TBD-6000 that was released 6/17/2011. Such an occurrence
would, of course, be an impossibility. The correct citation should have been Rev 0 of
TBD-6000 that was released 12/13/2006,

2. Co-petitioner McKeel has commented in previous DCAS and SC&A technical
document critiques that generic uranium slug facility intake data is not suitable as
surrogate data according ta both Board and NIOSH criteria. The equivalence of a
surrogate site needs to be established, and this has not been done for the slug facility
and GSI. Former Director Elliott identified GSI as a truly “unique site," John Mauro of
SC&A has echoed this statement, and the co-petitioner has amplified these sentiments
with abundant and compelling facts that illustrate many ways the slug facility and GSI
uranium operations, radiation sources, types of uranium metal processed, and other
parameters differed significantly between the slug and GSI sites. The slug facility did not
use a 24-25 Mev Betatron particle accelerators to irradiate and activate the uranium, as
one example. Another example is GSI processed MCW ingots and dingots as well as
recycled uranium metal and Betatron slices, none of which were the same as the
uranium source terms at the slug facility used for comparison in TBD-6000.

«fs


aolrich://774653 1027/

Subj: McKeel: critique of SC&A 5.30.12 report, GSI intakes update
Date: Saturday, June 2, 2012 10:07:32 AM

From: DanMcKeel2@aol.com

To: tmk1@cdc.gov, paz7@cdc.gov, josiebeach@charter.net, wimunn@aol.com, dkaG@cdc.gov,
jfn2@cde.gov, his8@cde.gov, melius@nysliuna.org

cc: danmckeel2@aol.corn F , eky] @cde.gov

Dear Ted, Dr. Melius, and members of the TBD-6000 work group and NIOSH colleagues,
Attachment <McKeel_SC&A_5,30.12-paper.pdf> 170 KB

1am enclosing my response to the SC&A 5.30.12 Discussion paper updating their analysis of GSI
occupational intake doses. Ted Katz, please circulate this e-mail and the attachment to all members of
the ABRWH. Thank you.

| am also submitting my new report this morning to NIOSH Docket 140 (GSI) for posting on the DCAS
website.

The final section of my report is a formal request | repeat here to postpone the presentation of GS!
SEC-00105 to the full Board that meets in Santa Fe in 18 days. | consider the presentation to be
premature until the following tasks are accomplished, which they cannot possibly be in the short
time between now and June 20. From my report:

etitioner request for ty m i i -00105: Based partly on these

considerations, together with the fact that eight (8) recent McKee! co-petitioner documents and this
document have not been thoroughly discussed by the work group or posted to Docket 140, }
therefore suggest it is premature, and will be patently claimant adverse, to bring the GSI SEC before
the full Board for a vote at the June 2012 Santa Fe meeting just 18 days from now.

jon of the should ned until (1) all Appendix
BB SC&A findings have been resolved by DCAS and SC&A within the TBD-6000 work group, (2) that
all 9 McKeel co-petitioner GSI documents related to the TBD-6000 work group March 2012 meetings,
and this report, have been thoroughly discussed and the issues raised have been worked through,
and (3) that the GSI SEC-0015 issues related to the residual contamination period have also been
discussed and all pertinent issues have been resolved with final agreement between all parties—the
Board work group, NIOSH and SC&A. Not until then SEC-00105 be ready to be brought before the full
ABRWH for a final vote.

Sincerely -- Dan McKeel 6.2.12

Daniel W. McKeel, Jr., MD

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

US Mail: P.O. Box 15, Van Buren, MO 63965-0015

toll 6/2/12 10:17 AM


Filename: McKeel_ SC&A_5,30.12-paper doc

3. This section leaves out the very important point that MCW-AEC uranium related
purchase orders to GSI for 1953-1957 do not exist, apparently. Thus calculations of
intakes during those years is not based on actual, known uranium source term data.

a) Also needed to be emphasized is the fact the mix of uranium metal products,
that is the percentage and volume that was ingots, dingots, Betatron slices, and
perhaps other alloyed forms that contained trace transuranics (slightly enriched
uranium) or depleted or recycled uranium, all of which were produced at MCW-
Destrehan Street and Weldon Spring Uranium Feed Materials Plant by the MCW
Uranium Division during 1953-1966, is completely unknown.

b) All pertinent records except limited purchase orders from 1958 to 1966 have
been misplaced, hidden or destroyed at GSI, Mallinckrodt, the NRC and U.S. DOE.
shipped from MCW to GSI for Betatron x-irradiation NDT inspection is not known. Those
records would include shipping manifests to confirm the information on the purchase
orders was correct.

c) There is absolutely no confirmatory evidence that DCAS/NIOSH possesses all
of the MCW-AEC uranium purchase orders issued to GSI.

Section [3] Intakes During Uranium Handling Observations—SC&A Observations
(pages 1-2)

1. The first paragraph on page 1 mentions that "...Subsequent dose reconstructions
that were audited by SC&A.” The co-petitioner has tried in vain to gain access to these
audited GSI DR reports, and currently has in process a request under FACA, to the
DFO to obtain redacted copies, The co-petitioner has not been able to ascertain who
tasked SC&A to “audit” these GSI cases, given that, according to the DFO, they have
not yet been reviewed by the DR subcommittee, which has primary responsibility for this
function.

2. The last sentence of the section on page 1 states, “...it has a significant impact on the
reconstruction of doses to the lung.” The fact is noted, but not commented upon further.

Page 2 of 6

3. The co-petitioner strenuously challenges the validity of the statement in the
first paragraph on page 2 that “...it is reasonable and claimant favorable to
assume this annual rate for the period January 1, 1953-June 30, 1958.” That
interpretation is adverse to client interests because it supports the untenable
NIOSH position that it can bound doses for this earliest 5.3 year portion of the
GSI covered period, thus supporting NIOSH recommendation that SEC-00105 be
denied. Extrapolating post March 1958 MCW purchase order Ur-238 source data
back to early years, without having the actual P.O.s, is scientifically indefensible;
it is a fabrication of data pure and simple and the flawed rationale should be
declared unacceptable to the Board.

Rather, the “best/good science” claimant favorable interpretation favored
by GSI co-petitioner McKeel would be that GSI SEC-00105 merits approval

oR