From: DanMcKeel2@aol.com 

To: NIOSH Docket Office (CDC) 

Cc: danmckeel2@aol.com 

Subject: Docket 140 (GSI) submission 

Attachments: Katz_DM2PLZemailCirc_5.17.11.pdf 

July 22, 2011 

NIOSH Docket Office: 

Please accept the attached 94K PDF file <Katz_DM2PLZemailCirc#290AB3.pdf> for DOCKET 140. It is 

most important that the NIOSH schedule for producing ten new exposure models applicable to the 

General Steel Industries EEOICPA AWE site be placed on the public docket record. 

The material submitted relates to a proposed schedule by NIOSH to rewrite 10 sets of "exposure 

models" based on aspects of dose reconstruction ("DR") at the General Steel Industries ("GSI") site in 

Granite City, IL. NIOSH proposes releasing these new exposure models in two batches. Four (4) will be 

released on July 29, 2011, and the remaining six (6) exposure models will be released on December 

30, 2011. A TBD-6000 work group meeting to consider the first four models has been scheduled for 

September 17, 2011, after the full Board next meets. It is clear that my predictions at the Oct. 10, 2010 

TBD-6000 work group meeting that the David Allen NIOSH "path forward" for GSI would take many 

months and probably years to implement was quite on target. I believed than and feel now even more 

strongly this is high claimant adversarial. The Board could vote now, at any time, to reverse NIOSH's' 

recommendation to deny SEC-00105. That would be the fair and equitable path forward for the Board 

to take with respect to GSI claimants. 

In an accompanying letter I wrote to Dr. Paul Ziemer, head of the TBD-6000 work group, the 

acknowledgment by NIOSH that all new exposure models (as opposed to real data measurements) 

must be developed is a tacit admission that NIOSH is unable, using methods in Appendix BB Rev 0 to 

TBD-6000, to reconstruct doses at GSI with sufficient accuracy. The need to develop ten new exposure 

models is a further admission by NIOSH that its evaluation of SEC-00105 for GSI was inaccurate in 

stating that NIOSH was able to reconstruct doses at GSI for all class members with sufficient accuracy 

as called for by the Act. 

By now, more than 94% of GSI DR have been completed using the scientifically flawed June 2007 

Appendix BB. Most or all of these denied claims will have to be reopened and new DR completed at a 

huge cost using the 10 new exposure models. That assumes that the Advisory Board on Radiation and 

Worker Health ("ABRWH") and SC&A, their scientific contractor, find the models to be scientifically 

robust and valid. That is a major assumption that is open to serious question and challenge. 

Worse, the GSI 83.13 SEC-00105 approval has been delayed for more than 3 years based on 

NIOSH's recommendation to deny. This recommendation was obviously premature and needs to be 

revised and reversed. There is no monitoring data of any kind for the first 10 years of the covered 

period from 1953 to 1966. 

Thank you for your consideration of my request. 

Sincerely,

 -- Dan McKeel, GSI SEC-00105 co-petitioner 

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 
aolrich://204983281031/ 

Subj: RE: General Steel Industries (msg 2), reply 

Date: Tuesday, May 17, 2011 10:44:42 AM 

From: tmk1@cdc.gov 

To: DanMcKeel2@aol.com 

Hi Dan. I’ve circulated your letter per your request. --Ted 

From: DanMcKeel2@aol.com [mailto:DanMcKeel2@aol.com] 

Sent: Tuesday, May 17, 2011 10:29 AM
 

To: pl.ziemer@comcast.net; Katz, Ted (CDC/NIOSH/OD)
 

Cc: crnfld@hotmail.com; Hinnefeld, Stuart L. (CDC/NIOSH/OD); melius@nysliuna.org; DanMcKeel2@aol.com; 

Allen, David (CDC/NIOSH/OD); jmauro@scainc.com; Robert_Stephan@mail.house.gov
 

Subject: Re: General Steel Industries (msg 2), reply
 

Dear Paul and Ted, 

I request that Ted Katz please circulate this message in its entirety to all members of the TBD-6000 

work group and to the full Board. 

The schedule below is exactly what David Allen said at the 10/12/11 TBD-6000 meeting would not 

happen. I observed that the Allen Path Forward white paper of October 2010 was (a) an explicit 

admission that NIOSH was unable to reconstruct doses at GSI with sufficient accuracy, (b) that the 

work implied would take months or years to complete. Mr. Allen stated that NIOSH would not have to 

start from scratch, but the listing below confirms that all of these parameters involved in dose 

reconstruction at GSI indeed will be developed anew. I reiterated that on this basis of (a) and (b), 

the TBD-6000 work group should recommend approval of the GSI SEC-105 SEC immediately because 

of NIOSH acknowledged its inability to sustain the main conclusion of the SEC-105 evaluation report. 

That is, to deny the SEC based on NIOSH's then current ability (in 2008) to accurately reconstruct 

doses. That capability is obviously not true 2.5 years later in May 2011. The NIOSH admissions of 

October 2010 in the Allen white paper coupled with this admission that all new DR models at GSI will 

have to be developed (a mere promise at this point) underscore the validity of my continuing 

concern. Besides those facts, John Mauro argued persuasively that SC&A and the Board would be 

unable to avoid recommending an SEC for GSI for the first 10 years of the covered period, as NIOSH 

lacks any significant data for that period on source terms (MCW purchase orders), personal 

monitoring, or area monitoring. I have argued that the film badge data at GSI is limited and not 

representative (89 of 3,000 people in the work force), pertains to one job only (radiographer), 

applies only to males, and is for only 3 of the 13 years of AEC uranium work that took place during 

the covered period at GSI. Besides that, there is an unresolved significant difference between the 

NIOSH and SC&A models, and an even greater disparity between those models and the RS Landauer 

film badge readings for a portion of GSI male radiographers (Magnaflux operators were not badged). 

I cannot see, in light of the ambitious and in my opinion unrealistic schedule presented below by 

NIOSH, how Stuart Hinnefeld can assert, as he did to me, that NIOSH has no plans to revise its 

evaluation of SEC-105, nor does it plan to revise Appendix BB, until all of the GSI issues/Findings 

identified by SC&A are resolved with NIOSH. Resolution of those issues/Findings, including mine as 

SEC co-petitioner, have disappeared from everyone's radar. The TBD-6000 work group could be 

working on those issues now. I do not believe this is the scientifically acceptable, as many of SC&A's 

findings are valid and have not been resolved, at least to my satisfaction. I called for the TBD-6000 

to take up the SC&A Findings and resolve them before NIOSH promises to deliver its Allen Path 

Forward work group products in late July. That will be 9 months after GSI matters were discussed 

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last October 12. 

Again, I mention that Rachel Leiton and DOL have stated in writing that they are unwilling to reopen 

denied GSI claims until the TBD-6000 work group completes its work, and certifies our 

advocate/claimant group's many new pieces of GSI DR information as valid. For example, even though 

SC&A established by consensus that the average work week at GSI was 65 hours rather than 46 hours 

as claimed in Appendix BB, and Mr. Allen at NIOSH has also acknowledged this fact, the new hours per 

week work figure cannot be used as formal DR guidance because it is not yet incorporated into 

Appendix BB. 

I have contacted the office of Congressman Jerry Costello (D-IL) 18th District that includes Granite 

City, IL, and we have a phone conversation about GSI matters scheduled for 10 AM today. 

Sincerely -- Dan McKeel 5/17/11 

In a message dated 5/16/11 12:38:19 PM, pl.ziemer@comcast.net writes: 

Mr. Wall: 

I have now received word that the following items will be delivered to the Work Group as shown in the 

schedule below: 

Develop exposure model for Ra radiography 

7/29/2011 

Develop exposure model for St. Louis Testing radiography 

7/29/2011 

Develop exposure model for portable x-ray radiography 

7/29/2011 

Develop exposure model for Co-60 radiography 

7/29/2011 

Develop exposure model for New Betatron 

12/30/2011 

Develop exposure model for Old Betatron 

12/30/2011 

Develop exposure model for air activation from betatron 

12/30/2011 

Develop exposure model for uranium activation from betatron 

12/30/2011 

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Develop exposure model for steel activation from betatron 

12/30/2011 

Reconcile dose estimates with dose records 

12/30/2011 

We will need to allow some time for SC&A to review the materials, so I will expect to have the Work Group 

meet in late August to consider the July 29 deliverables on the list. 

Regards, 

Paul Ziemer 

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 

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