Adley Melt Plant Building (Hanford) 1952

 4338717_ADLEY1952copy.pdf

Since comipiction of the field work in this study, three changes in
production activity ive beon effected: '
, 1, in April of 1981, the Melt ‘Plant crew started working a six-
. day week, ‘thus increasing their wonky exposure by “EO.
“2, On October 8, 1081, production was increased from #10 11/2
furnaces per day. : . :
3. On Januzey 7, 1952, activity was expanded to 2 shitty per day.
The increase in personnel has provided a rise in production to
$ furnaces.per day with even higher production anticipated

goon, ~ '

‘These increases in meiitig operations will unavoidably result in greater -
froduction ef dust aad fume in the atmosphere of the Melt Plant Bullding.
The exposures of workers will have-risen correepondingly,

The weighted exposurys just discussed are based on the cancon-
trations of dust and fume that would be inhaled by workers if they did not
r resplraters. However, in al] production areas of the building,
except in the furnaaec: room dering the normal remelt process, workers.
are required to wear respirators. Foil reliance cennot, however, be
placed on auch equipment asa satisfactory protective measure for the ©
& reasons:

followvit

‘
1, Evan with beat conprration hy the operators, respirators
ar: pol -worn 100% of ihe timc, Respirators are uncomfort-
- able to wear and the workers remove them occasionally to
' . relieve the discomfort, At or acar seme dusiy operation
, such a5 oxide+shovelling, © quantity grenier thar the maxi-
mum permissible dally quantity could be inhaled in less than
ane minute without a respirator,

2. Filters in the. Téspiraturs are not LOO% officient, Evoa if
99% efficient, there would be many inglaunces at operations
in the Melg Plant Buibtlag when the 1% penetrating the
filter would greatly excced the tolerance level. ‘

3. _Rospiraters are now always fitted perfecily to fecial cantours;
“hence contaminated air may leck around the edges of the mask.

-19-


Adiey Melt Plant Building (Hanford) 1952

TM 4338717_ADLEY1952copy.pdf

Find bd

~34-

Contributions of Red-Handling Activities (including Autoclave Acuvitles)

In Figure vil opposite, the etmospheric concentrations of U3,
average highest at Operation A, which consists in unloading rods from
freight cars. -Thesc procedures, however, do not contribute to the con-
tamination within the Melt Plant Building as this work 1a performed
Gui-of-doors about 400 feet from the building.

Nearly all activilies under Opersiton B contributed concentrations
in excess of the MPC. In these storage bay operations, the first set of 3
samplas represents air conditions. during Stacking and unstacking rods
with a forklift truck, Probably the stirring of dust from the floor is the |
chiei cause of atmospheric dustiness during such achvity. The next two
samples (H-i3 and HV-114) were taken to demonstrate the effect that
exhaust gases from a forkir truck have in stirring dust from the floor.

Included under Opefation B is a pair of samples (HV-95 and Cl-12).
taken during a non- routine procedure in the storage bay, These were
obtcined while a crew of three men were decontaminating the chassis of
a truck used io carry rods from the railroad spur to the Melt Plant
Building, The decontemination was done by filing, wire-brushing, and
grinding with a portable grinder. .

' The final two sampies in Part B (HV-31 and HV-101) are examples
of the atmospheric dust load that arises from sweeping operations in the
storage bay. A sawdust sweeping compound was used, but concentrations
still exceeded the MPC. .

, The groupings under Operation c, rod-etraightefing, consist of 2
samples taken while loading the table with rads, 6 at the feed ond of rod
Straightener during operation, 4 at the offtake @nd, and 1 within the cabi-.
net of the rod straightener while it wes being cleaned. Al) these activities
were heavy coniributors’to general air contamination, except the last |
(HV-30), which had.the benefit of cxhaust venUlation within the cabinet,
and did not-represent:-a ¢entribution to the ‘dust load of the ‘general Piant
air, “ .

-13-


Adley Melt Plant Building (Hanford) 1952

Page 8.
(1) 1 Remelting and recovery of metal and oxides

(2) Rod-straightening and related operations

(3) Autoclaving

The sequences of operations in these three categories are outlined in the "flow sheets"
which follow. Opposite each step in the process is listed the potential it has for creating
atmospheric contamination. Potentials for contamination were estimated from

preliminary survey of the operations. Similar operations occurred at MCW, not at GSI.

Page 9. The Adley ef a/ 1952 critique narrative continues on page [4] of this paper. Dan
McKeel's main thesis for this paper is developed. That is, that both NIOSH and SC&A’s
interpretations of the Adley 1952 report were extremely biased and therefore
scientifically unsound in not only using selected Adley 1952 data, but in failing to
emphasize other aspects of the paper. The Adley et a/ 1952 report is an excellent
example of how uranium rod and billet handling steps, including unloading from
railroad freight cars and sweeping, caused major airborne uranium dust levels
elevations above the then “maximum permissible concentrations (MPC). Also, workers
at the Hanford Melt Building were required to wear respirators, whereas GSI workers -
never wore them according to information NIOSH and SC&A have developed and
presented on the record.


Adley Melt Plant Building (Hanford) 1952

McKeel comment on page 44 of Adley 1952. The Melt Plant work load changed

significantly over time. Most of the workers tested wore respirators. To my knowledge,
no GSI workers were ever required to wear respirators. NIOSH and SC&A failed to
take this factor into account when strictly comparing Adley 1952 and GSI intake data.

= 4338717_ADLEY 195 2copy. pdf

Bioassay Results .

In the course of the environmental study, the results of which are
tabulated in‘Table [X,; several operators’ in the Melt Plarit rotated period--
ically from onc series of operations to another.’ This minimized the
chances. of any operator being exposed to elevated concentrations for ._
‘extended periods, - tf os

‘The “weighted” exposures calculated for each operator indicate
the levels of contamination which were encountered for cach process in-
volved. To facilitate correlation of these environmental exposures. with
bioassay findings, two operators working without respirators in.the-

' Machining and Canning Building at'a relatively constant level, approxi-
mately the maximum permissible conceritration, were studied carefully
fora one week period, Sufficient air samples were collected to permit

satisfactory evaluation of exposures, and urine samples were collected ‘ .
atthe beginning and end of each shift. Urinalyses were conducted by .

: the Bioassay Laboratory of the Radiological Sciences Department, This
“investigation showed that the average exposure was 7% 1075 ve U/ce. air.
and the average uranium excretion was at a level of 8.7 ag/iter. Using .
this data as a basis for appraising the relationship between exposures
and excretion of metal, the environmental data obtained in: the Melt 7
Plant during approximately six months of study. were correlated with the ¢
results of routine uranalyses. Over this period the: furnace roorn ,
operator was exposed to an average concentration of 40. times. the MPC.~ i

, Assuming that a total of 5% of the atmospheric dust ‘and fume penetrated
the filter of the respirator and/or leaks around the edges of the facepiece, .

va

McKeel comment. There was no urinary uranium bioassay data measured at GSI.

-20 -


Adley Melt Plant Building (Hanford) 1952

. As this is written, NIOSH and SC&A, unable to agree on an intake model for
1952-1962 at GSI after 5 attempts by NIOSH, considered a brand new “square wave”
distribution to bound GSI intakes at a 5/28/13 technical call meeting the GSI co-
petitioner and site expert were prohibited from participating in as silent observers. Two
days later he was sent an anonymously authored 2/3 page technical call summary that
did not indicate a resolution of the intake model had been achieved. Nor were final
quantitative bounding inhalation intake doses for GSI for 1952-1962 provided. It is thus
unknown whether or not OTIB-070 or the Adley ef a/ 1952 report (as surrogate data for
GSI) were discussed at this secretive technical call meeting.

. Data from Adiey et a/ 1952 was not cited by NIOSH in TBD-6000 Rev 0, in GSI
Appendix BB Rev 0, or in the GSI SEC-00105 evaluation report by NIOSH. It was
referenced in TBD-6000 Rev 1 (12/11/06) and was the focus of a May 13, 2013 white
paper by SC&A (source reference 2 this page). Full analysis of Adley 1952 as is done in
this report is now thus of paramount importance to revising GSI Appendix BB Rev 1.

+ Internet primary source reference 1: OST! document found at URL:

http://www.osti.gov/bridge/product.biblio.jsp?osti_id=4338717;

Adley, F.E. ; Gill, W.E. ; Scott, R.H. Study of Atmospheric Contamination in the Melt Plant Building.
Report: HW-23352(Rev.). OST! ID: 4338717. April 1, 1952. 94 pages.

* Source reference 2. Thurber, W.C. (SC&A): Supplementary comments on Revision 01 of Battelle-
TBD-6000. May 13, 2013. 34 pages.

Respectfully submitted,

+
eo

Daniel W. McKeel, Jr., MD 6/6/2013

Current contact information:

Daniel W. McKeel, Jr., MD

Southern IL Nuclear Energy Workers (SINEW)
GSI SEC-00105 co-petitioner

-22-


Adley Melt Plant Building (Hanford) 1952

 4338717_ADLEY1952copy.pdf _

jer} if Find ad

oho. |
performed by one operator. His daily exposure is about 40 times the
weighted tolerance level of 40, :

The next three duties are ratnted from day to doy among the”
other three regular operators in the Remelt Plant. Hence, over a long
period the average weighted exposure of any of these three men may be
assumed to be & simple mean of the threc totals listed. ‘This value is ;
3,134 or 78 Umes ihe weighted MPC.

Rod-handling in 314 Building is limited to 16 hours per week per
man, but the exposure is still excessive. _

Autoclave operation requires about 1 1/2 hours per day and the
weighted exposure is below the permissible ievel.

Those engeged in unloading rods from freight cars are restricted
to 4 hours per day and this work is done only a few days each month, .
Despite the limiled exposure time, however, onc 4-hour cxposure of

a man unloading cars is equivalent to a 14-day exposure at the weighted
MPC. :

. . hoe
McKeel comment on page 38-39 of Adley 1952. The Melt Plant administrators limited
worker exposure sharply because the measured data showed that numerous uranium
handling operations elevated air concentrations above the MPC (see last sentence).
McKeel comment on graph on page 17 (following graph) of Adley 1952. The bar
related to “rod receiving-unloading cars and loading trucks” is also revealingly high, with
doses being recorded above autoclave operators and above the maximum tolerance
level. MCW uranium ingots, dingots, billets and betatron slices came from MCW in St.
Louis to GSI by rail and truck. To my knowledge, neither NIOSH not SC&A have
attempted to calculate the load/unload truck and freight car doses at GSI.

-17-


Adley Melt Piant Building (Hanford) 1952

= 4338717_ADLEY1952copy.pdf

7

-32-

Under Operation B,’ sample's HV-82, CI-2, and HV-130 show that |
atmospheres. around: the oxide furnace during burnout contain onty a small
fraction of the amount of U0, that was found in ‘the atmosphere of the
original burnout room, | During other oxide~burning operatians (see HV-73),
concentrations are found similar to those in the samples just cited,

The general atmosphere ta the vicinity of the oxide furnace remains
contaminated even. when no production activities are under way as shown -
by samples HV-20 and. HV-34 under Fart E, This: suggests that dust and
fume particles from oxide: “handling | and other operaticns remain suspended
in the air for long peridds ‘and that atmospheric. concentrations are'not
sufficiently reduced by general ventilation. These factors:2 are discussed .
in subsequent sections of this report,

Sample Hv- 54, included in Part E, shows that concentrations in
: excess of the MPC can.extist during sweeping operations, even when a a .
sweeping compound is'used.’ : “*

Atmospheric concentrations in the old oxidé burner room were “very
high as shown under Operation F, This operation is now ‘abandoned.

. For further: detail regarding the above firings, reference may be.
made, to Table VI.in the Appendix, ‘

McKeel comment on page 32: Two points deserve special emphasis and
consideration with respect to modeling GSI uranium intakes during the operational and

residual periods.

First, samples HV20 and HV-34 under Part E showed that uranium dust levels
“remained elevated for long periods” even when production had stopped. Again, GSI
had no such measured levels. sweeping and elevated.

Second, Very importantly, sample HV-54 showed that “sweeping operations can
exist, even when a sweeping compound is used.” Site expert Ramspott has photos
showing a GSI Betatron operator sitting next to a large TENNANT industrial sweeper.

-9-


_ Adley Melt Plant Building (Hanford) 1952

McKeel comment on previous page 5 of this document. The ROD
STRAIGHTENING AND RELATED PROCEDURES largely recapitulated operations that

were performed at GSI while handling MCW Uranium Division uranium metal during the
operational period. These data should have been emphasized by NIOSH and SC8&A to
the TBD-6000 work group and the full Board in meetings prior to the final SEC-00105
vote on December 11, 2012.

The “PERSONNEL” footnote is perhaps most illuminating in giving the numbers
of people and the tasks they actually perform in “simple” unloading of freight cars:

First of all, seven men are required to unload one freight car. NIOSH and GSI
workers do acknowledge that rail (and truck) transport was the most likely way that St.
Louis-based MCW uranium metal was transported across the Mississippi River to
Granite City, IL, to GS! for Betatron NDT x-ray inspection. No MCW (MO) to/from GSI
(IL) shipping records are extant, however. Yet neither NIOSH nor SC&A emphasized
this highly relevant part of the Adley 1952 report in their work group and full Board
presentations;

Second, workers from two separate Hanford departments, Materiai-Handling
Group and Transportation, were involved;

Third, workers from both Hanford departments were limited to “4 hours per day’
shifts. The context of the footnote makes it clear the reason work periods were limited is
because of the high measured uranium dust levels. Such dust levels from any step(s) in
the handling of MCW uranium metal were never measured at GSI in Illinois.

Dave Allen's and NIOSH’s GSI thesis, emphasized to the WG and full Board, that
the dust levels from handling “cold uranium” were low, just the opposite of Adley 1952.

The GSI petitioners believe the citing of all the relevant data in Adley et a/
1952, including these listed freight car unloading activities, as surrogate data on
which to base a GSI air intake of uranium model, would have produced inhalation
intake doses for uranium far higher than were assigned in the extant NIOSH and
SC&A models. We assert that both NIOSH and SC&A misrepresented the facts
and some of the most relevant data to GSI uranium operations in their analyses of
Adley et af 1952.


Adley Melt Plant Building (Hanford) 1952

= 4338717_ADLEY1952copy. pdf

- = *
19]
, le
: oe YS
ROD-STRAIGHTENING AND RELATED PROCEDURES
: oa . " "Potential for Producing’
. Flow of Operations. : Atmospheric Dust or Fume
ray * Unloadin, rods fram freight “ Dust dislodged in quantities from
‘tars. Done af siding away heavily oxidized surfaces of rods.
._ from the building. Slo. .
" (2) Stacking unstraightened rods | Some dust shaken from rods, Dust
: ‘In storage bay” Also unstack- = stirred from floor by activity of:
ing them and transporting to fork lift trucks,
red straightener, an . ts
:.(3) Leading table at feed end of ’ Very dusty when rods slid from forks
Fod siraightener. onto table. ooo. —_
(4) ‘ Operating red straightener. Sliding.rods across table and banging
, ee . “ of rods against channel guides while
being fed into machine created dust.
Dust and fume created in large
: quantities within .machine. :
(5) Removing rods from offtake Fork lift truck'stirs up dust.
table ta storage bay. ,
(6) Transporting rods from Same condition-as above,

ing.

‘ siorage bay to the Slug- “
Machining and-Canning Build-

Personnel: Rod straightening and the attendant duties of rod-handling

_ Handling Group; the other‘five are from Transportation. -

in the storage bay are normally handled by, two men. from:
the Material-Handling Group.:- Each man 1s limited to 16 _
hours per week at this work and crews arerotated

periodically, -  _ : : ; mo

: ‘ . ' ¢ .
Unloading reds from a freight car requires’ the Services :
of seven men: two carry rods from the car to the scales; «'
Iwo weigh rods and record the data; two carry fods from
the scale to a truck; and one.man drives the truck: The
two men weighing and recording’ are from the Material-

Section, When two cars arc unlosded simulianeously, - ‘s

“twice as many men are needed. Any worker's exposure .|--

is limited to 4 hours per day at this task. | :

-5-


Adley Melt Plant Building (Hanford) 1952
TM 4338717_ADLEY1952copy.pdf
at ol cing .

. _ WEIGHTED DAILY EXPOSURES OF WORKERS COMPARED TO DAILY
TOLERANGE LEVEL - MELT PLANT BUILDING AND RELATED OPERATIONS

» FIGWRE TE
2
. z Tod
; ~
.
wh. aa ORIDETM Raa ~_. [wecnne
| 1 cecnaton | GPERATORS, RODS
{-_ . ee ee ee
’ ‘Say Rom | - [ROO ABNDLiNG .
OPERATOR AND STORAGE BAY
+9009 me —-~ : 4 + 4
ry : ROG RECEIVING: LALOADING
! POARS & LOOMS TRUCKS "
s - T , oT ~
‘ -
alk 4

4
os

WEIGHTED OAR FRPOSURE ¢ MiCROGRAM -HOURS }



Adley Meit Plant Building (Hanford) 1952

McKeel comment on page 23 of the Adley 1952 report. We include this page to

balance this paper and acknowledge that operations involving active heating of uranium
did pose the greatest exposures to workers at the Hanford, WA, remelt plant. GSI did
not heat treat MCW uranium as far as the author is currently aware (June 2013).

This page is also important in stressing the point that cross-contamination of the
furnace room with respirable uranium dust occurred from other areas of the Hanford
remelt plant. At GSI, buildings 5 through 10 by necessity were wide open to each other
and to large sections of the foundry. There is voluminous testimony these buildings, like
the Old Betatron facility in particular, were so dusty that overhead cranes with magnets
were used to clean the larger metal scraps embedded in the dust. NIOSH has ignored
this plant uranium contamination totally during both the operational and residual periods
even thjough they are aware through worker testimony about the extremely dusty
atmosphere that existed at the GSI 1417 State Street “South Plant” from 1952 through
1993. NIOSH is also aware, through petitioner, site expert and worker testimony that
numerous documented companies ran steel operation businesses within the leased GSI
complex of buildings 5 through 10 throughout the entire GSI residual period from July1,
1966 though December 31, 1992.

This page also shows that uranium airborne dust data published in Adley et al
1952 for the Hanford Melt Plant must be used extremely judiciously as surrogate data
for the GSI 1417 State Street plant in Granite City, IL. While some operations were
similar at Hanford and at GSI in IL. For example, the following uranium handling
operations occurred at both sites: (a) unloading uranium metal from freight cars, (b)
weighing, (c) stacking and unstacking, (d) cleaning the beds of uranium transport trucks
(Hanford) and railroad flatcars and rail transfer cars at GSI (that might have involved
chipping and grinding operations as was documented in Adley 1952), and (e) sweeping,
Other processes described in Adley et al 1952 at Hanford did not occur with MCW
uranium metal at GSI: (a) heat treating, (b) rolling, (c) autoclaving and other uranium
operations that uniquely occurred at the Hanford site in Washington State.


Dragon, Karen E. (CDC/NIOSH/EID)

From: DanMcKeel2; :

Sent: Friday, June 07, 2013 1:50 AM

To: Katz, Ted (CDC/NIOSH/OD); p!.ziemer@comcast.net; Ziemer, Paul (CDC/NIOSH/OD)
Ce: danmckeel2@aol.com; NIOSH Docket Office (CDC)
Subject: McKee! analysis of Adley et al 1952 Report and the GSI AWE site

Attachments: McKeel_AdleyFE_MeltPlantBld.pdf

Dear Ted and Pau! and the NIOSH Docket Office,
Attachment: <McKeel_AdleyFE_MeltPlantBid.pdf> 2.3 MB

The attached PDF file is my analysis of the Adley et a/. 1952 report on the Hanford Meit Plant as it pertains to the GSI
AWE site in Granite City, !L. This key report was not referenced in Battelle TBD-6000 Rev 0 (2006), GSI Appendix BB
Rev 0 (2007) of it, or in the NIOSH SEC-00105 evaluation report (2008). Later technical reports, TBD-6000 Rev 1 (2011)
and SC&A reviews (Thurber May 13, 2014), for example, have included this reference that | therefore assume will be a
key citation in a revised Appendix BB Rev 1. This analysis pertains directly to finalizing airborne uranium intake radiation
doses at GSI during both the operational (10/1/1952 - 6/30/66), and residual periods (7/1/66 - 12/31/1992).

Ted Katz, please distribute this paper to all ABRWH members and to the Board, NIOSH and SC&A members of the TBD-
6000 work group and others as appropriate.

NIOSH Docket Office, please consider posting this paper as a discussion paper for the 6/20/13 TBD-6000 work group
meeting and as a paper under GSI Docket 140. Please use the title: Daniel W. McKeel, Jr., MD "Analysis of the Adley et
al. 1952 Hanford Melt Plant technical report."

Thank ail of you for your consideration of these requests.

Sincerely,

- Daw McKeel June 7, 2013

Daniel W. McKeel, Jr., MD
SINEW co-founder
GSI SEC-00105 co-petitioner


Adley Melt Plant Building (Hanford) 1952

“© 4338717 _ADLEY1952copy.pdf

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ATMOSPHERIC CONCENTRATIONS OF ‘URANIUM AT ROD HANDLING
OPERATIONS (INCLUDING AUTOCLAVE OPERATIONS)

FIGURE MII ©
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+4 OPERATION A: -_ | OPERATION OF
' + sitonase “ay : : ENEMA AR '
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-11-


Adley Melt Plant Building (Hanford) 1952

Legend. This photograph was sent to NIOSH, the Board and SC&A in 2007. It shows
two General Steel Industries (GSI), 1417 State Street, Granite City, IL, workers sitting
by a Tennant industrial sweeper in the New Betatron building. Note the railroad tracks in
the foreground that were used to bring MCW uranium and steel castings into the facility
for NDT x-ray inspection with the Allis-Chalmers 25 Mev electron particle accelerator
operating in x-ray mode. A much smaller industrial vacuum found in the Old Betatron
shooting room at GSI to be contaminated with uranium dust during the DOE/FUSRAP
cleanup in 1992. Uranium related alpha radioactivity was also found embedded in the
floor of the GS! Old Betatron building during the same DOE cleanup operation. No
uranium residuum was found in the new Betatron building by DOE in 1992/3 because it
had been kept cleaner initially, power washed and renovated in the GSI residual period.

-10-


Adley Melt Plant Building (Hanford) 1952

= 4338717 ADLEY1952copy.pdf

-23-

The dust and fume arising from Operation D represents the greatest
contribution to atmospheric contamination in the furnace room, This con-
dition exists while the furnace }id is being lifted, the crucibles are being
removed, and the billets are being pulled. Such contamination occurs |
despite the purging effect of the fan that pulls air downward through the
furnace and the manhole. Air turbulence at thé time the furnace Hd and
manhole cover are removed could possibly account for the escape of dust
or fume into the atmosphere of the furnace room.. Also the fine particles
of oxide may, continue to he dislodged from surfaces of the crucibles
molds, and holders after they have been removed from-the furnace and
manhole.

‘Except for their locations, Operation B and Operation C are
nearly identical, both involving the handling of briquettes*, rod ends,

, rejected Slugs, and other scrap. When ‘these materials are handled outside
* the furnacé room (Operation C), the higher concentrations may be due
partiy to cross-contamination from other processes - rad- -straightening,
for example. Directiy charging crucibles with this scrap (Operation B)
produces ‘concentration sometimes below, sometimes in excess of the ,_ .
permissible level.

‘Miscellaneous cleanup activities, such as brushing and dusting
inside the furnace (HV-28 ond HV-43 under Part. F). also contribute
significantly to atmospheric contamination, but vacuum - -cleaning (RY-017)
Js an exception, . : - ‘
te The lowest concentrations were found in the furnace room. during
normal operation of the furnace (Operation A); but concentrations above
the permissible level ‘were oiten detected. As itis felt: sthat the furnace’
during a meiting cycle can contribute no dust or fume rt the atmosphere, ; ,

the observed concentrations must arise in part from crass contamination

“Tpriquettes are uran{um chips and Tathe turnings hydrnulically com- | -
pressed inte cylindrical cakes about § inches in diamc‘er and 4 inches
thick, .

-7-


Adley Melt Plant Building (Hanford) 1952

McKeel Summary Conclusions and Comment
on the Adley et a/ 1952 Report

The science methodology based on Hanford Melt Plant carefully measured uranium
intake data reported in this Adley et a/ 1952 paper differs significantly from any GSI
practices. GSI did not employ best radiation safety practices to protect its workers.

External doses at GSI. The 1962 Konneker/NCC radiation survey of the GSI Building 6
radiography facility, and the GSI survey of the New Betatron building using a Co-60
source in 1971, were concerned only with external photon doses. Beta doses and
neutron external doses were not measured for any of the many GSI radiation source
terms. Not validated by measured data computer models, very limited and decisively
unrepresentative film badge data (on a single worker 1957-1962), back extrapolation of
uranium purchase orders to years before 1958 when there were none, letters from GSI
administrators citing adherence to AEC exposure limits we believe is “evidence” that is
unsupported by any other hard evidence (such as a second set of film badge reports or
named badge vendors) as having been the actual situation at GSI, belt object photos
the petitioners have challenged as being GSI ID badges rather than film badges,
surrogate data the SEC-00105 petitioners have vigorously challenged, were all used to
assign external doses at GSI. Appendix BB Rev 0 appeared in June 2007 before
NIOSH had obtained any film badge data.

Internal doses at GSI. There were no bioassay or air samples (breathing zone,
ambient air, or process samples as defined by HASL taken, ever, at GSI during the
operational period of October 1, 1952, through June 30, 1966, as far as is presently
known. The measurements DOE/ORNL made during the 1992 GSI residual period
cleanup in the Old Betatron Building in a small industrial vacuum cleaner have been
discredited because the petitioners proved the Old and New Betatron buildings had
been repeatedly power washed and renovated during the residual contamination period
1966 through 1993.

-21-


Adley Meit Plant Building (Hanford) 1952

Page 6. Drawing Process and Equipment Layout of Melt Plant Building
Page 7. “The wearing of respirators is required...but degree of protection is uncertain.”
“.. recommendations are presented for improved general ventilation, for extending the
application of local exhaust to all of the principal dust- and fume-producing operations,
and for meticulous housekeeping through widespread use of vacuum-cleaning.”
McKeel Comment: GS! never employed respirators or local exhaust control for any
personnel, including the workers who handled MCW uranium metal. The only attempt at
GSI to maintain housekeeping in the production areas was the use of a Tennant (now
marketed by Grainger Co.) industrial vacuum sweeper that was used in the New
Betatron Building. GSI worker testimony states the New Betatron facility (constructed in
1963) was kept cleaner than the Old Betatron facility (constructed in 1951-52) because
more plant visitors went into and scrutinized the newer facility. A photograph of the
Tennant sweeper is shown on p. 10.

ENVIRONMENT
Description of Operations:
“The activities that comprise the remelt processes are weighing, melting, and pouring
of scrap metal, sawing and lathing of uranium billets, trimming samples on the grinding
wheel, and related handling of metal.” (emphasis added) [McKeel note: Weighing and
handling of uranium ingots, dingots, billets and Betatron slices took place at GS! from
October 1, 1952 through June 30, 1966, during the AEC operational (contract) period.
Although all remelted Hanford uranium metal had once had once been subjected to
héat, some of the time the “handled” Hanford metal was used, and during the freight car
unloading procedures, as described in Adley et a/ 1952, the metal was “cold” at
Hanford in the same sense as Dave Allen described GSI uranium metal from MCW as
being “cold uranium.” McKeel has mentioned that 24-25 Mev Betatron NDT x-ray
inspection causes molecular/physical damage and slight internal heating in many
materials, including uranium metal, as has been established by DOE Oak Ridge
research over the past decades. Dave Allen and DCAS, and the TBD-6000 work group
and the ABRWH, have chosen to ignore this well documented information.]


Adley Melt Plant Building (Hanford) 1952

McKeel comment on page 34. This entire page is perhaps the most important with
respect to relevance to GSI operations.

First, highest uranium air concentration was caused by unloading freight cars;

Second, in the storage bay, fork lift stacking and unstacking of uranium rods and
forklift exhaust gases both stirred up uranium dust on the floor and caused uranium
elevations above the maximal permissible concentration (MPC);

Third, two samples showed elevation of uranium air concentration while three
men were decontaminating the chassis of a truck used to carry uranium rods from the
railroad spur to the storage area, an activity that also had to be done at GSI. The GSI
1957 engineering drawing provided by GSI site expert _ showed in detail
the massive system of rail tracks on the GSI grounds and inside buildings that were
used to transport MCW uranium metal from/back to the weigh stations, storage areas
and freight cars. Two types of rail cars—“transfer cars propelled by an electric
motor—and regular flat cars moved by a diesel engine, transported uranium metal to
the New and Old Betatron facilities, respectively. The at GSI
( _ provided affidavit testimony to the Board, NIOSH and SC&A
that the transfer cars were cleaned only twice per year. The Adley reports that cleaning
the truck chassis uranium deposits involved “filing. wire-brushing, and grinding with a
portable grinder.” Although we have as yet no direct testimony at GSI as to how the RR
transfer and flat cars were cleaned, it is likely that similar types of methods would have
to be used to remove tightly embedded uranium from the transfer and RR flat car beds.

Fourth, Operation C, which also involved handling uranium by loading the rod-
straightening table, caused uranium elevations above the MPC. The text does not say
whether the handled rods at the Melt Plant had been heated.

These data from the Melt Plant indicated that similar uranium handling doses
need to be bounded with sufficient accuracy at GSI along the entire uranium transport
as Dan McKeel has called for, on the record, in previous white papers he has presented
to the TBD-6000 work group, the full Board, and to NIOSH Docket 140 (GSI). The MCW
uranium handling processes that need to be modeled at GSI include: (a) unloading
ingots, dingots, billets and Betatron slices from freight cars, (b) transport from the freight
cars to the loading dock, (c) handling during weighing using either a crane and chains or

-14-


Adley Melt Plant Building (Hanford) 1952

TM 4338717_ADLEY1952copy.pdf

Find .

om

The first four operators in Table iX are the only ones having
8-hour-per-day exposures, Of these, the first is a steady occupation :

-30- |
el

performed by one operator. His daily exposure is about 40 times the
weighted tolerance level of 40, .

The next three duties arc rotated from day to day among the’
other three regular operators in the Remelt Plant, Hence, overa long
period the average weighted exposure of any of these three men may be
assumed to be a simple mean of the three totals listed. This value is
3,134 or 78 times the weighted MPC. . ,

_  Rod-handling in 314 Building is imited to 16 hours per week per
mean, bul the exposure is still excessive.

. Autoclave operation requires about 1 1/2 hours per day and the
weighted exposure is below the permissible ievel.

Those engaged tn unloading rods from freight cars are restricted
to4 hours per day and this work is dane only a few days each month,
Despiile the limited exposure time, however, onc 4-hour exposure of

-16-


Adley Melt Plant Building (Hanford) 1952

Page 4 -- Is the Table of Contents. Major section headings included: Preface,

Summary, Environment, Method of Study, Findings, Conclusions, Recommendations,

and Appendix.

Page 5 header: “STUDY OF ATMOSPHERIC CONTAMINATION IN THE MELT PLANT
BUILDING, SUMMARY”

+ “Oxide-handling, machining operations, burnout, and rod-handling were the chief

contributors to atmospheric dust and fumes...” (emphasis added)

* McKeel Comment: NIOSH and SC&A have minimized the contribution of “cold

uranium handling” to uranium intakes at General Steel Industries in Appendix BB and

SEC-00105. Both entities have flagged simple handling of uranium as the scenario with

the least internal radiation exposure. The above passage indicates otherwise.

+ The following passage is the most relevant to GSI, however, and has been omitted

from their technical analyses of the Adley et a/ 1952 technical report to date:

+ “Weighted daily exposures at rod-handling showed an exposure 2 1/2 ‘times the

MPC.” (bolding emphasis in the original paper; underline emphasis added).

* McKeel Comment: Because simple handling of uranium metal rods causes 2.5-fold

elevations above acceptable limits, the GSI petitioners contend that similar elevated

doses could have affected any worker in the uranium handling path at GSI who handed

or transported or weighed the 3300 pound MCW uranium ingots and dingots, and the

billets and Betatron slices described in MCW site profile documents. When trucks or rail

cars carrying MCW uranium were logged into or out of the GSI plant, weighing
personnel were required to remove tarps and inspect and identify and record each piece
of inventory. Chain men handled the chains that chafed against the uranium, causing
airborne uranium particles to flake off. Workers riding the rail transfer cars carrying
MCW AEC uranium from and to the loading dock, storage areas (one of them is now
known by affidavits to have been in Building 5 in a locked metal cage. We have photos
of this structure in 2013), and Betatron buildings at GSI were exposed to airborne dust
and fumes. None of these personnel were ever badged 1952 to June 1966 during the
AEC-MCW contract period; all should have been badged. NIOSH has not bounded
uranium intakes for these GSI workers along the long MCW uranium transport path that
winds through buildings 5, 6, 7, 8, 9 and 10 and the rail tracks in the two GSI Betatrons.

-2-


Adley Melt Plant Building (Hanford) 1952

Review of: Adley FE, Gill WE, and RH Scott,
“Study of Atmospheric Contamination in the Melt Plant Building,”
Hanford Works, Richland, Washington (HW-23352[Rev.])
April 4, 1952

Daniel W. McKeel, Jr., MD
GSI SEC-00105 Co-petitioner

-- June 6, 2013 --
Cover Page 1: This document is marked “UNCLASSIFIED” on each page.
Page 0 is a legal disclaimer
Page 00 is a disclaimer about possible illegible pages
Page 000 states “declassified December 1, 1955” and has another Legal Notice.
“AEC, Oak Ridge, Tenn.” is written in the lower right of this page.
Page 1/2 is the formal Title page with the three authors, title, date and publication
information listed for this report. The report was issued by the Biophysics Section,
Radiological Sciences Department, Hanford Works, Richland, WA. An added note
states: “Operated for the Atomic Energy Commission by the General Electric Company
under Contract # W-31-109-ENG-52” The page number is typed as -1-2- at bottom page
center, and a handwritten “2” is written at the top of the page.
Page 3 contains the Preface. The following passage is a quote:

The following report discusses the findings of a study of atmos-
pheric contamination by uranium fume and dust in the Melt Plant Building.

Coincidental with the processing and handling of uranium ‘metal
are numerous opportunities for the workroom atmosphere. to become. con-
taminated with its oxides, This problem has been recognized generally as
being omnipresent wherever ‘uranium is processed due to this metal's
chemical and physical properties which readily predispose to atmospheric
conta mination . ;

Routine monitoring of the building atmosphere has been conducted
by what was formerly known as the Operational Division of the Health |
Instrument Divisions. Data compiled from Febriary, 1947 to May, 1951 |:



Adiey Melt Plant Building (Hanford) 1952

“onan concenrnarions (uwits oF 10S pp ree)”

‘o , |
7 Heed vee HOOT VEE ES" WAT CITE RVD MISE
: TH HVE HNO HVSO” KYTE WME vee vide

McKeel comment on page 3 rod handling graph. Activity A, unloading rods from

freight cars, was also done at GS! for MCW uranium ingots, dingots, billets and Betatron
slides. The MAC dust level exposures at the Hanford Melt Plant were very high, even
though this activity a priori was simple “cold” uranium handling. Neither NIOSH nor
SC&A stressed this point about the Adley et a/ 1952 Hanford Melt Plant report in
reference to GSI uranium operations, a major oversight.

-12-


Adley Melt Plant Building (Hanford) 1952

a fork lift, (d) unloading and loading Ur metal at the Bldg 5 and other GSI storage sites,
(e) placement on transfer cars and flatcars, (f) cleaning the beds of RR transfer and
flatcars using abrasive mechanical methods, (g) unloading/reloading in the Betatron
contro! room, and (h) sweeping along the entire transport pathway. NIOSH has done

none of this analysis.
. = 4338717_ADLEY1952copy.odf

ind 7

Non-Proeduction Areas

None of the data in Figure VIll opposite represent operations that .
contribute to atmospheric contamination, The consistent presence of
uranium in these aréas is significant, and the sainples illustrate the
extent of cross-contamination from production activities, One sample,
taken in the toilet at the end of the work day, showed = concentration ;
‘above the MPC, no :

Figure VU corresponds to Table VHl-in the Appendix, where more
complete details of these samples mey be found,

From the preceding figures (or from: thelr corresponding tables),
the operations in the Melt Plant Building may be rated in the approximate
order of their contributions to the atmospheric dist and fume within the

McKeel page 36 Adley 1952 comment. The measured uranium in non-production
areas due to dust cross-contamination was revealing. It proves that a priori assumptions
that GS! office/administrative workers were not exposed to radioactivity are not only
naive, but also not consistent with real measured data such as the Adley 1952 report
contains. (See McKeel Discussion paper on this topic submitted 6/5/13 to the TBD-6000
work group and the GSI Docket 140 for its 6/20/13 meeting.

-15-