McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

response to an application for a byproduct materials license dated
March 7, 1962. (1 page)

4. 09/07/1962 Letter to from regarding an area
radiation survey that was made of the Radiographic Exposure
Facility in Granite City, Illinois. (9 pages)

5. 11/6/1962 Compliance Inspection Report from General Steel Industries for
License Number 12-8271-1 (9 pages)

6. 121/11/1962 | Memorandum to : from regarding
Inspection Report -- General Steel Industries, Granite City, Illinois.
License Number 12-1271-1. (1 page)

7. 01/07/1963 Letter to General Steel Industries from 2 in reference to the
inspection conducted on November 6, 1962. (2 pages)

8. 01/18/1963 Letter to from " regarding a
registered letter directed to Mr. , Calling attention
to noncompliance on certain regulations of the AEC's “Standards
for Protection Against Radiation,” Part 20, and “Radiation Safety
Requirements for Radiographic Operations,” Part 31, Title 10.

(4 pages)

9. 01/29/1963 Letter to General Steel Industries from thanking
them for their letter of January 18, 1963, informing them of the
steps taken to correct their definitions in the AEC licensed
program. (1 page)

10. 04/22/1963 General Steel Industries Byproduct Materials License for
Cobalt-60 Sealed Source (Budd Company Model 41706) not to
exceed 1 curie, handwritten notes. (38 pages)

11. 03/07/1963 Letter to General Steel Industries from’ regarding
an application dated February 15, 1963, for renewal of their
byproduct materials license. (2 pages)

12. 03/15/1963 Letter to from in reference to a

letter dated march 7, 1963, listing deficiencies in General Steel Industries license

renewal application and tentative training program. (4 pages)

13. 04/02/1963 Letter to General Steel Industries from in
response to their March 15, 1963 letter. (1 page)

14. 04/09/1963 Letter to from 1 in reference to General Steel
Industries training program. (4 pages)

15. 1962 General Steel Industries Byproduct Materials License for
Cobalt-60 Sealed Source not to exceed 1 curie. (3 pages)

16. 04/30/1963 General Steel Industries Byproduct Materials License for
Cobalt-60 Sealed Source not to exceed 1 curie (27 pages)

17. 01/01/1964 Application for Renewal from General Steel Industries, AEC
License 12-8271-1 (54 pages)

-4-



11/16/08

I, ), in conversation with , a fellow radiographer, established that .
started to work in the Non-Destructive Testing department of General Steel in 1953. stated that , at that
time, there was iridium present and used at the GSI sight by GSI workers did military service time till 1956
and returned to the GSI non-destructive department and did receive source training along witl fellow workers,
on a one time basis. . There was also iridium, being used at the plant, after his return from service in 1956.
stated that at this time, there was no large 80 Curie Cobalt source present
said that the iridium source was in use in 6 building railway work. F

, and stated that there were cable ports in both Betatrons
From 1964-1965, 7 5, 4! . worked with, and
were aware of an 80 Curie Cobalt source used at GsI by the workers. ’ was himself an isotope

operator and safety man and used the 80 Curie Cobalt source in both Betatrons.. The old 24 MEV Betatron, in
1953, was in operation followed in 1964 by THE New 25 MEV Betatron

was hired by GSI in October of 1963. ~~ also served as SHOP STEWARD for, a
number of years. I, worked with, _ , in 64 or 65 with the large Cobalt source,
worked with handling the Cobalt, .worked with operator , also using
the large Cobalt. 1, ~ had conversations with all of the above listed people and had worked with all

of the above at GSI.

All of the above were members of GSI Non-Destructive Testing Department and are signing this
Statement



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

33.

34.

35.

36.

37.

07/28/1972 General Steel Industries Byproduct Materials License for
Cobalt-60, Budd Company Model 41706 Sealed Source not to
exceed 1 curie in a single source. (164 pages)

08/28/1972 Letter to from regarding their AEC
License for the period through July 1977. (218 pages)

12/17/1973 Letter to} from regarding License
Number 12-08271-01. (10 pages)

Undated Application for Byproduct Materials License Use in the Metallurgy
Department from General Steel Industries for metallic source of
Cobalt-60 in a sealed source, w/handwritten notes. (32 pages)

Undated Application for Byproduct Materials License Use in the Metallurgy
Department from General Steel Industries for metallic source of
Cobalt-60 in a sealed source, w/handwritten notes. (35 pages)

Key Findings of NRC FOIA/PA 2010-0012: the Petitioner’s View:

a

i)

[10] AEC Byproduct Materials License 12-08271-01 governed the use of three
(3) cobalt-60 sealed gamma sources from 1962 to license termination in 1/74.

[11] | The two smaller Co-60 sources were 280 and 260 mCi units in Budd
Unitron cameras. Use was at first confined to the 6 Building inner Radiography
facility. This facility is described as having a 22 x 60 foot area with 10 foot high
walls topped by three strands of barbed wire that was guarded by a single door
to be always closed. The Safety/Control officer always had to be notified when
work was done on the roof above this facility or when a crane was used to bring
target castings or rail trucks to be imaged.

Multiple GSI workers say this Building 6 Radiography facility description is
not accurate in several aspects: smaller overall dimensions, walls more like 7
feet tall, no barbed wire, and for a period no door was on the facility.

Both C0-60 sources had decayed to 100 mCi by 1968 when license 12-
08271-01 shows the large 80 Curie Co-60 source was purchased from Radionics
and used at GSI initially in the New Betatron building.

[12] Dr. (a Ph.D.) of Nuclear Consultants Corporation (NCC) was the
chief expert GSI named in its License 12-08271-01 application. NCC
administered a GSI film badge program in 1962-63 (at least) and a GSI
accountant maintained the AEC required records. The required records included
AEC/NCC film badge reports such as the one the petitioner McKeel provided to
SC&A before the 11/10/09 TBD-6000 work group meeting.

NCC and Dr. were also instrumental in doing a 1962 radiologic
survey of the Building 6 Radiography facility that is included in the NRC material.
NCC performed GSI survey instrument calibration and sealed source leak tests.

-6-



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

18.

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

30.

31.

32.

02/27/1964

12/22/1964

06/22/1965

04/14/1965

06/01/1965

1966

1968

04/22/1968

08/23/1968

09/16/1968

10/03/1968

11/04/1968

1969

03/17/1969

10/12/1970

Letter to from \ in reference to
their letter dated February 18, 1964 regarding license application
form AEC 313R. (1 page)

Letter to from in reference to
Byproduct Materials License 12-8271-1 where several changes
were made in the organizational structure of the General Steel
Industries radiography program at Granite City, Illinois. (1 page)

Byproduct Materials License for General Steel Industries for
Cobalt-60, Sealed Source (Budd Company Model 41706) not to
exceed 1 curie. (62 pages)

Letter to General Steel Industries from regarding
their application dated January 21, 1965 for renewal of Byproduct
Materials License 12-8271-1. (1 page)

Letter to AEC from regarding their radiographic
training program. (1 page)

Application for renewal from General Steel Industries for AEC
License 12-8271-1. (53 pages)

Application for renewal from General Steel Industries for AEC
License 12-8271-1. (58 pages)

Letter to from . regarding their new
Radionic Panoramic Camera P60-100-2. (4 pages)

Letter to General Steel Industries from , regarding a
phone conversation with on May 13, 1968 requesting
authorization to use an 80-curie cobalt-60 radiographic source in
the yard area at the Granite City plant site. (1 page)

Letter to . from regarding the use of 80
cobalt-60 radiographic source in General Steel Industries
facility. (1 page)

Letter to General Steel Industries from - regarding
AEC’s consideration for performing radiography using an 80-curie
cobalt-60 source outside of the Betatron. (1 page)

Letter to from ' regarding AEC License
12-8271-1 revision to restrict the use of 80 curie cobalt-60 source.

(3 pages)

Application for renewal from General Steel Industries, Inc. for AEC
License 12-8271-1 Radiograph with Cobalt-60. (148 pages)

General Steel Industries Byproduct Materials License for License
Number 12-08271-01 to amend item 4. (12 pages)

Letter to _ for _ tegarding a
telephone call from Mr. on September 29, 1970
inquiring as to training and experience requirements for
radiographers. (9 pages)

-5-



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

[21] Preliminary GSI worker concerns related to the NRC FOIA documents
center of several specific areas, as follows:

(a) Many workers believe the large 80 Curie Co-60 source was used at
GSI prior to 1968, and as early as 1964. These concerns were all expressed by
workers trained as GSI radiographers who assisted in its use.

(b) The description of many written aspects of the 6 Building Radiography
Facility safety and Radiography Training programs were not actually practiced.

(c) The Nuclear Consultants Corporation (NCC) GSI film badge
program on paper sounds like a daily activity with regular badge exchanges,
readings and detailed record keeping. The reality is perceived as different with
almost casual attention to details and little to no accountability to the workers. Mr.

perceived as a very aggressive manager who was will to compromise
safety procedures in order to maximize productivity.

(d) The physical characteristics of the 6 Building Radiography Facility as
perceived by the workers were significantly different from the license drawings.
The actual characteristics were such as to result in a higher radiation exposure to
workers outside of the building. More people worked closer than license
12-8271-1 indicates. Supervisors were not routinely warned before workers did
tasks on the Building 6 roof or the crane brought target castings to be
radiographed.

(e) The use of Co-60 sources was not confined to just the locations named
in AEC license 12-8271-1 but elsewhere in the GSI building complex. Building 10
was named by workers specifically as a place the gamma sources were used.

Respectfully Submitted,
Daniel W. McKeel, Jr.

Daniel W. McKeel, Jr.

GSI SEC-00105 co-petitioner

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

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


Page 1 of 1

Miller, Diane M. (CDC/NIOSH/EID)

From: DanMcKeel2@aol.com

Sent: Saturday, December 12, 2009 8:53 PM

To: NIOSH Docket Office (CDC)

Ce: DanMcKeel2@aol.com

Subject: PUBLIC DOCKET SUBMISSION: GS! SEC-00105

Attachments: DM_SEC105_Pub!Docket.pdf

December 12, 2009

Public Docket Office

Department of Health and Human Services

National Institute for Occupational Safety and Health (NIOSH)
Robert A. Taft Laboratories

MS-C34

4676 Columbia Parkway

Cincinnati, OH 45226

Public Docket Office:

Please accept the attached PDF file as a submission to the PUBLIC DOCKET as a comment on SEC-
00105 (General Steel Industries [GSI]). | am the co-petitioner on this SEC petition. The contents contain
newly obtained FOIA information from the NRC related to Byproduct Materials (sealed isotope source)
AEC licenses issued to GSI during 1962 to 1974. This informational summary is also being transmitted
directly to Ted Katz, DFO, on behalf of the Advisory Board on Radiation and Worker Health (ABRWH)
and its TBD-6000 work group that is considering SEC-00105.

Sincerely,
-- Daniel McKeel, Jr.

Daniel W. McKeel, Jr., MD

GSI SEC-00105 co-petitioner

Southern Illinois Nuclear Workers (SINEW)
Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

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



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI!)

a

[13] NCC and Dr. : “set up the GSI AEC required radiography training
program in 1964 at least two years after the GSI NDT gamma inspections were
well underway. Course topics taught, sample test forms, and one completed test
were included in the NRC-2010-0012 documents.

[14] GSI was cited for various deficiencies in its instrument testing and training
programs. GSI management apparently responded adequately to satisfy AEC
concerns. A specific concern was lodged by GSI union representative Tom
Hawkins (still alive, interviewed recently by SINEW) to the AEC concerning
inadequate training in the use_of the large 80 Ci Co-60 gamma source.

[15] No records were supplied by NRC under FOIA 2010-0012 during the
1950s when GSI isotope operator , testified GSI owned and used an
iridium-192 source (see ATTACHMENT 1).

[16] Prior to purchasing the two NCC/Budd-Unitron 260 to 280 mCi Co-60
sources in 1962, apparently two radium-226 sources were used at GSI with the
“fishpole” technique in the Building 6 Radiography facility during the 1950s. The
AEC insisted the fishpole practice was too dangerous and must be discontinued.

(17] Mr. of GSI was the contact for AEC inspections with the
Illinois State Board of Health and, later, with the Illinois Dept. of Public
Health. Both state agencies held regulatory powers over GSI radiography
operations and cooperated in GSI radiography inspections and regulation. An
example was a request by ~ , head of GSI Quality Control, who
requested that the AEC allow GSI to operate the large 80 Curie Co-60 source
outdoors. The state of Illinois denied the request, saying the operation was too
dangerous. AEC agreed, and GSI was forced to abandon the operation.

[18] St. Louis Testing Corporation, an employee of which ( )
testified at the Oct. 9, 2007, SC&A sponsored GSI! workers meeting in
Collinsville, IL., also performed survey instrument calibration and leak testing
after 1968.

[19] St. Louis Testing succeeded NCC in this instrument calibration/leak
testing work for GSI. NCC was purchased in 1966 by MCW as co-petitioner Dan
McKeel informed the TBD-6000 work group at its November 10, 2008 meeting.

[20] GSI isotope operator was recently interviewed by the
chairman of the ABRWH and TBD-6000 work group. Mr. testified he
once had to shut down a St. Louis Testing Co-60 NDT inspection of a large GSI
casting being performed outdoors near the Betatron buildings. The alleged cause
of this shut down was exceeding the exposure limits of 2 mR/hr.

GSI Worker Concerns with NRC FOIA 2010-0012 Content and GSI Operations:



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

period. CDC should thus be willing to share part of the costs. This Summary of NRC
FOIA 2010-0012 GSI material will also be submitted to the NIOSH PUBLIC DOCKET.
Mr. Katz indicated that Acting Director of OCAS/NIOSH, Mr. Stuart Hinnefeld,
would look into the possibility that his office could pay for the McKeel- _ copying
and overnight carrier invoices incurred with providing this FOIA material to the ABRWH.

Attribution of NRC FOIA/PA 2010-0012 in Technical Papers and Reports:

Q [8] This material should be attributed as follows (the complete paragraph
should be included) when cited or used in part or whole in ABRWH or work group
documents, or by NIOSH, DOL or SC&A:

“This material was provided directly to the ABRWH by Daniel
W. McKeel, Jr., M.D., SEC-00105 co-petitioner, on 12/12/09.
The documents were obtained from the Nuclear Regulatory
Commission (NRC) via FOIA/PA 2010-0012 submitted by
Dr. McKeel. NRC waived research and copying fees based
on the premise these documents would be shared widely
with the public on behalf of GSI workers and claimants. The
records were provided to Dr. McKeel by NRC in their
entirety, unredacted, with nothing having been withheld or
removed. It would be inappropriate for such documents to be
redacted by HHS, CDC or NIOSH. NRC noted that these
documents had not been released previously under FOIA.”

Full reference/literature citation: McKeel DW Jr. “Summary: Thirty seven documents
related to AEC sealed source Byproduct Materials licenses 1962-1974 to General Steel
Industries, Inc., of 1417 State Street, Granite City, Illinois." NRC FOIA/PA 2010-0012
received November 23, 2009. Pages 1-1016. [Please use this in all technical
publications]

Q [9] NRC FOIA/PA 2010-0012 Index of Documents:

APPENDIX A
RECORDS BEING RELEASED IN THEIR ENTIRETY
(If copyrighted identify with *)

NO. DATE DESCRIPTION/(PAGE COUNT)

1. 03/07/1962 Letter to from enclosing an application
for two Cobalt-60 radiographic sources. (1 page)

2. 04/04/1962 Letter to from regarding a request
from Dr. of Nuclear Consultants Corporation.
(1 page)

3. 04/18/1962 Letter to General Steel Industries from in

38



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

a [5] GSI co-petitioner Dan McKeel submitted another NRC FOIA request on
10/14/2009 that became NRC FOIA/PA 2010-0012. The first NRC response was that
almost 600 pages were found that would cost in excess of $400. McKeel focused his
request to GSI sealed source licenses 1952-1973 and more than 800 pages were found
at a cost of $227. McKeel then filed a fee waiver request that NRC approved. He
received 1,016 (including section dividers McKeel added for readability) printed pages
of responsive documents from the NRC FOIA office on 11/23/09.

NRC included an index for the 37 sets of documents that are included with this
letter. All but two of the documents (#36 and #37) were dated. The sections ranged from
1 to 218 pages in length.

The documents included the initial and several renewal applications of Byproduct
Materials Cobalt-60 license 12-08271-01 issued by the AEC to General Steel Industries,
1417 State Street, in Granite City, Illinois in 1962 and terminated in January 1974 when
the Granite City plant ceased operations.

Of great importance were the identification of four new source terms and
definite confirmation of a second film badge program at GSI. The newly identified
source terms used for industrial nondestructive testing (NDT) included two radium-226
sources, a second small (260-280 mCi) Co-60 gamma source, and a second standard
industrial x-ray unit that were identified at GSI during the AEC contract period. These
were 4 GSI source terms not heretofore characterized by either NIOSH or SC&A. Nor
have they been considered before by the TBD-6000/6001 and Appendix BB work group.

Source Document Attempted Submission to ABRWH:

Qa [6] Co-petitioner McKeel drove 170 miles to St. Louis and he and

then copied the NRC FOIA pages at a commercial vendor. McKeel returned to Van
Buren and Mr. recruited the IT section of his former employer, IKON copier
company of St. Louis, to scan the documents and save them onto CD-ROM media. The
commercial business center quoted a price of $0.99 per page to do this scanning work.
IKON provided its services for free, thereby saving the US Government more than
$1,000 in scanning and CD-ROM preparation fees.

a [7] McKeel then offered to supply the ABRWH through its DFO with copies of the
NRC FOIA 2010-0012 information on CD-ROM. He asked that the Board defray the
costs of copying and overnight mailing of the CD from St. Louis to McKeel in Van Buren,
and by McKeel to Mr. Katz in Atlanta. Cost was estimated at around $150. Mr. Katz
replied CDC could pay the FedEx fee from Van Buren to CDC, but not the other costs.
McKeel believed this position taken by the DFO and CDC was unreasonable,
and therefore decided to send this Summary to the DFO and to all members of the
TBD-6000/6001 and Appendix BB work group directly to consider at its meeting on
December 16, 2009. Petitioner McKeel believes he and Mr. ! have located
and obtained key records to the proper consideration of GSI DR and SEC-00105 under
OCAS-IG-003 that a// radiation sources must be utilized during the AEC production



McKeel Summary: NRC FOIA/PA 2010-0012 and SEC-00105 (GSI)

Nuclear Regulatory Commission
FOIA/PA 2010-0012 Related to
General Steel Industries (GSI)
AEC Sealed Source Licenses

-- Part 1. SUMMARY --

Provided for the ABRWH and the
OCAS/NIOSH PUBLIC DOCKET on the
NIOSH SEC-00105 Evaluation Report
and the SC&A Review
by
Daniel W. McKeel, Jr., M.D.

GSI SEC-00105 Co-petitioner
(December 12, 2009)

Historical Background

Q [1] , husband of a GSI claimant/survivor, brought the story of an
AWE facility, General Steel Industries, Inc., 1417 State Street, Granite City, IL, to the
attention of the ABRWH in mid-July 2005. This was in the midst of the MCW-Destrehan
Street SEC-00012 deliberations. GSI is an AWE site based on its AEC contract from
1952 to 1966 for high Mev (Betatron) x-ray radiographic nondestructive testing (NDT)
of Mallinckrodt Chemical Works (MCW) Uranium Division uranium metal products.

Q [2] At least seven [7] different GSI radiation source terms were identified by Mr.

and by Daniel W. McKeel, Jr., current GSI SEC-00105 co-petitioner. Those
GSI sources included AEC uranium metal products from MCW facilities in St. Louis and
Weldon Spring, Missouri, two 24 and 25 Mev Betatron x-ray machines, a large and a
small Cobalt-60 gamma source, an iridium-192 gamma source, and a 250 Kvp portable
x-ray unit. A few Betatron related documents were captured by ORAU and NIOSH,
while the three gamma isotope sealed sources and 250 Kvp standard industrial x-ray
unit remain essentially uncharacterized except for brief descriptions by workers.

Q [3] NO AEC licenses or radiation device registration records were captured by
NIOSH, SC8&A or DOE for the GSI AEC uranium contract period of 1952 through 1966.
McKeel and informed the Board of a 1957 Illinois state law that required
registration of radiation devices. DOE and HHS/CDC/NIOSH/OCAS as two of the
EEOICPA implementing agencies, and the Board contractor SC&A, reported they
expended extensive efforts to capture this sealed source license material but were
unsuccessful. None of the letters that attempted to obtain the licenses was provided to
the GSI petitioners to be able to judge the adequacy thereof.

Q [4] GSI SEC-00105 co-petitioner Dan McKeel submitted a FOIA request to NRC
on 05/23/2006 asking for Granite City Steel and/or General Steel Castings sealed
source licenses for Co-60 and Ir-192 during the 1953 to 1966 AEC contract period.
NRC responded saying no responsive records were found.

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