McKeel white paper: TIB-070 use at GSI

Dan McKeel still challenges that a smooth exponential averaging method, such as
is envisioned in TIB-70 using RES-RAD BUILD and/or D&D code, would necessarily
be the best statistical curve fit for these unknown and, we contend, unknowable
resuspension factor data at GSI. I strongly disagree with DCAS Director Hinnefeld in
his 6/19/13 e-mail that an exponential decay curve, as envisioned in OTIB-070 rev 1
by Sharfi 2012, is a reasonable approximation of average airborne uranium levels at
GSI hover 26 years. A “saw tooth” curve, even with uneven and difficult to define peaks
would be a better “real-world” matical fit.
NIOSH has Tepeatediy and stubbornly failed to acknowledge this other possibility that
was apparently mentioned at the 5/28/13 GSI technical call that Mr. Hinnefeld did not
attend.

The extensive renovations that the current owner of the GSI 5 and 6 buildings
(Granite City Pickling Warehouse) has made to the building structures exemplifies the
basis for our concern that the TIB-70 DandD and RESRAD BUILD codes cannot
accurately capture, in a claimant favorable way, the complex changes that may be listed
as follows:

(a) Four inches of black top have been added to the floor of 6 building;

(b) New metal siding has been added to the side and back (foundry) walls;

(c) The inner concrete radiography room has been removed.

(d) The milling machines, Direct Current power substation, and the locked metal
cage where radioactive sources and welding rods were stored in Bldg. 5 have all been
removed and replaced by the new pickling machines that are the basis for the new
owner’s business.

The transfer rail tracks between buildings 4-5-6 are still in place, The railroad
tracks at a right angle to the transfer tracks where parked his diesel engine
in the winter are still visible in GSI buildings 5 and 6 (May 2013).

* Third, The data to complete RESRAD BUILD input tables for GSI would depend
entirely on the use of stringently justified surrogate data. Slide X, Finding 2, of the Munn
PRS slide presentation to the Board on 3/12/13, indicates that four facilities were used as
surrogate sources for OTIB-0070 rey 1: Blockson Chemical , Dow Madison, General
Atomic, and Simonds Saw. Petitioners contend that Dow Madison had no such measured
data at their Illinois plant, and that no Dow Madison surrogate data was used in TIB-070
Rev 1 (see following item).

* Fourth, Dan McKeel tried to verify these 4 SD sites were actually specified in OTIB-
070 Rev |, the latest version, and could find no references to the Dow Madison site, Dan
McKeel was co-petitioner on the Dow SEC-00079 petition. An 83.14 type SEC was
granted for the Dow operational period (1957-60) based on NIOSH’s inability to bound
internal thorium doses with sufficient accuracy. The Board voted to deny extension of
Dow Madison site SEC-00079 to the residual period based on very skimpy film badge
data from another non-EEOICPA Dow plant located in Michigan. The key report on
airborne uranium at Dow, McKeel contended based on unanimous Dow worker
testimony, was not from the Madison, IL plant, where the author of the key paper was
said to be the chief radiation safety officer. None of the many Dow Madison IL workers

interviewed had ever seen Mr. at the IL location. I, and they, do not believe
that any direct airborne uranium measurements actually ema he Ilinoi

ik
plant. Surely, the skimpy surrogate data from the Michigan Dow site should not be used
in an AWE-wide important document such as OTIB-0070. This is not only scientifically
indefensible, it amounts to deliberate misuse of surrogate data.

Deliberations of the Procedures Review Subcommittee (PRS)
Dealing with OTIB-070


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

that no 6 bldg. radiography room existed from October 1, 1952,
through sometime in 1955 prior to its construction. The
petitioners assert the GSI AEC license application is incorrect
as to the eventual thickness of the 6 bldg. radiography room
walls. We believe those plans were only on paper and were not
implemented.

NIOSH on its own never produced any *independent* proof in the
form of engineering drawings or photographs of the 6 bldg.
Neither did SC&A, nor is there any evidence they even researched
confirming this important detail apart from the NRC FOIA 2010-
0012 material that Dan McKeel obtained in the first instance.

p- 11 ALLEN lines 5-10

So adjusting those readings up for 5 the lack of, the less
shielding in the radium 6 era and slightly higher source
strength of the 7 radium, I came up with, adjusted those survey
8 measurements to what they would be with the 9 radium sources
before the shielding was added.

MCKEEL COMMENT: It is impossible to make sense of this passage
unless, contrary to what I was told, Dave Allen was speaking
from a projected presentation that was available to work group
members on their computer screens or in person, but was not
provided to Dan McKeel, the GSI SEWC co-petitioner. All of the
terms used are qualitative where they need to be stated in
quantitative terms instead. Examples are: (1) "those readings”
(what readings?); (2) "slightly higher source strength" (how was
that determined? What was the Ra-226 source strength that Dave
Allen used? (3) "adjusted those survey measurements to what they
would be..." (what adjustments were made by Allen and what was
the final assigned value Allen used, citing the actual number
values used?).

p- 11 lines 11-18 ALLEN speaking

And from that, you can see from the rest of 11 this, from that
and the work practices source 12 utilization time, et cetera,
which I estimated 13 a dose for somebody at the wall, on the 14
outside of that radiography wall, if they were 15 there all
their work time, and that is the 16 estimate we intended to use
for non-17 radiographers in the radium era. 18

MCKEEL COMMENT: Again, statements such as “you can see" indicate
Mr. Allen was using a projected prepared presentation that he
was referring to while he talked. The SEC co-petitioner also
needed to have a copy of that presentation. When Allen states,
... "that is the estimate we intended to use for the non-

AS


McKeel white paper: TIB-070 use at GSI

“Why TIB-70 Use for the General Steel Industries
AWE Site Residual Period Is Scientifically Inappropriate”

by

Daniel W. McKeel, Jr., M.D.
SEC-00105 Co-petitioner

-- April 29, 2013 -
(rev 2.0, 5/13/13)
(Final ver, 6/19/13)

This paper is an extension of remarks GSI SEC-00105 made during the TBD-6000 work
group (“WG”) teleconference call on April 26, 2013. At that meeting, McKeel expressed
the very strong opinion that OTIB-070 Rev | was scientifically inappropriate for use at
General Steel Industries (*GSI") during the residual period. The major reason was that
OTIB-070 did not model the cyclical variations in airborne uranium caused by multiple
steel businesses operating during the GSI residual period.

On 4/26/13, at the request of McKeel, both David Allen of DCAS and John Mauro and
Bob Anigstein of SC&A defended their reasons why they believe TIB-70 and the
assigned values for resuspension factor and settling rate were scientifically defensible.
Dan McKeel commented his concerns were not allayed by these explanations, which he
appreciated having been given.

In a 6/19/13 e-mail to Dan McKeel, DCAS Director Stuart Hinnefeld added his reasons
why NIOSH believes OTIB-070 is appropriate to use to bound GSI residual period
radioactivity, as follows:

My question directed to NIOSH was:

“T request that NIOSH and SC&A provide me a final analysis of why
they contend OTIB-070 is a suitable model for the residual uranium
dust along the entire uranium transport pathway at GSI? I do
appreciate the verbal answers today.” (today referred to the 4/26/13
TBD-6000 WG meeting after which I first posed the question):

DCAS Director Hinnefeld’s answer on 6/19/13 to me was as follows:

“OTIB-070 provides a general framework for the reconstruction of doses
during periods of residual contamination at Atomic Weapons Employer
(AWE) facilities. While OTIB-070 describes methods that
can be used to bound exposure, i
toheused at GSLare sll being deliberated Specifically, initio’
inning of the residual period. There is agreement between SC&A
and NIOSH. however, that the OTIB-070 exponential depletion rate of
0.00067/day is an appropriate value to be used. While it is true that the
slearance of material will not perfectly follow a smooth exponential
, itis our opinion that it provides a reasonable approximation of the
integrated intake that would occur on an annual basis.”



McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

claims. Is he too busy, or does the CATI “database” I asked
about in 2006 not really exist, as I suspect to be the case?
This disingenuousness creates distrust of the NIOSH proposed
methodology. This is especially so because the CATI interview
has a specific questionl’ about whether or not the claimant was a
"“radiographer." The initial claim asks only for a self reported
job identification, which is less precise than the direct CATI
question. WHY WOULD NIOSH PROOSE USING BEST SCIENCE PRACTICE AND
THEN ACTUALLY USE LESS THAN THE BEST SCIENCE AS AN EXAMPLE OF
THEIR APPROACH?

p. 13 ALLEN CONTINUES THE SAME TOPIC, lines 11-17

That's not the process we intend 11 to use when we're actually
doing claims. You 12 know, the telephone interviews are always
13 reviewed, and they would be reviewed for those 14 job
categories or any other indications that 15 they were doing
radiography. This was just an 16 attempt to see how this process
would work.

MCKEEL COMMENT: Again, why would anyone waste the WG's time by
describing a process NIOSH WILL NOT USE, when what is necessary
is to describe as clearly as possible, and to demonstrate the
feasibility of, the exact process NIOSH WILL USE?

III. USE OF OTIB-070 rev 1 (Scharfi 2012) AT GSI

p. 17 lines 15-21 ALLEN SPEAKING

At the last Work Group, the Work 15 Group wanted to see, okay,
that's the number 16 we're going to start with, but how are we
17 going to use it? So in the White Paper, I 18 started with
that 68.7. I intended to assign 19 that to anybody considered,
well, actually, I 20 intended to assign that for the time period

p. 18 lines 1-21 ALLEN SPEAKING

1 We have the hours of uranium work that we 2 previously talked
about, we estimated. And 3 from other previous work with the
external 4 dose, we had a scenario on how long they shot 5 this
uranium and how long it took them to set 6 up the next shot, et
cetera. 7

I did not give them that intake 8 for the time they were
taking the shots. They 9 would not have been in the betatron

‘ this CATI information is posted on the: www.cdc.gov/niosh/ocas/ website

aa! ee


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

radiographers in the radium era" but fails to state the number
values he intends to use, the record is impoverished, inaccurate
and is not informative. NOTE that no Board or SC&A work group
members ask what numerical value Dave Allen was referring to.

II. CATEGORIZING "INDIVIDUAL CLAIMS INTO
RADIOGRAPHER AND NON-RADIOGRAPHER"

DAVID ALLEN (DCAS) Pages 11 through 13

p. 11 line 19-21 and following pages...

The next thing on there was how we 19 would categorize
individual claims into 20 radiographer and non-radiographer.
Like I 21

p. 12 lines 1-15 Allen speaking

said during the full Board meeting, we would 1 start with the
telephone interviews. 2 So what I did was took a search of 3 all
the claims we had from GSI so far, and I 4 actually started with
the job title that's in 5 our claims database, which is the job
title 6 that the claimant puts on the forms when they 7
originally filed the claim. And I put a list 8 in my White Paper
of the types of jobs that we 9 would flag initially as
radiographers, or at 10 least potential radiographers. That list
is a 1l short list. I took quality control; film 12 reader;
radiographer, obviously; inspector; 13 anything that said
betatron; magnaflux 14 operator; metallurgy department; or x-
ray. 15

MCKEEL COMMENT: This passage by Allen is very confusing. First,
he states he "will start with the telephone interviews." but
then describes how he used the initial claims database instead.
In 2006, as an invited guest at a NIOSH DR Workshop, I asked the
question about whether the CATI interviews were SYSTEMATICALLY
MINED and the data collected into a database TO BE USED IN NIOSH
TECHNICAL DOCUMENTS?. That question was not answered YES
directly. The answer was "sometimes" and a CATI database was not
stated to be an accomplished entity.

In 2013, I ask the same question because ALLEN follows by
stating, in lines 18-21: "But as I said during the full Board
meeting, we would use the telephone interview, and I 19 did not
go through all 284 telephone 20 interviews as part of this
exercise...21" MCKEEL ADDED COMMENT: Why did Allen not use the
CATI interview for this "exercise." After all, he is supposed to
be justifying a dose that will affect possibly hundreds of GSI


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

steel making operations multiple GSI buildings during the
residual period that we amply documented. These buildings
included the old and new Betatron facilities and (at least)
buildings 8 through 10 and 5 through 6, where MCW uranium was
handled and transported. These business cycles caused uneven
waves of uranium dust resuspension of different magnitudes and
with uneven settling rates that the two TIB-70 D&D and RES-RAD
computer models cannot accommodate. NIOSH has not demonstrated
that either of these codes will model the uranium airborne
concentrations at GSI 1966-1992 with sufficient accuracy;

(c) The air resuspension factor (RF) used is arbitrary, in
agreement with SC&A [REF 1], and the 3/12/13 Munn PRS
presentation shows that resuspension factors as high as 10° m
have been shown to be realistic at other sites. Yet Dave Allen
chose 10° mTM* four orders of magnitude lower. How is this
arbitrary RF selection by David Allen and DCAS scientifically
defensible? Petitioners support SC&A the RF number is too low.

1

Please refer to my attached Draft white paper on use of TIB-070
at GSI for further analysis of this subject matter.

REF 1. SC&A; Robert Anigstein and John Mauro, Review of NIOSH
Estimates of Internal Exposures at GSI, April 24, 2013. 3 pages.

File: TBD6K_sca-gsiintexp-42413.pdf

ATTACHMENT: McKeel DW Jr. White Paper: “Why TIB-70 Use for the General

Steel Industries AWE Site Residual Period Is Scientifically
Inappropriate" <TIB-70_Residual_Period.pdf>June 19, 2013

Respectfully submitted,

[Sameel amactect, ho.

Daniel W. McKeel, Jr. MD Date

6/19/2013

Contact information:
Daniel W. McKeel, Jr., MD
GSI SEC-00105 co-petitioner

ATTACHMENT A: See page 8 ff.


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

From: Daniel Mckeel

Sent: Friday, June 21, 2013 9:57 PM

To: ocaswebupdates (CDC); Katz, Ted (CDC/NIOSH/OD); NIOSH Docket Office (CDC)

Ce: danmckeel2@aol.com

Subject: McKeel 6/18/13 and 6/19/13 discussion papers for 6/20/13 TBD-6000 work group meeting and
Docket 140

Attachments: Transmit_GoalsMemo_6.18.13.pdf; McKeel_TIB-70_GSI\_critiqu2.pdf, TBD6Kwg_Goals_

6.20.13mtg.pdf

Dear OCAS Updates, Ted Katz, and the NIOSH Docket Office,

| note the SC&A 6/11/13 memo concerning the DCAS David Allen June 2013 "Square function approximation" white
paper was posted to the DCAS website today, 6/21/13. DFO Ted Katz sent me a PA-cleared version yesterday, which |
received after the TBD-6000 WG meeting ended.

My 14 page white paper dated 6/19/13 that is a critique of OTIB-0070 as it applies to GSI was e-mailed to the entire TBD-
6000 work group including Ted Katz on 6/19/13. May | please request that this paper be posted to DOCKET 140 (GSI)
and as a discussion paper for the TBD-6000 WG meeting to make the record complete and accurate
Also, on June 18, 2013, | e-mailed a one page "Goals for the TBD-6000 Work Group" memo to the TBD-6000 WG,
including Ted Katz, that should also be posted as a Discussion paper to the TBD-6000 WG 6/20//13 meeting and to
Docket 140. Copies of both documents and the 6/18/13 goals memo cover e-mail letter are attached. Thank you.
Sincerely,

-- Dan McKeel 6/21/13 Friday

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


McKeel white paper: TIB-070 use at GSI

summarized the 5/28/13 GSI technical call, there is a precedent for WG technical call
summaries to be generated and sent to petitioners. To ensure full transparency, and to
improve the written record even further, I suggest that summaries (or better, verbatim
transcripts) of all Board technical calls be generated in the future. The cost would be
small compared to the overall costs of implementing EEOICPA 2000.

A Note About PRS Transcripts

During a recent PRS meeting, Chairperson Wanda Munn noted “an astounding” 25
instances of court reporter notations that “persons talking over one another.” Ms. Munn
encouraged the court reporter to indicate when this more than one person speaking was
difficult for the court reporter to capture.

That comment resonated with me because recently I have carefully reviewed the
ABRWH December 11, 2012, and March 12, 2013 transcripts and have noted several
serious transcription mistakes that are both obvious, and significantly change the meaning
of the testimony. I wonder whether there is a current Board policy as to when the Board
chair reviews these transcripts to correct both minor typos and more serious errors that
impact the meaning of the spoken words,

McKeel’s Scientific Objections to Use of TIB-70
for the GSI Residual Contamination Period

t Slide X, Finding 2, of Wanda Munn’s TIB-70 presentation to the full Board on
3/12/13, indicated that Rev 1 of TIB-70 used recalculated data from four surrogate sites

including “Blockson Chemical, Dow Madison, General Atomics and Simonds Saw.”
crate | Rea I

2  OTIB-0070, Section 2.5 Closed on July 31, 2012
references Sehmel 1980, Till
and Meyer 1983, Linsley OTIB-0070, Revision 1 recalculated the default

1978, and Healy 1971. Allof — source-term depletion rate during the residual
these references are (except _ radiation periods based actual data from 4
Healy 1971) to outdoor soil AWE sites (Blockson, Dow Madison, General
contamination, which involve Atomics, and Simonds Saw) rather than being
conditions with little based on literature sources where outdoor
resemblance to building measurements were preponderant.

surfaces, building uses, room

heights, and ventilation rates.

Further reference to TIB-70 Rev I indicates references to all of these sites except
Dow Madison, which is not mentioned in either the text or the references. Thus, the
resolution of this finding as written here is inaccurate.

7 John Mauro on 4/26/13 at the TBD-6000 work group mentioned that resuspension
rates (RF) had been determined to be as high as 10-‘ mat some sites, and others
indicated the RF rates could be even higher (10-'m').


McKeel white paper: TIB-070 use at GST

This paper is an elaboration of McKeel’s 4/26/13 WG concerns based on additional
research of the ABRWH Procedures Review subcommittee deliberations on TIB-70 and
of the Rev 1 OTIB-0070 document itself. That subcommittee, which is headed by Board
member Wanda Munn, reported their findings on TIB-70 Rev I at the March 12, 2013
ABRWH meeting in Augusta, GA [REF 1]. There are conflicts between the Rev |
document and what is reported under TIB-70 Findings in the 3/12/13 Procedures Review
subcommittee,

During my further delving into TIB-70 deliberations by the Procedures Review
subcommittee, I discovered information about the documentation of technical calls by
SC&A and NIOSH that differs significantly from what I was told by the Board
designated official that such meetings were not documented. The information I gleaned
indicates that was not an entirely true statement. Some technical call information has, in
fact, been “memorialized” within the BOARD REVIEW SYSTEM (“BRS”) that
chairperson Wanda Munn refers to sometimes as “our database.” I learned that, after
years of development, the BRS is still not fully functional nor is it fully populated with
white paper reports that are relevant to the Findings. In particular, the link to BRS given
in the 3/12/13 slide presentation on TIB-70 is not functional (not an active working URL
link). The presentation slide is thus misleading. | explain in more detail later in this paper.

Summary: Dan McKeel’s concerns about the scientific validity, appropriateness, and
defensibility of the use of TIB-70 for the GSI residual period have, in fact, deepened after
studying the TIB-70 rev 01 document itself [REF 3] and the Procedures Review
subcommittee handling of SC&A’s findings that are encapsulated in the 3/12/13 Board
presentation by Ms. Munn [REF 1].

It should be noted that TIB-70 Rev 00 [REF 2] was dated 03/10/2008 and TIB-70 Rey 1
[REF 3) was dated 03/05/2012. As a general comment, in the co-petitioner’s view, the
Procedures Review subcommittee (PRS) closed several findings based not on the
evidence, but primarily it seems from expediency.

A Note About NIOSH and SC&A Technical Call
Documentation in the Board Review System (BRS)

The slide on page 4 of chairperson Munn’s Procedures Review Subcommittee (“PRS”) to
the full Board on March 12, 2013, in Augusta, GA [REF 1), contains a link to the BRS,
which, upon testing by Dan McKeel on 4/28/13, was not functional (did not work), The
slide indicated that *...text...”° a full discussion of all 17 TIB-70 Rev 00 Findings and all
7 TIB-70 Rev | Findings (24 in all) would be found in the BRS. I wanted to read that
material and Was therefore disappointed the link to BRS did not work.

That experience led me to read transcripts of the 2011 and 2012 PRS meetings, where |
learned additional information about the status of BRS development and current
functionality. [ also discovered how some NIOSH and SC&A technical call information,
specifically e-mail between Marschke and Anigstein, was in fact entered into BRS.

Josh Kinman, had written in an e-mail dated 2/28/13 [REF 4] to Dan McKeel that
“as far as Lam aware technical call discussions are not tracked” [n addition to Steve
Marschke entering “the gist” of Bob Anigstein’s e-mail report of their technical call into
BRS, Marschke reported to the PRS members that *...Bob Anigstein had sent an e-mail
report of the technical call discussions to persons who had not been able to listen in to
the call...” Therefore, the true situation is that some technical calls, at least, are recorded
(memorialized) in two ways; by the technical call participants sending informational e-
mails, and by summaries of the calls being entered into BRS, Now, since someone


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

shooting 10 room at that point. They'd be in a control 11 room.
I gave it to them for the time in 12 between shots. And after
that, that's just 13 for the direct handling type of airborne.
14 I did also account for any 15

I did also account for any 15 contamination that would be
caused from that 16 airborne using the TBD-6000 techniques that
we 17 went through some months ago and, using those 18 settling
rates and settling time, came up with 19 a contamination value
of what it would reach 20 after such a time as to build up to an
21

p. 19 lines 1-21 ALLEN SPEAKING

equilibrium value and re-suspended that to get 1 an airborne
that I was intending to use for 2 the times, actually for full
time, which we're 3 using 3,250 hours a year. So my intent was
to 4 use that re-suspended airborne full time for 5 everybody's
employment, the airborne from 6 actually handling the uranium
for the time 7 that they would be in the shooting room 8 setting
up shots with the uranium, and then 9 using TBD or, I'm sorry,
TIB-9 for the 10 ingestion. And we also, I believe, agreed, 11
either during a Board meeting or a Work Group 12 meeting, that
we should use TIB-70 reduction 13 of the airborne levels during
the residual 14 period after the operational period stopped. 15
And I just put a footnote in there about that, 16 that we
intended to decrease that or using 17 TIB-70 values. 18 That is,
essentially, what the 19 White Paper says. I summarized some of
that. 20 I don't know if anybody wanted more detail 21

MCKEEL COMMENT: Dave Allen's commentary on TIB-70 use for GSI is
full of inexactitudes that prompted me to write a rebuttal white
paper on why I believe that it is NOT scientifically defensible
or claimant favorable to employ OTIB-070 for GSI intake values
during the residual period. This paper incorporates my comments
on the deliberations of the ABRWH Procedures Review subcommittee
(PRS) that has been evaluating NIOSH/ORAU OTIB-070 science and
SC&A's many related findings for several years. PRS Chair Wanda
Munn reported their final analysis of OTIB-070 to the full Board
during its 3/12/13 meeting in Augusta, GA. An early draft copy
of my paper is included to augment this analysis of the TBD-6000
work group 4/26/13 transcript portions that are related to TIB-
070 use at GSI. A few key points I make are as follows:

(a) I point out that neither Appendix BB nor the SEC-00105
NIOSH evaluation report mention OTIB-070, and ask why is TIB-70
rev 1 being invoked now, years later, by David Allen and DCAS?;

(b) I have objected previously to use of OTIB-070 at GSI
because the model is too simplistic. Multiple businesses leased,
power washed cleaned, swept, partly renovated, and used for


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

MCKEEL COMMENT: Co-60 sources cannot, using good science,
substitute for Ra-226 sources that are different strengths, are
shielded differently, and have a different radiation pattern.
Mr. Allen has no way to know these details, including when the
Ra-226 were leased and what are their calibrated strengths. NCC,
according to the same license documents that Dan McKeel obtained
from NRC in FOIA 2010-0012, NCC did not start leak testing and
calibrating survey instruments at GSI until 1962. There is no
real measured data about the GSI Ra-226 sources between 10/1/52
and 12/31/62, the agreed upon end of the GSI "radium era." Mr.
James Powers does not know these details, either, based on
multiple interviews Dan McKeel and John Ramspott have had with
him after he was interviewed by SC&A in 2007 and thereafter for
Dr. Anigstein's "three GSI interviews" white paper. Ergo, NIOSH
cannot reliably "adjust for differences between the Co-60 and
Ra-226 sources."

p. 10, Allen speaking, line 8

But, also, there's at least some 8 indication that some
shielding was added soon 9 before that August 1962 survey. So I
adjusted 10 those survey readings up to account for 11
additional shielding prior to that survey. 12

The indications, essentially, were 13 the, it was a map that
indicated 24-inch walls 14 and a notation that said shielding
added June 15 and July of 1962. And then the prior drawing 16 of
that room was in the AC initial application 17 that indicated
there were 16-inch walls. So 18 from that, I took it as eight
additional 19 inches of concrete block shielding and the 20
write-ups in those AEC documents indicated 21

p. 11 (ALLEN continues...) lines 1-3

mortar-filled, so I indicated or I took it as 1 eight inches of
mortar-filled concrete block 2 additional shielding added in
June and July of 3 1962.

MCKEEL COMMENT: GSI workers uniformly challenge the GSI license
document that: (a) the bldg. 6 concrete block walls were ever 16
or 24 inches thick; (b) the concrete blocks were filled with
mortar, first, because the AEC license application states they
were sand-filled, and (c) because two GSI workers observed the
structure being built and testified the concrete blocks were one
block, 6 or 8 inches thick, and were observed being filled with
“river sand," in 1955 when it was built, and (d) no living GSI
workers confirmed the 6 bldg. walls were 16 to 24 inches thick.
NIOSH has not yet accounted for the established fact (see [c])


McKeel white paper: TIB-070 use at GSI

2010
(vj

Meeting dates where TIB-70 was discussed (reverse chronological order)

May 21. 2013 (No agenda or transcript 4.29.13)

March 25, 2013 (Agenda, no transcript 4.29.13) — reviewed sets 10-13: SRS,
RF, LANL, but not GSI — next sites sets 10-13 decided upon; TIB-70 not on
agenda [see transcript, write Ted Katz]

February 5, 2013 (Agenda and Transcript, 2 white papers from SC&A);
TIB-70 not on agenda; Agenda BRS overarching issues and closing notes.
Transcript: pp 27 and 86-87. Marschke and Anigstein had a technical meeting,
Anigstein sent e-mail to everyone not on the technical meeting, Marschke then
entered Anigstein’s comment by e-mail into the BRS. Katz attended the meeting
(see page 86) and knew about the technical meeting and Anigstein radon issue
that was closed, [Note: The info RE: technical meetings is relevant to McKeel
being told by Ted Katz that discussion of TIB-70 “would not take place during
the technical call proposed by SC&A and DCAS” over GSI matters, It was
discussed according to the meeting summary. Mr. Katz stated emphatically to
McKeel that no previous technical calls about GSI have been held by the Board.

December 30, 2012 SC&A reply to NIOSH Responses
July 23, 2012 third discussion, issues resolved

January 5, 2012 second discussion with PRS

July 10, 2010 first discussion with PRS

; My review of the 2010 and three 2012 meetings that discussed

MCKEEL COMMENT:
TIB-70 in detail will be submitted later as an ADDENDUM to this report.

References

is)

Munn, Wanda. ORAUT-TIB-0070: Dose Reconstruction During Residual
Radioactivity Periods at Atomic Weapons Employer Facilities. Presentation of the
ABRWH Procedures Review subcommittee to the full ABRWH meeting in
Augusta, GA on 3/12/13 (transcript and PRS handout).

Guido, Joseph (2008) OTIB-070 Rey 00 document: ORAUT-OTIB-0070 Rev-00.
Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons
Employer Facilities. PDF 26 pages, date 03/10/2008

6


TBD6K_Goals_6,20.13mig.doc

GSI APPENDIX BB INTERNAL AND EXTERNAL DOSE ASSIGNMENTS
TBD-6000 Work Group of the ABRWH (6/20/13) Meeting
by
Daniel W. McKeel, Jr., M.D.
GSI SEC-00105 Co-petitioner
(June 18, 2013)

Goals of the WG for GSI in order to revise Appendix BB (Rev 0) for Battelle TBD-6000 (Rev 1):

To finalize an Appendix BB exposure matrix in three tables that would do the following:

1. Fully report the deliberations and final results of the technical phone call that transpired on May 28, 2013,
between NIOSH/DCAS participants David Allen and Jim Neton, SC&A participants Robert Anigstein and John
Mauro, and Board DFO participant Ted Katz, with TBD-6000 work group chair Paul Ziemer as a silent listener;

2. Resolve all 13 original SC&A Appendix BB findings, and in addition, would also resolve all SC&A SEC-00105
findings that were later transferred to the Appendix BB issues matrix (11/26/13 latest version);

3. In strict compliance with the Board's five surrogate data criteria and OCAS-IG-003 guidance (all sources must be
bounded with sufficient accuracy) pertaining to AWE sites such as GSI, assign three levels of internal, external and
occupational x-ray dose to the following GSI personnel: (1) to radiographers and (2) to non radiographers, both of
whom worked in the plant production areas, and to (3) administrative personnel (to be defined), who rarely visited
the plant production areas, for three eras: Oct, 1, 1952-1962: radium era of the AEC operational period); 1963-June
30, 1966 (cobalt era of the AEC operational period; and July |, 1966-1992, the residual contamination period;

4, Specify the specific established technical guidances (including SRDB numbers), transport code version numbers
and dates, and literature sources pertaining to any surrogate data, for the methods proposed by NIOSH to reconstruct
gamma and x-ray photons, beta (electron) skin doses, and neutron doses (of specified claimant favorable relative
biologic effectiveness [RBE}), for all three levels of personnel dose assignment in all three eras at GSI, in a revised
Appendix BB to Battelle TBD-6000.

5. Define GSI job categories to be included in “radiographer,” “non radiographer,” and “administrative” personnel.

Table 1: Gamma and X-ray photon exposure matrix for Item #3:

JOB CLASS Radium Era (1952-62) | Cobalt Era (1963-66) Residual Era (1966-92)

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

Table 2: Beta (electron) skin exposure matrix for Item #3:

JOB CLASS Radium Era (1952-62) | Cobalt Era (1963-66) Residual Era (1966-92)

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

Table 3: Neutron (RBE=20) exposure matrix for Item #3:

JOB CLASS Radium Era (1952-62) | Cobalt Era (1963-66) Residual Era (1966-92)

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

Technical Guidance and References:


McKeel TBD-6000 WG 4.26.13 transcript: OTIB-070 & Other Dosimetry

TBD-6000 GSI WORK GROUP MEETING ANALYSIS:
Selected Parts of the 4/26/13 Meeting Transcript

by
Daniel W. McKeel, Jr., M.D.,
GSI SEC-00105 co-petitioner
(June 19, 2013)

David Allen's review of external doses during the radium era and
job assigned doses occurs on pages 9 through 17. I address only
a few salient passages (numbers within transcript = line numbers;
Dave Allen's transcript quotes are italicized):

p. 9 line 3

Okay. Thanks, Paul. 3 Like you said, during the last Work Group
4 meeting, February 21st, I was asked to do 5 those three things
you just mentioned. It was 6 the give our details of the
external dose for 7 non-radiographers prior to 1963 and describe
8 how we would assign individual cases to the 9 different job
eategories, which are, 10 essentially, radiographer and non-11
radiographer, as well as the details on how we 12 would use the
data we already agreed to for 13 internal dosimetry, exactly how
we would use 14 it for dose estimating.

MCKEEL COMMENT: Allen omits mentioning the third GSI job class,
"administrative," that has been the focus of this WG.

David Allen's review of his white paper and internal inhalation
and ingestion intakes is on pages 17, 18, 19. He also mentions
“use data we already agreed to" without stating what that data
is. This omission of key numbers makes the record unclear and
confusing. I wonder why the Board members did not ask to clarify
this omission?

I. EXTERNAL DOSIMETRY DURING THE RADIUM ERA
PAGES 9 and 10 (DAVE ALLEN SPEAKING):

p. 9, line 21: From the hierarchy

p. 10, line 1: of data, the actual measurements are usually 1
considered better than any kind of modeling, 2 so I started with
the actual measurements from 3 the cobalt-60, but, obviously, it
has to be 4 adjusted to account for the differences 5 between
cobalt and radium and the source 6 strengths.

is ee


Memo to TBD-6000 WG Re: 6/20/13 meeting goals 6/26/13 8:44 AM

From: DanMcKeel2 <DanMcKeel

To: pl.ziemer <pl.ziemer@comeast,net>; paz7 <paz7@cdc.gov>; josiebeach <josiebeach@charter.net>;
Josie_J_Beach <Josie_J_Beach@rl.gov>; j-poston <j-poston@tamu.edu>; wimunn <wimunn@aol.com>; tmk1
<tmk1@cde.gov>; dka6 <dka6@cdc.gov>; jfn2 <jfn2@cdc.gov>; jmauro <jmauro@scainc.com>; anigstein
<anigstein@cs.com>

Ce: jwramspott < « ;danmckeel. >
Subject: Memo to TBD-6000 WG Re: 6/20/13 meeting goals
Date: Tue, Jun 18, 2013 3:38 am
Attachments: TBD6Kwg_Goals_6.20.13mtg.pdf (73K)

Dear Dr. Ziemer and all members of the TBD-6000 work group,
Attachment: <TBD6Kwg_Goals_6.20.13mtg.pdf> 53K

| have recently reviewed the 2/21/13 and 4/26/13 TBD-6000 work group transcripts and the 5/28/13
NIOSH-SC&A technical call summary that Ted Katz provided to me, and | honestly cannot fathom where the WG
stands on assigning final doses to any of the 3 personnel classes, during any of the three eras at GSI, for
internal inhalation and ingestion intakes, or for external gamma and x-ray photons, beta skin dose (electrons),
or neutrons of a defined RBE.

Attached is a memorandum (PDF file) about the type of progress, in the form of 5 specific goals, that | would
like to see as the GSI SEC co-petitioner by the end of the TBD-6000 WG meeting scheduled for June 20, 2013.

Thank you for your consideration. | would also appreciate getting a WG meeting agenda for 6/20/13 as soon
as possible. If NIOSH or SC&A will make a presentation at the June 20th meeting, | would appreciate getting a
copy of that file in advance as well, | am certain would like to have these WG 6/20/13 meeting
materials as well.

Sincerely,

- Daw McKee’ 6/18/13 Tuesday

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

http://mall.aol.com/37834-111/aol-6/en-us/mail/PrintMessage.aspx Page 1 of 1


McKeel white paper: TIB-070 use at GSI

3. Slide X, Finding 10, of Wanda Munn’s TIB-70 presentation to the full Board on
Fue 12/13 [REF 1), indicated that resuspension factors could be as high as “107 to 10° m’

10 NIOSH’s recommended RF of Closed on July 31, 2012
10° m*t is inappropriate. The
scientific literature indicates A footnote added to Table 5-1 indicates that a
RF values of 104to10*m? __ site by site analysis should be conducted to
for indoor activities involving establish the RF at sites where no post-
substantial industrial operational clean-up has been performed, rather
activities. than simply accepting an RF of 10° m7.

John Mauro should have indicated to the WG on 4/26/13 that Tesuspension factors in the
literature are 100-fold higher (10° m’') than the value he mentioned (107""').

NIOSH and he TBD-6000 WG, despite overwhelming proof that GSI buildings 5-7 were
heavily repurposed during the residual period, tentatively appeared to agree with the
claimant unfavorable decision, based on no real measurement data, that | x 10° m‘! was a
better RF number compared to | x 10°m'', NIOSH made no credible scientific defense of
this number they chose; thus a final upper RF value is yet to be decided upon,

A Digression to Explore Closed Findings
11, 12, 14 and 15 of the PRS TIB-70
Powerpoint from the 3/12/13 ABRWH Meeting

Question 1, Was NUREG-1400 used in Appendix BB Rev 0 (2006)? The issue in the
PRS Powerpoint was that NUREG-1400 used no quantitative data.

Questions 2: How was Finding 01 of TBD-6000 resolved by PRS, NIOSH and SC&A?
This finding was that TIB-009 ingestion doses were too low/claimant unfavorable.
This was a circular unresolved argument in the PRS TIB-70 review on 3/12/13.

4. Dan McKeel’s basic objections to use of TIB-70 are:

« First, that no air sampling of any kind was ever performed at GSI until the very end of
the residual period in only the Old and New Betatron buildings [1993 FUSRAP Old
Betatron Building report. No air sampling of individual workers or of the rest of the
uranium transport pathway was ever performed;

* Second, SEC-00105 petitioners and GSI site expert have provided
ample evidence that multiple companies leased space at GSI after it ceased
Commonwealth Castings Division operations in 1973. These companies conducted
various types of steel making businesses, including pickling in acid. No air

sampling —breathing zone, general air, or process (the HASL triad)—for uranium was
ever done during these operations at 1417 States Street in the old GSI plant buildings to
our knowledge. One cannot say, absent any air sampling data, that resuspension rates |
were 10° m', The resuspension rates might have ranged between 10° and 10° per m'
as the literature and the Finding 10 notation and John Mauro’ s 4/26/13 WG comment
indicates. Viewed in this light, petitioner contend that 10° or 10° m’ is not scientifically
defensible as a GSI RF value, the selection of this value is too arbitrary and, on the face,
not the most favorable scenario.



McKeel white paper: T1B-070 use at GSI

we

Sharfi, Mutty (2012), OTIB-070 Rev 01 document: ORAUT-OTIB-0070 Rev-01.
Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons
Employer Facilities. PDF 520 KB (24 pages). date 3/05/2012

4. Kinman, J. E-mail to Daniel W. McKeel, Jr. (2/28/13) stating that NIOSH and
SC&A technical calls are not in any way tracked. The e-mail is reproduced below:

<quote>
Sent: Thu, Feb 28, 2013 2:02 pm
Subject: RE: GSI technical meetings

Hi Dan:

At this time and after discussing this anong DCAS staff members, I can
inform you that we do not have records of such calls. Also, 1 am not
aware that we track such calls or meetings. As explained to me, the only
calls between NIOSHISC&A would be worker interviews. I think you
were on those calls, according to Mr. Allen. If I am able to find any
records later, I will let you know. At this time we have none because we
do not record or track such meetings that do not involve worker
interviews.

Josh
<end quote>