McKeel

EXHIBIT 3

GSI SEC-105 talk to
ABRWH in Knoxville:

McKeel Letter referenced
in 12.11.12 ABRWH talk:
SEC Co-petitioner Resigns
from Participating in
11/28/12 TBD-6000
Work Group Meeting

12-11-2012


also reviewed dose records from an individual part time radiographer and prorated it to full time. Based
on the assumptions used for prorating the dose, the range developed was approximately 9 R/yr to 20
R/yr. Lastly, for most of this the time period under evaluation, the regulatory dose limit was 3 rem per
calendar quarter or essentially 12 rem per yr. Based on a statement GS! made to the AEC that no one
had exceeded the annual limit and the average was below 25% of that !imit, the maximum dose can be
established as falling between 3 R/yr and 12 R/yr.

If the NIOSH model is revised to assume one radiographer received the entire dose from the “fishing
pole technique” and the SC&A estimate of the exposure during the shot in the radiography room was
added, the new estimate would be 5.707 R/yr.

The dose estimate for other workers from radium radiography inside the radiography room was.
developed by SC&A. The result (2.09 R/yr) is bounding compared to estimates for radiography outside
the room (1.98 R/yr inferred fromm SC&A review, 1.35 R/yr NIOSH). NIOSH did not develop an estimate
for radium radiography inside the room. NIOSH agrees with the SC&A estimate for exposure to non-
radiographers from radium radiography.

NIOSH developed an exposure estimate for others from St. Louis Testing radiography. The estimate was
1.34 R/yr which would not be the bounding scenario given 2.09 R/ye exposures from radium
radiography. However, the NIOSH estimate was based on assuming the individual was near the
boundary only 50% of his workday. SC&A disagreed with applying that factor. If 100% occupancy is to
be applied, the St. Louis Testing exposure estimate becomes the bounding dose at 2.77 R/yr in the
radium era. However, during the interview with the former Administrator of St. Louis Testing, the
Administrator indicated this work occurred in the mid or early 1960s. He then recalled that it started
while they were working on the St. Louis Arch. SC&A noted that construction of the Arch began in 1963
which would be during the cobalt era.

This is a working document prepared by NIOSH or its contractor tor use in discussions with the ABRWH or its
Working Groups or Subcommittees. Oraft, preliminary, interim, and White Paper documents are not final NIOSH or
ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This
document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act 5 USC §552a and has been cleared for distribution.

6


Comment an McKeel TBD-6000 2/21/13 WG Meeting

Page 1 of 18

Note 1: Dr. Ziemer had announced during the 2/7/13 Board teleconference work group report on
TBD-6000 that a main agenda item for the 2/21/13 meeting would be resolution of Appendix BB
open matrix issues. As it turned out, that goal was not addressed during this meeting.

Note 2: The entire discussion revolved around two white papers that addressed unresolved
internal and external bounding doses for GSI workers during several time periods spanning Oct.
1, 1952 through December 31, 1982. There were many points of disagreement, net all of which
were addressed during the meeting. At the end, Chairman Ziemer advacated NIOSH prepare
another white paper, the third in this series, to address unresolved bounding doses for Layout
workers and other matters:

{a) [Attachment C] Dave Alten and OCAS, dated 2/4/13, GSI Dose Estimation
Comparison, August 2012, 7 pages. Dr. Ziemer chose not to announce this key paper to the full
Board during the February 7 conference call.

(b) [Attachment D) Robert Anigstein and John Mauro, SC8&A, Inc., dated 2/12/2013,
“SC&A Response to NIOSH Report: “GSi Dose Comparisan”, 11 pages.

1. Member Poston has missed many TBD-6000 work group meetings and discussions of
GSI matters as he did much of this one teaching two classes at Texas A&M.

2. Bob Barton from SC&A participated in this WG meeting for the first time. Dr. Anigstein
from SC&A joined the discussion at 9:08 AM ET.

3. All three members of the SEC-00105 GSI team participated in this WG meeting: primary
SEC petitioner a” , co-petitioner Dan McKeel, and main GS! site expert

4. Dr. Ziemer announced the key goals at this meeting for the GSI site would be to decide
(a) “final doses for both the “active (i.e. operational AEC contract period) and the residual
periods,” and (b) to decide “what assumptions should be used for final doses.” The petitioners
contend these models and assumptions should have been finalized before the full Board voted
9 to 8 to deny SEC-00106 on December 11, 2012, at the Knoxville, TN, ABRWH meeting.

5. As Dr. Ziemer admitted later in the 2/21/13 WG meeting, the GSI residual period doses
and assumptions were not discussed on 2/21/13, Thus, another key agenda goal was not met.

6. Dave Allen also stated a goal was to “Revise Appendix BB and move on.” Yet this has
not materialized 5.5 years after Appendix BB Rev 0 was released in June 2007. This transcript
provides an excellent insight into why this task, to revise a 13 page document, has taken so
long. There have been, and still are, many variances between NIOSH and SC&A dose
assignments. Key issues are discussed over and over without being resolved systematically.

7. Even though Dr. Ziemer initially states dose assignments will be “binary, radiographers
plus others at the site”, he himself later introduces a third category of office workers to further
complicate the task of signing three tiers of doses during two main time “era” periods.

8. Dave Allen stating "! will not read the whole thing,” that is his 2/4/13 focus white paper, is
his standard way of proceeding. He did not prepare a concise handout so his main points could
be followed or tracked systematically. This leads to confusion and delays in bringing final dose
decisions to closure. DCAS subtly delays, rather than expedites, the detiberative process.

-2-


SOURCE FILE: MCKEEL_TBG6Kwg_2.21.13.pdf

TABLE OF CONTENTS OF DANIEL W. MCKEEL, JR., M.D.
GSI SEC-00105 CO-PETITIONER SUBMISSION TO NIOSH
AND DOCKET 140 AND THE ADVISORY BOARD ON RADIATION
AND WORKER HEALTH (ABRWH)

- March 10, 2013 -

Doc Pages Number of actual pages

1-24 1-18, Attachment A title page

24-:

48

49

50

51

52-)

57 -;

s9-

62-1

65-

72-

McKeel transcribed notes on 2/2/13 TBD-6000 work group meeting.

47 1-23
NcKeel comment on above 2/21/13 TBD-6000 transcript.

1-2 Attachment A
McKeel analysis of EEOICPA compensation paid at 11 AWE sites with
and without SECs. {spreadsheet spreads over to 2nd page)

1 Attachment B (part of)
McKeel cover letter dated 12/14/12 to ABRWH chair Melius and DFO
Ted Katz, all Board members and Docket 140 on following document.

1 Attachment B (part of)
MeKeel ABRWH presentations 9/19/12 and 12/11/12 on GSI SEC-00105
File index documentation of 7 included files.

1 Attachment B (part of)
List of McKecl EXHIBITS 1-7 files (December 14, 2012)

56 1-5 EXHIBIT 1
McKeel GSI SEC-00105 talk to ABRWH Knoxville, TN on 12/11/12. Text.

5B 1-2 EXHIBIT 2

McKeel ABRWH presentation on GSI SEC-00105 12/11/12. Slide.
SLIDE comparing SCSA and NIOSH 2008 and 2012 modeled external
Betatron and Other GSI workers doses

61 1-6 EXHIBIT 3
McKeel letter resigning from direct participation in 11/28/12
TBD-6000 work group meeting, read inta record by DFO Ted Katz.

64 1-3 EXHIBIT 4
McKeel PUBLIC COMMENT to ABRWH, Knoxville, TN, on 12/11/12 after
GSI SE#C-00105 session. He was the sole commenter.

FL 1-7 EXHIBIT 5

McKeel Bibliography of 38 papers submitted to ABRWH and TBD-6000
work group 2007-2012. From Docket 140 GSI on

OCAS website (www.cdc.gov/niosh/acas).

79 1-7 EXHIBIT 6
McKeel talk (projected slides) to the ABRWH, Denver, CO, 9/19/12.


8) (Ref 6 pg 3}

h) Vaiue varies by year (ref 5 pg 28)

i) SC&A indicated bounding dose would be from radium source work (ref. 6 page 2 & 3)

j) New Betatron building estimate used for all years except half the value for 1966 (ref 4 pg 5)

Others — Radium Era
SCRA [ NIOSH

Ra-226 sources in radiography room 2.087 R/yr * ~~ “N/A?
Ra-226 source outside radiography room 1.978 R/yr* 1.353 Réyr ®
St. Louis Testing sources 2.771 Rfyr ® 1.336 R/yr’
Betatron Operator 1.35 R/yr ® 0.620 R/yr”
Layout Man N/a! 4.483 R/yr!

a) 25% of time near door of radiography room (ref 1 pg 7}

b} NIOSH did not develop an estimate of Ra sources inside the radiography room

c) Inferred from 0.07 mR/shift for an incursion plus 2 mR/hr at boundary (ref. 1 pg 6}

d} 0.567 R/yr walking through area plus 0.786 R/yr at the boundary {ref. 3 pg 16 & 17)

e) Assumes full time next to boundary for all workers (Ref 2 pg 10}

f) Assumes half time next to boundary for non-radiographers (Ref 3 pg 22)

g) Assuming dose for operator may be applicable to others (Ref 6 pg 3}

h} Value varies by year (ref S pg 28). Value intended for those routinely working in betatron

building.
i} SC&A indicated bounding dose wauld be from radium source work (ref. 6 page 2 & 3)
]) New Betatron building estimate used for all years except half the value for 1966 {ref 4 pg 5}
Radiographers ~ Cobalt Era
SCRA NIOSH

Co-60 sources in radiography room 1.170 Rfyr® 1.270 R/yr?
Co-60 source outside radiography raom N/A® 0.868 ©
St. Louis Testing sources 2,771 Rfyr® 2.671 R/yr"
Betatron Operator 1.35 R/yr ® 0.557 R/yr”

This is a working document prepared by NIOSH of its contractor far use in discussions with the ABRWH or its
Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or
ABRWH (or their technical support and review contractors} positions unless specifically marked as such, This
document represents preliminary positions Laken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act 5 USC §552a and has been cleared for distribution.

2



Daniel W. McKeel CsI SEC co-petitioner bibliography 12/8/12

« Comments from Daniel W, Mickeal Jc, M.D, regarding the agenda for the August 28,
Mecting of the Advi ad's Work Group on TBD 6000
{August 24, 2012)
3. POF 54 KS (3 pages)

C from Danie! W. iy H
Model {or the Calculation of Uranium Intakes af GSI
(August 5, 2012}

POF 9 MB (28 pages)

r)
‘

. ts from Daniel WY, Met regarding neral Steel tnd
Saecial Exposure Cohort Petition-00465
(July 26, 2012)
gy. PDF 589 K8 (44 pages)

. aniel W. McKee! Jr, M0. regarding the Genocal Steel Industries
Spaciat Exposure Cohort Patition-807 a
(July 10, 2042)
gy. POF 7 MB (24 pages)

. aniel W. ivicKer .D. on David Allen DCA! Dated June
208 2 te the TBQ-6090 Work Group of the ABRWH in Response to the SCBA
Discussion Paper Update on GSI Intake Doses

(June 13, 2042)

<f,. POF 439 KB (6 pages)

« Comments from Oaniel W, McKeel, Jr, M.0.0n SC&A Discussion Paper dated 5/30/12

"Update of "Reviews o('Si fi r Atomic Weapons Emofoyers That Worked
i AG Thorium Metals - dix BB; General Steci | des" Battelte-TBN-

6000, Anoendix BB." Occupational Internal Dose
(Sune 2, 2042)
4. PDF 7 MB (26 pages}

« Comments from Daniel W, McKeel, Jr, M.D. on SCBA Di

Giles “Undate of “Review of ‘Site Profites for Atom ons Employers That Wor
Uranium az ium Metals - Appendix BB: Geneval Steel Industries” Batielle-T

6000, Appendix BB." Occupational Internal Rose
(dune 1, 2012)
3 PDF 7 MB (26 pages}


2008 & 2012 Models Disagree

COMPUTER MODELED ANNUAL PHOTON DOSE
DURING GSI COVERED PERIOD 1953-1966 (Rem/YR}
DATA 2008 2012
SOURCE BETATRON BETATRON
1.0-6.3 (App BB)

NIOSH ND? (SEC ER) 0.2-.62 var.
SC&A mcnpx 12.4 - 13.6 4.35

2007-2008
DATA SOURCE OTHERS 2012 LAYOUT

1.73 (App BB)
NIOSH 0.417 [note 1] 1.02-2.03

SC&A menpx {see note 2] 9.20
Note 4; Annual dose assigned to only 1 of 3non-Betatron worker
exposure scenarios in SEC-00105 SEC evaluation report.

Note 2: SC&A review of Appendix BB, 4/21/08 Betatron doses
bounded layout men and Co-60 operators which in tum bounded
chainmen and all other workers. No actual values given for this
large subset of the GSI work force.

? ND = not done; no annual dose values given in SEC ER



McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 12 of 18

MUNN
[REDACTED] “Reasonable assertion.”

[REDACTED]

JWR main Bldg 6 finishing room, heavily occupied. Dose rate 1 meter from wall -- how
likely? JWR - Yes, people were working near the wall.

ANIG “Walls were thick” - was much thicker -- 16 to 24” thick filled -- than the door
hollow 2 1/8” steel thick.

[Dan McKee! note to self] Number is lower

MAURO
Strategy - we are not talking - NO, NO - talking about wrong thing. | didn’t hear
this, All workers triangular distrib.

ANIG Not at all what talking about.

MAURO
Get me a line. | apologize.

(MCKEEL NOTE TO SELF 11:10 AM CST
- | need this part of the transcript for my appeal]

PLZ fish pole fs controlling dose for radiographers + Betatron operators

ANIG report Oct 2011 Update on Sealed sources Sep/Oct. NIOSH Betron report next
OBE no detailed info outside “2.08 not supposed to be bounding

{McKeel -- INCONSISTENT: John Mauro now agrees with Bob Anigstein}

PLZ lam understanding triang. distrib. apply to everyone.

ALLEN
Credible for layout

-16-


Table J. Annual Doses to Betatron Operators

Exposure Neutron dose Beta dose to skin (rads)
Year oe AR) (rem) Hands andforearns Other skin

SC&A* DCAS = SC&A DCAS SC&A DCAS SC&A OCAS
1953-1957 1.35 0.734 0.48 0.050 33.4 25.9 6.27 2.27
1968 1.35 0.734 0.48 0.050 32.1 25.9 6.22 2.27
1969-1960 1.35 0.734 0.48 0.050 30.9 25.9 6.18 2.27
1961 1.35 0.763 0.48 9.056 34.2 29.5 6.30 247
4962 1.36 0.702 0.48 0.043 27.2 218 6.04 2.04
1963 4.35 0.586 0.47 0.019 13.9 7.0 5.56 1.23
1964 1.35 0.558 0.46 0.013 10.7 35 5.45 1.03
1965 1.36 0.654 0.46 0.012 10.2 3.0 §.43 4.00
1966° 9.68 0.275 0.23 0.006 48 2.4° 2.71 0.97°

Source: Anigstein and Mauro (20112)
Note: SC&A valucs from Anigstein and Olsher (2012)

* Maxima exposure. assuming hypothetical 30-kcV residual radiation from betatron behind operator's back
> uring contract period: January I-June 30

“As tisted by Allen (2012)}—should be prorated for 6-months of exposure in 1966 for consistency with exposure to
photons and doses frum neutrons

‘able 2. Annual Doses to Layout Men

Exposure Neutron dose Beta dose to skin (rads) _
(Ry - fem) Hands and forearms = Other skin
SC8&A DCAS SC8&A DCAS SC&A DCAS SCBA DCAS
9.20 4.483 0.46 0.148 4.20 1.02 2.45 0.54

Source: Anigstein and Mauro (2012)
Note: SC&A values from Anigstein and Olsber (2012). See text for applicable periads.

We note that Allen (2013) agreed to accept the SC&A estimates of doses to the skin. However,
there is disagreement on photon and neutron doses.

3 Areas of Agreement

NIOSH and SC&A agrce that the layout man represents the bounding scenario during the
operation of the New Betatron (not during the entire “Cobalt ra,” as stated by Allen, 2013). As
Allen points out, both groups agree that radium radiography constitutes the bounding scenario to
radiographers during the Radium Era.

Response to “GS] Dose Fstimation Comparison” 4. SC&A —February 12, 2013

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has nol been reviewed by the Advisory Board on Radiation and Worker
Llealth for factual accuracy or applicability within the requirements of 42 CFR 82.


References

Allen, D. 2011. “Battelle-TBD-6000 Appendix BB General Steel Industries: Dose Estimates for
Portable Radiography Sources.” ht(p://www.cdc.gov/niosh/ocas/pdfs/dps/de-gsidpradsrc08 11.pdf

Allen, D, 2012. “Battelle-TBD-6000 Appendix BB General Steel Industries: Dose Fstimates for
Betatron Operations.”

Allen, 2. 2013. “GSI Dose Estimation Comparison.*
http:/Avww.cdc.gov/niosh/ocas/pdfs/dps/de-gsidec-0112.pdf

Anigstein, R. 201 Ja. “Review of NIOSH Report on Portable Radiography Sources at GSI-
August 2011.” http://www.cde. gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsi-portradsrc-091511 pdf

Anigstein. R. 2011b. “Update on the Use of Sealed Radioactive Sources at General Steel
Industries.” http:/Avww.cde. gow/niosh/ocas/pdfs/dps/gsidp1 0201 Lpdf

Anigstein, R., and 3. Mauro. 2012. “Review of ‘Addendum to Dos¢ Estimates for Betatron
Operations White Paper’.*

Anigstein, R., and R. 11. Olsher, 2012. “Response to ‘Baltelle-TBD-6000 Appendix BB General
Steel Industries: Dose Estimates for Betatron Operations’.”
hitp://www.cde.

Nuclear Regulatory Commission (U.S.) (NRC), 2009a. “General Steel Industries Byproduct
Materials License for Cobalt-60 Sealed Source (Budd Company Madel 41706) not to exceed
1 curie, whandwritten notes.” ADAMS acquisition number ML093451452.

Nuclear Regulatory Commission (U.S.) (NRC). 2009b. “Leiter to James Mason from L. A.
Kicber Regarding an Area Radiation Survey That Was Made of the Radiographic Exposure
Facility in Granite City, Ilinois,” ADAMS acquisition number ML093412940.

S. Cohen & Associates (SC&A). 2008. “Review of ‘Site Profiles for Atomic Weapons
Employers That Worked Uranium and Thorium Metals - Appendix BB: General Stee]
Industries,” Battelle-TBD-6000, Appendix BB, Rev. 0.”

ittp//www.cde.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsisp-rL_pdf

S. Cohen & Associates (SC&A). 2012. “Issue Resolution Matrix for SC&A Findings on
Appendix BB to TBD-6000." Second Update: Fuly 28, 2012.
http://www.cde.gav/niosh/ocas/pdfs/abrwh/scarpts/sca-apxbbim-r2.pdf

Ziemer, P. 2013. TREE ccomeas net> “FW: Products for TBD-6000 WG” February 4,
2013, personal e-mail to Robert Anigstein, SC&A, Inc., CC: John Mauro, John Stiver, Ted Katz.

Response to “GS] Dose Estimation Comparison” -10- SC&A —February 12, 2013

NOTICE: This report has been reviewed tor Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


Daniel W. McKeel, Jr., MD

General Steel Industries (GSI)
SEC-00105 Co-petitioner
September 19, 2012


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 6 of 18

1.

Dr. Ziemer says *...already have,” “All post DR will include that -- can’t remember figure.”
Allen then fills in “65 hours” decided upon at the SC&A 10/9/07 outreach as a consensus
number of average hours worked per week” at GS!. NIOSH has promised this figure will

be used in Appendix BB, Rev 1, when itis finally released. Rev 0 states 46 hours.

After a comfort break, site expert . Somments the full Board needed
accurate dose information, including the data in the Allen & SC&A Feb. 2043 papers, at
their 12/11/12 meeting prior to the final SEC-00105 vote. “What was trying to be sold"
refers to Dave Alten alleging erroneously to the Board on 12/11/12, before the GSI SEC
final 9 to 8 vote to deny, that all workers would be assigned 12 to 15 REM total dose.

Dr. Ziemer states here that Layout man includes all other GSI workers than
radiographers.

_ hotes a logical absurdity -- how could the Layout men, who never wore
badges, get the highest assigned dose? Dr. Anigstein agreed that “workers in finishing
bldgs. (all but the two Betatron buildings) never wore badges.

Mr. + __ also reiterated: - testimony that radium sources were used out
in the plant beyond the 6 Bldg. radiography room. Mr.1 ‘also noted that a radium
source was Stolen from 10 building.

Bob Anigstein noted that SC&A disregarded Mr. - affidavit because it was
“inconsistent” with other workers. Dr. Anigstein did not elaborate in what way the _
information was incansistent, ar whose information conflicted with his. For the record,
Dan McKeel was a NIOSH and Board silent observer to the joint SC&A and NIOSH
interview Dr. Anigstein referred to. Several added aspects of Mr. information were
subsequently suppressed, including the fact that Ra-226 NDT shots outside the
radiography room were often left unattended and were not necessarily always roped off.


This tanseript of the Advisory Board on Radiation and Worker Health, Board Meeting, has baen
caviewed (or concems under the Privacy Acl (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. Tha transcript, however, has not been reviewed and
certified by ihe Chair of lne Advisosy Board for accuracy al this lime. The reader should be
cautioned that this tanscnat is for information only and is subject to change.

morning around 8:30. 340

(Whereupon, the above-entitled

matter went off the record at 6:26 p.m.)

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS



Comment on McKeel TBD-6000 2/21/13 WG Meeling

Page 13 of 18

1.

John Maura explains why his positian on a GSI SEC for the first 10 years 1953-62 has
changed over time. He states he has been “struggling for 5 years about “non
radiographers in “aff normal” conditions.” And further: “Very difficult fo assign.. can
assign 12 to 15 plausible upper bound--retated to SEC decision,” And further, “Jim
Neton strategy can have a hard time placing doses on individuals. Assign
distribution to ALL claimants - at time of particufar ciaimant, you can't do this.
(add emphasis)

«+ McKeel comment: These very important sentiments should have been shared with the
Board before the SEC vote on Dec. 11, 2012, at the ABRWH Knoxville meeting. The
WG mission has now tured to revising Appendix BB. The remarks about the triangular
distribution now supported by the WG and NIOSH are highly germane to individual! DR
done using a future revision of Appendix BB.

« The SEC has been denied by both NIOSH and the full Board, with the concurrence of
the TBD-6000 WG and SC&A, and is now in the hands of NIOSH/HHS for a final
decision. An administrative appeal after HHS reaches a final decision is the only remedy
available to the petitioners to reverse this SEC denial. This work group is not able to
modify its 11/28/12 vote to deny SEC-00105. The lone dissenter was Member Beach,
who voted for an SEC for the first ten years 1953-1962. The WG vote was 3 to 1 against
this limited SEC.

Dr. Ziemer’s comment “can we separate out who is a radiographer?" McKeel’s answer is
“no.” The chairman's assumption that one can assign job categories for all GS! workers
has not been substantiated by 5 years of NIOSH and DOL completed DRs. All GS!
completed DRs to date except the original 4 (see PER-24) were done with the June
2007 13 page Rev 0 of Appendix BB usng 2 dose levels, i.e., Betatron and Others.

Dave Ailen’s comment is incompletely captured and is thus not 100% interpretable. He
seems to be saying, in a very circuitous way, that if we (NIOSH/DOL) cannot correctly
identify which individual workers are radiographers, then it may not be possible to assign
individual radiographers the highest doses.

+ McKeel comment: Dave Aifen on 12/11/12 indicated to the full Board that all GSf
radiographers and non radiographers were assigned the highest dose scenario, a fact
we dispute under Appendix BB Rev 0 based on personal experience reviewing
adjudicated GSI claims. Mr. Allen here retracts his incorrect assertion made to the
ABRWH before they voted on GSi SEC-001085.

There was a short break and again Dr. Postan did not answer the DFO's “are you
online?” query, This indicates that Member Poston missed major parts of the FBD-6000
WG deliberations an 2/21/13.

Dr. Ziemer again directly asked: “Can we distinguish radiographers vs non
radiographers?” Then he added: “SEC differs from DR -- assigned highest dose Betatron
or jayout depending on the years. Appropriate to have a method for “two dose levels DR,
nuclear vs. office workers. Hear from SC&A on this -- possibte to establish who worked
where sources were.”

+ McKeel comment: This is a very odd suggestion, to establish a third category of GS!
jobs called office workers. “Nuclear” is a new Class definition, and it is unclear who that
would include except that 97% were unmonitored and only 3%, classical radiographers,
were dadged only between 1963 and June 1966 of the covered period and from July 1,

-16-


not use once, was 9.2 REM/year compared to 0,7 REM per year
for Betatron operators, In 2008, SC&A’s assigned doses for
Betatron operators in the SEC ER were 10-fold higher than
for other GSI workers. I have shown these comparative data
to the Board in September.

3. Mr. Allen repeatedly referred to NIOSH always
using the scenario that gave the highest assigned dose in
their dose reconstructions. This is simply NOT TRUE based
on GSI DRs I have seen. The non-radiographers often get the
lower of two doses Appendix BB specifies. Everyone is NOT

assigned the Betatron operator dose,

4. David Allen has replied by an e-mail I have seen
to a GSI Docket 140 contributor, who I won‘t name because
it will be redacted from the transcript, that the future
Rev 1 revision of Appendix BB will result in lower assigned
total dose for many claimants, so there won‘t be that many
reopened denied claims that will be reworked and approved
for compensation. Allen’s reason: NIOSH will be doing far
more “best estimate DRs in APPENDIX BB.”

There are many other points I would like to have added
to or to have rebutted, however I will reserve those for a
later time.

My final comment is, it is a shame that GSI claimants
have to wait perhaps weeks to learn the outcome of today’s
final vote. My question to Mr. Katz and the Board that
maybe they can answer now, is how will GSI claimants be
informed of the Board‘s final SEC-00105 decision? I want
to sincerely thank all members who did do the right thing

and vote NO to NIOSH‘s ill conceived recommendation to deny


Comment on McKee! TBD-6000 2/21/13 WG Meeting

Page $ of 18

1.

10.

Dr. Neton and Dave Alten both acknowledged the extended 10/1/52 to 12/34/52 GS}
covered period “will go into all DR.” They did not indicate when this change will occur.
Must Appendix BB be revised first? Dr. Ziemer added “We have agreement on that.”

Dave Ailen and SC&A then entered a colloquy on dose assigned to Layout personnel in
the radium era. Considered were 3-12 REM = 3.573 REM median point of fishpole for
the Ra-226 source. SC&A proposed 9-20 REM and Dr. Anigstein brought forth 9.69
REM. Dave Allen said “convincing to some people, for sure. Records we don’t have.
Made a couple of time. Made by Ripley started 1953.”

Dr. Ziemer added “never used limits -- the letter sets limits.”

Member Beach added ~9.69 REM 1952-1962 could be 5 to 15 to 1955; 3 REM/yr post-
1953. McKeel regarded this recitation as obscure and indecisive. Was it a proposal? A
bit later, she stated “Go w/12 and 15 agree with SC&A." The two statements conflict.
Dr, Ziemer asked “Need work group direction” a second time.

Member Munn added a cryptic “No evidence for regulatory boundaries.”

Member Beach noted “evidence could be higher,” which | could nat fully understand.
Or. Zeirner's returned to distance along the radium fish pole: “5 ft vs 4 ft.”

Dr. Neton offered a Solomonic compromise, a triangular 9--> 12-->15 dose distribution,
used elsewhere by NIOSH, to resolve “different opinion 3; SC&A 9." He noted such a
distribution could be input into IREP. He added he didn't believe everyone should get
that (high a} limit.

Dr. Neton of NIOSH aise alluded to “3.67” dose referred to “two radiographers”
presumably sharing Ra-226 NDT duties in the Bldg. 6 radiography facility. This last point

was not clear. SC&A had favored twice that dose being assigned to a single Bldg. 6
radiographer. As far as | could tell, this difference was not resolved.

-12-


Daniel W, McKeel GSI SEC co-petitioner bibliography 12/8/12

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

BJBLIGGRAPHY OF MCKEEL PAPERS
Submitted to the ABRWH

General Steel Industries (GS
NIOSH Docket 140

Comments Received:

= Commenis from Daniel W, McKeel, Jn MD. recarding GS! beiatron testi
(November 19, 2012}

, PDF 2 MB (13 pages)

« Comments from Daniel W, McKeel, Jr, M.0. regarding NOSHADCAS: Evatuation of
AdgitionaLAi Samote Dsta Applicable to GSI
(November 10, 2012)
jh PDF 4 MB (20 pages}

Addendum 1
(November 10, 2012}
if. PDF ¢ MB (4 pages)

Addendum 2
{November 26, 2012)
‘4. PDF 6 MB (8 pages}

« Comments from Danigl W, McKeel, Jr, M.D. recarding his presentation at Ine
September 19, 2012, Advisory Soard meeting
(September 21, 2012)
i. POF 3 2 (44 pages)

« CoPetitioner Daniel Wi, MeKeel, Jr, MD Presentation: General Steel Industries SEC
Petition 165
(September 18, 2012)
b POF 437 KB (7 pages)

» Andotated transcribed notes submitted by Dastigl W, McKecl, Jr M.D. from the August
28, 2012, Meeting of lhe Advisory Board's Work Grous on TBD -6000
(September 2. 2012}
am PDF 897 KE {43 pages)

Comments from Daniel W MeKeel, Jr. M.O. regardin, SH; Use of Surrogate Dala
a lo SC&A Revissy Dated July 16, 2042
{August 26, 2042)

gy POF 4 MB (16 pages}
Addendum

(August 26, 2012)
dg. BOF 7 MS (6 pages)


DWM_9.19.12_obrwh_p39-S3.txt
INTRODUCTION:

Daniel W. McKeel, Jr., M.O., the GSI SEC-@8185 co-petitioner, addressed the
ABRWH 86th meeting in Denver, Colorado, on September 19, 2812. Here is his
testimony that runs from page 39 line 7 to p55 line 13. There was an
accompanying slide presentation that is attached to this transcript excerpt.

TESTIMONY OF DR. MCKEEL, PAGES 39-53;
(QUOTE)

p.39

1 were -- the highest was 11 dpm per cubic 2 meter, which sort of fails into the
same range 3 of the limited samples from Leblond and I 4 would think also
reflects a low-exposure 5 situation based on the job task. 6 CHAIRMAN MELIUS:
Any other 7 comments or questions at this point? 8 (No response.) 9 CHAIRMAN
MELIUS: Okay, Let's 10 hear from the petitioner, see if we have any 11 questions
for them, I'm not sure if it's one 12 or two people speaking. And then we will
come 13 back and have further discussion. So don’t go 14 too far away, Dave. 15
OR. McKEEL: Hello, Dr, Melius. 16 This is Dan McKeel. Can you hear me? 17
CHAIRMAN MELIUS: Yes, we can. Go 18 ahead, Dan, 19 DR. McKEEL: Thank you. Are my
20 slides ready to go?

p4a

1 OR. McKEEL: Okay. 2 CHAIRMAN MELIUS: Stu is getting 3 them. 4 DR. McKEEL:
Okay. 5S CHAIRMAN MELIUS: I will let you 6 know when, Here we go. Okay. Your
title 7 slide is up now. 8 DR. McKEEL: Okay. Well, let me 9 just make o short
introduction and to thank 1@ the Board for being so generous with letting 11 me
submit materials to them on GST, In the 12 next ten minutes or so, I will try to
cover 13 the highlights. But I do want to comment 14 while it's fresh in mind
for everybody on a 15 couple of things that just came up in the 16 preceding
presentations by Dr. Ziemer and by 17 Dave Allen. 18 The first thing is that the
ingots 19 and the dingots from Mallinckrodt, the size is 2@ very well known. And
basically they were

p41

1 needed to be picked up with a crane and a 2 chain. 3 The other two types of
metals we 4 know are billets, uranium billets. We do not 5 know the size of
those. I don't think anybody 6 does. And it was commented by Dave Allen, I 7
think, that a betatron slice, which is 8 described in one of the six Site
Profile 9 documents for Mallinckrodt, was just the crop. 18 I think that is
definitely not true because 11 the Moilinckrodt document describes quite 12
clearly that a person spent long amounts of 13 time, at first at least, hand-
sawing uranium 14 ingots to get a slice. And SCRA has estimated 15 they were
maybe 4 inches thick, 18 inches in 16 diameter, 12 to 18 inches in diameter. 17
Nobody really knows is the answer. 18 And nobody knows the size of the billets.


the boundary of the exclusion zone set up by SLTL. An additional exposure of 133 mR was
assigned, based on an excursion into the exclusion zone while the radiographer was assumed to
take breaks. However, we later learned from a former administrator of SLTL, that the
source was retracted into its shield whenever the radiographer lett the arca (Anigstcin 20116).
Therefore, the limiting exposure should be 2.669 R/y.' At the same time, we learned that the
SLTL activities at GSI did not begin until 1963, past the end of the Radium Era. Consequently,
these exposures, although presented during an carlicr phase of our studies, should not be
included in exposure assessments during this period. Later in his report, Allen took note of this
last observation,

By the samc token, the exposures of the layout man resulted trom the operation of the New
Betatron, which was not installed until late 1963, and should likewise not be included in the
Radium Era assessments. This is also noted in a later part of Allen’s report.

Allen (2013) next presented a table entitled “Others — Radium Era.” The table correctly cites the
SC&A assessment of exposures outside the radiographic facility in No. 6 Building; however, we
disagree with Allen's derivation of an annual exposure from ”*’Ra radiography outside the
facility that he ascribed to SC&A, That value is based on all of the *6Ra radiography being
performed in an open area, which we do not believe was the case. The same comment on the
previous table with respect to the SLTL sources applies here. Finally, we note that the table
includes the betatron operator and the layout man, who are also listed in the previous table.

2 Exposures Following the Radium Era

Allen (2013) designated the period from the end of the Radium Fra until the end of AEC
operations as the “Cobalt Era.* This era needs to be subdivided, since it comprises three distinct
periods -pre-SI.T1, operations. SLTL operations prior to the New Betatron, and New Betatron
operations—-each of which experienced significantly different limiting exposures, Allen lists
exposures from the GSI-owned *’Co sources—we agreed with the exposures calculated on the
basis of the survey of the radiographic facility performed by the Nuclear Consultants Corp., but
disagreed with the exposures from performing Co radiography in open areas, since this was an
infrequent scenario that should not be used to calculate annual exposures.

2.1 Period Preceding SLTL Operations: May 22—-December 31, 1962

During the period after the Radium Era but prior lo STI. operations—May 22 to December 31,
1962--SC&A recommended that the limiting exposure be that of the betatron operator—1.35
R/y—as listed by Allen in each of his four tables.

' allen (2013) erroneously ascribed a rate of 2.771 R’y to SCRA—in fact, Anigstein (20 1a) cited this value {in units
of “mrem”) but ascribed it ta Alten (201 t). In the subsequent discussion, whenever a time period encompasses a fraction
of a calendar year, the recommended annual exposures should be prorated to the actual period of cxposurc.

Response to “GSI Dose Estimation Comparison” -2- SC&A —February 12, 2013

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However. this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual aceuracy or applicability within the requirements of 42 CFR 82.


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 17 of 18

1.

2

The topic turns to dose assignments for Layout man in the cobalt era.

SC&A dose 9.2 (REM/yr) and NIOSH dose 4.43 based on models using Excel SolverTM
software to achieve 10 mRem/wk in control room. This is normalized to film badges.

+ SC&A states they "categorically disagree with that.”

+ McKeel comment: | do agree with SC&A that adjusting model parameters to return a
desired result to match film badge readings is an inappropriate and not scientifically
defensible approach. NIOSH achieves a lower, less claimant favorable number, using
this badge normalization approach that SC&A objects to strenuously,

There follows an argument between Allen and SC&A regarding the two different types of
control film badges. The two parties disagree on how film badges are read related to the
actual reading and the background density treatment.

Dr. Ziemer comments on the different SC&A and NIOSH results and questions whether
they apply to Betatron or Layout workers. The disagreement is not resolved.

Member Beach asks Dave Allen about the “1966 value 1/2 how does that affect 4.483
dose?”
* McKeel comment: The meaning and intent of this comment as captured is not clear.

Dr. Ziemer intercepted Member Beach's question and answered for Dave Allen, an
action he has taken repeatedly to control the discussion. He puts the onus on SC8&A to
achieve a compromise. Dr. Ziemer assumes the inappropriate role ance more as NIOSH
advocate.

Member Beach reviews again the triangular distribution parameters: 15, 9 and 5
versus 3 REM doses at the comers. McKeel thought the main point of query was
whether the lower limit should be 3 or 5 REM. Again, there was no further resolution.

Dr. Ziemer then concluded the GSI portion by stating:

(a) “then we need to go back to aff matrix issues’ (last item page 17a of 18).

(b) “Did not go through the residual period -- agree it could be done. inhalation Ur
agreed on source term but not model.” (last discussion item page 17b of 18).

» McKeel comment: (a) Appendix BB matrix issues were supposed to be covered at the
2/21113 TBD-6000 WG meeting (agenda item 1d). The WG also needed to review the
two February 2013 white papers by NIOSH and SC&A portions that dealt with the
residual period that spans 7/1/1966 through 12/31/1992. (b} “Agree it could be dane" is
not an accurate statement -- where is that agreement in the record? Who agrees with
whom? The starting level of airborne uranium concentration at the start of the GSI
residual period has not been established. The appropriateness of using TIB-70 that has
been recently revised has been raised by the petitioners but has not yet been addressed
by the TBD-6000 WG. An exact method and finat doses still must be determined for the
GS] residual period and the many businesses that operated at the 1417 State Street
location in Granite City, IL, at the “South Plant” complex between 7/1/66 and 12/31/92
The petitioners were instrumental in discovering all of these other businesses and what
they did and placing this information into the Docket 140 record and in the hands of the
TBD-6000 work group, NIOSH and SC&A. The GS! residual period needs more work.

-22-


10

ii

12

13

14

16

17

18

19

20

21

This transcript of the Advisory Board on Radiation an¢ Worker Heailh, Soard Meating, has been
reviewed for concems under the Privacy Acl (6 U.S.C. § 552a) ans personally identifiable
intormation has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this anscript is for infarmation only and is subject lo change.

that's why I was asking how many samples there 39

were -- the highest was 11 dom per cubic
meter, which sort of falis into the same range
of the iimited samples from Leblond end I
would think also reflects a _ low-exposure
situation based on the job task.

CHAIRMAN MBLIUS:; Any other
comments or questions at this point?

{No response.)

CHAIRMAN MELIUS: Okay. Let's
hear from the petitioner, see if we have any
questions for them. I'm not sure if it's one
or two people speaking. And then we will come
back and have further discussion. So don't go
too far away, Dave.

DR. McKEEL: Hello, Dr. Melius.
This is Dan Mckeel. Can you hear me?

CHAIRMAN MELIOS: Yes, we can. Go
ahead, Dan.

DR. McKEEL: Thank you. Are my

slides ready to go?

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS



McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 5 of 18

ANIG SLIDE 8: diagram: Center of control Room.
NIOSH 10 mREM NOT to control badge. Betatron CTL #1 2nd hand info
1 worker handled badges, did not remember control badge.
Vatues not actual - differential.

Can't assume Betatron op was in controf room full time

ANIG our MCNPX 8.9 Betatron
94

Last Slide} Layout man not on RR tracks because couldn't get RR car in out.
Getting penumbra of Betatron.

PLZ? SCA models all less than regulatory limits. One FB extrapolation model could be
used as high as 20. 12-15 is a plausible upper bound 1953 --> May 1962.

ANIG presentation -- Same as in Santa Fe, if you remember.

MUNN
Can't formulate Q -- problem uncomfortable w/upper regulatory limits. Jim SLIDE
6 “never exceeded” “average is less than 25%, range 3 to 12 Allen. Anig "12 or
15." PLZ and Allen trying to beat him down.

PLZ -Radium era. Cobalt era -- model is all we have.
9.2 Layout man. Anig:

POSTON 9:15 CST 9:10 class
SKIN DOSE: Whole body + beta, add neutron. If neutron dose
dose “were important.”

ARJUN
Conflicted


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 2 of 18

ALLEN
Radium era to 1962 -- we need middle values 13.5 sec, d = 5 ft. SC&A used
shorter
NIOSH divided dose -- pult back that assumption. Not always a radium helper.
5 something/yr = trying to find it.
SC8&A 9.9 REM/yr. Used summary dose 1 part time radiographer
Bound.
Where do | Av less than 25% limit is REM/yr 54-55
these limits <-| Limit not an est,, statement <12, <15
come from? |

Where is WG comfortable, similar to Bob
PLZ Subset of larger ? sufficient accuracy. If take MAX bounds but not plausible

ALLEN
Go w/Bob 9.2 REM - 2 factors - 3.3 Ra + 2.2 SLT.

PLZ Give Betatron man layout man dose.
Bob Mutually exclusive
ALLEN
Take highest dose, assume full time that job.

That layout job was done by radiographers

BEACH
- NIOSH why they didn’t do room -- existed pre-1962

ANIG
No Munn or Poston (question or comment), Beach "well dane"

Layout Man: New Betatron source.
|- Marking casting

BOB ANIG Layout man marking repairs not shots

ALLEN
No, layout laid out some shots


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 15 of 18

1.

Ors. Anigstein and Mauro then make their recommendation again but express it in a
qualitative rather than the needed quantitative way. That is, what is the limiting dose?
The statement is: “Use timiting dose: good models. 1 FB record, “evidentiary.”

+ McKee! comment: This statement as captured by McKeel is not clear: My questions
are:

(a) What limit is being proposed? Is it +2 to 15 REM?

(6) What models are good, specifically? McKeel contends none of the SC&A
or NIOSH GSI computer models agree with one another between agencies
or over time, and none are validated against real measured data.

(c) Asingle film badge record is not representative or sufficient ta bound dose
for an entire SEC class. This is an example of poor practice, and is the
opposite of “good evidence” that WG Member Beach previously referred to
on 11/28/12 as “flimsy” and Board Member Brad Clawson characterized an
12/11/13 as NIOSH having “no significant data” for the GS! 1953-62 period.

(d) What does the term “evidentiary” mean in this context? Clarity is obscured.

McKeel notes that at this point far into the meeting allotted time, Appendix BB
matrix issues have not been addressed. Nor were they to be at this WG meeting.

Neton restates his view that a dose of 9 REM is “not appropriate” for “Administrative.”

He notes NIOSH assigns lower doses to admin personnel at other sites “all the time.”

+ McKeel comment: Then why wasn't this three tier approach used in App-BB Rev 0?
NIOSH is obviously attempting to limil assigned doses to avoid the number of reworks of
the 80% of denied GS claims that will be applied for when Appendix BB Rev 1 newly
emerges some uncertain time in the future. The next TBD-6000 WG meeting is 4/26/13.

SC&A expresses doubts that admin/office workers can be accurately identified. Note
“there are no records.” Outcome of job assignment will be “very subjective.” John Mauro
notes 3 tiers usually at large DOE sites in conjunction with co-worker models with
sufficient job data to employ a 95th percentile approach to dose assignment.

John Mauro of SC&A states: “No film badge data troubled me at the beginning...”
“Not averse to policy -- haven't heard what that is.”

+ McKeel comment: Landauer GSI flim badge data applies to only 89 of 3000 workers in
one job category (Belatron/isotope radiographers) at GS! 1963-1966. There is zero FB
data except for 2 worker summaries for October 1, 1952 through October 1963 for any
GS! worker. This fact of monitoring data at GS! being absent for ali but 3 of 13 years at
GSI cannot be overemphasized. Ai most, 3% of GSI were ever badged at all.

Dr. Ziemer “did not talk about office workers” reference is unclear.

John Mauro makes the extremely important declaration that: “15 REM no one got it --
confidence that was why SEC was denied.”

+ MckKeel comment: This is a too lafe admission by Dr. Mauro that Dave Allen’s
misleading inference that NIOSH would assign the 15 REM dose to everyone was
the major reason GS! SEC-00105 was denied. This observation is a great example of
“too little, too late." The statement had to be made before the Board voted 9 to 8 to
deny GSI SEC-00105 on December 11, 2072, at the Knoxville, TN, full ABRWH meeting.

-19-


McKeel

EXHIBIT 6

Dan McKeel
Talk to the 86th
ABRWH in Denver
September 19, 2012

12-11-2012


This ranscripl of the Advisory Board on Radiation and Worker Health, Board Meeting, hes been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a} and personally identifiable information has
been redacted as necessary. The transcripl, however, has nol been reviewed and ceflified by the Chair
of the Advisory Goard for accuracy al this time. The teader shoutd be caulioned that Lhis transcript is for
information only and is subject ta change.

UNITED STATES OF AMERICA
CENTERS FOR DISEASE CONTROL
tet tt

NATIONAL INSTITUTE FOR
OCCUPATIONAL SAFETY AND HEALTH

t++¢ ttt

ADVISORY BOARD ON RADIATION AND
WORKER HEALTH

t+ ttt
86th MEETING
ttt tt

WEDNESDAY
SEPTEMBER 19, 2012

+e ett

The meeting convened at 8:30 a.m.,
Mountain Daylight Time, in the Denver Marriott
Tech Center, 4900 South Syracuse, Denver,
Colorado, James M. Mélius, Chairman,
presiding.

PRESENT :

JAMES M. MELIUS, Chairman
HENRY ANDERSON, Member
JOSIE M. BEACH, Member
BRADLEY P. CLAWSON, Member
R. WILLIAM FIELD, Member
DAVID KOTELCHUCK, Member
RICHARD LEMEN, Member
JAMES E. LOCKEY, Member
WANDA I. MUNN, Member

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS



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

From: DanMicKeel

Sent: Tuesday, Maith 12, 2013 12:28 PM

To: NIOSH Docket Office (CDC)

Ce: danmckeel :

Subject: Docket 140 submission: McKeel 2/21/13 annotated WG transcript
Attachments: MCKEEL_TBD6Kwg_2.21.13b.pdf

Dear NIOSH Docket 140 officer,

Attachment «MCKEEL_TBD&Kwg_2.21.13b.pdf> 2.7.MB

Please consider posting this document under Docket 140 (GSI) on the DCAS website. It is an annotated transcript of

notes | made on the 2/21/13 meeting of the TBD-6000 WG. The members considered GS| SEC-105 and site-specific

Appendix BB issues including a comparison of NIOSH and SC&A final dose assignments. This material will be included in

a planned administrative appeal to the denial by HHS of SEC-00105 on March 6, 2013. Thank you for your consideration.
Sincerely -- Dan McKeel 3/12/13

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


uranium, 17

And the other thing is none of the 18 relevant records that would contribute to
the 19 accurate bounding have been recovered from 2@ Mallinckrodt on the work
done at GSI.

ps2

1 NIOSH has made a lot of errors of fact in 2 Appendix BB that still need to be
addressed, I 3 believe that the NIOSH betatron, the steel 4 casting activation,
and the uranium intake 5 models are not valid for reasons I have put 6 forward
and, therefore, not bounding. There 7 has been extreme underestimation of the
exotic 8 mixed activation fission radionuclides that 9 were discussed
prominently at Rocky Flats 10 yesterday that were caused by a bombardment of 11
uranium and the steel castings for the 12 betatrons. At those high MeV, both
things 13 occur, 14

And NIOSH used only iron-59 as an 15 activation product, where we sent you 16
literature documenting that there are at least 17 38 different radionuclides,
some with 18 half-lives that were days and weeks and much 19 longer than they
assigned for Fe-59. 20

And, finally, with respect to

p53 :

1 scenario, I will point out that one of the 2 main references cited by NIOSH
and SC&A from 3 TBD-6000 is that by Adley, et al., for the 4 Hanford melt plant
in 1952. And that showed 5 that uranium rod handling caused intake doses, 6 I
quote, intake doses 2.5-fald higher than the 7? permitted Limits. So they may
have been & relatively low, but they were two and a half 9 times what radiation
safety limits at the time 10 would permit. 11

So I thank you and appreciate your 12 attention. 13

CHAIRMAN MELIUS: Is the 14 co-petitioner on the line and wish to comment? 15
MS.~ | “: This is 6. And no, I don't have any comments, I 17 do
agree with Dr. McKeel. And I do hope that 18 we can reach a vote and put closure
to this 19 for all of our Class Members. I appreciate 20 everybody's help. Thank
you so much,

CEND QUOTE)

The TRANSCRIPT ENDS ON PAGE 34@ with the adjournment being at 6:26 PM Denver
Mountain time.


We therefore believe that our estimated exposure of the layout man of 9.2 R/y is a rcalistic and
claimant-favorable bounding value. This value was presented to the Advisory Board at the
June 20, 2012, meeting in Santa Fe, New Mexico.

4.2 Radium Radiography

Allen (2013) correctly summarizes the SC&A exposure analysis of the radiographer using Ra
sources described in paragraph | of section 1 of this memo. We would rephrase his reference lo
our use of “worst case” parameters: we would characterize the parameters as being claimant
favorable yet realistic, the regulatory requirement for assumptions used in dose reconstructions.
However, our exposure analysis based on time and distance, as well as the one based on
extrapolating the doses of a part-time radiographer to one occupied full time with such work,
serve only to buttress our recommendation that the bounding exposures should be equal to the
AEC limits. These limits were 15 rem/y prior to 1955 (which Allen failed to mention} and 12
rem/y in 1955 and subsequent years—up to the end of the Radium Era, We disagree with
Allen’s assertion that “Based on a statement GS] made to the AEC that no one had exceeded the
annual limit and the average was below 25% of that limit, the maximum dose can be established
as failing between 3 R/yr and 12 R/yr.” We interpret GST’s statement that no one exceeded the
annual limit to imply that somcone’s dose might have been at the lnnil. Since there is no way of
knowing who that person was, the AEC limit represents the bounding value. The average dose is
immaterial—the decision to compensate a claimant must be based on the real individual, not an
imaginary statistical average individual.

We further disagree with NIOSH’s adopting our calculated exposures of workers outside the
radiography room as a basis for dose reconstructions, Anigstein (201 1b) calculated doses
outside the steel door to the radiography room to check limiting doses to nonradiographers
calculated by Allen (2011). It was not our intention to endorse the assignment of different doses
to different classes of GS] workers, although we admit that citing that calculation in that report
may have implied as much. From the time of our earliest review of the GSI site profile (SC&A
2008), we have questioned the division of GSI workers into two categories by NIOSH. We
believe that the limiting exposures of 15 rem/y in 1953-1954, and 12 rem/y in 1955-1962 should
be assigned to all GS] workers. This is the SC&A position that was presented to the Advisory
Board on June 20, 2012 and reiterated in response to questions from board members at its
meeting in Knoxville, Tennessee, on December 11, 2012. This position is confirmed in the
following excerpt from Issue 11 of the Appendix BB issues matrix:

[NIOSH] 1/13/12: Allen [(2012}] stated that, in assessing doses from betatron
operations, dose reconstructors will choose the most favorable exposure scenario
(i.e., betatron operator or layout man} in each case.

SC&A Response (7/28/12): We agree that the most favorable exposure scenario
should be applied in-all dose reconstructions. The same procedure should be
extended to reconstructing the doses from external exposure to sealed sources. If

Response to “GSI Dose Estimation Comparison” -}- SC&A February 12, 2013

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Lealth for factual accuracy or applicability within the requirements of 42 CFR 82.


McKeel transcnpt TBD-6000 WG 2/21/13 meeting

Daniel W. McKeel, Jr., M.D.
Contemporaneous Notes Verbatim Transcription
from the 2/21/2013 Meeting of the
TBD-6000 Work Group of the ABRWH
Fitename: DM-transcr_TBD6K_2.21.13r.doc
{version 1.0r, 3/4/13)

Note: Van Buren MO time, where McKeel is located, is CST and is one hour ahead of
Cincinnati, OH EST where the WG meeting took place. Nine words or phrases that were
personal (margin) notes made by the author are marked [REDACTED]. This is not a
complete transcript. It is all the author could write down by hand during the phone call.
Words and phrases of text in italics are commentary inserted by the author.

PAGE 1 of 18

9:00 Katz rof caf: PLZ (Paut Ziemer, chair), Munn (Member), Beach (Member),
Katz: “Dr Poston (Member) a little late -- I've talked to him”

Neton, Allen, Toms, Ph: Rutherford

SC&A Bob, Mauro, Arjun - Anig/NO, Stiver

|- (Katz) “not feeling well”

Fed Katz, Jenny Lin HHS

GSI McKeel, Ramspott, Jeske

Terrie Barrie

PLZ Three main sites / categories
GSI ongoing activity -- final models for DRs for both active
and residual periods Baker residual SSS issues matrix
(breaks) Noon + mid AM
2 docs” NIOSH Allen summaries DR results for NIOSH models cf to SC&A
models - what assumptions should be used for final doses. Value for Allen
review highlights

Allen w/SC&A and petitioner materials. SC&A presentation (Bob Barton
prepped. Mauro - Anigstein now ON, 8:08 AM

ALLEN
Lot of models & tweaking past fee yrs, last iterations. 4 photon dose
tables, 2 eras, Raciographers + non radiographers. Revise Appendix and
move on,

PLZ  - Radiographers + others at site: Binary assignment.

(Affen)
Won't read whole thing -- you can see -- issues/models where we agree.
Radium source scenario + layout 2 problems. SC&A added timeline. What
we need to revise Appendix.


Comparison of NIOSH and SC&A External Exposure Assessments at GSI
Robert Anigstein

S. Cohen & Associates

February 21, 2013


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Pages 4b-e of 18

2a.
2b.

7a.
7d.

8a.

10.

11.

12.

43.

14,

Summary of Key McKeel Points in His Prepared 2/21/13 TBD6K WG Remarks

The GSi dose data in the Allen/OCAS and SC&A papers needed to be available to the
full Board prior to its vote on SEC-00105 on 12/11/13.

Appendix BB open issues all need to be resalved at the 2/21/13 work group meeting.
The GSI operational period start date has been changed to October 1, 1952.

The two papers in item #1 did not review the dose data used in APPENDIX BB for the
past 5.5 years ta complete more than 95% of NIOSH dose reconstructions at GSI.
Those doses were remarkably different from doses in DCAS and SC&A 2013 papers.

Allen and DCAS made a factual error in stating that GSI claimants all received the
highest dose scenario in completed DRs. In fact, external photon doses for
radiographers exceeded doses for other workers by about 10-fald. Why the Betatron
doses declined so precipitously from 2007/8 to 2012/13 was not adequately explained.
The film badge dose “normalization” process used by NIOSH also was unclear.

Allen and DCAS do not explain why NIOSH failed to model Ra-226 operator doses
within the Building 6 radiography room. Dr. Anigstein remarked about this on 2/21/13.

SC&A erred in not estimating Ra-226 doses outside the Bldg 6 radiography room
because, according to Dr, Anigstein, “we didn't accept that scenario.”

NIOSH/SC&A need to cite a source reference for their "AEC dose limits” 1943-1962.
NIOSH/Allen erred in stating that having an SEC is a bad thing for GSI claimants.
McKeel data proves otherwise (see Attachment A this document, PDF file)

A named radiography foreman testified Ra-226 was used “all over the plant.”
The two Feb. 2013 DCAS/SC&A papers did not address the inadequacy of TiB-70 to
model uranium intakes during the GSI residual period with cyclical cleanup periods.

Doses were not assigned for two GSI 250 Kvp x-ray units or the Ir-192 GSI source.

E-mails were introduced that showed (a) NIOSH and the DFO prioritized sites for action
on their SECs based on “political heat"; and (b) Allen used the “throw them a bone
technique” (his terminology) to biunt criticism of NIOSH science by work groups.

Dose from the two St. Louis Testing Laboratories Co-60 and Ir-192 sources used at GSI
were not bounded separately as OCAS-IG-003 mandates they must be.

Who was the NCC film badge vendor? It was a mistake to base dose on a summary for
one part time radiographer. The 1953 belt object SC&A identified as a film badge was
more likely a GSI ID badge.

SC&A (Drs. Anigstein and Mauro) agreed that Board members were misled on 12/11/12
by DCAS/Alien implying that all GSI workers would get 12-15 REM/yr under SEC-00105.

McKeel hoped all of the open Appendix BB issues would be resolved on Feb. 21. 2013.
-7-


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This lranscdpt of the Advisory Board on Radiation and Worker Heaith, Board Meeting, has been
caviewad for conoems under the Privacy Act (5 U.S.C. § 552a) and personally denilfiable
information has been redacted as necessary. The transcript, howevar, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy ai this time. The reader should be
cautioned that this transcript Is for information only af is subject to change.

3,309-pound objects. So they definitely 4,
needed to be picked up with a crane and a
chain.

The other two types of metals we
know are billets, uranium billets. We do not
know the size of those. I don't think anybody
does. And it was commented by Dave Allen, I
think, that a betatron slice, which is
described in one of the six Site Profile
documents for Mallinckrodt, was just the crop.
I think that is definitely not true because
the Mallinckrodt document describes quite
clearly that a person spent long amounts of
time, at first at least, hand-sawing uranium
ingots to get a slice. And SC&A has estimated
they were maybe 4 inches thick, 18 inches in
diameter, 12 to 18 inches in diameter.

Nobody really knows is the answer.
And nobody knows the size of the billets. And
nobody knows what mixture was sent to

Mallinckrodt, although I did introduce a

NEAL R. GROSS
COURT REPORTERS ANO TRANSCRIBERS



‘This \ranscripl of the Advisory Board an Radiation and Worker Health, Board Méeting, has badn
reviewed for conoems under ine Privacy Act {5 U.S.C. § 552a) and personally identifiable information has
been redacted:as necessary. The transcript, however, has nol been feviewed and cértified by the Chair

of the Advisory Board for accuracy at this fime. ‘The reader. should be cautioned thal this Wansoriat is for
information ory and Is subject 10 change.

*Participating via telephone. 3

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS.



MeKeol transcript TBD-6000 WG 2/21/13 meeting

Page 9 of 18

NETON and ALLEN
Op. period will go into all DR

PLZ We have agreement on that

ALLEN
<--one person testimony; how accurate is 15 sec?
Radium era: 3-12 REM = 3.573 REM median point fishpole
argues SC&A 9-20 REM} convincing to some people, for sure
w/Anigstein “single 8.69 REM records we don't have; made couple of
“sorry dose data point. times. Made by. _' Started 1953.

PLZ “never used dose limits - the letter sets a limit”
BEACH

- 9.69 | 1952->1962
REM | could be 15 to 1955; 3 REM yr / post-1955

(McKeel) They did not answer my question - where did they get the AEC limits?

Dan: Compare w/Passmore/Quierke Radiation limits letter
PLZ Need WG direction No comment, No answer

POSTON [REDACTED]
Legal limit (vs) calc.- on mute - Katz John Poston

ANIG Can't agree w/3.67; use 5.4; inconsistent

BEACH
Go w/12 and 15 agree SCA

MUNN
No evidence for regulatory boundaries

BEACH
Evidence could be higher

PLZ Sftvs4it
NETON
Different opinion NIOSH 3; SCA 9

Use distribution, triangular 9-->12-—->15 can put into IREP
Don't believe everyone should get that limit. --> 3.67 two radiographers

-13-


any site, to validate their computer model results. These key data seem not to exist. GS}
is an absolutely unique site in this regard.

[4] Aslide we showed in September showed very disparate SC&A and NIOSH
computer modeling results over time, comparing 2008 with 2012 data, and between the
two entities. Model agreement ranges between 2-fold and 12-fold between entities with
some concerning ratio reversals. The peer review literature standard for validating
camputer models fs that agreement with real measured data should be + 10 to 20
percent, not 200 percent.

[5] The SC&A revised GSI SEC-00105 issues matrix | received was dated
November 30, 2012, two days after the TBD-6000 work group met. Another GS! SEC
matrix version dated Dec. 5th has been posted for this meeting. Those matrices have
not been discussed by Dr. Ziemer's work group.

+t now address the November 28, 2012, TBD-6000 work group meeting draft
transcript that DFO Ted Katz provided to me fast Friday. My two GS! petitioner
colleagues, and" carried the ball at the Nov. 28 meeting
for reasons | made clear in a protest letter Ted Katz read into the record and then
circulated to all of you. Today, | stand by every word in that letter. The GS!
claimants have been treated very unfairly by the TBD-6000 work group.

[6] The SC&A August 2012 analysis of Allen's 3 NIOSH AWE surrogate sites failed

to meet 4 of S Board surrogate data criteria. However, by some magical reasoning that

baffles the GSI petitioners, on Nov 28, 2012, SC&A had reversed positions completely,

so that by now 5 of the 7 Allen-DCAS sites satisfied ALL 5 Board surrogate data criteria,
I strongly support the SC&A August analysis for the following reasons:

* The Allen surrogate sites are not comparable to GSI uranium operations or the forms

of uranium used. To be specific:


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This Iranscript of the Advisory Board an Radiation and Worker Health, Board Meeling, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacled a5 necessary. The transcrip!, however, has nol been reviewed and
certified by the Chair of the Advisory Board (or accuracy al this time. The reader should be
caulioned that this transesiptis for information only and is subject to change

said, there had never been any general eir
sampling, breathing zone samples, process
sampling for uranium ever at GSI or by DOE
until that 1993 survey.

Okay. If I could go to the slide
3?

CHAIRMAN MELIUS: And, Dan, I'll
ask you to please move it along.

DR. McKEEL: I will.

CHAIRMAN MELIUS: We have
something else scheduled at this time.

DR. McKEEL: Okay. Thank you,
Jim. I don't think I’ve used my ten minutes,
but I was trying to address guestions --

CHAIRMAN MELIUS: Yes, you have.

DR. McKEEL: -- that weren't
answered by anybody during the discussion
period. So the key events during the residual
period I would like to point out were the
power washings for the old and new betatron

buildings and that multiple steel companies

NEAL R. GROSS

COURT REPORTERS ANG TRANSCRIBERS

48



SLIDE 1

TITLE: Reat data AEC operational period 1953-June 1966

Landauer film badges on 89 radiographers Nov 1963-1966;

3% of workforce of 3000, one job out of hundreds, not assigned
the highest external dose, not worn in plant outside OBB/NBB
1962 one time survey of photons in Bldg 6 radiography Co-60
by Nuclear Consulting Corp. (NCC}

MCW Uranium Division purchase orders for Betatron NDT
radiography 1958 through June 1966 (1953 through Feb 1958
missing) -- No uranium weights or information on percentage
or numbers of 3300 Ib dingots/ingots, billets and slices; all
shipping manifests and weights and x-ray records missing


Comment on McKeel TBD-6000 2/21/13 WG Mecting

Page 10 of 18

1.

Different dose limits within the triangular distribution were proposed: Ziemer 5.4 MREM,
SC&A “lower limit not less than 9. (The value) 3 should not be included,”
disagreeing with Neton/OCAS. Dr. Netan observed “don't know if we can flesh out the
details here.”

+ McKeel comment: Once again, a final dose decision was put off and left in limbo.
Allen clarified a footnote (d) in one of four dosimetry tables in his 2/4/13 white paper.
Ted Kaiz inquired again whether Dr. Poston was on the line and got no answer.

There followed another confusing discussion of various doses including 2.06 REM, a
new figure of unknown origin. Allen said “use SC&A figure” but didn’t clarify the number
he was referring to.

Dr. Anigstein tried to disavow his prior 25% occupancy number as “How weil based |
don't know, Not a strong number.” Noted the new value was lower than the old skyshine
number 0.72 x 3250 hrs/yr = 2.3 mRéyr or mMRem/yr. Stated “same dose everyone gets
assigned.” | could not quite follow this discussion as it was too truncated.

Dr. Anigstein mentioned that “Bob Barton looked at all claims (in the radium era, t
believe) with a POC less than 50% and found only one radiographer in the group of
100+ records (167 records was also mentioned). McKeel wants to know the primary
source for the Barton list of cases. This list should be requested under FACA and the
Board access policy, or via a FOIA request.

Allen importantly states: “There is no agreement about Betatron operators.” (added
emphasis)

Dr. Ziemer adds to the confusion by stating: “Can’t get Betatron/radiographer--don't
know who did what. Rest of population, what is being proposed.”

- 13 -


STICS

DR COMPLETE DR PAID ° DR PAID
256 66 25.78%
131 46 38.02%
52 17 32.70%
42 15 35.71%

4 ie) 0.00%
4 1 25.00%
26.20%

124 42 33.87%
106 59 55.67%
14 2 14.29%
929 470 50.59%,
183 77 42.08%
39.30%

2 12/11/12 ABRWH testimony)

3 (also refutes Allen 12/11/12)



0 10 20m

$i - Betatron
Casting
» Layout man I

MCNPX Model of Exposure Geometry of Layout Man


Daniel W. McKeel, Jr. TALK
12/11/12 ABRWH KNOXVILLE, TN
-- GS! SEC-00105 PRESENTATION --

[1] Good afternoon - Dr. Melius has again restricted me to a 10 minute presentation
to highlight the 38 white papers of mine | have sent to the TBD-6000 work group and
Board between 2007 and 2011. The 38 papers total 539 pages. | must rely on the

Board having read these papers, only some of which were discussed in any detail in
work group meetings. Often the WG chair simply acknowledged receipt with no further
discussion of the contents. Numerous McKeel GS] Public Comments also have been
added to the written record.

[2] At the September 2012 Board meeting in Denver | presented SLIDES showing
that only six important pieces of real measured external or internal monitoring data have
been identified for the GSt Illinois site, as follows:

+ Aseries of 1958-66 AEC MCW purchase orders to do Betatron NDT x-ray
work. No P.O.’s have yet been discovered for the 1953-early1958 period;
A 1962 NCC limited radiologic survey of the 2 Co-60 sources in building 6;
A 1968 radiologic survey by GSI personnel of the New Betatron building

with a larger Co-60 gamma source;
* Two 1962 and 1963 NCC radiation film badge reports from two workers;
89 GSI radiographer Landauer film badge reports 1963-1966. These data
tepresent only 3% of the total annual work force of about 3,000 workers,

and they are all males doing a single job out of hundreds at the plant (10%
of the GSI workforce was estimated to be female);

+ Uranium dust concentrations were measured in and around a smalt industrial
vacuum in 1992 in the Old Betatron facility during the DOE/FUSRAP uranium
cleanup that closed the residual period;

13] ALL of the other monitoring data at GSI is either surrogate or modeled using
MCNPX. NIOSH and SC&A have no Betatron x-ray data, surrogate or measured, from

-t-


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

From: DanMckeel:

Sent: Friday, December 14, 2012 12:56 PM

To: Katz, Ted (CDC/NIOSH/OD}, melius@nysliuna.arg; NIOSH Docket Office (CDC)
Ce: danmeckee

Subject: GSI McKeel info for ABRWH members not voting 12/19/12 & Docket 140
Attachments: MCKEEL_ToABRWt_9.14.12.pdf

Ted Katz, DFO

Dr, James Melius, Chairman, ABRWH
NIOSH Docket 140 (GSI}

Atlachment: <MCKEEL_ToABRWH_9.14.12.pdf> 1.9 MB
Dear Ted and Dr. Melius,

Ted Katz, may | ask you to please ensure that all Board members, especially those who have not yet had an opportunity
to vote an the GS! SEC-00165 petition, receive the attached PDF cover letter and the combined 7 Exhibits. The conlents
are my presentations to the full Board on 9/19/12 and 12/41/12, my testimony on 9/19/12 (pages 39-53 of the transcript},
my 12/11/12 Public Comment, the externa! dose slide | mentioned 42/11/12 highlighling very disparate SC&A and NIOSH
computer modeted doses for Setatron -vs- Layout workers in 2008 and 2012, and a list of my papers presented to the
Board and TBD-6000 work group concerning GSI. | feel it is very important that the absent Board members on 12/1 4/12
get this information right away, before they cast their final votes. Thank you.

NIOSH Docket Office, may | please request you consider the atlached PDF file to be posted on the DCAS website under
Docket 140 (GSI). Thank you.

Sincerely,
~DanMcKeel = 12/14/12

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


Slide 4

TITLE: Reasons GSI deserves an SEC recommendation by the Board
Part4

° Operational period: No MCW uranium purchase orders 1953-Feb 1968;

. Limited real data: 3 items AEC contract years; 3 items residual years;
° Nonexistent intake data sampling: breathing zone, general air, process;
° No urinary uranium bioassay for radiographers or anyone in workforce;

. Most of GSI work force should have been badged: worked on activated
steel: 3% badged during 3 of 13 years of operation period; 0.7% were

badged during 8 of 20 years of the residual period (99.3% no badge):
97% of GSI work force never badged 1953-1966. Not representative;
: Zero monitoring of beta or neutron doses at GS! 1953-1993;
e MCNPx models not validated by any real measurements of Betatron
skyshine, activation products; results differ wildly with SC&A and over
time: Betatron operators >~10-fold> Layout 2008; reverse found in 2012.
° NIOSH has not used valid models to bound all GSI sources: Ra-226
(2 sources), Co-60 (3 sources); Ir-192 (1 source); (2) 250 Kvp X-ray units.


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This transcript of the Advisory Board on Radiation and Worker Heaith, Board Meeting, hes been
reviewed for Cantams.under the Privacy Act (5 U.S.C. § $52a) and personally identifiable
information has been redacted as necessary. The transcript, however. nas not been reviewed and
certified by the Chair of ihe Advisory Board for accuracy at this lime. The reader should be
cautioned thal this transcript is for information only and is subjecl 10 change.

CHAIRMAN MELIUS: Hold a second.
DR. MCKEEL: Okay.

CHAIRMAN MELIUS: Stu is getting

them.

DR. McKEEL: Okay.

CHAIRMAN MELIUS: I will let you
know when. Here we go. Okay. Your title

slide is up now.

DR. McKEEL: Okay. Well, let me
just make a short introduction and to thank
the Board for being so generous with letting
mé submit materials to them on GSI. In the
next ten minutes or so, I will try to cover
the highlights. But I do want to comment
while it's fresh in mind for everybody on a
couple of things that just came up in the
preceding presentations by Dr. Ziemer and by
Dave Allen.

The first thing is that the ingots
and the dingots from Mallinckrodt, the size is

very well known. And basically they were

NEAL R. GROSS.
COURT REPORTERS AND TRANSCRIBERS

40



Commant an McKee! TBD-6000 2/21/13 WG Meeting

Page 16 of 18

4

3a.

3b.

John Mauro stated, again only qualitatively and vaguely, that “careful modeling could be
bounded, did not exceed regulatory limits."

« McKeel comment and questions: What models could bound what doses for what
workers? The ailusion is to a totally unconfirmed GSI AEC license application by GSI top
management. No such film badge program or FB vendor or FB weekly/monthly data has
otherwise been proven to have been in place. The 1953 belt “film badge” photo that
SC&A constantly alludes to has been identified in a group affidavit by GS! radiographers
as probably, and more likely, being a GSI ID badge (identification badge worn by all
employees including management). SC&A keeps ignoring this on the record testimony.

Dr. Mauro states, “NDT mishandling is common,” a theme he echoes that was
expressed on 12/11/12 to the full Board by member Brad Clawson, who stated he had
been a NOT radiagrapher for 10 years. Mauro further argues for the 12-15 REM dose
that he says “captures my concern about mishandling. Model is reasonable upper
bound for radiographers. 15 limit only applies fo badged workers...”

Dr. Ziemer interrupted and cut off Dr. Mauro, thereby suppressing the obvious fact of the
dose disagreement with the Board/WG and NIOSH. In doing so, Dr. Ziemer admits the
dose issue cannot be closed right now: “Can't close that part of the loop off right now.”

Dr. Ziemer then adds: “Charge NIOSH to bound office workers. How to distinguish in
DR? Disproves Dr. Ziemer's contention the WG cannot and does not task NIOSH.

> McKeel comment: This charge by the WG chair overrules SC&A who noted severe
difficulties with identifying office workers definitively. Dr. Ziemer knows this will delay
getting to Appendix BB issues for many more months. The record suggests this a poorly
hidden agenda of the WG chairman. Backing this up is the fact the next TBD-6000 WG
meeting is not scheduted untif 4/26/13.

Dave Allen counters that NIOSH advocates “One bound for everyone, three group
increases errors.” This suggestion opposes Dr. Ziemer's “charge” (order) to NIOSH.

+ McKeel comment: This pushback and the minimal support by other WG members on
the record proves that Dr. Ziemer is primarily pushing his own individual agenda in
adding a third office worker very low dose assignment category fo Appendix BB Rev. 1.

Thereafter are a series of very brief comments by NIOSH and SC&A going back and
forth including higher dose, other jobs can be confusing, triangular for placing the dose,

Allen states the important admission that NIOSH “never compared the Betatron and
Ra radiographers.”

+ McKeel comment: This is a monumental admission at this point in the 4.5 year SEC
and 5.5 year Appendix BB deliberations by this WG after 15 meetings.

Neton again espouses 1 job category but is open to two: non-radiagraphers and
administrative.

Mauro of SC&A is “comfortable with clerk, only once or twice in plant/year.” McKeel has
interviewed several former clerks, one of whom managed the film badge exchanges with
Landauer. The other was promoted to a badged Betatron supervisor after being a non
padged clerk. | believe Mauro’s characterization of clerk exposures at GSI is incorrect..

-20-


4 Unresolved Issues
4.1 Layout Man

As shown in Table 2, the SC&A estimate of the exposure of the layout man is more than twice
the NIOSH estimate, while our estimate of the neutron dose is more than three times that of
NIOSH. Allen (2013) disagrees with our calculations, claiming that our betatron shot scenario
would have led to exposures in the control room that would exceed the film badge dosimetry
records of the betatron operators. That conclusion is inconsistent with our analysis and with
observations regarding film badge dosimetry for the reasons discussed below.

{Allen (2013) fails] to account for the unnumbered control badge {not Badge No.
601: Betatron Ctl) that was included with each baich of film badges sent to GS] by
Landauer. As an integral part of any personal dosimetry program, the control badge
is stored in the same location as the film badges of off-duty workers. It is returned to
Landauer along with each batch of film badge dosimeters, where al) the films are
developed in a single batch and read with an optical densitometer. The control badge
determines the background—in the terminology of an analytical laboratory, it
constitutes a blank. According to ¢ " *** CHP (former Landauer offi
currently a member of the SC&A staff}, “The assigned dose is determined by
subtracting two numbers that are derived from the density on the user film and the
density on the background or “blank.” .... Thus, any doses in the film badge
dosimetry report represent the doses received by the worker while wearing the
badge. not while it was stored in the rack.” (Anigstein and Olsher 2012)

al,

Therefore. Allen's (2013) assumption that the film badge dosimetry reports include the exposure
of the film badge while il was slored in the rack is incorrect. To the extent that the control badge
might have been exposed to stray betatron radiation while the operator was wearing his badge,
the dosimetry records might actually understate the doses to the workers.

Our calculation of the exposure of the layout man comprises 22.11 mR per 8-h shift from
betatron radiation and 0.53 mR from the activated steel. This yields an annual exposure of

8.98 R from stray radiation from the betatron and an additional 0.22 R from activated steel. With
the same shot geometry, we calculated an exposure rate of 0.339 mR/h at the operator's desk in
the control room. This results in an annual exposure of the bctatron operator of 0.46 R, assuming
he sal al the desk in the control room during the entire part of his shift that the betatron was in
operation. Thus, his weekly exposure, averaged over 50 weeks, would be 9.2 mR, less than the
MDL of the film badge. In reality, especially during the “long shots,” he may have left the
control room through a back door. Such a scenario is plausible if we note that the operator was a
member of the betatron team that was also responsible for processing the exposed films, and that
the room directly behind the contro! room is marked “Processing Area” on the floor plan in
Figure ]. This is consistent with the account of the BS a a GSI betatron operator,
who said the exposed films were processed in the betatron building. Thus, the operator may
have spent part of the time during betatron exposures away from the control room.

Response to “GSI Dose Estimation Comparison” -$- SC&A —February 12, 2013

NOVICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


BOUNDING SCENARIOS FOR NEUTRON AND BETA EXPOSURES
Apply to All Employees

Neutron dose (rem/y) B dose to skin—betatron operator (rads/y)
Year - SC&A _ NIOSH. ~~ Hands & forearms _Other skin :

Betatron operator Layout man SC&A NIOSH SC&A NIOSH
1953-1957, 0.48 : 33.4 259 627 227
1958 0.48 ; 32.4 25.9 6.22 2.27
1959-1960 0.48 30.9 25.9 6.18 2.27
1961 0.48 0.148 34.2 29.5 6,30 2.47
1962 0.48 27.2 21.8 6.04 2.04
1963 0.47 | 13.9 7.0 §.56 1.23
1964 | 0.46 ‘10.7 3.5 5.45 1.03
1965 0.46 10.2 3.0 5.43 1.00
1966? 0.23 0.072 48 2.4° 2.71 0.97°

® Doses prorated to first 6 months, except as noted
§ Doses should be proratec to first 6 months


Unresolved Issues
NIOSH and SC&A have different exposure models for the two bounding scenarios discussed below. The
differences exist primarily in the input parameters or assumptions used.

Layout man scenario
For the layout man scenario, NIOSH estimated doses at various locations in and around the new

betatron building from a variety of betatron shot scenarios. These scenarios were then combined with
the work scenario developed by SC&A {using worker input) to produce the highest dose rate at the
Jayout man location while producing 10 mrem per week at the film badge rack.

SC&A believed that many of the shot scenarios developed by NIOHS were unrealistic, They also
commented that it was not appropriate to normalize the dose rates to 10 mrem per week at the badge
rack location. Instead, SC&A's estimate of dose to the layout man was based on 100% of the shots being
the same as that used in their original Appendix BB review. This scenario is listed as RR_ST_No in Table
3 of the January 2012 NIOSH white paper, That table provides dose rates in the control room for that
shot scenario as 1.42 mrfhr at the door, 0.41 mrfhr at the desk, and 0.65 mr/hr in the center of the
room. With the betatron operating 41% of the time, a 65 hr work week would produce more than 10
mrem on a film badge worn by an operator in the control room, even at the lowest dose rate location.
Since the badge would also receive some amount of exposure while in the badge rack and also while the
operator was exposed to irradiated steel, the scenario appears to be unrealistic. If the three control
room dose rates were averaged, and the time spent utilizing this shooting scenario were adjusted to 10
mrem/week in the control room (based on the average dose rate), the SC&A layout man dose estimate
would be reduced to less than 4.2 R/yr. This is reasonably close to the NIOSH dose estimate of 4.48
R/yr. It does not appear there will be significant differences in the layout man dose if the betatron
operator badge is limited to 10 mrem/yr.

Radium Source Scenario

After interviewing workers, SC&A concluded that most radium radiography occurred in the radiography
roam of the 6 building. NIOSH agrees with this. SC&A developed a model for inside the radiography
room, while NIOSH developed a model for outside the room {radiography in the other areas of the
facility). The primary dose to radiographers in both models is that received while using the “fishing pole
technique” to place and retrieve the source. SC&A developed a dase of 9.39 R/yr from this technique,
utilizing the worst case parameters provided by a former worker. NIOSH used the midpoint of the
ranges and assumed at least two radiographers shared the duties {thus divided this dase by 2). SC&A

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its
Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or
ABRWH (or their technical support and review contractors} positions unless specifically marked as such. This
document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act 5 USC §552a and has been cleared for distribution.

5


2.2 Exposures from SLTL Sources: January 1-September 30, 1963

The highest exposures during the period January 1-September 30, 1963, were from the high-
activity Co and 'Yr sources by SLTL to perform radiography at GSI. As discussed in

section 1, above, the limiting exposure in this scenario should be 2.669 R/y. As stated earlier,
the SLTL work did not begin until 1963. Since we do not know the exact date, the claimant-
favorable assumption is that it began on January 1, this limiting exposure rate should be assigned
to all GSI workers during the period January 1-September 30, 1963.

2.3. Exposures from New Betatron: October 1, 1963—Jume 30, 1966

The next period for which doses or exposures need to be assigned is from the installation of the
New Betatron in Jate 1963 until the end of the covered period. The September 1963 edition of
GSI General Steel Industries Magazine shows a photograph of the New Betatron Building under
construction (SC&A 2008). Presumably, this issuc was prepared in August or later. [t is
unlikely that the New Betatron was put in service before October |, 1963, which would be a
claimant-favorable date for the start of operations. Further indirect evidence for this starting date
is the summary record of externa] exposure 0: for 1963 (Attachment |). During
the first 3 calendar quarters, his quarterly doses ranged from 0-15 mrem. Since he performed
radiography only on a part-time, weekend basis, it was likely that he did little radiography during
this period. However, in the 4th quarter, which began on October 1, the dose jumped to

100 mrem, which suggests a marked increase in his radiographic activitics.

Further information on radiographic activities in the 4th quarter can be inferred from the film
badge dosimetry data that NIOSH obtained from Landauer, the vendor who supplied and
processed the film badges. The first weekly report included in these records, which is for the
week starting Monday, January 6, 1964, lists doscs to Mr. and to 17 other GSI workers.
The report states that there were seven reports to date for cach of these workers, implying that
they had been issued six film badges prior to the ones listed in that report. We thus infer that the
Landauer dosimetry program began during the week of November 25, 1963. Since Mr. P
cumulative dose is left blank in the report, we can infer that cach of these six previous badge
reports had readings below the MDL, which was 10 mrem for the Landauer badges. Thus, to
accumulate 100 rorem during the 4th cuore would have to have had at least one film
badge prior to the Landauer dosimetry program. This increase in his work schedule would
indicate an increase in radiographic operations at GSI, which, according to the accounts of
former workers, occurred when the New Betatron was put into service.

From the assumed date of installation of the New Betatron until the end of the covered period—
October 1, 1963—June 30, 1966—the limiting exposure rate should be 9.20 R/y. We calculated
this rate for the layout man working in No. 10 Building, just outside the New Betatron Building
{Anigstein and Olsher 2012). This valuc was cited by Allen (2013), first under “Radiographers —
Cobalt Fra,” then again under “Others - Cobalt Era.” The following tables summarize the
differences between the NIOSH and SC&A estimates of limiting exposures connected with
betatron operations.

Response to “GSI Dose Estimation Comparison” -3- SC&A —Pebruary 12, 2013

NOTICE: This seport has been reviewed for Privacy Act information and has been cleared for distribution
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


p. 80-101 1-8 EXHIBIT 7? (part of)
Transcript pages 143, 39-53, 339-340;
McKeel ABRWH court reporter transcript text, ABRWH 9/19/12,
pages 1-5 and 39-53. Original triple spaced transcript version.

p. 102-106 1-5 EXHIBIT 7 (part of)
Transcript pages 39-53 only;
Mickeel ABRWH court reporter transcript text, ABRWH 9/19/12,
pages 1-5 and 39-53. Compacted single-spaced version.

p- 107-115 1-9 Attachment C
: SC&A Dr. Robert Anigstein's PDF 8 slide presentation to the
TBD-6000 work group on 2/21/13.

p. 416-121 1-7 Attachment D
. Dave Allen, DCAS, White Paper "GSI Dase Estimation Comparison,”
released 2/4/13.

p. 122-134 1-13 Attachment E
Robert Anigstein and John Mauro, SC&A White Paper: "Response
to NIOSH Report: GSI Dose Estimation Comparison," dated 2/12/13.

-- end of document --

---f}---

FOOTNOTE: This material is to germane to fully document the General Steel Industries,
Inc. the deliberations of the ABRWH, the TBD-6000 work group, NIOSH and SC&A
leading to a proposed revision 1 of (“GSI”) Appendix BB revision 0 (June 2007) and to
the Special Exposure Cohort SEC-00105 for GSi.

The Advisory Board considered SEC on 9/19/12 and voted to deny it by 4 9 to 8 final
vote on December 11, 2012. NIOSH had sustained the same recommendation since
2008. SEC-00105 co-petitioner Dan McKeel’s PowerpointTM presentation on 9/19/12
and his text and a slide from his 12/11/12 presentation to the full Board are also
included.

The documents herein include Dan McKeel’s annotated personal transcript, with
comments, of the 2/21/13 TBD-6000 work group (WG) meeting. The official court
reporter transcript of this WG meeting may not be available for several more weeks.
The five attachments A through C are included to encompass thirty eight McKeel 2007
to 2012 white papers and his Public Comment to the full Board made on 12/11/12.

Attachments D and E, respectively, are Dave Allen’s DCAS white paper dated January
2012 and released on 2/4/13, subject “GSI Dose Estimation Comparison,” and the
Robert Anigstein and John Mauro SC&A response to the Allen (DCAS) white paper
teleased on 2/12/13.

Including the DCAS and SC&A 2013 white papers is necessary to understand the most
recent 5 months of Board and TBD-6000 work group deliberations on SEC-00105 and
on revising Appendix BB as a basis for an appeal if HHS denies the GSI SEC.


1 buitding, That was done by the GSI radiation 2 safety people and they used an
8@-curie 3 cobalt-6@ source, where the main work done in 4 that building, of
course, was with a 24 or -S 5 MeV betatron. $o the source they used to 6 model
the building was not the source that was 7 primarily used in that building. 8
Then they also had additional 9 Landauer film badge data on 19 radiagraphers 10
during that period from July 1, 1966 to 1973 11 late or early ‘74, when GSI
ceased operations. 12 And, of course, that was a much smaller 13 percent of the
workforce. 14

And, then finally, the data that 15 they had that Dr. Ziemer mentioned was when
16 Bechtel came in and did a radiologic survey of 17 the old and new betatron
buildings. And ORNL 18 surveilled that. And this was done for DOE 19 under the
FUSRAP program. They only surveyed 20. the new and old betatron buildings, did
not

p46

4

The remediation took a week. And 2 they found uranium and cleaned it up in the 3
old betatron building only, No uranium is 4 found in the new betatron building.
They 5 found some alpha uranium activity on the 6 floors, which they had to chip
out, in the ? vents and in the small industriel vacuum. And 8 it's that piece of
data that the washings 9 relate to. And I’11 mention a little bit more 18 of
that in o few minutes. But we do know of 11 one additional set of washings,
power 12 washings, that was done in both the old and 13 new betatron buildings
in 1973, just at the 14 time of plant closure. And this was an 15 eyewitness
account by a worker who is very 16 well-known to this Board. So there were 17
multiple power washings of the old and the new 18 betatron buildings thot we
hove I think well 19 documented. 2@

A point that is really overlooked

p47?

1 the residual period applies to everybody in 2 the workforce. And most of the
people in the 3 workforce worked in other buildings than the 4 betatron
buildings. And workers there were 5 also exposed to uranium along the whole long
6 uranium pathway whereby it was transported 7 from the weighing scales. 8

Wwe know that everything was 9 weighed that went into and out of the plant. 14
Inspectors had to look under the tarps to moke 11 sure what was on those
transport vehicles. We 12 have operations at the loading dock. We have 13 a
transfer ta rail cars. We have transport 14 along the rail tracks through
buildings S, 15 through 1. And then the railroad tracks ron 16 into the old and
new betatron buildings so 17 that the actual areas that were surveyed for 18
uranium were a tiny fraction of the whole area 19 that formed the volume and the
space along the 2@ uranium transport pathway. And, as David

p48

1 sampling, breathing zone samples, process 2 sampling for uranium ever at GSI
or by DOE 3 until that 1993 survey. 4

Okay. If I could go to the slide 5 3? 6

CHAIRMAN MELIUS: And, Oan, I'll 7 ask you to please move it along. 8


McKeel

EXHIBIT 5

Dan McKeel
BIBLIOGRAPHY
of 38 Papers
submitted to the
ABRWH and the
TBD-6000 Work Group
2007-2012

12-11-2012


McKeel

EXHIBIT 1

GSI SEC-105 talk to
ABRWH in Knoxville

12-11-2012


10

qi

12

13

14

15

16

1?

18

19

20

21

This iranseript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed fox concems under the Privacy Act (S U.S.C. § $523) and personally identifiable
information has been redacted as necessary, The lranscript, however, has nol been reviewed and
certified by the Chair of the Advisory Board for accuracy al (his tima. The reader should be
cautiones that this transcript is for information only and is subject lo change.

handling béing a relatively low-dose exposure
scenario, I will point out that one of the
main references cited by NIOSH and SC&A from
TBD-6000 is that by Adley, et al., for the
Hanford melt plant in 1952. And that showed
that uranium rod handling caused intake doses,
I quote, intake doses 2.5-fold higher than the
permitted limits. So they may have been
relatively low, but they were two and a half
times what radiation safety limits at the time
would permit.

So I thank you and appreciate your
attention.

CHAIRMAN MELIUS: Is the
co-petitioner on the line and wish to comment?

MS. JESKE: This is Patricia
Jeske. And no, I don’t have any comments. I
do agree with Dr. McKeel. And I do hope that
we can reach a vote and put closure to this
for all of our Class Members. I appreciate

everybody's help. Thank you so much.

NEAL R. GROSS

533



Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 2 of 18
1. This portion of the discussion highlights “facts” that appear to still be very contentious.
2. The fact there were two radium NDT sources at GSI was unknown to, and undiscovered

by, this WG until SEC co-petitioner McKee! obtained 1,016 pages of new GSI saurce term data
license data as NRC FOIA 2010-0012. However, beyond the fact the twin Ra-226 sources were
used with the fishpole technique for GSI NDT radiography both inside and outside the 6 Bldg.
roofless, concrete block radiography room, neither SC&A nor NIOSH know the strength or
decay time for the Ra sources, how often they were used, what workers were exposed to them.

3. This WG continues to place great credence on a statement in the GSI 1962 AEC license
application that during the past 20 years AEC dose limits had not been exceeded, and in fact
averaged only 25% of the AEC limits. This statement was completely unverified and no
corroborating film badge data, a film badge vendor, or any living person who can corroborate
this statement with an affidavit has been established. Petitioners consider this reliance on a
statement by a GSI "Vice President and General Manager’ » , not to be reliable.
GS! 1961-63 annual reports do not list Mr. as a company Officer or Director for those 3
years. We have an e-mail from a deceased GSI supervisor to the effect that Mr. was
not employed at GSI from 1955 through 1963. This casts doubt on the validity of Mr.

1962 AEC license assertion about a two decades long GSI film badge program. Where is the
direct evidence of this second major film badge program at GSI 1943-1963?

4, The Alten DCAS and SC8&A give and take discussion under the first “ALLEN” was
difficult to listen to, with lots of talking over one another in incomplete sentences. NIOSH
assigned a dose to a radium radiographer then split it in two, assuming the radiographers
always had a helper. This was not true, so OCAS withdrew this assumption. The petitioners are
distressed this passage deals with a single dase summary for one warker for an unverified
second film badge program at GSI. And it deals with statements we do not trust from a GSI
official (. ) who was not in a position to know for a significant part of the 20 year
period in question. The key paint is this discussion did not lead to a definite dose assignment.

5. Mr. Allen asks where is the WG comfortable, but no answer is forthcoming.

6. Dr. Ziamer acknowledges that defining sufficient accuracy, the hallmark scientific
principle underlying both dose NIOSH/ORAU dose reconstructions (DR) and SEC outcomes, is
still in debate, a “question.” The petitioners find this fact to be utterly discouraging +2 years into
full implementation of EEOICPA 2000. The term should have been defined in 2000-2001.

7. Allen recommends “go with Bob” (i.e. SC&A dose estimate}, Or. Ziemer recommends
giving Betatron man the layout man dose, which is logically absurd. All Betatron operators and
assistants were not Layout men and vice versa, some layout men were not radiographers.
Thus, not all, only an unknown fraction, of layout men were badged. NIOSH and SC&A have no
way to determine who was and was not a Layout man. Also, this “Layout man” term was viewed
by same to be a generic term that fit all 2900 GSI workers who were not radiographers, who.
numbered less than 100 workers during the October 1952 to mid-1966 GSI operational period.

8. Dr. Anigstein of SC&A nullifies the Allen-Ziemer points by observing their suggestions
are "mutually exclusive” (and therefore poorly reasoned). This exemplifies the quality of the


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 18 of 18
PLZ Ask SC&A to do anything?

BEACH
Who occupied thru 1996 - any activity contractors or successors

PLZ - who can clarify

NETON
Don't know

TOMS
store motors

NETON
No radioi work

PLZ Production

NETON
Std TIB-70 Model

3. {Simonds Saw & Steel]

PLZ NIOSH draft matrix responses 2 weeks ago
SC&A gave responses yesterday
« Bob Barton wrote SC&A responses
Look at bounding bioassays

MAURO .
We erred 10 M not 1 M/m3 - [REDACTED]

TED KATZ
What to do at March 12, 2013 Augusta mtg.

4, Next date WG: GSI “closure on models
KATZ (April 26, 2013) How much time we need: “at least a few weeks before mtg.”

PLZ April, Brd teleconfer,, wk 15th out

MUNN
41st wk April (4), 2013 (6 wks)][A/en indicated 6 wks not enough for him to
prepare] [REDACTED]- May 3.6 29, 30, 1, 2 [REDACTED]

-- Adjourn: 2/21/2013 at 2:57 PM EST --
~ 23 -


And 19 nobody knows what mixture was sent to 2@ Mallinckrodt, although I did
introduce a

p42

1 product sent from Mallinckrodt to GSI was 2 dingots. And that would be the
3,38@~-pound 3 metal. 4 Anyway, the first thing I wanted 5 to do in the first two
slides is to review the @ real data that is available right now for the 7 AEC
operational period at GSI from 1953 to 8 June 1966. 9 And it really comes down
to three 1@ data pieces. The first was there were 11 Landauer film badges on 89
radiographers 12 between November 1963 and 1966, June. This 13 represents only 3
percent of the workforce of 14 3,800 people, represents 1 job out of 15
hundreds. The radiographers did not wear 16 their badges outside the betatron
buildings. 17 As a matter of fact, in the 2012 modeling of 18 betatron doses,
they were not even assigned 19 the highest external doses. And so that's 20
point one, very limited and nonrepresentative

p43

1 the entire period from 1953 to 1966, in June. 2

In 1962, there was a one-time 3 survey by GSI personnel of photons in the 4
building 6 radiography room from a cobalt-6@ 5 source. I'm sorry. The 1962
survey was by 6 not by GSI personnel but by the Nuclear 7 Consulting
Corporation. 8

And then the third piece of real 9 data they had in the operational period is 10
they have a series of purchase orders from 11 Mallinckrodt for uranium that
extended from 12 March 1958 through June 1966. There were no 13 purchase orders
found for 1953 through 14 February 1958. So there was no real data on 15 the
uranium source term for those years of the 16 covered period. There was only an
1? extrapolation, back extrapolation, from 1958 18 forward as to what might have
been present. 19

I need to comment that there was a 2@ comment made by Dave Allen in Appendix BB
and

p44

1 they made on the uranium: And that really 2 goes against what we know about
those 3 operations. They, in fact, did send with 4 every item radiographed with
the betatrons a 5 checklist of findings. 6

Now, that's not the final report, 7 Mallinckrodt may well have analyzed that 8
further, and I'm sure they did. But the point 9 is that all of the Mallinckrodt
GSI contract 1@ work records, which must be voluminous, every 11 one of those
has been lost. We don't have any 12 shipping manifestations -- manifests. We 13
don't have any weights. We don’t have any 14 X-ray records, So that's the
operational 15 period real data. 16

Now, on slide 2, I review the real 17 data on residuals contamination period
between 18 July 1, ‘66 and 1993. And, again, that boils 19 down to three items,
three first bullets, and 2@ the comments by me. They had a one-time 1971

pas


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 8 of 18 -- Page is blank (not part of McKeel 2/21/13 TBD-6000 WG notes)

-11-


Betatron Operator

Maximum dose of 26 mrem/week, due to hypothetical 30 keV radiation from behind, film badge partially
shielded by operator's body

Exposure to SLTL Sources

Maximum exposure duration:
° 180 h longest shot
© 10 shots during 6-month period

© Maximum fraction of time: 180 h x 10 shots x 6 mo + 12 mofy = 3,600 hfy + 8760 h/y = 41%

Exposure rate at exclusion area boundary: 2 mR/h

o Maximum exposure of worker at boundary: 2 mR/h x 3250 h/y x 0.41 = 2.67 Rly


2008 & 2012 Models Disagree

COMPUTER MODELED ANNUAL PHOTON DOSE
DURING GSi COVERED PERIOD 1953-1966 (Rem/Y¥R}

DATA 2008 2012
SOURCE BETATRON BETATRON
1.0-6.3 (App BB)
NIOSH ND? (SEC ER) 0.2-.62 var.
SC&A mcnpx 12.4 - 13.6 1.35
2007-2008
DATA SOURCE OTHERS 2012 LAYOUT
1.73 (App BB}
NIOSH 0.417 {note 1] 4.02-2.03
SC8&A mcnpx (see note 2] 9.20

Note 1: Annual dose assigned to only 1 of 3non-Betatron worker
exposure scenarios in SEC-00105 SEC evaluation report.

Note 2: SC&A review of Appendix BB, 4/21/08 Betatron doses
bounded layout men and Co-60 operators which in tum bounded
chainmen and ali other workers. No actual values given for this
large subset of the GSI work force.

3 ND = not done; no annual dose values given in SEC ER


BOUNDING ANNUAL EXPOSURES TO PENETRATING (PHOTON) RADIATION

Years j SC&A—applied to all employees NIOSH |
Bounding scenario Dose/exposure : Source Radiographers Others

1963-1954 oe 45 rem

Radiographer—Ra-226 Ra-226 3.573 R 2.087 R
1955-5/21/62 12 rem
§/22/62-12/31/62 Betatron operator 1.35rem* .Co-60—GSI 4.17R 1348 R
1/1/63-9/30/63 SSLTL Co-60 source 2.669 R jCo-60—SLTL 2.671R :
9/30/63-6/30/66 ‘Layout man 9.2R Betatron 4.483R

* Note change of units from previous reports


SLIDE 2

TITLE: Real data on residual contamination period 7/1/66->1993

One time 1971 radiologic survey of New Betatron Building

by GSi radiation safety officers using 80 Curie CO-60 source.

Landauer film badge data on 19 additional radiographers from

July 1, 1966 to close of GSI operations in 1973 (0.3% work force)
Bechtel/ORNL/DOE uranium radiologic survey of NBB and OBB
between 1988 and 1 week remediation in 1993 of uranium in Old
Betatron building. Uranium alpha on floor, in vents, and in small industrial
vacuum in OBB. No Ur found in NBB. (FUSRAP program]

No survey ever of other GSi buildings that formed a long AEC uranium
transport pathway: Weighing scales, loading dock, transfer to rail cars, RR
tracks through Bldgs. 5 through 10 into OBB and NBB that formed only a
tiny fraction of the air volume/space along the uranium contamination
pathway (had uranium ever been surveyed there by GSI or DOE).


Comment on McKeel TBD-6000 2/21/13 WG Meeting
Page 3 of 18

1. Allen admits the previous confusing discussion caused him to “lose his train of thought”
about the differences between radiographers and non radiographers.

2. Co-petitioner McKeel strongly disagrees with Dr. Anigstein: In 2008 NIOSH and SC&A
computer models assigned a much higher external photon dose for Betatran/isotope operator

radiographers compared to Layout men, who were equated with all other plant workers. This
SC&A untrue comment is a good example of how the historical records gets distorted. The
petitioners believe all of the NIOSH Appendix 8B and 2008 SC&A dose assignments should
definitely have been reviewed with the full Board on December 11, 2012, during the SEC-00105
deliberations. The same information should have been reviewed today at the 2/21/13 TBD-6000
work group meeting to finalize GSI dose assignments, which Board members had been led to
believe were “in place” by Mr. Allen before they voted on 12/11/12. Obviously, this was not true.

3. Allen's next two groups of statements listed below were not understandable for the most
part because they were so truncated and not fully explained:

{a) 10 mRem in control raam + MAX layout man (vs) SC&A

({b) > 10 mRem on film badge - Anigstein disagrees [McKeel: how and why?}

(c} | did not mention in this paper [McKeel: what was not mentioned?}

(a) “Neutron dose falls into Layout man.” (MeKeel: what could this possibly mean?]
There was no actual neutron doses measured at GSI, all was computer models. What RBE was
assigned? Relative biologic effectiveness for neutrons may vary between 2 and 20 and must be

measured. GSI radiographer film badges from Landauer did not measure neutrons.
(e) Beta dose reran, etc. [McKeel: Completely clear what this means}

4. Dr. Anigstein prepared a POF presentation that was projected in Cincinnati to those

around the table. Bob Barton operated the projector and changed the slides. However, neither
he nor Dr. Anigstein identified each and every slide being discussed. The petitioner team was
e-mail the document, but McKeel had no way to view it while the WG discussion was ongoing.

5. Petitioners have submitted 5-6 worker affidavits that the “1953 object” in a photograph
worn on his belt by one GSI worker is more likely a GSI identification (ID) badge rather than a
Landauer type film badge as Dr. Anigstein repeatedly puts into the record. We believe this is
incorrect and does not prove there was a GSI film badge program in 1953. No film badge
records from this period have ever been recovered by NIOSH, the Board, or SC&A.

6. The SC8&A position was clearly stated that Layout men during the radium era should
have been assigned a dose of 12 to 15 REM/year, characterized by them as “good evidence.”
But DCAS did not accept this position.


10

il

12

13

14

15

16

17

18

19

20

21

This transcrip! of he Advisory Goard on Radialion and Worker Health, Board Meeling, has been
reviewed for concerns under the Privacy Act ($ U.S.C. § 582} and personally identifiable
informatian has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this fime. The reader should be
cautioned that this transcript is for information only and is subject a change.

survey the rest of .the plant at all.

The remediation took a week. And
they found uranium and cleaned it up in the
old betatron building only. No uranium is
found in the new betatron building. They
found some alpha uranium activity on the
floors, which they had to chip out, in the
vents and in the small industrial vacuum. And
it's that piece of data that the washings
relate to. And I'll mention a little bit more
of that in a few minutes. But we do know of
one additional set of washings, power
washings, that was done in hoth the old and
new betatron buildings in 1973, just at the
time of plant closurxe. And this was an
eyewitness account by a worker who is very
well-known to this Board. So there were
multiple power washings of the old and the new
betatron buildings that we have I think well
documented.

A point that is really overlooked

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

46



McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 6 of 18

PLZ Already have
“All post DR will include that -- can’t remember figure”

ALLEN
“65 hours"

JWR: “Can } comment after (symbol for p with line over it) break?
PLZ: You bet

to $:55 hrs comfort break
Login 9:53 hr CST DWM (10:52 ET) [n=16]

KATZ/PLZ back in session

RAMSPOTT:
1} Thank entire Board, esp. 9 to 8.
2) Futl Board should have had both papers; doses to be assigned
What was trying to be sold.
3} SEC and App BB
{?)=> Layout man is limiting once the NBB was built
- Chainman & all others outside door.
PLZ -Layout = all other

JWR 4) GSI management, if layout got most dose - they never wore badges.
Theory implausible. Never took readings from a layout person. Never was

a badge outside of Betatron Bidgs./ Story is <--- JWR - ignore

John doesn't think /inconsistent<--| . I said
\Mr | sources Ra out in
\ account | plant -- Ra source

| stolen Bldg 10

ANIG Agree workers in finishing Bldgs never wore badges.

-10-


Stide 3

TITLE: Key GSI events during the residual period 1966-1993

OBB had been power washed and cleaned in 1973 and 1984;
NBB had been power washed/cleaned and renovated for offices
in 1973, August 1978, and 1984;

National Stee! taught classes in the New Betatron Bldg. offices;
Multiple companies used former GSI buildings for operations:

a) 5 and 6 for steel “pickling” (conc. acid cleaning) rolled steel:
Granite City Pickting & Warehouse from 1984 to present;

b) 8, 9 and 10 for “slitting” steel rolis: Michigan Metals Process-
ing (1978 through 1981) and Affiliated Metais (dates uncertain).
Overhead crane w/magnet to clean dust from GSI Bldgs. 5 --> 10.

Multiple users and intermittent operations = massive dust disturbance
that make accurate modeling and bounding difficult or impossible.


This transcript of the Advisory Board on Radiation and Worker Health, Goard Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C, § 5523) and personally identifiable information has
been redacted as necessary. The Wanscripl, however, has nol been (eviewed and certilled by the Chair
of the Advisory Board for accuracy al this lime. The reader should De cautioned thal this lranscript is for
information only and is subject to change.

DAVID B. RICHARDSON, Member
PRESENT: {CONT.)

GENEVIEVE $. ROESSLER, Member

PHILLIP SCHOFIELD, Member

PAUL L. ZIEMER, Member

THEODORE M. KATZ, Designated Federal Official

REGISTERED AND/OR PUBLIC COMMENT PARTICIPANTS:

ADAMS, NANCY, NIOSH Contractor
ALEXANDER, TERRY
ALLEN, DAVE, DCAS
BARRIE, TERRIE

BROCK, DENISE, DCAS
BURGOS, ZAIDA, NIOSH
CARROLL, STEPHANIE
DOBROVOLNY, MARK
EATON, CLARISSA*
EVASKOVICH, ANDREW
FITZGERALD, JO£, SC&A
GALLAGHER, DER

GLOVER, SAM, DCAS
HINNEFELD, STU, DCAS
JERISON, DEB

JESKE, PATRICIA‘
KENNEY, CECELIA, DOE
KINMAN, JOSH, DCAS
KOTSCH, JEFF, DOL
LEWIS, GREG, DOE

LIN, JENNY, HHS
MAKRIJANI, ARJUN, SC&A
MAURO, JOHN, SC&A*
MAUSER, TERRIE*
MCCPEE, MATTHEW, ORAU Team
MCKEEL, DAN*

NETON, JIM, DCAS

RAY, SARAH*
RUTHERFORD, LaVON, PCAS
STIVER, JOHN, SC&A
TAULBEE, TIM, DCAS

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS:

GAAP RUE IAL AMIN AT



MeKeel transcript TBD-6000 WG 2/21/13 meeting

Page 4c of 18 (McKeel SEC-00105 co-petitioner comment)

6. Conversely, SC&A did not estimate doses for Ra-226 and check DCAS's dose
estimates *outside* the Bldg 6 radiography facility. Both Co-60 and Ra-226 sources
were used outside the Bldg block radiography Bldg. 6 facility, and sometimes these
exposures were unattended.

7a, Where did SC&A & NIOSH get AEC limits 1954-55 (source reference}? No verified
GSI film badge program (with a known vendor) before 1963 or during the period GSI VP
and General Manager -stated "past 20 years.” There is no proof of this
last statement -- no film badges, badge reports, known badge vendor.

7b. It was very misleading of Mr. Allen to imply on 12/11/12 to the Board that being
awarded an SEC could be a bad thing for GSI claimants. The statement is false and |
have data comparing 11 AWE sites with and without SECs to prove that point (PDF
Attachment A). | stressed the point in my PUBLIC COMMENT on 12/11/12 after the GS}
SEC session ended. | was allowed only 10 minutes to comment by Dr. Melius during the
SEC session and had no further time allotted to rebut Dave Allen's several inaccurate
statements made to the Board.

Dan McKeel then read into the record the four main totals from his AWE “with and
without SEC” analysis (ATTACHMENT A: Excel Spreadsheet POF file). The major
results read into the record were:

+ EEQICPA Part B % paid covered cases, no SEC [n=6] 26.34% vs
+ EEOICPA Part B % paid covered cases, has SEC {n=5] 52.43% wiSEC
+ EEQICPA Part B completed DR % paid, no SEC [n=6} 26.20% vs
+ EEOICPA Part B completed DR % paid, no SEC [n=5] 39.30% wiSEC

8a. said both Co-60 and Ra-226 sources were used outside Bldg. 6
“throughout the plant.” (former worker interviewed by SC&A on the record)

8b. There was no discussion in these two latest papers that TIB-70 does not include the
cyclical pattern of usage that GSI buildings in the uranium path got because of
repurposing of the facilities by multiple commercial entities during the residual period
from Mid-1966 through 1992. The exact intake model that NIOSH will use for DR has
not been spelled out clearly.

9. Doses were not assigned for the two GSI 250 KVP portable x-ray machines or for the
GSI owned Ir-192 source in the latest Allen and SC&A papers.


SOURCES OF EXTERNAL RADIATION EXPOSURE AT GSI
{Entire period of AEC operations, unless otherwise noted)
Exposure to direct penetrating radiation (photons) from betatron operations
© Stray radiation during betatron operation

© Delayed radiation from activated metals

Exposure to sealed radiography sources

o *6Ra—2 sources, 500 mCi ea: 1953~May 21, 1962

© Co—260 & 280 mCi (initial activities). May 21, 1962—June 30, 1966
o ©Co—10 Ci, employed by SLTL: from January 1, 1963

o TMr—50 Ci, occasionally employed by SLTL: from January 1, 1963

Exposure of skin to non-penetrating (beta) radiation
9° Natural uranium and photoactivated uranium isotopes

© Activated steel


McKeel

EXHIBIT 7

Dan McKeel
Talk to the 86th
ABRWH in Denver
September 19, 2012

Transcript Pages 39-53
(original + condensed)

12-11-2012


OR. McKEEL: I will. 9

CHAIRMAN MELIUS: We have 1@ something else scheduled at this time. 11

DR. McKEEL: Okay. Thank you, 12 Jim, I don't think I‘ve used my ten minutes, 13
but I was trying to address questions -- 14

CHAIRMAN MELIUS: Yes, you have. 15

DR. McKEEL: -- that weren't 16 answered by anybody during the discussion 17
period. So the key events during the residual 18 period I would like to point
out were the 19 power washings for the old and new betatron 2@ buildings and
that multiple steel companies

p49

1 through 18, but they required an overhead 2 crane with a magnet to clean the
dust from the 3 GSI building. So there was lots of it there 4 and that all of
these multiple users in 5 intermittent operations during the residual 6 period
meant that it would be very difficult 7 to model and bound residual
contamination. &

Slide 4 and slide S. I go over my 9 reasons why I believe sufficient information
1@ hos been presented to vote for the SEC at this 11 point and that I hope very
much the Board 12 might consider that done. 13

And I think I have been over the 14 work that was the real data thot was there
15 during the operational and the limited 16 periods. I've been over the fact
that most of 17 the workforce, which should have been badged 18 because of their
exposure to activated steel 19 had not been badged. 20

The slide you see after four shows

pse

1 betatron and layout workers that SC&A and 2 NIOSH had generated in 2208-2012
didn’t agree 3 with each other at those times, and they 4 flip-flopped. 5
Whereas in 2632, the Layout 6 workers had a low dose assigned by SC&A, by 7
2012, the SC&A Layout dase had gone to 9.2 and 8 the NIOSH Layout dose was only
1.02 to 2, So 9 they didn’t agree with each other at that 10 time. 11

And, finally, you can see in slide 12 S -- I apologize. I am going to go to
Slide 13 6. I am going to go to slide 5, finish this 14 up quickly. 15

It is often said there was a 16 robust, relatively robust, radiation safety 17
program between 1963 and 1966 and during part 18 of the residual period at GSI.
And we have 19 just given you evidence now that J don’t think 20 that was true
compared to other sites. I sent

p$1

1 Watertown Arsenal, which also was in 2 compliance with AEC regulations in
about the 3 same time period as GSI's operational period. 4 And they were far
more extensive than anything 5 that was done at GSI. 6

T have pointed out that NIOSH has 7 no valid uranium intake model for the whole
8 operation and residual periods. NIOSH didn't 9 want to use SC&A's alternate
model. In my 18 opinion, the new surrogate data that NIOSH has 11 proposed
really would probably not pass the 12 surrogate deta criteria for the same
reasons. 13 There were two slug facilities and one billet 14 facility. And there
were no dingot facilities 15 similar to GSI and the use of Mallinckrodt 16


10

11

12

13

14

15

16

17

18

19

20

21

This vanscript of Ihe Advisory Board on Radiation and Worker Health, Board Meeling. has been
reviewed for concems under the Privacy Acl (5 U.S.C. § $52a) and pessonally identifiable
information has been redacted as necessary. The transcript. however, has no! been reviewed and
certified by the Chair of the Advisory Board Jor accuracy at this time. The reader should be
caulioned thal lhis Gansoript is tor information only and Is subject to change.

today that GSI did not analyze the reports 4,

they made on the uranium. And that really
goes against what we know about those
operations. They, in fact, did send with
every item radiographed with the betatrons a
checklist of findings.

Now, that's not the final report.
Mallinckrodt may well have analyzed that
further, and I'm sure they did. But the point
is that all of the Mallinckrodt GSI contract
work records, which must be voluminous, every

one of those has been lost. We don't have any

shipping manifestations -- manifests. We
don't have any weights. We don't have any
X-ray records. So that's the operational

period real data.

Now, on slide 2, {1 review the real
data on residuals contamination period between
July i, '66 and 1993. And, again, that boils
down to three items, three first bullets, and

the comments by me. They had a one-time 1971

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS



General Steel Industries SEC-00105 Co-petitioner
Daniel W. McKeel, Jr., M.D,
Letter to the TBD-6000 Work Group

November 28, 2012
To members of the TBD-6000 work group and staff of the ABRWH,

J am today resigning by this letter, in protest, from active participation in the further
deliberations of the ABRWH TBD-6000 work group concerning GSI Appendix BB and SEC-
00105. I have become persuaded that a majority of this work group, together with the DCAS and
SC&A representatives, have exhibited a longstanding persistent personal bias against adequately
evaluating the many substantial scientific contributions made to the ABRWH since 2005 by
myself, other GSI site experts, and the GSI petitioner team. In particular, GS claimants have
been denied statutory due process under BEOICPA 2000 by not having Appendix BB to Battelle
TBD-6000 revised in a timely and factvally accurate manner since it was released in June 2007.

McKeel personal contributions have included: (a) in 2006, being the first person to alert
the ABRWH, DCAS and SC&A to the existence of Landauer film badges for a limited number
of GSI radiographers 1963-1973; (b) to clearly define all of the radiation source terms at GS] in
conformance with DCAS directive OCAS-1G-003, via NRC FOIA 2010-0012, of | ,1016 pages
of AEC by-product license material for GSI; and (c) most recently, via DOB ORO FOIA 2013-
00013, I have shown that during November and December 1952 an active collaboration was
ongoing among MCW, AEC Oak Ridge Office (ORO), and GSI personnel in developing
Betatron radiography uranium imaging techniques that were applied to thin slices of MCW
ingots. A special uranium shield fabricated at MCW was used to contain scattered radiation
fields from the 24 Mev Betatron x-ray beam. The stated purpose was to provide higher quality
x-ray images of AEC/MCW uranium products.

Furthermore, DCAS/NIOSH and SC&A and certain Board members have chosen to
ignore a large fraction of the above and other numerous factual contributions, as oral and written
comments and papers, by the petitioner/site expert and GSI worker/claimant team as reflected in
the transcripts of TBD-6000 work group and ABRWH full Board meetings. Various HHS FOIA
and DCAS personnel have made accessing crucial GSI SRDB documents especially difficult.
For example, obtaining a single copy of Harris-Kingsley 1958 from the COC/ATSDR FOIA
Office took over two and a half months. Many of my e-mail requests to the TBD-6000 work
group chairman go unanswered by him, except through a surrogate, the DFO or NIOSH SEC
Counselor, neither of whom are the Board or work proup secretary per se.

Finally, | am persuaded that, for GSI at least, the SC&A evaluation team has switched
from strongly recommending a GS] SEC for the first 10 years in October 2010, to its present
position in supporting a denial of SEC-00105. SC&A is no longer acting as an effective
oversight agent for the Board, at least in the case of GSI. Rather, it and the work group chair
have become stalwart scientific allies and collaborators with DCAS. The SC&A review paper
released to me on November 26, 2012, at 12:30 p,m, is a prime example of the close
collaboration between SC&A and DCAS. Whereas in their August 2012 paper SC&A found that
use of a uranium slug facility in TBD-6000 failed to pass the S Board surrogate data criteria, now
SC&A finds that David Allen’s slug facitities meet all Board surrogate data criteria. Four Allen
Aug/Nov 2012 white paper AWE sites have only 14 claims and 13 dose reconstructions between

-t-


operations within Buildings 6 through 10, All this was presented and agreed to by all
parties at the 8/28/12 TBD-6000 WG meeting. TIB-70 does not model this scenario.

, [10] Petitioners have submitted three DOE documents that prove GS! Belatron AEC-
MCW operations were underway during November and December 1952. Those
documents have been available since 1998 in the ORO RHTG unclassified database,
and on the FUSRAP website as IL.28-5, and as an ORAU data capture dated April 4-8,
2011. We circulated the key information to the Board, work group, SC&A, NIOSH, and
DOE on Oct. 19th and to DOL on December Sth and 10. The 1952 GS! betatron AEC
collaboration data should have resulted in changing the GS! operational period start
date from Jan. 1, 1953, to Nov. 1, 1952, long ago. We hope that will be done soon.

{11} Member Beach on 11/28/12 offered a motion to recommend approving a GSI
SEC for 1953-62. That motion died because there was no second by the other three
WG members. Dr. Ziemer's stide presentation for today omitted that important fact.

in closing, The TBD-6000 work group, NIOSH and SC&A have had 5+ years since
June 2007 to fully resolve al! Appendix BB Rev 0 issues. The SEC-105 deliberations
have taken 4+ years to come to this point. The petitioners, “the fifth vote” in this drama,
from the outset have recommended this Board APPROVE an SEC for GSI from 1953 to
4993. We urge the Board to do the right thing and cast this approval vote today.

- verbal run through #1 ~10 minutes 8:57 to 9:07 CST
- text edits...

- verbal run through #2: 11 minutes

- re-edit taxt to shave 1 minute

- verbal run through #3: no time left...


McKee! lranscript TBD-6000 WG 2/21/13 meeting

PAGE 15 of 18

ANIG & MAURO .
Use limiting dose: good models. 1 FB record, “evidentiary”...
mentions my (Dan McKee! photos) sign do not approach within 100 Feet

HAVE NOT GOTTEN TO APP-BB
ISSUES MATRIX 1 1/26/2072
NETON
Still feel people are Admin - 9 REM not appropriate. We do this all the time at
Other sites.

* BOB BARTON
Industrial Hygienist (McKeef note to self.) WHO IS HE? DCAS OR SC8&A

MAURO

If we had interview | How could you come up with dose for office mgr, clerk
ANIG There are nor records | Outcome will depend on dose reconstructor.

Very subjective.

MAURO
Philosophically in agreement w/what was said, but usually at DOE - 95%ile
environmental co-worker models at DOE.

1255 CST --> No FB data troubled me at the beginning...not averse to policy -- “Haven't
heard what that is"
Not 3 categories as at DOE / co-worker:

PLZ did not talk about office workers - found dose (do know who was a radiographer)
for radiographers. Have 3 groups -- limited numbers doing that
- Most are not operators

MAURO
15 REM no one got it - confidence - “WHY SEC DENIED”

-19-


EEOICPA AWE COMPENSATION RATES, WITH & WITHOUT SECS, 1/8/2013 DOL STATI

SITE (SEC YES/NO} B COV CASE 6 PAID CASE 8B % PAID DR TOTAL

GSI (NO) 333 72 21.60% 288
CHAPMAN VALVE (NO) 154 46 29.90% 134
UNITED NUCLEAR (NO) 102 46 45.10% 68
BLISS-LAUGHLIN (NO} 57 16 28.10% 49
ALLIS-CHALMERS (NO) ? 0 0.00% 4
WR GRACE (NO) 6 2 33.33% 4
DOW Madison (YES) 231 124 53.68% 182
BLOCKSON (YES) 175 129 73.71% 141
TEXAS CITY CHEM.(YES) 45 11 24.40% 25
BETHLEHEM STEEL (YES) 2116 1359 64.22% 1116
SIMONDS SAW (YES) 260 120 46.15% 208

DR Paid last column: DR paid / DR complete x100 =% DR paid
Chapman AWE has 16 pt E claims - why?

Daw 57 in SEC class paid

Blockson 33 in SEC class paid

Texas City Chemicals 9 in SEC class paid

Bethlehem Steel 158 in SEC class paid

Simonds Saw & Steel 24 in SEC class paid

CONCLUSIONS
1. AWE sites with SECs get paid twice as much under Part B as AWEs without SECs (refutes Alle
2, AWE sites with SECs have 50% more payments for DRs compared to AWE sites without SECs

Submitted by: Daniel W. MckKeel, Jr., MD, GSI SEC-60105 co-petitioner



DAN MCKEEL LIST OF EXHIBITS 1-7 (December 14, 2012}

EXHIBIT 4 is Dan McKeel's verbal presentation to the ABRWH about GS} SEC-00105 on
12/11/12 when it met in Knoxville, TN. This presentation was delivered just before the full Board
voted 7 aye and 6 nay with other members absent at the time of the final full Board vote on
SEC-00105. The absent members, who include Drs. Poston (work group member), OR. Lockey,
and Mike Gibson, may not get to see an official ABRWH 12/11/12 meeting transcript before
they cast a final vote.

EXHIBIT 2 a PDF format slide presented 9/19/12 and 12/11/12 to the full Board that hightights
large differences in GS| external dose assignments by SC&A and NIOSH computer models to
Betatron operators and other workers, including layout men, comparing 2008 with 2012 results.
This same siide results were also discussed in detail al the TBD-6000 work group meetings on
March 1§ and 28, 2012, June 2012, 8/28/12 and 11/28/12.

EXHIBIT 3 is POF file of Dan McKeel’s protest letter read into the record by DFO Ted Katz
when the GS! SEC co-petitioner resigned from active participation in the TBD-6000 work group
meeting held on 11/28/12. The letter states his reasons why he withdrew.

EXHIBIT 4 is a PDF file of Dan McKee!’s Public Comment made on the record immediately
following his presentation at the ABRWH 12/11/12 meeting in Knoxville, TN.

EXHIBIT 5 is a PDF bibliographic listing of 38 technical review and informational papers about
GSI that Dan McKeel has created and delivered to the TBD-6000 work group and full ABRWH
between 2007 and 2012. The active URL links and titles come directly from the DCAS website
listing for Docket 140 (GSI}

EXHIBIT 6 is the Powerpoint (PDF version) presentation made to the full ABRWH on
September 19, 2012, in Denver, Colorado,

EXHIBIT 7 is two PDF versions of Dan McKeel’s Board testimony on pages 39-53 of lhe 340
page ABRWH meeling court reporter transcript far 9/19/12. One version is formatted as is the
original transcript and contains the first S pages of the transcript and the last two as well. The
second version is copy/pasted to produce a more compact new version with the exact same
content. The reader may prefer whichever version is more comfortable for them to read

Founding member SINEW


Slide 5

TITLE: Reasons GSI deserves an SEC recommendation by the Board

Part 2
Rad safety program rudimentary 1953-1993. NCC license documents are
inadequate based on Watertown Arsenal AEC compliance program;
NIOSH has no valid Ur intake model 1953-1993; failed surrogate criteria;
At least three previous attempts have failed to pass Board/WG scrutiny.
NIOSH rejects SC&A alternate mode! that had to be withdrawn because
Betatron buildings had been washed/cleaned multiple time 1973-1993.
NIOSH “new” surrogate data not based on uranium ingots/dingots that
was the product MCW primarily sent to GSI for betatron NDT radiography.
NIOSH “better” surrogate sites were not stringently justified: 2 slug and 1
billet facilities proposed; no dingot facilities similar to MCW-GSI;
NIOSH has never recovered from Mallinckrodt the multitude of Betatron
NDT related records (shot fogs, x-ray reporis, shipping manifests, etc.)
from GSI generated over 13 years of the AEC uranium NDT contract (only
purchase orders February 1958-June 1966).


Attachment 1

20 U.S. Atomic Energy Commission
CURRENT OCCUPATIONAL EXTERNAL RADIATION BXPOSURE
Ident ficacion.
Name (Printe-Last, first, and oiddle) 2, Soe
Dat year) MG. Age im Full Years (N}
Se
Occupational Rxpogure

Dose Recorded For (Specify: Whole
body; skin of whole body; or handi
and forearms, feet and ankles.)

. Permissible Dose at ?.
Beginning of Pariod

Covered by This Sheet

Method of Montroring (e.g., Fila
Badge--FB; Pocket Chamber--PC;
Calculation--Calc.)

Gamma Bie tw.
Whole Body 48.26 BEN Neutrons.
ree eae Dose for she Period (cam) MREM p> Roreing Total Sor
9. Canma 10, Beca | 12. Neutron) 12, Total (rem)
“1963,
lel To 3-31 Total 15 015
4-1 To 6-30 Total Q O15
J-1 Ta 9-30 Total $ 2020
16-1 To 12-31 = Totald 100 120
Geend total | 120 120
——!
Lifetime Aceuwilared Dose
1. Previous 15. Total Bose | 16, Total Accum-17, Perm. Ace. Dose 1G, Permissible Dose
Total Recorded on lated Dose
This Sheet
16.74rcn a“ ren| 26.86 rem|$(N--18)= 70.0 ren 53.16 re
1, Same af Licenses —
\
\ GENERAL STEEL INPUSTRIES, INC.
\ COMMORWEALTE DIVISION

Response to “GSI Dose Estimation Comparison” -ll- SC&A February 12, 2013
NOTICE: ‘his report has been reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82.


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 10 of 18

ANIG Lower limit not fess than 9.
3 should not be included.

PLZ Taiking 5.4 mRem

NETON
don’t know if we can flesh out the details
here [0.63 triangular]

1.86
ANIG Where did &.41 come from? Footnote (d) + 8.68 at boundary, still divided:
§.41/2 + 8.68 (Allen nothing at bound)

POSTON
Not on line. Katz asked again - no answer.

ANIG Can use 2 Ra sources simultaneously Rat || Ra2

MUNN
mREM levels

Betatron era: different

Others: This era from Ra alone
{--> |--2.08 mREM

/ ALLEN says use SCA figure

ANIG ---{2.087 “very arbitrary]
25% occupancy factor. How well based | don't know. Not a strang number.
Lower than skyshine 0.72 x 3250/yr = 2.3 mR/yr or MREM/yr - old were higher
Same dose everyone gets assigns
Bob Barton looked at all claims POC < 50% to date = 1 radiographer. 5 or 6
duties unknown

(McKeel) How did Barton get these stats?
margin note: Taiking about Radiographer + Betatron

ALLEN
There is no agreement about Betatron operators

PLZ Can't get Beta/radiographer -- don't know who did what. Rest of population, what
is being proposed.

-14-


a) GSI used only Mallinckrodt ingots, uncropped dingots, “betatron slices,” and
some billets. The surrogate Allen-NIOSH sites used uranium dingots, billets, derbies
and slugs but no ingots or betatron slices.

b) The surrogate sites did not perform 24-25 Mev Betatron x-ray radiography on
their uranium. That is why the AEC was actively collaborating with GSI in +952 to
imporve x-ray images soon after the first Betatron was put into operation in January
1952.

c) The DCAS surrogate sites have not been “stringently justified.” Allen admits
this, saying he will do the justification in a revised Appendix BB at some undefined time
in the future. This is not acceptable: NIOSH needs to be able to demonstrate stringent
justification today, before this full Board votes on GSI SEC-00105.

{7} Six GS! SEC issues were moved to the Appendix BB issues matrix as was
mentioned at the 11/28 WG meeting. Those issues were deliberately left open to be
resolved and closed later in 2013. This was a poor decision, because they were still

SEC issues that needed to be resolved prior to the final recommendation.

[8a] There is zero monitoring of uranium air intakes or urine uranium bioassays,
or of GSI external Beta and Neutron doses, for any GSI site worker 1952-1993.
SC&A and NIOSH admit this fact.

{8b] The only film badge data for GSI is for radiographers 1963-73. The Landauer
GSI film badges only read photons. Radiographers only wore their badges pari time.
97% of the GSI work force of 3,000 covered in the SEC-105 class were never badged.
They should have been because Betatron-activated castings were all over the plant,

{8] _ TIB-70 surrogate data is not appropriate for modeling GSI residual period
uranium intakes. The T/B is based on a known start value that steadily declines. At GSI
there were periodic uranium dust resuspension cycles due to power washing both

Betatron buildings, renovation construction at the New Betatron facility, and new


McKeel transcript TED-6000 WG 2/21/13 meeting

PAGE 3 of 18

ALLEN
- lost train of thought - non radiographers + radiographers

ANIG - highest dose in 2008 to layout man - (NO! McKeel insertion) but this
dose was low

ALLEN
- Several shooting scenarios used by DCAS - various angles + locs in shooting
room. Used work schedule for workers for
m10 REM in control room + MAX layout man (vs) SC&A
> 10 mRem on FB - Anig disagrees

ALLEN #3
(did not mention in this paper.
“Neutron dose falls into Layout man.”
“Beta dose reran etc.”

ANIG Based entirely on cleared -- Just cleared .
PLZ Mail this out. Do It this moment.

ANIG Sending me, JWR Anigstein’s PwrPoint over(/y) accommodating -- DM
can't view - it's too tate.

SLIDE 2: Dates, confess by calendar year. DCAS May 21, 1962; 1/4/63 StL
Testing began its work.

Uran - 2 short isotopes very high beta dose. Called into ?
Badged 1953,
Rubber hits road -- SC&A position. 12 + 15 REM, Good evidence


DAN MCKEEL GS) PAPER BIBLIOGRAPHY: PAGE COUNT SUMMARY

DOC PAGE

Na. Pages

Duplicates

13
20
4
9
14
7
43
16

28
wa
24

26
26

31
36

14
12

Attached 1
Attached 2
Attached 3
Attached 4
Attached 5
Attached 6
Attached 7
Attached B

12/8/12
Page No. Papers | No. attachments
1 9 0
2 7 0
3 1 8
4 11 o
5 2 o |
30 &
Pages per document Page|
DOC page | Pages total
1 132
2 127
3 117
4 130
5s |
539
Mckeel Papers by Year
YEAR PAPERS ATTACHMENTS
2012 23 8
2011 s Q
2010 2 i)
2009 4 0
2008 i) Q
2007 1 °

29

37

24

n

19

buljpasboaa bone e elwewuwu wees WINN YN NM NTO Pr eRe

10
23

TOTAL

539

413

less Attached’

426



Comment on McKeel TED-6000 2/21/13 WG Meeting
Comment on page 2 of 18, continued from page 3...

8. (cont'd from previous page...) science used by Allen and the TBD-6000 work group at
the GSI Illinois AWE site in deliberating both SEC-00105 and revision 1 of Appendix BB and
revision 1 of TBD-6000, the parent document.

9. Allen then recommends taking “the highest dose” without stating what that dose ts,

10. Allen follows with a false (untrue and inaccurate) statement that the “layout job was
done by radiographers.” This is a distortion of the official record. What is on the record is that
some isotope and Betatron radiographers sometimes filled in as jayout workers. There is
absolutely no documentation that the layout job was done by radiographers all of the time. In
fact, since 2008, SC&A and at the start of this meeting chairman Ziemer equated Layout men as
all other workers at GSI. That is, “layout man” defined non radiographers. That this mix-up in
jobs and terminology should occur within this key work group to this extreme extent this late in
the deliberations on GSI Appendix BB is truly astounding and is not scientifically defensible.

11. Member Beach's question, which | presume was directed to Mr. Allen and DCAS, was
why did NIOSH not calculate or mode! doses for the Bldg. 6 radiography room during the period
1952-1962 when Ra-226 sources were being used for NDT radiography in addition to the Old
Betatron 24 Mev x-ray unit? This question went unanswered. Chairman Ziemer did not ask
DCAS to answer the Beach question. And Ms. Beach did not press for an answer. This happens
repeatedly during TBD-6000 WG meetings. The members talk past one another, questions are
not answered or ignored by the chair, and decisions are therefore delayed or not made.

12. Neither Member Munn nor Member Poston joined in the preceding discussion thread.

13. The petitioner's rejoinder to Ms. Beach is that the foregoing discussion was disjointed
and inconclusive, and was the opposite of “well done," scientifically speaking.

14. The next two passages are factually incorrect. Layout men operated at both the Old and
New Betatron buildings on the rail tracks just outside the x-ray facilities on “rush” or “hot”
castings that needed NDT inspection immediately. This need prevailed throughout the covered
period at GSI that is now Oct. 1, 1962, through June 30, 1966.

15 The last two passages show that Allen and DCAS and Anigstein and SC&A could not
even agree on what the layout man job entailed. Allen and NIOSH believes they laid out shots in
contrast to Bob Anigstein who states layout workers marked repairs but not shots. The
petitioners believe Layout men, who may not all have been men (another unknown at GSI), did
both shot layouts and repair marking. One can observe that no rea! attempt was made by the
Chair to resolve this central issue “on the spot.”


Daniel W, McKee! GS| SEC co-petitioner bibliography 12/8/12

+ Dockel 140 (GSI) Submission rom Daniel V7. bickecl, Jr, M.D. aresentation to the
Advisory Board's Wark Group on. arch 45, 2012

(March 17, 2042)
(2. PDF 5.3 MB (29 pages)

+ Docket 146 (GSN Submi
(March 11, 2012)
f. POF 82 KB (+ page}

Docket 149 Genera! Steal ndusiries; Addend a
4 POF 4.8 MB {37 pages}

. chet 14 SI) Submission fr nie] W, MeKeel, Jr, V1.0. reaardino the Nil
January 2042 White Pacer on "Dose Estimates For Belatron Operations”
(February 27, 2012)
yp. POF 2 MB (1 page)

Aflachnent: Critique of tho NIOSH Janyary 2012 While Pape: "Dose Estimates For
Betatron Operations”
}» PDF 4.2 MB (24 pages)

Comments from Kent Wall, is vember 2. 2011, Advisory Board's
Work Group Meeting an TBD 6000

(November 4, 2011)

af, PDF 4 MB {2 pagas)

« Comments from Daniel W, M4 na new General Sleel Indusiries related
1978 report: OSHA Regulates Betatrons & Accelerators

{September 6, 2011)
g. POF 97 KB (6 pages)

Comments from Daniel W, MeKeel, Jr .D., on the General Siee! Industries SEC
(July 22, 2011)
g PDF 203 K8 (4 pages)

« Comments fr niel WW, MeKeal .0.,.0n the Genera! Steel Indusiries SEC
Petitions (NIOSH SEC-00105) .
(March 12, 2011}
i. PDF 3.5 MB (19 pages)

» Comments from Daniel W, McKeel, Jr, M.0,, onthe General Steel Industries SEC
Potition (NIOSH SEC.00105}
(February 7. 2011)
{,. PDF 2.7 M8 (4 pages)

= Comments from Daniel W, MecKeel, Jr. M4... on the General Steel Industries SES
Petition (NIOSH SEC-0010S)
(Aprit 26, 2010)
gs PDF 163 KB (3 pages)


DM_PublComment_12.11.12.rtf

PUBLIC COMMENT — DAN MCKEEL
-- 12/11/12 -
Good afternoon again.
I want to respond to several points just made in the
GSI SEC session that I feel need to be corrected
immediately and put on the record.

[1} David Allen and DCAS’ suggestion that recommending an
SEC for the early years 1953-62 might actually be a BAD
THING and be “claimant unfavorable,” was the way he put it,
is misleading to GSI and other claimants. Larry Elliott,
former DCAS director told me the same tall tale way back in
2005. Since then I have checked out this proposition that
seemed incredible to me at the time and it certainly has
turned out to be “not true” in practice.

Compare EEOICPA compensation history for the GSI and
Dow IL "sister sites” right next to one another. GSI has
twice as many claims, cases, and DR completed, yet the
total Part B compensation amounts are $10 million+ dollars
at GSI with no SEC and a far longer covered period,
compared to $17+ million dollars at Dow with a 1957-60 SEC.
I have had it confirmed by many observers that SEC sites do
far better compensation-wise despite the 22 SEC cancer
restrictions.

And Mr. Allen speculated on the types of cancers GSI

claimants might have, a fact that he doesn‘t really know.

2. David Allen’s answers to member Richardson's questions
about non-radiographers being assigned higher doses that
Betatron doses was not accurate or complete. In 2012 the

SC&A assigned dose for GSI “layout men,” a term Allen did


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 17a of 18
Layout Man -- cobalt era

SC&A 9.2 | NIOSH 4.43 models
| No shots/L's Excel/Solver 10 mREM/wk control room

ANIG |Kec-eeseerrernennna| {-> This is normalized to film badges
“Categorically disagree with that” [emphasis added DWM Jr]
Landauer always

ALLEN (NIOSH) arguing with SC&A ANIGSTEIN
{Badge 1 - control room badge - don’t know where it was: OBB or NBB
(Badge 0 is "control badge” Zlotnicki density always diff between 0 and dose
(densitometer subtract NO Anigstein stated) Exact quote said “denied” (Allen)
|--> Not Defensible - Control room never got
NIOSH Allen “Have ‘em both --> Control badge = zero except 2 in 1971
|-> Anig means below (MDL)

PLZ diff between NIOSH 4.483} Excel Solver shots in different directions match
numbers SC&A 9.2 } =be= or </Layout worker.
“shots” we normalized to 10 MREM SCA does not

BEACH
1966 value 1/2 how does that affect 4.483 dose?

PLZ Answered instead of Alien -- puts ONUS on SC&A because (Dan thiinks)
Need SC8&A to write a memo

BEACH /15\
/ \
Q -------- “5” (or 3) ?
On Layout Man cobalt era

PLZ then we need to go back to all Matrixes issues

-21-


Comment on McKee! TBD-6000 2/21/13 WG Meeting

Page 11 of 18

1.

10.

41,

This page continues the discussion of assigned doses for the radium era 1952-1962 to
GSI worker classes whose activities are not clearly defined both inside and outside of
the Bldg. 6 radiography room.

Many different doses are mentioned by all parties: NIOSH 1.3 based on 25% occupancy
(that Dr. Anigstein has previously disavowed) to “everybody else gets outside the room.”
Dr. Ziemer asks regarding the 2.087 MCNP model, “What was the dose rate at the
door?”

Dr. Anigstein answers (from the SC&A Oct. 2011 white paper on GSI portable radiation
sources, “8.56 mR/hr, 30% duty cycle, 10 exposures/shift.” ... “confirm by AEC." Co-

petitioner McKeel did not understand this last comment, because to his knowledge the
AEC didn't measure or estimate any GSI doses at any time at GSI.

Dr. Anigstein speaks for SC&A “We did not model outside because we thought that
scenario was implausible. He adds “2.087 is the assigned dose for everyone.”

» McKeel note: Yet there has been direct interview testimony by GSI worker.

given to both SC&A and to NIOSH, with McKee! as a sifent observer, codified in a format
SC&A white paper, “Report on Three Interviews...” that Radium-226 NDT shots were
often performed outside the Bldg. 6 radiography room “throughout the plant.” Those
doses needed fo be bounded with sufficient accuracy and they have not yet been in the
petitioner's view.

Dr. Ziemer asks NIOSH to weigh in but receives no reply to my knowledge.

Member Munn states the 2.087 figure is "more claimant favorable than | expect real life
would be,” while avoiding saying directly that she agrees or disagrees with the 2.087
number.

Member Beach agrees with the 2.087 number.

DFO Ted Katz has to contact Member Poston, who replies “...very claimant favorable”
and notes “/ have another Class,” (He is a Professor at Texas A&M).

Dr. Ziemer asks whether SC&A is "OK" with the 2.087 dase assignment and Or.
Anigstein replies, “No” adding “25% occupancy rate x 30% throw in 2 factors

= 7.5 rads through the door.”

» McKeel note: | have % and rads as the unit in my notes: the “%’ must be a typo. Note
the SC&A dose would be 3.5 times the NIOSH assigned dose.

John Mauro of SC&A adds: “Yes, gives me comfort." Then adds emphatically: "f
disagree with Bob (Anigstein). | applaud Neton triangular distribution, saying “he
should be in Congress.” (emphasis added)

Summary: Dan McKeel's conctusion by end of this page is “there is no agreement,” a

consensus has not been achieved, with SC&A's Robert Anigstein strongly dissenting
from the NIOSH and Board view (SC&A dose 3.5-fald higher than NIOSH/WG dose),

-14-


McKeel

EXHIBIT 2

GSI SEC-105 talk to
ABRWH in Knoxville:

Slide comparing SC&A
with NIOSH Modeled
External Betatron &

Layout Worker Doses
2008 vs 2012

12-11-2012


McKeel transcript TBD-6000 WG 2/21/13 meeting

ATTACHMENT A

Dan McKeel Compensation Comparison Chart
of 11 EEOICPA AWE Sites:
6 without an SEC
5 with an awarded SEC
(from DOL website
EEOICPA Statistics by State

- 244


10

il

12

13

14

15

16

17

18

19

20

22

This transcript of the Advisory Board on Radiation and Worker Healih, Board Meeting, has been
reviewed for concerns under lhe Privacy Act (5 U.S.C. § 552a) and persanally identifiable
information has been redacled as necessary. The Wanscript, however, has nol been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader srculd be
cautioned that this transcript is for information only ang is subject to change.

letter from the AEC that said the primary 45

product sent from Mallinckrodt to GSI was
dingots. And that would be the 3, 300-pound
metal.

Anyway, the first thing I wanted
to do in the first two slides is to review the
real data that is available right now for the
AEC operational period at GSI from 1953 to
Jane 1966.

And it really comes down to three
data pieces. The first was there were
Landauer film badges on 89 radiographers
between November 1963 and 1966, June. This
represents only 3 percent of the workforce of
3,000 people, represents 1 job out of
hundreds. The radiographers did not wear
their badges outside the betatron buildings.
As a matter of fact, in the 2012 modeling of
betatron doses, they were not even assigned
the highest external doses. And so that's

point one, very limited and nonrepresentative

NEAL R. GROSS

TRANSCRIBERS,

COURT REI



Comment on McKeel T8D-6000 2/21/13 WG Meeting
Page 16 of 18 (continued...)

8 Mauro (continued...)
Mauro says he has "come to agree -- how NIOSH can bound’
+ McKeel comment: Mauro has come to agreement with NIOSH on what specific issue
or dose assignment or category or policy? Bound what, specifically? The statement is
unclear as captured in McKee! notes.

9, Neton of NIOSH here advocates 2 categories. “If not," he asks, “why use CATI?”
+ McKeel summary comment: This discussion of job categories up to this point
has been very disorganized and inconclusive with parties constantly asking
questions that are not answered clearly and with no consensus being reached. It
is impossible thus far to tell anything that the Board members, NIOSH and SC&A
members of the WG have agreed to up to this point.
+ McKeel footnote on the CATI: telephone interview given to all part B DR claimants by
ORAU.# have asked repeatedly (beginning at a 2006 NIOSH OR workshop in Cincinnati)
exactly how CATI information is factored into AWE technical documents apart from
being used in the individual OR program? It appears that CAT! data is mined
intermittently but not thoroughly. Ta my knowledge, there is no DCAS comprehensive
database that incorporates CATI information in specific fields. The main actual use of
CAT information is by dose reconstructors for individual claims.

-21-


This transcript of the Advisory Baard on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (6 U.S.C. § §52a) and personally identifiable information has
heen redacted as necessary, The tenscripl, however, has not been reviewed and Cerlified by the Chair
of the Advisory Board for accuracy at this time. The reader should be cautioned that (his transcript is for

information only and is subject lo change.

TABLE OF CONTENTS
AGENDA ITEM
Welcome - Dr. James Melius, Chair

GSI SEC Petition Update -
Mr. Dave Allen, NIOSH
Dr. Paul Ziemer, WG Chair
Petitioners: Dan McKeel
Patricia Jeske

Pantex Plant SEC Petition (1984- 1991)
Stuart Hinnefeld, NIOSH
Mr. Joe Fitzgerald, SC&A
Petitioner: Sarah Ray

Baker-Perkins {Saginaw, MI) Technical
Basis Document Review
Dr. Henry Anderson, WG Chair

Weldon Spring Plant (Weldon Spring,
MO) SEC Petition
Dr. Richard Lemen, WG Chair
Mr. Stuart Hinnefeld, NIOSH
Petitioners: Tina Triplett

Mound Plant SEC Petition (1972,
1975-1976) (83.14)
Dr. James Neton, NIOSH

Mound Plant SEC Petition (1980-2007)
Dr. James Neton, NIOSH
Ms. Josie Beach, WG Chair

Board Work Session
Or. James Melius, Chair

United Nuclear Corp. (Hematite, MOQ} SEC
Petition
Dr. Henry Anderson, WG Chair
Petitioner: Clarissa Eaton

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

4977 QUE IDL AKIN AMIE KLIAT

15

36
4g

54
84
75
88
94
94
104
104
105
130
165
165
173
173
174

211
211

231

270
270



McKeel

EXHIBIT 4

Dan McKeel
PUBLIC COMMENT to
ABRWH in Knoxville:

42-11-2012


‘This Wanscript of the Advisory Board-on Radiation and Worker Health. Board Meeling. has been
reviewed for concemis under the Privacy Act ($ U.S.C. § 52a) and personally Identifiable information has
been redacted as necessary. The transcript, however, hes not been seviewed and certified by the Chair

of the Advisory Board for accuracy at this Ume. The reader should be cautioned that this transcrigt is for
infarmation only and is subject to change.

Public Comment 301
5

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS



Neutron Dose

The source of neutron exposure is from the operation of the betatran, Thus, neutron doses are included
in the betatron operator dose estimate (which includes others working in the betatron building) and the
layout man dose estimate. The estimates are based on the same models and results used in the photon

analysis.

Beta Dose
Sources of beta radiation are from exposure to uranium metal (both irradiated and intrinsic) and from
the irradiated steel.

The uranium beta dose modeled by NIOSH utilized the SC&A model from its original Appendix 8B
review, Therefore, there appears to be agreement on this approach.

NIOHS estimates of beta doses from exposure to irradiated steel rely on the SC&A model that was
included in their initial Appendix BB review. In their last white paper review, SC&A pointed out that the
MCNPX version used (version 26e} was an early version of the applicable capability and the latest
{version 27e) provided different results. There is no disagreement from NIOSH.

Agreement

- Both SC&A and NIOSH appear to agree that the dose to the layout man is the bounding
exposure scenario during the cobalt era, even though current estimates differ. This bounding
scenario is true for both radiographers and others categories.

- Inthe last SC&A review, SCRA pointed out that the layout man estimate used by NIOSH for alt
years was only really applicable to the new betatron which was not built until 1963. NIOSH
agrees with this. Because NIOSH and SC&A agree on this point, radium radiography becomes
the bounding exposure scenario in the radium era. This is true of radiographers but unclear for
others.

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its
Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or
ABRWH (or their technical support and review contractors) positions untess specifically marked as such. This
document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act 5 USC §552a and has been cleared for distribution.

4


REFERENCES

1} SCRA, October 2011, Update of the Use of Seated Radioactive Sources at General Stee! Industries,
SC&A draft white paper

2) SC&A, September 2011, Review of NIOSH Report on Portable Radiography Sources at GSI, SCRA draft
white paper

3) NIOSH, August 2011, Battetfe-TBD-6000 Appendix 8B General Steel industries Dose Estimates for
Portable Radiography Sources, NIOSH white paper

4) NIOSH, March 2012, Addendum to Dose Estimates for Betatron Operations, NIOSH white paper

5) NIOSH, January 2012, Response to Battetle-TBD-6000 Appendix BB General Steel industries: Dose
Estimate for Betatron Operations, NIOSH white paper.

6} SC&A, March 25, 2012, Review of NIOSH Report: Addendum to Dose Estimates for Betatron
Operations, SC&A memo

7} SCRA, March 2012, Response to Battele-TRD-6000 Appendix BB General Steel Industries: Dose
Estimate for Betatron Operations, SC&A draft white paper

This is a working document prepared by NIOSH or its contractor far use in discussions with he ABRWH or its
Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are nat final NIOSH or
ABRWH (or their technical support and review contractors} positions unless specifically marked as such, This
document represents preliminary positians taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act 5 USC §552a and has been cleared for distribution.

7


Comment on McKeel TBD-6000 2/21/13 WG Meeting
Page 5 of 18

4 There followed a back and forth between work graup members regarding the “control”
film badges -- what they were and what was their significance. Virtually all of these arguments
had been presented and discussed thoroughly in previous work group meetings. This was 2

waste of time that should have been spent deciding Appendix BB matrix issues on Feb. 21st.

2. Or. Anigstein’s assertion that Layout man was not on the railroad tracks at both Betatron
Buildings because one couldn't get the RR car in and out was refuted by worker affidavits during
2012 TBD-6000 WG meetings. Different rail transfer means were used for the two Betatrons.

This is an excellent example of historical revisionism to fit a particular agency scientific position.

3. Someone, probably Dr. Ziemer according to McKeel notes, comments that 12-16 (REM)
is a plausible upper bound 1953 through May 1962. Then why could this dose assignment not
be resolved and “set in stone” right then and there?

4, Dr. Anigstein comments his 2/21/13 PDF presentation is essentially the same as his
June 2012 presentation in Santa Fe to the full Board. That is an admission that old and
inaccurate data is being represented to the work group. Or alternatively, SC&A's position has
not changed significantly in 8 manths despite the two new February 2013 white papers

5 Member Munn, in saying she is uncomfortable with regulatory limits, impeaches her
support of citing the identical regulatory limits to prove doses could be bound and voting to deny
SEC-00105 both in the work group on 11/28/12 and at the full Board final vote on 12/11/12.
Such reasoning is scientifically indefensible and is very claimant adverse. In this regard, neither
SC&A nor NIOSH have stated on the record where they obtained the AEC regulatory limits they
espouse and support. What are the original source documents?

6 Dr. Ziemer acknowledges that computer models are the only method available ta bound
dases during the Radium and Cobait eras. He doesn't nate the absence of validating measured
data at GSI, the lack of bioassay data or air uranium samples, etc., the scientific peer review
community ordinarily demands of authors who publish a new computer data model.

7. Dr. Poston trivializes neutron dose by saying “if it were important.” OCAS-IG-003
mandates that all doses from all sources must be determined with sufficient accuracy. Thus,
bounding the several scurces of GSI neutron doses are very important.

Significantly, no discussion whatsoever took place about the facts that no measured
neutron data was available, resolving the 3-fold discrepancy between DCAS and SC8&A
assigned neutron doses in the two Feb. 2013 papers, or what was the correct RBE (2 to 20),


McKeel transcript TBD-6000 WG 2/27/13 meeting

Page 4e of 18 (McKeel SEC-00105 co-petitioner comment)

Cobalt-60 license application with heavy input by NCC. We now know that many of the
safety practices stated in the AEC license 12-8271-1 were not carried out. WE thus
doubt the veracity or accuracy of the 1962 AEC GSI license absent more proof.

The logical inconsistency: If GSI was always badged 1943-1963 as the license
indicates, why did NCC have to start supplying FB in 1962? - see page 4 of notes

413. 1 underscore that Drs. Mauro and Anigstein both acknowledged during this
meeting on 2/21/13 that Mr. Allen and NIOSH/DCAS swayed the Board, and led them to
vote to deny SEC-00105 on 12/11/12 in Knoxville by stating that all workers would
receive 12-15 REM, which has turned out not to be the case.

14. | hope the Appendix BB 11/26/12 issues matrix will be resolved today. [Note the
matrix was not even discussed at the February 21, 2013, TBD-6000 work group
meeting.)

JESKE (GS! SEC-00105 primary petitioner}
So much emphasis put on 1 radiographer, how accurate for that.
Is amt overtime for 1 radiographer to be assigned to (al! workers?)

[end of McKee! comment notes)

MCKEEL FOOTNOTE:

Although the Board and NIOSH asked McKee! no questions immediately
foltowing his presentation, Dr. Anigstein did make detaifed personal replies tater in the
meeting. These remarks are captured in this transcript on page 7.


Comment on McKeel TBO-6000 2/21/13 WG Meeting

Pages 17b and 18 of 18

The discussion of agenda items 3, 4 and 5 -- Baker Brothers and Simonds Saw and
Steel and the March 12, 2613, WG presentation at Augusta, GA, consumed the final 30
minutes of the 2/21/13 WG meeting that adjourned shortly before 3:00 PM EST.

AttachmentA
McKeel Analysis of Compensation Comparing AWE Sites With And Without SECs

Attachment B
McKeel GS! White Papers “ GSIC.V.” list from NIOSH Public Docket 140, Exhibit 5,
posted to DCAS website on 12/19/12, paper filename: mckeel121412.pdf

Attachment ¢
Robert Anigstein SC&A PDF 8 slide presentation to the TBO-6000 work group 2/21/2013
(slides projected at the meeting in Cincinnati by Bob Barton; Dr. Anigstein by phone)

Respectfully submitted:
SAUNT SAIS NEP RASS S
MS SMARLLLRG eS

Cate SCENY q
LEON
Daniel W. McKeel, Jr., M.D. 3/9/13
Founding member SINEW ___

-23-


McKeel transcript TBD-6000 WG 2/21/13 meeting

Page 4d of 18 {McKeel SEC-00105 co-petitioner comment)

10. Two highly disturbing e-mail threads recently emerged in FOIA requests that were
described in recent ANWAG blogs on the EECAP.org website.

(1) One of these was an e-mail exchange in 2010 in which, at DCAS's request,
the DFO rank ordered various sites with pending SECs based on the degree of "political
heat" that might be brought to bear on SEC decisions. Both LANL and Linde Ceramics
received "high" ratings, whereas GSI received a "low rating” and Texas City Chemicals
and several other sites received a "Never Mind” political heat rating by the DFO. |
personally believe this is one reason that GSI SEC-00105 took so long to adjudicate.

(2) The other e-mail thread was even more disturbing. It was related to the issue
of using surrogate data at the Hooker Electrochemical site and occurred during late
2009. Dave Allen outlined his "throw them a bone" strategy this way...

| quote from his e-mail dated 12/19/09 found on page 4 of the FOIA file that was
obtained by the Hooker petitioner and forwarded to ANWAG and distributed it to me:

“Tor.

From: David Allen

SUBJECT: Good Hooker reading

BODY OF MESSAGE: (quote) The truth is my intent is to "throw them a bone*
strategy. Basically, give SC&A an obvious point to pick on so they will. Often. they stop
once they find one. At that point, | walk in toa WG meeting and agree 100% with all
their hits and let WG members try to figure out how they are going to make it an SEC
when there is total agreement.{end quote)

| plan to include this infarmation in my SEC-105 appeal for i believe the same
deplorable tactic has been used repeatedly during the deliberations on GSI Appendix
8B to TBD-6000 and during the decision process on SEC-00105.” (end quote)

11. St. Louis Testing used 2 sources - Co-60 (10 Ci) + IR-192 (50 Ci) that are not
separately bounded by Allen or by SC&A. [OCAS-iG-003 used by NIOSH mandates
that during the covered period, all radiation sources must be determined with sufficient
accuracy; this has not been done for all sources at GSI in Appendix BB or SEC-105].

12. a) NCC [Nuclear Consutting Corp.} furnished FB [who supplied them?]

b) 1 person summary 18 gtrs

c) 1953 belt object Dr. Anigstein and SC&A state is a Landauer flim badge was
stated more likely to be a GSI ID badge by 5 former GS! workers who furnished an
affidavit fo that effect. Landauer states unequivocally in a letter to Dan McKeel that GS!
film badge program #2084 started in late 1963 and not before. This directly refutes
SC&A’s position the photo of a belt object in 1953 was a Landauer film badge. It could
not have been according fo Landauer. NIOSH and SC&A and the WG accept the object
is a FB and use this as part of their “good” and “clear” evidence that a film badge
program existed at GS/ for 20 years prior to 1963. The petitioners claim there is no solid
evidence for this having happened other than VP/General Mgr. __...... .. 2 1962

-7-


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 13 of 18 (continued...)
5. (continued...) Dr. Ziemer's remark, McKeel comment concluded.

1966 to December 31, 1973, of the residual period when GS! ceased its corporate 1417
State Street, Granite City, IL, manufacturing operations of the Commonwealth Division
« The “office worker” category has never before been contemplated on the record

at GSI by anyone including the T80-6000 WG, the full Board, SC&A, or NIOSH.

-17-


[ Layout Man [92

[4.483 R/yr?

a) Agreement with NIOSH {ref 1 pg 9)

b} Full time at maximum survey location (ref. 3 pg. 18)

c) SC&A indicated this scenario was rare (ref. 1 pg 9)

d) (ref. 3, pg 20)

€} Full time next to boundary plus one incursion of the boundary per shift (ref 2 pg 10)

f) Full time next to baundary Ref 3 pg 22

g) (Ref 6 pg 3)

hh) Vafue varies by year (ref 5 pg 28).

i) Layout man dose applicable only to new betatron building (Ref 6 pg 3}

j) New Betatran building estimate used for all years except half the value for 1966 (ref 4 pg 5)

Others - Cobalt Era

SCRA NIOSH
Co-60 sources in radiography room 1.170 R/yr* 1.170 R/yr?
Co-60 source outside radiography room N/A‘ 1.348 R/yr 4
St. Louis Testing sources 2.771 Ré/ye * 1.336 Réyr ‘
Betatron Operator 1.35 R/yr® i. _ 0.557 R/yr”
Layout Man 9.2 R/yr' 4.483 R/yr!

a) Agreement with NIOSH (ref 1 pg 9}

b) Full time at maximum survey location (ref. 3 pg. 18)

c) SC&A indicated this scenaria was rare {ref. 1 pg 9)

a} 0.562 R/yr walking through area pius 0.786 R/yr at the boundary (ref. 3 pg 21)

e) Assumes full time next to boundary far all workers {Ref 2 pg 10)

f) Assumes half time next to boundary for nan-radiographers (Ref 3 pg 22)

g) Assuming dose for operator may be applicable to others (Ref 6 pg 3}

h}) Vaiue varies by year (ref 5 pg 28). Value intended for those routinely working in betatron
building.

i} Layout man dose applicable only to new betatron building (Ref 6 pg 3)

j) New Betatron building estimate used for all years except half the value for 1966 (ref 4 pg 5)

This is a working dacument prepared by NIOSH or its contractor for use in discussions with the ABRWH or its
Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are nat final NIOSH or
ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This
document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
: Privacy Act 5 USC §552a and has been cleared for distribution.

3


McKeel Iranscript TBD-6000 WG 2/21/13 meeting

PAGE 16 of 18

MAURO + ALLEN
Feit careful modeling could be bounded, did not exceed regulatory limits. There
was this incident w/Co-60 sources, not in operational! period. Co-60 got left out --
supervisor came & said: “something wrong with my meter. Source had been left
out.”

MAURO
NDT mishandling is common. 12 to 15 captures my concern about mishandling
Mode is reasonable upper bound for radiographers. 15 limit only applies to
badged workers...

PLZ cut him off --> Can't close that part of the loop off right now. Charge NIOSH to
bound office workers. How to distinguish in DR?

ALLEN
One bound for everyone, 3 grps (up arrow) [increases] errors

NETON
Assign higher dose

ANIG Other jobs can be confusing

ALLEN
Triangular for “placing the source”
Never compared the Betatron + Ra radiographers
Not badged -- did do that

NETON
+ category, open to 2 - NON radiographers + administrative

MAURO

Comfortable clerk -- only once or twice in plant / yr.
wi2 categories. Have come to agree -- haw NIOSH can bound

NETON
2nd categories. If not 2, why use CATI?

- 20 -


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 11 of 18

Everybady else gets outside raom. NIOSH 1.3
25% occupancy

Re: 2.087 MCNP model
PLZ What was dose rate at door?

ANIG 8.56 mR/hr SCA Oct 2011 “confirm by AEC”
30% duty cycle
10 exp./shift
We did not model outside; scenario implausible.
2.087 is the assigned dose for everyone

PLZ NIOSH

MUNN
More claimant favorable than | expect real life would be.

BEACH
! agree

POSTON
ON /| have a cold, on mute.

KATZ did you hear all - are you OK?

POSTON
“Yes, | am. Very claimant favorable, have another Class.”

PLZ (Is) SCA OK

ANIG “NO” “25% x 30% “throw in 2 factors = 7.5% rad. thru door

MAURO
"YES" - gives me comfort
"| disagree with Bob.” Applaud Neton compromise trang distrib “he should be in
Congress.” [REDACTED] Not in slides because | no longer agree with it.

(DWM}
No agreement: [REDACTED}.

MAURO & ANIGSTEIN disagree - are arguing my own number. 25% was not (verified).
No survey of Ra facility explained by NCC {

-15-


McKeel transcript T8D-6000 WG 2/21/13 meeting

PAGE 4 of 18

ANIG No one exceeded the dose. Real worker got 15 REM, limiting, high side.
Knoxville meeting some Brd members assumed everyone was going to
get 15 REM dose, changed mind.
Model not necessarily bounding.

ANIG “More credence to dose limits” than model.
4 FB 4.5 yrs. 9.2 REM lower limit, worked whenever he could. Weekends - not
clear 1 or 2 days. 45 weekdays to 90 d.
40 to 90 days. Surprised not what NIOSH did; Bob thought 12 to 15 REM would
be assigned to ail.

pt 12 McKeel appeal, points to make to work group from today's discussion:
[ 1 person FB 18 qtr Summary]
[ we dispute truthfulness of license statement of never exceeding limit
[Allen misled Bob confirmed

MCKEEL (GS/ SEC-00105 Co-petitioner prepared WG statement 2/21/13, pgs.4b-4)
{see pages 4b through 4e)
{Note: There was no immediate comment from the WG following McKeel remarks
except for a “Thank you, Dan,” from Chairman Paul Ziemer]

OBB (up arrow) to 25 Mev

ANIG Layout neutron: limiting to Betatran
Neutron dose: NIOSH 1/3 as much

SLIDE 6 --|| Betatron 26 mRem/wk - 30 Kev to workers back - never been able to
explain - dose 26 mMREM to back but FB chest only 10 mREM

9:00 CST | Exp Stk Test -- longest shot 180 hrs. 10 shots 6 months. 41% util
same as Betatron utilization 41%. Exposed source never left unattended, GSI
radiographers not involved.

2.67 Riyr.


such instructions are included in the revised Appendix BB, we will recommend that
this issue be closed. [Italics added]

Since these are the only exposures for which there is a factual basis, it is SC&A’s position that
doses derived from these exposures should be assigned to all workers, not just known or
presumed radiographers. This was the basis on which we supported NIOSH’s assertion that they
can reconstruct doses to all workers during this period.

Otherwise, NIOSH would need to track each worker's job assignment and activilies. For
instance, was he the one who was taking, measurements inside a tank hull while it was being
tadiographed with a betatron, as recounted by the late! ? Was he the draftsman
(not likely to be considered a radiographer by dose reconstructors} who was in the betatron
shooting room during a radiographic exposure? Such incidents would most likely be bounded by
the 12-15 R’y limiting exposures, bul not necessarily by exposures from other scenarios.
Likewise, how can NIOSH assign any doses to workers whose job assignments placed them in
locations that were not in the proximity of the radium sources? Since the New Betatron Building
was not erected until after the Radium Era, the scenario in which workers in No. 10 Building
were exposed to stray betatron radiation is not applicable. Since not many workers would have
reason to be in or in the proximity of the Old Betatron Building, which was about 250 ft from the
nearest other building, stray betatron radiation from the old betatron is likewise nol a basis for
assigning doses to such workers.

Discussions among Advisory Board members during the Knoxville meeting indicated that at
least some believed that the limiting doses would be assigned to all workers during the Radium
Era, not just to the smal] number of known radiographers. Furthermore, using different exposure
scenarios in dose reconstractions of different workers is inconsistent with the policy enunciated
by Allen (2012), who stated,

Betatron operator dose is intended to apply to anyone working in the betatron
building. Because little information is available for the location of most workers,
these doses will apply to a// workers at GSI. For the same reason, the layout worker
dose is intended to apply to a/? workers. ... Dose reconstructors will choose the
most favorable set of doses for the given case. [Italics added]

There is no reason why workers employed during the Radium Era should be treated differently
from those employed during the period when the New Betatron was in operation.

4.3 Exposure to SLTL Sources

It is our position that an exposure of 2.67 R/y from SLTL radiography should be assigned to all
GSI workers from January 1 to September 30, 1963, whereas NIOSH would assign this exposure
only to GSI radiographers, assigning approximately one-half this value to other workers. Since
there was no need for GSI radiographers to be involved in this operation, there is no reason they
would have a higher cxposure than other workers. GSI employees that were most likely to
remain in the vicinity of these operations would have been those involved in the production and

Response to “GS] Dose Estimation Comparison” -8- SC&A —February 12, 2013
NOTICE; This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


PERIODS OF SITE OPERATIONS,
DIVIDED ACCORDING TO LIMITING EXPOSURE SCENARIOS

January 1, 1953: Start of covered operations under EEQICPA

© Two 500-mCi ***Ra sources used for radiography, in addition to 24-MeV betatron ("Old Betatron")
May 21, 1962: GSI acquires two “Co sources (260 and 280 mCi) to replace "Ra

January 1, 1963: Assumed date St. Louis Testing Laboratories (SLTL) began radiography at GS! site,
using 10-Ci Co and 50-Ci Ir sources

October 1, 1963: Assumed date “New Betatron” began operation at Commonwealth foundry in Granite
City; Old Betatron upgraded to 25 MeV

June 30, 1966: End date of last MCW purchase order—beginning of residual period


Daniel W. McKeel GSt SEC co-petitioner bibliography 12/8/12

mms he nveen 228'42. and 32
VIS OF

(May 21, 2012)

tl, PDF 3 MB {4 pages) .

Aifachment 1; Critique of the NIOSH January 2042 White Paser “Dose Estinatas
For Betatron Operations”
t. PDF 7 MB (31 pages}

Attachment 2: Docket 440 General Stoct fies - Addendum 24 £2012
iS Si
{- PDF 8 MB (36 pages)

Attachment 3: Corrected Concrete Activation tsotopes, SEC {ssues 5 and 6 From
the David Alien! to! *Pajh Forward for GS!"

g, PDF 4 MB (6 pages)

Atlachnient 4; Menjo-E-mailfrom: _ Ue Divi 3/22/52 RE: MENPx

gode
gi. PDF 868 KB (4 pages)

Attachment 5: Dan McKeel GS1-00105 Co-Pefitioner Comments, Pad 4. to David

{lea Adgendum i 2012 Betatron Operations White Paner (via e

fail)

tt. PDF 9 hid (14 pages)

Attachment 6: Daniel McKee! GS! Co-Politioner Comments. Part 2: David Allen

January 2012 Betatron White Paper, ADDENDUM 3: New Betatron Scenario For

Worker E: ures; Inlempretation of McKeel-Landauer Program 20
(GSi} Film Badge Dala (Macch 25, 2012) by Daniel W, McKeel, Jc
2. POF 8 M3 (12 pages)

Atlachment 7; McKee! Petitioner Comments on NIOSH Allen August 2041 and

danuary 2012 Path Forward For GSI Whits Papers and Addenda to Them
gs POF 4 MB {7 pages)

tachment 8; E-mail fr fy Di Ted Katz - Request to distribute TBD-
6006 work grous information to full Board
os, POF 2 MB (3 pages)


Comment on McKee! TBD-6000 2/21/13 WG Meeling

Daniel W. McKeel, Jr., M.D.
General Steel Industries (GSI)
SEC-00105 Co-Petitioner Comments
On Transcript of Dan McKeel Notes
On the 2/21/13 Meeting of the
TBD-6000 Work Group of the ABRWH

- March &, 2013 -

(version 2.0)
FILENAME: Comment_McKtrTBO8K_2.21.13F.doc

« Page numbers of this document are keyed to corresponding page numbers of the McKeel
transcript of the 2/21/13 TBD-6000 work group. The transcript is a verbatim version of Dan
McKeel's contemporaneous hand written notes with a few added margin note redactions and
inserts marked off in italics. This document will be part of the appeal to denial of SEC-00105.

Background

On December 11, 2012, the full ABRWH voted 9 Aye and 8 Nay to support NIOSH’s
recommendation to deny the Genera! Steel Industries (GS!) SEC-00105. Currently, the Board
has formulated its recommendation in a letter to the HHS Secretary dated 1/31/13. That letter
and accompanying materials will go first to NIOSH Director John Howard, who will make a
recommendation to forward to the HHS Secretary along with an informational packet of
materials from the Board and NIOSH. No petitioner material are atlawed to be included.

According to DFO Ted Katz, the 30 white papers submitted to the TBD-6000 work group by the
SEC petitianers, and work group transcripts of the 15 WG meetings held between 2008 and
2/21/13, will not be transmitted to Dr. Howard and the HHS Secretary. The petitioner’s
maintain this is a grievous and unfair procedure. The process is adverse to GSI claimant
interests and to be addressed. The 2/21/13 TBD-6000 WG meeting was held two months and
10 days after the full Board voted on 12/11/12. The ABRWH believed all SEC matters were
settled and all bounding doses had been assigned as EEOICPA and the SEC rule stipulate
must be done for all SEC petitions. This transcript abundantly tells a different stary.

If the NIOSH Director supports, and the HHS Secretary upholds, the NIOSH and ABRWH
recommendations to deny SEC-00105, then the petitioner's will have 30 days in which to file an
Administrative Appeal. The appeal will be placed in the hands of a three member panel of
“independent” HHS employees who are selected by the HHS Secretary. The DFO informs us
that all materials may be included in the Administrative Appeal that the petitioners believe will be
helpful in overturning the denial of SEC-00105. This comment will be sent to the review panel.

The Agenda of the 2/21/13 TBD-6000 work group meeting included 4 main items:
a, Summary of NIOSH approaches for final DR estimates.
b. SC&A comments.
c. Petitioner comments.
d, Matrix issues and actions.

All except the last half hour of the 2/21 meeting that lasted from 9:00 a.m. to 3:00 p.m. ET was

devoted to GSI agenda items (a), (b) and (c). All final DR estimates were not agreed upon, and
item (d), the resolution of Appendix BB matrix open issues necessary for Rev 1, was not done.

-41-


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 7 of 18

JWR

PLZ

ANIG

ANIG

basing doses on persons who never wore badges. Layout men getting scatter
from Beta - 3 doses sources simultaneously. Ra and Betatron implausible.
Anigstein says one or the other.

Need to focus on 2 NIOSH summaries.

- Close uncertainties.

- Dave Allen, where is there a difference?
1, Time line: Co-60 5/21/62 ship date

2 0°

3.

[commenting on Dan McKeel's earlier presentation]
June 2012 Santa Fe made to Board.
Rather strong objections to irresponsible, out of line. Limited info on Betatron
Bldg. Most important we got FB - subsequently got FB records. Totally reckless.
Not valid whatsoever | Normalization done by NIOSH we don’t agree with that.
1r192 makes no difference
Co-60 | 2 mr/bounding limit
NCC brought in by GSI -- Supply FB to replace, some outside vendor, had FB -
that's clear. (McKeel comment to seff) Did not answer who they were

All 1962 radium era -- modifying Jun/Ju! 1962 post 1963 Betatron era

MUNN [REDACTED] OK from, “what do we know about production facilities.

POSTON

PLZ

(faint) -

You will agree full 1962 Layout man 1963

ALLEN

Added Oct 1-Dec, 1952 ==> Not in SEC; App-BB

-11-


Comment on McKeel TBD-6000 2/21/13 WG Meeting

Page 4 of 18
1. Dr. Anigstein is quoting a passage from the GS| AEC license application for two Co-60
sources. The license application was signed by - , VP and General Manager.

Dr. Anigstein’s statement is very important that “at Knoxville (the 12/11/12 full Board meeting
and final SEC vote) some Board members assumed everyone (emphasis added) was
going to get 15 REM dose, changed mind.” And, “Model not bounding.” John Mauro later in
this WG meeting echoed the same sentiment that Board members had been misled into
believing the 15 REM dose would be assigned to all GS! workers. Based on the activities of this
meeting of the TBD-G000 WG on 2/21/13, the 15 REM dose will certainly not be assigned to
everyone. In fact, in opposition Jim Neton of DCAS pushed for a two or three tier dose
assignment protocol, where Layout men would get the highest assigned dose, radiographers
(isotope and Betatron) would get the middle level, and a brand new category, “office workers,”
would get the lowest dose assignments in a revised Appendix BB. Chairman Ziemer concurred.

2a. “pt 12 McKeel appeal, ...” are notes to self regarding a possible administrative appeal to
HHS if the Secretary upholds the denial of SEC-00105.

2b. Oan McKeel’s prepared public comment to the WG, pages 4b-e of 18 of this paper, were
read into the record and made orally following the SC&A Anigstein projected presentation.

3. Dr. Anigstein commented that the Layout man neutron dose is limiting to Betatron
workers. What he does not state is the reverse was true in 2007-2008 when the Betatron
radiographers class of workers were assigned the highest external photon and neutron dose
compared to other non workers and layout personnel. The definition of Layout man as a
surrogate changed between 2007/8 and 2012/3 between the way SC&A and NtOSH defined
and used the term. “Layout man” was used variably as a job class or for ali other GSI non
radiographers. Again, it would have been helpful to have the exact naming conventions for non
radiographers in Appendix BB redefined at the 2/21/13 WG meeting.

4, Or. Anigstein notes the NIOSH neutron dose in his 2/12/13 paper was 1/3 as much as
the SC&A dose. The table in related slide number 5, shows actual values as 0.148 rem NIOSH
compared to 0.46 rem for SC&A. Relative biologic effectiveness (RBE) values are not slated.

5. Or. Anigstein again notes that SC&A could “never explain” NIOSH consultant Jack
Scheutz’s measurement of 15 R/min with the Betatran power OFF. The fact is, the SC&A
MCNPX and DCAS Attila computer transport codes did not confirm this effect. Therefore,
illogically, both SC&A and NIOSH made the indefensible and biased scientific decision to ignore
this established fact they could nat explain or model. The GSI SEC petitioner team has provided
several references that clearly indicate particle accelerator heads, collimators, beam spreaders
and columns become chronically activated and posed a danger to personnel working around
them even in the off position. DCAS and SC&A chose to ignore these valid references.

6. Alt “facts” SC&A cites were gleaned from one person at St. Louis Festing Laboratories.
There was no attempt at confirmation by DCAS/NIOSH. SC&A research was determinative.
Despite several urgings fram the SEC petitioner's, neither organization obtained the AEC
licenses to confirm what NDT sources St. Louis Testing Laboratories actually possessed. The
license number was stated in NRC FOIA 2010-0012 obtained by Dan McKeel. The person who
testified the longest shot tock 180 hours and there were 10 shots in 6 months was not referring
to actual shot records, merely from his memory of events that took place in 1963. The time
assumptions used to derive 41% Betatron utilization and occupancy vaiues are contested.

-6-


10

11

12

13

14

15

16

17

18

19

20

21

This transcript of the Advisory Board an Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a} and personally identifiable
information has been redacled as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for acouracy al ins ime, The reader should be
cautioned tnat this transcript is for information only and Is subject to change.

that the models that GSI --- for the GSI
betatron and layout workers that SC&A and
NIOSH had generated in 2008-2012 didn't agree
with each other at those times, and they
flip-flopped.

Whereas in 2012, the = layout
workers had a low dose assigned by SC&A, by
2012, the SC&A layout dose had gone to 9.2 and
the NIOSH layout dose was only 1.02 to 2. So
they didn't agree with each other at that
time.

And, finally, you can see in slide
5 -- I apologize. I am going to go to slide
6. I am going to go to slide 5, finish this
up quickly.

It is often said there was a
robust, relatively robust, radiation safety
program between 1963 and 1966 and during part
of the residual period at GSI. And we have
just given you evidence now that I don't think

that was true compared to other sites. I sent

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

50



10
il
12
13
14
15
16
. 7
18
19
20

21

This transcript of the Advisory Board:on Radiation and Worker Health, Board Meeling, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and persanally identifiable.
information has heen redacted as necessary. The transcript, however, has nol been reviewed and
certified by the Chair of the Advisory Board for accuracy al this lime. The reader should be
cautioned that this lranseript is or information only and is subject lo change.

film badge data by radiographers only during 43

the entire period from 1953 to 1966, in June.

In 1962, there was a one-time
survey by GSI personnel of photons in the
building 6 radiography room from a cobalt-60
source. I'm sorry. The 1962 survey was by
not by GSI personnel but by the Nuclear
Consulting Corporation.

And then the third piece of real
data they had in the operational period is
they have a series of purchase orders from
Mallinckrodt for uranium that extended from
March 1958 through June 1966. There were no
purchase orders found for 1953 through
February 1958. So there was no real data on
the uranium source term for those years of the
covered period, There was only an
extrapolation, back extrapolation, from 1958
forward as to what might have been present.

TI need to comment that there was a

comment made by Dave Allen in Appendix 8B and

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

AAD BUNRE Der ARIF ANE ALA



MckKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 8 of 18

[BLANK - There was no page 8
of McKeel 2/21/13 meeting notes]

-12-


10

11

12

13

1s

16

17

18

19

20

21

This transcript of the Advisory Board on Radialion and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Aci (§ U.S.C, § §52a) and personally Identifiable
information has been redacted as necessary. The iranscripl, however, has not been reviewed and
Certified by the Chair of the Advisory Board for accuracy at Ihis time. The reader should be
cautioned (hat this vanscript is for information only and is subject to charge.

had done work within buildings 5 and 6 and 7
through 10, but they required an overhead
crane with a magnet to clean the dust from the
GSI buiiding. So there was lots of it there
and that all of these multiple users in
intermittent operations during the residual
period meant that it would be very difficult
to model and bound residual contamination.

Slide 4 and slide 5. I go over my
reasons why I believe sufficient information
has been presented to vote for the SEC at this
point and that I hope very much the Board
might consider that done.

And I think I have been over the
work that was the real data that was there
Guring the operational and the limited
periods. I've been over the fact that most of
the workforce, which should have been badged
because of their exposure to activated steel
had not been badged.

The slide you see after four shows

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

43



10

ll

12

13

14

15

16

17

18

19

20

21

This transcript of the Advisory Board on Radiation and Worker Healih, Board Meeling, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 5523} and personally identifiable
information has been redacted as necessary. The tansaipt, however, has no! been reviewed and
certified by the Chalr of the Advisory Board for accuracy at this time, The reader should be
caulioned that this transcripl is tor information only and is subject lo change.

Labor because it would really help to have 339
some place to go. Please, i there was any
way we could get that to happen, it would be
wonderful.

And, lastly, I would like to add
great appreciation to Terrie Barrie and
(identifying information redacted] for all the
work that they put in, you know, another two
people that they don't get any financiai gain
from this. And they put in hours and hours of
work and dedication and love into this. And I
just want to thank them for all their work.

So thank you. And thank you to
you.

CHAIRMAN MELIUS: Thanks. Okay.

Anybody else in the room wish to
make public comments?

(No response. }

CHAIRMAN MELIUS: Okay. If not,
thank you for attending. And we will be

following up. And we will reconvene tomorrow

NEAL R. GROSS
TRANSCRIBERS

COURT



GSI Dose Estimation Comparison
Prepared by Dave Allen, DCAS
January 2013

The following comparisons of NIOSH and SC&A dose estimates for workers at GSI was assembled from a
review of various white papers and matrix notes, starting with the latest and working backwards in time.
Based on this review, a summary of the latest modeled doses proposed by NIOSH and SC&A for various
exposure scenarios is provided. It does not include some additional exposure scenarios that were
evaluated and not used {i.e, they were determined not to represent the limiting source of exposure).
The summary is categorized by time frame (Radium Era and Cobalt Era) as well as by worker category
(Radiographer and Other) so that four exposure categories were established.

Photon Dose
Radiographers ~ Radium Era

SC&A NIOSH
Ra-226 sources in radiography room 9.69 R/yr* n/a®
Ra-226 source outside radiography room 9,39 Réyr* 3.573 R/yr ©
St. Louis Testing sources _| 2.771 R/yr® 2.671 R/yr!
Betatron Operator 1.35 R/yr® 0.620 R/yr"
Layout Man N/A! 4.483 R/yr!

a) 9.39 R/yr from the “fishing pole technique” estimate plus 0.296 R/yr during the shot (Ref. 1,
page 7. Fishing pole technique estimate ref. 2 pg 6 & 7}

b} NIOSH did not develop an estimate of Ra sources inside the radiography room

c) 9.39 R/yr from the “fishing pole technique” only. SC&A did not develop a dose estimate
specifically for the use of Ra-226 sources outside the radiography room (ref. 2 pg 6 & 7) Using
other methods, SC&A bound the dose between 9 and 20 R/yr. Matrix recommends using 12
R/yr based an AEC limit.

d) 5.411 R/ye for the fishing pole technique divided between 2 radiographers plus 0.868 R/yr at the
boundary {ref 3 pg 15 & 16)

e) Full time next to boundary plus one incursion of the boundary per shift (ref 2 pg 10)

f} Full time next to boundary Ref 3 pg 22

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH ar its
Working Groups or Subcornmittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or
ABRWH (or their technical support and review contractors) positions untess specifically marked as such. This
document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the
Privacy Act S USC §552a and has been cleared for distribution.

1



GSI an SEC today.
Thank you. -- Dan McKeel 12/11/12

NOTE: Chairman Melius responded to Dan McKeel the “public
process” would have to take place before claimants could be
notified of the final vote tally on the GSI SEC. The
claimants may not, or admittedly will not be able to learn
about the final SEC-00105 vote until the next Advisory
Board meeting “next year,” no date mentioned. I was the
only person in the ABRWH venue hotel room or on the phone

to make a Public Comment this day.


Daniel W. McKeel GS! SEC co-petitioner bibliography 12/8/12

« Commenis irom Danicl W, MeKeol, Jo MO. on the Gears: Steet Indusiries SEC

Petition {MOSH SEC-G0106)
(December 12, 2009)

3h. PDF 7 MB (10 pages}

Note: The documents mentioned in the above comment can be viewed on the U.S.

Nuclear Requlatory Commission Web site,
Exiernat Link: htip-adamswebsearch?2.nrc.gowidmws/ViewDocBy
Ascession.asp7AccessionNumber=MLO235 10887

» Comments on the Site Profile for Atomic Weapons Employers that Worked Uranium and

Thorium Metals document, Appendix BB -- General Stee! Industries

« Critique to NIOSH of Anpendix BS to Batlello TBD.
Industries SEC AWE Site
$x PDF 1.4 MiB (23 pages)

NIOSH writ

6000 for the General Steel Industries SEC AWE Site"
j- PDF 4 M3 (41 pages}

O for the General Steel

response to “Critique lo NIOSH of Appgndix BB to Baitelle TBD-

Comment and Reply Re: Anpendix BB to Battelle TBD-6000 for the General Stee}
Industries Site, Submitied to OCAS andits Director, Larry Eifott, as a public

comment to the July 7 2007, ABRWH meeting and as a public dockel

comment to the An; © pasting on the site.
3. POF 4. TPB (23 pages)

NIOSH writen response to "Cor

galy Re: Appsndix tele

and Re
TBO-6000 for the General Steel industries Site. Submitted

to OCAS and iis
Director. Larry Elliott, as a public commento the July 17-19, 2007, ABRWH

meeting ai

Li et comment to the Appendix RB for pasting on the

OCAS Web site."
s PDF 1.2 MG (13 gages)

The first “Critique to NIOSH of Appendix BB to Battelle TBD-6000 for the
General Steel Industries SEC AWE Site” document was contributed by GS{ SEC-
00105 co-petitioner Daniel W. McKeel, Jr. lt incorporates remarks made as an
ABRWH general meeting PUBLIC COMMENT. The written response by NIOSH was
the first and last written response that NIOSH ever made to any of the Dan McKeel
white papers that followed and are listed above in this bibliographic compilation.
The other 3 documents were from*. -

«GSI site expert and from NIOSH.

Summary of McKeel Submissions (total papers = 30 + 8 attached papers}

Bibliography Pg. No. of Papers Total pages/ Page | Papers by Years
1 5 2012 all
2 7 2012 all
3 1+ 8 attachments 2012 all
4 11 2010/11, 2012{5)
$ 2 2007, 2009



McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 13 of 18

MAURO

PLZ

Straggling 5 yrs non radiographers “off normal” conditions. Ail a collective picture.
Very difficult to assign.. can assign 12 and 15 plausible upper bound--related to
SEC decision. Now we don't know how to ID achieve this level of granularity...
cannot operate. Jim (Neton) strategy can have a hard time placing doses on
individuals. Assign distribution to ALL claimants -- at time of particular claimant,
you can’t do this.

Assume we could ID categories, But if not, Can we separate out who is a
tadiographer? -- Had at SRS. Many of these we don’t. Know “small” group who
were

ALLEN

\f we don't know, do not know all radiographers to high doses. Do know if he was

BREAK 1120 AM CST
Reconvene 1:25 PM --
{Airport came on - request expedited WG 2...

KATZ & PLZ

PLZ

Poston - (NO}

Can we distinguish radiographers vs non radiographers

SEC differs from DR - assigned highest dose Betatron or layout depending on
the years. Appropriate to have a method for “two dose levels DR,” nuclear vs
office workers. Hear from SC&A on this -- possible to establsh worked where
sources were,

-17-


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This transcript of the Advisory Board on Radialion and ‘Worker Health. Board Meeting. has been
reviewed for concems under the Privacy Act (5 U.S.C. § 6524) and personally Kenbflabie
information has been redacted as necessary. The transcript, however, has nol been reviewed and
certified dy the Chair of the Advisory Board for acouracy at this lime. The reader should be
cautioned that tris uanscript {s for information only and is subject to change.

you the radiation safety program at the 51
Watertown Arsenal, which also was in
compliance with AEC regulations in about the
same time period as GSI's operational period.
And they were far more extensive than anything
that was done at GSI.

I have pointed out that NIOSH has
no valid uranium intake model for the whole
operation and residual periods. NIOSH didn't
want to use SC&A's alternate model. In my
opinion, the new surrogate data that NIOSH has
proposed really would probably not pass the
surrogate data criteria for the same reasons.
There were two slug facilities and one billet
facility. And there were no dingot facilities
Similar to GSI and the use of Mallinckrodt
uranium.

And the other thing is none of the
relevant records that would contribute to the
accurate bounding have been recovered from

Mallinckrodt on the work done at GSI.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS.
AQZTRVONE IG ANN AVE AW



McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 17b of 18 GSI last discussion point

PLZ Did not go through residual period -- agree it could be done. inhalation Ur agreed
on source term but not model.

ann ffnnn

PLZ Have 1/2 hr left, want to move into [Baker Brothers]
No recommendation now for Board

MAURO
Whole lot of talking points “#7 issue has SEC implicatians" - other SP issues do
not impact. (continued below) ...

PLZ Board took action on SEC
residual period - can’t assign bounding dose for beginning then this is the rack.
We ail got your comments 1 day ago. Neton has looked at.

MAURO
Picked airborne dust loading 580 dpmicm3 gross alpha
Fly in ointment - many fires on surface
1943-44: Amt Ur on surfaces may be shifted because of fires. Mechanics of
assuming. Was there cleanup during op. period after fires.
-- Did look at SRDB. Tom Toms comment on fires.
(margin note: p 36 of ER)
Closing contract” collect turnings, sweepings, drumming
- It was these that caught fire and settled out.
- 1 Ig fire 100 Ibs of uranium. NIOSH please clarify

NETON
How many fires “several” not “many”...

BEACH
What went on 1945--> 1980s; ER nothing in it -- sold + co. dissolved, no info.
SC&A calc. for air is wrong! - not asked to do anything

(McKee! margin note to seif: What is the start value airborne Uran GSI 6/30/66)

-22-


Daniel W. McKeel, Jr., M.0.
GSI SEC-00105 co-petitioner

Documentation of McKeel Presentations
at the September and December 2012
ABRWH Meetings 86 & 87 and the
November 28, 2012, Meeting of
the TBD-6000 Work Group
--December 14, 2012--

The purpose of this assemblage of 7 Dan McKee! documents is to serve as reference
for those Board members who missed the GS| SEC-00105 83,13 petition vote by the full
Board on September 19, 2012, in Knoxville, TN. These documents will also be
submitted today to NIOSH Dockel 140 (General Steel Industries AWE site) for posting
on the OCAS website: www.cde.govinioshfocas.

moe eee - ay

“10 GSisec AZSENTEES 12.31,22

J g ,

ali pe ee en
@ 1) oy FE _ExXHIgrTs 140 12.14.12
vy (6 OL FALK 12.21.12
\ AE) MCKEEL_ABRWH_12.11,22f3b.0df
[ yf} 92 suDE SCA NIOSH

I>

[E; SUDE_Sep2012_SCAVNIOSH.grab
x [2 02_RESIGN LTR

Th) Dit4_resignTBDGKwg_11.28.12.pdf
wv FEI 04_0M PUBL COM 12.11.12

E\ DM_PublComment_12.11.12.pdf
y_ [J 05_0M PAPERS BIBLIO

T) McKeel_GStPape-s_2007-2012.p¢f
+ OY fl OS TALK 9.19.12
. rh) ABRWHsep2012_mekeelO9k2ic. pdf
vy {LF 07M 9.19.120r PP 39-53
| TE) ABRWH_86th_tr091912.pdf

®} ABRWH_86th_tt091912pp39-53.odf

i} DWM_9.19.12_abrwh_p39-53.1xt

The POF files 01-07 comprise the documents in the current 9.14.12 submission in the
altached file named: McKeel_GS{_9.14.12.pdf.



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This transcripl of the Advisory Board on Radiation and Worker Health, Board Meeting. tas been
reviewed for concerns under the Privacy Act (5 U.S.C. § 5$2a) and personally identifiable
infarmation has been redacted as necessary. The transcrip!, however, has not been reviewed and
cerlified by the Chair of lhe Advisory Board for accuracy at this time. The reader should be
caulioned that this anseript is for information only and is subject to change.

here for the residual period, I think, is that
the residual period applies to everybody in
the workforce. And most of the people in the
workforce worked in other buildings than the
betatron buildings. And workers there were
also exposed to uranium along the whole long
uranium pathway whereby it was transported
from the weighing scales.

We know = that everything was
weighed that went into and out of the plant.
Inspectors had to look under the tarps to make
sure what was on those transport vehicles. We
have operations at the loading dock. We have
a transfer to rail cars. We have transport
along the rail tracks through buildings 5,
through 10. And then the railroad tracks ran
into the old and new betatron buildings so
that the actual areas that were surveyed for
uranium were a tiny fraction of the whole area
that formed the volume and the space along the

vranium transport pathway. And, as David

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS
1273 RHONF IS} ANN AVE NW

47



Comment on McKee! TBD-6000 2/21/13 WG Meeting

Page 7 of 18

1. Mr. noted that doses were being assigned for nan monitored workers. He
stated that Layout men outside the Old Betatron building could actually receive three doses
simultaneously from the two Betatrons and an outside Co-60 source such as the one St. Louis
Testing used. Dr. Anigstein noted this was implausible, could be exposed to one or the other
source buf not to both. The two Betatron buildings were 300 feet apart and an 80 Ci Co-60 was
used outside of the New Betatron Bidg by StL Testing. Dr. Anigstein noted elsewhere the
Mckee! photographed sign on the Old Betatron Bldg that stated "Do Not Approach This Building
Within 100 Feet." The petitioners thus conclude that multiple source simultaneous exposures
were possible. These doses weren't measured because outside workers were never badged.

2. Dr. Ziemer tried to refocus the discussion on the two most recent DCAS and SC&A white
papers and the identification of differences and the need “to close uncertainties.” Unfortunately,
he did not list those differences and uncertainties.

3. Dave Allen stated the time line was the main unresolved issue. This was an
aversimplification. No one had yet finalized specific doses to be assigned that Dan McKeel had
been able to detect.

4. Or. Anigstein then disputed several of Dan MeKeel’s key points on pages: 4b-e and he
stated he had rather strong objections te use of the word “irresponsible” because Appendix BB
was before SC&A and NIOSH got film badge records. Dr. Anigstein referred to McKeel’s earlier
remarks as “totally reckless.” Interestingly, McKeel’s prior remarks were primarily directed at
NIOSH's methodology since they and the Board both recommended denying SEC-00105, and
because only NIOSH can revise Appendix BB.

5. Dr. Anigstein states SC&A does “not agree with NIOSH (film badge) dose normalization
methodology.” He didn't explain the basis for this statement on the record as Dan McKeel had
asked to be done.

6. Dr. Anigstein stated that bounding St. Louis Testing Ir-192 doses, for unexplained
reasons, “makes no difference.”

7 Dr. Anigstein believes Co-60 doses outside Bldg. 6 were somehow limited to 2 mR at the -
boundary that was roped off. There was testimony this boundary was often breached, Mr. Dell's
employment spanned both the Radium and Co-60 eras in Bldg. 6 and he testified that shots

were often left unattended.

8. Dr. Anigstein thought it was natural that NCC as a consultant to GSI would institute their
own film badge program for 2 years (1962-63). Yet only a single NCC film badge report is
known to exist. ts a single badge sufficient to verify an entire NCC badge pragram? | think not.
9. NIOSH and SC&A/WG agreed the “radium era" would extend from 193 through 1962.

10. | could not understand or record the remarks by Members Munn, Poston and Ziemer.

11. Dave Allen indicated that the revised Oct. 1 through 12/31/1952 GSI covered period
would be recognized in Appendix BB Rev 1, but would not be added to SEC-00105 where the
covered period is established as 1/1/1953 through June 30, 1966.

-10-


testing of the castings—supervisors, metallurgists, layoul men, etc —and perhaps chippers,
grinders, and welders who repaired any defects uncovered by the radiographs. Since the
identities and cvcn the categories of these workers are unknown, all workers should be assigned
this exposure.

§ Summary and Conclusions

NIOSH and SC&A agree on who are the maximally exposed individuals during each era, There
is, however, substantial disagreement on the doses to be assigned to GSI workers. SC&A
believes that all workers should be assigned the same doses in a given cra. NIOSH is
inconsistent in this respect, assigning lower doses to nonradiographers prior to New Betatron
operations, but the maximum doses—either those modeled for the layout man or the betatron
operator, whichever is the most claimant-favorable—during New Betatron operations.

Response 10 “GSI Dose Estimation Comparison” 9. SC&A —Pebruary 12, 2013

NOTICE: This report has heen reviewed for Privacy Act information and has been cleared for distribution.
However, this report is pre-decisional and has not becn reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82


McKeel transcript TBD-6000 WG 2/21/13 meeting

PAGE 14 of 18
NETON
Co-worker models
TBD-6000 / supervisors & production “precedent”
Question is: work on all sources at plant. Outside production area.
MAURO
In and around Betatron facilities. Around Betatron but office workers. Lg number
may have worked in and around.

ANIG 100 odd during Radium era wi1 ID'd as radiographer, How do you parse out -
John and | agree, One scenario -- What about those working

PLZ Not using radiographer + layout 1st category. Other was office.
ANIG Different from NIOSH...

PLZ May have morphed -- everybody else

ANIG Layout only applies in New Betatron Bldg. Betatron ops

KATZ Category not known to be radiographers, put in category.

ANIG {reading from) ist) - Switchman, grinder, clerk, faborer, miliwright,
core op, industr. eng./accountant/3rd job, furnace worker. Random order sample.

ANIG 1 worker alive and well, not sick, Can't know what they did
PLZ Ask NIOSH what is possible?
ANIG Can NIOSH parse the jobs?
ALLEN
NIOSH Radium era 10 yrs / major
Guidetine --> In genl radio assign to radiographic. Include inspectors, Qual.

Control. Cannot ...? Dose does not include incidents. If DR can establish,
assume if survivor doesn't know,

-18-


them and no one has been compensated. Those AWE sites and the Weldon Spring DOE site are
judged by SC&A and DCAS to be “stringently justified” as being comparable to GSI. This is
scientifically ludicrous and offensive! It is definitely scientifically indefensible in my opinion.

Also, the authors of the November 25, 2012, SC&A review of Allen | 1/6/12, continue to
insist that uranium ingots and dingots sent from MCW to GS} had only a few uranium oxide
flakes on their pure uranium surfaces that were easily rubbed off. The petitioners and site experts
have proven beyond a reasonable doubt, using technical publications and photographs, that
MCW-Destrehan Street and Weldon Spring site uranium dingots of the type sent to GSI for NDT
radiography were rough surfaced and taller than they were wide before cropping. SC&A ignores
the proven fact that the adherent magnesium-fluoride slag or crust of MCW uranium ingots and
dingots sent to GSI 1953-1966 contained radioactive daughter products of uranium and Betatron
activation products. The DCAS term “cold uranium” is inappropriate. SC&A and DCAS
continue to ignore the well substantiated fact that GSI NDT Betatron radiography defined the
interface between pure MCW uranium and the tightly adherent crust. Detecting structural flaws
competed with this prime MCW/AEC directive. Objective science has been abandoned to the
detriment I claimants. Please refer to NIOSH Docket 140 for more documentation of
Statements in this letter.

Thank you for this added opportunity to set the record straight.

Reference: OCAS-IG-003, Rev 0, 11/05/2007, 11 pages, title: “Radiation Exposures Covered for
Dose Reconstructions under Part B of the Energy Employees Occupational JiIness
Compensation Program Act” (Approval: James W Neton, Concurrence: LJ Elliott)

Sincerely.

Daniel W. MeKeel, Jr., M.D. 11/27/12


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Section 6 ia} Page 26

Figure 1. Drawing of New Betatron Building Showing Desk in Control Room (NRC 2009b)

Response to “GSI Dose Estimation Comparison” 6 SC&A. February 12, 2013

No’
Hower

is report has been reviewed for Privacy Act information and has beer cteared for di on
1¢ Advanory Board on Radsation and Worker
1 requirements of 42 CFR 62.



DETAILED DISCUSSION OF BOUNDING SCENARIOS

Radiographer Using “Ra: 1953-May 21, 1962

“During this period [1953-1962] the exposure limits published by the A.E.C. at the applicable time were
followed. They were never exceeded and averaged under 25%.” (GSI AEC license application)

AEC Form 4: Occupational External Exposure History of GSI worker

7)

is}

18 quarters (July 1, 1957-December 31, 1961)
9.1 rem total, 2.02 rem/y

Worker performed radiography on weekends
» 1-2 shifts, 80%—-90% of the time
* 40-90 shifts/y: 22-50 mrem/shift

Extrapolate dose to full-time radiographer, 65 h/wk: 9-20 rem/y

Worker testified he wore film badge while performing radiography

MCNPX and exposure rate analysis, based on worker's account of radiographic practices: ~10 Rly
(~11 rem/y)


Layout Man—1963-1966

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New Betatron Building (A.E.C. license application)


McKeef transcript TBD-6000 WG 2/21/13 meeting

Page 4b of 18

(McKeei SEC-00105 co-petitioner comment)
(Filename: OWM_TBD6Kwg_2.21.13b.txt])

1. The Board needed to have both the Allen 2/4/13 and SC&A Anigstein-Mauro GSI
dose estimation papers BEFORE it voted 12/11/12 9 to 8 to deny GSI SEC-105. These
two papers show that DCAS and SC&A are still far apart, dose estimates differing 2 to
10-fold. This is not acceptable agreement for bounding dose data.

2a. The SEC-00105 deliberations are now over except for the Administrative Appeal.
The main TBD-6000 WG task for GSI is now to resolve all TBD-6000 Appendix BB
remaining issues so that DCAS can revise badly outdated Rev 0. That work needs to he
completed at today's meeting.

2b. NIOSH needs to acknowledge the GSI operational period HAS BEEN EXTENDED
by DOE and DOL to include the October 1 through December 31, 1952 period. This
time period needs to be covered by Appendix BB Rev 1.

3. Neither the Allen January 2013 GSI dose comparison paper nor the SC&A reply
memo dated 2/12/13 directly address assigned doses in Appendix BB Rev 0 or in the
SC&A 2008 calculations and compare them with 2012-2013 doses. This is
irresponsible. The two latest 2013 papers do not reflect the fact that earlier estimates
gave radiographers a 10-fold *higher dose* than other workers, whereas the reverse
ratio was the result of calculations 4 years later. The full Board on 12/11/12 was not told
how this magical reversal of Betatron/non-radiographer doses took place between
Appendix BB and 2008 computer models and 2012-2013 dose calculations and models.

4. Mr. Allen's 12/11/12 assertion that GS{ non-radiographers routinely gat credit for the
highest dose scenario was inaccurate. Under Appendix BB Rev 0, under which all but 4
early GS| DRs have been carried out, radiographers got the highest dose, whereas now
both NIOSH and SC&A have flip-flopped and conclude the reverse is true. That is,
Layout men are assigned a much higher dose than Betatron/isotope radiographers,
using the same computer models and an occuit film badge "normalization" process
neither Dave Allen nor SC&A has described adequately enough to be properly
evaluated by anyone. What, precisely, was the process of "film badge normalization?”
We know that non radiographers often get assigned the Appendix BB lower dose level,
contradicting what Mr. Allen told the Board.

5. Dave Allen points out in his latest paper that NIOSH did not estimate Ra-226 doses
in the GS! Bldg 6 radiography room, relying instead on SC&A's dose estimate. The
problem with that is who will perform the validity check on SC&A's methods —~ would
DCAS be evaluating SC&A science?


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This transcript of the Advisory Board an Radiation and Worker Health, Board Meeling, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 52a) and personally identifiable
information has been redacted as necessary. The transcripl, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy al this time. The reader should be
cautioned thal this transeripl is for information only and is subject to change.

radiologic survey of the new betatron 4.
building. That was done by the GSI radiation
safety people and they used an 80-curie
cobalt-60 source, where the main work done in
that building, of course, was with a 24 or -5
MeV betatron. So the source they used to
model the building was not the source that was
primarily used in that building.

Then they also had additional
Landaver film badge data on 19 radiographers
during that period from July 1, 1966 to 1973
late or early '74, when GSI ceased operations.
And, of course, that was a much smaller
percent of the workforce.

And, then finaily, the data that
they had that Dr. Ziemer mentioned was when
Bechtel came in and did a radiologic survey of
the old and new betatron buildings. And ORNL
surveilled that. And this was done for DOE
under the FUSRAP program. They only surveyed

the new and old betatron buildings, did not

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS

FARA RUARE [el AAUN ACE RI IRE



Comment on McKeel TBD-6000 2/21/13 WG Meeting

11.

(cont'd...) and with Or. Anigstein's SC&A colleague and co-author of the 2/12/13 white
paper on GSI dose estimates, John Mauro, who is disagreeing on the record with Bob
Anigstein.

Page 12 of 18

1.

40.

11.

Member Munn notes (something unclear) is a “reasonable assertion.” She may be siding
with the Mauro view that Bob Anigstein is incorrect.

adds the main Bldg. 6 finishing room was heavily occupied. He explains

“in response to a previous question that a dose rate 1 meter from the wall was realistic,

and that in fact “Yes, peopfe were working near the wail.” Note added by Dan
McKeel: Past transcripts worker affidavits show that around 300 people worked in close
proximity to the 6 Bldg. radiography room fram 1953 through 1962 (the GSI radium era).

Dr. Anigstein notes the Bldg. 6 radiography room walls were 16-24 inches thick and filled
compared to the 2 1/8th inch steel door.

* McKeel note: What was not mentioned was former GS! worker testimony that in the
1950s, before a source overexposure incident occurred, there was no door at ail and
walls were one biock thick. The door was added as a result of the reportable incident.

Drs. Mauro and Anigstein then have a colloquy wherein the current discussion does not
involve the past discussion of a triangular dose distribution. Mauro notes “talking about
the wrong thing..., didn't hear this,,,, give me a line. | apalogize.”

Dr. Ziemer then adds a cryptic comment that “fish pote is controlling for
radiographers and Betatron operators.” (That is, higher than, reverse of App-BB)

+ McKeel comment: Or. Ziemer perpetuates the misinformation that Dave Allen and
DCAS/NIOSH provided to the full Board before they voted to deny GSI SEC-00105 on
42/11/12. The 2/21/13 WG discussion pertains only to Appendix BB that comes into play
for complete and partial individual dose reconstructions only. As in Rev 0 of Appendix
BB (June 2007 version), radiographers include both isotope and Betatron operators, and
they receive a different dose level (~ REM/yr) compared to Layout men and all other
non radiographer personnel (0.72 REM/yr). The difference is that 2012/13 doses being
discussed here for inclusion in a future Rev 1 of Appendix BB, Betatron radiographers
will get assigned 10-fold lower doses by NIOSH compared to other workers.

Dr. Anigstein then notes SC&A October 2011 and NIOSH Jan 2012 white papers on
Betatrons and portable GSI radiation sources “2,08 is not supposed to be bounding.”

McKee! notes “Inconsistent: John Mauro now agrees with Bob Anigstein (in
opposition to the WG and NIOSH Allen and Neton).

Dr. Ziemer notes “lt understand the triangular distribution apply(ies) to everyone.”

Allen responds, in part: Credible for layout (McKeel note: missed the fast part of this
commenti.) -- again the key issue of assigning a final dose is not concluded as it could
and should have been after this lengthy a discussion between ail parties.

Note the WG chair and members and NIOSH had only addressed one McKeel comment
about the change in the start date of the GS! AEC operatianal period to 10/1/52.

-15-


$C&a, inc.)

TO: Advisory Board on Radiation and Worker Health Work Group on TBD-6000
FROM: Robert Anigstein and John Mauro, SC&A

SUBJECT: Response to NIOSH Report: “GSI Dose Estimation Comparison”

DATE: February 12, 2013

SC&A Response to NIOSH Report: “GSI Dose Estimation Comparison”

On February 4, 2013, Dave Allen (2013) transmitted a report comparing NIOSH and SC&A dose
estimates for General Steel Industries (GSI), The same day, Paul Ziemer (2013), Chairman of
the ABRWH Work Group on TBD-6000, sent an e-mai) message asking if SC&A will be able to
provide responses to this and another document in time for the February 21 meeting. This memo
is our response to Allen’s report. The following discussion is keyed to Allen (2013) and follows
the same sequence as Allen. Allen’s intent was to present a historical account of the
development of the dose estimates—we will bring the SC&A dose estimates up to date while
reviewing Alien’s presentation, thus deviating somewhat from Allen’s framework.

1 Exposures During “Radium Era”: 1953-May 21, 1962

Ina table on p, 1, Allen (2013) lists estimated exposures of radiographers during the “Radium
Era” (i.e., 1953--May 21, 1962 [date when GSI procured Co radiography sources to replace
*6Ra)). The table compares the NIOSH results to the SC&A **Ra exposure estimate that we
derived from first principles. However, this was but one of three exposure estimates that we
developed for radiographers during the Radium Era, which are listed below:

1. Time and motion study of a radiographer handling the “Ra sources and staying in the
radiographer’s office inside the concrete block radiographic facility in the No. 6
Building during radiographic exposures, which yielded an exposure rate of 9.69/y
(listed in Allen's table);

2. Extrapolation of radiation exposure records for veo performed
radiography part-time on weekends—to a full-tme radiographer. ve received
a dose of 9.1 rem during [8 calendar quarters. An estimated range of work shifts that
he spent performing radiography over the course of a year yiclded a range of 9.1-
20,5 rem/y to a full-time radiographer (a rounded range is cited in a footnote to Allen's
table).

3, The statement on the AEC license application that the applicable AEC dose limits for
each time period were never execeded (NRC 2009a, p. 26), which implies that the dose
rates could have been as high as 15 rem/y in 1953-1954, and 12 rem/y in 1955-1962
(only the latter value is cited in Allen's footnote).

Allen (2013) next compared SC&A and NIOSH estimates of exposures ta sources used by St.
Louis Testing Laboratories (SLTL) on the GSI site. The SC&A value was presented by
Anigstein (201 1a), who assigned an annual exposure of 2.669 R to a GS] worker remaining at

Response to “GS] Dasc Estimation ComparisonTM -I- SC&A February 12, 2013

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distnibution.
However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
Health for factual accuracy or applicability within the requirements of 42 CFR 82.


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This transcaipt of the Advisory Board on Radiation and Worker Health, Board Meeling, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § §52a) and personelly identifiable
information has been redacted as necessary. The lransevipt, however, has not been reviewed and
certified by Ihe Chair of the Advisory Board far accuracy al this time. The reader should be
cautioned that this transcrip! fs for information only and is subject to change

So, in summary, then, I think that 52

NIOSH has made a lot of errors of fact in
Appendix BB that still need to be addressed. I
believe that the NIOSH betatron, the steel
casting activation, and the uranium intake
models are not valid for reasons I have put
forward and, therefore, not bounding. There
has been extreme underestimation of the exotic
mixed activation fission radionuclides that
were discussed prominently at Rocky Flats
yesterday that were caused by a bombardment of
uranium and the steel castings for the
betatrons. At those high MeV, both things
occur.

And NIOSH used only ixron-59 as an
activation product, where we sent you
literature documenting that there are at least
30 different radionuclides, some with
half-lives that were days and weeks and much
longer than they assigned for Fe-59.

And, finally, with respect to

NEAL R. GROSS

COURT TRANSCRIBERS



Comment on McKeel TED-6000 2/21/13 WG Meeting

Page 14 of 18

1,

A discussion ensues between Dr. Ziemer, SC&A and NIOSH about who should be
included in the new office worker category.

+ McKeel comment: There is no consensus reached, in fact, the issue becomes more
confused as the discussion progresses.

Dr. Neton's comment about DOE co-worker models didn't apply ta AWE GSI, and was
thus off-topic. McKeel did not understand why Neton’s comment about TBD-6000.
supervisors and production “precedent” was germane. He is correct the difficult issue will
be to define who “works on aif sources at the plant outside of the production area.”

+ McKeel comment: That wilt be impossible. Deceased Betatron operator John Terry
Dutko certified that most radiographers formerly held non radiographer jobs at GS!
before they become isotope or Betatron operators. A significant number of radiographers
later took non radiographer jobs at GS}. The CAT! interviews cannot accurately depict
these job transitions. There were well over a hundred job categories at GSI as was the
case at all major steel companies.

This WG has extensively discussed previously that GSI employees such as inspectors,
clerks, and many non radiographers such as electricians worked inside and around the
Betatron facilities. No one at NIOSH has defined a list of who these people were,

Dr. Anigstein mentions again an ad hoc Bob Barton study of 100 plus radium era GSt
workers only one of whom was a radiagrapher

+ McKeel comment: This actually attests to the fact that NIOSH and DOL, by their own
admission, cannot accurately distinguish with sufficient accuracy who held what jabs for
what years at particular buildings at GSI. The data is simply not available.

Dr. Anigstein comments the Ziemer job categories differ from those NIOSH proposes.

Dr. Anigstein's assertion that Layout only applies to the New Betatron building has been
refuted by several former GS] workers ( . thers). That is,
the Old Betatron building was serviced by rail and workers frequently laid out shots
outside the building while waiting for the previous Betatron job to be completed.

Both Dr, Ziemer and SC&A expressed doubts that NIOSH could accurately identify job
categories and asked Dave Allen to clarify this point. Dave Ailen’s reply was difficult for
Dan McKeel to understand except that he was responding to the 10 year radium era. His
statement McKeel captured did not really make sense, specifically: "Guideline: tn
general radiographers assigned to radiographic. include inspectors, Quality
Control. Cannot (missed portion)... Dose does not include incidents. If DR can
establish, assume survivor doesn’t know.”

+ McKeel comments: The answer is incomplete and vague. Of course, radiographers
would be assigned to “radiographic,” a newly coined odd term | have never heard used
before at GSI or elsewhere. Perhaps the official 2/2113 TBD-6000 WG transcript. that
has not been released as of 3/8/13, will clarify this key point. Mr- second DR did
include a new assignment of an extra 10 REM based on an incident where his pocket
“pencit” dosimeter “pinned” at 10 REM and he reported this incident to his supervisor, So
Mr. Allen is mistaken in saying that “dose does not include incidents.” |n at least
one instance it did based on my own experience. | reviewed Mr. .» two DRs.

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