McKeel Critique to Allen 7/10/15

lowering the dose by 50% assuming that betatron operators always have their
hands in the air before them. How could he possibly know this to be true?

[2] Page 4 of 9. The most concerning aspect of this SC&A Finding is that basal
cell skin cancers are common human cancers and are frequently compensated when
they occur in part B EEOICPA claimants. The fourth paragraph that extends to page
5 indicates “The applicable Tables in Appendix BB will be changed from 1.3 rem
photon dose to 10.225 rad...” He should state the version of Appendix BB, which I
assume means the values in Rev 1 (6/6/14) will be changed in Rev. 2 of Appendix
BB, a release date for which has not yet been determined. At the present time 196
GSI denied claims are being reconsidered under PER-057 and 16 more under PER-
058, with 100 part B GSI denied claims targeted for “rework” dose reconstructions
at NIOSH due to the PER POC being 250%. Because of the sharp increase in air
kerma from Rev 1 (from 26 mrem to 204.5 mrad per week), it can be anticipated
that a new PER will have to be issued based on Appendix BB Rev 2. Some claimants
will be forced to wait more months to years, All of these deliberations should have
been decided in 2012 prior to the Board’s final vote on SEC-015 12/11/12. Clearly,
the changes should have been incorporated into Rev 1 of Appendix BB.

[3] Page 4 of 9. Mr. Allen again refers to “betatron” singular, which was the
case only during 1952 through 1963 at GSI before the Eddystone, PA castings
division of GSI closed and moved its operations to Granite City, IL. After that, there
were two 24-25 Mev A-C Betatron x-ray units at GSI. The operations performed by
the GSI betatrons need to be distinguished as “Old Betatron” and “New Betatron,”
always in every situation addressed in technical papers.

Finding 5 -- Adding Betatron Operator Dose to Radium Radiography Dose

[1] Page 5 of 9, first paragraph. Neither SC&A nor DCAS NIOSH havea
rational basis for deciding what percentage of the time any of many GSI
radiographers used Ra-226, or performed as Old A-C Betatron operators from 1952
through the end of the radium era agreed arbitrarily to be on 12/31/1962. Thus, the
time assignments are completely arbitrary. The radiographers also used two

. industrial 250 Kvp portable x-ray machines for NDT work, and some did Magnaflux
and ultrasound as well. DOL and NIOSH do not have a complete verifiable listing of
the people who were GSI radiographers and which specific radiographic jobs they
performed for specific amounts of time.

[2] Page 5, paragraph 2, Allen states “operators indicated 15 minutes
between shots...” To make this statement credible, Mr. Allen needs to cite specific
worker testimony among the several GSI radiographers who offered testimony in
interviews or affidavits or both regarding this important matter —

-, etc. Their testimony varied


McKeel Critique to Allen 7/10/15

4. Whether the alternating castings is a reasonable bounding scenario.

5. Two betatrons — whether the scenario should include 3 castings alternating between 2
betatrons and the layout man.

6. Work time after short shots (15 minutes or 75 minutes).

On Page 9 of 9 Allen reviews the 5 parameters that need to be resolved ina Path
Forward statement about SC&A findings 2, 5 and 10.

1. Using 8 hours per shift of exposure for uranium work in the betatron building (Finding
2)

2. Using intermittent irradiation equation for beta dose calculation for betatron operator
(Finding 2)

3. Fraction of time a betatron operator stands with his hands behind his back or to his
sides

(NIOSH recommends 0.5) (Finding 10)

4. Fraction of betatron operator dose to be added to radium dose (Finding 5)

5. Biasing of betatron dose fraction toward uranium work (Finding 5)

FINAL MCKEEL COMMENT:

* More than 8 years have elapsed after GSI Appendix BB Rev 0 was first issued and 13
months after Appendix BB Rev | was issued on June 6, 2014.

+ In the final analysis, David Allen and DCAS on July 10, 2015 proposed a Path Forward
for 4 GSI Appendix BB Rev 1 open issues before the TBD-6000 WG on 2/5/15, and
concluded his paper by listing eleven (11) parameters upon which SC&A and DCAS
NIOSH need to reach agreement in the future. Their respective positions are far apart on
most of these findings, and a path forward based on sound scientific hard data appears not
to be possible to me. What is left is guesstimating and speculative, scientifically
indefensible assumptions. NIOSH cannot bound these doses with sufficient accuracy.

‘Respectfully submitted,

Daw McKeel July 19, 2015

Current contact information:
Daniel W. McKeel, Jr., M.D.
GSI SEC-105, Dow IL SEC-79 and
Texas City Chemicals SEC-88 co-petitioner
SINEW cofounder


McKeel Critique to Allen 7/10/15

during that time period. Petitioners argue that back extrapolation is not warranted
and cannot be justified scientifically.

[2] NIOSH continues to ignore the fact that the GSI did not do production
uranium NDT runs during October through December 1952. According to AEC
operational reports Dan McKeel obtained through FOIA, during November and
December of 1952 GSI did “R&D work with MCW uranium billets to improve image
quality of NDT inspections using a uranium shield designed and built by MCW.” It is
scientifically incorrect and unjustified to equate betatron R&D work to improve
x-ray film image quality with production NDT inspection on MCW-AEC uranium
ingots (and dingots) that took place during April 1958 through June 1966 according
to extant MCW-AEC purchase orders made to GSI in Granite City, IL. NIOSH has
never modeled betatron exposures to operators (x-ray photons, beta or neutrons)
using the Old GSI A-C Betatron 1952, including use of the experimental R&D
uranium shield furnished by MCW in 1952.

[3] How could the peak years for Uranium Hand and Arms beta dose be
1953-1957 for which NIOSH has zero uranium source term data at GSI? There is
absolutely no evidence that more uranium was processed at GSI 1953-57 compared
to 1958, for example. Such peak beta dose values cannot logically be derived by
simple back extrapolation. Mr. Allen and Dr. Neton and DCAS need to explain these
derived numbers. Or, DCAS needs to admit the doses cannot be bounded, which is
the GSI petitioner team view.

[4] DCAS/NIOSH has zero direct information on the tonnage or number or
varietal mix of types of steel castings at GSI for any year of the operational or
residual contamination periods at GSI. Why, then, is a slight incremental increasing
trend noted for steel beta dose to hands and forearms during 1953-1965? Some
beta must derive from Betatron photoactivation of steel. Where are those dose
calculations?

McKeel conclusion about Table 1 Beta doses: The 1952 data is invalid. The
1953-1957 data has no factual basis and cannot be justified with scientifically
defensible assumptions. It is illogical and unreasonable and not plausible to make
1953-57 uranium skin, forearm and body beta doses the peak values.

Finding 10 -- Betatron Operator Gamma Dose

[1] Page 3 of 9. Allen makes an unwarranted assertion that is not supported
by the facts as I know them. He states “Since most of the accounts in the betatron
building indicate they were always rushed to get the next shot started.” Mr. Allen
needs to cite the particular interviews by date and transcript page. In fact, he is
merely speculating and adjusting the facts to the point he is making, to support


McKeel Critique to Allen 7/10/15

about the time for the shots and set up time and other factors. Almost all of this
testimony was by radiographers during the 1963-1966 post radium era.

[3] The time percentages assigned by SC&A and DCAS NIOSH for
Betatron/radium-226 radium operators are purely arbitrary. The assumptions
cannot be supported. The most claimant favorable split should be assigned to assign
the radiographers the highest possible doses. NIOSH continues it betatron operator,
claimant adverse external dose assignments.

[4] NIOSH for years ignored Dan McKeel’s and the GSI SEC petitioner team
admonitions that GSI radiographers 1952-1962 used both Betatron and radium-226
and 250 Kvp and perhaps other sources in their work at GSI. It is highly claimant
adverse and therefore discouraging this Finding is still undergoing dispute
resolution after so many years.

Finding 6 -- Layout Man Beta Dose

[1] Page 5 of 9. David Allen perpetuates the “layout man” terminological
erroneous construct. There is no “layout man” job category at GSI. No person can be
identified who worked solely as a Layout man.” The term should be dropped.

[2] Page 6 of 9. “Layout man” is a surrogate term for GSI workers who were
not radiographers or administrative personnel. Such “other workers” were assigned
a much lower (~10-fold) overall external photon dose compared to Betatron
operators in Appendix BB Rev 0 (June 25, 2007) that has been used for 90% or more
of completed NIOSH dose. Appendix BB Rev 0 by David Allen and Samuel Glover
totally ignored Betatron and Other worker beta and neutron doses.

[3] It is another distressing and major oversight that DCAS and SC&A are
listing points of agreement and disagreement for a brand new competing models
that both are jointly developing. My often repeated objection is that SC&A is not
contracted to do NIOSH work, which I believe is to develop a model that SC&A
critiques for scientific validity. This may be termed “evaluation.” I do not believe
that SC&A developing a model that NIOSH adopts and uses is “evaluation” at all.

[4] Stating the bulleted list under paragraph 1 on page 5 are “agreement...
parameters” is a misnomer. Allen actually points out that SC&A differ in the values
of assigned fractional values for long and short shots, the time a layout man is
exposed, and that intermittent irradiation used by NIOSH alone. These are points of
disagreement, not of agreement.

[5] The second bullet list of “differences in the parameters used” that vary
wildly. For example, NIOSH assumes layout man works on a short shot for 15
minutes while SC&A assumes 75 minutes. The problem is, Mr. Allen fails to state any
specific scientific or testimonial justification for making either assumption. | believe


Dragon, Karen E. (CDC/NIOSHIEID)

From: NIOSH Docket Office (CDC)

Sent: Monday, July 20, 2015 7:51 AM

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

Subject: FW: McKeel Critique of Allen/DCAS GS! paper dated 7/10/15
Attachments: McKeel_Critique_ToAllen_71015.pdf

From: Daniel McKeel

Sent: Sunday, July 19, 2015 8:36 AM

To: pl.ziemer@- . Ziemer, Paul (CDC/NIOSH/DCAS); Katz, Ted (CDC/NIOSH/OD); NIOSH Docket Office (CDC);
Allen, David (CDC/NIOSH/DCAS); Neton, Jim (CDC/NIOSH/DCAS); Hinnefeld, Stuart L. (CDC/NIOSH/DCAS);
jmauro@scainc.com; Josie_J_Beach@rl.gov; j-poston@tamu.edu; wimunn@aol.com

Cc: patriciajeske27/ 43 jwramspott/ danmckeel2¢ Kinman, Josh (CDC/NIOSH/DCAS)
Subject: McKee! Critique of Allen/DCAS GSI paper dated 7/10/15

Greetings to the TBD-6000 WG members and to NIOSH Public Docket 140 (GSI),

Please consider the attached rebuttal and constructive critique to David Allen's GS! Path Forward white paper dated
7/10/15. | was supplied with copies of the PA cleared paper on July 16th.

Ted Katz, please distribute this paper to all current ABRWH members.

NIOSH Docket office: Please consider posting this paper to Public Docket 140 (General Steel Industries) on the DCAS
website. A suggested title is:

"Submission by Daniel W. McKeel, Jr., MD: Critique of the David Allen (DCAS NIOSH) “Discussion of
Remaining Issues to Sanford Cohen & Associates Review of Battelle TBD-6000 Appendix BB (General
Steel Industries, Rev. 1) Response Paper" dated 7/10/2015.

Thank you for your consideration.
Sincerely yours,
-- Dan McKeel July 19, 2015
Daniel W. McKeel, Jr., M.D.

GSI, Dow IL & TCC SEC co-petitioner
SINEW cofounder


McKeel Critique to Allen 7/10/15

these assumptions are worthless from a strictly scientific view. There is no hard
data to support them.

Then follows on Pages an expanded discussion on each of the different model
assumptions. In all these expanded discussions, there is no hard science offered. The
back and forths are mere speculations. DCAS and SC&A are making invalid
unjustified assumptions and mentioning worker testimony that is not validated by
providing specific affidavit, transcript, of interview transcript pages. For example,
on Page 7 of 9, item 2. 10% long shots versus 36%, Allen sates “Based on
statements by workers, it has been assumed that 10% of the shots in the
betatron were long shots.” The same questions arise: 1. Which Betatron?, 2. What
workers? 3. Where is this testimony recorded? Etc.

Mr. Allen presents uninformed speculation rather than facts to support his views.
This is reflected in comments he makes about relative numbers of defects in thick
and thin castings. This discussion is irrelevant, since NIOSH and SC&A do not have
any GSI shot logs to identify what types of castings were shot for how long with
what radiation sources during different GSI operation time periods.

On page 7 of 9, under item 3. Single large Casting, Mr. Allen cites further
undocumented off-record e-mails sent to him by SC&A that apparently were apart
from a formal technical phone call meeting. I strongly protest because such e-mails
are not further identified or put into the record as an Appendix to Mr. Allen’s white
paper. In refereed scientific journals, such unsubstantiated “personal
communications” are frowned upon by editors or are disallowed. Mr. Allen should
document these extracurricular e-mails from SC&A which he allegedly received and

factored into his arguments in the 7/10/15 path forward for GSI Appendix BB Rev 1
four open issues paper.

Points 4. (15 minute exposure to short shot versus 75 minutes) and 5. (Two
betatrons on site) on Page 8 of 9 are scantily developed and do not add scientific
validity to the discussion. No further comment by Dan McKeel.

Page 8 of 9, last paragraph Mr. Allen outlines Path Forward for Layout Man Beta
Dose (finding 6). He reviews the 6 parameters on which agreement needs to be
reached between DCAS and SC&A to resolve the finding.

1. Fraction of short and long shots.

2. Whether a single large casting dose is to be included.

3. Fraction of time worked on “hot shots” — related to #2 above. If it is assumed that a
single large casting represents some of the time, that fraction is necessary.


McKeel Critique to Allen 7/10/15

Submission by Daniel W. McKeel, Jr., M.D.
General Steel Industries SEC-105 Co-petitioner
To NIOSH Docket 140 and to the TBD-6000
Work Group of the ABRWH (7/19/2015)

A Critique of the
David Allen (DCAS NIOSH)
“Discussion of Remaining Issues to
Sanford Cohen & Associates Review of

Battelle TBD-6000 Appendix BB
(General Steel Industries, Rev. 1)

Response Paper”

Dated 7/10/2015

This paper is a critique of David Allen’s DCAS NIOSH response to the four open
issues raised by SC&A in its 12/10/14 memo regarding GSI Appendix BB Rev 1.
Nine SC&A findings were part of the 12/10 memo and another SC&A follow on
memo issued 1/26/15 added a 10% Finding.

Ten SC&A Findings were discussed by the TBD-6000 work group (WG) at their
latest meeting on February 5, 2015. Six were considered closed. I received copies of
this latest David Allen DCAS NIOSH paper on 7/16/15.

My comments on SC&A open issues/Findings 2, 10, 5 and 6 follow in the order these
issues were discussed in the Allen 7/10/15 response paper.

MCKEEL SPECIFIC FINDINGS COMMENTS
Finding 2 -- Betatron Operator Beta Doses

(a) Finding 2, page 2: The language Allen uses is too vague for a scientific
communication. An example is: “In 2013, NIOSH and SC&A exchanged files...”
leaves open what type of files were exchanged? Were they MCNPX data files, or an
Excel spreadsheet, and if so what version of MCNPX was used? For what purpose
were the files exchanged? Which agency and persons initiated the file exchanges and
performed the data analyses at DCAS and SC&A?

(b) Finding 2, page 2: Allen fails to defend or justify why the “timeline and
values using 1953 as an example” were selected by DCAS. These values are from the


McKeel Critique to Allen 7/10/15

first full year of the operational period, at the Old Betatron facility 10 years before
the second GSI Betatron was brought to Granite City from Eddystone and placed in a
new Betatron Building that differed structurally in many ways from the Old
Betatron building constructed by the Chicago District of USACE. DCAS NIOSH has
zero MCW purchase orders, Betatron shot records or maintenance records, or film
badge data, or Betatron operator affidavits from 1953 - zero measured data of any
kind. So, why would DCAS select purely fictional data from an computer model that
possessed no measured beta or neutron or photon doses that NIOSH itself accepts.

Jim Neton, who reviewed the Allen 7/10/15 paper, and DCAS had previously
rejected Dan McKeel’s NYO-4699 papers with HASL (AEC) measured 22 Mev
photon, neutron and operator film badge data, and facility drawings, at three U.S.
Betatron particle accelerator sites for use at GSI.

(c) Allen fails to justify or attempt to explain the failure of both NIOSH and
SC&A to agree on Betatron beta skin doses to the operators hands and forearms
during the almost 7 years it took to issue Rev 1 of Appendix BB on 6/6/14. Thirteen
additional months have elapsed before the Allen 7/10/15 response paper to SC&A
appeared. Betatrons accelerate electrons which leak into the beam as well as
bombard the internal target that produces x-rays. Knowing this basic fact about
betatron particle accelerators, about which hundreds if not thousands of scientific
papers have been written, it is difficult for the GSI SEC-105 physician/co-petitioner
to understand why this final assignment of beta skin doses is taking so much time to
resolve.

(d) On page 3, why is there such a gross 10-fold discrepancy between the
uranium and steel hand and arm doses? Allen needs to justify and explain this order
of magnitude difference in detail. Especially given the fact that adequately defining
betatron operator skin doses were ignored so long, including in Rev 1 of Appendix
BB. How can this inaction be justified scientifically?

(e) On page 3, what was the basis for adjusting the steel beta dose from
continuous to intermittent? The assumption should be restated here. How was the
specific intermittent dose factor derived? Allen states that “NIOSH further indicated
their intention to adjust the beta dose to account for intermittent irradiation of
castings.” But SC&A did not ratify doing so would be claimant favorable. NIOSH, in
fact, by adjusting the dose to entirely arbitrary unjustified assumptions, is making a
claimant adverse decision (one of many made between 2007 and 2015).

(f) Page 4, Table 1 - Betatron Operator Annual Beta Doses raises
multiple questions, as follows:

[1] NIOSH has no uranium AEC-MCW purchase order source term data for
the years October 1952-April 1958. What assumptions did NIOSH use to derive the
values they list for Hands and Forearms Uranium and Steel and for Whole body skin