McKeel_Notes_8.28.12wg.doc

[62] Mauro: “Can use some surrogate data. If scoured, what can

you do? Have to throw the model out.” (emphases added)

[63] McKeel: Assailed John Mauro’s “if scoured” remark, making a
bold statement that:

(1) Defended . ’s eye witness statement that “power
blasting did occur for OBB in 1984”, and said he spoke for all
nuclear weapons workers in the EEOICPA program who generally
offered honest, accurate, eye witness testimony.

(2) That petitioners have photos they can share that prove
white lead paint covered the OBB walls during GSI operations, in
about 1964, in contrast to DOE / ORNL photos taken in 1993 at
the time of the uranium cleanup that clearly show 75% of the OBB
white paint has been stripped off leaving bare concrete walls
with faint patches of white paint remaining.

[NOTE: See Figure 1 of OBB 1964 versus 1993 next page 20]

(3) GSI uranium was not as “simple” an operation as
Dr. Mauro had stated because 50% of the time at GSI, after NDT
radiography, the “cold uranium metal” was “hot” from being
subjected to 24-25 Mev Betatron x-irradiation that caused both
photofission and photoactivation.

[64] PLZ [Ziemer]: Quibbled to Dr. McKeel that GSI uranium “was
not thermally hot.”

[65/65] McKeel/Ziemer exchange: McKeel countered the Ziemer
attack about how McKeel used the term “hot” as semantic nit-
picking that has occurred before (hot particles), asserting
that: (a) GSI uranium from MCW was subjected to Betatron fission
that generated new radioisotope daughters, could Dr. Ziemer
disagree with that statement? Dr. Ziemer answered “No”; and (b)
GSI uranium from MCW was subjected to photon activation that
also generated new radioisotope daughters, was that right? Dr.
Ziemer agreed "Yes", the statement was correct, and added that

“they have been accounted for in Appendix BB 2007.”

- 19 -


APPENDIX B

This Appendix corroborates the statement by
to participants at the 8/28/12 TBD-6000 work group that Dan
McKeel did inform the same work group participants at an earlier
TBD-6000 work group meeting, held on June 14, 2012, that the Old
Betatron Building (“OBB”) at GSI had been cleaned and power
washed in the 1970’s.

Dr. McKeel’s rendition of that specific piece of
information is found on page 21, lines 12 through 14, of the
official, verbatim, court reporter transcript of the June 14,
2012, TBD-6000 work group meeting.

Dr. McKeel’s comment spanning the entire residual period is
given in this Appendix in order to place the OBB power washing

quotation in context.

[Sameol us eleet, Whee

- Daniel W. McKeel, Jr., September 1, 2012

Excerpt from the June 14, 2012 transcript of the TBD-
6000 work group of the Advisory Board on Radiation and
Worker Health. The testimony of interest is that by
Daniel W. McKeel, Jr., GSI SEC-00105 co-petitioner
with . GSI primary petitioner

Filename: McKeel_TBD6k_tr_6.14.12.txt

® Note: Names, page numbers and line numbers are bolded. The passage
regarding the Old Betatron Building being power washed in the 1970's
on transcript page 21 is bolded, italicized and highlighted in yellow.
Dow worker Bill Hoppe has given further testimony in August 2012 that
the power washing of the OBB actually occurred with certainty in 1984.

PAGE 18 (McKeel note: “Dave” in line 12 is David Allen
(DCAS)

1 switch. When you walk in the door, it goes to 2 maximum.
3

CHAIRMAN ZIEMER: Right. 4

Page 1/40



McKeel_Notes_8.28.12wg.doc

[129] Beach: “Don’t agree to use 1993 back extrapolation here.”
[130] Munn: “Now we are going to look for surrogate data from
other sites. We can do this.”
[131] Beach: “Third option: Vote for early period SEC if Board
wishes.”
[132] Ziemer: (McKeel, from memory): “When will NIOSH start?”
[133] Allen: “Start, now, nothing before Board meeting.”
[134] Katz: “SC&A, DCAS, Dr. Ziemer will summarize -- do we need
any presentations?” (emphases added)
[135] Anigstein: (McKeel, from memory) “Should I go, I already
am booked?”
[136] Ziemer: “No, don’t need to present SC&A and DCAS.”
(McKeel Note: No one mentioned 10 minutes Dr. Melius has set
aside for Dan McKeel to address the Board on September 19th.)
[137] Katz: “You can choose.”
[138] Beach: “Matrix wasn’t closed, SC&A needs to update matrix.
SEC issues were not transferred to the Appendix BB issues
matrix.”
{139] Ziemer: “Yes. I‘1l make a chart ‘so we are all on same
page’. There is always overlap between SEC and Appendix BB
issues.” Then Dr. Ziemer cross referenced some SEC issues that
had been closed and some that were still open, and some that had
been transferred as Appendix BB issues: [McKeel comment: This
part of the discussion was very difficult to follow because two
matrices were being cross referenced and the issues were not
described in exact sequence]:

- “Issue 1 closed.”

- “Issue two became part of App-BB (2)”

- “Issues 3, 4 and 5 move out and closed”

~- Beach mentioned “issue 6 wasn’t closed, part of Appendix

BB 11”

- Issue 7 was “in progress, show update”

- 36 -


McKeel_Notes_8.28.12wg.doc

5.

New information on the GSI residual period from 1978 to 1993 has recently been
gathered and transmitted to the TBD-6000 work group and to the full Board and posted
on the DCAS website. In brief, there were two known extensive cleanup, power pressure
washing, and rewiring and renovation campaigns to the New Betatron building. The first
was in August 1978 by Michigan Metals Processing who had a three year contract with
National Steel. The New Betatron facility was cleaned up, rewired and power washed by
Power Blasting Company in August 1978 and used for offices and classrooms. The MMP
contract work also included cleaning up buildings 8, 9 and 10 during the three year
period. Apparently none of the MMP workers wore protective clothing or respirators and
our eye witness states the subject of possible uranium contamination was not mentioned.

There also was a power washing by the Power Blasting Company to the Old
Betatron building interior in 1984. Photographs of OBB before and after the power
washing in 1984 show marked stripping off of the white paint on the walls from the force
of the power washing (see Figure on page 20).

We believe a company named Affiliated Metals occupied former GSI building 6
during part of the residual period and continued the steel pickling operation that MMP
had initiated.

Thus, large areas of the former GSI building complex and both Betatron facilities
were extensively renovated, cleaned, power washed with sufficient force to strip paint
from the walls, rewired, paneled (NBB only), and repurposed for class room work and
pickling operations. This must have created massive disturbances of the surface dust on
floors, wall, ceilings and in air vent ducts. It is difficult to imagine this scenario could be
modeled accurately in the uranium transport and NDT paths, even with monitoring data.

However, during this same time period, no workers were badged and there was no
monitoring for uranium done except for the ORNL/DOE FUSRAP survey of the Old and
New Betatron buildings and the removal of some uranium by them from the Old Betatron
facility in 1993. The DOE/ORNL cleanup was started in 1988 and completed in 1993.

Conclusions:
NIOSH has no acceptable uranium intake model for GSI after three attempts.
2. NIOSH rejects the SC&A July 25, 2012, alternate intake model for uranium.

3. Airborne uranium levels varied widely because of renovation and cleanup and
repurposing work in the GSI Betatron buildings and buildings 6, 8, 9 and 10.
4, We believe the conditions described cannot be modeled absent measured data.

Page 13/10d



McKeel_Notes_8.28.12wg.doc

{79] Anigstein: “Disconnect between ORISE (sic) Old Betatron
Building cleanup; doesn’t seem plausible. Pattern along railroad
track.”

[80] Mauro: “Do we want to stipulate, rather than dispute, there

was an old Betatron Building cleanup? -- can’t use our model.

Set it aside.” (emphasis added) “Pursue, surrogate data, ‘our
work’ -- whether we can find a starting point. Tractable point.
All issues with surrogate data -- can work through that.

(81) McKeel clarifying editorial comment that must be made here:
[There is a dispute about how the SC&A alternate GSI uranium
intake model paper of 7/25/12 came to be tasked and approved.
The SC&A report and e-mail from ABRWH DFO Ted Katz to McKeel
clearly indicate that SC&A and Dr. Zeimer, with Ted Katz
present, discussed the SC&A surrogate data 7/16/12 paper and the
SC&A 7/25/12 alternate model paper before either of the reports
was released to the Board or the public, including McKeel. Mr.
Katz clearly indicates that Dr. Ziemer approved both SC&A papers
going forward. SC&A indicated the alternate model paper was
approved by Dr. Ziemer. The complete McKeel-Katz correspondence
has been previously circulated to all Board members by Mr.
Katz.]

[82] PLZ (Ziemer]: “John (is) plausibility like concentrations?
Picked a surrogate for GSI. Would fulfill plausibility --
reasonableness of model.”

“Once you pick a surrogate -- amongst new ones, we have that
Mauro would not refer to model as plausibility. What models
should be used operational and residual periods -- semantics.”
“PLZ-Allen-criteria / plausibility -- how? We use it? refers not
to value but to manner. Tractable if we have a starting point.”
[83] Mauro: “I am OK with that. Mechanics are easy, episodic
dust all very tractable IF we have a good starting point.”

(84) McKeel margin note: “Illogical, hard to get start point.”

- 23 -


MEMBER POSTON: When you walk out, 5 the door, it goes to
zero. 6

CHAIRMAN ZIEMER: Right. 7

MEMBER POSTON: Okay. All right. 8 I understand. 9

DR. MCKEEL: Dr. Ziemer, this is 10 Dan McKeel, may I make a
comment? 11

CHAIRMAN ZIEMER: Sure. 12

DR. MCKEEL: Dave mentioned, when 13 he was reviewing what
was done at the slug 14 production facility, he made a
comment that 15 there was no cutting, grinding, or abrasion
of 16 uranium at GSI. 17 And one of the points that I want
18 to reinforce is that, although that was not 19 done as a
machining operation, those large 20 slugs, I mean, the
large ingots and dingots

PAGE 19

1 even the betatron slices, were so heavy that 2 they had
to be picked up and handled by chain 3 men and by chains. 4
And, of course, those chains were 5 hanging down from a
crane, the ingots and 6 dingots were swinging, and,
undoubtedly, those 7 chains scraped the outer surface of
the ingots 8 and dingots which had not been cleaned of 9
their outer crust. 10 So a point that I think has been 11
ignored throughout this consideration of GSI, 12 but it is
mentioned by SC&A in their White 13 Paper, that there was a
long path thl4 General Steel by which the uranium from 15
Mallinckrodt traversed, even before it got to 16 the
betatron buildings. 17 So, you know, it had to come to 18
the loading docks, we know that it was stored 19 before and
after it got there, it had to be 20 loaded onto their
railroad transfer cars,

PAGE 20

1 traversed many of the buildings beside the 2 foundry,
through Buildings 6, 7, 8, 9, 10. 3 The railroad tracks
from Building 4 10 went into the new betatron building, so
the 5 ORNL assumption in 1989 that the only areas 6 that
had uranium contamination were the old 7 and new betatron
buildings must have been a 8 cost containment sort of
consideration, 9 because anybody who thinks about the
process 10 for uranium handling at GSI has to recognize 11
that there were long pathways that probably 12 were
contaminated by chafing and scraping by 14 betatron slices.
15 So I think that is a major lack of 16 the analysis of
the residual period. There is 17 zero data on uranium
surveys at GSI. Real 18 uranium survey, radiologic data,
from 1952, 19 when the first machine, betatron government-
20 owned machine, was there until the ORNL survey 21

Page 2/41



McKeel_Notes_8.28.12wg.doc

“Criterion 2: Exclusivity stringently justified”

“Criterion 3: Site or process similarities. Don’t know where
site was”

"Criterion 4: Time period -- accepts NIOSH”

(Criterion) “5. Biggest issue plausibility: slow deposition not
plausible.”

Then Bob tracks “adjustment for uncertainty, never get perfect
surrogate, make accommodations. Judgment difficult. No

monitoring URANIUM; Purchase Order duration handling...”

McKeel Page 2 ABRWH TBD6K 8.28.12

“Purchase orders on firm ground. Uran. handling operations...
NIOSH didn’t use ...” (words missing)
[4] Poston: “Is it not subjective thus far?” (McKeel comment to

self in notes in text and in margin: Arguing with SC&A! Can do

uncertainty analysis - “should be adjustments”)
[5] Anigstein response to Poston: “should use site data... on
why he says --> data uses in TBD-5000... geometric versus
arithmetic mean...error that needed to be corrected... 590
Harris-Kingsley arithmetic mean 162...geometric SD = 5 could
call it SD (standard deviation) -- YES!! Got to 264 (error)...
NIOSH prev(s?)ent value too high, make geometric mean. One
number by NIOSH can’t be geometric mean; driver of logistical
regression.”
[6] Anigstein: Going through adjustments for

1. “Geometric mean ~ 1 no” (McKeel: you need multiple
numbers to establish a mean; NIOSH has only a Single value, a
valid point - but Allen didn’t respond to this criticism)

2. "8 hr day -- NIOSH assumes 4 hrs with uranium, a 50%
decrease -- 75% of 50% (to be) consistent with TBD-6000.”

“Criterion 2. NIOSH agrees not stringently”...


McKeel_Notes_8.28.12wg.doc

revealed additional radiation source terms at GSI including
another C0-60 small source, a Co-60 80 curie source, another 250
Kvp portable x-ray source and two Ra-226 sources, all of which
were unknown to either NIOSH or SC&A up until that time.
McKeel’s successful justification of a fee waiver led to NRC
posting this information, unredacted, subsequently on the NRC
website. I do not make this claim to boast -- it is the truth

and will be borne out by the written record.]

McKeel Page 16 ABRWH TBD6K 8.28.12

[113] Anigstein (continued from Page 33...): “...looking into

what happened at GSI -- 90% what happened. Told very, very
recently -- a little fast. I don’t take ownership of my model.
Won’t give up this model -- “based on site data. Plausible upper

bound. (emphases added)”
(114) McKeel note to self: “NOT 100% GSI site data in alt.
model.” [is not a plausible upper bound because of the
stipulated OBB power washing and withdrawal of the alt. model]
[115] Mauro: “Hate to abandon model.”

a) “NIOSH can find a better surrogate.”

b) “They have already stipulated OBB was cleaned.”
[116] PLZ [Ziemer]: “Agrees OBB was cleaned up 1984. Accepted.”
[117] Ramspott: “”...few months ago transcript” (Ziemer cut him
off)
[118] PLZ [Ziemer}]: “Ask NIOSH and SC&A to collaborate on a
better surrogate?” (emphases added)
[119] Beach: “What period? Covered period. Surrogate data covers
the covered and the residual periods.”

[120] Neton: “Be start point for a new model.” (emphases added)

(121) McKeel editorial comment: [This would be NIOSH’s fifth
opportunity to develop an intake model. Allen Appendix BB, two

- 34 -


McKeel_Notes_8.28.12wg.doc

Power Washing in 1984 Removed Much of White Lead Paint on GSI Old Betatron Walls

| Ord Betistron Apter. 1964 fwhile paved wails)

Above: GSI Old Betatron shooting room 1964 with walls covered in white lead paint

‘id Betatron.._ DOE Photo FUSRAP Ci

Below: By the time of the ORNL/FUSRAP cleanup 1993 most of white paint was gone

-~ 20 -


McKeel_Notes_8.28.12wg.doc

Bob Anigstein and DCAS (Mr. Allen, Dr. Neton) have just not
gotten their facts correct.

2006 napkin drawing of Betatron 4 corner shot

~<

yen

Dan McKeel napkin drawing 4 comer GSI Betatron shot MCW Ur

Copyright notice: This digital image is ©2012 by Daniel wW.
McKeel, Jr. It may not be reproduced in any form by anyone
without written permission of Dr. McKeel. _ owns
the copyright to the original napkin drawing concept dated

6/13/06 drawn by Dan McKeel and the same stipulations for use

apply. © 2006, 2012 by ~ and Daniel W. McKeel, Jr.

- 26 -


McKeel_Notes_8.28.12wg.doc

[69] Mauro: Confirmed again (twice) -- “stipulated, a legal term
I’ve used more recently” -- that since the OBB was cleaned, the
SC&A alternate intake model for uranium had to be withdrawn from
further consideration [McKeel paraphrase of this part of the
conversation].

[70] Work group members as a whole: There followed by unanimous

acclamation a statement that “All work group members accept

testimony that the Old Betatron Building was cleaned.”

(emphases added)

e A lunch break followed from 12:15 PM to 1:15 PM ET. McKeel

logged back on at 1:13 PM ET when 7 people were participating in
the conference call.

[71] PLZ [Ziemer]: “How much mutual agreement is there on
criteria 2 and 4?

[72] Anigstein: “On 4 we agree.”

[73] PLZ [Ziemer]: “Criterion 2 did they agree?”

[74] Anigstein: “Site or process -- similarities -- if NIOSH
used.”

[75] PLZ [Ziemer]: (Putting words in mouth). “Feel more
comfortable with hierarchy issue if distinct advantage -- and if
process and plausibility.”

“We still need to agree and accept surrogate data.”

[76] Neton: “Criterion 1 -- if cleaned up; SC&A would agree.”

(emphases added)
[77] Anigstein: “But adjustments not made appropriately.
Criterion use surrogate data if no” (cut off by next speaker)

[78] Mauro: “I_agree with Bob. Now we have to use surrogate

data. Appropriate to use surrogate data, move into that realm.

Start with a good data set. (emphases added) Agree to” (continue

next page...)

McKeel Page 12 ABRWH TBD6K 8.28.12

[78] Mauro (continued...) “use a better data set.”

- 22 -


McKeel_Notes_8.28.12wg.doc

Path Forward for GSI Allen white papers, white paper 8/21/12
defending their own TBD-6000 SD model that was turned down
8/28/12, rejection of the SC&A alternate model, today’s 8/28/12
meeting, and the new model that is proposed for some time in the
indefinite future. This process is unreasonable in several ways:
way too many tries allotted to NIOSH, no successful models SC&A
and the WG accepts, and way too much time allotted for NIOSH to
accomplish their mission.]

[122] PLZ [Ziemer]: To Dr. Poston, “Are you suggesting a
technical meeting? Allen model. Bob’s off the table.”

[123a] PLZ [Ziemer]:

“Motion:

(1) “SC&A review was NIOSH did not meet 3 or 4 surrogate
data criteria.”

(2) “Extensive discussion what would constitute appropriate
surrogate. Want NIOSH to tell us a different surrogate route.
Then SC&A comes on board to review.”

(123b) McKeel to self: There was no second or vote on this
motion). No reply by Dr. Ziemer to [122] Poston.
McKeel Page 17 ABRWH TBD6K 8.28.12

[124] Beach: “Vote on an SEC for early period -- MOTION NOW”.

(emphasis added)

(125) McKeel observation to self: “PLZ ignored this.” (emphasis

added) WG chair Ziemer ignored WG member Beach’s immediate
motion, did not ask is there a second?)

[126] PLZ [Ziemer]: “Can vote here...” “Is everyone
comfortable?”

[127] Person not identifiable: Someone who McKeel cannot
identify blurts out “Yes”.

[128] Munn: “Prefer not to conclude it. Reliance on FUSRAP not

as desirable.”

- 35 -


McKeel_Notes_8.28.12wg.doc

“Two Betatrons 4000 pounds each on floor of Old Betatron
Building.”

[49] PLZ [Ziemer]: “These are sampling sites, not measured.”
[50] Ramspott: “Not just sampling. Another drawing shows “hot”
spots.”

[51] Anigstein: “I put on red and blue dots to correspond to
plot coordinates.”

(52] Beach: “Are you...” (words may have been lost)

[53] Allen: “198 dpm Appendix BB is bounding, few other sites.
Have not dismissed SC&A model but have problems heterogeneity
after cleanups. SD is better approach. Other site”... (missed
words)

"True intent (laughing) see what work group feels - use what we

have.” (emphases added; here Mr. Allen was asking for how the
work group was going to vote, I believe, but this is
speculation). “Starting point first, then mechanics.”

(11:45 hrs ET]

[54] PLZ [Ziemer]: “Work group recommends to the Board. What we
say is not the final word. Finding common ground is helpful.
Board can go for SEC both periods. Or, one or the other. Need
some level of SC&A and NIOSH agreement. We can present to Board

what issues are.”

McKeel Page 10 ABRWH TBD6K 8.28.12

[55] PLZ [Ziemer}: Asks Anigstein “are SC&A...” (words missed)
[56] Anigstein: “SC&A has been interviewing GSI for 5 years.
Even though this model was just recent. Measurement validation
by NIOSH.”

(McKeel aside to self: goobledegook - no mention of a cleanup)
“Now getting second hand info.”

“When I did model, I knew NBB was cleaned up.”

-17 -


McKeel_Notes_8.28.1l2wg.doc

McKeel Page 7 ABRWH TBD6K 8.28.12

“Devil is in the details -- dealing with minutiae.” (emphases

added)

“Can’t we do any...” (missed words)
“We have done a remarkable job of holding up to light.”
[31] PLZ [Ziemer]: “On item 1. (of agenda) the work group and

Board will have to decide if slug facility is suitable surrogate

versus using back extrapolation from 1993.” (emphases added)

(MCKEEL NOTE: Later I stated to the work group the time to do
this and decide on the SEC was today, but they declined to vote
and did not make a clear decision about the existing NIOSH
Appendix BB June 2007 uranium intake model. They left these key

matters, which were work group goals for today, open for the

full Board to decide at the September meeting presumably. I
believe the decision to take this avoidance approach happened
during the lunch break.)

[32] Beach: “40 years back plus”

[33] Anigstein: “Alternative model bears on this.” (Dr. Ziemer
concerned work group here decides (to) recommend NIOSH approach.
[34] Mauro: “Light went on -- Bob’s work can be used as a
validation. Whole another way -- not a replacement -- do we come
within an order of magnitude. Not a bad number.” (emphases
added)

[34] PLZ [Ziemer]: “I’d like to hear NIOSH comments on other

criteria.”

[35] Allen: “Exclusivity constraints -- we agree not justified.

(emphases added) [McKeel_ margin note: “Big!”]
"Site processes -- no task of moving uranium metal.”

“Temporal no issue.”


McKeel_Notes_8.28.12wg.doc

make SEC recommendations today, SC&A is still trying to do

NIOSH’s job as if they, not NIOSH, have to bound doses with
sufficient accuracy. No, McKeel asserts, that is NIOSH’s job.
The Board and SC&A have to assess the quality of NIOSH science
under the Act].

[98] Ramspott: “Size can determine the amount of uranium. You
don’t know the quantity of uranium at GSI.”

[99] PLZ [Ziemer]: “Does not have to irradiated?” <-- [McKeel
note to self: size and volume (of uranium used) have to be
surrogate data OK, plausible amounts of dingot/ingot U-238 (pass

five Board SD criteria)]

McKeel Page 15 ABRWH TBD6K 8.28.12

[100] PLZ [Ziemer]: At 2:30 PM ET. “Need a motion options”:
“Accept NIOSH approach (modified surrogate data) criterion 3
SC&A agrees to as well. Although it is tractable...”

[101] Munn: “Whether we will or will not continue to rely on
FUSRAP or use NIOSH use surrogate data in a different manner.”
[102] Neton: “Mg Fl -- inhalation goes down, What fruitfulness?”
a) “reconstruct dose contract period...”

b) “reconstruct dose residual period...”

[103] Mauro: “Other places pure plus Mg Fl ‘not radioactive’ no
direct knowledge of this. Dolomite crust. Can we wrap and
wrestle -- way to bound it?”

[104] Poston: “We should move forward.”

[105] Ramspott: “Dingots 1958-66 Weldon Spring; ingots 1953-58
Feb. at Mallinckrodt” (Destrehan Street St. Louis).

[106] Poston: “SC&A working for the Board; NIOSH has their
responsibilities.”

- “Get SC&A and NIOSH together to provide a suitable

surrogate.” (McKeel, NO, that is NIOSH’s job)

- 32 -


McKeel_Notes_8.28.12wg.doc

NEWEST UNITED STATES
URANIUM PROCESSING PLANT

MALLINCKRODT CHEMICAL WORKS

WELDON SPRING, MISSOURI!

-~ 29 -


McKeel_Notes_8.28.12wg.doc

[9:36 a.m.]

“One alt. scenario -- as we were directed (emphases added) --
did find Adley melt plant Bldg Hanford -- handling rods
(emphases added) -- unloading with forklift (emphases added)

3900 dpm vs 590 dpm ~- 6x higher... still have concerns.”

(NOTE: slug = “powder metallurgy” ]
[9] PLZ (Ziemer] -- “Any work group questions?”
[10] Poston Ql: “All measured? -- Hanford --”

[11] Anigstein answer to Poston Ql: “Yes --low 88 was machined”
[12] Poston Q2: “Are these maximum values from Tables?”

[13] Anigstein answer to Poston Q2: “Difference unloading the
truck -- speculating don’t know but guessed two locations, no
further info, many measurements, only data on handling ‘cold

uranium’.”

McKeel Page 4 ABRWH TBD6K 8.28.12

[14] Allen. “One issue is much higher in area from other
Operations -- impossible to say is purely (from) handling cold
uranium. Can say. Not a good set of data to use.” (emphases
added)

[15] Beach: “Best guess...”
{16] Anigstein: “no surrogate data is ‘that good’. Just a few

default parameters from other places” (emphases added; passage

refers to his new alternative uranium intake model for GSI).
{17] Mauro: “Start point long time ago; NIOSH uses Mauro (at
first) supported -- ingots were not as rigorous as slugs.
Important message: 550 (wrong 590) -- is Harris-Kingsley a good
starting point?”

“Separate start point from mechanics -- SC&A criticized

NIOSH approach. Bob has come up with a whole new approach



McKeel_Notes_8.28.12wg.doc

“Criterion 3. Slugs do not have same properties.”

“Other SD sources (criterion) 3 or 4. Is work site
identified? Harris-Kingsley don’t mention (work sites). Does
slug...”

“Criterion 4. Has been resolved -- no measures taken to
reduce uranium dust at GSI”

"Criterion 5 -- Plausibility... uranium handling, immediate
dust cloud, 1/2 hr/handling” (peak drawing by McKeel showing
part going into mouth and part settling in a straight line to
ground). “... like a belt -- that and only that settles then

‘poof it’s gone’ “.

McKeel Page 3 ABRWH TBD6K 8.28.12

“SC&A calculates it will take a 5 micron AMD (particle)...
(words missed) to settle...”

“Space heaters up on wall -- higher than a few feet, thus more
on the floor.”

“Latest report Simonds-Saw / took days to settle” (McKeel note
to self: but does not [say Simonds-Saw was a rolling mill
operation])”

“TBD-6000 30 days for equilibrium with each ‘dust stir up
event’.”

2. “Deposition based on 1...”

“1961-62 maximum, constant all time thereafter -- not a
scientifically acceptable model.” (emphasis added)

[7] Poston: Calls Anigstein out on use of an inadvertent double
negative: Anigstein agrees.

[8] Anigstein:

3. “Air levels and surface concentration cannot be calculated
from air alone. Loose contamination on incoming ingots and

dingots. Ground by feet, trucks -- NOT satisfied.”


McKeel_Notes_8.28.12wg.doc

“OBB was just left.”

“Allegation of competence: done by ORISE MARSSIM manual

(emphases added) more reputable competent people in business” --

-- (McKeel comment to self: MARSSIM, (1) from the EPA website

general FAQ, “MARSSIM was developed collaboratively over a four-year period,
by a multi-agency workgroup. Members of the workgroup represented the four
federal agencies that have primary responsibility for controlling radioactive
materials.”); (2) ORNL did the GSI cleanup, not ORISE; (3) ORNL
operated under a DOE/ORNL expedited cleanup because the
radioactivity amount at GSI was anticipated to be low)

“Berm - only 10 to 15% of data” [sic: floor space] (McKeel
observation to self: OBB floor space vs 25% Ramspott had
estimated).

[57] Ramspott: “We invited everyone to visit that site (GSI)

as we did. (There) was mention of power washing in past

transcripts. If there was a cleaning, and that was done.

RE: berm, must clean old concrete before installing new.”

“IT suspect ORNL, they say there was a huge door “main door” to
left of drawing. Was knocked in wall after plant closure.”

[58] PLZ [Ziemer}]: (I’d like to hear) “Neton remarks on NIOSH
approach.”

[59] Neton: “Leblond 3 billets hooked. 500 “worth considering”,
I think 200 is bounding. SC&A feels could be bound some way.”

(emphases added).

(DWM note to self: uranium fission & activation ignored)
[60] Mauro: “agrees with Neton.”
[61] PLZ [Ziemer]: “Mauro want to agree: slug stamping not like
at (GSI) - troubled. 500 not analogous. Go with different
surrogate.”

McKeel Page 11 ABRWH TBD6K 8.28.12

- 18 -


McKeel_Notes_8.28.12wg.doc

very low.” (McKeel margin note to self: No forklift data cited

was 6-fold higher)
McKeel Page 6 ABRWH TBD6K 8.28.12

[26] Anigstein: “10° resuspension factor is too low for an active
area.”

[27] PLZ [Ziemer]: “Not using 10°.

[28] Allen: “Yes, we are.”

[29] Mauro: “Plausibility clause came into being because of
applying to Texas City Chemicals the Blockson model. Blockson
handled thousands of pounds (of uranium); TCC handled 300 pounds
over a very short period.”

(McKeel observation to self: Mauro now tries to discredit

plausibility criterion as useful for GSI model)

“True, ... ability ...(missed some words) but not the attention;
can’t use plausibility to apply to a big number and walk away =
No SEC.”

“Inappropriate...”

“I want to help out a little here...”

“If there is a model problem, we can resolve this” (emphases
added)

“A number of scenarios a lot better...” (emphases added; McKeel

to self: statements without backup -- what scenarios, what sites
are better? And, define “better,” in what way better?)

[30] Munn: “Entire discussion is extremely difficult. We are
dealing... Science around uranium is quite well established.
Sizes of particulates that create biohazards. Administrative

processes, looking at details (possibility) can make statements

over and over.” (emphases added) “How to focus on large known

issues? Are models correct, debates assume there is a

significant hazard in handling this material.” (emphases added)



McKeel_Notes_8.28.12wg.doc
(85) Munn: “Know what the material does. Poster child for why
Appendix BB put together. Info is not clearly available. Entire
knowledge base, don’t have to do.” (McKeel to self: No! Many

Appendix BB scientific flaws have been pointed out repeatedly)

McKeel Page 13 ABRWH TBD6K 8.28.12

[86] Beach: “Are dissimilar processes -- we don’t know. Charter
(sic?) surrogate data is not similar.”

[87] Allen: “Models don’t count. Process similarities --
handling is not a process. Surrogate data from multiple sites is
bounding.”

(88) McKeel must be made editorial comment: [Mr. Allen’s
preceding statement in [87] is NOT CORRECT if all the surrogate
sites use dissimilar processes and are not stringently justified
as to site comparability using the Board and/or NIOSH surrogate
data criteria. That’s why these SD criteria were formulated in
the first place. The work group is trying to obviate and by-pass
their own SD criteria that are proving “inconvenient” to the
recommendation that NIOSH has advanced, and some Board members
clearly are biased to support, to deny SEC-00105, based on

methods it has in hand, because it is currently able to bound

with sufficient accuracy all internal and external doses from
all sources during the operational period (1953-June 1966), and
do the same for residual uranium (July 1966-1993) during the
residual contamination period.]

[89] McKeel: “There is no good start place SD for GSI” is what I
have asserted repeatedly.... (words of all McKeel comments
missed. Must refer to official TBD-6000 WG 8.28.12 transcript).
[90] Mauro: “Is the metal we are handling Ur milligrams in air
plausible in air? Composition of metal. This is the only

question.” [McKeel arrow to “composition” - “NO, IT IS NOT!”]

= 24 -


Dragon, Karen E. (CDC/NIOSHIEID) d

= — ~
From: DanMcKeel2@aol.com

Sent: Sunday, September 02, 2012 2:42 PM

To: Katz, Ted (CDC/NIOSH/OD); NIOSH Docket Office (CDC); melius@nysliuna.org; Kinman,

Josh (CDC/NIOSH/DCAS); pl.ziemer@comcast.net; Ziemer, Paul (CDC/NIOSH/OD); Allen,
David (CDC/NIOSH/DCAS); Neton, Jim (CDC/NIOSH/DCAS); anigstein@cs.com;
jmauro@scainc.com

Ce: danmckee!2@aol.com;
Subject: McKeel annotated notes 8.28.12 [BD6K WG mig
Attachments: MCKEEL_8.28.12wg_Notes. pdf

Drs. Melius and Ziemer, Members of the TBD-6000 work group and full ABRWH
DCAS: David Allen and Jim Neton

SC8&A: Bob Anigstein and John Mauro

NIOSH Docket 140 Office

Ted Katz, DFO (ABRWH)

Josh Kinman: NIOSH SEC Counselor

cc: GSI petitioners & site expert

September 2, 2012

Attachment: <MCKEEL_8.28.12wg_Notes.pdf> 802K

Dear Members of the TBD-6000 work group and full Board, DCAS and SC&A; NIOSH Docket 140,

| have attached my annotated detailed transcribed notes from the 8/28/12 TBD-6000 work group meeting (pages 1-37).
Pages 20 and 26-30 of the main report, plus Appendix A (pages 38-39) and Appendix B (pages 40-42) address some of
the key documentation Mr. Ramspott and | promised to furnish on August 28th. This documentation should supplement
and complement the official court reporter transcript of this important GSI meeting

Ted Katz: Please distribute to all Board members including the TBD-6000 work group and staff.

NIOSH Docket 140 office: Please consider this document for posting on the DCAS website.

Thank you -- Dan McKeel 9/2/12 Sunday

Daniel W. McKeel, Jr., MD

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

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


McKeel_Notes_8.28.12wg.doc

McKeel Comments (ver2): 8/28/12 TBD-6000 Work Group

1. SC&A surrogate data findings:
a) [agree with SC&A the TBD-6000 slug facility does not meet Board SD

criteria and have been saying so on the record since 2008.

b) The scope of the SC&A tasking was too limited -- GSI uses lots of models
based on surrogate (not real measured) data. MCNPX Betatron models were developed
by SC&A as a research project that John Mauro hoped would be applied at many sites.
There were not then, and are not now, any real data sets of measured photon and neutron
doses for 24 to 25 Mev Allis-Chalmers vintage 1952 Betatrons and Betatron facilities
built to Allis-Chalmers specifications. I argue that the GSI betatron facilities were unique,
not strictly duplicated anywhere else, There is no comparison in the shielding afforded,
for example, by the 70 ton steel plated controi room door filled with steel pellets that
Allis-Chalmers donated to the Milwaukee School of Engineering, and the two inch
standard metal room doors of the GSI Old and New Betatron control rooms that offered

little protection to operators inside the control rooms.

2. Allen response to SC&A surrogate data findings:

a) David Allen agrees the slug facility uranium operations were not rigorously
justified for comparability to GSI under Appendix BB Rev 0. However, Allen argues,
that was acceptable because Appendix BB was issued before the Board SD criteria were
ratified.

I believe this analysis misses the point. The NIOSH uranium intake model for
1953-1993 is getting its final assessment now, in August 2012, a belated three years after
the Board SD criteria were finalized for application in situations just like this one. So the
Allen DCAS argument does not pass muster in my opinion,

b) Without reviewing all my reasons here, my white paper goes into detail on

each DCAS rebuttal to SC&A’s findings that DCAS failed to meet Board SD criteria.

3. SC&A new alternate uranium intake mode] for GSI:

a) Petitioner’s view: not SC&A’s role to develop de novo models. That is
DCAS’s job.

Page 11 / 10b



McKeel_Notes_8.28.12wg.doc

“Plausibility”
[36] Poston: “We have been recalibrated by Wanda. Arguing about

insignificant things. We know where it goes.”(emphases added)

"Values vary hugely -- pick blindly - experience plays a role.”

(37) McKeel note to self: “BUT YOU HAVE NO EXPERIMENTAL DATA”

McKeel Page 8 ABRWH TBD6K 8.28.12

{38] Beach: “We have to go through the surrogate data for the

Board. That's why we are here.”

[-- Break for 15 minutes, hear McKeel

afterwards: 10:25 to 10:40 a.m. -- ]

{39] McKeel written talk is three pages to be inserted here. The
oral version will have to await the official transcript as
McKeel deviated some from the written remarks to accommodate new
information from today’s meeting.

McKeel remarks on 8.28.12 to the TBD-6000 work group

are on following pages 11/10b, 12/10c and 13/10d ...

A_few of the added points McKeel made orally were:

1. Uncertainty analysis is a formal statistical method. It
requires detailed analysis of the uncertainty components.

2. I was shocked to hear that uranium doses and discussions
thereof were “insignificant. trivial, not important, that they
“assumed there was some hazard” and discussions were “difficult”
and the work group was “dealing with minutiae.”

3. On page 2, item 4a, I inserted vacuum Ur data had been
back extrapolated from 1993.

4. David Allen’s newest candidate surrogates are NOT good
ones: 2 are other slug facilities, 1 billet facility, 1 rolling
mill.

- 10 -


McKeel_Notes_8.28.12wg.doc

[93] Ramspott: “No, they didn’t give pounds. Chambersburg, do

any (of the new NIOSH SD sites) tell pounds of uranium?”

“Looking at it (paper) now -- with WG and Board -- “symposium
NDT in Nuclear Energy” -- use high energy x-rays to define
crust.”

McKeel Page 14 ABRWH TBD6K 8.28.12

[94] Mauro: “Don’t get lost in the woods. How many days handling
ingots, dingots, billets -- there is airborne dust. Some metal

had scale, some not. Surface could be influential (emphases

added) -- sparking -- is Thurber on line, derby or ingot surface

differ. Worthy of consideration.” (emphases added)

[95] Thurber: “I am on. One or two comments. Worker surveys bomb

reduction done. Chipper cleaned up surface. Some chipping to

remove easily removable material. (emphases added) What is?”

[Aside note (McKeel?) “But: slag = scale = crust / (Mauro?) slug
not good start. dolomite crust. Yes uncertainty. Once we come up
with. Reasonable.” “What was left was very adherent. Wouldn’t be
removed during handling. Fails to recognize vertical lathes
if...” “does it speak to specifics?” (NOTE: refer to figures on
pages 27 through 30)]

[96] Ramspott: “Post-Dispatch 1959, a chipper at Weldon Spring
operating turret lathe. NDT (symposium book) names MCW. Taking
off flake Mag Fluoride; exhausts at Weldon Spring. Three
articles (McKeel filled in from memory, not in my hand notes, a
paraphrase of what Ramspott conveyed) show WS and other sites
removed crust based on Betatron NDT inspection. [Pages 27-30]
[97] Mauro: “Let’s make believe there were chippers at GSI. NO -

- we will find bounding surrogate (emphases added: McKeel

clarifying editorial comment: Mauro/SCé&A are determined to admit

that, at this time 8/28/12, when the agenda states the WG is to

-31-


McKeel_Notes_8.28.12wg.doc

The initial concept of the dingot process was to eliminate the vacuum
casting by collecting the metal from a bomb reduction in a properly
shaped cavity to permit direct rolling of the scalped regulus. The hot
magnesium fluoride slag produced in the reaction would keep the
upper portion of the metal molten longer than the bottom, and thus
provide for diréctional. solidification of the metal. Chemical analysis

and dingots confirmed the expectation

was sound metal of exceptional purity.
however, in attempting to roll the scalped reguli in the existing rolling
mill because of their short length. Reguli of greater length would
result in greater scalping losses, The best solution to this problem
seemed to be the adoption of o primary hot forming step prior to final
fabrication by rolling or extrusion. This would provide an additional
advantage in that it would permit the design of bomb shapes producing
optimum metal yields.

® This is the passage from the MCW Weldon Spring “Newest United
States Uranium Processing Plant” brochure that confirms the use
of Betatron NDT to define the Mg-Fl uranium interface using
dingots. The reference quoted on pages 27 and 28 referred to
uranium ingots.”

® The passage also indicates that neither the process nor the
use of the formed uranium, the rolling operation, were “simple”
and “all the details well known” as has been claimed by members
of this work group. The facts on these pages 26 through 30
appear not to have been known well enough as this transcript and

the official transcript will clearly demonstrate.

® This material should have been addressed in TBD-6000 Rev 1
released in 2011. We suggested including it, but this suggestion
was not acted upon by the TBD-6000/6001 and Appendix BB or the
subsequently formed TBD-6000 work groups.

- 30 -


McKeel_Notes_8.28.12wg.doc

(emphases added). Compare strengths -- start with real 1990's
data. I hope that is helpful.”

[18] PLZ [Ziemer]: “Let's hear alternate model.” (McKeel to
self: but Allen speaks instead) (emphases added)

[19a] Allen: “Not much data... I worked at uranium foundry 18
years. Pointed out not many air samples. TBD-6000 also used
airborne ‘evolutions’ one was handling uranium ingot metal in
Harris-Kingsley.” [19b] McKeel: Note to self: No mention of
PUTZIER effect thus far)

[20] PLZ [Ziemer]: “most of other data is handling plus. All
involve handling.”

[21] Allen: “Number of places, have issues -- 3 sites found some
(surrogate data), not a great deal. Most pertinent (McKeel: site
not named) 3 samples, hoist to billet [Leblond?]. Others had
issues” -- DID NOT MENTION (that Simonds Saw was steel rolling
mill operation) -- “Does show uncertainty -- Need real data (to

make) surrogate data OK.”

McKeel Page 5 ABRWH TBD6K 8.28.12

[22] Mauro: “Process start with slug. There are, data out
there.” *--(DWM -- Which ones?) “Are there any that fall into

place? If you can’t come to that place, SD falls apart. Have a

pretty nice set; pretty close to GSI.” (emphases added)

(23) McKeel note to self: “NO -- 3 sites = 2 slug, 1 billet”
[24] Anigstein: “Chambersburg data -- what they (are) handling

is 1/2 inch by 3/4 inch slugs, 75 lbs over one day.” (emphases

added) “Smallest at GSI hundreds of pounds, ingots even higher.”
[25] PLZ [Ziemer]: “Geometric mean would get more plausible
value. Is that right, Dave? Handling, everyone agrees, is at the
lowest end of all this. Could say bounding, but they have

plausibility. Is that plausible, Bob or John? Know something is


McKeel_Notes_8.28.12wg.doc

(67) [Footnote inserted for clarification: Dr. Anigstein several

times mistakenly referred to ORNL as “ORISE,” which is a
different organization sited at the huge Oak Ridge National
Laboratory campus in Tennessee. The FUSRAP report cover pages on
the GSI OBB and NBB cleanups clearly state “ORNL” was the
contractor.

Also, Dr. Anigstein made a statement declaring that “ORISE”
(sic) was the most competent organization in the U.S. to perform
uranium radiologic surveys and cleanups. The fact is, that in
1997 Congress judged DOE, that hired (contracted with) ORNL as
primary FUSRAP cleanup agency at GSI, was so incompetent in
conducting cleanup operations, it:

(a) Transferred FUSRAP cleanup responsibilities from U.S.
Dept. of Energy (“DOE”) to the U.S. Army Corps of Engineers;

(b) DOE was relegated to a legacy record-keeping role
within FUSRAP; and

(c) Eliminated part D of EEOICPA on which DOE was lead
agency, and substituted Part E with US Dept. of Labor (“DOL”) as
lead agency.

All three situations—(a), (b), (c)—prevail today.]

[68] Ramspott: Also challenged the “if scoured” Mauro statement
and reiterated the Old Betatron cleanup did occur in 1984 and

this was not the first time this fact had been brought to the

attention by the petitioners to the work group, Board, SC&A and
NIOSH. McKeel had done so in a 6/13/12 paper commenting on a
6/08/12 DCAS-Allen memo, prepared for the 6/14/12 TBD-6000 work

group meeting. This paper was circulated to all participants at

the 8/28/12 WG meeting on 8/30/12 by Ted Katz. (see Appendix B).

John Ramspott offered to contact - 7 during the lunch
break to have call in to the work group and give his OBB
power washing testimony in person. Dr. Ziemer declined to accept

this proposal.

- 21 -


APPENDIX A

The following 2009 e-mail was supplied to Dan McKeel by
on 8.31.12. It documents an interview by deceased

GSI Betatron operator . and a former GSI
radiography division supervisor, - The subject
matter is the crucial issue, referable to GSI SEC-00105, of
exactly what radiographic nondestructive testing (“NDT”)
examinations and inspections were performed on MCW-Destrehan
Street and Weldon Spring Uranium Division uranium metal products
(ingots, one-step dingots, billets and slices) under AEC
contract 1953 through June 1966 at General Steel Industries,
Inc. (“GSI”), located at 1417 State Street in Granite City, IL.

NIOSH and SC&A have not discovered any technical reports
from the two MCW sites, or from GSI records, that give details
of precisely what was done with the uranium sent to GSI under
MCW purchase orders 1958 through 1966. So this corroborative
testimony is particularly pertinent and seminal information.

Mr. indicates that some of the MCW uranium
ingots he observed were transported to GSI from MCW in flat bed
trucks. The truck loading dock at GSI was a long path away from
the two Betatron buildings where NDT radiography was done.

This testimony corroborates the napkin drawing and GSI
rvadiographer Ed Brawley’s testimony to SEC-00105 co-petitioner
Dan McKeel in 2006 (see napkin drawing of Betatron 4-corner
uranium “shots” diagram on page 26 of the main body of this

report).
3 DAS WAR D
Pamek bo Meee.
- Daniel W. McKeel, Jr., September 1, 2012

Testimony from GSI Betatron Supervisor _—
to GSI Betatron operator, in 2009

Page 1/38



Appendix A, page 2

Subj: Fwd: Ingots

Date: Friday, August 31, 2012 11:16:51 PM
From: .

To: danmckeel2@aol.com

Begin forwarded message:

From: ©
Date: March 29, 2009 12:39:21 PM CDT
To: < ——

Subject: Ingots

(McKeel note: verbatim, spelling errors not corrected)
‘ - | discussed "Ingot" shooting with ne evening of

3/28/09 and the morning of 3/29/09. _ stated "I observed Ingots leaving the

old betatron on the early morning weekend shifts. They were leaving on a flat
bed truck and standing in a vertical position the same as they had been shot”.
referred to the ingots as Mellinckrodt Ingots. v. was a Betatron
Supervisor and Film reader stated that the Ingots were around 20 inches high
and 18 inches in diameter, were shot in a vertical position, and an upper left,
upper right, Lower left, and lower right shots were fired. also said that after
the upper left and upper right shots were fired, the ingot was turned over by
betatron crane to shoot the two bottom shots to achieve a clear edge on the

film. (Invert the ingot). It is known that at least four "glancing" corner shots were
fired with multiple film to record variable thickness. There is a possibility of four
more shots having been fired to complete the circumference quadrants of the
ingots. (6 & !2 o"clock quadrants and 9 & 3 o'clock quadrants of the ingots)

The shots were to achieve corner penetration of the ingot so as viewable depths
could be checked for scraping or milling. The corner glancing shots were
normally shot with 14 x 17 Metal cassettes sitting on wood blocks in the rear
comers of the ingot with a lead scattershield. The edge of the cassettes would be
placed in a manner so as the curvature of the ingot would flatten out on image of
the edge of the ingot leaving a clear straight black edge on the film”

24 & 25 MEV Betatron & Magnaflux operator
GSI.

Page 2/39


McKeel_Notes_8.28.12wg.doc

Applied Science Dept.

Symposium on

Nondestructive Tests in

Presented in
Chicago, Tll., April 16-18, 1957
2 sponsored by
MERIcAN Insrrrure or Cuxatcat Exoixgers, Yucvear
Excingraing Division

Americas Nucvear Soctery
Amertcan Soctety ron Testino Matextats
Aroute Ixpusteiat Foruw
Soctrty, yor Noworstavetive Testixe

ASTM Special Technical Publication No. 223

Price $10.00; to Members of Participating Societies $7.5¢

Published by the
AMERICAN SOCIETY FOR TESTING MATERIALS
igté Race St., Philadelphia 3, Pa.

- 27 -



McKeel_Notes_8.28.12wg.doc

Dan McKeel’s hand written notes 8.28.12 begin:

McKeel Page 1 ABRWH TBD6K 8.28.12

Ted Katz roll call: Board members (all in room): PLZ present;
Beach present; Poston present; Munn present. No Board members on
phone. DCAS: Neton present; Allen present; Kinman present. SC&A:
Anigstein present; Mauro present on phone; Thurber present on
phone. Federal: Katz present; Kinman present. (transcriber note:
I did not hear Jenny Lin’s name). Public/petitioners (all on
phone): Ramspott present; McKeel present; Jeske present.

[the notes hereafter are verbatim, raw, nothing

has been added or filled in, nothing left out.

McKeel comments to self in parentheses]

[1] Katz: “agenda.”

[2] PLZ [Paul Ziemer, WG chair]: - “Focus is on full Board
issue. WG motion discussions on residual period” -- (McKeel note
to self: no action on SEC-105 was mentioned). “Applies to both
operations and residual periods. Issue of surrogate data (“SD”)
uranium part of DR internal dose. internal dose primary for
residual period.”

“SC&A recommendation, NIOSH and petitioner comments. Seen
Bob’s paper...” (McKeel note: singular, Bob wrote two papers --
no mention of ALT. model paper.) “Bob...”

[3a] Anigstein: setting up (need his PPT [Powerpoint]). “My...”
[3b] PLZ [Ziemer]:. “Speak up.”

[3c] Anigstein: “In all fairness, original Appendix BB 2007 --
SD from TBD-6000 5 sites.”

“In all fairness, Board set up SD criteria few years later.”
“Criterion 1: 1993 (date was) very detailed” - (MCKEEL NOTE:
“NO” -- was very limited). “One set of data was used. One

scenario not appropriate.”


McKeel_Notes_8.28.12wg.doc

{End of McKeel oral remarks]
McKeel Page 8b ABRWH TBD6K 8.28.12

[40] Pat Jeske [GSI SEC petitioner Patricia (Coggins) Jeske]:
“New information from my uncle ++. used gas masks,
not sure about Affiliated Metals being there.”

[41] John Ramspott: “From various sources. One gentleman auto
dealer worked (at GSI) 1978-81. He personally did it, with son
of last man who worked at GSI last. Dow worker at Granite City,
while doing rewiring. Three people, all prior to FUSRAP cleanup.
Dr. Ziemer and Neton can’t separate operational and residual
periods. We don’t know when vacuum was put in there. Was not in
auction... vacuum cleaner.”

[42] PLZ [Ziemer]: “Will listen to SC&A.”

“Neither, Ted nor I tasked SC&A to come up with an alternate

model. Not tasked to develop this model. Some think we did.”

(emphases added)
(43) (MCKEEL NOTE pg. 8b: “I have in writing from Ted he (Dr.
Zeimer) did task SC&A”. Furthermore, I have the complete e-mail
correspondence with my initial questions and Ted Katz responses
where Ted clearly implicated about he and Dr. Zeimer (a)
discussed the surrogate data paper and alternate model work with
Dr. Anigstein before the 7/16/12 SD paper was submitted to the
Board by SC&A, and (b) Ted clearly stated that Dr. Ziemer
allowed this second alternate SC&A model paper to go forward. I
shared this e-mail correspondence with all Board members. Dr.
Ziemer is thus disagreeing in public, on the record on 8/28/12,
with what Ted Katz wrote to me was the true situation with
respect to tasking the SC&A 7/25/12 alternate Ur-238 intake
model paper for GSI.

The opening section of the alternate model paper indicates

it was sanctioned by Dr. Zeimer. Related to this transcript, it

- 14 -


McKeel_Notes_8.28.12wg.doc

“Deposition rate 1200 Beq/meter/day.”
Removal rate - 1 datum | had to be added up
43.6 average activity | to a single number
“These are plausible upper bounds -~ reasonable. <1 mg/cu mm for

uranium dust.”

( McKeel Notes to Self )
(1) OBB was power washed 1984 - berm placed + fans + furnaces
(2) Data in 1993 is not related in a simple way to 1953.
(3) Anigstein et al. paper says they were tasked by Dr.
Ziemer to do ALT. model. [Musing to self: Do I say this now
or later LATER to full Board; see how work group votes?]
(4) The SEC recommendation has to be based on what NIOSH can
bound with sufficient accuracy; what SC&A can do is

immaterial.

[Note] Ted Katz says regs do NOT say who has to determine dose
with sufficient accuracy. McKeel countered Katz had made a

“preposterous statement”. Everyone knows that is NIOSH’s role.

McKeel Page 9 ABRWH TBD6K 8.28.12

[48] Ramspott: ” was there 1984 cleaned up the Old
Betatron Building and the New Betatron Building. Red and blue
dots, see berm, not there is “GSI days.” Stored leaky oil and
transformers. Berm 18 inch wall, 25% shooting wall. Red dots in
corner. So localized. Berm area is where they worked -- kinda
unusual.”

“Red dots in between control room and vault,”

“No dots in control room.”

“Was ‘cleaned’ ~- [DWM note to self in hand notes: “JWR was

power washed/blast -- did NOT use the word ‘water.’]

- 16 -


McKeel_Notes_8.28.12wg.doc

7.

(Agenda as circulated by Josh Kinman
prior to editing of the public version)

ABRWH
Work Group on TBD-6000
9:00 a.m. EDT

Cincinnati Airport Marriott
2395 Progress Dr.
Hebron, KY 41048

859-586-0166

Conference phone: 1-866-659-0537
Participant Code: 9933701#

AGENDA
Welcome and roll call.

SC&A surrogate data review for the General Steel Industries
SEC petition 00105 and DCAS responses; related SC&A
recommendation for the use of GSI data and DCAS responses.
(Bob Anigstein/John Mauro; Dave Allen/Jim Neton --
response)

GSI petitioner comments and responses (Patricia Jeske/Dan
McKeel; Dave Allen/Bob Anigstein -- responses to any
technical matters).

Work Group discussion and recommendations on the use of
surrogate data and/or alternative approaches. Complete SEC
recommendations.

Status of remaining TBD issues (Dave Allen) and discussion
of open issues as time permits.

Overview of plans for the full Board presentations on
September 19, 2012. (Paul Ziemer)

Adjourn (3:00 p.m.)

[McKeel added notes: A 15 minute break was taken between agenda
items 2. and 3., and there was a 1 hour lunch break between
items 3. and 4.]


McKeel_Notes_8.28.12wg.doc

- “Issue 8 closed, transfer to App-BB”
~ “Issue 9 equals issue 6; closed”
[140] Katz: “And I will distribute that chart.”
(141] Ziemer: (June 1, 2012 update)
Meeting adjourned 3:08 PM ET 8/28/12 Tuesday

--end of transcript hand notes--
(142) McKeel final editorial comment:

1. I doubt that any WG or SC&A or DCAS person could
follow the preceding matrix update session. It is difficult
to understand why, given that Appendix BB matrix issues
were a scheduled agenda item, SC&A had not been tasked to
update both the SEC and Appendix BB matrices expressly for
this final meeting before the TBD-6000 work group voted on
a recommendation on GSI SEC-00105 to the full Board.

2. Dr. Ziemer’s final motion to the full Board was not
clearly delineated, and there was no final vote to show
that, in fact, all four Board/work group members present
agreed with the motion. Dr. Ziemer’s motion was also not
formally seconded. In other words, the chair made up a
motion, bypassed getting a second, and did not restate the
exact wording of the motion to be presented to the full
Board on September 19, 2012.

3. Let it be recorded that a vote of the full four member
TBD-6000 work group (Ziemer, Beach, Munn, Poston) on an SEC
for GSI for the covered and residual periods was not taken
at the August 28, 2012, TBD-6000 work group meeting. Member
Beach asked “for a vote on an SEC for the early period -
Motion now” but this motion was not recognized nor acted
upon by the chair, Dr. Paul Ziemer. Dr. Ziemer offered no
explanation why such a vote on the WG recommendation for
SEC-00105 was not taken 8/28/12, even though such was an
agenda item.

Respectfully submitted:

Pawel OMe eel he

Daniel W. McKeel, Jr. September 1, 2012
P.O. Box 15, Van Buren, MO 63965

Phone: 573-323-8897 ° Fax: 573-323-0043
E-mail: danmckeel2@aol.com

-~ 37 -


Ot

McKeel_Notes_8.28.12wg.doc

“Ingots and dingots have varying thickness Mg Fluoride “bomb”

crust. with different -- simple as you can have.” (emphases

added)” “NIOSH picked a poor surrogate datum. Have found one.

| Simplest of things.” (emphases added)
[9la] McKeel: “Dingots and ingots -- too few -- some

isotopes”... (most of this comment not recorded, see official
transcript)”
[92] Anigstein:

(1) “As fission products “miniscule” below unity -- far
lower, not an issue -- for DR. All latest physics paper. Don’t
need to refer to 1945 paper.”

(2) “Slag Mg Fl -- cleaned off as soon as made. Slices

imperfections.” (emphases added: McKeel note: No, not correct,
some (outer easily removed part) is removed by chippers right

away; significant amount of Mg-Fl remains all over the dingot].

e “How much end sawed off -~ end shots -- 1 worker corner

shots. Vertical lathing don’t need it (Betatron NDT

radiography) .

e “No first hand information.” (emphases added)

(93) McKeel:

(1) See McKeel napkin drawing of Betatron uranium corner
shots made at GSI, page 26; (2) GSI radiography supervisor

also confirmed there were four “corner shots”

performed on MCW uranium dingots. (See interview APPENDIX A);
(3) On pages 27 through 30 are two of the references that John
Ramspott mentioned that prove that at Mallinckrodt Uranium
Division, which contracted with AEC and GSI for the Ur NDT

radiography work 1953-June 1966, the main purpose was to define

the crust/underlying pure uranium metal interface, just as

McKeel and Ramspott have claimed, on multiple occasions, and
provided this same proof, only to be ignored and not taken

seriously as was very evident at this meeting. Bill Thurber and

- 25 -


McKeel_Notes_8.28.12wg.doc

Dan McKeel’s Personal Notes on the
August 28, 2012, Meeting of the
TBD-6000 Work Group of the ABRWH

September 1, 2012

by

Daniel W. McKeel, Jr.
GSI SEC-00105 Co-Petitioner

[Transcriber’s note: I am preparing this personal transcript
because the next full ABRWH (“Board”) meeting, when a final vote
is scheduled for the General Steel Industries (“GSI”) SEC-00105,
is scheduled for September 19, 2012. I have asked Ted Katz that
an official work group meeting transcript be delivered to the
petitioner’s and to GSI site expert Mr. prior to
the full ABRWH meeting in Denver. However, based on past

experience, I cannot depend on that happening. ]

DISCLAIMER: Transcriber makes no warranty of total accuracy of the
following transcribed, contemporaneous and handwritten notes he made
during the August 28, 2012, meeting of the TBD-6000 work group.
Passages set off by quotation marks refer to verbatim text of spoken
words in the notes. Portions of notes that are not in quotes are “as
is” transcriptions of the handwritten notes. Passages where the
identity of the speaker was unclear and/or words were known to be
missing are so indicated. Transcriber Dan McKeel was also a meeting
participant. His comments not on the record (not made orally) are
noted as “comments to self” or “editorial comments” and are set off by
parentheses. No attempt was made to capture all of the transcriber’s
oral exchanges with the work group. Those McKeel remarks will be
captured in the official court reporter transcript that has been

requested from DFO Ted Katz.


McKeel_Notes_8.28.12wg.doc

[107] Ziemer: “What does that mean? Can’t do it before ABRWH
meets.”

[108] Poston: “Do you want a motion (laughing during this
question)?” (McKeel: there was no response from Dr. Ziemer)
[109] Allen: “White paper justified 198 best; Anigstein thinks
work group shot both of these down.”

[110] Mauro: “Can’t use the model.”

[111] Anigstein: “Few days heard about the cleanup of Old

Betatron Building. Radical abrupt change needs to be looked

into. (emphases added) Five years...” (continued on page 34)

(112) McKeel: clarifying editorial note that must be made.

[McKeel referred to the Old Betatron Building power washing in
his June 13, 2012, paper on David Allen’s 6/08/12 memo. He has
furnished this reference previously on 8/30/12 (see APPENDIX B).

Dr. Anigstein thus was forewarned twice by the petitioners
about this matter he today claims is “radical” and “abrupt”.
Nothing could be farther from the truth. This exchange proves
something I have contended for a long time, that some members of
this TBD-6000 work group have repeatedly ignored, or not read,
my technical papers and written and oral comments. The present
transcripted notes is proof of that contention.

Also, with respect to Dr. Anigstein’s considerable research
effort on GSI matters over the last 5 years, and
Dan McKeel have been doing GSI related research longer (since
2005), interviewed more workers more times in more depth and
have contributed far more material than has SC&A and Dr.
Anigstein, to tell the full GSI story. Witness the alert in 2006
by Dan McKeel to David Allen at a NIOSH public meeting that
Landauer possessed GSI film badges. Dan McKeel also submitted a
FOIA request that produced 1,016 pages of unredacted NRC
FOIA2010-0012 GSI by-product material license information

furnished to everyone first by Dan McKeel. This material

- 33 -


PAGE 21 (KEY MCKEEL OBB POWER WASHING 70's COMMENT, lines
12->14)

1

So the idea that, somehow, the 2 dust content in a small
industrial vacuum 23 3 years after the plant closed is, in
any way, 4 indicative of the residual contamination in 5
that plant is really, scientifically speaking, 6
ridiculous, absurd, and really unacceptable. 7

The proper way to look at things 8 is, there is really no
representative residual 9 period real data; air monitoring,
surface 10 concentrations. You know, we do know from 11
worker testimony that that building, the old 12 betatron
building for instance 13, had been power washed in the
intervening years back in 14 the '70s, and that small
vacuum was used 15 repeatedly, we are told, you know, every
day 16 it was emptied and so forth. 17 So all that
represents is the 18 residual uranium dust in that vacuum
when it 19 was probably last used. Nobody even knows 20
when it was last used. And the other point

PAGE 22

1 was really used to clean the floor in the old 2 betatron
building was much larger, and that 3 one, there's no
measurement of that. 4 So I think those points need to be 5
put on the record. Thank you. 6

CHAIRMAN ZIEMER: Okay. Thanks, 7 Dan. One connection, Dave,
could you clarify 8 the application of the activity that
you're 9 proposing. Who would this apply to, the air 10
concentrations that you're proposing? 11

MR. ALLEN: Air concentrations and 12 the external would
apply to everybody at GSI...[MORE FOLLOWS]

ly You know, we doa imow from
1q that that building, the old
14 betatron building for instance, had been
14 power-washed in the intervening years back in
1q the '70s, and that small vacuum was used
ig repeatedly, we are told, you know, every day
14 it was emptied and so forth.

--(end of relevant McKeel transcript excerpt page 21)--

Page 3/42



Mckeel_Notes_8.28.12wg.doc

Fuel Tests:

Uranium, like most metals, shrinks on
solidifying and blowholes and pipes are
formed in the ingots. The amount of
metal to be removed by cropping in order
to produce sound material for rolling js
determined by the use of high-energy
X-rays. This test has supplemented other
work mn aiding the development of im-
proved casting techniques. Uranium al-
loys may be cast in rounds or flats so that
very little if any machining is required
for use, Such bars may be tested by ul-
trasonic techniques for soundness.

Please note the underlined passage: “The amount of metal to be
removed by cropping in order to produce sound material for

rolling is determined by the use of high energy X-rays."

The petitioners "and McKeel, and site expert

again assert that a main purpose of the MCW Uranium Division in

its AEC contract with GSI 1953-1966, was to identify for later

machine removal, the interface between the outer Mg-Fl “crust”

and the underlying pure uranium. The TBD6K WG and NIOSH have

previously determined that thorium-234 accumulated in the outer
layers of uranium dingots and ingots -- the so-called “Putzier
effect”. At GSI, this known dose has been ignored repeatedly.

We also assert, until challenged and proven wrong: (a) that

MCW Uranium Division was the only US plant that furnished

uranium dingots to DOE nuclear weapons sites, including Hanford,

and (b) that GSI thus will not have a suitable surrogate site.

- 28 -


McKeel_Notes_8.28.12wg.doc

b) Model is supposed to be based entirely on GSI data but it is not.

c) Model relies on differential equations: some constants are defined with respect
to their source; other equation constants are not sourced. My paper pointed out these
missing source citations.

d) In the last sentence, SC&A clearly indicates it is offering their model for
DCAS to use in the dose reconstruction program. This is clearly NOT “evaluation.”
SC&A is performing NIOSH’s job in designing this new intake model.

e) My comment paper offers several additional specific concerns. In particular, in
order to be able to bound uranium intakes with sufficient accuracy, NIOSH needs urine
bioassay and breathing zone or sequential area air monitoring data which they do not

have,

Allen response to SC&A’s alternate uranium intake model for GSI:

a) Allen dismisses the SC&A model in one sentence saying you cannot back
extrapolate data 40 years from 1993. While I agree wholeheartedly, Mr. Allen in saying
this also invalidates NIOSH’s own June 2007 Appendix BB uranium intake mode] that
relies partly on the uranium activity associated with the small industrial vacuum sweeper
(ORNL 1993).

The new information in [5] on the residual period years 1978 to 1993 provides
compelling evidence that bounding the airborne uranium at GS/ with sufficient accuracy
for SEC-00105 class members would be difficult or impossible.

b) Allen says the new SC&A model has way more uncertainty than the surrogate
data NIOSH uses from the slug factory. He ignores SC&A’s finding that use of the slug
facility data has failed the five Board SD criteria. He employs an absurd argument: if one
has no or insufficient real intake data, then one can use inappropriate surrogate data that
violates Board SD criteria to bound uranium intakes (reductio ad absurdum argument).

c) Allen does not mention application of the NIOSH SD criteria in OCAS-IG-004
to the slug facility. Nor does he compare the NIOSH OCAS-1G-004 and Board surrogate

data criteria with respect to GSI uranium intake data modeling.

page 12/10c



McKeel_Notes_8.28.12wg.doc

is also noteworthy the sole author of the 7/16/12 SC&A surrogate
data paper was Dr. Anigstein. Dr. Anigstein and John Mauro and a
third person co-authored the SC&A alternate model paper. Dr.
Mauro repeatedly refers to “Bob's work” and “Bob’s approach”
when he, himself, was a co-author of the alternate model. The
latter fact was not mentioned anytime during the entire TBD-6000
8/28/12 work group meeting)

[44] Anigstein: “Overlooked TIB-70 removal rate and resuspension

rate. No drastic changes in Old Betatron Building remained.”

(emphases added) If there was cleanup -- (pause) -- we have
found something internally consistent. Can’t find slide...
cartoon house -- something infiltrates through the walls.
Airborne material generated. Arrows going up and down. Here's
what comes in (by P.O.= purchase orders) extrapolated 1953-Feb.
1958 “conservative” use highest.”

(45) McKeel: RE: [44] emphasis added passage; I have this
statement boxed for emphasis on my hand notes. McKeel had just
presented new eye witness evidence that the Old Betatron
Building underwent power water “blasting” in 1984 that was
forceful enough to strip white lead paint from the concrete
walls before ORNL and DOE did the 1993 cleanup. My margin note:
“DWM - This ignores 1984 power washing I just put on the

record.”

Page 8 McKeel Notes continues...

[46] Beach: “June 1993 is when measurements were made.”
[47] Anigstein: “Good number source 1 daily. Uranium handling =

Rate / Velocity... Bottom line: to show it can be used for DR.”

(emphasis added) “Take geometric mean: factor of 2 not bad,
right ball park.” Arrow drawn to geometric mean <--[next

verification]. “Very little resuspendable material left.”

- 15 -