Attachment B

Ted Katz Summary GSI
5/28/13 Technical Call

DCAS, SC&A
Discussed at
6-20-13 TBD-6000
Work Group Meeting


DM-Notes_6.20.13tbd6Kwg.doc
ZIEMER: (no response captured in McKeel notes)
ALLEN: “That’s the intent.”

NETON: “I’ve examined the complete data set -- very few - everyone
else radiographers.” Other job categories “ambiguous.”

ANIGSTEIN: The NIOSH number is close to the 500 mRem/yr OK limit.
[McKeel comment: Again, this is an inappropriate NIOSH endorsement. If
the fact is true, then NIOSH (Allen or Neton) should have made it].

MAURO: Made same math error, which he at first denied then admitted,
saying “son of gun, did it again.” Correct dose = 487.5 (mRem/yr).
Start for both - we agree | error | 10 fold error. I want to correct
it right now, don’t like erroneous SC&A reports being out there.
[MCKEEL COMMENT: Contrast this with Dave Allen and DCAS/NIOSH who said
he would correct the TBD-6000 Rev 1 calculation error “in the next
revision” (that was perhaps years away) ]

--The discussion then turned to the Allen paper #2 about the square
function approximation...

(MCKEEL COMMENT ON THE FOLLOWING SECTION. The entire discussion of
this most important paper seemed truncated, off target to what was
actually in the Allen June 4 paper delivered 7 days after the 5/28/13
technical call. The WG discussion was very difficult to capture
accurately. No one acknowledged reading Dan McKeel’s very critical
Paper. McKeel doubts the 5/28 meeting discussion by Katz was complete)

ALLEN: out of airborne; 95th percentile. [Tech call summarized at the
end -- agreed white paper with math]

Instant
Attach A - Math.
Rest points out what that means in showing accurate (when integrated)
over infinity [MCKEEL: Very brief, jumbled and unclear presentation]

ZIEMER: Sufficient. Is estimate realistic? (no response asked or
given) [MCKEEL COMMENT: Was this just a rhetorical comment for the
record? If the question were serious, then Dr. Ziemer should have
followed up with DCAS and SC&A for a response. Since he did not do
this, I believe his question was merely posturing for the record)

BEACH: No question; surrogate data not addressed;
McKeel: SC&A Square function: SC&A response memo 6/11/13 not PA

cleared, not sent to Dan McKeel until 6/20/13 after the GSI
presentation.


DM-Notes 6.20. 13tbdéKwg.doc

paper) (2) SC&A stated Allen’s Ist SD dataset failed 4 of 5 Board SD
criteria; second look SC&A “magically” stated now passed all 5 SD
criteria. I stated McKeel strongly disagreed with SC&A‘s reversal,
that Allen used Weldon Spring and Fernald as SD sites, two large DOE
uranium feed materials plants that were very dissimilar to GSI in
operations, source mix, etc., to an extent the DOE facilities could
NOT be stringently justified as being similar to GSI].

MAURO: Search on surrogate data find facilities analogy uranium
handling, do not recall Appendix with paragraph...

MCKEEL NOTES PAGE 8 OF 8

BEACH: Dan McKeel give feedback / June 6 Adley, June 19...

MCKEEL: Added comments that Munn Procedures Review subcommittee (PRS)

reported on TIB-70 at 3/12/13 Augusta meeting and cited higher RF than
10° m’ to be more claimant favorable; Mauro did not acknowledge. Also
commented that RESRAD-BUILD and DandD codes could not accurately model
GSI cyclical uranium resuspension cycles. McKeel also stated that SC&A
had not reviewed use of Adley 1952 data as surrogate data for GSI.

MAURO: Relevant deposition velocity OTIB-70 | dust falls > residual
data. Has Adley been shown to be...

ANIGSTEIN: Adley not used in TIB-70 Rev 1, was used in TBD-6000 Rev 1.
SC&A first brought up Adley. [MCKEEL: Anigstein is correct on this
point, McKeel misspoke and confused OTIB-0070 for TBD-6000 Rev 1)

ZIEMER: “I see no deliverables on this.” [MCKEEL: This was Dr.
Ziemer's final decision on the use of Adley. I, of course, strongly
disagreed with him and regard this as another example of personal
animus by the TBD-6000 work group against both the GSI SEC co-
petitioner and the chief GSI site expert. Very disappointing. |

BEACH: “I just wanted to make clear that SD use at GSI was covered --
I'm good”

McKeel notes that Dr. Ziemer did not bother to ask either John Poston
or Wanda Munn whether they were still on the line, and whether they
had any concluding questions or comments regarding GSI. Both WG
members had uttered only a single sentence of commentary.

-- end of GSI discussion --

ZIEMER: (about 2:22 PM ET) Now move on to Baker Brothers -- 4/26/13
SEC not approved for residual period.

McKeel logged out at this point (end of transcript GSI portion)



DM-Notes_6.20.13tbd6Kwg.doc

ZIEMER: NIOSH formalize this. ...break? [No responses heard]

MCKEEL NOTES PAGE 5 OF 8

ZIEMER: Aside Re: earlier McKeel remarks (see ATTACHMENT A):

Item 1: 4/26/13 work group transcript section on this method is
on pages 138-158; “term Square Function not used.

Item 2: (McKeel) “quite correct - don’t see three pager” (refers
to SC&A 6/11/13 memo on 6/4/13 square wave Allen/NIOSH-DCAS paper)

MAURO: My notes the 6/11/13 paper is labeled “not PA cleared, in his
file, hasn’t been PA cleared.”

ANIGSTEIN: “Administrative glitch. Production manager sends out. “slip
through cracks” - today or tomorrow. [MCKEEL COMMENT: But that will be
too late: (a) for McKeel to incorporate in his already submitted white
paper on the square function approximation; (b) for McKeel to have
read and understand prior to this discussion taking place. Everyone
was well aware of McKeel being mightily upset he was denied access to
the 5/28/13 technical call by DFO Ted Katz, when the TBD-6000 WG chair
had stated to McKeel that he, Dr. Paul Ziemer, had no personal
objections to McKeel sitting in -- DFO overrules current WG chair and
former ABRWH Chairman prior to Jim Melius taking over the job.]

KATZ: Clear everything, Nancy, day or before issues what partly
responsible for posting to SEC petitioner - Josh Kinman. Posting
requires 508 policy. PA cleared everything goes through OGC. Extra
step...

RAMSPOTT: Comment RE: Tl... 1965 P.O. item C: “Betatron ‘labor
charges’ operations, maintenance, overhead (heat, lights, cooling).
All handling has not been accounted. Missing a very big piece of
labor.

1) Terminal railroad

2) Transfer to GSI RR car
Another time issue: 3 people handled uranium at GSI. All three started
work after radium era: (McKeel: which was 1952-63)

° started |
e started |==> Don’t know about uranium handling
° started | (McKeel: during the radium era)

ANIGSTEIN: Does not matter about uranium during the radium era. Doses
are determined by film badges. Talking about “uranium dust.” 3250 hrs

has been proposed -- 15 + 60 minutes “gone” [MCKEEL COMMENT: Anigstein
stating the doses are determined by film badges is confusing. What
doses are being referred to? McKeel and were under the

impression that radium era external doses were to be determined by the
“triangular distribution” that SC&A insisted upon with apices being
12-15 / 9 / ~3 REM/year. This is what the whole Board was informed
would be the case by Dave Allen and others at the 12/11/12 meeting
before the final 9 to 8 full ABRWH vote to deny GSI SEC-00105.)


DM-Notes_6.20.13tbd6Kwg.doc

MCKEEL NOTES PAGE 4 OF 8

MAURO: Admin paper: 25% and 30% “fine with it”;

Square function paper: “Anigstein and Marschke checked math” then
referred to “6/11/13 paper think it is to public,” “solution is called
‘elegant’, is correct.” [MCKEEL INSERTED A NOTE AT THIS POINT: “SC&A
6/11/13 paper not on Web or sent to McKeel” - McKeel had downloaded
the TBD-6000 work group 6.20.13 meeting discussion papers the morning
of the meeting and had the printout before him when this NOTE was
inserted - Mauro’s announcement caught McKeel by surprise, which soon
turned to chagrin and annoyance this key paper was not sent to him
prior to the 6/20/13 WG meeting)

MAURO: (continues)

Figure 1 peak (graphic cartoon of Allen paper rising limb (sharp
curvilinear rise with plateau at peak | falling limb steep descent at
first then curving gently to asymptote on x-axis = 0)

“Bequerel seconds per shot x no. shots = integrated time exposure”
“could be more than this” “Tl = 15 minutes”;

“Is the contracted no. (max 400 hrs per year)”

“Some fraction of uranium being handled 15 out of 75 minutes -- does
this capture full handling?”

“time integrated number”

“Exposures between handling must be calculated achieve RF 10°”

MCKEEL COMMENT TO SELF NOTE: Exposure + Handled --> sweep, --> unload
freight car, --> clean uranium from transport [missed Adley 1952
operations that recapitulated uranium handling tasks performed at GSI}

ANIGSTEIN: “Fill in dark years” [McKeel Comment: 1952-1958 when there
are no extant MCW to GSI purchase orders. Another key “hanging chad”
detail not pursued further by the WG on 6/20/13. McKeel assumes they
will OK back extrapolation from later P.O. years without further
justification why this maneuver is scientifically defensible]

ZIEMER: I had a similar question on Tl - Are we accounting for other
handling?

NETON: I thought about it quite a bit -- can’t nail it down as 15

minutes. Use total hrs/yr. Can‘t estimate “dark years.” [McKeel
Comment: But NIOSH has no problem extrapolating FB to those same “dark

years that include 1952-1963 for the Landauer #2084 GSI dataset.)

ANIGSTEIN: “Go to 22-24 average + 68 95th percentile (decrease
[concentration] | increase [hrs] (parameters)”

MAURO: “Tl is a struggle”

ANIGSTEIN: Maximum year 1961 assign to “dark years” like co-worker or
cohort approach.


DM-Notes_6.20.13tbd6Kwg.doc

MCKEEL NOTES PAGE 7 OF 8

phoned McKeel to say * told him just now that GSI
transport RR cars were cleaned with a reversed backhoe bucket used as
a scraper, done outside. | said air hoses were used inside for the

same task. [MCKEEL COMMENT: These maneuvers mirror Adley 1952 where
cleaning the beds of trucks that transported uranium was said to
require “filing, grinding, and chipping.” Such factors need to be
factored into the GSI operational and residual period uranium air
intakes, assuming that during the residual period there was leftover
uranium that still adhered to the GSI owned RR transfer and regular
flat cars used during the operational period to get MCW ingots into,
respectively, the New and Old Betatron shooting rooms at GSI.]

ZIEMER (after lunch break): High MAC, overall facility higher ambient?
{rod handling] and a couple of other operations -- sweep, freight
cars, grind truck beds data at variance with surrogate data.

ALLEN (Re: Adley et al 1952): Interfere... Table 10, page 43 three
page table 1420 micrograms/m (*) note procedure was changed. Page 42
rod handlers: stack, sweep, load table was higher. If you go near Map
page 6... [MCKEEL: a diversion]

ANIGSTEIN: “Data in 8/31/12 SC&A report 3 forklift unloading rods
dpm/cubic meter - ‘extremely high’ -- 3900 (max 70 dpm at GSI). SC&A
objection to NIOSH surrogate data - unlikely due to handling. [MCKEEL:
Fact should have not been ignored then or now at this WG meeting; it
is another ignored “inconvenient truth” this WG glides over easily)

WANDA MUNN (who did not answer roll call, first and only comment):
“I heard most of Dr, McKeel’s comments, sorry”

POSTON: No questions (first and only meeting comment after roll call)
BEACH: No questions

ZIEMER: “Deliverables: (1) TBD-6000 one point from NIOSH (MCKEEL: not
spelled out what the point was); (2) Square function Tl update intake
estimate; (3) NIOSH chart for all eras: radiographers and all others,
all pieces, the simpler the better. (To Allen) OK Table with footnotes
to include Anigstein “couple pieces do not agree.”

ZIEMER: We will go through all this at July Board meeting.

KATZ: Is 15 minute report enough?

BEACH: Should surrogate data, use Adley, be looked at by SC&A?
ANIGSTEIN: (MCKEEL: defensively) “We did that, SC&A Nov. 28, 2012
paper. Look at AWE, no sites “consensus data” [MCKEEL: (1) Actually
not a paper but a meeting Powerpoint with bullets rather than full

text with graphs and references as in a regular white/discussion

a S


jana, Sherri A. (CDC/NIOSH/EID) (CTR)

From: DanMcKeel _

Sent: Sunday, June 23, 2013 3:36 PM

To: NIOSH Docket Office (CDC)

Ce: danmckeel

Subject: Docket 140 (GSI): new McKeel submission
Attachments: DWMnote2_6.20.13_TBD6Kwg.pdf

Dear NIOSH Docket Office,

Attachment: <DWMnote2_6.20.13_TBD6Kwg.pdf> 371K

Please consider the attached PDF file as a new submission to GSI Docket 140. A suggested citation is: Daniel W.
McKeel, Jr. MD, “Annotated Personal Transcript of GS! Portion of TBD-6000 Work Group 6/20/13 Teleconference
Meeting" (371K PDF, 6.23.13)." Thank you.

Sincerely,

-- Dan McKeel 6/23/13 Sunday

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


Attachment A

Dan McKeel Prepared
Public Comments

TBD-6000 Work Group
6-20-2013 Meeting


DM-Notes_6.20.13tbd6Kwg.doc

1:25PM Van Buren time (ET one hour later 2:25 PM) called DWM to
say Ted Katz had forwarded the SC&A 6/11/13 PA-cleared square wave
paper to us by e-mail (before the WG meeting ended). McKeel wondered
how the PA cleared version was produced that quickly; did someone
actually have it before the meeting?

The following one page each ATTACHMENTS are included in this paper:

ATTACHMENT A. Dan McKeel prepared remarks delivered to the TBD-6000
work group on 6/20/13.

ATTACHMENT B: One page Ted Katz 5/28/13 GSI technical call summary.
To SEC co-petitioner 5/30/13.

ATTACHMENT C: McKeel one page goals for the TBD-6000 work group to
bring closure and allow NIOSH to generate a revised GSI Appendix BB.
To TBD-6000 work group on 6/18/13.

Respectfully Submitted:

(Samal ometiel, |.

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

S 6/23/13

Current contact information:

= th.


DM-Notes_6.20.13tbd6Kwg.doc

ZIEMER: Endorses (McKeel suggestion) for “charting out all doses
SUMMARY CHART - Neton chart it out.”

MCKEEL NOTES PAGE 6 OF 8

RAMSPOTT: “I have another ‘settling’ concern: two external fan
sources, hanging gas furnaces -- no outside discharges 24/7
summer/winter -- BLOWS dust all the time. Are fans a consideration?”

ALLEN: Yes, I have seen furnaces at Fernald plus my Dad's service
station. Not unusual. [MCKEEL COMMENT: This comment is not responsive
to ‘consideration” query. ~ was asking whether NIOSH has
or will account for constant dust resuspension in both GSI Betatron
facilities? McKeel believes there are GSI photos showing similar
hanging gas furnaces in other plant buildings. The furnaces are
directly related to assigning an appropriate -- plausible and claimant
favorable = RF at GSI, which is not 10° m’ should be 10? *~* mj

RAMSPOTT: How is this taken care of with surrogate data?

ALLEN: “In Northern hemisphere.” [MCKEEL: What kind of non-answer is
this? Did IT miss something important?]

ZIEMER: Still have settling - air [concentration] higher -- all have
the “air moving” -- still get oxygen, have air settling and
resuspension. [McKeel Comment: See comment on ALLEN above. This answer
again avoids the point that Ramspott was asking about. Deliberate
evasion of a totally legitimate issue. Is this personal animus against
the GSI site expert? Question twice put and twice not answered by DCAS
and the WG chair)

MAURO: Put matrices together, 5 criteria surrogate data are put to. In
support of surrogate data, is part of process, and should be part of
the record. (emphasis added - McKeel) “Can you put out a preview
Appendix BB?” Mauro asked Allen, who did not respond.

ANIGSTEIN: (Reminder that DCAS/NIOSH) modeling Layout man in New
Betatron Building era 2x off versus SC&A, and skin dose “there are
significant differences between us.”

ZIEMER: On McKeel’s previous comments about Adley report issues (such
as the forklift and RR freight car uranium unloading), and the need to
resolve all Appendix BB issues prior to DCAS issuing a revised GSI
Appendix BB preview or full report. (1) Work Week, (2) Internal
uranium intakes, (3) Beta doses, ”...each of these pieces will lead to
coming to closure. Have in a sense been closed; have to close the
(McKeel: Appendix BB SC&A 11/26/12 issues) matrix (McKeel, too).

Lunch Break for 30 minutes then ensued...


DM-Notes_6.20.13tbd6Kwg.doc

MCKEEL NOTES PAGE 3 OF 8

ZIEMER (continuing with McKeel response...) Square function was what
we | Allen had discussed previously.

MAJOR NOTE OF 1ST OF SEVERAL PLZ PHONE INTERRUPTIONS AT VERY
INCONVENIENT TIMES BLAMED ON “PROBLEMS WITH PHONE” AND “BEING ON
MUTE”: At 10:21AM there was abrupt cutoff of the phone line --> Paul
dropped off (silence) --> 10:22 --> 10:23 PLZ silent --> 10:24 PLZ
still off --> Court reporter on line asked “Am I heard?” Ted Katz
on...

ZIEMER (returning to line, still responding to McKeel): “OTIB-70 not
actually discussed. We said it needed to be discussed at the next WG
meeting.” Ziemer than asked if there were any “DFO comments, Ted?”

PHONE INTERRUPTION #2: The Ziemer phone and Katz dropped out 2nd time
(no voices)--> [Allen: “can anyone hear me? - Ted, are you on the
line?]

KATZ: “I was muted.”
ZIEMER WAS THEN CUT-OFF AGAIN (3RD TIME) “Blocked out again”

GLOVER (Simonds) and TOMS (Joslyn) asked to be excused until after
lunch when their sites would be discussed. Ziemer gave his OK, “but
stay at your offices.”

KATZ: Dan (asked) why Katz asked questions: “multiple roles, contract
office tech/wG staff for contract SC&A. I don’t need to say any more,”
defending his position. Ted stated he “asked a lot of questions all
the time at WG and at technical calls." [McKeel comment: Ted Katz
being DFO, and being WG “staff,” and being SC&A contract officer
simultaneously is a HUGE CONFLICT, WELL BEYOND THE STATED DFO ROLES.)

ZIEMER: There are two DCAS (Allen) white papers: dose estimate for
administrators, and square function inhalation intakes.

ALLEN was asked questions after his presentation No McKeel notes, no
questions to Allen captured. [MCKEEL COMMENT: The preceding
confrontations with PLZ and TK and the mysterious, but convenient for
them, phone interruptions, were very unsettling (to me)]:

ZIEMER: No questions at first, clarified that NIOSH must be certain
that “admin” people were never in the production areas, or they had to
be treated as production area people for DR purposes.

BEACH: I am afraid, upper end Admin we are not capturing.

ZIEMER: Are you concerned about more time in plant?

BEACH: No, about offices being in production areas

eS


GSI TBD (Appendix BB) Review Staff Technical Conference
May 28, 1:00 p.m.

Attendance: Paul Ziemer (ABRWH TBD 6000 Work Group Chair), Jim Neton (DCAS), Dave Allen (DCAS), John
Mauro (SC&A), Bob Anigstein (SC&A), Ted Katz, ABRWH DFO

Summary:

The staff met by teleconference to clarify elements of the modeling approach being proposed by DCAS for
estimating internal doses at GSI and concerns regarding the approach as understood by SC&A staff, and similarly
to clarify an alternative approach proposed by SC&A in its April 24, 2013 memorandum and to clarify concerns
regarding this approach as understood by DCAS staff. The discussion produced the following clarifications:

* The DCAS modeling approach, as proposed, simplifies the exposure pattern at GSI to a square wave
function in which the 95" percentile of the surrogate data for comparable operations aerosol levels is
applied to operational periods and the modeled re-suspension exposure is applied to all other periods
(non-uranium operations) during the AEC operational era at GSI.

* Aconcern of SC&A staff regarding this model is that the proposed square wave function simplification
may not conservatively estimate the combined total exposure of workers (uranium operations + non-
uranium operations). Specifically, SC&A staff members are concerned that if the decrease of the
exposure level following the termination of an operational period is slower than the increase of the
exposure level at the beginning of an operational period, then the square wave function may
underestimate the net contribution to exposure associated with the uranium operations.

* The SC&A approach, as proposed, does not attempt to model exposures during the AEC operational era
at GSI “mechanistically”, to directly reflect and account for differing exposure levels during periods of
uranium operations and periods of non-uranium operations. Instead, it would apply an arithmetic mean
(average) exposure level (based on the same surrogate data sets applied by DCAS) to all work time,
avoiding the use of any assumptions about the timing and periodicity of the uranium operations.

* Aconcern of DCAS staff regarding this approach is that it may be more simplified than warranted given
the information available for modeling and, as a consequence, it may produce overly conservative
estimates of internal dose.

* SC&A staff noted that the number of days to be applied to deposition modeling might need discussion at
the Work Group meeting, as might the determination of the initial exposure level during the residual
period at GSI, as applied under OTIB 70,

* The DFO asked whether any adjustment was applied to the contractual labor hours information to
account for concurrent work by multiple production employees and for administrative work, to estimate
the operational time handling uranium. No adjustment was made.


TBD6K_Goals_6.20.13mtg.doc

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

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

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

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

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

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

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

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

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

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

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

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

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

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

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

Radiographer (production)

Non radiographer (prod.)

Administrative (office)

Technical Guidance and References:


DM-Notes_6.20.13tbd6Kwg.doc

ALLEN (continued...) settling rate x time - PRODUCT | quibble with
SC&A; SC&A should we use -0052? [NO RESPONSE FROM SC&A]

Airborne 1400 not far off - IF STATEMENT - not data real measured.
(McKeel noted to self and notes that Allen “still insists on using 30
days, ignores Thurber”].

Issue 5, “TBD6K air values higher than Adley” - days to equilibrium.
ZIEMER: To Thurber, (Will you) put in writing?
THURBER: Yes

[speaker not clear: Ziemer (less likely) or ALLEN (more likely - DWM]
SC&A uses not appropriate. Thurber didn’t talk about - all Adley
settling data lower than TBD6K. SC&A = Why discussed in his paper.
Definite NIOSH in writing. [Margin note: ACTION #1, white paper ALLEN]

THURBER: SC&A, David (Allen) shared his DCAS spreadsheet with time
that shows 30 day rate derivation. Surface amount Adley, settling rate
TBD6K: (thus) NIOSH uses “apples to oranges.” SC&A used only Adley
data for both parameters, to avoid “apples to oranges.”

MAURO: Affirmed NIOSH/Allen (i.e. arqued against Thurber and his own
SC&A colleague!) Mauro queried: “How well does 30 days stand up as
solo data? BINGO!” Accepts Allen’s bone (falls into trap set by Allen)

BEACH: Calculation errors. Sweeping and dust: Are they highest at GSI?

MAURO: Use SD (surrogate data) from real facilities -- purely
empirical number. That’s what we've got -- does it cover all
activities. NIOSH uses 95%’ile which accommodates uncertainty. [McKeel
comment: Another glaring example where SC&A and Dr. Ziemer
inappropriately go out of their way to defend NIOSH/Allen, which is
NOT their job. The mission is oversight of NIOSH science. Their
comments sound like they are NIOSH employees working for the agency].

MCKEEL: Summarized Adley data on uranium airborne levels being high
from 7 men unloading freight cars that was also the case at GSI.
Mentioned the 5/28/13 technical call 2/3 page summary. Mentioned
inappropriateness of a new method being introduced.

ZIEMER (responding to McKeel): Dr. Ziemer noted that he also had some
Adley comments, and that McKeel’s Adley data was “coming up.” Ziemer
stated that Katz wrote the 5/28/13 technical call summary “sent to all
parties” - everyone said this was “reasonable summary” PLZ/Allen &
Neton “NO” (answer?, my note unclear); SC&A answered “fine”. [MCKEEL
COMMENT: Turned out not to be true because Ziemer’s subsequent Adley
comment was regarding rod handling, a different topic. I believe NIOSH
and SC&A should have been more forthcoming on this point. No one
wanted to deal with the fact that McKeel and had been denied
access to listening to the 5/28/13 technical call.)

a


DM-Notes_6.20.13tbd6Kwg.doc

Annotated Notes From the
6/20/13 Meeting of the TBD-6000 ABRWH
Work Group Conference Call Meeting

Daniel W. McKeel, Jr., MD
GSI SEC-00105 Co-petitioner
(version 0; June 22, 2013)
[near verbatim transcription of
8 handwritten page of DWM Jr.
contemporaneous notes; minor edits
for clarity; annotated comments]

MCKEEL NOTES PAGE 1 OF 8

[Dan McKeel logged in to the call at 10:26AM ET; n=9 on the line]

10:28AM Ted Katz (DFO) queried whether Wanda Munn was on the line. No
answer: “having trouble contacting her for several recent matters. Dr.
Ziemer responded “health problems e-mail yesterday.”

1) Roll Call: Present = Ziemer, Beach, Poston from ABRWH; Neton,
Allen, Glover, Toms (NIOSH); Monica Maples (ORAU); Mauro, Anigstein,
Thurber, Barton (SC&A); Katz DFO and Lin HHS (Federal); Dan McKeel
(GSI SEC co-petitioner) and (GSI site expert) (Public)

2) ZIEMER: start with agenda item #1, TBD-6000 Rev 1 (2011) SC&A
report

THURBER: Lot of detail I won’t go into. 4 issues: (1) appropriate
terminal settling velocity; t = surface equilibrium; attenuation rate
| buildup/removal. 4 sites; Kingsley and Harris. Rev 0 did not
identify sites “generic data.” Operations not in TBD-6000 Rev 1: floor
sweeping, uranium fires, and [?]. I will skip all intermediate
information. 6 conclusions summary: 5 micron AMD claimant favorable
7.5 10“ m/sec SC&A agrees; time surface to reach equilibrium (better
document: NIOSH 30 days) but SC&A on average reasonable but 33-37 days
better. Adley (1952) 30 days not adequate, SC&A up to 84 days.

Further Discussion: (a) compare rolling and extrusion, in general
geometric mean OK, some sites increased POC differ 6% (arithmetic mean
better). (b) Uranium chip fires info: NIOSH Joslyn worker interview:
burned centerless grinding residue, was wet, dump into steel trough;
“brown paper -- whoosh, done!” Called weather service every night to
see if wind velocity was equal to or greater than 7 MPH (had to be
above this level), reasonable. (c) Equilibrium: .035/day higher than
OTIB-70 rate (“not surprising”); (d) floor sweep - any dust covered by
TBD6K data set. (e) outdoor burn - any dust covered by TBD-6K data
set. (thus SC&A sees no need to modify TBD-6000 Rev 1)

ZIEMER: Calculation errors in TBD-6000 “ought to be checked.”

ALLEN: agree, include cale error; will fix next revision (add
emphasis). [MCKEEL: That could be years down the road, unacceptable! |


Dan McKeel Public Comments TBD-6000 Work Group 6/20/13 Meeting

Thurber - Supplementary comments on TBD-6000 Rey 1 (see #7)
* Left out Adley 1952 freight car unloading of uranium (7 men) high MACs;
directly relevant to GSI MCW uranium operations (see McKeel Adley paper)

5/28/13 technical call 2/3 page very brief summary:
+ Secret: anonymous summary, public/McKeel denied access — why?
+ TIB-70 was discussed breaking a promise it would not be

* DFO Katz Q&A on production labor hours > precedent to participate?

Re: Agenda; why was Appendix BB matrix omitted? When will these issues
be addressed? It is now 7 months since the Board voted on SEC-105 and
six (6) full years since Appendix BB Rev 0 was first released.

Hinnefeld replied to McKeel 6/19/13 with statistics on GSI Appendix BB doses

assigned to date: (n=252 total, 166 of 252 got highest dose=65.9%)

+ 166 radiographer +82 Other +4 No External Estimate (partial DR)

The last category is ODD; GSI has no SEC and is an AWE site with many Part E claims.
: there were only 89 known badged GSI radiographers 1952-

1966 and 11 “subimitted claims. How many (and %) job=radiographer got highest dose?

Number and % of non-radiographers that got lower dose? Relates to Dave Allen's

12/11/12 Board remarks that non-radiographers got highest dose scenario — not true; only

some did. Which non-radiographers got higher and lower doses by job category?

McKeel critique of Allen (May 2013) Administrative Personnel Dose paper — “Dose
estimate from radium radiographer, to employees | not routinely working i in production
areas” (3 pages).

* NIOSH does not have the capability of discerning which GSI employees

worked almost solely in the Admin Bldg.

* The one trip per day to and from the plant is unrealistic & arbitrary.

McKeel critique of Allen Square Function Approximation paper.

¢ Why was this first named as such at a technical call that excluded Dan McKeel?

* Can't see the value of this theoretical qualitative modeling: what was it?
Added after meeting: McKeel was not sent the SC&A 6/11/13 memo RE: square wave
model. This fact materially changed what my remarks would have been 6/20/13. I do
not consider this to be an “elegant model” and wonder why square wave model came to
be the final designation on 5/28/13 rather than at the 4/26/13 TBD-6000 WG meeting?

McKeel paper on Adley 1952: Allen ignored important data that relates directly to GSI.
High MACs, exceeding limits, for cold uranium handling including rod stacking,
sweeping, cleaning uranium transport truck beds by filing, scraping and grinding,
handling by fork lift with exhaust, and unloading from freight cars. MACs so high that
Hanford Melt Plant restricted number of hours/day on job. SC&A mentioned 8.28.12.

An adequate reason for ignoring these important data has not emerged. Adley 1952 use at
GSI as surrogate data needs to be re-examined and subjected to five SD review criteria.

McKeel paper on TIB-70 being inappropriate to use at GSI:

* PRS Board S/I2N/3 summary by Wanda Munn showed that RF could be

as high as 10° m"; 10° or 10m" are not claimant favorable (too low)

* RESRAD-BUILD and DandD code cannot faithfully model cyclical uneven
uranium resuspension at GSI during the 26 year residual period: building power
washing, renovation, multiple new steel making businesses used GSI facilities.
+ Further details on my concerns about TIB-70 are in the white paper I e-mailed
to the TBD-6000 work group on 6/19/13. I apologize for the later submission.

The three phone line interruptions to Dr. Ziemer and Ted Katz are very concerning.


Attachment C

McKeel Goals Memo
for 6/20/13 TBD-6000
Work Group Meeting