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

From: DanMcKeel:

Sent: Saturday, November 10, 2012 9:16 AM

To: NIOSH Docket Office (CDC)

Ce: danmckee

Subject: Fwd: McKeel Comment on Allen Nov 2012 GSI Discussion Paper
Attachments: McKee! Comment on Allen Nov 2012 GSI Discussion Paper

To the NIOSH Docket Office

Attachment: <McKeel_Comment_AllenNov2012.pdf> 1.1 MB
Please accept the attached PDF file as my comment on David Allen's DCAS/NIOSH latest Discussion paper on the
General Steel Industries (GSI) site. The Allen paper was prepared for the TBD-6000 work group atits scheduled Nov 28,
2012 next meeting. The Allen paper analyzes additional surrogate data sources to be used in a future revision to
Appendix BB to account for uranium intakes at GSI. | wasn't sure whether or not Ted Katz, DFO, forwarded your office a
copy of the attachment. Thank you
—Dan McKee! 11/10/12
\n a message dated 11/9/12 12:40:44 PM, writes:
Paul Ziemer, Chair, and members of the TBD-6000 work group
Ted Katz, ABRWH DFO.
Members of the ABRWH full Board
NIOSH Docket 140 (GS!) Office
November 9, 2012
Attachment: <McKeel_Comment_AllenNov2012.pdf> 1.1MB
Dear Dr. Ziemer,

| have attached as a PDF file my comment related to the latest David Allen and DCAS/NIOSH Discussion paper that was
posted on the DCAS website on 11/8/12

Ted Katz, please distribute this Discussion comment paper to the full Board membership

NIOSH Docket 140 Office, please consider posting this message and the attached POF file to the DCAS website as a
discussion paper for the Nov, 8, 2012, TBD-6000 work group meeting.

Thank you - Dan McKee! 11/9/12

Daniel W. McKeel, Jr, MD
GS! SEC-105 co-petitioner

Danie! W. McKeel, Jr, MD


Allen_ATTACH1_DMaddendum doc

Daniel W. McKeel, Jr. ADDENDUM COMMENT

David Allen November 2012 Discussion Paper

Additional Air Sample Surrogate Data for GSI
November 12, 2012

Further research prompts these additional comments to be added to my previous
11/9/12 review and rebuttal of the Allen Nov. 2012 discussion paper on GS] air
intake surrogate data sources.

1. Surrogate air sample data sheets from two sites (LeBlond, Chambersburg)
listed in the Attachment 1 table were provided by Allen in his August 2012
Discussion paper on the same topic, so they are not actually "additional" sites.

2. The Heald Machine Company and its data sheet, and the Simonds Saw and
Steel, surrogate sites listed in the Allen August 2012 paper are not used in
Attachment 1 table 1. That fact is not explained in the Allen Nov. 2012 paper.
The omission of Heald is puzzling: if that site data was applicable in August 2012
to GSI air intakes, why is it not applicable and included in the table of Attachment
1 of the November 2012 paper only three months later?

McKeel footnote: | have asked why the Simonds Saw and Steel site, which
already has an SEC, was only recently added to the task assignment for the
TBD-6000 work group? To date | have not received a satisfactory answer from
the work group chair, Dr. Ziemer.

3. The additional (not previously identified) surrogate data sites added by Allen
in the November paper were “Tocco” (only designation in Allen November 2012),
Fernald (FMPC) and Weldon Springs (sic) sites.

4. The air samples are not classified according to the three required air intake
sampling groups that HASL and the AEC said were necessary to characterize
MAC “dust” samples (See Adley 1952): general air, breathing zone, process. This
important omission seriously limits the utility of the surrogate data Allen provides
and pools together from four different types of uranium metal products at five
different sites and combines into a single value that NIOSH intends to
incorporate into Appendix BB using some future model at some unidentified
future date. The work group and full Board should reject such a casual approach.
NIOSH needs to have a validated intake model for GSI in place now as the TBD-
6000 work group and the full Board approach votes on the GSI SEC-00105
recommendation on August 28, 2012, and at the December 2012 ABRWH
meeting at Oak Ridge, Tennessee.


Allen_ATTACH1_DMaddendum.doc

5, All Tocco samples were from slugs that (a) were not used at GSI, and (b) that
were not further characterized as to size and weight in the three Tocco FUSRAP
documents on the Internet in the DOE-LM Considered Sites Database as Ohio
site 42-1, -2 and -3. Data sheet 42-1 is appended to this ADDENDUM report.

6. Four of the six (6) LeBlond air sample activities (dpm/m3) are based on
billets listed in Attachment 1 and are "nd" non detect. The values are not
therefore scientifically informative absent any added information on how they
were measured. No measurement methods are stated for any of the air sample
activity values reported in the ATTACHMENT 1 table of Allen, Nov. 2012.

7. Allnine (9) of the Fernald derby air samples were covered under a footnote
that stated the following: "(1) Values listed as maximum, minimum and average
were used as three different samples.” What does this mean? How can such
nonstandard and deceptive data manipulation be scientifically defended? Dan
McKeel's view is, it cannot be. Derbies were not used at GSI and therefore are,
per se, not justified as surrogate data at that site.

8. Of the eleven (11) Weldon Springs (sic, site name is Weldon Spring singular)
air samples, three are slugs and eight (8) are dingots. One dingot air sample is
labeled "nd" (not detect) and three (3) dingot air samples are samples are
footnoted as follows in the ATTACHMENT 1 table of 37 samples:
+ Footnote 2: "Values back calculated using conversion factors at the bottom of
the summary report." How can a reader possibly evaluate the scientific validity of
such derived secondary data absent having the summary report? Allen should
have provided the primary data, Those three back calculated activity values are
higher than the other WS dingot air sample values that were not back
extrapolated. The WS dingot values are not further characterized and thus
cannot be considered scientifically valid until support information is supplied to
the work group and the full Board and the petitioners for review.

The 11 Weldon Springs air samples were collected on only four dates, so this
is a very tiny and not representative statistical sampling of the universe of WS air
sampling data. Weldon Spring DOE site is not similar to the AWE site.

Respectfully submitted,
(ened Wd, Meal,
Date: 11/11/12

Contaet information:
Daniel W. McKeel, Jr., M.D.
GSI! SEC-00105 co-petitioner