McKeel comment on SC&A alternate uranium intake model

5 Conclusion

We have presented an alternate model for the assessment of uranium intakes at GSI that does not
employ surrogate data derived from measurements at other sites. The model produces results that are
plausible and claimant favorable, and are in a form that is suitable for use by NIOSH in performing
dose reconstructions,

Altemative Model for Uranium Intakes at GSI -11- SC&A —Jnly 25, 2012

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

MCKEEL COMMENT ON 5 CONCLUSION: The petitioners disagree with the conclusions. The
model does use surrogate (derived or virtual) data liberally that is not real measured GSI site data.
The last sentence shows that SC&A clearly had a goal to develop a model “that is suitable for use
by NIOSH in performing dose reconstructions.” We strongly disagree the alternate uranium intake
model should be used for dose reconstruction by NIOSH because it is scientifically flawed in many
aspects that we have identified in our comments throughout this paper. The petitioners also assert in
the strongest way possible that developing this model “out front” is an obvious counteraction to
NIOSH demonstrably not being able to develop a valid intake model after two tries over a 5+ year
period dating back to the release of Appendix BB Rev 0 in June 2007. We believe that Dr. Ziemer
and Mr. Katz in tasking this paper by SC&A off the record were attempting to support a work group
recommendation to deny SEC-00105 on August 28, 2012. We sincerely hope that the work group
and full Board reject this unwarranted maneuver that is tantamount to SC&A doing NIOSH’s work.

References

ABRWH Work Group on Use of Surrogate Data. 2010. “Criteria for the Use of Surrogate Data,”
Final Draft (May 14, 2010). http://www.cdc.gov/niosh/ocas/pdfs/abrwh/proc/abrwh-proc-sd-r0.pdf.

Abu-Eid, R. M., et al. 2002. “Re-evaluation of the Indoor Resuspension Factor for the Screening
Analysis of the Building Occupancy Scenario for NRC’s License Termination Rule: Draft Report for
Comment,” NUREG-1720.

http:/Awww.nre.gov/reading-rm/doc-collections/nuregs/staff/sr1720/

Adley, F. E., W. E. Gill, and R. H. Scott. 1952. “Study of Atmospheric Contamination in the
Metal Melt Building,” HW-23352 (Rev.); SRDB Ref. ID: 27354.

Allen, D., and S. Glover. 2007. “Site Profiles for Atomic Weapons Employers That Worked
Uranium and Thorium Metals - Appendix BB: General Steel Industries,” Battelle-TBD-6000,

Appendix BB, Rev. 0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r0.pdf.

Anigstein, R. 2012. “Review of the Use of Surrogate Data for Estimating Intakes of Uranium at
General Steel Industries.” http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsisd-r0.pdf

Anigstein, R., and J. Mauro. 2012. “Reply to NIOSH Response to SC&A Memo Dated May 30,
2012.” Memo to Advisory Board on Radiation and Worker Health Work Group on TBD-6000 (June
11, 2012). http://www.cde.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiid-061112.pdf

-19-


McKee! comment on SC&A alternate uranium intake model

facility with fresh, recently deposited surficial contamination that is subject to pedestrian and
vehicular traffic may have a factor of 5 + 10 m or higher. In the proposed model, the contamination
includes both recently deposited activity and material that may have accumulated over the entire
13.5-y period of AEC operations, whereas Allen and Glover (2007) postulated an accumulation

over a period of one year. We believe that the intermediate value of | + 10 m is a plausible upper
bound for use with the proposed model.

MCKEEL COMMENT: Regarding the concluding sentence, | believe the “intermediate value”
cited is a guess that is different from previous well reasoned pseudoscientific guesses and should
not be accepted as a validated bounded value, which | contend is impossible to determine in the
absence of real data. Again, SC&A is employing surrogate data without admitting they are doing
so. The Board should reject this analysis.

The resuspension factor should also be in reasonable agreement with the fractional removal rate
recommended by Sharfi (2012). Removal can involve various unspecified mechanisms; for the
purpose of the present comparison, we will assume that some unknown fraction of the removal is
through resuspension, with the resuspended material being vented to the outside air.

MCKEEL COMMENT: Terms like “in reasonable agreement” are not scientifically acceptable.
What are the established limits for the pseudoscientific term “in reasonable agreement?” What is
reasonable and who decides that? Is “reasonable” + 1 standard deviation from some unknown and
undefined mean value that does not actually exist? The Board should again reject this model based
on this type of reasoning. In other GSI contexts, NIOSH and SC&A call agreement between models
of 200% to 300% “reasonable agreement.” This is another example of extreme fuzzy reasoning.

Note the text above admits that resuspension necessarily involves “various unspecified
mechanisms” and “some unknown fraction of the removal” that is due to resuspension. These terms
clearly place the mathematic formula that follows into question because the input data into the model
is unknown and unknowable, and the limits of uncertainty (that must be enormous) are not defined
by a formal uncertainty analysis. All of this modeling is pure speculation, not solid science and it
should be rejected by the Board, This model should not be used by NIOSH in Appendix BB or for
dose reconstructions.

The relationship among the removal rate, the resuspension factor, and the building ventilation rate
can be expressed by the following equation:

removal rate due to resuspension (d")

Hy =
=B
¢? = conversion factor
= 4hd
ry = air exchange rate (h)
V = volume of affected region (m’)
A = area of contaminated surface (a)

This is a plausible value of the effective air exchange rate for the shooting room in the Old Betatron
Building.

-13-


McKeel comment on SC&A alternate uranium intake model

SC&A’s contract officer representative. There is no vote but we typically report the tasking, if is
significant, at the next meeting.

MCKEEL COMMENT: This answer ignores several of the specific questions that McKeel posed
to Mr. Katz: (a) who besides Dr. Ziemer and Mr. Katz participated in any way in the SC&A
tasking? (b) did Board Chair Dr, Melius know about and approve of the SC&A tasking? Our
strongest challenge is to Mr. Katz’s statement that “When the Board is not in session, tasking and
related clarification of tasks are handled by the Chair of the Board or its subcomponent, as
appropriate, and me, as SC&A’s contract officer representative.” Mr. Katz refers to “we” as
though the Board and DFO were one and the same. The petitioners are not aware that the DFO,
who is a CDC employee where CDC is an allied agency of NIOSH, is authorized to task SC&A.
This seems to be the role of the ABRWH appointed by the President. I am not aware that the
DFO is a Board member. Could Mr. Katz please cite for me the specific language in the SC&A
contract that gives the DFO to act as the representative for the contract officer with authority to
task SC&A? Can he point me to the specific document and page where this authorization is
written? It seems to me this is a clear conflict of interest. I believe the Board and SC&A, which
do derive their operating budgets and administrative support from HHS, should nevertheless be
independent when it comes to making scientific decisions. This tasking, in my opinion, should
reside solely in the hands of the Board itself and not be a function of the DFO or the contract
officer, who is conflicted in the same sense as the DFO. The tasking ideally should be open and
transparent to the full Board as was the SC&A 7,16,12 analysis of the surrogate data issue at
GSI. Dr. Ziemer did the tasking during the June 19-21, 2012, ABRWH 84th meeting, and the full
Board voted unanimously to support it. The tasking of this alternate method was done off the
record, and apparently only two people and one Board member knew about the second tasking.

The Board member who brought forward both motions to have SC&A review surrogate
data use at GSI with respect to the slug facility was apparently not informed about this second
SC&A tasking to create an alternate uranium intake model for GSI.

Sincerely, --Ted

(The entire message thread follows)

333i.


McKeel comment on SC&A alternate uranium intake model

Table 1. Uranium Handling Times, Based on MCW Purchase Orders

Period covered by PO Uranium handling
Dates Hours? Total (h)’ _ Fraction®
1/1/53" 2/28/58" 0.0499°
3/1/58 6/30/58 2928 125 0.0427
7/1/58 = 10/31/58 2952 112.5 0.0381
11/1/58 6/30/59 5808 225 0.0387
THUI59 6/30/60 8784 337.5 0.0384
7/1/60 6/30/61 8760 337.5 0.0385
T/N61 6/30/62 8760 4375 0.0499
7/162 6/30/63 8760 125 0.0143
T1163 6/30/64 8784 28.12 0.0032
7/1164 6/30/65 8760 28.12 0.0032
TI65 6/30/66 8760 12.86 0.0015

* Duration of period

> Total hours of uraninm handling operations during specified time period

© Fraction of time devoted to uranium handling operations (column 4~ column 3)
*@ No poschase orders found for this period

* Maximum of all later periods

To evaluate equation 2 at time 4, we must solve for R. We can derive R from equation 2, provided we
know the value of S(t) at some known time f. Such a value can be obtained from the results of the
survey of the Old Betatron Building performed by the Oak Ridge National Laboratory (ORNL) on
June 7, 1993, as reported by Murray and Brown (1994, Table 4). The authors list the a-radiation
levels at 31 random locations on the first floor of this building, as shown in Table 2 of the present
memo. These random samples constitute the best available data for estimating the average
contamination level on the floor of the shooting room of the Old Betatron Building. Since the authors
state that the MDA = 50 dpm/100 cm, we set readings of “<MDA” to one-half that value—25

dpm/100 cm. The average of the 31 readings— converted
Page 4

to units of Bq/m —is equal to 43.6 Bq/m. The time fis expressed in days since January 1,
1953, the start of the operational period at GSI, until the date of the survey.



McKee! comment on SC&A alternate uranium intake model

Harris, W. B., and I. Kingsley. 1959. “The Industrial Hygiene of Uranium Fabrication,” A.M.A.
Archives of Industrial Health, 19, 540-565.

Murray, M. E., and K. S. Brown. 1994. “Results of the Independent Verification Survey at the Old
Betatron Building, Granite City, Illinois (GSG001),” ORNL/RASA-94/2. Oak Ridge, TN: Oak
Ridge National Laboratory.

Murray, M. E., and M. S. Uziel, 1992. “Results of the Radiological Survey at the New Betatron
Building, Granite City Steel Facility, Granite City, Illinois (GSG002),” ORNL/RASA-91/8. Oak
Ridge, TN: Oak Ridge National Laboratory.

Nuclear Regulatory Commission (U.S.) (NRC). 2009. “General Steel Industries Byproduct Materials
License for Cobalt-60, Budd Company Model 41706 Sealed Source not to exceed | curie in a single
source,” ADAMS acquisition number ML093480290.

a 2007. “Fwd: Overhead door / Old BetatronTM
7, 2007, and Robert Anigstein, SC&A, Inc., and
Larry J. Elliot, NIOSH, c i

Alternative Model for Uranium Intakes at GSI -12- SC&A —Inly 25, 2012

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

EL COMMENT ON REDACTION, LAST REFERENCE OF PAGE 12: This extensive
redaction clearly has the effect of censoring the identity of the copyright holder to this photograph
That is, proper attribution was thwarted. The photograph was actually taken in September, 2006.
That information should have been included in the citation and should not have been redacted.
Documenting the pedigree and source of data is important. Copyright owner names should be stated.

Page 13

S. Cohen & Associates (SC&A). 2008. “Review of ‘Site Profiles for Atomic Weapons
Employers That Worked Uranium and Thorium Metals - Appendix BB: General Steel
Industries,’ Battelle-TBD-6000, Appendix BB, Rev. 0.”
http://www.cde.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-t1-24-rl pdf

Sharfi, M. M. 2012. “Dose Reconstruction During Residual Radioactivity Periods at Atomic
Weapons Employer Facilities,” ORAUT-OTIB-0070, Rev. 01.
hutp://www.cde.gov/niosh/ocas/pdfs/tibs/or-t70-r1 pdf.



3 of 4

aolrich://287 10391026/

reconstructing uranium internal intakes. --Ted

From: DanMcKeel2@aol.com [mailto:DanMcKeel2@aol.com
Sent: Thursday, July 26, 2012 11:21 AM
To: Kinman, Josh (CDC/NIOSH/DCAS)

Cc: DanMcKeel2@aol.com; Katz, Ted
(CDC/NIOSH/OD); Ziemer, Paul (CDC/NIOSH/OD); pl.ziemer@comcast.net; Wade, Lewis
(CDC/NIOSH/OD) (CTR); melius@nysliuna.org

Subject: Re: CORRECTED Alternative Model for Calc. of Uranium Intakes at GSI, reply
Dear Mr. Kinman,

| did not receive an earlier corrected or uncorrected copy of the above paper today (July 26). | note
that you replied to an earlier message of mine (weeks ago) that Mr. Allen told you "he didn't know"
whether NIOSH would reply to SC&A and the Anigstein paper that was released on 7/16/12. |
submitted my reply to that paper earlier today to Ted Katz and to the NIOSH Docket 140 (GSI) office
BEFORE | received this new Allen method paper from you. | asked Ted to please circulate my
transmittal letter to all TBD-6000 work group members and staff, and to the full ABRWH
membership.

It is very concerning that | and you, possibly, were not informed by Mr. Allen and NIOSH that this
new method was in the works. As | said in my critique sent this morning, | do not believe it is
reasonable for the TBD-6000 work group or the full Board to entertain a THIRD attempt by NIOSH at
bounding intake doses at GSI. Whatever new effort that went into this new paper, which | have not yet
had time to read, could (and definitely should) have been expended during the_19 months that have
elapsed since October 2010 when Mr. Allen issued his "Path Forward for GSI" white paper. NIOSH
should have assured their methods met surrogate data criteria long ago. NIOSH to this day has never
applied its OCAS-IG-004 surrogate data criteria to the GSI site dosimetry data. It is always playing
catch up, and the time for the Board to call a halt in my view is now. Allowing NIOSH unlimited
latitude in constructing new methods to replace scientifically unacceptable prior methods at the GSI,
which has happened repeatedly, constitutes highly claimant adverse decision making.

Sincerely -- Dan McKeel 7.26.12 Thursday

In a message dated 7/26/12 8:56:09 AM, eky1 @cdc.qov writes:

Good morning,

Attached is a PA-cleared, 508-compliant version of the corrected memo provided to you earlier
today, Alternative Model for the Calculation of Uranium Intakes at GSI. There are some minor
redactions in this cleared version.

Should you have any difficulties accessing this file, please contact me.

Sincerely,

Josh Kinman

8/2/12 6:47 PM


McKeel comment on SC&A alternate uranium intake model

unnecessary for reconstructing the intakes in question. SC&A duly notified Paul and I of its
progress and proposed that it address the surrogate data questions first, and follow this by fully
describing the approach it indicated it would be recommending (which relies solely on available
GSI data and on existing DCAS methods). Paul and I had not seen the surrogate data review,
which was still underway, but Paul decided SC&A should proceed accordingly because it might
expedite the Work Group’s efforts to conclude the GSI review, should the Work Group agree
with the SC&A surrogate data review.

MCKEEL COMMENT AND ANALYSIS: SC&A, according to this narrative, suggested that it
perform NIOSH work and show that it could develop an alternate uranium intake model for GSI.

NIOSH had not proposed developing such a model and Dr, Ziemer and Mr. Katz were aware of
this fact. Clearly there was interaction between the client, the work group, and the contractor,
and this off the record conversation could have influenced both the surrogate data report
wording, and the new SC&A model rationale and content. In fact, this conversation was alluded
to in the first paragraph of the alternate model paper, which proves this point. Is this appropriate
for a report that is supposed to be an independent assessment of NIOSH work?

I think this is all logical enough. We could have left the question of examining SC&A’s
recommendation, if it proves applicable, until the Work Group had judged the surrogate data
review, but that would have cost time in coming to decisions on this SEC petition. Whether
DCAS and the Work Group agree with the surrogate data review, whether DCAS and the Work
Group agree with alternative approach, etc. are all undetermined at this point. But it is the
prerogative of the Board to examine the feasibility question as fully as it deems necessary and
sufficient.

MCKEEL COMMENT: The petitioners do not agree with Mr. Katz. The main point is missed
that the Board and SC&A are supposed to be “evaluating” (using their preferred terminology)
NIOSH science, and in this case, the NIOSH Glover and Allen 2007 method for bounding GSI
uranium intakes during both the covered and residual periods was found not to meet Board
surrogate data criteria. It is hard to see how the Board could not accept these conclusions, that
the slug facility was not fully justified as a surrogate site to use for GSI operations. This finding
was obvious to Dan McKeel and was commended upon by him as early as 2008. SC&A and the
work group ignored this observation at the time until the subject again arose and gained traction
at the March and June TBD-6000 work group meetings. The petitioners also challenge Mr.
Katz's statement that “it is the prerogative of the Board to examine the feasibility question...
However, developing a new alternative intake method goes beyond the ordinary definition of
“testing resale in the peridoner’ s view. WwW F

Finally, you questioned the process of tasking SC&A. We task SC&A during Board meetings
(and all subcomponents thereof) to the extent we are prepared to do so. However, there are
many details and related needs that arise when the Board is not in session. There is no
requirement for tasking to be done in session, let alone exclusively in session, nor would it be
practical to operate that way. When the Board is not in session, tasking and related clarification
of tasks are handled by the Chair of the Board or its subcomponent, as appropriate, and me, as

-22-



McKeel comment on SC&A alternate uranium intake model

2.4 Intakes of Uranium by Inhalation

We calculated the inhalation of uranium by GSI workers by assuming that they were exposed to the
airborne concentration _s(f), evaluated for each calendar year, during each work shift, including the
periods of uranium handling operations. We assumed that they were also exposed to the airborne
concentration, _h. during the entire time of uranium handling operations, as listed in Table 1. The
intakes are based on a breathing rate of 1.2 m//h; they are listed in Table 3 for each calendar year
from the start of AEC operations until the time of the cleanup under FUSRAP.

MCKEEL COMMENT: There is no justification or source cited for the breathing rate used here.
There is no analysis that recognizes that determination of the percent of workers who were nose
and mouth breathers as has been assessed by some other work groups at other sites. There is no
calculation of rafter uranium-bearing dust that became airborne during 1953 to 1993 throughout
the entire GSI building complex. The SEC-00105 petition includes all workers at all building
locations. This model can apply only to the Old Betatron Building, a tiny part of GSI.

3 Discussion of Model

Our alternative model utilizes all available GSI-specific data, and does not employ any
measurements from other sites. The model assumes two sources of airborne uranium
concentrations: disturbance of the uranium metal during handling operations and resuspension of
uranium dust on the floor. Since these concentrations have two separate source terms, it is
appropriate that the intakes should be additive.

The model does assume that the uranium oxide released during the uranium handling operation forms
an aerosol with a particle size distribution equal to 5 um AMAD. Anigstein (2012) questioned that
assumption as employed by Allen and Glover (2007), because the uranium oxide

Page 11

could have included a wide range of particle sizes, including large particles that were not
respirable and would not have been included in the measurements reported by Harris and
Kingsley (1959) that were the basis of the uranium source term used by Allen and Glover. In the
present analysis, however, that calculation is performed in reverse. The uranium source term
(i.e., the deposition rate), is calculated from the site-specific surficial contamination levels. Since
the derived concentration during uranium handling operations is inversely proportional to the
deposition velocity, which increases with particle size, our assumption regarding the particle size
distribution leads to a higher concentration and to a higher respirable fraction than would result
from larger particles. Both of these are claimant-favorable results.

MCKEEL COMMENT: The true particle size distribution at GSI was not measured and is not
known. The petitioners therefore state that SC&A is making use of surrogate data that has not
been assessed as meeting Board criteria. The size settled upon is another not validated
guesstimate that adds to this house of cards intake model. This model is not plausible as defined
in any definite way or by any believable rationale. The values assigned for particle size are thus
picked out of the universe of possible particle sizes based on assumptions that are not
scientifically justified.

=


McKeel comment on SC&A alternate uranium intake model

18
20
21
21
22

3

> mw

<MDA
<MDA
<MDA
<MDA
<MDA

42
42
42
42
42

Average

43.6

Source: Murray and Brown (1994, Table 4)

* Calculated assuming “<MDA” = 25 dpmy/100 ca

Page 6

Since syis after the end of uranium-handling operations, we can solve for R using the second and third
lines of equation 2. Substituting for f, we obtain

R=rate of accumulation of surficial uranium during uranium handling operations =

1,195 Bam d°

S(t) = average a-activity concentration on first floor of Old Betatron Building at time “=

43.6 Bam

= time of ORNL survey = 14,767 d (January 1, 1953-June 7, 1993)

The average surficial activity concentration during a given calendar year can be estimated by
calculating S(t) on June 30, the midpoint of the year. The results are listed in Table 3. As shown in
this table, the surficial concentration increases markedly from 1953 to 1958, then gradually levels off
and starts to decline after 1962. To determine the accuracy of using the midyear date, we explicitly
calculated the average concentrations during the first 5 years by integrating the first line of equation
2 over each year. We found that the results of this exact calculation agree with the concentration on
June 30, with a maximum difference of 0.6% during the first year and less than 0.2% in the following
4 years. This indicates that using the midpoint of the year results in an accurate determination.


McKeel comment on SC&A alternate uranium intake model

The uranium detected in 1993 in the Old Betatron shooting room is clearly not representative of
the entire residual period or of an undisturbed decay of uranium, So to mathematically calculate
an assumed dose for each year from 1953 to 1993 at GSI is completely absurd. It is unreasonable
to assume a priori, without measured data to back it up, that radiation levels declined in a
smooth are, whatever type of curve fitting decay formula one chooses to use in the model. The
model is flawed from the outset because accurate, comprehensive, real measured data for 1953 to
1993 from throughout the GSI building complex to validate and define and bound doses using
the alternate uranium intake model is simply not available. The model is surrogate data based.

The statement starting on the fourth line from the bottom of page 3 of the SC&A alternate model
report that “These random samples constitute the best available data for estimating the average
contamination level on the floor of the shooting room of the Old Betatron Building,” may be true
but is also is a bit misleading and disingenuous because (a) these are the only such data, and (b)
they were taken 40 years after the start of the covered period and 20 years after the start of the
residual contamination period. Uranium dust can and often does settle on building rafters as well
as on the floor (see Dow Madison SEC-00079 petition Board deliberations for more discussion
of this point). The GSI Old and New Betatron rafters were not surveyed for uranium dust
radiation during the cleanup in 1993, Why this was not done is hard to understand.

Refer to Figure | on the following page and to Table 2 on the next page after that. Both are part
of section 2.1.



McKeel comment on SC&A alternate uranium intake model

Figure | shows the locations of the measurements reported by Murray and Brown (1994),
superimposed on a map of the first floor of the Old Betatron Building. The blue squares denote the
random locations. In addition, the ORNL team scanned the entire floor using large-area floor
monitors and G-M pancake probes. Red squares indicate locations that showed elevated B/_
activities. Since they represent biased samples, the activities at these locations were not used in the
present calculations but are shown to indicate the localized distribution of these “hot spots.” At 13 of
these 25 locations, the a-radiation levels were <MDA. We note that a separate ORNL survey of the
New Betatron Building “showed no residual “U attributable to former AEC-supported operations at
this site.” (Murray and Uziel 1992)

MCKEEL COMMENT ON SECTION 2.1 Surficial Uranium Activity Concentration:

1, OLD BETATRON BUILDING. As Dan McKeel, GSI co-petitioner explained at length at the
June 14, 2012, TBD-6000 work group meeting, the petitioner's view is that the tiny amount of
uranium dust data collected by ORNL for DOE for the GSI Old Betatron facility at the end of the
residual contamination period bears essentially no relation to radioactivity in 1974 at the start of
the residual period or at any time during the residual period except on the October day in 1993
when the ORNL-DOE alpha and beta measurements were made.

ORNL did not survey any other areas or the GSI uranium transport pathway where
uranium ingots, dingots, billets and Betatron slices were brought by crane and railroad transfer
cars on tracks that ran through building 7, 8, 9 and 10 beside the foundry and outside into the Old
Betatron Building entry tunnel.

The Old Betatron Building had been scoured and power washed and used to store leaky
transformers and the old Betatron hardware. We believe based on comparisons of what the Old
Betatron shooting room floor looked like at the SINEW site visit in September 2006 in
comparison with photos we have during the 1953-mid 1966 covered AEC contract period, that
tons of floor dust had been removed by some means. We can’t be sure when or how that was
done, There are no records. There are no real measured general air, or breathing zone, or urine
uranium bioassay data for any part of the GSI residual period. There is no similar enough
EEOICPA site to serve as a surrogate site.

Basing calculations on the limited uranium alpha and beta activity data for one day at the
end of the residual period is absurd, and totally scientifically indefensible and claimant adverse.

2. NEW BETATRON BUILDING. By the time of the ORNL radiation surveys in October 1993,
the New Betatron facility had undergone an even more stringent cleanup and repurposing as
office spaces, There are no written or precise worker testimony to indicate exactly what was
done. The original control room, wall, rafter and tunnel areas were not fully accessible to ORNL
during the cleanup. Thus, for SC&A to conclude that because ORNL found no residual
radioactivity in the New Betatron facility in 1993 (a) is not surprising, and (b) does not mean, of
course, that no uranium contamination was present during the residual period, a supposition that
is scientifically implausible and indefensible speculation and lacks face validity.

It must be emphasized that no Betatron or uranium direct source photon, beta or neutron
monitoring was done in either the Old or New Betatron facilities at GSI during the covered
period or the residual period up to the time of the ORNL radiologic surveys in 1993. There was
limited film badge data on 108 Betatron and isotope radiographers 1964 through 1973 out of a
work force of 3,000 people. | photographed New Betatron office renovation in September 2006.

= 5



McKeel comment on SC&A alternate uranium intake model

4 Results

One result of the analysis is an evaluation of the airborne uranium activity concentration due to
uranium handling activities equal to 1,106 dpmim. This value is approximately twice the breathing-
zone activity concentration of 590 dpm/m reported by Harris and Kingsley (1959) for the uranium
slug-stamping operation. However, it is about 30% of the value of 3,926 dpm/m presented by
Anigstein (2012) that was derived from Adley (1952) for the operation “Unloading rods from truck
with fork lift.” On the one hand, the activity concentration derived for GSI is conservative in that it is
based on the assumption that the deposition is entirely from 5 um AMAD particles, as discussed in
section 3 of the present memo. However, it could increase by a factor of 2 if we were to assume, as
did Allen and Glover (2007), that the uranium handling operations took place during only one-half of
the hours authorized by the MCW POs, the remainder of the time being spent on radiographing the
uranium metal. Since the higher concentration would be offset by a shorter exposure duration, such
an assumption would not change the uranium intakes and resulting internal doses, but it would affect
the comparison of the derived concentration with data from other sites.

MCKEEL COMMENT ON 4 RESULTS TO THIS POINT OF THE ANALYSIS: This text
characterizes and defines three scientific studies that suggest airborne uranium activity concentration
varies between 590 and 3,926 dpm/m’. Selecting one of the three studies is essentially employing
surrogate data, The selected value certainly does not represent use of actual measured GSI data.
Another factor of 2 is introduced into this fuzzy math formulation, Again, there are too many
unproved assumptions that attempt to bypass lack of real data. The model belongs to SC&A and not
to NIOSH, which has not commented on this paper as of this writing.

Next, we compare the calculated uranium surficial activity concentrations with those used by Allen
and Glover (2007). These authors derived a maximum value of 1,170 dpm/100 cm, which they
assigned to all time periods following July 1, 1961. By contrast, we derived values ranging from 27
dpm/100 cm during 1993, prior to the FUSRAP cleanup, to a high of about 43,000 dpm/100 cm
during 1962. Finally, we note that Allen and Glover listed intakes ranging from

0.932 dpm per calendar day during the entire residual period to about 128 dpm per calendar day in
1962. Our model results in intakes ranging from 0.29 dpm per calendar day at the end of the
residual period to a high of 971 dpm per calendar day in 1957. For the entire 40.5 years from 1953
to mid 1993, Allen and Glover's average inhaled intake is about 29 dpm per calendar day, vs. an
average of 261 dpm per calendar day calculated with our alternate model.

MCKEEL COMMENT ON 4 RESULTS: COMPARISON WITH ALLEN AND GLOVER
2007: The final sentence conclusion again illustrates how differently SC&A and the petitioners
view the newly derived inhaled intake per day values by NIOSH (29 dpm per calendar day)
and by SC&A (261 dpm per calendar day), a dramatic ten-fold difference. The petitioners view
this discrepancy as clear evidence that models based on assumptions and not on real data
generate values that are so disparate as to totally lack scientific credibility. GSI merits an SEC.

=1$-



McKeel comment on SC&A alternate uranium intake model

Table 2. Alpha Activity Concentrations on Floor of Old Betatron Building

Sample location Alpha
North East dpm/100 cm? Ba/m=
0 4 <MDA 42
0 8 <MDA 42
0 14 <MDA 42
1 6 <MDA 42
1 10 <MDA 42
1 17 <MDA 42
2 2 <MDA 42
2 4 <MDA 42
2 1 21 35
3 3 <MDA 42
3 vf 35 58
3 9 <MDA 42
4 12 <MDA 42
4 15 <MDA 42
5 6 <MDA 42
6 7 <MDA 42
6 10 <MDA 42
7 8 <MDA 42
7 13 35 58
7 17 <MDA 42
8 1 <MDA 42
9 5 <MDA 42
9 14 <MDA 42
10 17 42 70
11 1 <MDA 42

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Subj: RE: CORRECTED Alternative Model for Calc, of Uranium Intakes at GSI, reply
Date: Monday, July 30, 2012 3:54:38 PM

From: tmk1 @cde.gov
To: DanMcKeel2@aol.com, eky1 @cdc.gov
cc: patriciajeske27@gmail.com, jwramspott@sbcglobal.net, paz7@cdc.gov, pl.ziemer@comcast.net,

low0@cdc.gov, melius@nysliuna.org
Dear Dan:

SC&A was tasked with reviewing the DCAS approach to reconstructing radiation doses from uranium
intakes, under the surrogate data review criteria of the Board. In the process of doing so, SC&A realized
that, in its opinion, the surrogate data DCAS was relying on was unsuited and unnecessary for
reconstructing the intakes in question. SC&A duly notified Paul and I of its progress and proposed that it
address the surrogate data questions first, and follow this by fully describing the approach it indicated it
would be recommending (which relies solely on available GS] data and on existing DCAS methods). Paul
and I had not seen the surrogate data review, which was still underway, but Paul decided SC&A should
proceed accordingly because it might expedite the Work Group’s efforts to conclude the GSI review.
should the Work Group agree with the SC&A surrogate data review.

I think this is all logical enough. We could have left the question of examining SC&A’s recommendation,
if it proves applicable, until the Work Group had judged the surrogate data review, but that would have
cost time in coming to decisions on this SEC petition. Whether DCAS and the Work Group agree with the
surrogate data review, whether DCAS and the Work Group agree with alternative approach, etc. are all
undetermined at this point. But it is the prerogative of the Board to examine the feasibility question as
fully as it deems necessary and sufficient.

Finally, you questioned the process of tasking SC&A. We task SC&A during Board meetings (and all
subcomponents thereof) to the extent we are prepared to do so. However, there are many details and
related needs that arise when the Board is not in session. There is no requirement for tasking to be done in
session, let alone exclusively in session, nor would it be practical to operate that way. When the Board is
not in session, tasking and related clarification of tasks are handled by the Chair of the Board or its
subcomponent, as appropriate, and me, as SC&A’s contract officer representative. There is no vote but
we typically report the tasking, if is significant, at the next meeting.

Sincerely, --Ted

From: DanMcKeel2@aol.com [mailto:DanMcKeel2@aol.com]

Sent: Friday, July 27, 2012 6:40 AM

To: Katz, Ted (CDC/NIOSH/OD); Kinman, Josh (CDC/NIOSH/DCAS)

Cc: DanMcKeel2@aol.com; 5 , Ziemer, Paul
(CDC/NIOSH/OD); pl.ziemer@comcast.net; Wade, Lewis (CDC/NIOSH/OD) (CTR); melius@nysliuna.org
Subject: Re: CORRECTED Alternative Model for Calc. of Uranium Intakes at GSI, reply

Dear Mr. Katz, .

Please confirm that my interpretation about what you say is correct. That is, that Dr. Ziemer, off the
record and separately from his Board approved tasking during the ABRWH June 2012 meeting,
which did not mention any alternative method to be produced by SC&A, tasked SC&A to produce an
alternative method for calculating GSI uranium intakes. If that is so, | would say that Dr. Ziemer
tasked SC&A to perform contract work that should have been done by NIOSH/DCAS.

Your statement that "SC&A produced this analysis in support of its review recommendation that
NIOSH not use surrogate data for reconstructing uranium internal intakes" does not seem valid or
logical to me. Why should an SC&A finding that NIOSH's use of TBD-6000 slug facility intake data
failed to meet any of 5 Board SD criteria logically require SC&A to produce an alternative method?

8/2/12 6:47 PM



Dragon, Karen E. (CDC/NIOSHIEID)

From: DanMcKeel2@aol.com

Sent: Sunday, August 05, 2012 11:16 AM

To: NIOSH Docket Office (CDC); Katz, Ted (CDC/NIOSH/OD)
Ce: danmckeel2@aol.com

Subject: Board & Docket 140 submission (GSI site related)
Attachments: McKeel_SC&AAItModel_comment.pdf

Ted Katz, ABRWH DFO

NIOSH Docket 140 (GSI) Office

August 5, 2012
Attachment: <McKeel_SC&AAItModel_comment.pdf> 793 K
Dear Mr. Katz and NIOSH Docket Office,

| ask Mr. Katz to please distribute the attached PDF comment to all ABRWH members, including TBD-6000 work group
members and staff.

| also request the NIOSH Docket Office consider my paper for posting on the DCAS website as a Discussion paper under
Docket 140 (GSI) for the upcoming 8.28.12 TBD-6000 work group meeting.

The main body of this communication is a critique of SC&A's paper dated 7.25.12 on an “Alternative Model for Calculating
Uranium Intakes at GSI." The new SC&A intake method is posted as as a Discussion paper for the 8.28.12 TBD-6000
work group meeting. Appendix A to this submission is my response to the explanation Ted Katz provided to Dan McKeel
on 7.30.12 about the way this SC&A 7.25.12 method paper was tasked by Dr. Paul Ziemer (chair of the TBD-6000 work
group) and himself as DFO, apparently acting on their own volition. Thank you.

Sincerely -- Dan McKee!

Daniel W. McKeel, Jr., MD

GSI SEC-00105 co-petitioner

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 comment on SC&A alternate uranium intake model

Table 3. Inhalation of Uranium by GSI Workers

Year U concentration Intake (dpm/calendar day)
Baim — dpm/100cmTM —dpmimTM | Resuspension —_U handling Total

1953 10,119 6,071 6.07 64.87 1,591.28 1,656.15
1954 27,245 16,347 16.35 174.67 1,591.28 1,765.95
1955 40,657 24,394 24.39 260.65 1,591.28 1,851.93
1956 51,209 0,725 30.73 328.30 1,591.28 1,919.58
1957 59,402 35,641 35.64 380.82 1,591.28 1,972.10
1958 64,775 38,865 38.86 415.27 1,327.34 1,742.61
1959 65,559 39,336 39.34 420.30 1,229.22 1,649.52
1960 66,123 39,674 39.67 423.91 1,229.25 1,653.16
1961 66,682 40,009 40.01 427.49 1,410.92 1,838.41
1962 71,491 42,895 42.89 458.32 1,018.30 1,476.62
1963 61,489 36,893 36.89 394.20 276.89 671.09
1964 49,322 29,593 29.59 316.20 102.44 418.64
1965 39,887 23,932 23.93 255.72 74.30 330.02
1966 31,800 19,080 19.08 203.87 23.19 227.06
1967 24,902 14,941 14.94 159.64 159.64
1968 19,473 11,684 11.68 124.84 124.84
1969 15,259 9,155 9.16 97.82 97.82
1970 11,949 7,169 7A7 76.60 76.60
1971 9,356 5,614 5.61 59.98 59.98
1972 7317 4,390 4.39 46.91 46.91
1973 5,733 3,440 3.44 36.76 36.76
1974 4,489 2,694 2.69 28.78 28.78
1975 3,516 2,109 21 22.54 22.54
1976 2,749 1,650 1.65 17.62 17.62
1977 2,154 1,293 1.29 13.81 13.81
1978 1,687 4,012 1.01 10.81 10.81
1979 1,321 793 0.79 847 8.47
1980 1,033 0.62 6.62 6.62
1981 809 486 0.49 5.19 5.19
1982 634 380 0.38 4.06 4.06
1983 496 298 0.30 3.18 3.18
1984 388 233 0.23 2.49 2.49
1985 304 182 0.18 1.95 1.95
1986 238 143 0.14 1.53 1.53
1987 186 112 0.11 1.20 1.20

PS hes



McKeel comment on SC&A alternate uranium intake model

2.2 Airborne Uranium Activity Concentration
The airbome uranium activity concentration due to surficial contammation 1s calculated by
applying a resuspension factor to the surficial concentration.
xs = FSO a)
xs(f) = airbome uranium activity concentration due to surficial contamination at time f

F, = resuspension factor
1*10° m"

The airbome uranium activity concentration due to urantum handling operations can be
estimated from R, the rate of accumulation.

R
mary

1%
Page 7

MCKEEL COMMENT | on section 2.2 Airborne Uranium Activity Concentration.

Table 3 and formulas (4) and (5) support the proposition that “The airborne uranium activity
concentration due to surfic ‘ial contamination is calculated by applying a resuspension factor to
the surficial concentration.” And “The airborne uranium activity concentration due to uranium
handling operations can be estimated from R, the rate of accumulation.” Specific numbers are
given to plug into these formulae for the following parameters:

* _h=airborne uranium activity concentration due to uranium handling activities

*cl =conversion factor

* vd = deposition velocity of 5 um (micrometer symbol) AMAD particles

The source data for the first two of these values is not given. (Allen and Glover 2007) is given as
the source of the va variable.

MCKEEL COMMENT 2 on section 2.2 Airborne Uranium Activity Concentration: The
preceding formula and the data in Table 3 below are due to surrogate, that is derived rather than
real or measured, data and hence is not acceptable for calculating uranium intakes at GSI based
on SC&A’s own recommendation that NIOSH develop an intake model that does not depend on
surrogate data. The SC&A basic assumptions are rife with uncertainty and incompleteness. The
formulae may be correct but, as SC&A admits later in this paper, there are many processes and
factors that enter into airborne uranium. The key point is, GSI has no (zero) real measured
ambient air, general air, or breathing zone or urine uranium bioassay data to define and
accurately and plausibly bound the true level of airborne uranium at any time or location within
GSI for the full forty year time period between 1953 and 1993. The phrase “full of sound and fury,
signifying nothing” (that’s real or good in science) comes to mind with respect to this SC&A model.

>10-


McKeel comment on SC&A alternate uranium intake model

= = Biased samples |

= <= = Random samples
}- ma .

1-30 end

u if

i

: SAND-FILLED CONCRETE

N-S grid (m)
as

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5 10 15 618
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Figure 1. Locations of a-Activity Measurements in Old Betatron Building

Page 5 (see Table 2. next page)


McKeel comment on SC&A alternate uranium intake model

APPENDIX A

On the Tasking of This SC&A Discussion Paper for the
TBD-6000 Work Group 8.28.12 Meeting

The October 12, 2010 TBD-6000 work group meeting:

At the October 12, 2010, TBD-6000 work group meeting, the relevant transcript records the
following exchange:

SOURCE URL: http://www.cdc.gov/niosh/docket/archive/pdfs/NIOSH-194/0194-031211-
McKeel_sub.pdf

Page 271 = document page numbered 13 (14 of 19 counter).

In response to a question from Dr. Robert Anigstein of SC&A about a report
on air activation doses he is preparing, Dr. Ziemer says "Hold that in reserve
So that there's not at least a perception that you're out front on this. Note that
you're not out in front, but -- and I think that Ted's points are well made, but
there is a perception that we need to be cognizant of what -- let NIOSH have
a chance to see how they deal with air activation. Then you can easily say,
"Yes. we agree with this or we disagree based on our analysis."

Dan McKeel’s comment is that Dr. Ziemer appears to be conflicted about being “out front,”
that is, for SC&A to be preparing a paper about a topic that NIOSH should address first before
NIOSH has addressed the topic. This is the case with the present paper of concern.

An e-mail exchange between Dan McKeel and Ted Katz, ABRWH DFO and a CDC employee,
on tasking the Anigstein eg al. alternate method for calculating uranium intakes at GSI
Discussion paper to be presented at the August 28, 2012, TBD-6000 work group meeting.

MCKEEL COMMENT ON MESSAGES IN THIS THREAD (in blue to follow):

From: “Katz, Ted (CDC/NIOSH/OD)” <tmk1@cdc.gov>

Subject: RE: CORRECTED Alternative Model for Calc. of Uranium Intakes at GSI, reply
Date: July 30, 2012 3:54:19 PM CDT

To: “DanMcKeel2@aol.com” <DanMcKeel2@aol.com, “Kinman, Josh (CDC/NIOSH/DCAS)
<eky 1 @cdc.gov> Cc: (omitted, see complete message thread to follow)

Dear Dan:

SC&A was tasked with reviewing the DCAS approach to reconstructing radiation doses from

uranium intakes, under the surrogate data review criteria of the Board. In the process of doing

so, SC&A realized that, in its opinion, the surrogate data DCAS was relying on was unsuited and
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SEC Petition Counselor
DCAS/NIOSH

4676 Columbia Parkway, MS C-46
Cincinnati, OH 45226

Office: 513.533.6831
Mobile: 513.846.4819
Fax: 513.533.6826

Legal notice: This e-mail is intended for the_exclusive use of the recipient(s) named above. It may
contain information that_is protected by the Privacy Act, privileged, or confidential. It
should not be disseminated, distributed or copied to persons not authorized to receive such
information and whom are not named above. If you are not the intended recipient(s), any such
dissemination, distribution or copying is strictly prohibited. If you believe you have received this
document in error, please notify the sender immediately and delete the original.

Daniel W. McKeel, Jr., MD
GSI SEC-00105 co-petitioner
Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com
US Mail: P.O. Box 15, Van Buren, MO 63965-0015

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

8/2/12 6:47 PM


McKeel comment on SC&A alternate uranium intake model

Sharfi 2012. The question then arises, does use of Sharfi 2012 data fulfill all 5 Board criteria for
surrogate data? And since SC&A chose Sharfi 2012 data to base its alternate method upon, at
least in part, who will independently assess the appropriateness of this data source with respect to
the Board surrogate data criteria? SC&A should not assess itself.

2.1 Surficial Uranium Activity Concentration

The surficial uranium activity concentration can be derived from the following differential equation:
do,
—=0,+fR 1
a HS (1)
Gj = surficial uranium concentration due to accumulation during time period i (Bq/m”)
time (d)
#t = fractional removal rate
= 6.7 = 107 d (Sharfi 2012)
Ji = fraction of time during period i during which uranium handling operations occurred
qT,
fa —
T; = duration of uranium handling operations during time period i
i) = start of time peniodi
t2 = end of time periodi
R= rate of uranium accumulation during uranium handling operations (Bq m” d)
Integrating equation 1, using the boundary condition si(/i/) = 0, we obtain the following expression
for the surficial activity concentration at time

~
"

si(t) = surficial uranium activity concentration at time ¢ due to accumulation during time period i
(Bq/m )

Page 3

S(t) = total surficial uranium activity concentration at time f (Bq/m )
n(t) = number of uranium-handling time intervals up to time ¢

Table | lists the dates covered by the purchase orders for uranium radiography issued by MCW. The
total hours of uranium handling were based on the monthly or annual costs for each period, as well as
on the hourly rate, as specified by the purchase orders. These were divided by the length of each
period (in hours) to calculate the fraction of each period during which uranium handling operations
took place, represented by the symbol fiin equations | and 2. Because the frequency of uranium
handling operations prior to March 1, 1958, is unknown, the highest fraction of the later periods was
assigned to the period starting from January 1, 1953, the beginning of covered operations at GSI.


McKeel comment on SC&A alternate uranium intake model

MCKEEL COMMENT: The statement “This is a plausible value...” is not substantiated at all. Thus,
it is by definition not plausible because the reasoning is “surrogate” and is not a real measured value.

Although an often-quoted nominal value of the ventilation rate for an industrial building is about 1 h

' there are several factors that would have reduced the effective air exchange rate in this instance.
First, we note that the ventilators (exhaust fans) were located on the roof.

MCKEEL COMMENT: GSI site experts and I have pointed out the Old and New Betatron buildings
are physically different in many parameters that include construction materials, size, volume, wall
height, shielding, and in the number of rooftop ventilators, one having two and the other three
(evident form aerial photos).

Air entered the building primarily through the outside entrance. The entrance to the exposure room of
the New Betatron Building was approximately 17 ft high, as scaled from the elevation drawing
shown in Figure 2. The entrance to the Old Betatron Building (shown in Figure 3) appears to have
had a similar height. Some of the air entering through the door would have been exhausted directly
through the roof, without mixing with the air in the workers’ breathing zone that is a few feet above
the floor. Thus, the effective air exchange rate while the outside door was open would have been less
than the exhaust rate. Furthermore, the room had no openings other than the outside door and the
door to the control room. The outside door would normally have been opened only to permit the
passage of castings to be radiographed and probably, in summer, to allow additional ventilation, but
would be closed while radiography was in progress. The door to the control was always locked while
betatron radiography was in progress, which was approximately 41% of the time (SC&A 2008).

MCKEEL COMMENT: This paragraph is replete with factual errors and is rife with pure
speculations that cannot be substantiated by SC&A or any real measured data.

We challenge the statement that openings in the two facilities were the same in number and
size and dimensions. Doors were added to the New Betatron building, for example.

SC&A knows nothing about the exhaust fan capabilities as to amount of air flow or removal
rate or how they would affect the overall building air flow pattern. The walls of both facilities were
made of several types of material which had joints that were porous to air and had gaps. Above the
concrete walls was tin shielding. When we visited in 2006 parts of the tin roof was rusted through
and had holes in it. Given all these potential ways that air could enter and escape, a statement that a
few doors was the only air path is utterly ridiculous to anyone that has actually visited GSI. Many
living Betatron employees and other GSI workers can and have attested to the truthfulness of the
statements I am making here.

An exact statement that betatron radiography was in progress “approximately 41% of the
time” is another pure guess; the statement is not substantiated by any actual workplace log books,
shot records, NDT x-ray reports, NDT x-ray films, or anything but guesstimates derived from worker
interviews and pseudoscientific speculation. SC&A and NIOSH staff were invited to visit the GSI
facility several times by John Ramspott (this name should not be redacted), Mr. _ ,aGSI site
expert and Dan McKeel and members of SINEW visited the GSI site in September 2006 and took
extensive photographs and videos of what we observed. SC&A and NIOSH could and should have
availed themselves of the same opportunities. These repeated overtures by us were, however, always
ignored. Making statements that appear to impart scientific exactitude when the uncertainties are
completely undefined is not scientifically defensible and should be rejected as unconfirmed
speculation by both the Board and by NIOSH, who again should not use this alternate model for
calculating uranium intakes 1953-1993, NIOSH at this time has no validated intake method.

BS pes


McKeel comment on SC&A alternate uranium intake model

Figure 3. Photo of Old Betatron Building (BM 2007)

MCKE COMMENT: This photo was given to SC&A by GSI site expert Mr.
whose name will be redacted again here when this report is posted to Docket 140. This redacuon

represents a violation of the principle that copyright ownership should be attributed when someone
such as SC&A uses a photo copyrighted by someone else. The redaction above destroys this attempt
at proper copyright attribution, which is “John Ramspott © 2006.” The 2007 date is not correct. The
SINEW team site visited GSI in September 2006 when this photo was taken.

The purpose of this calculation is to bound the selected resuspension factor. In reality, there are
means of removing the surficial activity other than by resuspension and subsequent exhaust. Thus,
the removal rate due to resuspension, _r, is most likely substantially less than _, which, according to
equation 7, would imply a lower air exchange rate. A higher value of F would lead to a still smaller

air exchange rate, one that would no longer be realistic. This calculation confirms that F-= 1 _ 10 m
constitutes a plausible upper bound.

MCKEEL COMMENT: Nothing about the foregoing analysis was plausible for reasons stated by me
and confirmed in the first sentence above. SC&A acknowledges “there are means of removing the
surficial activity other than by resuspension and subsequent exhaust.” Of course there are. One is by
vacuuming that was done daily at GSI using a bevy of industrial vacuums that were larger than the

one DOE/ORNL assayed during the 1989-1993 survey and cleanup period. None of these larger GSI

- 16-


McKeel comment on SC&A alternate uranium intake model

the aerosol generated during handling operations, He found that such an approach is not suitable for
calculating uranium contamination generated during the intermittent uranium handling operations.
He also questioned the methodology of calculating the surficial uranium contamination levels
throughout the operational and residual periods based on the accumulation of uranium during one
year of uranium handling operations, with no year-to-year carryover and no removal.

2 Methodology of Alternative Model

Our alternative approach assumes the continuous introduction of uranium dust throughout the
operational period. The average rate of accumulation of uranium on the floor during each time
period specified in the purchase orders for uranium radiography issued by the Mallinckrodt
Chemical Works (MCW) is proportional to the fractional time of uranium handling during that
time period. The removal rate is based on the exponential source-term depletion rate
recommended in OTIB-0070 (Sharfi 2012). The final surficial concentration is given by the
average contamination level on the floor of the Old Betatron Building at the time of the FUSRAP
cleanup, reported by Murray and Brown (1994). The airborne concentration due to resuspension
at any time during both the operational and residual periods is calculated by applying the
appropriate resuspension factor to the time-varying surficial concentration. The airborne
concentration during uranium handling operations is calculated from the derived accumulation
rate and the deposition velocity of the uranium aerosol.

MCKEEL COMMENT: The petitioners challenge all of the assumptions stated above that are
the basic scientific underpinnings of this new alternate model for calculating uranium intakes at
GSI.

Challenge 1. There is no a priori reason to expect, without any measurements to back
this up, that uranium dust was necessarily “continuously introduced” and was always
proportional to “fractional uranium handling time” as indicated by GSI purchase orders, for
several reasons. There are no purchase orders for 1953-57. The mix of uranium billets, dingots,
ingots and Betatron slices was not known. Different uranium products could easily have shed
different amounts of “dust” from chafing of the outer surfaces that consisted of pure uranium and
oxide for billets and parts of slices, and consisted of “bomb” Mg-fluoride residue of different
chemical composition (trace impurities) and thicknesses in the case of Ur ingots and dingots.

Challenge 2. Each of the physical forms of uranium metal could have shed different
sized components that decayed differently thereby resulting in four simultaneous exponential
decay curves. This assumption implies the floor dust was not disturbed during the residual
period. We know t ea was repurposed, the floor was power washed and vacuumed, and
possibly replaced or resurfaced, and these operations may have, and probably did, disturb the
surficial layer and resulted in peaks of uranium dust being released into the air (resuspended) and
causing different degrees of intake by workers at different time periods.

Challenge 3. The Murray and Brown 1994 result for the Old Betatron Building is not
transposable to the New Betatron Building or to the rest of the GSI building complex. The
nearest Building to the Old Betatron facility was Building 10 that was located 100 yards from it.

In short, the actual physical attributes of the components of intake dose during a given
year are not known. The mathematical assumptions that indicate smoothly changing values are
mere suppositions that are pseudoscientific and not defensible. The Sharfi data on which SC&A
depends for validating its model assumptions, clearly is surrogate data. So SC&A has substituted
one discredited surrogate source, the slug production facility of TBD-6000, for another used by

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Rather, those dramatic findings should persuade the Board that NIOSH is unable to bound GSI intake
doses with sufficient accuracy for Appendix BB and SEC-00105. It is really not relevant that SC&A
can do so,

ls it now perceived that bounding doses at GSI with sufficient accuracy under SEC-00105 and
Appendix BB has switched from being a primary NIOSH task to a primary SC&A task? Is that your
view and that of the Board? If so, | strongly disagree.

TED KATZ: Please distribute this e-mail to all members of the TBD-6000 work group and staff and
to all members of the full Board. Thank you in advance.

My additional questions:

1. Is it Dr. Ziemer and SC&A's position that the ultimate utility of the alternative SC&A method for
calculating uranium intakes at GSI could be the alternative model can be adopted by NIOSH to bypass
the 7.16.12 SC&A findings that the current NIOSH method for calculating intakes fails to pass any of
the Board's five SD criteria? In other words, does this new paper offer NIOSH a way to do an end
around the SC&A findings without NIOSH having to do any work? That would be improper in my view.

2. Is it still your position that Dr. Ziemer tasking SC&A to develop an alternate uranium intake
method, another new (aka alternate) model not based on sufficient real measured data at GSI, is
justified by SC&A's assigned and contracted "evaluative" role to monitor the quality of NIOSH
science?

If so, | would feel more comfortable hearing this response directly from Dr. Ziemer directly
rather than trying to obtain the tasking correspondence via FOIA/FACA.

The interpretation that SC&A is merely performing an assigned, valid federal contract
"evaluation" function strains my sense of (a) the definition of the word "evaluate", and (b) it runs
counter to my view of SC&A's proper role as the "Board's technical advisor" or contractor. It seems
as though SC&A is acting as NIOSH's technical advisor and partner in producing the alternate method
paper.

Question: Please clarify for me why this separate SC&A tasking was done off the record in a
non-transparent way?

3. Who else besides Dr. Ziemer approved the SC&A tasking of the "alternate" method paper? More
specifically:

(a) Did tasking of SC&A by Dr. Ziemer to produce this "Alternative method" Discussion paper
have the prior concurrence of any or all members of the full Board and the TBD-6000 work group?

(b) Was there an accompanying off-the-record vote? If so, was the result recorded?

(c) Was this off-the-record tasking of SC&A action to produce the alternative uranium intake
method known and approved by the Board chairman, Dr. James Melius?

Thank you.
Sincerely -- Dan McKeel 7.27.12 Friday

In a message dated 7/26/12 11:16:19 AM, tmk1@cdc.gov writes:

Hi again, Dan. DCAS has not produced a new method or otherwise responded to the SC&A review of the
surrogate data use for dose reconstructions at GSI. At Dr. Ziemer's direction, SC&A produced this
analysis in support of its review recommendation that NIOSH not use surrogate data for

2of4 8/2/12 6:47 PM



McKeel comment on SC&A alternate uranium intake model

Dan McKeel GSI SEC-105 Co-Petitioner Comment to NIOSH Docket 140 (GSI)
(August 5, 2012)
[Text of the original SC&A paper in black; McKeel Comments in blue]

TO: Advisory Board on Radiation and Worker Health Work Group on TBD-6000 FROM: Robert
Anigstein, Stephen Marschke, and John Mauro, SC&A SUBJECT: Alternative Model for the
Calculation of Uranium Intakes at GSI DATE: July 25, 2012

Alternative Model for the Calculation of Uranium Intakes at GSI

1 Background

During Meeting 84 of the Advisory Board on Radiation and Worker Health, the Board tasked SC&A
with reviewing NIOSH’s use of surrogate data for estimating intakes of uranium at General Steel
Industries (GSI). Anigstein (2012) found that the use of the concentration of airborne uranium dust,
based on the uranium slug stamping scenario as a surrogate for airborne dust concentrations during
uranium handling operations at GSI, does not comply with the five criteria for the use of surrogate
data adopted by the Advisory Board (ABRWH 2010). He also considered other sources of surrogate
data and found issues with the use of these data for GSI. However, as stated in his report, “The
contamination levels on the floor of the Old Betatron Building at the time of the 1993 cleanup,
reported by Murray and Brown (1994), together with the depletion rate and the varying hours of
uranium handling operations at GSI, could be used to calculate the average surficial uranium
concentrations during each year of the operational and residual periods.” We believe that NIOSH
can calculate bounding values of uranium intakes by GSI workers without the use of surrogate
data, In accordance with advice from Paul Ziemer, Chair of the ABRWH Work Group on
TBD-6000, we present an explicit example of our suggested approach.

MCKEEL COMMENT: Given comments Dr. Ziemer made at the October 12, 2010 TBD-6000
that SC&A needs to avoid the perception of “being out front” of NIOSH on developing a method
for calculating air activation doses, | find the bolded passage to be quite amazing. Here Dr.
Ziemer is clearly encouraging and giving SC&A license to develop a new method that NIOSH
should use, by implication, so they “can calculate bounding values of uranium intakes for the
operational and residual periods.” Dr. Ziemer is unequivocally tasking SC&A to carry out
NIOSH’s work to compensate for SC&A's finding that NIOSH’s current method does not meet
Board surrogate data criteria. In other words the client whom SC&A serves (the Board, TBD-
6000 work group) is ordering a method they need to support NIOSH’s contention the agency can
bound uranium intakes during 1953 to 1993 at GSI. Correspondence between the Board DFO,
Ted Katz, and Dan McKeel, which is included in Appendix A to this commentary, indicates that
Dr. Ziemer and Ted Katz collaborated in tasking SC&A to prepare this paper. The petitioners
strongly believe that this tasking is improper, and that this paper should be withdrawn, and
should be rejected by the rest of the Board and should not be allowed to be used by NIOSH.

Allen and Glover (2007) described two pathways for the inhalation and concomitant inadvertent
ingestion of uranium dust: intakes of uranium aerosols during uranium handling operations and the
later resuspension of dust that settled to the floor during these operations. Anigstein (2012) raised
several questions regarding their approach, including the use of a uranium aerosol concentration,
based on surrogate data, the duration of settling of the aerosols, and the possible sloughing off of
large particles of uranium oxide that contribute to the accumulation of uranium on the floor but not to


McKeel comment on SC&A alternate uranium intake model

1988 146 87 0.09 0.93 0.93
1989 114 69 0.07 0.73 0.73
1990 89 54 0.05 0.57 0.57
1991 70 42 0.04 0.45 0.45
1992 55 33 0.03 0.35 0.35
1993 46 28 0.03 0.29 0.29

7 Surficial activi =
b Airbome activity due to resuspension from contaminated surface
bi Intakes continued until July 10, 1993, the date remediation under FUSRAP was completed.
% = airbome uranium activity concentration due to uranium handling activities
18.44 Bq/m’
1,106 dpm/m?
¢) = conversion factor
= 86.400 sid

Va = deposition velocity of 5 ym AMAD particles
7.5 x 107 m/s (Allen and Glover 2007)

2.3 Resuspension Factor

We selected a value of 1 + 10 m for the resuspension factor from the range of values cited by Sharfi
(2012). Anigstein and Mauro (2012) had suggested a value of 5+ 10 masa plausible upper bound
in the model described by Allen and Glover (2007). Use of such a value would have made the
results of their model more claimant favorable. However, as we shall demonstrate, the present value
is more appropriate for our proposed alternative model.

MCKEEL COMMENT: The above paragraph indicates that SC&A resuspension factor numbers
change on a whim. Anigstein and Mauro (2012) had forcefully argued for the 5-fold higher
number, but now develop a new alternate model for use by NJOSH that revises the number
downwards to an admittedly less claimant favorable 5-fold lower number. How can anyone
accept this as good defensible science? This type of flip-flop reasoning makes a mockery of that
concept. There has been a huge amount of agonizing with tortuous unscientific reasoning,
speculation really, about what resuspension factor should be used for OTIB-70. The answer is
obvious. All the estimates are only guesses. Nothing can substitute for having real measured
resuspension values as a meters/sec rate and as units of radioactivity/sec which would be even
better; neither of these data is known for GSI. Thus, using contrived resuspension factors not
based on real measured data is employing surrogate data. Note that Sharfi (2012), which SC&A
has latched onto for reasons that escape me, gives a “range of resuspension factors.” All of these
numbers are made up, educated guesstimates. They are not real values that are science based

Reviewing some of the resuspension factors cited by Sharfi (2012), we note that a factor of | + 10

m is appropriate for a decommissioned facility in which surfaces would have been cleaned or
washed, and no fresh radioactive material would have accumulated (Abu-Eid et al. 2002, p 4). A

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McKeel comment on SC&A alternate uranium intake model

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Figure 2. Elevation Drawing of New Betatron Building—Detail (NRC 2009)

Page 10

MCKEEL COMMENTS:

1, The New Betatron Building elevation drawing cannot be used to calculate a building dimensional
model. Note the height of the control room is not shown. This is a side view sketch, not a blueprint
and the doorway dimensions are not given. Nothing is to exact scale. One sand filled wall is said to
be 11 ft. thick and the other 12 ft. thick, which makes no sense based on other drawings we have of
the same structure. What one can see is the different height between the exposure room and the
tunnel to the left is much larger for the New Betatron Building than it appears to be for the Old
Betatron Building pictured below.

2. The photo view of the Old Betatron building that follows is dimensionless. The ground is
obscured because of the angle of view prevent seeing the ground. Perspective distortion prevents the
truck to be used as a measurement marker as the distance from truck to building is not known.

Figures 2 and 3 are thus entirely worthless for making any definitive statements about building
volumes and dimensions. No one has made any serious attempts to obtain engineering drawings,
including “as built” plans from the Army Corps of Engineers or from GSA, which sold the Old
Betatron building and contents in 1974 as it was government owned.

Exact building dimensions are required to accurately model air flows or building air turnover rates as
shown at both Blockson and Texas City Chemical plants that processed phosphate rock to extract
uranium ore for the AEC. In the process radon gas was released. SC&A developed a radon model
that NIOSH employed that was rejected by the full Board and led to approval of both SEC-58 for
Blockson and SEC-88 for Texas City Chemicals based on the defective SC&A radon model.

= JS-