DW McKeel reply to White Paper 11/9/08

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DRAFT

(Board got 10.31.08, McKeel 11/6/08)

Author? Agency? Date of report?

Note: all scientific reports should include such information

WHITE PAPER FOR GSI APPENDIX BB REVIEW

For Discussion Purposes Only

Background

The NIOSH dose estimate for General Steel Industries (GSI) employees is described in 

Appendix BB to Battelle 6000, approved on June 25, 2007. This dose estimate was

reviewed by SC&A and documented in a report dated March 17, 2008. The report was

subsequently reviewed and made available on the OCAS website in April 2008. Neither

report had the advantage of using film badge data later retrieved from Landauer Inc. This

white paper describes the film badge data as well as analyzes the film badge results. It

also identifies several inconsistencies in the SC&A report and the effect of correcting

them. Lastly, the white paper will examine the effect of the film badge results on these

corrected values.

(DAN MCKEEL comments in red) Why was collecting and reporting the Landauer film

badge data delayed so long? I obtained part of these data, said to represent 30 GSI

workers in 2006 and so informed both SC&A and NIOSH (possibly the Board as well) in

2006. Both agencies declined to obtain the Landauer data then.

NIOSH needs to document when it requested and when (date)) NIOSH obtained these

film badge data and made it available to the Board and to SC&A. Why did NIOSH not

inform the petitioners these data had been obtained so they could at least have obtained 

what NIOSH had through the FOIA process. Neither Dan McKeel nor Pat Coggins, the

GSI petitioners, or advocate John Ramspott were so informed. Why not? NIOSH and 

SC&A should now make available to everyone concerned ALL the correspondence and 

contact notes it had with Landauer. My main contact was Chris Passmore.

Analysis of Film Badge Data

Data

This section should begin with basic information physically characterizing the Landauer

data as follows: From whom to whom, date requested and received, number of pages,

format (hard copy, CD, electronic file with file name and size in MB), what were the

request data, names of the two film badge project managers at GSI that were provided to

Landauer and SINEW by Dan McKeel (fee charged for research and copying).

One of the Betatron operators cited in this white paper informed me that David Sundin of

OCAS supplied the worker with his film badge data that consisted of 20 pages with other

names redacted. The worker said that all 19 data pages were “completely unreadable.”

The researcher at Landauer who I worked with apologized that many of the pages I

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would receive would also be unreadable despite valiant efforts on their part to provide the

best available data. Her warning turned out to be accurate, the tabular text on some pages

being a grey blur. NIOSH needs to disclose what percentage of the total data in terms of a

readable/total number of GSI film badge data pages they received from Landauer were

entirely decipherable.

NIOSH also needs to disclose how much Landauer charged them for the GSI badge data.

Our bill was between $200-300.

What percentage *number/total” of the persons with badge data were (1) currently

deceased, (b) had filed or had filed by their survivors an EEOICPA claim on the worker’s

behalf. How many claims and cases are we speaking about?

This white paper should note than NO (zero) neutron film badge measurements are

recorded in any of the Landauer data as was the case in the data on 30 GSI workers that

McKeel obtained in 2006.

The oldest data received from Landauer covers the week beginning January 1, 1964 (a

Tuesday). The next oldest data covers the week beginning January 6, 1964 (a Sunday)

followed by the week beginning January 13, 1964. The data continues to cover every

week with the last week covered being the week beginning December 10, 1973.

The data provides the last name of the person to which the badge was assigned. It also 

provides the results of the badge processing. An “M” was recorded for readings that

were less than the recording level of 10 mr. The current reading as well as the

cumulative dose for the calendar quarter and year was included. The report also included 

a cumulative dose for the individuals’ entire employment at the site.

How does NIOSH or would Landauer know or did determine that the badge data was for

the entire employment period for these individuals? Did NIOSH verify this with their and

DOL’s employment data from the individual claims?

However, it is important to realize the beginning of this tabulation is the day that person 

started wearing a film badge, not the day the individual actually began employment.

Lastly, the report indicates the number of times the person was monitored by film badge

and the first week he was monitored. The early reports indicate 17 people were

monitored beginning on November 6, 1963. However, the weekly reports prior to 

January 1, 1964 were not recovered.

The question is, what specific attempts did NIOSH or SC&A make to obtain earlier film

badge data from DOE/HASL or other badge vendors of that time period such as Picker

C-ray that was active at the Dow Madison sister site?

A spot check of these values indicates several people were often missing from the report

in late December and would show up again in January. The cumulative number of

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badges was not increased while the names were missing. This likely indicates vacation 

time was accounted for in this total.

A total of one hundred eight different names were recorded between 1964 and 1973.

Landauer told McKeel they only had any GSI data for 30 GSI workers, a huge

discrepancy with this statement. NIOSH needs to verify with GSI workers that all 108

names were actually GSI employees. A GSI Betatron operator cited in this report

furnished McKeel a GSI seniority list from 1963-64 with 91 names, 61 of which were

badged. Magnaflux operators who operated in buildings 8/9/10 were not badged. Again,

the Board and work group need to check the NIOSH/OCAS and Landauer

correspondence to investigate this huge discrepancy.

Also, if 17 of the 108 were isotope people, then what were the job descriptions of the

other 91 names of badged workers?

There were never that many names assigned a badge at any one time.

What was the maximum number of names at any one time?

Through June 1966, a total of 6999 badge readings were recorded for how many

individuals. Of these, 22 were recorded at or greater than the 10 mr recording level. For

the full amount of data, from 1964 through 1973, a total of 16292 individual badge

readings were recorded with a total of 49 recorded greater than 10 mr. Also, there were

114 badges recorded as “Betatron CTL” for the Betatron Control room. The last was the

week of February 6, 1966. All 114 readings were less than 10 mr.

In the annual summary film badge data McKeel/SINEW got from Landauer in 2006,

there were 3 individuals with far higher cumulative doses than any others. The highest

level was an isotope person among the top two people listed on the 1963-64 GSI seniority

list. Why does NIOSH not cite these values and attempt to explain them as NOT BEING

BOUNDING, WHICH WOULD BE THE MOST CLAIMANT FAVORABLE

ASSUMPTION FROM THE LANDAUER INDIVIDUAL BADGE DOSIMETRY

DATA?

Representativeness of Data

Individuals that clearly identified themselves as being associated with radiography 

(Radiographer, Radiographer Helper, Film Processor, etc) during worker outreach 

meetings (a total of five people) were checked against the film badge data. The names of

all five appear in the records.

However, as alluded to earlier, there were far more than 5 Betatron operators between

1953 and 1966 (around 100, at least). DOL and NIOSH should have extensive job 

descriptions of the named Landauer individuals from their CATI interviews and other

EEOICPA claims information databases.

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This reports fails to mention major classes of job classifications in the GSI industrial

radiography department. Such workers included “Chem Lab” workers and the isotope

certified subset who worked with three gamma sources not mentioned in this white paper

that contributed to dose, Betatron operators, Magnaflux operators, layout people who 

planned shots, and film readers/processors who inspected the x-rays for MCW uranium to 

ensure the x-rays produced were technically satisfactory. Betatron operators also handled 

the larger Co-60 source that was used in the Betatron buildings with the Betatrons

“locked out.”

Also, an article from a company publication named 11 people that had passed a 32-hour

course in Health Physics. The article indicated the course was to “qualify them as

radiographers in handling radioactive isotopes”. All 11 names were checked against the

dosimetry reports and all 11 appear in the records.

Does the author of this report recognize that “isotopes” refers to two GSI Cobalt-60

sources, and an iridium-192 gamma source? These should have been included in the dose

and film badge data analysis since they were used during the AEC MCW uranium

contract period at GSI. Why was this not done? In addition, St. Louis Testing conducted 

additional Co-60 gamma source studies of GSI castings, some on the outside near the Old 

Betatron Building. He attended and testified at the Oct. 9, 2007 SC&A-Anigstein meeting 

in Collinsville, IL.

Note: The 250 Kvp portable industrial x-ray device at GSI, contrary to the mandate of

OCAs-IG-002 and the Act that all source term doses must be considered during dose

reconstruction in the production period (1953-1966), omission of dose due to this source

term in Appendix BB, the white paper, and NIOSH’s SEC-00105 evaluation report is a

serious misapplication of its own technical guidance that needs to be explained in detail.

McKeel and SINEW have maintained since 2005 that the three gamma sources and the

250 Kvp x-ray sources at GSI (1) have not and cannot be accurately characterized by

either NIOSH or SC&A, and (2) on this basis alone an 83.14 SEC was the proper course

for GSI. We still maintain the same position.

With all 17 people known to be associated with radiography included in the records,

This is a totally untrue and inaccurate statement. Only a subset of 11 of 17 “Chem Lab”

radiographers was isotope trained. The number of 17 thus may include all Chem

Lab/isotope” workers. It certainly does NOT include all GSI betatron operators from

1953 to 1973 by any means. NIOSH should be well of this fact three years into intensive

study of this AWE site.

it appears that the all the employees directly associated with radiographers were assigned 

a film badge at GSI between 1964 and 1973.

Completely untrue and inaccurate statement as explained above.

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It also appears these radiographers were indeed the ones who performed the source

radiography.

Not true or accurate, either. Many GSI Betatron operators were not isotope certified and 

never worked in the Chemistry Lab (a $1,000,000 facility pictured in John Ramspott’s

elegant GSI workbook and as described above. This can be easily verified with current

Betatron operators. Many more than 5 Betatron operators and helpers testified at the three

GSI worker meetings held in 2006 in addition to the 10/9/07 SC&A outreach meeting.

Verbatim (names, job redacted) transcripts are available under GSI on the OCA website

and (hopefully) on the O drive in unredacted form.

The betatron buildings were described as a very busy place. With only 108 names

appearing over the entire time span, it appears equally clear that ancillary workers (those

working to move or repair castings, maintenance personnel, etc.) that were not directly 

involved with the radiography were not issued film badges.

That is not entirely clear, either. NIOSH has not adequately categorized the jobs of those

108 individuals and, I suspect, cannot do so,

The question of how representative these readings are for years prior to 1964 must be

asked. Only one betatron existed at the site prior to 1963. During 1963, a new betatron 

building was built and a betatron was moved from the Eddystone, PA site to the Granite

City site. The “new betatron” as it was called was reportedly upgraded when it was

moved to Granite City. Operators indicated that the new betatron had a higher output

than the old betatron.

More importantly, a supervisor for the Betatrons described work prior to 1963 as much 

slower paced. He indicated prior to 1963 the radiography was essentially a quality 

control function that checked a sampling of castings.

This is a misleading statement that unfairly and with little compelling data indicates that

1953 to 1964 Old Betatron work was trivial. This is not true! The proof is that AEC and

MCW selected GSI to perform Betatron 24 Mev particle accelerator-based x-ray work to

characterize the quality of its extremely valuable uranium metal products. The fact is that

ten years+ of GSI film badge dosimetry data (1953-1963) has been lost, destroyed, at

another badge vendor ant not found, or withheld. The extent of film badge data on hand

at NIOSH appears to be more extensive (108 workers) than Landauer told McKeel and 

SINEW it possessed two years earlier in written communications (30 GSI workers). This

discrepancy casts doubt on the validity of NIOSH assertions of this entire white paper.

In 1963 the role of radiography at GSI changed from “two people who worked there part

time to, as these guys have said, seven days a week, 24 hours a day and we were 500

percent overscheduled”. Another worker indicated that 1963 to 1966 was the peak 

production period.

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Dan McKeel wonders why NIOSH so readily accepts one GSI worker’s testimony that

supports its thesis on why 10+ years of missing badge data is unimportant, while it

steadfastly refuses to accept the sworn testimony of 11 Dow workers who say that Dow

Madison shipped to Rocky Flats large amounts of thorium alloy, of the same type DOE

now accepts was used in nuclear weapons during 1957-58 at MCW. This policy appears

to be very capricious and self-serving to this petitioner.

It appears after 1963 the radiography at GSI occurred much more often and included a

higher output machine. This indicates the film badge readings starting in 1964 would not

necessarily be representative of the pre-1963 dose but it should be higher and thus

bounding.

This is pure speculation using fuzzy logic based on subjective limited information. Terms

such as “much more” and “should be” unless quantified and objectified are

uninformative, misleading and have no place in scientific communications. The

petitioners CHALLENGE NIOSH’s assertion the 64-66 questionable badge data are in 

fact bounding, given the very much higher doses several individuals have recorded (up to

30,000 mrem lifetime that Landauer might have occurred over a short time period, I can 

supply the person’s name)

I must note that workers used their badges only in the Betatron buildings, probably while

handling the Co-60 sources, one of which was used in a concrete roofless structure in 

Building 6, and took them off when working in the Chem Lab, for example. Only two

GSI workers could produce AEC badge dosimetry reports, and all agree the badge data

was not reported back to them as either positive or negative feedback concerning safety 

of the 24-25 Mev Betatrons, the 250 Kvp source, or the multiple gamma NDT sources

used at GSI.

The badges were red Landauer types and the workers relate they were loaded with 

standard dental film packs that are “useless” according to our experts from Milwaukee

School of Engineering (VK and RK). The badges did not measure neutrons. This white

paper fails to address the accuracy of film badges for monitoring 24-25 Mev x-ray 

sources. Doing this is a necessity.

Analysis

From 1964 through the end of the contract period (June 1966) only 22 of the 6999 film

badges processed resulted in a reading greater than 10 mr.

List the three individuals with cumulative doses in the 6,000, 7.000 and 30,000 mrem

ranges. These data stood out in the Landauer badge data I obtained in 2006.

With 99.7% of the readings being below the recording level, statistical analysis is limited.

The rank-file 95th percentile is obviously less than 10 mr. If a lognormal distribution is

assumed, the distribution results in a geometric mean of 2.06x10-5 mr/badge reading. The

geometric standard deviation of this distribution would be 100. This results in a 95th

percentile of 0.04 mr/badge reading. While there is no standard value considered too

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high for a geometric standard deviation, a value of 100 is very high. If a normal

distribution is assumed, the mean is 0.46 mr/badge reading with a standard deviation of

29.8 mr. This results in a 95th percentile of 49.4 mr. Since a normal distribution is

symmetrical about the mean, this distribution implies 49.3% of the values of this

distribution are less than zero. Obviously it is impossible for the true radiation dose to be

less than zero. While a small percent of negative values may still represent a distribution 

that is an acceptable approximation of the true distribution, nearly half the values being

negative is clearly not a good approximation.

Next, the average badge reading for each individual was determined. The individuals

were monitored for different periods and lengths of time. Therefore, to normalize the

values an average weekly reading was determined for each individual. That is, each 

person’s recorded dose was divided by the total number of badges he was assigned. A

distribution of these averages was then determined. Sixty-seven of the eighty-nine

individuals (approximately 75%) had no dose recorded at or above the recording level of

10 mr. The average of these values was 0.371 mr with a standard deviation of 2.76 mr.

Again, this results in a normal distribution with a large fraction of the values (44.6%)

being less than zero. If a lognormal distribution is assumed, the geometric mean is

0.0065 mr with a geometric standard deviation of 16.7. The 95th percentile of this

distribution would be 0.673 mr. With the high percentage of censored data and a GSD

that is still relatively high, additional distributions were explored.

From the above description, it is clear that no analysis of this data is going to provide a

distribution that clearly well represents the data.

In plain English, the Landauer GSI film badge data is not representative because it is very 

incomplete and inaccurate and is based on a flawed radiation safety program. The

workers say they mistrusted the badge data, for good reasons that are partly evident in

this analysis. These data cannot be used to reconstruct GSI doses with sufficient

accuracy, and actually support my and SINEW’s position that an 83.14 SEC should be

issued knowing now that the scanty real dosimetry data for this site is very incomplete

and flawed.

This is due to the high percentage of censored data. As an alternate approach, the

recording level (10 mr) was substituted for each reading recorded below the recording

level. As with the last analysis, a weekly average reading for each individual was then 

determined using these substituted values. A distribution of these values has an average

of 10.35 mr with a standard deviation of 2.75 mr. That produces a 95th percentile of

14.87 mr. If a lognormal distribution is assumed, the geometric mean is 10.2 mr with a

geometric standard deviation of 1.15 for a 95th percentile of 12.78 mr.

The parameters of both of these distributions are more reasonable than the previouslyreported distributions. The normal distribution does not imply a large fraction of the

readings have a negative value. The GSD of the lognormal is not exceedingly high and

the median and 95th percentiles of both distributions are relatively similar. The

substitution is obviously a bounding substitution (replacing those recorded as less than 10 

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mr with 10 mr). It is equally obvious that with 99.7% of the values replaced with this

substitution that the result is a bounding estimate of the recorded dose. However, in 

order to insure the doses actually recorded are accounted for, the 95th percentile is used.

This is essentially the upper bound of a bounding distribution. Therefore, the 14.87 mr

per reading (per week) is used for the rest of this white paper.

This whole analysis should be submitted to an expert in statistical analysis. Our position 

is these calculations, with all the negative values are invalid because the primary data is

incomplete and inaccurate. The film used cannot accurately monitor very high energy xrays, photons and electrons, so statistical analysis of the resulting data is futile and

provides very misleading results that should not be used in GSI dose reconstructions.
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Inconsistencies in SC&A review of Appendix BB

This entire section is misleading and superficial. What NIOSH needs to do is to

respond point by point to SC&A’s review of Appendix BB and each of the 13 

findings that conclude NIOSH ignored several source terms and neutron doses, and

seriously underestimated external doses. The work group and SC&A should review

the unredacted versions of the McKeel and Ramspott critiques of Appendix BB and

resolve those finds as well, since the McKeel critique now represents the view of a 

co-petitioner of SEC-00105.

Betatron Operator Exposure to Apparatus

In the SC&A review of Appendix BB, photon dose from the betatron apparatus was

based on two different scenarios. For the “short shot” scenario, the casting was assumed 

to be 9 feet from the betatron target and the betatron operators’ distance from the

apparatus was assumed to vary uniformly between 3 feet and 6 feet. The operator is

therefore assumed to be at a distance of 3 feet to 6 feet from the casting. However, the

photon dose from the casting was based on the assumption that the operator was 1 foot

from the casting half of the time and 1 meter (approx. 3.3 feet) from the casting the other

half. Combining these two scenarios effectively puts the operator in two places at one

time.

Using the same technique described in the review, the dose from the apparatus can be

recalculated to be consistent with the other scenarios. That is, the operator is assumed to 

be 1 foot from the casting half of the time (5 feet from the apparatus for long shots, 8 feet

for short shots). The other half of the time, the operator is assumed to be 1 meter from

the casting (approximately 2.7 feet from the apparatus for long shots, 5.7 feet for short

shots)

The formula on page 19 of the SC&A report were used to calculate dose based on a

uniform varying distance. However, since the exposure scenario elsewhere in the report

indicates a dose rate from two set distances was used, this formula is not necessary. The

inverse square law was used to determine the initial exposure rate at the various

distances. These were based on the exposure rate of 15 mr/hr at 6 feet. The initial

exposure rates are then 73 mr/hr at 2.7 feet, 16.5 mr/hr at 5.7 feet, 21.6 mr/hr at 5 feet, 15

mr/hr at 6 feet and 8.44 mr/hr at 8 feet.

The formula on page 20 was used to determine the dose over the exposure period taking

into account the decay rate. This formula assumes an operator is exposed from the

moment the Betatron is turned off to the end of the assumed period of time (11 minutes

for the short shot scenario, 15 minutes for the long shot scenario). However, when the

dose from the uranium metal and steel after the shot was calculated in the report, it was

assumed that the operators were not exposed for the first 5 seconds after the shot. This

was described as the minimum amount of time it would take to exit the control room and

reach the vicinity of the metal object. In order to allow this same assumption for the

apparatus dose calculation, the formula on page 20 is adjusted to:

Daniel/McKeel 11/9/08 7:36 AM

Deleted: betaton
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Daniel/McKeel 11/9/08 7:29 AM !

" "

"

"

= =

2

1

0 0

60

( )

60 ( )

1 2 t

t

t t

t R e e

e dt RX t

#

# #

#

In this equation, t1 is the time from the end of the x-ray exposure until the operators reach 

the betatron (5 seconds). Also, t2 is the time from the end of the x-ray exposure until the

operators leave the betatron area (11 minutes for the short shot scenario and 15 minutes

for the long shot scenario).

In order to minimize rounding errors, the dose rates in the SC&A document were first

recreated. Next, the exposure was calculated as described above and the exposure for the

two appropriate distances were averaged. This average was multiplied by the number of

“shots” described in Table 16 to arrive at the exposure per shift.

Railroad Shot Exposure Scenario

Dose rates outside the new and old betatron building were modeled based on two 

scenarios. One was a “center shot” in which the betatron was in the approximate center

of the shooting area while an x-ray exposure was occurring. The other was a “railroad 

shot” in which a casting is assumed to be exposed while sitting on a railroad car straight

in from the equipment door. The betatron has limit switches that prevent a shot from

occurring in this position but operators indicated they were ordered to defeat these limit

switches by “flipping the head” of the betatron and perform shots in this position.

The author does not understand what was done. Allis-Chalmers that manufactured both

GSI Betatrons recommended railroad track (RR) shots. This was done routinely in the

1953-1963 (see below).

Flipping the head was a disapproved, known to be dangerous and unsafe maneuver that

took the Betatron beam out of the approved exposure zone and subjected the control

room to extra exposure. Noteworthy is that SC&A’s MCNP modeling showed highest

exposures in the Betatron control rooms that were designed to protect operators.

Footnote: Our GSI Old Betatron building site visit photos from September 2006 clearly 

show a port through the control room wall for the chain that opened the large Co-60 “pig”

to expose the inner Co-60 “pill.”

The operators went on to indicate that this was not done until the supervisor present in the

early 1960s left the company and was replaced by another. This supervisor left the

company on 6/30/1966 which is the last day of the uranium work. This information

indicates the railroad shots occurred after the covered period.

No, this is an incorrect interpretation. RR Betatron shots were done THROUGHOUT the

production period, confirmed 11/8/08 with one of the knowledgeable GSI Betatron

operators cited in this white paper report.

The analysis performed by SC&A summarized photon dose rates based on the railroad 

shot scenario. However, some dose rate information for the center shot was included in

the report.
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Table 2 shows that the exposure rate in the control room of the new betatron building is

calculated to be 1.9 mr/hr for the railroad shot and 0.3 mr/hr for the center shot. Likewise

the neutron dose is calculated to be 0.6 mrem/hr for the railroad shot and 0.3 mrem/hr for

the center shot. Table 3 provides two exposure rates for the control room of the old 

betatron building. These two values were averaged when calculating values for Table 16.

The average of the railroad shot photon exposure rate was 1.05 mr/hr. The SC&A report

provided no values for a center shot, however, values for the center shot can be calculated 

similar to those calculated for the new betatron building. This was done using MCNP to 

find control room values for both neutron and photon doses. The same two points in the

control room were used. Only the location and orientation of the betatron and the steel

were changed.

No actual (real) neutron doses were available at GSI to validate the neutron exposures so 

we challenge the use of purely virtual MCNP modeled neutron and gamma doses at GSI.

250 R/min Exposure Rate from Old Betatron Machine

SC&A used a betatron output of 250 R/min from both the new and old betatron

machines. This was based on a letter from a former Allis Chalmers employee. It was

also noted that this was consistent with a GSI employee recollection of 160 R/min once a

35% reduction for the beam compensated was factored in. However, the seven tube

outputs listed by the Allis Chalmers employee represent shipping dates between 

12/29/1969 and 5/31/1973. In the paragraph immediately preceding this table, the

employee wrote:

Tubes manufactured in the early 1950s produced outputs between 125-150 R/M,

the 1960s between 200-275 R/M and by the late 1970s, between 300-375 R/M @ 

25 Mv.

Both Betatrons were built in the early 1950s but the new betatron was originally in

Eddystone, PA. That betatron was moved to GSI in 1963 and reportedly underwent an 

upgrade at that time. The statement above from the Allis Chalmers employee indicates

the early 1950s model would have an output between 125 and 150 R/min. This is also 

consistent with GSI employee recollections. During an August 21, 2006 meeting, an

operator indicated the output of the new betatron was between 200 and 250 R/min but the

old betatron “couldn’t do that good”. He indicated the old betatron had an output of

“probably 100, 110 at maximum”. The SC&A report relied on the recollection of a GSI

employee that he recalled 160 R/min on the new betatron. The same employee in a

meeting held on October 9, 2007 indicated that a 10,000 R shot would have taken 1 hour

and 15 minutes (133 R/min) but that the old betatron would have taken longer because it

did not have a capacitor bank.

The compensator used to flatten the photon flux causes a reduction of about 1/3 of the

beam intensity (35% per the SC&A report). The Allis Chalmers employee was referring

to the uncompensated output of the betatron. If the maximum 1950s output is assumed 

(150 R/min) the compensated beam would have an output of approximately 100 R/min.

Daniel/McKeel 11/9/08 7:37 AM

Deleted: betatrons
DW McKeel reply to White Paper 11/9/08

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This is consistent with the GSI employee recollection. Either way, both GSI employees

clearly remember the output of the old betatron being lower than the output of the new

betatron. Therefore, the rest of this white paper will consider the uncompensated output

of the new betatron to be 250 R/min and the uncompensated output of the old betatron to

be 150 R/min.

The Betatron output varied short-term due to heating and degradation of the capacitors.

Fluctuations in beam output intensity were not routinely recorded at any time. There was

apparently a meter that gauged and recorded power input variations to the machines.

Inconsistent Assumption between Photon and Beta dose

A summary of the annual doses is presented in the SC&A report. Section 2.6.1 describes

the photon and neutron doses while Table 21 in section 2.6.2 describes the beta doses. In 

order to estimate the beta dose, an estimate of the amount of uranium work was

performed and a mixture of uranium and steel work was used. However, in order to 

estimate the photon and neutron doses, no uranium work was assumed. This leads to the

inconsistent assumption that employees were working both with and without uranium at

the same time. The remainder of this white paper will use the estimated uranium versus

steel work time used in the beta dose calculation.

The effect of adjusting for these inconsistencies is shown in the next two tables. The first

table is a recreation of Table 16 from the SC&A report. The second table is the same

table with the values adjusted as described above. The values in the first table were

recreated as best as possible from the SC&A report as well as MCNP output files

provided by SC&A. The recreation produced some differences between this table and

Table 16 in the SC&A report due primarily to different rounding errors. One value, the

photon exposure from uranium metal in the new betatron building, was incorrectly

reported in the original SC&A report as 0.66 mr/shift and later corrected to 6.8 mr/shift.

However, the recreation below resulted in a value of 6.56 mr/shift. This represents the

largest difference in attempting to recreate this table. The 6.56 mr/shift was recreated 

starting with values from tables 8 and 9 from the SC&A report. While round-off error

may explain some of the difference, it cannot explain it all.

Unexplained errors mean more uncertainty in the bounding dose calculations. How was

this handled?

Daniel/McKeel 11/9/08 7:37 AM

Deleted: can not
DW McKeel reply to White Paper 11/9/08

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Recreation of Table 16 from SC&A review of Appendix BB

Metal Type of shot Number

per shift

Fraction Source of

radiation

Duration

(h/shift)

Exposure

(mR/shift)

Neutron dose

(mrem/shift)

25 MeV

Control room 1.6 3.11 0.92

Metal 5.87 0.35

Doughnut 5.87 34.56 Short 32 64%

Total 38.02 0.92

Control room 6.0 11.66 3.44

Metal 1.5 0.66

Doughnut 1.5 13.03 Long 6 36%

Total 25.35 3.44

HY-80

Composite 100% 33.46 1.82

Control room 6.0 11.66 3.44

Metal 1.5 6.56 0.67

Doughnut 1.5 13.03 Uranium Long 6

Total 31.25 4.11

24 MeV

Control room 1.6 1.68 0.59

Metal 5.87 0.35

Doughnut 5.87 34.56 Short 32 64%

Total 36.58 0.59

Control room 6.0 6.29 2.20

Metal 1.5 0.66

Doughnut 1.5 13.03 Long 6 36%

Total 19.97 2.20

HY-80

Composite 100% 30.60 1.17

Control room 6.0 6.29 2.20

Metal 1.5 6.56 0.67

Doughnut 1.5 13.03 Uranium Long 6

Total 25.88 2.87
DW McKeel reply to White Paper 11/9/08

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Daniel/McKeel 11/9/08 7:29 AM

Adjusted Table 16 from SC&A review of Appendix BB

Metal Type of shot Number

per shift

Fraction Source of

radiation

Duration

(h/shift)

Exposure

(mR/shift)

Neutron dose

(mrem/shift)

25 MeV

Control room 1.6 0.50 0.52

Metal 5.87 0.35

Doughnut 5.87 14.37 Short 32 64%

Total 15.21 0.52

Control room 6.0 1.86 1.96

Metal 1.5 0.66

Doughnut 1.5 10.28 Long 6 36%

Total 12.79 1.96

HY-80

Composite 100% 14.34 1.04

Control room 6.0 1.86 1.96

Metal 1.5 6.56 0.67

Doughnut 1.5 10.28 Uranium Long 6

Total 18.70 2.63

24 MeV

Control room 1.6 0.07 0.22

Metal 5.87 0.21

Doughnut 5.87 8.62 Short 32 64%

Total 8.90 0.22

Control room 6.0 0.27 0.84

Metal 1.5 0.39

Doughnut 1.5 6.17 Long 6 36%

Total 6.83 0.84

HY-80

Composite 100% 8.16 0.45

Control room 6.0 0.27 0.84

Metal 1.5 4.08 0.40

Doughnut 1.5 6.17 Uranium Long 6

Total 10.52 1.24
DW McKeel reply to White Paper 11/9/08

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Application of Film Badge Data

With an analysis of the film badge data and the adjustments to the SC&A model in place,

it is possible to put the information together. A briefing of the model was previously 

given to a working group of the Advisory Board by SC&A. An overview of the dose was

provided in a table format during that briefing.

Dan McKeel has never seen this table nor was he informed of its existence. What meeting 

(work group, which one? Or full Board meeting number and date and transcript

Reference) on what date was this Table reviewed, please?

The table is a recreated below.

Estimated Annual External Exposures of Betatron Operators

External exposure Skin dose (rads/y)

(R/y)

Neutron dose

Years (mrem/y) Hand & forearms Other skin

SC&A NIOSH SC&Aa SC&A NIOSH SC&A NIOSH

1952-

1957b 12.4 5.8 470 27.2 19.4 2.5 1.8

1958 12.4 5.8 470 25.9 19.4 2.4 1.8

1959-1960 12.4 5.8 470 24.7 19.4 2.4 1.8

1961 12.4 6.3 470 28.1 22.3 2.6 2.0

1962 12.4 5.1 470 20.9 16.2 2.2 1.65

1963 12.4 2.8 470 7.0 4.4 1.4 0.4

1964 13.6 2.2 735 3.8 1.6 1.2 0.15

1965 13.6 2.1 735 3.3 1.2 1.2 0.11

1966c 6.8 1.0 368 1.4 0.37 0.6 0.034 a Neutron doses not assessed by NIOSH

b NIOSH assumed covered period began 1953 c Total during covered period: January 1 – June 30

There is a huge difference between SC&A and NIOSH external exposure that again casts

serious doubt on NIOSH’s ability to perform DR at DSI with sufficient accuracy.

Supports my and SINEW’s repeated 83.14 SEC requests for the GSI site.

The photon dose of 14.87 mr/week from the film badge data can be multiplied by a 50 

week work year resulting in an annual exposure of 743.6 mr/yr. The values in the table

above were recreated and then adjusted for the inconsistencies described earlier. After

that, a value of 743.6 mr/yr was substituted for the photon exposure and the neutron and

skin dose was adjusted proportionately. The resulting dose is shown in the table below.

Adjusted Annual External Exposures of Betatron Operators

Skin dose (rads/y) YearsExternal exposure

(R/y)

Neutron dose

(mrem/y) Hand & forearms Other skin
DW McKeel reply to White Paper 11/9/08

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1952-1957 0.7436 41 6.733 0.536

1958 0.7436 41 6.369 0.514

1959-1960 0.7436 41 6.009 0.493

1961 0.7436 41 0.550 6.978

1962 0.7436 41 0.431 4.959

1963 0.7436 41 0.224 1.450

1964 0.7436 41 0.160 0.485

1965 0.7436 54 0.156 0.418

1966 0.3718 54 0.076 0.175

A summary comment on the overall effect of the film badge data would be helpful. It

appears these calculations result in a severe attenuation of assigned doses. This usage of

the spotty non-representative Landauer film badge data should not be allowed and the copetitioners strongly object if we understand the above Table correctly. To be more

explicit, for the reasons cited and others that we can put forward as the SEC and

Appendix BB progresses, the use of the fragmentary and still to be validated and 

authenticated GSI film badge data should be prohibited.

NIOSH’s external dose underestimation is highlighted in SC&A’s review of

Appendix BB. This paper and this last table suggests, rather, for example in 1958,

that NIOSH now believes it’s own data in Appendix BB overestimates doses by 8-

fold and that SC&A overestimated doses by up to 17-fold. Since all the dosimetry

calculations up until the badge dosimetry data suddenly appeared were much

higher, the implication of these new Betatron exposure numbers in the last table on

page 7 is quite significant. The new numbers also mean that Attila and MCNPbased external dose models are off by a factor of 8 to 17-fold from real data and this

conclusion is inconsistent with many studies that compare data from these programs

with real measured exposure data.

SC&A NIOSH 12.4 R/yr, SC&A 5.8 R/yr, NIOSH factoring badge data .74 R/yr. a

16.7:7.8:1 ratio.

NIOSH appears to be bolstering its recommendation to deny the GSI SEC-00105 and to

markedly lower the assigned external dose to Betatron operators, further controvert

SC&A’s findings. We strongly recommend the Board reject this new finding.

Respectfully submitted 11/9/2008,

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

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