DWMreply_Allen_8.26.12.doc

monitor the exposed work force with adequate lilm badges except to a few Betatron-
isotope radiographers (n=89 of a work force of at least 3,000 in a given year) for 3 of the
13 covered period years and an even smaller number (n=19 workers) during part of the
residual period of July 1, 1966 through 1973 when GSI ceased operations. Other owners
owned and maintained the GSI property and buildings during the entire residual period
up through 1993, ORNL made an expedited (and inadequate and too limited) assessment
of residual radioactivity in the OBB and NBB only. The finding of no residual uranium in
the GSI New Betatron Building is easily understood now that more detailed facts of the
multiple cleanups. power washing, rewiring and paneling have been laced on the record,
The full extent of uranium contamination of the GSI Old Betatron Building was obscured
by the 1984 cleanup, concrete berm installation in the shooting room, and power washing
in 1984 by the Power Blasting Company. ORNL and DOE did not even survey the
majority of the areas in the transport pathways to and from the loading dock and the Old
and New Betatron facilities where the NDT radiography work on MCW uranium took
place at GSI from 1953 through June 1966.

Heald Machine Company (SRDB 40986 page 10, Figure 2 in this paper).

At the Heald Machine Company, air samples were taken while machining uranium metal
slugs. Values ranged from | to 11 dpm/m3. It is likely coolant was used to cool and
lubricate the uranium while it was being machined so air samples while machining were
not necessarily representative of uranium metal handling. However, coolant is normally
supplied by a fixed nozzle on the machine. Thus, dry uranium metal would be moved to
the machine prior to machining. If significant airborne contamination was caused by this
movement, it would still be present while machining the slugs. Although this activity
may not be directly applicable to the movement of cold uranium metal, they do provide
an indication that actual values are relatively low.

MCKEEL: This was a slug production facility not justifiably similar to GSI operations.
The data is very scanty, insufficient to bound intake doses.

Chambersburg Engineering Co (SRDB 10048 page 39, Figure 3 in this paper)

At Chambersburg Engineering approximately 150 hot uranium slugs were forged into
washers during a two day test. The slugs were dry heated and no ventilation was provided
for the work. A summary of the air samples are provided in Figure 3. The average air
concentration while loading cold uranium slugs into a furnace was 69 dpm/m3 while
loading one slug every 15 minutes and increased to 77 while loading one slug every two
minutes. The maximum air concentration while loading cold uranium into the furnace
was 174 dpm/m3, Air concentrations after heating and while forging were higher and it is
possible some of that airborne contamination caused by this work interfered with samples
taken while loading the furnace.

MCKEEL: This was a slug production facility not justifiably similar to GSI operations.
The data is very scanty, insufficient to bound intake doses.

-13-


DWMreply_Allen_8.26.12.doe

would have accumulated along the entire transport pathway. In addition, uranium metal
products were sometimes stored for several days before and after undergoing NDT
radiography at GSI and being returned to the MCW Uranium Division. This
interpretation of the facts has not been challenged or disputed,

(3) In light of the facts outlined in subsections (1) and (2), DCAS’s statement that
“Thus, the only potential for generation of airborne uranium at GSI would be from the
movement of the metal into position for the examination.” was simply not accurate. The
reasons for making this statement include:

(a) The sentence ignores resuspension of surficial uranium (SC&A’s term), that
is, uranium particles and “dust” that was on surfaces that undoubtedly included the rail
road tracks throughout the entire transport path; the rail transfer cars: the chain hoists; the
overhead cranes; the storage area floors, walls and rafters; buildings 6, 7, 8, 9 and 10; and
the tunnels leading into the OBB and NBB Betatron shooting rooms. NOTE: In a
separate Discussion paper submitted to the Board by Dan McKeel on 8/25/12, the
extensive cleanup and power washing and renovation of the NBB that occurred 1978-
1993, and the power washing that occurred in OBB in 1984, led to a marked and
unquantifiable attenuation of surficial uranium on the NBB and OBB facilities, further
distorting and interfering with accurate quantification of both airborne and surficial
uranium, In spite of all these cleanups and power “blasting” some residual uranium was
demonstrated by ORNL on the floors, in the air vent ducts, and in a small industrial
vacuum cleaner during the DOE/ORNL cleanup that marked the end of the residual
contamination period at GSI in 1993,

Most active manipulation of uranium metal requires the metal to be heated. Typically
uranium in these processes is heated to well over 1000 degrees Fahrenheit. At these high
temperatures, the uranium metal oxidizes readily forming a loose oxide layer that can
easily create airborne contamination. An exception to heating uranium metal during
operations is machining. When uranium metal is machined or cut, it is not normally
preheated. Rather, the area being cut is cooled with machine oil, water or some other
coolant. This not only reduces the release of airborne activity, but also cools the metal to
prevent fuming. In all cases, however, the metal is moved by various means to the
furnace or equipment prior to working. The movement of cold uranium metal presents
such a low potential for airborne uranium that

Page 2

very few air samples were ever taken. Those that were, are often taken while other
operations are also occurring causing the air in the vicinity to be contaminated by the
nearby operations. Therefore, samples intended to be representative of the operation at
GSI must consider not only the type of operation but the potential interferences in the
vicinity.

MCKEEL COMMENT: There are major concerns about this presentation of the facts
concerning the AEC MCW-GSI contract and MCW uranium NDT radiography, First, in


DWMreply_Allen_8.26.12.doc

As with each process described in TBD-6000, the airborne contamination from this
movement of cold uranium metal is not quantified so Appendix BB used one of the
lowest airborne creating tasks as a bounding estimate of the movement of cold uranium
metal, While the task as a whole is not representative of the movement of cold uranium
metal, the movement of cold uranium metal is included in the task.

MCKEEL: This argument also is weak and scientifically indefensible. There really is no
similarity between the slug facility operations and Betatron 24-25 Mev NDT radiography
that produces fission and activation of crusted uranium ingots and dingots. The uranium
is not “cold” following Betatron irradiation; it is “hot” by induced activation and fission
products of uranium caused by the twin GSI 24-25 Mev Betatrons, Mr, Allen and DCAS
cannot deny these salient facts. The last sentence is an argument reductio ad adsurdum.

Criterion 4: Temporal Considerations

SC&A notes that the data used was likely collected prior to 1958 which is therefore not
contemporaneous with the end of the operational in 1966. However, the Board's criterion
indicates the data should be from the same general period unless it can be demonstrated
that the “working conditions, procedures, monitoring methods, and (perhaps) legal
requirements were comparable to the period in question”.

In addressing this, we note that there has never been any indication of any intentional
controls over airborne contamination at GSI. The source of airborne uranium was simply
movement of cold uranium metal in order to position it for x-ray examination. The source
of airborne is then a physical characteristic of uranium metal which doesn’t change over
time.

MCKEEL: Mr. Allen restates the premise that “The source of airborne uranium was
simply movement of cold uranium metal in order to position it for x-ray examination.”
This statement is ridiculous, specious, factually inaccurate, and scientifically indetensible
for reasons already stated: (1) GSI uranium became airborne from handling uranium and
from resuspension and dispersion all along the transport pathway and on many
surfaces—rail transfer cars, chains, cranes surfaces, floors, rafters, ceiling, vents of air
ducts, sweepers, floor traffic —to identify some of them. As is described in more detail in
my 8/25/12 Discussion paper on the 1978-1993 residual period at GSI, several eye
witness cleanup workers and electricians who observed the OBB power washing in 1984
and the renovation and power washing and rewiring of the NBB facility by Michigan
Metals Processing, Water Blasting Company, Dow Chemical in 1984. and possibly later
paneling by Affiliated Metals, the NBB facilities also were used as classrooms with lots
of foot traffic by National Steel/Granite City Steel. Also, as noted previously, SC&A
(first author Joe Fitzgerald), stated in his 2009 Weldon Spring site profile review that
uranium photofission and activation production by 24-25 Mev Betatron x-irradiation
posed another inhalation intake scenario for workers who handled this “hot uranium”
after Betatron exposure, These effects begin to appear in the 6-10 Mev range, The
petitioners have pointed out previously that both DCAS and SC&A have seriously
underestimated the full range of half lives of these Betatron-induced daughter
radionuclides. We have offered several key references from the literature to document


DWMeeply_Allen_8.26.12.doc

hierarchy of data criterion adopted by the Board does not exclude the use of surrogate
data when actual site data is available. The criterion states:

“Surrogate data should only be used to replace data if the surrogate data have some
distinct advantage over the available data and then only after the appropriate
adjustments have been made to reflect the uncertainty inherent in this substitution”

NIOSH agrees the use of the FUSRAP data would eliminate the need for the use of
surrogate data, however, the uncertainty associated with back extrapolating the data 40
years would likely far exceed the uncertainty associated with the use of more
contemporaneous sources of surrogate data.

MCKEEL: Here DCAS uses extremely tortured logic to ignore and circumvent SC&A’s
scientifically defensible finding that DCAS violated Board surrogate data criterion |. In
doing so, DCAS actually impugns its own current Appendix BB intake model for 1953 to
1993 for uranium by stating: “the uncertainty associated with back extrapolating the
data 40 years would likely far exceed the uncertainty associated with the use of more
contemporaneous sources of surrogate data.” This misses the point entirely that the
surrogate data from the slug facility that DCAS chose and back extrapolation of the scant
GSI vacuum cleaner data uranium dust data from 1993 to the entire residual period in the
new SC&A uranium intake model, are BOTH faulty in their inception. Also, the
underlying slug facility surrogate data and the GS] ORNL. 1993 vacuum cleaner real data
are invali ho SONS

As outlined in my August 25, 2012, Discussion paper on the GSI residual period
1978-1993, the Old Betatron Building had been extensively power washed in 1984 and a
new concrete berm that consumed 25% of the shooting room floor had been constructed.
The berm was built in order to store PCB-contaminated oils and transformers, and the
two Betatroo machines, at some unknown time between 1974 and 1988 when
ORNL/DOE first documented the condition of the GSI OBB as part of the FUSRAP
cleanup.

Thus, NIOSH believes that the use of surrogate data at GSI is justified under criterion 1,
given the complete lack of available contemporaneous monitoring data and the large
degree of uncertainly inherent in backwards extrapolation of data collected in 1993.

MCKEEL: This argument is scientifically specious in a logical sense, based on the
preposterous assumption that surrogate data (“SD”) use is justified even if it fails to meet
Board surrogate data criteria. DCAS again fails to mention whether the slug facility data
Meets it own surrogate data criteria in OCAS-IG-004. The DCAS-Allen argument is
basically that any rype of SD is OK if there is a total lack of real measured site data! This
type of argument should not be acceptable to anyone. The GSI petitioners strongly object.

In TBD-6000, the daily average slug production airborne activity was estimated as 198
dpm/m3 by assuming an operator was exposed to the maximum airborne causing
concentration 75% of the time. SC&A pointed out a mathematical error in TBD-6000 that
caused the calculated geometric mean to be too high. SC&A also points out that while the


DWMreply_Allen_8.26,12.doc

the case of ingots and dingots, the uranium was heated in stages to over 1400 degrees in a
“bomb” by the MCW Uranium Division in Missouri before it was shipped to GSI 40 to
70 miles mcs across “ Mississippi River to nig City, IL, where GSI was located,

knowledge. re GSI, all the four MCW uranium rpeohsots were subjected to high
energy—24 to-25 Mev Betatron bombardment— known to cause both fission and
generation of a range of fission products, and photon activation, causing added
radionuclide daughter products, SC&A*s Joe Fitzgerald acknowledged this potential
danger to Weldon Spring workers in his 2009 revision of the Weldon Spring site profile,
as shown in the following excerpt:

[Joe Fitzgerald SC&A WS site profile revision, page 15 of 91)

[Effective Date: fone ‘No. a ‘No. [Page No.
February 10. 2009 0 SCA-TR-TASK1-0028 15 of 91

13 OPPORTUNITIES FOR IMPROVEMENT

SC&A has identified some areas where changes in the TBDs would be beneficial to the claimant
by preventing possible mistakes during dose reconstruction or clarifying items to make them less
ambiguous. These are listed as Observations in this section.

13,1 Observations —- General
Observation — Lack of Coverage of Offsite Activities

Apparently, some work was performed by offsite contractors for the WS site. which consisted of
inspection of uranium metal samples by cutting of the material and then irradiation using high-
energy betatrons. This procedure could induce fission in uranium and create fission products
that could emit radiation not normally encountered in a uranium facility, and expose nearby WS
workers and transporters who may not have normally been badged; and it could have created
inhalable radioactive material for which bioassays were not performed. This subject should be
investigated and addressed in the appropriate TBDs.
GSI Appendix BB Rev 0 was one of the TBDs that Mr. Fitzgerald was referring to. Of
course, We now know that bioassays were NOT performed. Note SC&A in this Weldon
Spring document, states that the offsite x-rayed uranium “could have created inhalable
radioactive material...” DCAS has ignored this possibility and so did SC&A in its new
Alternate intake model that DCAS has dismissed as having too much uncertainty. The
Betatron induced fission and photoactivation products were udditional sources of intake
radiation exposures not only to Weldon Spring handlers of the activated irra
uranium, but also of the exposed GSI workforce after leaving the Betatron faciliti
their way back along the transport pathway to the shipping dock.

R SC&A’s Review C

Criterion 1: Hierarchy of Data

SC&A points out that FUSRAP contamination data from 1993 exists at GSI and could be
used to estimate intakes, thereby eliminating the need for surrogate data. However, the


DWMreply_Allen_8.26.12.doc

defensible intake model for uranium at GSI, and it admits it cannot so. DCAS states it has
the “...éntent to incorporate relevant parts in the next revision to Appendix BB.” This is
NOT sufficient to constitute evidence that the DCAS/NIOSH new model, its fourth
attempt, will be superior to the first three attempts. In effect, this argument is “please trust
me,” whereas the Board should insist the argument should “you must show me now,”

There is also a bothersome underlying assumption that somchow the DCAS
uranium intake model for 1953-1993, which has now been stated to be invalid by SC&A,
is purely an Appendix BB issue. [tis not; itis also a key SEC issue. DCAS must persuade
the full Advisory Board on Radiation and Worker Health it can bound with sufficient
accuracy all intake doses 1953-1993 for all GSI in order to sustain its current
recommendation to deny the GSI SEC-00105 for the entire covered and residual period
for all workers in the class with all types of cancer.

Joe Fitzgerald, in the 2009 SC&A review of the Weldon Spring DOE site profile,
has this to say about the use of scanty inhalation date to bound intake doses:
[SC&A Fitzgerald quote here]

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Insufficient Data for Unmonitored Workers’ Internal Environmental Dose

The TBD used one series of measurements (decontaminating 5-ton hoppers) and site parameter
measurements to determine contributing intakes to non-bioassayed workers during 1957-1967.
The hopper dust monitoring experiment consisted of measurements performed on one day under
one particular condition. and the parameter measurements contributed very little (<1%) to the
final results. This limited (in space, operations, and time) airbome/intake data is not sufficient to
construct an adequate intake dose database for unmonitored workers at the WS complex,
especially considering that a sizable fraction of the work force was not bioassayed on a routine
basis during this period.

At GSI, none of the workforce was bioassayed for uranium at any time 1953-1993. The

GSI airborne uranium intake data by inhalation is even more limited (i.¢., is nonexistent).

Criterion 3: Site or Process Similarities

SC&A points out that slug production by powder metallurgy is not similar to x-raying
uranium metal. As discussed previously, each task in TBD-6000 inherently includes the
movement of cold uranium metal at some step in the particular process, In the slug
production process described in Harris and Kingsley 1, the process starts with a uranium
metal ingot loaded into a hydriding furnace. In the process, a uranium

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

Page 4

hydride is formed and later dehydrided to form a metal powder that is shaped into slugs.


Dragon, Karen E. (CDC/NIOSHIEID)

From: DanMcKeel2@aol.com
Sent: Sunday, August 26, 2012 2:30 PM
To: NIOSH Docket Office (CDC); Katz, Ted (CDC/NIOSH/OD); Ziemer, Paul (CDC/NIOSH/OD);

pl.ziemer@comcast.net; josiebeach@charter.net; j-poston@tamu.edu; wimunn@aol.com;
danmckeel2@aol.com

Ce: Kinman, Josh (CDC/NIOSH/DCAS); :
Subject: McKee! comment on 8.21.12 DCAS-Alien response to SC&A SD paper
Attachments: McKeel_reply Allen_8.26.12.pdf

Dr, Paul Ziemer and members of the TBD-6000 work group
All members of the ABRWH

NIOSH Docket 140 (GSI) Office

Ted Katz (DFO, ABRWH)

Josh Kinman (NIOSH SEC Counselor)

August 26, 2012 Sunday
Dear Dr. Ziemer and TBD-6000 work group and Board members, NIOSH Docket Office,
Attachment: <McKeel_reply Allen_8.26.12.pdf> 1.3 MB
Attached please find my comment on the DCAS and David Allen discussion paper dated 8/21/12. The DCAS-Allen paper
is in response to SC&A's 7/16/12 paper on surrogate data use at GSI and the SC&A 7/25/12 alternate uranium intake
model Discussion papers, all to be presented next Tuesday at the TBD-6000 work group meeting. | consider these issues
to be SEC-00105 issues and not merely Appendix BB matrix issues.
Ted Katz: please distribute this e-mail and the attached PDF file to all Board members. Thank you.
NIOSH Docket Office: please consider this Discussion paper for posting on Docket 140 on the DCAS website. Thank you.
Sincerely,

-- Dan McKeel
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


DWMreply_Allen_8,26,12,doe

uranium oxides would not be quickly ground into dust under foot or forklift traffic. This
results in the equilibrium value in Harris and Kingsley for a continuous operation being
higher than that expected at GSI.

NIOSH agrees that work with uranium at GSI was intermittent and thus it is less likely
that an equilibrium concentration would be reached. This implies the value in Appendix
BB is too high, However, the argument used by SC&A appears to be based on the idea
that the resuspension of surface contamination is the major source of airborne
contamination during operational periods.

Page 5

In reality, airborne contamination while working with uranium metal would initially be
caused entirely by disturbing uranium oxides on the surface of the uranium metal. This
contamination would be relatively consistent from one piece of uranium to the next. As
additional pieces of uranium metal are brought in, a fresh source of contamination is
available. Since this source of airborne does not depend on the slow buildup of
contamination, it occurs immediately and builds up quickly to a maximum.

The other source of airborne, resuspension from surface contamination, will build up to a
maximum more slowly as the surface contamination builds up from continued operations.
This source of airborne is much lower than the operational source. This effect can be seen
in Figure | which depicts the relative levels of airborne contamination during operational
and post-operational period at Simonds Saw and Steel. The time scale in this figure is
days. Once the rolling operations end, the airborne contamination decreases quickly to a
steady level caused by resuspension. It should be noted that, at Simonds Saw and Steel,
the uranium metal was heated and rolled resulting in a much larger fraction of the metal
being oxidized, This would result in higher levels of airborne and surface contamination
than would be seen with the movement of cold uranium.

MCKEEL: There are several misstatements in this section because of incomplete data on
key events that occurred during the GSI residual period 1978-1993 that are now on the
record in the previously mentioned Dan McKeel 8/25/12 Discussion paper. The
petitioners belleve that DCAS has seriously underestimated uranium intakes at GSL
DCAS has no real data of significance related to GSI airborne uranium intake factors,

* The inference that surface uranium metal content would be similar from one specimen
to another would be constant is a false premise. Different amounts of crust encoated both
ingots and dingots. The Putzier effect contributes to dose and this was not mentioned,

* “Once the rolling operations end, the airborne contamination decreases quickly to a
steady level caused by resuspension,”’ However, this is true only while the surface levels
of uranium remain undisturbed. We have now shown that the NBB and OBB and
building 6 and 7 though 10 dust was cleanup up, power washed, covered up with a new
concrete berm at several intervals during the GSI residual period, The very fact that
ORNL found residual uranium in the OBB during the DOE FUSRAP cleanup. in fact,
confirms the uranium contamination levels must have been far higher in times past. There

<1.


DWMreply_Allen_8.26.12.doc

these daughter products (Kuttemperoor, Guo and Ziemer, Sugarman). Many of them had
longer half-lives that lasted weeks rather than minutes or 24 hrs as is usually cited in the
NIOSH technical reports that give data for only selected daughter products.

| offer a new abstract of another such study I just ran across by Harold G. Richter
and Charles D, Coryell (Nobel laureate and the discoverer of the element promethium in
1945) to add to this evidence, Twenty fission products are identified in this abstract:

Z1L. Fission of Uraniym with 16-Mev X-Rays.* Haroun
G. Ricutert anp Cuarces D. Coryeu., Af./.7,—The de-
pendence of fission yield on mass number has been studied for
the fission of natural uranium (U"8) with x-rays of 16-Mev
maximum energy from the linear accelerator.' The following
fission products were studied: Br®*!, Sr8%9o yet, Zrs7,
Mo", Ru, P03. 12, Ag! us, Cd", Tel, [481 1a3, Bats Mo,
and Ce", Pre-existing chemical procedures* were tested and
some modifications made for better suitability in quantitative
isolation of the low activities available. Conditions of counting
were controlled to permit the calculation of absolute disinte-
gration rates, Fission yields were determined relative to 6.0
percent for 85rn Ba!**. Precision of the values is about +:10
percent. The yield-mass curve exhibits the familiar double-
humped shape, rising from about 0.3 percent at mass 83 to a
maximum of about 6.2 percent at mass 97. The minimum is
0.05 percent at mass 117, and the heayy hump maximum is
6,2 percent at mass 138, Fission yields lying above a formal
smooth curve were observed for 77h TeTM (5.8 percent) and
22.4h 1°83 (7.1 percent),

* This work wag supported in part the USAEC,
t Department ot Chemistry. Univers! a af Oregon, Eugene, Oregon.

tp. Deron M.1.T,-L,N.S.E, Technical  xsnort No, 50, May. 1950.
4. D, Coryell and N. Sugarman. Radiochemical Studies: Tae Fission
proeser (Mecraw: Tu Beate Comin Ine., New York, 1951), Buuk 3,

The exact citation for this paper is not clear, Publication years is probably 1951-54. The
same two authors published “Low energy photofission yields for U-238" Phys, Rev, 95:
1550-1553, 1954. Coryell and Sugarman production a 1951 monograph on
“Radiochemical Studies: The Fission Products.” (see citation above)

Criterion 5: Plausibility

SC&A appears to be indicating the airborne contamination calculation in Appendix BB is
not plausible because uranium work at GSI was intermittent and thus “large flakes” of

-IN-


DWMreply_Allen_8.26.12,doe

geometric mean of the airborne contamination may be appropriate for lognormal
distribution, Appendix BB uses it as a constant.

Page 3

Appendix BB used the geometric mean as a constant instead of a lognormal distribution
because the airborne concentration TBD-6000 is associated with slug production rather
than simply moving cold uranium metal. The use of the geometric mean is an attempt to
prevent the value from being unrealistically high (i.¢., it represents a plausible upper
bound) as SC&A appears to indicate in their review of criterion 5.

MCKEEL. All of these mathematical calculations are moot because the slug facility SD
has been declared by SC&A as invalid, and the petitioners agree with this point of view
and have advocated such a position, on the record, as far back as 2008.

Criterion 2; Exclusivity Constraints

This criterion requires the use of surrogate data to be stringently justified. SC&A points
out that the basis for selecting the surrogate data used by NIOSH was that uranium
handling alone results in less disturbance of the metal than the other scenarios listed in
Battelle-TBD-6000. That is, the data used are higher than the exposure conditions that
existed atGSI. SC&A does not believe this qualifies as stringently justified.

NIOSH agrees the use of surrogate data at GSI has not been stringently justified in
Appendix BB.

However, Appendix BB was written approximately three years prior to the Board
formally adopting its surrogate data criteria.

MCKEEL: Again, this argument is specious. The slug facility data SD data is being
evaluated for appropriateness in August 2012, years after both the Board and DCAS have
approved separate sets of SD criteria. It is entirely appropriate to apply these criteria now.
The petitioners position is the SD criteria should have been applied by the Board and
SC&A at GSI years ago, earlier in the evaluation process, just as was done at Texas City
Chemicals for SEC-00088, and for Dow Chemical (Madison, IL) under SEC-00079.

In response to SC&A's comment, NIOSH has reviewed the airborne exposure data
available from a number of sites to determine if a more comprehensive dataset are
available to satisfy the intent of this criterion. At the end of this paper NIOSH provides a
more robust analysis of the use of surrogate data at GSI (see section titled Evaluation of
Other Sources of Surrogate Data) with the intent to incorporate relevant parts in the next
revision to Appendix BB.

MCKEEL: Here DCAS misstates the scanty SD data from three sites, two producing
uranium slugs, and one producing uranium billets, as being “more robust.” The new SD
is not robust, it is fragmentary as examination of the data sheets and text will clearly
show. Furthermore, this is DCAS' third opportunity to construct a scientifically valid and


DWMreply_Allen_8.26.12.doc

A photograph of a typical Weldon Spring site uranium metal ingoV/dingot was a
rough coat is shown below. The photograph was provided to through the
courtesy of the DOE Weldon Spring Site Interpretive Center. This community resource
feature a museum and visitor center in St. Charles County, MO, that is adjacent to the 45
acre engineered disposal cell.

Symposium on nondestructive tests in the ticld of nuclear energy.

(See Page 7. Fuel Tests) It answers and contirms “why dingots went to GSI”, and that Betatron X-rays were done
“before any cropping” See Page 7.

This material had been provided to everyone and mentioned many times.

This is not a clean slug by means: (Photo trom Weldon Sp

(2) The complex uranium transport pathway at GSI was not acknowledged.

GSI employed two 24-25 Mev Betatron electron accelerators operating in x-ray
mode at two separate GSI building locations, the Old and New Betatron facilities. In
order to get the uranium metal from the shipping and receiving dock, the products first
needed to be lifted and scraped with sturdy metal grabber hooks and metal chain hoists
and unloaded from trucks onto rail transfer cars that were not cleaned and themselves had
uranium dust contamination that was never measured and quantified, nor was it
accounted for and bounded as a portion of dose by DCAS/NIOSH. The rail tracks have
been demonstrated by the petitioners to run though buildings 6, 7, 8, 9 and 10 and inside
building 10 into a short above ground “tunnel” causeway and break area leading into the
New Betatron Facility (*NBB”). The rail transfer tracks branched and led outside to the
Old Betatron Building that stood alone 300 feet away from the NBB not connected to any
other GSI building. It is to be expected, therefore, that some uranium contamination



DWMreply_Allen_8.26.12.doce

R, W. Leblond Machine Tool Co. (SRDB 10634 page 11, Figure 4 in this paper)
Page 8

A test was conducted at Leblond to evaluate a hole boring machine. Air samples were
taken while boring a hole into a uranium billet with a rapid bore machine. Coolant was
used while boring the hole but air samples were taken while loading the dry billet onto
the machine. The first thee samples on the data sheet (Figure 4) were taken as breathing
zone air samples while “hooking hoist to billet and placing billet into position on
machine”. The remarks section of the data sheet indicates there was no ventilation on the
machine and very little air movement. Coolant used during the boring reduced any
possible interference from nearby operations. Together, these issues make the Lablond
samples the most directly relevant samples to the work at GSI. One of the samples
measured 9 dpm/m3 while the other two samples had results that were labeled as “nd”
which stands for none detected.

MCKEBL: This was a uranium billet production facility not justifiably similar to GSI
operations, The data is very scanty, insufficient to bound intake doses.

Conclusions

While it is difficult to find air sample data representative of moving cold uranium metal,
it must be realized that this movement is inherent with every operation involving uranium
metal. If the movement were to cause high levels of airborne uranium, it would in most
cases continue to be present during the tasks for which samples were taken, The most
relevant samples to GSI discussed in this paper are those taken at Leblond, which
involved moving an ingot to a boring machine. Because this data set contains only three
samples collected over a one day period, it is not a very robust sample set. Samples taken
at Chambersburg Engineering while loading cold uranium slugs into a furnace were as
high as 174 dpm/m3. While it is very possible some of this airborne activity was caused
by nearby operations, it is not definitely known. Therefore, it is possible that handling
cold uranium metal could cause airborne activity this high. This is relatively close to the
198 dpm/m3 used in Appendix BB.

The value used in Appendix BB, therefore, appears to be bounding without increasing it
by a factor of 2.9 as suggested by SC&A in criterion 1. It also appears to be a plausible
upper bound when the degree of uncertainty is taken into consideration, rather than
implausibly high as implied in SC&A criterion 5. The process of moving cold uranium
metal without special controls or ventilation is a function of the physical characteristics
of uranium metal and not a function of the time frame in which the samples were taken
(criterion 4). While the processes described in TBD-6000 are based on sources of

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DWMreply_Allen_8.26.12.doc

+ Betatron slices that were hand sawn at MCW into pieces perhaps 4 to 5 inches
thick, and;

+ A few cast billets.

Only the billets and the sawn surface of the Betatron slices had an exposed
surface composed of pure uranium, free of crust, with an oxide later being exposed,

Exact numbers and composition of these four uranium metal types sent from the
two MCW sites to GSI are unknown, Dingots and ingots were known to be alloyed and to
contain trace impurities including thorium radionuclides. Recycled (previously irradiated
in a nuclear reactor) uranium was known to be processed at the Weldon Spring MCW-
DOE site for part of its operating period of 1957-66. Purchase orders from MCW to GSI
are completely missing 1953-57. A 1992 DOE memo to its Oak Ridge office, which
reproduced below, states that “dingots,” not billets, were the main uranium metal product
sent from MCW to GSI for NDT Betatron radiography.

“nite ae _ 895801
United States Government : Department of Energy
“memorandum
— ware OCT 06 1992 riz ect 1d ft 29
RERY TO
armor: EM-421 (W. A. WIT Tiams, )

~ suanct: Authorization for Remedial Action at Granite City Steel Site, Granite
City, Tilinois

TO Manager, DOE Oak Ridge Field Office

This is to notify you that the Granite City Steel site in Granite City,
Illinois, is designated for remedial action under the Formerly Utilized
Sites Remedial Action Pree (FUSRAP). This notification does not
constitute a FUSRAP baseline change control approval. proval of the
baseline change will be accomp] is! through the normal baseline change
contral p lures.

The site was used by the former Atomic Energy Commission for x-ray studies
on uranium dingots during the 1950s and 1960s. A radiological survey

found residual uranium inside one building and around an industrial vacuum
cleaner. Because of the limited extent of the contamination, the site may
be remediated using the expedited cleanup process now

for Environmental Restoration

It is difficult to understand, after all our previous interactions on this important
point, why DCAS would mention uranium “billets” as the main product processed at
General Steel Industries 1953 through June 30, 1966, the extent of the GSI AEC
Mallinckrodt Chemical Works uranium contract period. The treatment of uranium
dingots in TBD-6000 Rey 0 and Rev 1 is incomplete and not totally accurate.


DWMreply_Allen_8.26.12.doc

Comment by Daniel W. McKeel, Jr., GSI SEC-00105 co-petitioner,
to the TBD-6000 work group discussion paper
“Use of Surrogate Data at GSI dated July 16, 2012
Response to SC&A Review,” prepared by
Dave Allen, DCAS, August 21, 2012

On July 16, 2012, SC&A released a review of the use of surrogate data at GSI which
evaluated the use of surrogate data at GSI against the Advisory Board's Surrogate Data
Criteria. This paper provides NIOSH’s response to that review.

MCKEEL GENERAL COMMENT: The majority of concerns about this paper is it
repeatedly ignores well substantiated facts that have been put on the record by the GSI
petitioner team, by site experts, and by previous GSI workers including multiple eye
witness Betatron operators. This substantial body of factual evidence has been largely
overlooked, or ignored, by DCAS.

Overview

Unlike most Atomic Weapons Employer (AWE), the AEC contracted work at GSI did
not involve active manipulation of uranium metal through processes such as rolling,
machining, cutting, or straightening. The work at GSI consisted solely of taking x-rays of
uranium metal that were used to evaluate the integrity of the casted billets manufactured
at Mallinckrodt Chemical Works. Thus, the only potential for generation of airborne
uranium at GSI would be from the movement of the metal into position for the
examination.

MCKEEL: There are several major technical errors in the foregoing paragraph:

(1) The statement that: “The work at GSI consisted solely of taking x-rays of
uranium metal that were used to evaluate the integrity of the casted billets
manufactured at Mallinckrodt Chemical Works.” is not accurate for several reasons that
are discussed here and in section (2) that follows.

(a) The petitioners believe they have proven through MCW records that the
primary purposes of subjecting MCW uranium (o Betatron NDT examination was not just
to inspect the metal for structural defects. NDT radiographed was required to define the
interface between the uneven thickness adherent outer “bomb” crust of dingots and ingots
and the underlying pure uranium metal,

(b) Uranium billets were not the primary or the sole type of uranium metal
sent to GSI from the MCW-Destrehan Street plant and the MCW Uranium Division
Weldon Spring Uranium Feed Materials plant in St. Charles County. In fact, there were at
least four different types of uranium metal examined by nondestructive testing (NDT)
radiographic techniques at GSI:

* One step dingots with shaggy, irregular outer crust (magnesium fluoride)
“bomb” remnants and weighing 3,000 pounds each:

* Two step ingots produced by a two step process in a “bomb” which were
shipped before the crust was cropped and lathed off, weighing 3,000 pounds each;


DWMreply_Allen_8.26.12,doc

is no credible, scientifically defensible method available, absent real measured air intake
or urinary uranium bioassay data, to quantify intake exposures at GSI,

Page 6

Figure | — Airborne Uranium at Simonds Saw and Steel During and After Rolling
Operations (FIG. | data omitted].

MCKEEL: DCAS is comparing apples (Simonds-Saw rolling mill) to oranges (GSI NDT
radiography) with two different operations and two different facilities that are not
comparable physically or with respect to what operations they performed at all. Simonds-
Saw data would also not pass Board SD criteria. Rolled steel is cleaned by scraping and
polishing, whereas uranium cast ingots and dingots sent to GSI from MCW were in their
raw encrusted form before cropping and vertical lathing were performed later after
Betatron NDT radiographic inspection was performed and the reports and x-ray films
were returned to MCW Uranium Division. All of those vital records have been lost or
destroyed.

Page 7

Evaluation of Other Sources of Surrogate Data

As described earlier, monitoring data associated with the movement of cold uranium
metal is limited. A review of the data from AWE facilities indicate that most data are
associated with actual airborne causing activities, rather than simply moving the metal.
Also, some sample results that are associated with moving the metal are positively biased
by nearby work with uranium metal. In searching the available data from a number of
AWEs, however, a few examples were found.

MCKEEL: These facilities are not comparable to GSI. Two produced uranium slugs (not
a product used at GSI) and the other produced uranium billets (a minor uranium metal
product used at GSI). These surrogate data would not pass the Board SD criteria, so
citing them is immaterial to NIOSH being able to demonstrate now that it can bound GSI
uranium intakes with sufficient accuracy and thus make a valid recommendation to deny
SEC-00105. That demonstrably cannot be done by DCAS/NIOSH at the current time,

Also, this belated advancement by DCAS/NIOSH of other surrogate intake data is “too
little and too late.” They have had three chances (June 2007 to October 2012, the Path
Forward for GSI from October 2010 to January 2012, and the response to SC&A’*s
development of a new alternate uranium intake model for GSI (which DCAS roundly
rejected in the Allen $/21/12 response paper) to develop a valid uranium intake method at
GSI.

What has been shown is that the TBD-6000 and other surrogate data that DCAS can
produce is inadequate to pass Board SD criteria because it is so scant and so different
from the unique uranium operations at GSI. And as Mr. Allen and DCAS admits, GSL
made no real attempt to monitor air intakes or to perform urine uranium bioassays, or to

-1?-


DWMreply_Allen_8.26.12.doc

airborne contamination with greater potential to generate airborne activity than merely
the movement of

Page 9

uranium metal, they do include the movement of metal and therefore represent work at
GSI in part (criteria 3). Lastly, it is NIOHS’s position that, while it is difficult to find air
samples that perfectly match the exposure condition at GSI, the value used in Appendix
BB is both plausible and bounding. It is believed that this paper provides justification for
its use and applicable portions of this justification will be incorporated in the next
revision to Appendix BB (criterion 2).

Page 10

Figure 2 - Airborne Uranium Data Sheet from Heald Machine Company

Page 11

Figure 3 — Airborne Uranium Summary from Chambersburg Engineering

Page 12

Figure 4 - Airborne Uranium Data Sheet from Leblond

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