Summary of Five Document Reviews 

Approved by the Subcommittee for 

Procedure Reviews

Kathleen Behling, SC&A, Inc.

Advisory Board on Radiation and Worker Health

August 18, 2022
2

SCPR-approved documents

 DCAS-PER-049, rev. 0, “Paducah Gaseous Diffusion Plant”

 OCAS-PER-008, rev. 0, “Modification of NIOSH-IREP Lung 

Cancer Risk Model: Effect of ‘Combined’ Lung Model on Noncompensable Lung Cancer Claims”

 OCAS-PER-006, rev. 0, “External Dosimetry Target Organ for 

Prostate Cancer”

 ORAUT-OTIB-0023, rev. 00, “Assignment of Missed Neutron 

Doses Based on Dosimeter Records”

 DCAS-PER-066, rev. 0, “Huntington Pilot Plant”
3

DCAS-PER-049, rev. 0

 Title: “Paducah Gaseous Diffusion Plant”

 Issued August 5, 2016

 Determines the effect of several revisions to the Paducah 

technical basis document (TBD)

 Doses increased due to revisions in TBD sections:

– Section 3: Occupational medical x-ray exam frequency default 

increased in rev. 03, August 23, 2012

– Section 4: Occupational environmental external doses increased for 

some assigned years in rev. 03, August 24, 2012

– Section 6: Occupational external dose increased due to assigned dose 

from neutrons and inclusion of Tc-99 in rev. 04, August 24, 2012 
4

SC&A’s review of PER-049, rev. 0

 Paducah TBD reviewed separately

 SC&A identified 25 findings that were resolved under 

the work group (WG) on K-25, Paducah, and 

Portsmouth gaseous diffusion plants

 PER-049 review consisted of only subtask 4 protocol 

for evaluation of a sample set of impacted cases
5

Subtask 4 case selection

 Case selected based on criteria:

– Nonsmoker with site default x-ray frequency assigned between 1951 

and 1973

– External environmental dose assigned for some years

– Increase in neutron dose assigned

– Tc-99 external dose assigned

 Cases were selected from six cases where the rework resulted 

in a POC between 45% and 50%

 Among the six cases, none had external environmental dose or 

Tc-99 external dose assigned
6

SC&A’s subtask 4 review of PER-049, rev. 0

 SC&A reviewed one case 

– Energy employee (EE) was assigned site default occupational x-rays

– EE was assigned neutron dose

 Review limited to assessing only those methods that relate to 

issues addressed in PER-049

 SC&A submitted its subtask 4 report March 2, 2018

 No findings

 SC&A presented its review to the SCPR at the October 31, 

2018, meeting
7

PER-049 case background

 EE worked at Paducah for ~1 decade

 Worked throughout the facility

 Monitored for external and internal radiation exposure

 Diagnosed with qualifying cancer ~4 decades after termination 

of employment
8

Comparison of NIOSH’s reworked doses and 

original doses for PER-049 case

Dose categories Reworked vs. original dose 

percentage

External 9% decrease

Occupational medical 84% decrease

Internal 81% increase

Total 24% increase

POC 15% increase
9

Original occupational medical dose 

calculation for PER-049 case

 Used default x-ray exams and frequency recommendations 

from Paducah TBD-3, rev. 00

 Assigned dose as specified in Paducah TBD-3, rev. 00

 Total dose ~3.5 rem
10

Reworked occupational medical dose 

calculation for PER-049 case

 Frequency of exams based on DOE records

 Also assumed pre-employment exam

 Assigned dose as specified in Paducah TBD-3, rev. 03

 Total dose ~0.5 rem

 Note: Although exam frequency increased, the lumbar spine 

dose decreased from 2,900 mrem to 347 mrem 
11

SC&A’s review of reworked occupational 

medical dose calculations

 Identified eight posterior-anterior x-rays and a lumbar spine 

exam in DOE records

 Pre-employment exam included in accordance with TBD-3 

rev. 03 guidance

 Assigned dose based on tables 3-3 and 3-4 of Paducah 

TBD-3, rev. 03

 Verified total dose ~0.5 rem

 Doses appropriately entered in IREP as normal distributions 

with 30% uncertainty
12

Original neutron dose for PER-049 case

 Neutron dose not considered

 Paducah TBD-6, rev. 00, did not recommend assignment of 

neutron dose based on job title and work location
13

Reworked neutron dose calculation for 

PER-049 case

 Neutron dose calculated based on guidance of TBD-6, rev. 04:

– neutron-to-photon ratio value of 0.2 applied to measured, missed, and 

unmonitored photon doses

– International Commission on Radiological Protection adjustment factor 

of 2.0

– energy range of 0.1 to 2 MeV

 Applied OCAS-IG-001 dose conversion factor (DCF) values

 Assigned total neutron dose of ~4 rem
14

SC&A’s review of reworked neutron dose 

calculations for PER-049 case

 Confirmed that neutron dose calculations were based on 

guidance of TBD-6, rev. 04

 Verified that appropriate IG-001 DCF values were applied

 Recalculated measured, missed, and unmonitored neutron 

doses

 Total assigned neutron dose was correctly calculated

 Annual doses entered in IREP appropriately
15

Environmental and Tc-99 doses

 Neither original nor reworked DRs considered external 

environmental dose because measured, missed, and 

unmonitored dose were assigned

 Neither original nor reworked DRs considered dose from 

exposure to Tc-99 because organ of interest would not be 

impacted by nonpenetrating dose

 SC&A concurs with NIOSH’s conclusions on environmental 

and Tc-99 doses
16

Internal dose calculations for PER-049

 SC&A did not verify the accuracy of internal dose, because it 

was not impacted by PER-049

 SC&A noted that the significant increase in internal dose was 

based on:

– Original DR used hypothetical intakes

– Reworked DR used EE’s bioassay data
17

Board discussion of DCAS-PER-049
18

OCAS-PER-008, rev. 0

 Title: “Modification of NIOSH-IREP Lung Cancer Risk Model: Effect 

of ‘Combined’ Lung Model on Non-compensable Lung Cancer 

Claims”

 Issued April 12, 2007

 Determines the impact of NIOSH-IREP 5.5 issued February 28, 

2006, followed by version 5.5.1 issued May 16, 2006

 IREP revision: 

– compares POCs calculated using NIOSH-IREP and NIH-IREP for lung, 

trachea, or bronchus cancers and reports the higher

– incorporates a bias correction factor for random errors in dosimetry for “never 

smoker” exposed to radon
19

SC&A’s review of PER-008, rev. 0

 PER-008 review submitted December 15, 2010

 Identified two findings

 SC&A presented review to the SCPR at the March 22, 2011, 

meeting

 SCPR determined subtask 4 case review was not necessary, 

because only IREP was re-run and no DRs were reworked
20

Issue resolution for PER-008 finding 1

Finding date Finding description NIOSH response Finding resolution

12/15/2010 NIOSH-IREP lung model 

generates excessively 

high probability of 

causation values due to 

the model’s failure to 

account for the age at 

exposure, as well as the 

attained age of the 

exposed individual at the 

time of cancer diagnosis.

3/22/2011. Scientific 

Issues WG Chair has 

“age of exposure” on 

the list of issues to be 

evaluated. Therefore, 

this finding is broader 

than PER-008 and 

should be considered 

an overarching issue.

3/22/2011. SCPR 

agreed that the 

finding should be 

addressed under the 

Scientific Issues WG 

and closed the 

finding. 
21

Issue resolution for PER-008 finding 2

Finding date Finding description NIOSH response Finding resolution

12/15/2010 NIH-IREP lung model 

adjusts on a limited basis 

the effects of age at 

exposure and attained 

age. A potentially 

significant shortcoming of 

this model is that there is 

no further adjustment for 

attained age greater than 

age 50 years.

3/22/2011. Scientific 

Issues WG Chair has 

“age of exposure” on 

the list of issues to be 

evaluated. Therefore, 

this finding is broader 

than PER-008 and 

should be considered 

an overarching issue.

3/22/2011. SCPR 

agreed that the 

finding should be 

addressed under the 

Scientific Issues WG 

and closed the 

finding. 
22

Board discussion of OCAS-PER-008
23

OCAS-PER-006, rev. 0

 Title: “External Dosimetry Target Organ for Prostate Cancer”

 Issued September 15, 2006

 Assesses the impact of changing external dosimetry target 

organ for prostate cancer from testes to bladder

– Dosimeter external doses decreased due to bladder DCF < testes DCF

– Occupational medical surrogate organ dose increased slightly, but 

offset by measured, missed, and unmonitored external doses

 No cases reevaluated because dose and POC will not increase
24

SC&A’s review of PER-006, rev. 0

 Review submitted October 29, 2007 

 Concurs that bladder is more appropriate surrogate organ:

– Bladder deep in the body cavity

– Bladder close to prostate

– Testes significantly overestimates external beta and low-energy 

photons since close to body surface

 SC&A had one administrative finding
25

Issue resolution for PER-006 finding 1

Finding date Finding description NIOSH response Finding resolution

10/29/2007 The structure of PER-006 

does not strictly follow the 

guidance provided by 

OCAS-PR-008 

“Preparation of Program 

Evaluation Reports and 

Program Evaluation 

Plans.” PER-006 has a 

single Evaluation section 

rather than separate Issue 

and Probability of 

Causation Evaluation 

sections and is missing 

Summary section.

12/9/2008. NIOSH 

agrees that PER does 

not include the specific 

sections described in 

PR-008 but does 

include all required 

information for 

determining if claims 

required rework. The 

PER process has 

change significantly 

over time and PR-008 

will be revised or 

canceled. 

12/9/2008. SC&A and 

SCPR agreed with 

NIOSH’s response 

and closed the 

finding. PR-008 was 

later canceled.
26

Board discussion of OCAS-PER-006
27

ORAUT-OTIB-0023, rev. 00

 Title: “Assignment of Missed Neutron Doses Based on 

Dosimeter Record”

 Provides guidance to determine when it is appropriate to 

assign neutron doses to EEs at DOE sites using the half limit of 

detection (LOD/2) method

 Revision 00 issued March 7, 2005

 Revision 01 issued May 14, 2008
28

OTIB-0023, rev. 00, guidance

 When neutrons were monitored using reliable dosimeters and 

results are zero, the LOD/2 method is appropriate

 Missed neutron dose is not assigned if both of the following 

conditions are met:

1. Neutron missed dose estimate (nLOD/2) exceeds 75% of measured 

and missed photon dose

2. Based on work location and site-specific data, it is determined EE 

neutron dose was zero or incidental relative to assigned external 

dose
29

SC&A’s review of OTIB-0023, rev. 00

 Review submitted June 8, 2006

 Review identified eight findings

 Findings discussed and resolved during many SCPR meetings 

in 2007 and 2008
30

Issue resolution for OTIB-0023 finding 1

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure lacks clarity 

by failing to provide clear 

definitions and is 

inconsistent in its 

terminology. Primary 

concern is inconsistencies 

between OTIB-0023 and 

OCAS-IG-001.

10/2/2007. All guidance 

must be used by dose 

reconstructors in their 

entirety and judge which 

guideline best applies to 

a given DR. Consistency 

in interpretation and 

application of the array of 

guidance is achieved 

through training and QA. 

There may be a need to 

provide further 

clarification in OTIB0023.

10/2/2007. SCPR 

requested that NIOSH 

and SC&A hold 

teleconference with 

technical experts and 

report on clarification 

discussions at the 

next SCPR meeting.
31

Issue resolution for OTIB-0023 finding 1 

followup

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A and 

NIOSH held 

conference call to 

discuss finding.

11/7/2007. Section 2.0 and 

other portions of this OTIB 

will be revised in 

conjunction with a revision 

to section 2.2.2.2.1 of IG001 to clarify guidance 

regarding the application of 

missed neutron dose. One 

of the significant changes to 

OTIB-0023 will be the 

removal of “Condition #1” in 

section 6. 

11/7/2007. Issues 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
32

Issue resolution for OTIB-0023 finding 2

Finding date Finding description NIOSH response Finding resolution

6/8/2006 When LOD/2 method 

is not used, detailed 

information is required 

that will not be readily 

available to the dose 

reconstructor.

10/2/2007. Same as 

finding 1.

10/2/2007. Transferred to 

item 1 of the review of 

this OTIB. NIOSH and 

SC&A will report on 

technical clarification 

discussions to the SCPR 

at the next SCPR 

meeting.
33

Issue resolution for OTIB-0023 finding 2 

followup

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A and 

NIOSH held 

conference call. All 

issues were resolved.

11/7/2007. IG-001 and 

OTIB-0023 will be 

revised to expand on 

the options for 

reconstructing missed 

dose when LOD/2 

method does not 

provide appropriate 

result.

11/7/2007. Issue 

resolved to satisfaction of 

the SCPR. NIOSH 

should report back when 

procedure has been 

revised.
34

Issue resolution for OTIB-0023 finding 3

Finding date Finding description NIOSH response Finding resolution

6/8/2006 OTIB-0023 references 

OCAS-IG-001 as the 

basis for its guidance; 

however, guidance 

contained in OTIB0023 and OCAS-IG001 is inconsistent. 

Reference to reliable 

versus unreliable 

neutron dosimeter 

differs between 

guidance documents.

9/25/2007. The guidance is 

not inconsistent; rather it 

seeks to provide DR staff 

with additional guidance 

with respect to section 

2.2.2.2.1 of OCAS IG-001. 

This purpose is stated in 

section 1.0. In addition, it is 

critically important to review 

this and other TIBs 

considering other 

information available to DR 

staff.

10/2/2007.

Transferred to item 1 

of the review of this 

OTIB. NIOSH and 

SC&A will report on 

technical clarification 

discussions to the 

SCPR at the next 

meeting.
35

Issue resolution for OTIB-0023 finding 3 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. OTIB-0023 will be 

revised (in conjunction with a 

revision to section 2.2.2.2.1 of 

IG-001). Revision will remove 

“Condition #1” in section 6 of 

OTIB-0023 and will expand 

IG-001 on the possible 

options for reconstructing 

missed dose when 

dosimeters are unreliable or 

when the LOD/2 method does 

not provide an appropriate 

result.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
36

Issue resolution for OTIB-0023 finding 4

Finding date Finding description NIOSH response Finding resolution

6/8/2006 It is questionable 

whether dose 

reconstructors are in a 

position or have the 

information to make 

the potentially 

subjective decisions 

required.

9/25/2007. OTIB is not intended for 

best estimate dose reconstructions. 

It is intended to provide additional 

information to DR staff regarding 

the application of missed neutron 

dose using the LOD/2 method. 

Missed neutron dose must be 

considered regardless of the “type” 

of DR. Additionally, the DR staff 

does have access to the 

information needed to make 

decisions regarding the application 

of missed neutron dose.

10/2/2007. Transferred 

to item 1 of the review 

of this OTIB. NIOSH 

and SC&A will report on 

technical clarification 

discussions to the 

SCPR at the next 

meeting.
37

Issue resolution for OTIB-0023 finding 4 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. NIOSH has 

agreed with SC&A’s finding 

and will introduce appropriate 

changes in a future revision of 

the procedure.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
38

Issue resolution for OTIB-0023 finding 5

Finding date Finding description NIOSH response Finding resolution

6/8/2006 OTIB-0023 references 

OCAS-IG-001 as the basis 

for its guidance; however, 

guidance contained in OTIB0023 and OCAS-IG001 is inconsistent. The 

need for neutron survey data 

and stay times when missed 

neutron doses exceed 75% 

of photon doses is 

prescribed in IG-001. Same 

condition in OTIB-0023 

requires second condition to 

be met.

9/25/2007. Same response as 

finding 3: The guidance is not 

inconsistent; rather, it seeks to 

provide DR staff with additional 

guidance with respect to 

section 2.2.2.2.1 of OCAS-IG001. This purpose is stated in 

section 1.0. In addition, it is 

critically important to review 

this and other TIBs considering 

other information available to 

DR staff.

10/2/2007.

Transferred to item 1 

of the review of this 

OTIB. NIOSH and 

SC&A will report on 

technical clarification 

discussions to the 

SCPR at the next 

meeting.
39

Issue resolution for OTIB-0023 finding 5 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. OTIB-0023 will be 

revised (in conjunction with a 

revision to section 2.2.2.2.1 of 

IG-001). Revision will remove 

“Condition #1” in section 6 of 

OTIB-0023 and will expand 

IG-001 on the possible 

options for reconstructing 

missed dose when 

dosimeters are unreliable or 

when the LOD/2 method does 

not provide an appropriate 

result.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
40

Issue resolution for OTIB-0023 finding 6

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The reconstruction of 

missed neutron doses 

from “numerous 

neutron measurements 

and accurate time

information” is 

unrealistic.

9/25/2007. If survey data 

are not available, other 

types of data sources as 

listed in the hierarchy of 

data (table 1.1 of OCAS-IG001) could be used. Use of 

any approach for neutron 

missed dose requires a 

description of the method in 

the DR report.

10/2/2007.

Transferred to item 1 

of the review of this 

OTIB. NIOSH and 

SC&A will report on 

technical clarification 

discussions to the 

SCPR at the next 

meeting.
41

Issue resolution for OTIB-0023 finding 6 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. IG-001 and OTIB0023 will be revised to 

expand on the options for 

reconstructing missed dose 

when LOD/2 method does not 

provide appropriate result.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
42

Issue resolution for OTIB-0023 finding 7

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The regulatory 

recommendation for 

“striking a balance 

between the need for 

technical precision and 

process efficiency” has 

been ignored.

9/25/2007. Significant effort 

has been expended to 

ensure precision and 

efficiency in the DR process 

with respect to missed 

neutron dose.

10/2/2007.

Transferred to item 1 

of the review of this 

OTIB. NIOSH and 

SC&A will report on 

technical clarification 

discussions to the 

SCPR at the next 

meeting.
43

Issue resolution for OTIB-0023 finding 7 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. OTIB-0023 will be 

revised to remove condition 1 

from section 6.0; only 

condition 2 must be satisfied in 

order to conclude that missed 

neutron dose need not be 

included in a reconstruction. In 

addition, IG-001 and OTIB-0023 

will be revised to expand on the 

options for reconstructing 

missed dose when the LOD/2 

method does not provide 

appropriate result.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
44

Issue resolution for OTIB-0023 finding 8

Finding 

date

Finding 

description

NIOSH response Finding resolution

6/8/2006 The generic 

assumption of a 

neutron-to-photon 

ratio of 0.75:1 as a 

limiting value for 

the application of 

nLOD/2 is neither 

technically 

defensible nor 

claimant favorable.

9/25/2007. The rationale for the 

guidance in IG-001 section 2.2.2.2.1 

is reflected in the language of 

section 5.0 of OTIB-0023. 

Additionally, it is common practice to 

apply missed neutron dose (during 

site NTA film eras) based on the 

application of the site-specific 

neutron-to-photon ratio to measured 

and missed photon dose. This 

approach is both technically 

defensible and claimant favorable.

10/2/2007.

Transferred to 

item 1 of the review 

of this OTIB. NIOSH 

and SC&A will 

report on technical 

clarification 

discussions to the 

SCPR at the next 

meeting.
45

Issue resolution for OTIB-0023 finding 8 

followup 

Finding date Followup action NIOSH response Finding resolution

6/8/2006 11/5/2007. SC&A 

and NIOSH held 

conference call to 

discuss finding.

11/7/2007. NIOSH has 

agreed with SC&A’s finding 

and will introduce appropriate 

changes in a future revision of 

the procedure.

11/7/2007. Issue 

resolved to 

satisfaction of the 

SCPR. NIOSH 

should report back 

when procedure has 

been revised.
46

Final issue resolution for all OTIB-0023 

findings

Finding date NIOSH followup SC&A followup Finding resolution

6/8/2006 5/14/2008. OTIB-0023, 

rev. 01, issued.

6/17/2008. SC&A reviewed 

OTIB-0023, rev. 01, and 

found it adequately 

addresses the eight 

findings.

6/24/2008. SCPR 

closed all findings.
47

Board discussion of ORAUT-OTIB-0023
48

DCAS-PER-066, rev. 0

 Title: “Huntington Pilot Plant”

 Issued November 30, 2015

 Determines the effect of rev. 01 of the Huntington Pilot Plant 

TBD, DCAS-TKBS-0004, issued December 12, 2013

 Revision added intakes for Am-241, Th-230, and Tc-99 for the 

periods 1956–1963 and 1978–1979, which increased internal 

dose estimates for all claims
49

History of Huntington Pilot Plant TBD

 ORAUT-TKBS-0004, “Technical Basis Document: Basis for Development of 

an Exposure Matrix for Huntington Pilot Plant,” rev. 00 (October 2003)

 ORAUT-TKBS-0004, “Technical Basis Document: Basis for Development of 

an Exposure Matrix for Huntington Pilot Plant,” rev. 01 (January 2004)

 OCAS-PER-025 (September 2007) evaluated addition of electron dose in 

revision 01

 OCAS-TKBS-0004, “Technical Basis Document for the Huntington Pilot 

Plant, Huntington, West Virginia,” rev. 00 (August 2008), added intakes for 

total uranium, Pu-239, and Np-237

 DCAS-PER-033 (December 2011) evaluated increase in internal dose
50

SC&A’s review of PER-066, rev. 0

 SC&A’s previous reviews included:

– OCAS-TKBS-0004, rev. 00 (focused review under Subcommittee for Dose Reconstruction 

Reviews) (reviewed March 2013)

– OCAS-PER-025, rev. 0 (reviewed July 2013)

– OCAS-TKBS-0004, rev. 00 (reviewed June 2013)

– OCAS-PER-033, rev. 0 (reviewed July 2013)

 PER-066 review consisted of only a sample set of impacted cases 

(Subtask 4)

 SC&A submitted its subtask 4 report October 11, 2016

 SC&A identified one finding

 Review presented to SCPR at the October 31, 2018, meeting
51

PER-066 subtask 4 case selection and review 

process

 NIOSH identified two reworked cases with POCs between 45% 

and 50%; these cases were selected for review

 Review was limited to evaluating only those methods and 

corrective actions that relate to issues addressed in PER-066

 SC&A’s review evaluated only internal dose calculations
52

Huntington Pilot Plant history

 Alternative name: Reduction Pilot Plant

 Covered period: 1951–1963, 1978–1979

 Supplied nickel powder used to make gaseous diffusion barrier 

for Paducah and Portsmouth gaseous diffusion plants

 Sources of feed material were nickel oxide and barrier scrap 

contaminated with uranium and associated radionuclides from 

the uranium enrichment process 
53

PER-066 case 1 background

 EE worked at Huntington Pilot Plant for many years

 No records of external or internal monitoring available

 EE classified as a plant worker

 Diagnosed with a qualifying cancer after termination of 

employment
54

Comparison of NIOSH’s reworked doses and 

original doses for PER-066 case 1

Dose categories Reworked vs. original dose 

percentage

External ~69% decrease

Occupational medical ~3% decrease

Internal >40,000% increase

Total ~202% increase

POC ~47% increase
55

Original internal dose calculations for 

PER-066 case 1 

 DR performed in 2003 

 Used internal intake values from table 5 of ORAUT-TKBS0004, rev. 00

 Calculated doses using CADW for total uranium, Pu-239, and 

Np-237

 Resulted in assigning a total dose of >0.100 rem
56

Reworked internal dose calculations for 

PER-066 case 1 

 Used appropriate inhalation and ingestion intake values from 

table 5 of DCAS-TKBS-0004, rev. 01

 Calculated doses using CADW for total uranium, Pu-239, 

Np-237, Am-241, Th-230, and Tc-99

 Compared absorption types as specified in table 5

 Doses entered in IREP as constant values

 Resulted in assigning a total dose of nearly 9.0 rem
57

SC&A’s conclusions about internal dose 

calculations for PER-066 case 1 

 Concurs that EE should be classified as a plant worker

 Verified correct inhalation and ingestion intake values from 

table 5 of DCAS-TKBS-0004, rev. 01

 Confirmed the greater dose was assigned considering the 

potential solubility types

 Re-ran CADW used rev. 01 TBD-specified values

 Entered annual doses in IREP 

 Calculated a POC that approximated NIOSH’s POC

 No findings about rework of case 1
58

PER-066 case 2 background

 EE worked at Huntington Pilot Plant for many years

 No records of external or internal monitoring available

 EE classified as a plant worker

 Diagnosed with qualifying cancers several years after 

termination of employment
59

Comparison of NIOSH’s reworked doses and 

original doses for PER-066 case 2

Dose categories Cancer 1 reworked 

vs. original dose 

percentage

Cancer 2 reworked 

vs. original dose 

percentage

External ~72% decrease ~72% decrease

Occupational 

medical

~37% decrease ~37% decrease

Internal ~718% increase ~721% increase

Total ~263% increase ~272% increase

POC ~25% increase ~9% increase
60

Original internal dose calculations for 

PER-066 case 2 

 DR performed in 2004 

 Used internal intake values from table 5 of DCAS-TKBS-0004, 

rev. 01

 Calculated doses using CADW for total uranium, Pu-239, and 

Np-237

 Resulted in assigning a total dose of ~6.000 rem for both 

cancers
61

Reworked internal dose calculations for 

PER-066 case 2 

 Used appropriate inhalation and ingestion intake values from 

table 5 of DCAS-TKBS-0004, rev. 01

 Calculated doses using CADW for total uranium, Pu-239, 

Np-237, Am-241, Th-230, and Tc-99

 Compared absorption types as specified in table 5

 Doses entered in IREP as constant values

 Resulted in assigning a total dose of >22.0 rem for cancer 1 

and >23.0 rem for cancer 2
62

SC&A’s conclusions about internal dose 

calculations for PER-066 case 2 

 Concurs that EE should be classified as a plant worker

 Verified correct inhalation and ingestion intake values from table 5 

of DCAS-TKBS-0004, rev. 01

 Confirmed the greater dose was assigned considering the potential 

solubility types

 Re-ran CADW used rev. 01 TBD-specified values

 Using IREP, SC&A calculated a POC that approximated NIOSH’s 

POC

 No findings about the rework of case 2

 SC&A did have one finding about TBD rev. 01
63

Issue resolution for PER-066 subtask 4, 

finding 1

Finding 

date

Finding description NIOSH followup Finding resolution

6/8/2006 TKBS-0004, rev. 01, table 5, has 

errors associated with inhalation and 

ingestion for Administrative Workers:

• Th-230 ingestion intake value of 

6.3E-1 pCi/day is incorrect; the 

correct value is 1.7E-3 pCi/day

• Tc-99 inhalation intake value of 

1.9E-1 pCi/day is incorrect; the 

correct value is 5.2E-4 pCi/day

• Tc-99 ingestion intake value of 

4.0E-3 pCi/day is incorrect; the 

correct value is 1.1E-5 pCi/day

10/31/2018. 

NIOSH 

acknowledged that 

there were errors 

in these three 

entries in table 5. 

They are in the 

process of revising 

the TBD to correct 

those values.

10/31/2018. SCPR 

closed the finding 

but requested that 

the BRS be 

updated when the 

TBD was revised. 

NIOSH revised the 

TBD November 5, 

2018, and table 5 

values were 

corrected.
64

Board discussion of DCAS-PER-066