OCAS-PER-025 and DCAS-PER-033, 

Subtasks 1–3

EVALUATION OF HUNTINGTON PILOT 

PLANT (HPP) TBD REVISIONS

SC&A Report Dated July 18, 2013

Presented to the

Advisory Board’s Procedures Review Subcommittee

November 7, 2013

1
PER Summary

• PER-025 (2007) was issued due to the 

addition of electron dose to the TBD in 2004.

• PER-033 (2011) was issued because of the 

revisions in the TBD that occurred in 2008.

2
TBD Revisions

• A summary of the HPP TBD (OCAS-TKBS-0004) 

revisions is as follows: 

 10/31/2003, Rev. 00

 01/16/2004, Rev. 01

 08/12/2008, Rev. 02

3
PER-025 NIOSH Issue

• NIOSH stated that the revised HPP TBD (Rev. 

01 of January 16, 2004) could potentially 

increase assigned dose to claimants whose 

claims had previously been processed, with a 

resulting POC <50%, using an earlier version of 

the HPP TBD (Rev. 00 of October 31, 2003) 

because of the added section concerning 

electron dose. 

4
PER-025 NIOSH Number of Claims

• NISOH identified one HPP claim with a POC 

<50% that was potentially impacted due to 

the issuance of the January 16, 2004, TBD 

revision.

5
PER-025 NIOSH Corrective Action

• NIOSH provided a plan of corrective action to 

resolve the issue created by the revision by 

requesting that claims be returned for a new 

dose estimate.

6
PER-033 NIOSH Issues

• NIOSH stated that several changes in the DR 

methodology occurred in the 2008 revision to 

the TBD:

 The estimate of internal dose increased from 1956 

through 1963 and for 1978 and 1979. 

7
PER-033 NIOSH Issues (continued)

 The inhalation estimate for operators went from 

approximately 3.83 pCi/day (1,400 pCi/yr) to 44 

pCi/day.

 The original intake was the geometric mean of a 

lognormal distribution with a geometric 

standard deviation of 4.3. The new estimate is a 

single bounding value. 

8
PER-033 NIOSH Number of Claims

• NIOSH found that there were 32 HPP 

potentially impacted claims completed with 

a POC <50% prior to the issuance of the 

August 13, 2008, TBD revision. 

9
PER-033 NIOSH Corrective Action

• NIOSH provided a plan of corrective action 

to resolve the issues created by the revision 

by recalculating the dose for each of the 32 

claims using all current DR methods, 

including the current version of the TBD. 

From that recalculated dose, a new POC was 

determined.

10
SC&A’s Evaluation of PER-025 & 033

Subtasks 1 (Issues) & 2 (Corrective Action)

• In conjunction with SC&A’s evaluation of OCASPER-025 and DCAS-PER-033, SC&A performed a 

paragraph-by-paragraph comparison of the 

following documents to determine if there were 

any changes in the later revisions that could 

potentially increase the assigned dose: 

 01/16/2004, Rev. 01 was compared to 10/31/2003, 

Rev. 00

 08/12/2008, Rev. 02 was compared to 01/16/2004, 

Rev. 01.

11
SC&A’s Evaluation (continued)

• From this evaluation, SC&A identified the 

following changes that have the potential to 

increase assigned dose during DR:

 Electron Skin Dose

 Occupational Medical Dose 

 Shallow Dose 

 Period of Internal Intake

 Internal Intake Values

12
Electron Dose

• Electron Skin dose – This change was addressed in 

OCAS-PER-025, and was the basis for initiating 

OCAS-PER-025. SC&A evaluated OCAS-PER-025 

and found it to sufficiently address this issue. SC&A 

had no findings from this comparison.

13
Occupational Medical Dose

• Occupational Medical Dose – The Occupational 

Medical Dose Section 9.0, page 17 of Rev. 02, 

recommends using ORAUT-OTIB-0006 to assign 

medical x-ray doses. However, it is recommended in 

Rev. 01 to use organ doses as listed in Table 8, page 

12, of the TBD. Comparing the recommended dose 

in ORAUT-OTIB-0006, Table 6-5, to Table 8 of the TBD 

Rev. 01 indicates that this change could cause an 

increase in dose to the skin, stomach, and thymus in 

some cases. However, if a new DR is performed as 

recommended by DCAS-PER-033 using the current 

TBD, this issue will be addressed. 

14
Shallow Dose

• Shallow Dose – Table 6, page 17, in Rev. 02 

provides for lower annual deep and shallow dose 

assignments than those recommended on page 12 

of Rev. 01; except Rev. 02 recommends an annual 

dose of 1.000 rem shallow dose to the hands and 

forearms for Operators and Maintenance 

personnel, whereas only 0.85 rem per year skin 

dose is recommended in Rev. 01, page 12, without 

reference to hands or forearms. This could result in 

an increase in assigned skin dose in some cases. 

However, if a new DR is performed as 

recommended by DCAS-PER-033 using the current 

TBD, this issue will be addressed. 

15
Period of Internal Intake

• Period of Internal Intake – Table 5, page 16, of Rev. 

02 provides a summary of the recommended 

inhalation and ingestion intakes for the periods 

1956–1963 and 1978–1979. However, Rev. 01 

addresses the period 1951–1963, but does not 

specifically address the period 1978–1979. 

Therefore, in some cases, the inclusion of the 

period 1978–1979 could increase the assigned 

dose. However, if a new DR is performed as 

recommended by DCAS-PER-033 using the current 

TBD, this issue will be addressed. 

16
Intake Values

• Internal Intake Values – Table 5, page 16, of Rev. 02 

provides a summary of the recommended inhalation 

and ingestion intakes for the periods 1956–1963 and 

1978–1979. The values assigned in this table were 

derived from an updated inhaled intake of 44 pCi/d 

of total uranium. Table 5, page 8, of Rev. 01 

recommends only 3.83 pCi/d; therefore, in some 

cases, this change could increase the assigned dose. 

However, if a new DR is performed as recommended 

by DCAS-PER-033 using the current TBD, this issue 

will be addressed.

17
Summary of Subtasks 1 & 2

• SC&A evaluated the TBD changes (concerning 

occupational medical dose, extremity shallow 

dose, periods of internal intake, and internal 

intake values) and concurs with NIOSH’s 

corrective action plan.

• SC&A found that OCAS-PER-025 and DCASPER-033 sufficiently addressed the changes in 

the HPP TBD and that the PERs recommended 

proper corrective actions. 

18
OCAS-PER-025

Subtask 3 (Number of claims)

• SC&A used the NOCTS database system to 

verify that only one HPP claim was 

impacted by OCAS-PER-025, and that a new 

DR had been performed for this claim.

19
DCAS-PER-033

Subtask 3 (Number of claims)

• SC&A used the NOCTS database system to 

verify that there were 32 HPP claims impacted 

by DCAS-PER-033. It is recommended that 

SC&A review the 32 remaining claims as 

described in Subtask 4 below.

20
Subtask 4

Selection of DRs to Audit for PER-025

• Because there was only one case that was 

impacted by PER-025, it is recommended that 

SC&A review this case and evaluate the 

recalculated and assigned doses to verify that 

they conform to the new recommendations in 

the revised TBD and OCAS-PER-025.

21
Subtask 4

Selection of DRs to audit for PER-033

• Because there were numerous (32) claims 

impacted by PER-033, it is recommended that 

SC&A review this list of claims and select 5 to 

10 of the claims that would most likely be 

impacted by DCAS-PER-033. SC&A will then 

evaluate the recalculated and assigned doses 

to verify they conform to the new 

recommendations in the revised TBD and 

DCAS-PER-033.

22
Questions?

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