Draft

Advisory Board on Radiation and Worker Health

National Institute for Occupational Safety and Health

Review of ORAUT-RPRT-0092, Revision 00, “Evaluation of 

Bioassay Data for Subcontracted Construction Trade 

Workers at the Savannah River Site” 

Contract No. 75D30119C04183

Document No. SCA-TR-2019-SEC005, Revision 0

Prepared by

Robert Barton, CHP

Ron Buchanan, PhD, CHP

Joe Fitzgerald, MS, MPH

SC&A, Inc.

2200 Wilson Boulevard, Suite 300

Arlington, VA 22201-3324

November 12, 2019

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for 

Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker 

Health (ABRWH), including its Working Groups or Subcommittees. Documents produced by 

SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or 

ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected 

by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, Inc. Technical Support for the Advisory Board on Radiation and Worker Health’s Review 

of NIOSH Dose Reconstruction Program

Document Title Review of ORAUT-RPRT-0092, Revision 00, “Evaluation of Bioassay Data 

for Subcontracted Construction Trade Workers at the Savannah River 

Site”

Document Number SCA-TR-2019-SEC005

Revision Number 0 (Draft)

Supersedes N/A

Effective Date November 12, 2019

Task Manager Joe Fitzgerald, MS, MPH [signature on file]

Project Manager John Stiver, MS, CHP [signature on file]

Document Reviewer(s) John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision Number Effective Date Description of Revision

0 (Draft) 11/12/2019 Initial issue
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Table of Contents

List of Tables................................................................................................................... 5

List of Figures.................................................................................................................. 5

Abbreviations and Acronyms........................................................................................... 6

1 Executive Summary ................................................................................................. 8

1.1 Sampling premise .............................................................................................. 8

1.2 Sampling execution............................................................................................ 9

1.3 Coworker datasets ........................................................................................... 10

1.4 Overall conclusions .......................................................................................... 10

2 Summary of Findings and Observations ................................................................ 12

3 Introduction and Background ................................................................................. 14

4 Review of Assumptions and Basis for Subcontractor Data Sampling, 1972–1989 16

4.1 Special Work Permits, job plans, and required bioassays (1972–1989) .......... 17

4.2 Basis for identifying “radionuclides of interest” for sampled permits................. 24

4.3 Representativeness of SRS facilities in RPRT-0092 sampling......................... 28

4.4 Inclusion of incident-based bioassays to supplement permit-related job-specific 

bioassays................................................................................................................... 33

4.5 Incompleteness of SRS dose records .............................................................. 34

4.6 SRS internal dosimetry policy and procedural changes, 1972–1998 ............... 38

5 Analysis of Pre-1990 Subcontractor Data .............................................................. 41

5.1 1972–1974 ....................................................................................................... 44

5.2 1980–1989 ....................................................................................................... 46

5.3 Summary conclusions for pre-1990 time period............................................... 51

6 Evaluation of RPRT-0092 1990–1998 Data ........................................................... 54

6.1 RPRT-0092 RWP data per SRS area (1990–1998)......................................... 54

6.2 Procedural check of RPRT-0092’s analyses of bioassay data (1990–1998).... 55

6.3 Analysis of coworker data needed to supplement CTW data........................... 59

6.4 Implementation in the field was not a step function beginning in 1990............. 60

7 Conclusions ........................................................................................................... 62

7.1 Sampling premise ............................................................................................ 62

7.2 Sampling execution.......................................................................................... 63

7.3 Coworker datasets ........................................................................................... 64

7.4 Overall conclusions .......................................................................................... 65
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8 References............................................................................................................. 66

Appendix 1: SC&A’s Analysis of OTIB-0081 NOCTS Bioassay Data per SRS Area 

(1972–1990).................................................................................................................. 71

Appendix 2: SC&A’s Analysis Used to Spot Check RPRT-0092 Data Process............. 73
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List of Tables

Table 1. Total identified workers by year, building 773-A.............................................. 31

Table 2. Summary of SC&A evaluation of plutonium monitoring data (1972–1974)...... 45

Table 3. Summary of SC&A evaluation of fission product monitoring data (1972–1974)

...................................................................................................................................... 46

Table 4. Summary of SC&A evaluation of americium monitoring data (1980–1989)..... 47

Table 5. Summary of SC&A evaluation of plutonium monitoring data (1980–1989)...... 50

Table 6. Summary of SC&A evaluation of fission product monitoring data (1980–1989)

...................................................................................................................................... 51

Table 7. Summary of SC&A evaluation of pre-1990 subcontractor data for total 

monitored versus RPRT-0092 values............................................................................ 52

Table 8. Comparison of monitoring percentages involving at least one radionuclide 

(RPRT-0092 value) versus all radionuclides on work permit (SC&A value) .................. 53

Table 9. Summary of using all required radionuclides compared to using only at least 

one required radionuclide for subCTWs directly monitored........................................... 57

Table 10. Breakdown by year of using all required radionuclides compared to using only 

at least one required radionuclide for subCTWs directly monitored .............................. 57

Table 11. Summary of using all required radionuclides compared to using only at least 

one required radionuclide for subCTWs effectively monitored ...................................... 58

Table 12. Breakdown by year of using all required radionuclides compared to using only 

at least one required radionuclide for subCTWs effectively monitored.......................... 58

Table 13. Summary of use of coworkers for subCTWs ................................................. 59

Table 14. Summary of use of monitored coworkers for unmonitored subCTWs for 

plutonium....................................................................................................................... 60

Table 15. Percent of RWP required bioassays compared to the total number of 

bioassays in RPRT-0092, table C-1 .............................................................................. 61

Table 16. Comparison of monitoring percentages involving at least one radionuclide 

(RPRT-0092 value) versus all radionuclides on work permit (SC&A value) .................. 64

List of Figures

Figure 1. Example of Special Work Permit (DuPont, 1972)........................................... 19

Figure 2. Example job plan (DuPont, 1983) .................................................................. 22

Figure 3. Number of years elapsed between end of job plan and internal monitoring 

result ............................................................................................................................. 48

Figure 4. Number of RWPs per SRS area per year (1990–1998) ................................. 54

Figure A1. Fraction of NOCTS in vitro bioassays from areas at SRS (1972–1990) ...... 71

Figure A2. Fraction of NOCTS in vivo bioassays from areas at SRS (1972–1990)....... 72
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Abbreviations and Acronyms

ABRWH, 

Advisory Board Advisory Board on Radiation and Worker Health 

ALARA as low as reasonably achievable

Am americium

ANSI American National Standards Institute

BSRC Bechtel Savannah River Company

Ce cerium

Cs cesium

CTW construction trade worker

CW coworker 

DOE U.S. Department of Energy 

DPSOL DuPont Savannah River Operating List 

DPSOP DuPont Standard Operating Procedure 

E&I Electrical and Instrumentation

EDWS Electronic Document Workflow (Records) System 

FP fission product 

HP Health Physics (department)

HPO health protection organization 

HPT Health Physics Technology 

mrem millirem

N/A not applicable 

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH Division of Compensation Analysis and Support Claims Tracking 

System

Np neptunium 

OCAS Office of Compensation Analysis and Support 

ORAU Oak Ridge Associated Universities

Pu plutonium 

RCA Radiologically Controlled Area 

RCO Radiological Control Operations 

Ru ruthenium 

RWP Radiological Work Permit 
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SAR safety analysis report

SEC Special Exposure Cohort 

SID sample identification

Sr strontium 

SRDB Site Research Database

SRS Savannah River Site 

SRTC Savannah River Technology Center 

SRWP standing radiological work permit 

subCTW subcontracted construction trade worker 

SWP Special Work Permit

TBM technical basis manual 

U uranium 

WSI Wackenhut Services Incorporated

WSRC Westinghouse Savannah River Company 
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1 Executive Summary

The report, ORAUT-RPRT-0092, revision 00, “Evaluation of Bioassay Data for Subcontracted

Construction Trade Workers at the Savannah River Site” (NIOSH, 2019a, “RPRT-0092”), was 

issued by the National Institute for Occupational Safety and Health (NIOSH) on June 14, 2019.

The Advisory Board on Radiation and Worker Health’s (Advisory Board’s) Savannah River Site 

(SRS) Work Group tasked SC&A, Inc. to review it on June 16, 2019.

This NIOSH evaluation is particularly important because construction subcontractors often 

performed nonroutine jobs involving unique radiological source terms or conditions, and permitindicated, job-specific bioassays were necessary to verify whether intakes may have taken place. 

SC&A earlier raised concerns over identified gaps in such bioassay data for 1997 and questioned 

whether it was sufficiently complete and representative for earlier years to support the 

application of a coworker model for assigning internal doses.

SC&A reviewed NIOSH’s evaluation from three vantage points:

1. Sampling premise: From the standpoint of sampling experience and results, were the 

guiding assumptions upon which the evaluation was planned and conducted borne out for 

the time periods in question?

2. Sampling execution: From the standpoint of sampling execution, was its primary goal 

accomplished? In other words, did it “randomly select radiological workers from the 

various areas at the Savannah River Site (SRS), such that an evaluation of monitored and 

unmonitored workers can be conducted” (NIOSH, 2018a, p. 1)?

3. Coworker datasets: From the standpoint of NIOSH’s “Draft Criteria for the Evaluation 

and Use of Coworker Datasets” (NIOSH, 2015), did the evaluation satisfy its stated 

objective of demonstrating that “monitored subcontractor CTWs and unmonitored 

subcontractor CTWs worked side by side in the same radiological environment at the 

same time” (NIOSH, 2018a, p. 1)?

1.1 Sampling premise

For the first vantage point concerning the sampling premise, SC&A concludes that NIOSH’s 

guiding assumptions for sampling subcontractor bioassay data for 1972–1989 have neither been 

validated in practice nor adequately grounded in DuPont policies, procedures, and practices of 

that time period. In vitro and in vivo bioassays were linked to Special Work Permits (SWPs) and 

job plans without clear evidence that the former stemmed from the latter and were not merely 

incidental. None of the SWPs and job plans for that period reviewed by SC&A contain any 

bioassay requirements, despite the vast majority of them requiring respiratory protection. The 

basis for identifying “radionuclides of interest” for sampled permits does not account for 

inadequate radiological characterization cited by the U.S. Department of Energy (DOE). The 

scope of sampling is limited to only one SRS facility, 773-A, for incomplete operational periods, 

and is not representative of other critical SRS facilities. The inclusion of incident-driven 

bioassays is not appropriate, given the degree of procedural accountability provided special 

bioassays, as compared with that afforded the routine and job-specific bioassay program (for 

which DOE found a history of delinquent bioassays). Finally, the completeness of these and 
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other radiological records is questionable, given the acknowledged destruction of subcontractor 

records, DOE findings of missing occupational dose data, and firsthand worker accounts

regarding dose records gaps. 

For the post-1989 period, SC&A concludes there were similar concerns until such time as the 

new contractor, Westinghouse Savannah River Company (WSRC), was able to develop and 

implement improved internal dosimetry programs, and hold SRS line management more 

accountable, as part of its Radiological Improvement Plan. This plan included a spectrum of new 

and updated radiation protection and bioassay policies and procedures that evolved over time, 

including (1) the late 1990 “Internal Dosimetry Technical Basis Manual” (WSRC, 1990b), 

(2) the implementation of a 1990 standardized Radiological Work Permit (RWP) program 

(WSRC, 1990a) requiring job-specific bioassays (implementation began in 1991) that were 

required upon respirator use (WSRC, 1992b), and (3) manual 5Q1.1, “Radiation and 

Contamination Control Procedures” (WSRC, 1992b), which replaced DuPont Savannah River 

Operating List (DPSOL) procedures. However, it is not clear when effective implementation was 

actually achieved, given the persistence of former workplace practices, as illustrated by the 

significant job-specific bioassay gaps uncovered by WSRC and DOE in 1997–1998. 

1.2 Sampling execution

For the second vantage point concerning sampling execution, SC&A concludes that for 1972–

1989, NIOSH’s interpretation of “effective monitoring”1

 to include unmonitored workers who 

are matched to workers monitored via an internal dosimetry method (in vivo or in vitro) that is 

not used in the development of the ORAUT-OTIB-0081 coworker models (NIOSH, 2019c; 

“OTIB-0081”) is not appropriate. Likewise, NIOSH considered chest count data that were more

than 2 years past the end of the job plan as a valid monitoring result. However, NIOSH’s own 

policies regarding chest counts for long-lived nuclides consider periods longer than 2 years to be 

“unmonitored” (refer to ORAUT-OTIB-0060 (NIOSH, 2018b, pp. 24–25) and RPRT-0092 

(NIOSH, 2019a, p. 34). When SC&A revised the “matching” percentage in RPRT-0092 based on 

removing these two questionable adjustments, it was found that the effective monitoring for 

americium for 1981–1987 dropped to 33 percent versus 76 percent reported in RPRT-0092; for 

plutonium for 1972–1974, the effective monitored population decreased to 64.7 percent versus 

69 percent.; and for fission products for 1972–1974, it dropped to 69.9 percent from 94 percent, 

and for 1980–1989, it dropped to 73.9 percent from 99 percent (see section 5 of this report).

 1 “Effective monitoring” as used in RPRT-0092 indicates the percentage of workers who were monitored directly 

(in vitro or in vivo) plus those who were on the same job plan/work permit with an individual who was monitored 

directly.

For all evaluated periods (1972–1998), SC&A concludes that the NIOSH review did not appear 

to adhere to its sampling plan because bioassays for all of the radionuclides listed on the RWP 

were not addressed in the corresponding data analyses for the specific time intervals. When 

SC&A recreated and compared data from RPRT-0092, table 6-4, “Rates of Monitoring of 

subCTW for at Least One Radionuclide, 1981 to 1998,” when considering all radionuclides on a 

work permit, it was found that results adjust downward to significantly lower percentages, 

particularly in the earlier periods. For 1972–1974, the percentage of directly monitored workers 

reported drops from 76 percent to 47.1 percent, and that of effectively monitored workers drops 

from 85 percent to 55.1 percent. For 1980–1989, the percentage of directly monitored workers 
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reported drops from 90 percent to 51.3 percent, and the effectively monitored percentage drops 

from 99 percent to 65.5 percent. For 1990–1998, the percentage of directly monitored workers 

reported drops from 96 percent to 77 percent, and that of effectively monitored workers drops 

from 98 percent to 89 percent. 

1.3 Coworker datasets

For the third vantage point concerning establishing that unmonitored subcontractors worked side 

by side with monitored subcontractors, SC&A concludes that the current sampling effort in 

RPRT-0092 was not successful in identifying suitable coworkers for americium for 1981–1987, 

as just 13 percent of the overall population (16 percent of the unmonitored population) was 

matched based on coworker urinalysis. For fission products 1980–1989, just 1.4 percent of the 

overall population (37 percent of the unmonitored population) were effectively matched by in 

vivo. No suitable coworker matches were identified for fission products in the 1972–1974 

period, and only a single unmonitored worker was identified for americium exposure during this 

same period. No coworker evaluations for any radionuclides were possible for 1975–1979. For 

plutonium, the sampling effort identified coworker matches for about 15 percent of the worker 

population (29 percent of the unmonitored population), which raised the effective monitored 

population from 50 percent to 65 percent for 1972–1974. 

For 1990–1998, a focused review of plutonium coworker matches during the WSRC period notes 

that while nearly 96 percent of the identified coworker matches involve the same job plan, 

inclusion of additional criteria (e.g., the same date, time, and craft) decreases this percentage 

significantly. When considering all four criteria for a coworker match (job plan, date, time, and 

craft), appropriate coworker matches for plutonium were identified in RPRT-0092 just 

45 percent of the time.

1.4 Overall conclusions 

Overall, SC&A concludes that the RPRT-0092 assessment of subcontractor data completeness 

for 1972–1998 (1) does not reflect the policies, procedures, and practices during the DuPont 

operating era of 1972–1990 and (2) makes unfounded assumptions, inferences, and claims for 

monitoring “success” rates for bioassay performance that sometimes lead to errant results and 

conclusions, as a function of the radionuclide and timeframe involved. These sitewide SRS 

operational conditions only change with the advent of new and updated RWP and bioassay 

procedures implemented by WSRC in the early 1990s, at which point the basis and assumptions 

for the RPRT-0092 assessment can be better substantiated, and results considered valid. SC&A 

finds that applying the same assumptions and evaluation criteria concerning permit-driven, jobspecific bioassays for the entire 26-year span of SRS operations under evaluation is not plausible 

and does not consider critical changes in work controls and bioassay procedures during that 

timeframe. Further, questions of overall data completeness persist based on reported destruction 

of subcontractor records and gaps in worker exposure records, compounded by issues of records 

retention and retrievability.

In summary, without a validation of subcontractor data completeness for all relevant SRS

radionuclides and representative facilities that the RPRT-0092 evaluation was to provide, there 

has not been adequate substantiation for 1972–1990 that there are sufficient job-specific bioassay 

measurements available to ensure that the coworker data in OTIB-0081 are either bounding or 
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representative of the exposure potential of subcontractors performing permit-driven work across 

the SRS site. Further, based on SC&A’s review, this question of completeness is not confined to 

subcontractor CTWs but extends to all CTWs who would have been subject to permit-required 

bioassays in 1972–1990. 

The next section (section 2) provides a summary of SC&A’s review findings and observations 

for RPRT-0092. 
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2 Summary of Findings and Observations

This section presents SC&A’s 11 findings and five observations from its review of RPRT-0092. 

• Finding 1: No SWPs or job plans sampled by NIOSH for 1972–1990 contain any 

requirements or indications for job-specific bioassays, despite respiratory protection 

being required, bringing into question the approach taken to satisfy RPRT-0092’s first 

evaluation objective. See section 4.1. 

• Finding 2. “Radionuclides of interest” assumed for sampled permits in RPRT-0092 are of 

questionable accuracy given cited lack of adequate radiological source term 

characterization prior to 1990. See section 4.2. 

• Finding 3. The scope of permit sampling for 1972–1990 at SRS is essentially limited to 

one facility, 773-A, falling short of achieving NIOSH’s sampling objective and the 

representativeness called for in NIOSH’s coworker guidelines. See section 4.3. 

• Finding 4: SRS incident-based/special bioassays were provided by workers on a more 

stringent procedural basis and should not be used to supplement the evaluation of permitrelated, job-specific bioassays for 1972–1989 as a measure of historic data completeness. 

See section 4.4. 

• Finding 5: The incompleteness of SRS dose records for 1972–1990 is substantiated by 

the acknowledged destruction of subcontractor records and firsthand worker accounts, 

coupled with DOE findings of missing occupational radiation dose data from many SRS 

personnel files, as well as systemic bioassay delinquencies, and wide gaps in NIOSH’s 

capture of permit documentation. See section 4.5.

• Finding 6: For the period 1980–1989, only 20 percent of the identified subcontractor-job 

plan combinations identified by NIOSH as requiring americium sampling had internal 

monitoring performed within an acceptable timeframe (i.e., within 2 years for chest 

counting). See section 5.2.1. 

• Finding 7: The total “effectively monitored” population for americium (those monitored 

directly or have a coworker on the same job plan with a urinalysis result) during the 

1980–1989 period is approximately 33 percent. If a urinalysis sample taken during 1991 

as in a different SRS location (and is not currently used in the SRS 

coworker model) is removed, the effective monitored population drops to 26.5 percent. 

See section 5.2.1. 

• Finding 8: Many of the workers (around 70–73 percent) who should have been monitored 

for fission products underwent appropriate internal sampling during the two periods 

evaluated prior to 1990 (1972–1974 and 1980–1989). However, very few of these 

monitored workers underwent in vivo counting for fission products. Thus, they are not 

included in the coworker model developed for SRS and are not considered representative 

of the unmonitored worker. See section 5.3. 

• Finding 9: SC&A does not find that the data collected as part of the RPRT-0092 review 

support the premise that subcontractors on job plans that should have required internal 

monitoring for americium were either directly monitored (around 20 percent) or, 
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alternately, appropriately represented in the derived coworker models for SRS (around 

13 percent). See section 5.3. 

• Finding 10: Data for 1990 are lacking. Therefore, 1990 should be included with the 

period of limited data, 1972–1989, and not bundled in with the year 1991. See 

section 6.1. 

• Finding 11: For both the 1972–1989 and the 1990–1998 periods, when considering all 

radionuclides requiring internal monitoring per work permit, as opposed to “at least one 

radionuclide” requiring monitoring, the percentage of monitored workers drops 

significantly (particularly in the earlier periods). Directly monitored workers ranged from 

47 percent to 77 percent (in comparison to 76–96 percent in RPRT-0092), and effectively 

monitored workers ranged from 55 percent to 89 percent (in comparison to 85–99 percent 

in RPRT-0092). See section 7.2. 

• Observation 1: The back application of assumptions regarding work permits, job-specific 

bioassays, and target radionuclides to conduct a completeness review for 1972–1998 is 

not plausible given the significant changes in radiological policies, procedures, and 

practices that occurred in the early 1990s. See section 4.6. 

• Observation 2: During the 1972–1974 period, RPRT-0092 only evaluates one job 

plan/worker combination (Job Plan 46) for potential americium exposure. However, 

attachment D, table D-1 indicates at least one other job plan (Job Plan 47) requiring 

americium monitoring during this period. Neither of the workers were directly monitored 

nor had an appropriate coworker monitored for americium. See section 5.1.1. 

• Observation 3: Only 13 percent of the subcontractor-job plan combinations (17 total) had 

americium urinalysis performed that could be considered relevant to coworker modeling. 

Eleven of the 17 urinalysis data points represented a single worker who had a single 

sample taken in 1991 as that occurred in a different area ( ) 

during that year (i.e., representative of a different area and different period). See 

section 5.2.1. 

• Observation 4: SC&A’s analysis indicates that identified coworker matches may not be 

sufficiently representative of the subCTW intakes in all cases unless strict criteria are 

applied, such as the same craft designation as well as the same date and time of the work 

performed. See section 6.3. 

• Observation 5: Bioassay data in the 1990s are not entirely free of the earlier data issues.

The implementation of methods used to correct for the bioassay deficiencies seen in the 

1970s and 1980s did not take place immediately with the change in the contracting 

company in 1990. It was not a step function that took place in 1990; instead, it took a 

number of years to identify, address, and effectively implement the changes. For 

example, there was only one RWP with one subCTW listed for 1990 in RPRT-0092, and 

specific radionuclides were not required on the RWPs until the mid-1990s. See 

section 6.4. 
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3 Introduction and Background

SC&A was originally tasked by the Advisory Board in 2017 to conduct a broad review of 

bioassay data completeness for subcontracted construction trade workers (subCTWs) at SRS, 

resulting in its report, “Evaluation of Savannah River Site Subcontractor Bioassay Data 

Completeness” (SC&A, 2017a). This completeness review was undertaken in parallel with a 

NIOSH effort to review the completeness of bioassay data for building 773-A for the years 

1981–1986 (ORAUT-RPRT-0083, revision 00 (NIOSH, 2017a)). At the time, the Advisory 

Board was concerned that NIOSH’s review would be too narrow (in terms of facility scope and 

timeframe) to resolve the issue of subcontractor CTW bioassay data completeness on a sitewide 

basis (ABRWH 2016a, p. 49; 2016b, pp. 150–172). 

Establishing data adequacy and completeness is a prerequisite for developing and applying any 

coworker model, as is currently proposed by NIOSH in OTIB-0081 for construction trade 

workers (CTWs), including subcontractors (NIOSH, 2019c). As has been emphasized in various 

meetings and forums, SC&A finds that the rapidly changing operational circumstances at SRS 

beginning in the late 1980s and extending into the 1990s, with emphasis given to reactor restart, 

decontamination and decommissioning, waste management, and environmental cleanup, 

contributed to a rapid influx of subcontractor CTWs to augment onsite resources. This led to 

questions by SC&A and the Advisory Board about their bioassay monitoring. In particular, 

transient subcontractors may not have been bioassayed adequately in light of their oftenintermittent work on site and the lack of a comprehensive termination bioassay program. This 

concern was underscored by an earlier finding that DOE had, in fact, cited and fined WSRC in 

1998 for not adequately monitoring workers performing radiation work under job-specific RWPs 

(DOE, 1998a).

NIOSH has since discovered 852 boxes of RWPs, job plans, and SWPs for SRS that 

encompassed the years of interest, 1972–1998. Given the paucity of RWPs identified to that 

point in time, these records offered a means to conduct sampling for bioassay completeness and 

to characterize the subcontractor CTW cohort for the years in question. The ABRWH Savannah 

River Site Work Group requested that NIOSH conduct such an evaluation based on its 

experience evaluating bioassay completeness for building 773-A for 1981–1986 in ORAUTRPRT-0083, “Evaluation of Monitoring of Construction Workers Identified in High-Level Cave 

Job Plans at the Savannah River Site” (NIOSH, 2017a). 

NIOSH prepared an “SRS Work Permit Sampling Plan” that had as its primary goal to 

“randomly select radiological workers from various areas at the Savannah River Site (SRS), such 

that an evaluation of monitored and unmonitored workers can be conducted” (NIOSH, 2018a, 

p. 1). NIOSH noted in its transmittal of the Plan that “the attached SRS Work Permit Sampling 

plan describes what we have learned and proposes details of how information can be sampled to 

obtain an unbiased data set to evaluate subcontractor monitoring for both co-worker applicability 

(original question – did monitored and unmonitored subcontractor CTWs work together) and to 

evaluate specific radionuclides of interest (new question – appropriate source term)” (Taulbee, 

2018). 

SC&A’s approach to reviewing RPRT-0092 is distinguished by the two time periods and two 

corresponding SRS operating contractors—DuPont and Westinghouse—who programmatically 
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defined and implemented distinctly different work permit and job-specific bioassay programs for 

1972–1989 and 1990–1998, respectively. This distinction manifested itself in a number of ways 

but was most apparent in the lack of procedural requirements, permit records, job-specific 

bioassays, and other program documentation before 1990, with major initiatives thereafter by 

WSRC to update requirements, define formal technical bases and procedures for internal 

dosimetry, and hold line management and workers more accountable for adhering to them. 

The lack of available records led NIOSH to diverge from its sampling plan for the 1972–1989 

period and collect all applicable records, which happened to be for only one area, 773-A/776-A, 

SRS’s analytic laboratory operation. SC&A divided its review in a similar manner, focusing first 

on the premise and assumptions underpinning NIOSH’s evaluation for each of the two time 

periods, with a second assessment of how the sampling was actually performed for plutonium, 

americium, and fission products consistent with the sampling plan goals and evaluation 

objectives. Although there were more bioassay records that covered plutonium, americium, 

uranium, neptunium, and fission products for more of the major work areas at SRS for the 1990–

1998 period compared to the 1972–1989 period, SC&A found that some issues carried over into 

the 1990s, and that it took time to implement new procedures in the field.

SC&A’s goal was to test both the central thesis for RPRT-0092—that bioassays can be linked to 

corresponding work permits so that monitored subcontractor CTWs can be compared with 

unmonitored subcontractor CTWs—and whether the actual sampling process was conducted in a 

sound manner. As such, it is a “weight of evidence” assessment that reviews all aspects of 

NIOSH’s evaluation, from sampling premise and design, to sampling execution, and finally, to 

results achieved.
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4 Review of Assumptions and Basis for Subcontractor Data 

Sampling, 1972–1989

In an earlier presentation to the SRS work group (NIOSH, 2017b), NIOSH found that 91 percent

of 371 subcontractor claimants in NIOSH’s Division of Compensation Analysis and Support 

Claims Tracking System (NOCTS) (340 of 371) have internal monitoring data. Based on 

NIOSH’s qualitative review, any lack of monitoring appeared to be “randomly distributed.” 

However, as emphasized before the Advisory Board in 2017, SC&A believes that the key 

question is the representativeness of that data. As concluded by SC&A (2017b), 

• “Representativeness” is a key issue: How relatable are exposures of 

subcontractors on RWP job-specific bioassays compared to those working 

under “typical” or general work conditions with prescheduled routine 

bioassays? NIOSH needs to adequately demonstrate that routinely 

monitored workers were doing the same jobs or tasks as those solely on 

job-specific bioassay.

• RWPs before 1999 at SRS were neither complete nor consistently applied 

with respect to job-specific bioassays. Unmonitored intakes may have 

occurred due to workplace radiological source terms not being properly 

characterized and included in RWPs. Most RWPs appear to be missing for 

WSRC 1989–1995[2]

; few remain for the DuPont era (past interviews 

indicate subcontractor records destruction in 1989 during contract 

transfer).

 2 The correct time span for WSRC permits is now established as 1990–1998.

While the lack of available work permits (RWPs) for the earlier SRS time periods precluded an 

examination of these issues at the time, NIOSH’s discovery of 852 boxes of such records 

spanning the 1972–1998 timeframe led to the job-specific bioassay sampling evaluation whose 

results are presented in RPRT-0092. However, as with any sampling of historic monitoring 

records, the goals, assumptions, protocol (including evaluation criteria), and operational basis are 

critical. In the April 2018 version of its “SRS Work Permit Sampling Plan” (NIOSH, 2018a), 

NIOSH defined its approach, as follows. 

The primary goal of this sampling plan is to randomly select radiation workers 

from the various areas at the Savannah River Site (SRS), such that an evaluation 

of monitored and unmonitored workers can be conducted. A concern has been 

raised by the Advisory Board on Radiation and Worker Health (ABRWH) that a 

co-worker model, even if the models are stratified by operations workers and 

construction trades workers, might not be representative for subcontractor CTWs. 

The ABRWH’s Savannah River Site Workgroup’s contractor indicated that they 

would be more comfortable with the co-worker models if it could be 

demonstrated that monitored subcontractor CTWs and unmonitored subcontractor 

CTWs worked side by side in the same radiological environment at the same time. 

The NIOSH/ORAU team determined the best way to demonstrate this monitoring 

is to randomly pull Special Work Permits (SWPs), Job Plans, and Radiological 
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Work Permits and directly compare the monitoring of subcontractor workers 

listed as having worked on the individual Work Permit. [(NIOSH, 2018a, p. 1)] 

SC&A provided comments on this sampling plan (SC&A, 2018b). These included agreement 

that Standing Radiation Work Permits (SRWPs) should not be included (typified more routine 

work), that permits involving tritium exposures should not be included (less dose significance, 

more data availability), and that while in vivo monitoring should be considered, caution needed 

to be exercised to account for all of the target radionuclides in the periodic counting performed. 

Most importantly, SC&A expressed a concern over how NIOSH would address pre-1989 permit 

sampling. While the use of subcontractors was more limited during the DuPont era (i.e., before 

1990, although increasing numbers of subcontractors were being brought on site beginning in the 

mid-1980s), SC&A emphasized the need for “obtaining a representative sample from which a 

bioassay completeness assessment can be performed for that earlier period,” and the “need to 

reflect the availability of RWPs/SWPs for 1972–1988, and encompass a sufficient scope of 

facilities and timeframe” (SC&A, 2018b, p. 5). While it was observed, at the time, that NIOSH’s 

sampling approach may differ for this earlier period due to relatively fewer subcontractors and 

permits, and that clearly 773-A was the only facility represented, SC&A stressed the need for 

“continued scrutiny for any additional boxes of permit records that may apply for pre-1989 

facilities beyond just A Area” (SC&A, 2018b, p. 6). 

Contrary to NIOSH’s statement that its bioassay comparisons in RPRT-0092 would serve to 

make the Board’s contractor “more comfortable with the co-worker model” (Taulbee, 2018), 

more importantly, it is the Advisory Board that needs assurance that the approach taken in the 

RPRT-0092 evaluation achieved its intended goals, that the assumptions made proved sound, and 

that sampling itself was conducted in a manner consistent with the sampling plan, SRS 

operational practice, and established NIOSH technical positions.3 SC&A addresses the first two 

questions in this section (section 4) and the question of sampling execution in sections 5 and 6 

for the 1972–1989 and 1990–1998 periods, respectively.

3 Including the OTIB-0081 coworker model (NIOSH, 2019c), plutonium CTW stratification refinement (NIOSH, 

2019d), and internal dose reconstruction (NIOSH, 2018b). 

4.1 Special Work Permits, job plans, and required bioassays (1972–1989)

As NIOSH notes in RPRT-0092, very few boxes were identified with job plans and Special 

Work Permits (SWPs) for the period before 1991, and those were only for work in A Area 

(facility 773-A). SWPs most closely resembled the later RWPs in intent and format, with not 

only procedural checkoffs for radiological practice, monitoring, and equipment but also an 

explicit requirement for a job-specific bioassay to be left “before leaving building” (DuPont, 

1972; see figure 1 under item 1 below). NIOSH indicates that SWPs were phased out sometime

between 1972 and 1976,4 with DuPont Standard Operating Procedures (DPSOPs) (or DuPont 

Savannah River Operating Lists (DPSOLs))5 becoming the sole source of bioassay sampling 

guidance (NIOSH, 2019a). However, as NIOSH confirmed, these procedures were too general in 

terms of monitoring guidance and did not specify bioassay requirements. 

 

4 However, some were still in use in 1985, based on SC&A’s review of NIOSH’s “List of Construction Trade 

Workers Identified in Job Plans” (NIOSH, 2019b). 5 DuPont issued its procedures as DPSOPs, with some contained in DPSOLs. 
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Because of the relatively small number of SWPs and job plans available for 1972–1989,6 NIOSH 

forwent its planned sampling regime and collected all subcontractor work data from job plans 

that required bioassay or respiratory protection. Job plans and SWPs were collected covering 

portions of 1972, 1973 through 1976, and 1979 through 1988 for work done in facility 773-A, 

with a total of 204 work permits (“permits”7 meaning SWPs and job plans) included in the 

sampling review by virtue of NIOSH’s sampling protocol. Following a detailed review of all 

permit “folders of interest” that were identified based on these criteria, NIOSH excluded a

number of permits as not actually requiring bioassay for their task, resulting in 146 permits of 

interest encompassing 662 subcontractors for 1972–1989 (NIOSH, 2019a). 

6 While NIOSH bifurcated its review into two periods, 1972–1989 and 1990–1998, SC&A found little permit 

documentation was identified for 1990, for unknown reasons. However, it should be noted that WSRC had just 

assumed management of the SRS operating contract and was in the process of implementing a new, formal RWP 

system. Any conclusions for 1972–1989 would, therefore, also apply for 1990. Additionally, no permits were 

identified after March 1988. 7 SC&A is using “permits” to signify SWPs and job plans in the context of DuPont operations at SRS in 1972–

1989. RWPs did not exist at SRS during this timeframe, until implemented by WSRC in the 1990–1991 timeframe.

SC&A reviewed CTW permits obtained for 1971–19888 and determined that none of those 

reviewed actually specified a job-specific bioassay requirement. 

8 This was accomplished by reviewing every SWP and job plan listed in NIOSH’s internally compiled “List of 

Construction Trade Workers Identified in Job Plans” (NIOSH, 2019b) for 1972–1981, and a sampling of one every 

month for 1981–1988 (given the larger numbers involved), for a total of 430 individual permits reviewed. The 

disparity between NIOSH’s number of permits and that of SC&A’s review stems from SC&A’s review of available 

CTW permits identified (including subCTW permits) before they were culled in the selection process.

It is clear that the vast majority 

of permits identified as “of interest” in terms of an assumed job-specific bioassay requirement 

are actually so designated because of a specified requirement for respiratory protection. SC&A 

considers the assumed linkage between a work permit and a related bioassay to be faulty for the 

following reasons: 

1. None of the SWPs reviewed for the 1972–1989 period have a required job-specific 

bioassay checked off.

SWPs are the only work permits for the 1972–1989 period that actually provide for a jobspecific bioassay requirement, but none that SC&A reviewed, at least in NIOSH’s 

survey, have that requirement checked off, and no indication for a job-related bioassay is 

provided in the comment portion of the SWP for any bioassay monitoring. This is despite 

most of the selected SWPs requiring respiratory protection, with the work location being 

773-A, a facility that involved laboratory services that included high-level cells used in 

the analysis and testing of highly radioactive material from onsite and offsite facilities

(La Bone, 1996). These operations involved plutonium-239 (Pu-239), curium-244, 

americium-243 (Am-243), californium-252, and fission products, all of which posed an 

exposure potential given the scope and magnitude of work activities and the presence of 

contamination. An illustrative example of a 1972 SWP selected by NIOSH, without the 

bioassay requirement being checked but requiring an “assault mask” (respirator), is 

provided in figure 1. 

 
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Figure 1. Example of Special Work Permit (DuPont, 1972)

2. None of the job plans reviewed for the 1972–1989 period have a required jobspecific bioassay indicated, despite DPSOPs providing such an option to line 

supervisors and health physics.
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Job plans can include provisions for tritium and other nuclides being required for 

bioassay, as outlined in DPSOP-40 (for tritium) or “as specified by area Health Protection 

in Construction Job Plan” (DuPont, 1972–1992). These procedures indicate that area 

health physics can specify radionuclides and sampling frequencies beyond routine ones

(DuPont, 1989). Line organizations also had the discretion to develop procedures for 

“routine bioassay samples at frequencies equal to or less than one month” (DuPont, 

1987). 

Such nonroutine,9

 job-related bioassay sampling would complement what routine 

sampling would have been already required at a particular SRS facility, in terms of 

radionuclide type and frequency. Ensuring that workers who moved from job to job and 

facility to facility were monitored for all applicable radionuclides is something that would 

be later termed “composite” bioassay monitoring by WSRC and be required for “Roving 

Employees,” such as CTWs and subCTWs, as follows: 

Roving Employees 

Personnel whose job assignment requires them to enter RCAs in different 

facilities across the Site during the course of their regular work should be 

placed on a bioassay schedule which ensures they are counted (in-vivo

program) and/or sampled (in-vitro program) for the appropriate 

radionuclides. Examples of these groups may include Site Support 

Services such as E&I and Maintenance, HPO inspectors and supervisors, 

WSI personnel, and Bechtel Construction personnel and their 

subcontractors. For these individuals a composite routine bioassay 

program is required. [(WSRC, 1992b, PDF p. 37)] 

Such explicit requirements for “composite” routine bioassays for construction workers, 

specifically for those that moved (“roving”) from facility to facility, and from job to job, 

did not exist in DuPont procedures. 

9 Job-specific bioassays were defined as “non-routine” bioassays until the mid-1990s, when they were redefined in 

the WSRC 5Q1.1 procedure and incorporated in the routine program as part of internal exposure verification; they 

were defined as part of the routine bioassay program in the internal dosimetry Technical Basis Manual beginning in 

1991.

The importance of this dictum was emphasized in the same procedure, WSRC’s first 

version of 5Q1.1, procedure 506, revision 0, as follows: 

 
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5.2 Routine Bioassay Program Assignment 

Caution: It is EXTREMELY IMPORTANT to note that the 

effectiveness of the bioassay program in general depends on 

combining both the routine program and the non-routine, jobspecific program. Any time unusual events occur, or jobs are 

performed that may expose personnel to unusual hazards, a jobspecific program should be considered per Section 5.1.2.1. 

[(WSRC, 1992b, PDF p. 36)] 

DPSOL procedures for bioassay10 provided different guidelines for construction workers 

versus operational workers. Operational workers had type and frequency of bioassay 

sampling designated by specific area and facility, while construction workers had general 

requirements, with discretion provided facility managers or local health physics to 

specify bioassay for job-specific radionuclides. The only sitewide requirement was for 

plutonium, tritium, and fission products, with all other radionuclides to be addressed in 

construction job plans (DuPont, 1971). However, there is no evidence in the sampled 

permits referenced in RPRT-0092 for 1972–1989 of any such sampling for “other 

radionuclides” being required in job plans for CTWs or subCTWs. Without job-specific 

bioassays to complement the required plutonium, tritium and fission product routine 

bioassays, “roving” construction workers would not have been adequately enrolled for 

the radionuclides to which they may have been potentially exposed, and the bioassay 

database for both CTWs and subCTWs would accordingly be incomplete. 

 10 Examples of bioassay procedures include DPSOL 47-137 (DuPont, 1973a) and DPSOL 193-302, revision 7 

(DuPont, 1976). 

A typical job plan selected by NIOSH is shown in figure 2. 
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Figure 2. Example job plan (DuPont, 1983)

While NIOSH concludes that DPSOPs are too “general” to be a basis for identifying 

specific permit-related, job-specific bioassay requirements, it is still apparently assumed 
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that DuPont line managers and health physicists would have done so, either through 

SWPs and job plans or by some other means. However, while respiratory protection 

requirements are often checked and workplace contamination cited in the permits 

sampled, there is no evidence that related job-specific bioassays were indicated or 

required. Such a procedural requirement would not have been in standard practice until 

1991, when a formal RWP system with job-specific bioassay requirements was 

implemented by WSRC. 

3. No identified procedural requirement or practice supports the linkage between 

respiratory protection requirements in job plans “of interest” and related jobspecific bioassays.

One of NIOSH’s guiding assumptions for ascertaining whether a job-specific bioassay 

would have been required in conjunction with an SWP or job plan during 1972–1989 is 

reflected in the following provision: 

Because of the low number of boxes identified for 1972 through 1990 in 

the sampling plan, the team was charged with collecting all subCTW work 

data from Job Plans that required bioassay or respiratory protection. 

[(NIOSH, 2019a, p. 47)] 

The assumption that a respirator requirement on the job plan made it one “of interest” 

(i.e., one having a corresponding job-specific bioassay) has no clear basis in DuPont 

practice. It was not made a sitewide guideline for routine respirator use until 1992 in 

WSRC manual 5Q1.1, revision 0 (WSRC, 1992b), as follows:

Personnel who wear respiratory protection or who work in posted 

Contamination or Airborne Radioactivity Areas must be sampled for the 

nuclide to which they are potentially exposed, via either the routine 

sampling program or non-routine, job-specific sampling program. 

[(WSRC, 1992b, PDF p. 60)] 

While it can be considered good practice and may have been implemented by DuPont 

facility managers or area health physicists on a job-by-job basis, until 1992, there was no 

sitewide procedure for workers using respiratory protection, and for those working in 

contamination, to be bioassayed for the radionuclides to which they were potentially 

exposed. There may have been routine bioassays performed as called for by DPSOL 

procedures governing bioassay types and frequencies by facility, but there is no evidence 

provided in either RPRT-0092, DPSOL procedures, or other records from the DuPont era 

reviewed by SC&A that job-specific bioassays were procedurally linked to a respirator 

requirement in the job plan.

The survey of subcontractor bioassay completeness conducted in RPRT-0092 for 1972–

1989 is founded on the key assumption that SWPs and job plans “of interest” can be 

identified by their required job-specific bioassays or respirator requirements. However, 

none of the permits sampled by NIOSH and reviewed by SC&A show any bioassay 

requirements, and there is no basis provided, in either DuPont procedures or practice, for 
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a procedural link between respirator requirements and follow-on job-specific bioassays.

On the contrary, a formal RWP program with clearly defined job-specific bioassay 

requirements was not initiated until the early 1990s under WSRC. Likewise, a formal 

procedure for job-specific bioassays linked to a respiratory protection requirement in a 

work permit was not promulgated until 1992. 

Finding 1: No SWPs or job plans sampled by NIOSH for 1972–1990 contain any 

requirements or indications for job-specific bioassays, despite respiratory protection 

being required, bringing into question the approach taken to satisfy RPRT-0092’s first 

evaluation objective. 

4.2 Basis for identifying “radionuclides of interest” for sampled permits

As noted in RPRT-0092, NIOSH conducted three evaluations of permit-related subCTW data:

(1) the fraction of subCTWs identified on RWPs of interest who were monitored 

for internal intakes of radionuclides, (2) identification of appropriate coworker(s) 

who were internally monitored to use as surrogates for unmonitored subCTWs, 

and (3) radionuclides of interest for each RWP along with the bioassay 

monitoring for those radionuclides. [(NIOSH, 2019a, p. 28)] 

To support the third evaluation criterion, regarding “radionuclides of interest” for the work area 

or facility, NIOSH first investigated the work area identified in the permit (NIOSH 2019a).

However, for 1972–1989, the SWPs and job plans did not typically include “radionuclides of 

interest” based on a SC&A review of those sampled by NIOSH. At most, survey readings and 

sometimes contamination levels are indicated. 

A second-tier consideration for identifying appropriate radionuclide source terms in RPRT-0092 

were “those that should have been required by SRS procedures in place at the time of work” 

(NIOSH 2019a, p. 30). While WSRC bioassay type and frequencies for the 1990s were based on 

comprehensive workplace exposure characterization as described in WSRC’s technical basis 

manuals for internal dosimetry (WSRC, 1990a, 1990b, 1992a, 1992b, 1993, 1996, 1997), DuPont 

DPSOL procedures for bioassay were “general” in nature (as noted by NIOSH), with health 

protection operations managers responsible for maintaining and updating DPSOL tables that 

listed facility radiological exposure sources and required bioassay frequencies. Line managers 

were also responsible for development of facility procedures governing bioassay sampling for 

radionuclides for which sampling frequency was equal to or less than 1 month (DuPont, 1987). 

For construction workers, including subcontractors, “Construction Job Plans” were relied upon 

to complement routine facility-based bioassays (for plutonium, tritium, and fission products) by 

ensuring that additional job-specific bioassays were conducted for “other nuclides” (DuPont, 

1985). 

Whether facility “radionuclides of interest” for bioassay purposes were accurate and updated for 

changes in operation or experience is questionable during the DuPont era. General DPSOL job 

plan and bioassay requirements, coupled with delegated implementation of those requirements 

through facility managers, would have made consistent radiological characterization and 

accurate radionuclide identification difficult. While SC&A did not find an internal (i.e., DuPont) 

self-assessment of this issue, the DOE Tiger Team review of 1990 made the following finding: 
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The internal dosimetry program does not comply with the requirements of DOE 

5480.11. Radiological areas have not been sufficiently characterized to provide a 

technical basis for the assignment of bioassay sample types and frequencies.

[(DOE, 1990, p. 4-193)] 

This finding was based on a sitewide assessment of the internal dosimetry program that found 

the following, in part: 

• The technical basis for determining bioassay type and frequency has not been 

established for the nuclides encountered at SRS. The Naval Fuel Facility was 

characterized (report dated February 16, 1989) to provide a basis for assigning 

the proper bioassay type and frequency to workers in that facility. However, 

no other nuclear facilities have been characterized in a similar manner. 

Consequently, bioassay assignments are made without the benefit of a sound 

technical basis. Health Protection (HP) Operations Managers decide the type 

and frequency of routine bioassays, based on DPSOP 193-211, Table A. 

• Particle size and solubility are not well known or used to help decide bioassay 

type and frequency. [(DOE, 1990, p. 4-198)] 

In its June 20, 1990, action plan response, WSRC agreed that “a formal technical basis for the 

SRS bioassay program has not yet been established” but emphasized that its program was “based 

on years of experience [and an] awareness of what has constituted good practice in the past, 

common sense, and conservative assumptions for determining employee doses” (WSRC, 1990a, 

PDF p. 432). It further noted that SRS was in the process of developing a technical basis 

document for the internal dosimetry program that would be “consistent with the requirements of 

the Order [5480.11] and appropriate guidance.” The action plan further detailed that, “during the 

development of the technical basis manual this year, the radionuclide materials at each area on 

the site are being characterized” (WSRC, 1990a, PDF p. 432). 

The development of the internal dosimetry technical basis manual (WSRC, 1990b) and new 

“Radiation and Contamination Control Procedures” in WSRC manual 5Q1.1 (WSRC, 1992b), 

and their respective, successive revisions, were intended to update and replace DuPont’s 

procedures, as part of an overall SRS Radiological Improvement Plan. This plan addressed “the 

necessity for the line management to accept responsibility for radiological protection of their 

employees and facility visitors” (WSRC 1990a, PDF p. 433).

The specific issue of workplace characterization was raised again in a 1999 WSRC selfassessment following the 1998 DOE enforcement action surrounding implementation of the 

WSRC job-specific bioassay program (Morgan, 1999). At that time, it was determined that for 

two SRS facilities, Am-241 was present as an operational source term but not included in the 

routine bioassay program.11

 11 This issue was raised separately in SC&A’s memorandum report of January 11, 2018 (SC&A, 2018a). A 

response was provided by NIOSH in ORAUT-RPRT-0091, revision 00, “Evaluation of Savannah River Site 

Americium-241 Source Terms between 1971 and 1999 Using Bioassay Frequency Tables” (NIOSH, 2019d). SC&A 

is currently responding to this report, separately.
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The apparent reliance of DuPont era facility managers and health protection organizations on 

their longstanding radionuclide sampling tables and their knowledge of facility operations is 

similar to the identified root cause of the 1999 concern, which was described as a reliance on 

programmatic facility knowledge rather than continuing and rigorous radiological source-term 

characterization, as noted below: 

Historically, bioassay requirements were identified by the Radiological Control 

Operations (RCO) organization through facility process knowledge (i.e., safety 

analysis documentation), procedural guidance and professional judgement. The 

[new] methodology discussed in this memorandum [Farrell & Findley, 1999] was 

used by Health Physics Technology (HPT) to update and/or reverify facility 

specific radionuclides of concern for bioassay program compliance. [(Farrell & 

Findley, 1999, p. 1)] 

The updated methodology provided by this memorandum was a detailed, facility-by-facility 

baselining of relevant radiological source terms based on review of “existing waste certification 

or process stream analysis data,” coupled with alternative means such as isotopic workplace air 

and contamination sampling. The basis for including target radionuclides were those isotopes 

with “dose fractions greater than 10%” based on respective Annual Limit on Intake Values, 

which is indicative of “which isotopes contribute the majority of internal dose to an individual 

for a specific source term” (Farrell & Findley, 1999, p. 2).

The facility characterization process was defined and implemented by WSRC, as reflected in its 

technical basis manual (TBM), beginning in 1990, with refinements through the 1990s (WSRC, 

1990b, 1992a, 1993, 1997). The 1997 Manual predated the Farrell and Findley (1999) guidance, 

but provided similar guidelines:

Radionuclides of concern are determined in the following manner: All 

radionuclides in a facility to which workers could be exposed are identified from 

contamination survey records, safety analysis reports (SARs), technical reports, 

the open literature, personal interviews, etc. The radionuclides whose 

radiotoxicity and exposure potential combine to deliver the majority of the dose, 

say 90%, are deemed to be the radionuclides of concern. All other radionuclides 

may be ignored unless they are suitable for use as a tracer. This process for 

selecting radionuclides of concern is of most use for waste streams where many 

radionuclides may be present. 

This information is used, along with facility experience, to produce a listing of 

facilities and the radionuclides for which workers in that facility should be 

monitored. This list, which appears in Procedure 5Q1-506 . . ., recommends 

bioassay programs that are in agreement with those given in most radiological 

work permits (RWP) that are issued in a facility. However, it must be stressed that 

the radiological requirements for a task, including the bioassay program, are 

specified in the RWP. Thus, the requirements of the RWP supersede the 

requirements of 5Q 1.1-506. [(WSRC, 1997, p. 3-4)] 
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As noted previously, this sitewide, detailed guidance for comprehensive facility characterization 

was not in place during the DuPont era at SRS. If workplace radiological characterization was 

not adequately and consistently performed at SRS facilities, as found by the 1990 DOE 

assessment, bioassays would not necessarily have been performed when required based on the 

potential exposures present and for the sampling frequencies necessary for an adequate 

measurement. 

Farrell and Findley (1999), which constituted the third consideration and “final authority” for 

determining facility radionuclides in RPRT-0092, was issued “In response to a concern over 

prescribing the correct urine bioassay sampling program[s] on radiological work permits” 

(WSRC, 1998, p. 1). For building 773-A (encompassing the Savannah River Technology Center) 

and associated operations, it observed: 

Additionally, certain facilities such as the Savannah River Technology Center 

(SRTC) and the solid waste disposal facilities handle a wide array of 

radioactive materials, some of which may not be encountered in the typical 

radiological work environment by workers in those areas. For facilities such 

as 221-FB-Line, where the source term is well defined and not subject to change, 

this is not a concern unless there is a major change in the facility mission. To 

ensure that the proper radionuclide(s) is identified for the RWP urine sampling 

program it may be necessary to perform a thorough characterization of the work 

environment. It is important also that this characterization be performed on a 

routine basis to stay current on the source term present. [Emphasis added.]

[(WSRC 1998, p. 2)] 

Such a routine, comprehensive characterization was not standardized practice during the DuPont 

era into the early WSRC era, except at specific facilities such as the Naval Fuel facility cited by 

DOE in its Tiger Team Assessment finding above. Given the complexity of operations in 773-A, 

the multiple source terms, the noted inadequacies of the DuPont bioassay procedures 

(particularly the absence of a sitewide defined job-specific bioassay program managed on a 

facility-by-facility basis), and finally the lack of a rigorous workplace radiological 

characterization process, it is questionable whether, based on DPSOL procedures alone, a 

particular “radionuclide of interest” could be designated for a specific job plan, as undertaken by 

RPRT-0092 (and reflected in attachment D). 

From Farrell and Findley (1999), supplemented by DuPont bioassay type and frequency tables, 

primary source terms for 773-A were deemed to be plutonium, americium, and fission products, 

for which bioassay matches were tracked in attachment D of RPRT-0092. However, given the 

noted complexity of laboratory operations in 773-A and the changing nature of experimental and 

operational support studies, DuPont procedures, together with Farrell and Findley (1999), would 

not necessarily reflect source terms of relevance for bioassay requirements. For example, for the 

Actinide Technology Center, neptunium-237 (Np-237) and various uranium isotopes were 

handled, in addition to plutonium and americium. For the Analytical Development Section, 

uranium, neptunium, and curium12 figured in operations,

 12 SC&A acknowledges that curium was measured as part of the trivalent bioassay method, which measured 

americium, curium, and californium coincidentally.

 in addition to plutonium and fission 
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products (La Bone, 1996). From a review of radiological survey data and logsheets for 773-A 

from 1975 to 1986, SC&A found a number of instances of the handling and contamination 

surveying of neptunium and curium in various operations at 773-A (e.g., DuPont, 1975, 1977, 

1981a). While the primary radionuclides (plutonium, americium, fission products) may have 

constituted the majority of the routine potential dose, these and other source terms, particularly 

those of an experimental or operational support nature, would have figured in permitted 

nonroutine, job-specific work that should have been evident from the RPRT-0092 sampling 

conducted. 

Finding 2: “Radionuclides of interest” assumed for sampled permits in RPRT-0092 are of 

questionable accuracy given cited lack of adequate radiological source term 

characterization prior to 1990.

4.3 Representativeness of SRS facilities in RPRT-0092 sampling

The SRS work permit sampling plan has as its primary goal to “randomly select radiological 

workers from the various areas at the Savannah River Site (SRS), such that an evaluation of 

monitored and unmonitored workers can be conducted” (emphasis added) (NIOSH, 2018a, p. 1).

However, as noted later in the plan (and repeated in RPRT-0092), following an initial inventory 

search conducted of the estimated number of RWPs per year by area, it was concluded that “the 

only clear information that we have been able to glean from this search is that SWP and Job 

Plans are only available for one area during the 1972-1989 time period” (NIOSH 2018a, p. 6). 

This was attributed to the possibility that “SWPs and/or Job Plans for other areas may have been 

destroyed,” although it was noted that “we likely will never know” (NIOSH 2018a, p. 6).

Given the lack of identified permit records for SRS areas and facilities other than 773-A,13

NIOSH chose to depart from its detailed and statistically based random sampling of permits for 

1972–1989 and simply use all of the subcontractor work data it had collected, as noted below: 

Because of the low number of boxes identified for 1972 through 1990 in the 

sampling plan, the team was charged with collecting all subCTW work data from 

Job Plans that required bioassay or respiratory protection. The team reviewed 

folders from physical boxes and EDWS identified in the box inventory. Job Plans 

and SWPs covered portions of 1972, 1973 through 1976, and 1979 through 1988 

for work done in Building 773-A. [(NIOSH, 2019a, p. 47)] 

 13 SC&A’s review of available CTW permits identified by NIOSH in its search of various records sources (i.e., 

Federal Records Center, Electronic Document Workflow (Records) System (EDWS), Site Research Database 

(SRDB)), as listed for 1972–1989 in SRDB 173828, determined that with only a few exceptions (e.g., 776-A), 

permits were only identified for 773-A. This circumstance is apparently acknowledged by NIOSH by the 

interchangeable use of “A Area” and “773-A” as the cited scope of facility permits in RPRT-0092.

However, by diverging from its sampling plan and conducting its subcontractor job-specific 

bioassay review for only one SRS facility (773-A), NIOSH neither met its stated primary goal 

for the RPRT-0092 assessment to sample “various areas at SRS,” nor satisfied the following 

criteria in NIOSH’s “Draft Criteria for the Evaluation and Use of Coworker Datasets” (NIOSH, 

2015): 
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the amount of available monitoring data must be evaluated to determine if there 

are sufficient measurements to ensure that the data are either bounding or 

representative of the exposure potential for each job/exposure category at the 

facility. This analysis should look, not only at the total amount of data that are 

available, but also consider any temporal trends in data availability. [(NIOSH, 

2015, p. 5)] 

The scope of permit sampling conducted for 1972–1988 for the one facility, 773-A, has 

expanded the existing subcontractor completeness review for 773-A conducted by NIOSH in 

ORAUT-RPRT-0083 (NIOSH, 2017a). In that review, job plans and SWPs for 1979–1986 for 

773-A were identified, generating an initial random sample of 110 subcontractors without 

bioassay, which was evaluated and culled down to 88 subcontractor CTW-job pairings 

monitored by bioassay (based on respirator requirements). The RPRT-0092 review has added 

additional pairings of permits with bioassay results (likewise based on respirator requirements), 

e.g., for 1972–1979 and 1987–1988. 

It is clear that assessing the work permits for only one of 30 plus facilities at SRS and, even then, 

for only intermittent periods (1972, 1973 through 1976, and 1979 through 1988), does not 

provide for a representative SRS-wide validation that subcontractor job-specific bioassays were 

performed for permit-related radiological work for representative SRS facilities. These other 

facilities include (with key operational radiological source terms cited) as described in La Bone 

(1996): 

• F and E Areas: 

o 221 FB-Line, A-Line, 221-F Canyon, Solid Waste Disposal Facility, Pu Storage 

Facility, F/H Area Tank Farms, F Area Outside Facilities, PuFF and PEF 

facilities, Effluent Treatment Facility 

o Source terms:14 Pu-239, Pu-238, uranium-235 (U-235), U-238, cerium-144 

(Ce-144), ruthenium-106 (Ru-106), strontium-90 (Sr-90), cesium-137 (Cs-137) 

• H Area: 

o H Canyon, Pu Oxide Facility, 211-H Outside Facilities, Receiving Basin for 

Offsite Fuel facility, Resin Regeneration Facility 

o Source terms: Pu-239, Pu-238, Np-237, U-235, Ce-144, Cs-137, Ru-106, Sr-89, 

Sr-90 

• M Area: 

o Uranium Target Fabrication Facility, Fuel Fabrication Facility, 320-M, 322-M, 

341-M 

o Source terms: U-235, U-236, U-238 

 14 This is a representative listing by area and is not all inclusive of full range of facility radiological source terms.

The magnitude of these historic operations, with their diverse and substantial radiological 

hazards, history of contamination and intakes, and large worker populations, makes their absence 
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from NIOSH’s sampling in RPRT-0092 a fundamental concern. For example, the F/H Area Tank 

Farms had radiological jobs that were regularly supported by CTWs, including subcontractors, 

and were associated with a history of serious contamination incidents, intakes, and uptakes of 

fission products (e.g., Cs-137), plutonium and other high-level waste constituents (e.g., DuPont 

(1981b), DuPont (1982)).15

15 As cited in various DuPont incident reports involving skin contaminations, fission product intakes, and Cs-137 

uptakes (assimilations) at the 241-F/H Tank Farms for 1975, 1980, 1981, and 1982.

Likewise, the F and H Area Canyons were the major fuel 

reprocessing facilities for the site and were associated with a similar radiological history of 

contamination, intakes, and confirmed uptakes, as indicated by the review of incidents for 1985–

1990 in RPRT-0092 and also by SC&A’s review of the same and similar incidents (e.g., DuPont 

(1973b), DuPont (1974), DuPont (1984)).16

16 As cited in various DuPont incident reports involving skin and clothing contaminations and uptakes 

(assimilations) of Pu-238, tritium, and fission products.

 Based on a review of available operational logbooks, 

facility descriptions, and incident reports, operations in these and other facilities involved many

high-hazard radiological jobs for which contamination was present and respirators required. 

This raises several fundamental questions, including the following: 

• What was the implementation experience involving job-specific bioassay performance 

for SWPs and job plans for all of these key operations? 

• How did various facility managers and local area health physicists for these specific 

operations apply work planning requirements, and how was bioassay mandated and 

carried out where known contamination existed and respirator protection was required? 

• Can the original concerns surrounding the completeness of job-specific bioassays that 

surfaced in the 1997–1998 WSRC self-assessments and DOE enforcement action be 

addressed without permit records for other significant radiological operations at SRS for 

1972–1990? 

SC&A believes that the answer to the last question is “no,” and the response to the other two is 

that there is no way to know given the lack of available records cited in RPRT-0092. 

As a potential qualifying consideration, NIOSH noted the following regarding the relative 

number of subcontractors in the SRS workforce for this earlier period:

The number of individual subCTWs employed at SRS from 1972 to 1989 further 

complicates the analysis for that period. At SRS during this period DuPont 

primarily used in-house CTWs. A large majority of work performed under Job 

Plans and reviewed by the team for A Area was done by DuPont construction 

workers. SRS employed relatively small numbers of subCTWs during that time, 

and not all work by subCTWs was on jobs that required bioassay. [(NIOSH, 

2019a, pp. 47–48)] 

SC&A agrees with NIOSH that subcontractors figured less prominently in the SRS workforce 

prior to the Westinghouse era (1990), and that DuPont tended to use in-house CTWs side by side 

with its own employees. However, as SC&A pointed out in its comments on the sampling plan, 

this did not negate the importance of establishing “that those subcontractors were doing the same 

 
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work as the in-house CTWs” (SC&A 2018b, p. 5). Further, SC&A reconfirmed the need to 

conduct a representative sampling of subcontractors in 1972–1989: 

As a followup to last Friday’s teleconference regarding SRS path forward, we 

have discussed this within SC&A, and propose that NIOSH pursue pre-1989 

RWPs/SWPs in terms of obtaining a representative sample from which a bioassay 

completeness assessment can be performed for that earlier period. This 

assessment would need to reflect the availability of RWPs/SWPs for 1972–1988, 

and encompass a sufficient scope of facilities and timeframe. Based on Tim’s 

presentation, it appears that 11 boxes have been identified to date that contain 

records of this kind for that period; presumably, additional boxes will be 

identified as the ongoing NIOSH review is completed. It would be important that 

NIOSH include a sampling approach for the pre-1989 period based on what is 

found in the boxes. The work group, supported by SC&A, would review these 

sampling plans (including one for the latter period) and provide any comments to 

NIOSH, as noted [in] Friday’s call. Given the relatively fewer number of 

transient subcontractors (and subcontractors, in general) and RWPs during 

the 1970s and 1980s, it is understood that NIOSH’s sampling approach may 

differ from what is done for the 1990s. 

We believe this approach to be the most efficient one that can provide the best 

assessment on the subcontractor completeness at this point. [(SC&A, 2018b, 

p. 5)] 

While SC&A acknowledges that “NIOSH’s sampling approach [for 1972–1989] may differ from 

what is done for the 1990s,” SC&A also pointed out that the number of subcontractors identified 

even for the one facility, 773-A, differed widely between March 1973 (“0” subcontractors, 

compared with 35 DuPont CTWs and 185 operations employees) and the period 1981–1986. For 

that latter period, table 2-2 of ORAUT-RPRT-0083 (see table 1 below, which is reproduced from 

that table), shows a total of 650 subCTWs at 773-A, with as many as 172 subCTWs in the year 

1985 alone (NIOSH, 2017a).

Table 1. Total identified workers by year, building 773-A 

Year DuPont CTW

DuPont CTW with 

potential for intake Subcontractor CTW

Subcontractor CTW 

with potential for 

intake

1980 60 48 8 8

1981 47 41 82 47

1982 68 55 80 20

1983 70 43 99 57

1984 60 49 122 65

1985 49 44 172 115

1986 43 25 87 38

Totals 397 305 650 350

Source: Reproduced from table 2-2 of ORAUT-RPRT-0083 (NIOSH, 2017a) 
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As SC&A pointed out, “it is clear that the particular year and SRS facility chosen to be sampled 

(at least for Radiation Survey Logsheet surveys) will influence the number of subcontractor 

CTWs identified” (SC&A, 2018b, pp. 5–6).

Finally, SC&A further emphasized: 

It is important to sample what pre-1989 RWPs are available to validate that the 

two worker cohorts (DuPont CTW and subCTW) are similar in terms of work and 

exposure potential. This would add further basis for confirming that conclusion, 

given the initially ambiguous findings of the recent NIOSH/OCAS Claims 

Tracking System (NOCTS) comparison. This would argue for a sampling regime 

focused on the SWPs identified for A Area facilities, for which permits were 

identified in the 1972–1989 timeframe (although SWPs appear to have been 

phased out by 1976). It would also argue for continued scrutiny for any additional 

boxes of permit records that may apply for pre-1989 facilities beyond just A Area. 

[SC&A, 2018b, p. 6]17

17 The “recent NIOSH/OCAS Claims Tracking System (NOCTS) comparison” refers to a NIOSH analysis of 

DuPont CTWs vs. subcontractor CTWs for plutonium urinalysis, 1956–1988, as a means to compare 95th percentile 

urinary excretion rates in support of subcontractor CTWs being included in the same cohort as CTWs for 

stratification purposes in the coworker model (NIOSH, 2017c). SC&A has reviewed the white paper (NIOSH, 

2019d), issued as a further review of this issue, and has issued a memorandum report in response.

From RPRT-0092, it is evident that SWPs were, in fact, only identified for the 1970s (although a 

few were noted for 1980–1985), and none of those had a job-specific bioassay requirement 

checked off. Further, additional searches conducted by NIOSH did not surface any pre-1990 job 

plan records for SRS facilities other than for 773-A/776-A. 

While the NOCTS in vitro and in vivo bioassay data that support the OTIB-0081 coworker 

model for CTWs do include a spectrum of SRS facilities,18 it has not been demonstrated to be the 

case for the RPRT-0092 bioassay sampling of subcontractor data for 1972–1990. With 

completeness of subcontractor bioassay data being gauged as a basis for validating the coworker 

model (OTIB-0081), this becomes particularly important, as acknowledged in the 2015 “Draft 

Criteria for the Evaluation and Use of Coworker Datasets,” because of the need to ensure, “as 

part of this analysis, [that] the number of monitoring samples for each identifiable job category 

should be compared to the total number of workers who were potentially exposed in that job 

category,” including “any temporal trends in data availability” (NIOSH, 2015, p. 5). That is not 

feasible with RPRT-0092’s sampling only addressing one of more than 30 SRS radiologically 

significant facilities, with only 773-A subcontractor data being used as a representative sampling 

for SRS, and even for that set, having incomplete time periods of permit-related sampling. 

18 As part of this review, SC&A conducted a validation review on this question (see appendix 1 of this report).

Finding 3: The scope of permit sampling for 1972–1990 at SRS is essentially limited to 

one facility, 773-A, falling short of achieving NIOSH’s sampling objective and the 

representativeness called for in NIOSH’s coworker guidelines.

 
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4.4 Inclusion of incident-based bioassays to supplement permit-related jobspecific bioassays

NIOSH’s subcontractor completeness review for 1972–1989 includes bioassay results from 

incident reports in the late 1980s, as noted in RPRT-0092: 

As a reminder, the data in Tables 5-6 through 5-11 represent work in A Area 

Building 773-A only. While the team was not able to capture job-specific data for 

other areas, it did capture incident reports for the latter portion of the 1980s for F 

and H Areas (DuPont 1983–1989, 1989–1992). The reports include listings of 

DuPont CTWs and subCTWs. Often, the same incidents involved both sets of 

workers. The team identified 45 subCTWs in those reports who received headarea contamination occurring from 1985 through 1990 to determine if HP 

followed up with the workers with bioassay. The team assumed required bioassay 

radionuclides based on the location of work and description of the incident. 

[(NIOSH, 2019a, p. 54)] 

From a review of these incident reports (for DuPont 1989–199219), it can be confirmed that most 

of them required “special bioassays” to be performed; others, while not explicitly citing the form 

of followup bioassay, would have likely involved this particular bioassay program. 

19 SC&A’s review of DuPont (1983–1989) found it to be a collection of job plans for this period, not incident 

reports. In addition, the citation for DuPont (1989–1992) in RPRT-0092 refers to a collection of incident reports 

titled “Contamination Statistics and Monthly Reports 1983–1988” In the SRDB. For continuity between RPRT-0092 

and this review, the citation remains unchanged in this report.

Incident or intake-driven “special bioassays” are not routine bioassays. While routine bioassays 

encompass regular radiological work monitoring, verification, and termination, special bioassays 

are initiated for the following reasons (WSRC, 1997, p. 4-1, PDF p. 15): 

• in response to an incident to determine if an intake has occurred, 

• as follow-up to a known intake to quantify the intake and monitor the 

status of the person, and 

• as a follow-up to a positive routine bioassay. 

Little is referenced in DPSOLs for job-specific bioassays, other than general guidance that 

provides latitude to line supervisors to specify them, as necessary. However, special bioassays 

are accorded particular emphasis and detailed procedures. For example, as illustrated by DPSOL 

193-302, revision 7 (DuPont, 1976), detailed instructions are provided and responsibilities 

assigned to the health physics supervisors for determining when special samples (and in vivo 

counts) are needed, for notifications of medical and line supervisors, for sample collection and 

handling (including various reports and forms), and sample delivery verification. 

Clearly, job-specific bioassay sampling, when and if it occurred, was considered “verification” 

monitoring and was determined and approved by line supervisors based on their judgment of 

need for specific radiological jobs. Special bioassay sampling, however, was mandated whenever 

a known or suspected intake was determined and was the responsibility of the health physics 

 
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organization. As such, the relative level of oversight and accountability for these respective 

bioassay sampling programs can be seen as considerably different, with the special bioassay 

program being given a high level of followup attention by management and health physics.

Given the detailed procedures, the assigned management responsibilities, and higher level of 

accountability for ascertaining whether uptakes occurred and radiological limits were exceeded, 

it can be expected that almost all of the 45 subCTWs involved in the incidents cited by NIOSH 

for 1985 through 1990 would have had special bioassays conducted in a timely manner. That 

NIOSH found only 83 percent (100 percent for H Area and 78 percent for F Area), may be as 

much attributable to some of the workers being assigned to more routine followup given the 

circumstances of their contamination (that was found in a few cases reviewed by SC&A), with 

attendant delinquency issues.

The stark difference between the handling of job-specific bioassays in the DuPont era in the 

absence of a formal RWP program20 and the much more prescriptive special bioassay program 

makes the inclusion of the incident-driven bioassays for F and H Area inconsistent with what 

was actual DuPont policy and practice. One does not complement the other, and the resulting 

comparison should not be considered together as a common measure of subcontractor bioassay 

completeness. While SC&A acknowledges the lack of available permits identified by NIOSH for 

SRS facilities other than for 773-A, the use of incident-driven bioassays as a means of 

comparison to supplement the job-specific bioassay evaluation in RPRT-0092 is not appropriate. 

20 The RWP program was discontinued in the 1960s by DuPont in favor of applying internal DPSOL procedures, 

but as a DOE assessment pointed out, a requirement for RWPs and SRWPs for any work within a radiologically

controlled area (RCA) was carried forward as cited in Special Hazards Bulletins in DPSOP 40, revision 82, 

September 1989. As DOE observed, “Radiation Work Permits or Standing Radiation Work Permits are not used 

even though required by Westinghouse Savannah River Company procedures and accepted industry standards”

(DOE, 1990, p. 4-307). 

Finding 4: SRS incident-based/special bioassays were provided by workers on a more 

stringent procedural basis and should not be used to supplement the evaluation of 

permit-related, job-specific bioassays for 1972–1989 as a measure of historic data 

completeness. 

4.5 Incompleteness of SRS dose records

In its RPRT-0092 review, NIOSH identified and inventoried permits from 126 physical boxes 

and 70 electronically stored boxes, the former aided by the discovery of 852 boxes of records 

identified at an offsite Federal Records Center, and the latter through online searches of SRS’s 

EDWS online document inventory. Applying sampling criteria to identify “folders of interest” 

containing suitable subCTW permits for review, NIOSH found that “only one area (A Area) 

appears to have routinely used SWPs and/or Job Plans in the 1972 through 1989 era (DuPont 

era)” (NIOSH, 2019a, p. 14).

SC&A disagrees with this finding.21

 

21 A later statement in RPRT-0092 modifies this finding by stating, “the only clear information the team was able 

to glean from this search is that SWP and Job Plans are only available for one area during the period from 1972 to 

1990” (NIOSH, 2019a, p. 15), which SC&A believes is the accurate assessment.
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As NIOSH itself acknowledges in RPRT-0092, “current and former employee interviews 

indicated that some records were destroyed in the late 1980s or early 1990s,” and “the SWPs or 

Job Plans for other areas might have been destroyed as part of that effort” (NIOSH, 2019a, p. 

15). The following is a summary of the interviews in question: 

There were all kinds of records destroyed from the offices of subcontractors after 

they left the plant. In 1989, the subcontractors started leaving the job as their 

contracts expired. The personnel were transferred to BSRC [Bechtel Savannah 

River Company]. The crafts were transferred at various times starting in 

September 1989. In 1989, the electricians changed from Miller Dunn to BSRC. In 

the early 1990s, the fitters changed to Bechtel. Sometime in the early 1990s, 

crews of 6–8 laborers went around to the office buildings that the general 

contractors had left. It was the records in their offices that were destroyed. 

Laborers went in and shredded the records; they loaded the stuff on pickup trucks 

and left. The interviewee is not sure whose laborers were doing the shredding; 

they were either DuPont construction laborers or Bechtel construction laborers. 

They shredded all kinds of records (e.g., monitoring records, time cards) after 

the subcontractors left the plant. The interviewee observed this when [the 

interviewee] had a maintenance crew out there to fix the electricity for the 

building. [The interviewee] went out to see why the electricity was out. There 

were laborers in there cleaning out file drawers to be shredded. If the interviewee 

is not mistaken, it was the heavy equipment office [where [the interviewee]

observed this occurring], but [the interviewee] is not positive. The interviewee 

asked the laborers what they were doing, and they said they were shredding 

records. [Emphasis added.] [(SC&A, 2012, p. 55)] 

As indicated by these interviewed workers, the destruction of records during DuPont’s departure 

as SRS operating contractor in early 1990 was extensive and apparently involved a wide range of 

records, including radiation monitoring records. It will never be clear what records were 

destroyed and for what years, but the extent of this reported records destruction renders any later 

survey or compilation of subcontractor records dating prior to 1990 as suspect and presumptively 

incomplete. 

In about the same timeframe (early 1990), DOE headquarters conducted a Tiger Team 

assessment of SRS and made the following finding. 

Comprehensive records related to occupational radiation exposure are not retained 

consistent with ANSI N13.6. There are many personnel files where radiation dose 

data are missing for many years. [(DOE, 1990, p. 4-193, PDF p. 530)] 

The DOE assessment team found that SRS radiation records did not satisfy the Department’s 

performance requirement that “records related to occupational radiation exposure should 

accurately document exposures received and be readily retrievable” (DOE, 1990, p. 4-202, PDF 

p. 539). Their findings included the following (DOE, 1990, p. 4-202, PDF p. 539): 

• Radiation exposure history records are maintained in the dosimetry files in 

Bldg. 735A. All other records are boxed, inventoried, and sent to the 
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Federal Repository in Atlanta, after an interim storage period of up to 

2 years onsite. . . . 

• Prior to 1989, not all of the required records were compiled and retained in 

a readily retrievable system. Consequently, there are many personnel files 

where radiation exposure data are not easily assembled. . . . 

• Radiation records related to status of work areas, e.g., radiation survey 

reports, air sample results, etc., are not retained onsite beyond the interim 

storage period. The records sent to the Federal Repository are readily 

retrievable, but complete records are not easily compiled.

In its action plan response, WSRC noted the following: 

Radiation Work Permits (RWP’s) have been developed and their use is being 

phased in across the site. The RWP’s will tie the worker(s) and the job conditions 

together in a database in each area. Once the RWP program is in place, the record 

program will meet the requirements in ANSI N13.6. [(WSRC, 1990a, p. 3C-66, 

PDF p. 439)] 

This response seems to acknowledge22 that, while the routine internal and external dosimetry 

program maintained relatively complete and accessible dose data, the nonroutine job-specific 

dosimetry data were not being consistently obtained from workers and retained in retrievable 

form. The establishment of an RWP program to monitor and record job-specific radiation 

exposures was coupled with formal and explicit responsibilities assigned to facility management 

for ensuring bioassay samples were collected, as follows: 

As part of the 1990 SRS Radiological Improvement Plan, the site management 

has placed the responsibility for the radiological protection of the employees on 

line management. This responsibility includes monitoring the submission of 

routine and non-routine bioassay samples and followup on delinquent samples. 

Line management assures the same responsibility for facility visitors. In addition, 

the Radiation/Contamination Control Manual, 5Q, is being revised to explicitly 

state the employee’s responsibility to submit requested bioassay samples or be 

subject to disciplinary action. [(WSRC, 1990a, p. 3C-61, PDF p. 434)] 

 22 SC&A has not yet found information about the WSRC action plan that explains why and how the new RWP 

program would be the key link for ensuring the completeness and retrieval of onsite radiological records at the time.

The cited inability to readily compile radiation exposure data obtained prior to 1990, as well as 

key radiation control records (e.g., SWPs and job plans), is traceable to a longstanding SRS 

policy in the DuPont era that limited onsite retention of all but exposure histories. Records were 

only retained for up to 2 years and then shipped to the Federal Repository, for which retrieval of 

complete records can be difficult, as noted by the DOE assessment team and illustrated by 

NIOSH’s survey results for the 852 boxes retrieved. 

The issue of incomplete records is clearly compounded by evidence that SRS workers did not 

consistently submit required bioassay samples, and facility managers and SRS management did 
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not hold them accountable for doing so, an issue that was the subject of the 1998 DOE 

enforcement action. This concern was, likewise, cited in the 1990 DOE Tiger Team assessment, 

which determined that scheduled/routine bioassays were not being provided by some SRS 

employees:

Employees who fail to leave a scheduled bioassay sample for over 1 month are 

added to a delinquent list. The list also tabulates those who are 2, 3, and 4 months 

delinquent. A person who is 5 months delinquent is listed again as being 1 month 

delinquent. There is a policy to remove people from radiation work if they are 3 

months delinquent on a bioassay sample. However, there is no enforcement of this 

policy and some employees ignore requests for bioassay samples. [(DOE, 1990, 

p. 4-198, PDF p. 535)] 

DOE concluded that “when scheduled bioassay samples are not provided, it is impossible to do 

an accurate dose assessment” (DOE, 1990, pp. 4-198–4-199, PDF pp. 535–536). WSRC 

responded in its action plan that “when routine or special bioassay samples are not . . . provided 

at all, the related dose assessments must be made using available data. . . . these assessments [are 

made] on a reasonable but conservative basis” (WSRC, 1990a, p. 3C-60, PDF p. 433). However, 

apart from the need to rely on “conservative” dose assessment techniques to bridge bioassay 

gaps, for transient construction workers it may not be feasible to adequately monitor job-specific 

doses between jobs and for intermittent work at SRS. Given that DOE and WSRC both found 

that some routine and special bioassays were “not provided at all,” and that DOE established that 

management (both facility and health protection organization) was not holding workers 

accountable and enforcing bioassay sampling policies, these resulting gaps clearly become a 

contributor to bioassay data incompleteness before 1990. 

The lack of complete personnel records, including radiation exposure records, is corroborated by 

interviews with SRS workers, who provided the following accounts: 

A worker representative has sent hundreds of records requests to SRS on behalf of 

workers. When they would get the records, they would see there were gaps in the 

records. They would get a summary, but would not see the details. There would 

be an indication that a sample was given, but nothing in the records as to the 

result. NIOSH has requested records, and they have more records than are made 

available to the claimants, but they are still not complete. Even now, people who 

worked for the contractors have no records of employment out there. They want 

to know how they can verify that they worked there. Some of them have income 

tax records, or they can get signed affidavits from someone who knew that they 

worked out there. In one case, an individual was at SRS off and on from the early 

1980s to about 2002. When he returned to SRS, they did not seem to have records 

of where he had worked. They said they could not find when he was there. 

[SC&A observed that one interviewee’s DOE records (collected by NIOSH) did 

not include any data for several years scattered over a 15-year period when the 

worker was employed at SRS (late 1950s through mid-1970s).] The worker 

reported no significant changes in work activities that would explain these gaps. 

The interviewee was still entering radiological areas during these years, and does 
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not know why there are no data. Worker representatives are concerned that 

NIOSH does not have all the records. If they do have all the records, then the 

monitoring information is incomplete. [(SC&A, 2012, pp. 54–55)] 

The lack of retention of radiation monitoring records and the inability to efficiently access a 

complete file from a central offsite records repository poses a barrier to assuring an adequately 

complete work history, work permit record (relevant to RPRT-0092), and personnel exposure file 

to support a representative coworker model and dose reconstruction. This circumstance is 

analogous to that of Sandia National Laboratory prior to 1994, where program and dose records, 

in paper form, were stored in an offsite repository in “record storage boxes which are not easily 

nor routinely searched” (NIOSH, 2011, p. 27). The inability to readily access complete records 

from the offsite repository was a key stated basis for the Special Exposure Cohort (SEC) class 

being defined for Sandia for 1963–1994 (NIOSH, 2011).

In summary, an extensive onsite and offsite search for SRS records of SWPs and job plans for 

1972–1989 identified only those for one facility, 773-A. No permits were identified for the other 

major SRS areas and facilities (leaving out the production reactors).

As acknowledged by NIOSH, the lack of such documentation may stem from the reported 

destruction of records in 1990. It is also likely due to the inability to retrieve records that were 

transferred for storage at the Federal Records Center without an effective means to search and 

retrieve them. That both of these shortfalls may have led to missing radiation monitoring and 

work records brings into question the completeness of radiation dose records necessary for a 

representative coworker model and NIOSH’s ability to establish the completeness of 

subcontractor job-specific bioassay records for 1972–1990, as stipulated in RPRT-0092. 

Finding 5: The incompleteness of SRS dose records for 1972–1990 is substantiated by 

the acknowledged destruction of subcontractor records and firsthand worker accounts, 

coupled with DOE findings of missing occupational radiation dose data from many SRS 

personnel files, as well as systemic bioassay delinquencies, and wide gaps in NIOSH’s 

capture of permit documentation.

4.6 SRS internal dosimetry policy and procedural changes, 1972–1998

The notable difference between how internal exposures were monitored and controlled at SRS 

between the DuPont era of the 1970s and 1980s and the WSRC era that began in early 1990 

mirrors the overall policy shift in radiation protection at DOE facilities between those 

timeframes. From a policy standpoint, the Savannah River Plant under DuPont implemented 

DOE Order 5480.1, Chapter XI, for which the requirements for radiological monitoring were as 

follows:

(d) Monitoring Requirements. Monitoring is required where the potential exists 

for the individual to receive a dose or dose commitment in any calendar 

quarter in excess of 10 percent of the quarterly standards stated in paragraphs 

4a(1) and 4a(2)(a)2 above. Monitoring requirements as specified for the 

following conditions shall include: 
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1 External Radiation. Personnel monitoring equipment for each individual. 

2 Internal Radiation. Periodic (monthly, quarterly, annually, etc.) bioassay 

analysis or in vivo counting or evaluation of air concentration to which the 

individual is exposed, or a combination of all methods. [(DOE, 1981, PDF 

p. 162)] 

This DOE order stipulated that these and other radiation protection requirements were the sole 

responsibility of the headquarters and field line organizations, who developed their own facility 

requirements and procedures to implement them. DuPont’s procedures satisfied DOE orders by 

(1) stipulating a standard type and frequency for the primary radionuclides encountered in the 

SRS operations, and (2) allowing facility managers and health physicists to require bioassays for 

“other radionuclides,” as necessary.

In contrast, DOE Order 5480.11, which was issued on December 21, 1988 (with required 

implementation a year later), required the following (DOE, 1988):

9.f (1) Combining Internal and External Dose Equivalent. The annual effective 

dose equivalent to an individual shall be determined by summing the annual 

effective dose equivalents from internally deposited radionuclides and from 

external exposure to radioactive material and/or radiation generating devices 

resulting from DOE activities. When in-vivo and/or in-vitro measurements 

confirm the retention of radionuclides in the body, with respect to evaluating 

conformance with the limiting value for occupational exposure, the annual 

effective dose equivalent due to all radionuclides retained in the body from 

these intakes shall be assessed for as long as the annual effective dose 

equivalent is 10 mrem or greater. Exposures to the skin, extremities, and lens of 

the eye are not included in the determination of the annual effective dose 

equivalent. For uniform external Irradiation of the whole body, a weighting factor 

(Wt) equal to one may be used. This whole body dose is to be measured in 

accordance with the provisions in paragraph 99(1). Non-uniform external and 

internal irradiation values of Wt for organs and tissues are defined in paragraph 

8e(12). [Emphasis added.] [(DOE, 1988, p. 13)] 

A programmatic requirement was also included for internal dosimetry in paragraph 9.g(2): 

Internal Radiation. Internal dose evaluation programs (including routine bioassay 

programs) shall be adequate to demonstrate compliance with the radiation 

protection standards in paragraph 9b.[23]

 Such programs are required for radiation 

workers exposed to surface or airborne radioactive contamination where the 

worker could receive 0.1 rem (0.001 sievert) annual effective dose equivalent 

from all intakes of all radionuclides from occupational sources, or if any 

organ or tissue dose equivalent could exceed 5 rem (0.05 sievert) annual dose 

equivalent. [Emphasis added.] [(DOE, 1988, p. 17)] 

 23 These standards provide internal dose limits for stochastic effects of 5 rem (annual effective dose equivalent), 

and for non-stochastic effects, a limit for organ or tissue of 50 rem (annual dose equivalent)] (DOE, 1988).
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These provisions (particularly combining internal and external dose equivalent, and the required 

100-millirem (mrem) threshold for monitoring), coupled with a formal DOE 5480.11 

requirement for implementing and monitoring “as-low-as-reasonably-achievable” (ALARA) 

objectives in the workplace and formal independent review by DOE,24 had a decided effect on 

how bioassay programs would be implemented between the late 1980s and early 1990s. These 

policy changes would be amplified by (1) the first change in operating contractors for the SRS 

site since its inception in 1951 and (2) a Tiger Team assessment, both occurring in early 1990. In 

SC&A’s judgement, it is not plausible to apply the same completeness review, with the same 

evaluation criteria and assumptions, over a 25-year span of SRS operations without accounting 

for these fundamental changes in internal dosimetry policy, procedures, and practice that 

occurred simultaneously in 1989–1990. 

 24 Including a provision to elevate ultimate interpretation of requirements to the Secretary of Energy and approval 

of exemptions to the headquarters Assistant Secretary for Environment, Safety and Health (DOE, 1988). 

Observation 1: The back application of assumptions regarding work permits, job-specific 

bioassays, and target radionuclides to conduct a completeness review for 1972–1998 is 

not plausible given the significant changes in radiological policies, procedures, and 

practices that occurred in the early 1990s.
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5 Analysis of Pre-1990 Subcontractor Data

Section 5 of RPRT-0092 presents the NIOSH evaluation of subcontractor internal monitoring 

data based on the assumed job plan requirements,25 primarily for building 773-A. The evaluation 

was restricted to A Area because this was the only SRS location for which job plans could be 

identified for the site. The RPRT-0092 analysis was separated into three time periods based on 

the observed job plan availability:

• 1972–1974 (see NIOSH (2019a), section 5.1) 

• 1975–1979 (see NIOSH (2019a), section 5.2) 

• 1980–1989 (see NIOSH (2019a), section 5.3) 

25 NIOSH assumed an internal monitoring requirement if the job plan prescribed respiratory protection during the 

job, as discussed in section 4.1 of this report.

Notably, no job plans were identified for 1975–1979; thus, no evaluation of subcontractor 

internal monitoring was feasible for this period. The compiled dataset used in the NIOSH 

analysis can be found in tables D-2 and D-3 of RPRT-0092 for the 1972–1974 and 1980–1989 

periods, respectively. Internal monitoring was evaluated for the assumed exposure potential to 

americium, plutonium, and mixed fission products, although americium exposure potential and 

monitoring practices were only assessed if the job plan was located in the F-Wing of 773-A.

SC&A’s evaluation of the NIOSH dataset focused on two main facets:

1. the total number of workers monitored for each radionuclide of interest in the identified 

job plans (including both in vivo and in vitro monitoring results) 

2. the percentage of monitored workers who would theoretically be included in the 

coworker model formulation and thus can be considered representative of unmonitored 

workers on the same job plan 

While facet 1 simply reflects the workers for whom monitoring should have been required, 

internal monitoring was performed, and the subsequent results are available, facet 2 addresses 

the question of the applicability and representativeness of available subcontractor internal 

monitoring to the unmonitored worker. A key aspect in evaluating the applicability and 

representativeness of the subcontractor monitoring data is whether unmonitored workers worked 

side by side on the same jobs as the monitored workers who are theoretically included in the 

coworker model formulation. 

RPRT-0092 introduced the concept of “effective monitoring,” which it defined as the total 

number of workers who were either monitored directly or who were working side by side with a 

worker who was monitored directly. However, SC&A believes that an unmonitored worker can 

only be considered “effectively monitored” if they worked side by side with a worker whose 

 
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internal monitoring result would hypothetically be included in the development of the SRS 

coworker model in OTIB-0081.

26

26 Several of the coworker models developed in OTIB-0081 do not use the full scope of SRS internal monitoring 

data but rather rely on the subset of claimant data to develop coworker intakes. Thus, not all directly monitored 

workers evaluated in RPRT-0092 are necessarily included in the OTIB-0081 coworker formulation.

As a simplified example, consider a job plan that lists three subcontractors with the same job 

type, period of work, and potential exposure to a contaminant for which a coworker model has 

been developed using urinalysis. In this hypothetical example: 

• Subcontractor 1 was monitored via urinalysis. 

• Subcontractor 2 was monitored via in vivo counting. 

• Subcontractor 3 was unmonitored. 

This example would result in about 66 percent direct internal monitoring coverage 

(subcontractors 1 and 2 were monitored) with 100 percent “effective monitoring” coverage 

because the unmonitored worker (subcontractor 3) is represented by the coworker who submitted 

urinalysis (subcontractor 1). However, consider an alternate situation in which both monitored 

subcontractors had undergone in vivo monitoring. In this alternate situation, subcontractor 3 

would no longer be represented in the coworker model because no in vitro samples were taken 

that reflect the job plan. Thus, the “effective monitoring” coverage would remain at 66 percent

(two subcontractors directly monitored and one subcontractor unmonitored and not represented). 

This example illustrates the importance of the identified method of internal monitoring (in vitro 

or in vivo) in establishing whether the unmonitored worker is truly represented. 

Further complicating the evaluation of subcontractor bioassay is the establishment of an 

acceptable time limit between the end of a given job plan and the subsequent direct monitoring 

result. Section 4.1.3 of RPRT-0092 quotes ORAUT-OTIB-0060, revision 02 (NIOSH, 2018b, 

pp. 24–25), as follows: 

A long-lived, long-retained nuclide (e.g., plutonium and uranium) can be retained 

for decades with continuous excretion of small amounts. One result after many 

years of employment can contain activity from all previous intakes and provide 

information for determining an intake amount for all previous years and, in such a 

situation, a lack of bioassay samples for several years would not be considered 

unmonitored because an upper bound can be placed on the intake. This is not true 

for nuclides that are eliminated relatively rapidly from the body (e.g., 137Cs). . . . 

Long-lived, long-retained nuclides include all absorption types of plutonium, 

uranium, and americium, unless the only monitoring method is chest counting. 

Types F and M are not retained for significant periods in the lungs and the rules 

for short-retained radionuclides must be followed. 

For short-lived or short-retained radionuclides (including 137Cs and 90Sr) during 

potential exposure periods: Missed dose is calculated in the intervals where there 

are bioassay results; other periods are considered to be unmonitored. Gaps of 

 
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greater than 2 years between results are considered to be unmonitored. 

[Emphasis added.] [(NIOSH, 2019a, p. 34)] 

Therefore, SC&A only considered monitoring results for fission products valid if they occurred 

within 2 years of the end of the job plan. Similarly, chest counts for americium and plutonium 

are only considered valid if they occurred within 2 years, per the guidance above. SC&A notes 

that in the original sampling plan, the acceptable time limit was originally restricted to one year 

regardless of the biological half-life of the contaminant: 

A CTW being monitored means the worker was bioassayed per the RWP 

requirement. For a pulled CTW, the ORAU team would use available bioassay 

data including NOCTS to determine if worker was bioassayed within one year 

from date of RWP sign-in, either by urinalysis or in vivo analysis for all 

radionuclides listed on the RWP other than tritium (H3). [Emphasis added.] 

[(NIOSH, 2018a, p. 2)] 

Finally, when establishing an appropriate representative coworker, the majority of matches 

indicated by NIOSH included workers on the same job plan, with the same craft designation and 

the same date/time. This characterization of a coworker is reflected in the example provided in 

NIOSH (2018c):

 RWP#4 had an unmonitored subcontractor CTW, on a work crew of five CTWs, 

in which 3 DuPont CTWs were monitored. This results in either an unmonitored 

subcontractor CTW with no surrogate, or 60% monitoring of the work crew if 

considered as a whole and depends on the point of view. . . . 

if the whole crew were pipefitters and the subcontractor was simply brought in as 

an additional worker then the criteria noted in [NIOSH] (2015) would be 

appropriate and 60% would be considered a success. If the DuPont CTWs were 

Electricians that did electrical work in the morning and the subcontractor 

CTW was a pipefitter who worked in the afternoon doing a separate task 

then the DuPont CTWs would not be an appropriate co-worker. [Emphasis 

added.] [(NIOSH, 2018c, p. 17)] 

In a few cases, NIOSH appears to identify workers as “appropriate coworkers” when they were

on the same job plan but may not have had the same craft designation or worked on the same 

date/time. SC&A did not remove these matches from its own analysis; however, they are noted 

(where applicable) in the evaluation subsections below. Where feasible in these circumstances, 

SC&A attempted to identify a more appropriate coworker designation (i.e., another coworker on 

the same job plan with the same craft/date/time) and made the correction prior to reporting the 

totals below. However, SC&A did remove coworker matches from its calculated totals in a few 

rare cases where the NIOSH coworker match was based on workers who were on completely 

different job plans. As discussed above, suitable coworkers were only recognized by SC&A in 

the “effective monitoring” totals if they were monitored via the same method used in coworker 

model development (i.e., urinalysis for americium/plutonium and in vivo counting for fission 

products). 
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5.1 1972–1974

5.1.1 Americium (1972–1974)

Only a single worker was identified in RPRT-0092 as requiring americium monitoring as a result 

of their job plan specifications, and the worker was not monitored either by in vitro or in vivo 

methods. The job plan description involved the installation of an air sampling line in the F 

section valve pit. Although RPRT-0092 concludes that americium exposure potential only 

occurred in the F-Wing area of 773-A, table D-1 of attachment D indicates americium 

monitoring was required for a second job plan occurring in the high-level caves (Job Plan 47). 

The job plan indicates the work was to pick up regulated tools and transfer them to radiation 

control for surveying. The work required two sets of coveralls, shoe covers, gloves, and a hood. 

Observation 2: During the 1972–1974 period, RPRT-0092 only evaluates one job 

plan/worker combination (Job Plan 46) for potential americium exposure. However, 

attachment D, table D-1 indicates at least one other job plan (Job Plan 47) requiring 

americium monitoring during this period. Neither of the workers were directly monitored 

nor had an appropriate coworker monitored for americium.

5.1.2 Plutonium (1972–1974)

Table 2 shows the results of SC&A’s independent assessment of the available monitoring data 

provided by NIOSH for plutonium (1972–1974). When evaluating the available job plans, 

SC&A found that about 63 percent of the job plans had at least one worker with valid internal 

monitoring identified. SC&A’s evaluation of the total number of monitored workers 

(independent of job plan) was slightly less than NIOSH’s evaluation (50 percent versus 

51 percent) due the removal of a chest count occurring more than 2 years after the end of the job 

plan. When evaluating appropriate coworkers, SC&A removed five matches from the original 

NIOSH analysis due to the coworker matches occurring on different job plans. This results in an 

effectively monitored total of 64.7 percent rather than the 69 percent reported in RPRT-0092. 

SC&A notes that, in one case, the coworker match was on a different date but the same job plan 

and craft. One additional coworker match was from a different craft but the same job plan and 

date/time. Finally, three coworker matches were from a different time of day (e.g., one worker 

entered the area in the morning and the other entered in the afternoon) but were on the same job 

plan and date and were designated as the same craft. Removal of these entries from consideration 

would further reduce SC&A’s estimate of the total effectively monitored workers to 

approximately 61 percent. 
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Table 2. Summary of SC&A evaluation of plutonium monitoring data (1972–1974)

Category SC&A 

total (%)

RPRT-0092 

total (%)* SC&A comment

Total job plans for 

review 59 NR —

Job plans with internal 

monitoring 36 (61.0%) NR

—

Total workers for 

review 136 136 —

Total workers 

monitored internally 68 (50%) 69 (51%)

SC&A removed one chest count result that was 

more than 2 years from the end of the job plan 

(2,779 days).

Coworker match by 

urinalysis 20 (14.7%) 25

SC&A rejected 5 coworker matches because 

they were on different job plans. SC&A’s total 

does include 1 coworker match on a different 

date, 1 coworker match from a different craft, 

and 3 coworker matches from a different time of 

day. Removal of these entries would decrease 

the total to 15 (11.0%).

Total effectively

monitored workers 88 (64.7%) 69% Removal of the coworker matches described above reduces this total to 83 (61.0%).

*NR = Not reported

5.1.3 Fission products (1972–1974)

Table 3 shows the results of SC&A’s independent assessment of the available monitoring data 

provided by NIOSH for fission products (1972–1974). When evaluating the available job plans, 

SC&A found that nearly 90 percent had at least one worker with valid internal monitoring 

identified. As seen in the table, SC&A’s evaluation of the directly monitored workers was 

slightly less than NIOSH’s evaluation (~70 percent versus 74 percent). The difference is partially 

due to four entries containing urinalysis results that were more than 2 years after the end of the 

job plan. The monitoring records could not be located by SC&A for the two remaining case 

discrepancies (CTW-700 and CTW-838) in the documentation provided by NIOSH. 

When evaluating appropriate coworkers, SC&A’s total was very close to that reported by 

NIOSH (26 for SC&A, 27 for NIOSH). However, the coworker matches were based on 

monitored workers with in vitro samples, while the SRS coworker model in OTIB-0081 is based 

on in vivo monitoring. Therefore, monitoring results associated with urinalysis are not 

representative of the unmonitored worker and should not be included in the effectively 

monitored total. As there were no appropriate chest counts identified for the workers during this 

period, the effectively monitored total is simply the number who were directly monitored (i.e., 

around 70 percent).
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Table 3. Summary of SC&A evaluation of fission product monitoring data (1972–1974)

Category SC&A 

total (%)

RPRT-0092 

total (%)* SC&A comment

Total job plans for 

review 59 NR —

Job plans with 

urinalysis sampling 53 (89.8%) NR —

Job plans with chest 

count sampling 0 (0.0%) NR —

Job plans with internal 

monitoring 53 (89.8%) NR —

Total workers for 

review 136 136 —

Workers with 

urinalysis 95 (69.9%) NR —

Workers with chest 

counts 0 (0.0%) NR —

Total workers 

monitored 95 (69.9%) 101 (74%)

SC&A rejected four entries because the 

urinalysis value was more than 2 years after 

the job plan. The records for two additional 

entries could not be found by SC&A in the 

supporting files provided by NIOSH.

Coworker match by 

urinalysis 26 (19.1%) 27

OTIB-0081 coworker intakes are based on in 

vivo monitoring, not in vitro, so these 

coworker matches are not appropriate for 

inclusion in the effectively monitored total.

Total effectively 

monitored workers 95 (69.9%) 94% SC&A total includes only those workers directly monitored via urinalysis. 

*NR = Not reported

5.2 1980–1989

5.2.1 Americium (1980–1989)

Table 4 shows the results of SC&A’s independent assessment of the available monitoring data 

provided by NIOSH for americium (1980–1989). RPRT-0092 identified 145 total job plans 

during the time period of interest; however, only 35 of those job plans (about 24 percent) were 

identified as having workers required to be internally monitored for americium. Furthermore, no 

job plans were available for 1980 or 1988–1989. The identified job plans for americium 

evaluation cover 151 total worker/job plan combinations. Approximately 63 percent of the job 

plans had at least one worker with associated internal monitoring (37.5 percent via urinalysis 

sampling and 25.7 percent via in vivo monitoring). 
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Table 4. Summary of SC&A evaluation of americium monitoring data (1980–1989)

Category SC&A 

total (%)

RPRT-0092 

total (%)* SC&A comment 

Total job plans for 

review 35 NR This constitutes just 24% of the total job plans reviewed for 1980–1989.

Job plans with 

urinalysis sampling 13 (37.5%) NR —

Job plans with chest 

count sampling 9 (25.7%) NR

Five job plans were discounted due to the 

chest count occurring more than 2 years after 

the job plan.

Job plans with internal 

monitoring 22 (62.9%) NR —

Total workers for 

review 151 151 —

Workers with 

urinalysis 17 (11.3%) NR

Represents the number of workers with 

urinalysis values used in coworker model 

development. The 17 urine samples identified 

were taken from only 3 workers. Eleven of 17 

were taken from a single worker who was 

sampled in April 1991 (note: 1991 data are not 

currently used in the SRS coworker model).

Workers with chest 

counts 13 (8.6%) NR

Twenty-two chest count results were 

discounted due to the chest count occurring 

more than 2 years after the job plan.

Total workers 

monitored 30 (19.9%) 52 (34%) —

Coworker match by 

urinalysis 20 (13.2%) NR

One of 20 matches involved a different craft 

and date. Removal of this sample would 

decrease the total to 19 (12.6%). Ten of the 20 

matches were to a urinalysis result in 1991 that

is not currently used in the coworker model.

Coworker match by 

chest count 35 (23.2%) NR

Sixteen of 35 matches involved different craft 

designations. One of 35 matches involved a 

different date. Removal of these would 

decrease the total to 18 (11.9%). However, 

chest counts are not used in coworker 

development; thus, these matches are not 

relevant to establishing the effectively 

monitored worker totals. 

Total coworker 

matches 55 (36.4%) 63 (NR)

The difference between SC&A’s total (55) and 

NIOSH’s total (63) is the removal of coworkers 

who were tied to chest counts more than 2 

years. Where possible, SC&A matched these 

entries to appropriate workers with urinalysis. 

Additional removal of coworker entries 

described in two preceding rows would 

decrease the SC&A total to 37 (24.5%).
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Category SC&A 

total (%)

RPRT-0092 

total (%)* SC&A comment 

Total effectively 

monitored workers 50 (33.1%) NR (76%)

Represents the total monitored workers plus 

those represented by coworker urinalysis 

values. Removal of the coworker match 

involving a different craft and date would 

decrease the total to 49 (32.5%). Removal of 

10 coworker matches to the 1991 result that is 

not currently used in coworker modeling would 

reduce this total to 40 (26.5%). 

*NR = Not reported

Although nearly two-thirds of the job plans had at least one worker with internal monitoring for 

americium, this reflects just 20 percent of the total identified americium workers. As noted in 

table 4, a large portion of the workers monitored via chest count were removed due to the chest 

count occurring more than 2 years after the end of the job plan. This is in accordance with 

ORAUT-OTIB-0060, revision 02 (NIOSH, 2018b), and restated in RPRT-0092, which notes that 

long-lived nuclides monitored via chest count must be treated as a short-lived nuclide for which 

periods longer than 2 years are considered unmonitored (see section 5 of this report for the 

pertinent excerpt from RPRT-0092 quoting ORAUT-OTIB-0060). Figure 3 plots the time 

elapsed between the identified internal monitoring results and the end of the job plan. 

Figure 3. Number of years elapsed between end of job plan and internal monitoring result
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Although long-lived urinalysis results for americium are considered valid for the purposes of 

internal monitoring, it is clear that the majority of urinalysis results were not associated with the 

actual job plan, as they were taken more than 4 years after the end of the work. Furthermore, the 

17 identified urinalysis results shown in table 4 were taken from just three workers. Eleven of the 

17 results were taken from in 1991 

and was sampled subsequent to (i.e., neither the sample nor the reason for the 

sample occurred in the period of interest). The remaining two workers were involved in separate 

incidents .

Finding 6: For the period 1980–1989, only 20 percent of the identified subcontractor-job 

plan combinations identified by NIOSH as requiring americium sampling had internal 

monitoring performed within an acceptable timeframe (i.e., within 2 years for chest 

counting). 

Observation 3: Only 13 percent of the subcontractor-job plan combinations (17 total) had 

americium urinalysis performed that could be considered relevant to coworker modeling. 

Eleven of the 17 urinalysis data points represented a single worker who had a single 

sample taken in 1991 in a different area ( ) 

during that year (i.e., representative of a different area and different period).

Per table 4, most of the coworker matches identified by SC&A were associated with chest 

counts, which are not considered in coworker modeling and thus cannot be considered 

representative of the unmonitored worker. In addition, in several cases the coworker chest count 

match was for workers with different craft designations27 (e.g., carpenter matched with a sheet 

metal worker). SC&A was able to match 13 percent of the unmonitored workers (20 in total) to a 

coworker on the same job plan with a relevant urinalysis result. 

27 SC&A considered craft designations to be “different” if they were delineated with a separate entry in table 5-9, 

“SubCTW Americium Bioassay by Craft, 1980 to 1988” (NIOSH, 2019a).

Therefore, the total “effectively monitored” population for americium is just 33.1 percent 

(20 percent directly monitored and 13 percent represented by a suitable coworker). As noted in 

observation 3, the majority of urinalysis results were for a single worker 

sampled in 1991, which is outside the current coworker model period (i.e., the 

sample was not used in the current coworker model in OTIB-0081. If the coworkers matched to 

this individual are removed, then the effectively monitored population is reduced to 26.5 percent. 

Finding 7: The total “effectively monitored” population for americium (those monitored 

directly or have a coworker on the same job plan with a urinalysis result) during the 

1980–1989 period is approximately 33 percent. If a urinalysis sample taken during 1991 

 in a different SRS location (and is not currently used in the SRS 

coworker model) is removed, the effective monitored population drops to 26.5 percent. 

5.2.2 Plutonium (1980–1989)

Table 5 shows the results of SC&A’s independent assessment of the available monitoring data 

provided by NIOSH for plutonium (1980–1989). When evaluating the available job plans, 

SC&A found that nearly 98 percent had at least one worker with valid internal monitoring 

identified. As seen in the table, SC&A’s evaluation of the total monitored workers was slightly 

 
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less than NIOSH’s evaluation (79.4 percent versus 80 percent) due to three chest count results 

occurring more than 2 years after the end of the job plan. However, when evaluating coworker 

matches, SC&A identified four additional matches that had not been included in the original 

NIOSH analysis. The net result is that SC&A’s and NIOSH’s estimate of the effectively 

monitored population is essentially identical (around 97 percent).

Table 5. Summary of SC&A evaluation of plutonium monitoring data (1980–1989)

Category SC&A 

total (%)

RPRT-0092 

total (%) SC&A comment 

Total job plans for 

review 145 NR —

Job plans with 

urinalysis sampling 141 (97.2%) NR —

Job plans with chest 

count sampling 1 (0.7%) NR —

Job plans with internal 

monitoring 142 (97.9%) NR —

Total workers for 

review 591 591 —

Workers with 

urinalysis 442 (74.8%) NR —

Workers with chest 

counts 27 (4.6%) NR —

Total workers 

monitored 469 (79.4%) 472 (80%)

SC&A rejected 3 entries due to the chest 

counts being more than 2 years from the job 

plan date.

Coworker match by 

urinalysis 104 (17.6%) NR —

Coworker match by 

chest count 2 (0.3%) NR —

Total coworker 

matches 106 (17.9%) 102 SC&A identified four additional coworker matches. 

Total effectively 

monitored workers 573 (97.0%) 97% —

*NR = Not reported

5.2.3 Fission products (1980–1989)

Table 6 shows the results of SC&A’s independent assessment of the available monitoring data 

provided by NIOSH for fission products (1980–1989). When evaluating the available job plans, 

SC&A found that over 99 percent had at least one worker with valid internal monitoring 

identified. As seen in the table, SC&A’s evaluation of the total monitored workers was slightly 

less than NIOSH’s evaluation (about 73 percent versus 78 percent). The difference is mainly due 

to 23 entries containing internal monitoring results that were more than 2 years after the end of 

the job plan. The remaining discrepancies are due to 11 entries for which SC&A could not locate 

the source dosimetry file or the specific entry indicated in the NIOSH documentation was not 

found within the provided dosimetry file. 

When evaluating appropriate coworkers, SC&A identified 18 additional matches compared to 

the total reported by NIOSH (138 for SC&A, 120 for NIOSH). However, it should be noted that 

only a small portion of the coworker matches (8 of 138) were represented by in vivo monitoring, 
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which is used in the formulation of the SRS fission product coworker model (NIOSH, 2019c). 

Therefore, SC&A’s assessment of the total “effectively monitored” population is significantly 

lower (around 74 percent) when compared to the value reported in RPRT-0092 (99 percent). 

Table 6. Summary of SC&A evaluation of fission product monitoring data (1980–1989)

Category SC&A 

total (%)

RPRT-0092 

total (%) SC&A comment

Total job plans for 

review 145 NR —

Job plans with 

urinalysis sampling 126 (86.9%) NR —

Job plans with chest 

count sampling 18 (12.4%) NR —

Job plans with internal 

monitoring 144 (99.3%) NR —

Total workers for 

review 591 591 —

Workers with 

urinalysis 406 (68.7%) NR —

Workers with chest 

counts 23 (3.9%) NR —

Total workers 

monitored 429 (72.6%) 463 (78%)

SC&A rejected 23 entries because the 

monitoring occurred more than 2 years after 

the job plan. SC&A could not verify an 

additional 11 entries because either the 

dosimetry file was not available, or the 

specified result could not be located in the 

provided dosimetry file.

Coworker match by 

urinalysis 130 (22.0%) NR —

Coworker match by 

chest count 8 (1.4%) NR OTIB-0081 coworker intakes are based on in vivo sampling.

Total coworker 

matches 138 (23.4%) 120 —

Total effectively 

monitored workers 437 (73.9%) 99% —

*NR = Not reported

5.3 Summary conclusions for pre-1990 time period

As described in section 5 and presented in sections 5.1 and 5.2, SC&A reevaluated the available 

data provided by NIOSH to correct for three identified issues: 

• Remove identified internal monitoring that is outside the acceptable timeframe between 

the end of the job plan and the internal monitoring result. 

• Remove coworker matches that involved two workers who were associated with different 

job plans. 

• Adjust the “effectively monitored” population to reflect only coworker matches with the 

type of internal monitoring used in coworker model development (i.e., in vivo for fission 

products and in vitro for americium/plutonium). 
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Table 7 summarizes the results of SC&A’s reevaluation of the subcontractor data in comparison 

to the RPRT-0092 reported values. As seen in the summary table, SC&A’s evaluation of the 

plutonium data showed reasonably good agreement with the RPRT-0092 values. Similarly, the 

total number of monitored workers for fission products was similar to RPRT-0092, although it 

was slightly lower in SC&A’s analysis due largely to the exclusion of bioassay samples taken 

more than 2 years after the end of the evaluated job plan. The differences in the “effectively 

monitored” population for fission products was largely due to the exclusion of coworker matches 

based on urinalysis results that are not used in the formulation of the SRS coworker model in 

OTIB-0081. 

Table 7. Summary of SC&A evaluation of pre-1990 subcontractor data for total monitored 

versus RPRT-0092 values 

Radionuclide 

(time period) 

Years 

with 

available 

data

SC&A 

monitored 

RPRT-0092 

monitored 

Ratio 

(SC&A

/RPRT

-0092)

SC&A 

effectively 

monitored 

RPRT-0092 

effectively 

monitored 

Ratio 

(SC&A

/RPRT

-0092)

Americium 

(1972–1974) 1973 0% 0% N/A 0% 0% N/A

Plutonium 

(1972–1974) All 50% 51% 0.986 64.7% 69% 0.936

Fission 

products 

(1972–1974)

All 69.9% 74% 0.941 69.9% 94% 0.742

All 

radionuclides 

(1975–1979)

None N/A N/A N/A N/A N/A N/A

Americium 

(1980–1989)

1981–

1987 19.9% 34% 0.577 33.1% 76% 0.435

Plutonium 

(1980–1989) All 79.4% 80% 0.994 97.0% 97% 0.998

Fission 

products 

(1980–1989)

All 72.6% 78% 0.927 73.9% 99% 0.750

N/A = Not applicable

Finding 8: Many of the workers (around 70–73 percent) who should have been monitored 

for fission products underwent appropriate internal sampling during the two periods 

evaluated prior to 1990 (1972–1974 and 1980–1989). However, very few of these 

monitored workers underwent in vivo counting for fission products. Thus, they are not 

included in the coworker model developed for SRS and are not considered 

representative of the unmonitored worker.

The largest observed differences between SC&A’s analysis and the values reported in RPRT0092 were for americium during the 1980–1989 time period. SC&A’s estimations of the 

monitored and effectively monitored population were approximately half those presented in 

RPRT-0092. The reported differences are largely due to the exclusion of chest count results that 

are more than 2 years from the end of the job plan, as well as only including coworker matches 

that involve a worker monitored via urinalysis. 
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It should be reiterated that evaluation of americium monitoring practices for subCTWs is 

severely limited for the pre-1990 time period. The only years in which job plans were identified 

for analysis were 1973 (two workers who were unmonitored) and 1981–1987. Nonetheless, 

SC&A’s analysis of this limited sample indicates that fewer than 20 percent of the workers who 

should have been monitored for americium exposure actually underwent appropriate internal 

monitoring. If we include the unmonitored workers who are represented by a monitored 

coworker via urinalysis on the same job plan (the “effectively monitored” population), the total 

percentage rises to just over 33 percent.28 

28 This percentage includes the 11 urinalysis values that were taken in 1991 [Redacted] during that year in a 

different SRS location.

Finding 9: SC&A does not find that the data collected as part of the RPRT-0092 review 

support the premise that subcontractors on job plans that should have required internal 

monitoring for americium were either directly monitored (around 20 percent) or, 

alternately, appropriately represented in the derived coworker models for SRS (around 

13 percent). 

Finally, section 6.3 of RPRT-0092 provides summary table 6-4, “Rates of Monitoring of 

subCTW for at Least One Radionuclide, 1981 to 1998” (NIOSH, 2019a, p. 59). The table 

contains both direct monitoring and effective monitoring rates “for at least one” radionuclide 

assumed with the evaluated job plans. SC&A believes such a metric can be misleading. For 

example, a worker who should have been monitored for plutonium, fission products, and 

americium on a given job but was only monitored for fission products would be considered a 

“success” and counted toward the monitored totals in this summary table even though they were 

not monitored for two other key radionuclides (plutonium and americium). SC&A believes a 

much more informative metric would look at the rates of monitoring of subCTW for all

radionuclides contained in the respective job plan. Table 8 provides a comparison of this latter 

metric to the table 6-4 data in RPRT-0092. Not surprisingly, when considering all radionuclides 

that should have been monitored (as opposed to “at least one”), the percentages drop 

considerably. For 1972–1974, the percentage of directly monitored workers reported drops from 

76 percent to 47.1 percent, and the effectively monitored workers drops from 85 percent to 

55.1 percent. For 1980–1989, the percentage of directly monitored workers reported drops from 

90 percent to 51.3 percent, and the effectively monitored percentage drops from 99 percent to 

65.5 percent. 

Table 8. Comparison of monitoring percentages involving at least one radionuclide (RPRT-0092 

value) versus all radionuclides on work permit (SC&A value)

Time period 

RPRT-0092 directly 

monitored for at 

least one 

radionuclide 

SC&A directly 

monitored for all 

radionuclides on 

work permit

RPRT-0092 

effectively 

monitored for at 

least one 

radionuclide

SC&A effectively 

monitored for all 

radionuclides on 

work permit

1972–1974 76% 47.1% 85% 55.1%

1975–1979 No data No data No data No data

1980–1989 90% 51.3% 99% 65.5%

 
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6 Evaluation of RPRT-0092 1990–1998 Data

6.1 RPRT-0092 RWP data per SRS area (1990–1998)

In view of the lack of representativeness of the various areas at SRS in RPRT-0092 concerning 

the 1972–1989 job plan and SWP data (which were limited to Area A) and temporal gaps in 

those data (i.e., no evaluation was possible for 1975–1979 or 1989), SC&A analyzed the area 

and temporal representativeness of the 1972–1989 bioassay data used in coworker modeling in 

OTIB-0081 and the 1990–1998 RWs data NIOSH sampled in RPRT-0092. A summary of the 

results using the 1972–1998 data in OTIB-0081 is provided in appendix 1 of this report. For the 

1990–1998 data used in RPRT-0092, SC&A analyzed the data NIOSH used to derive table 4-4 

using the file “Table C-3 Final.xlsx” in the folder G, labelled “Report Tables,” provided by 

NIOSH, which does not have a corresponding table in attachment C of RPRT-0092. The results 

are summarized in figure 4. 

Figure 4. Number of RWPs per SRS area per year (1990–1998)

Figure 4 indicates that, of the 146 RWPs analyzed, the main concentration of the RWPs was 

during the period 1992–1994, with Areas F and H containing the largest fraction of the total 

number of RWPs. 

There was only one RWP with one unmonitored subCTW listed for 1990. This does not appear 

to warrant bundling 1990 with 1991 and treating it as part of the period when additional data 

became available. The year 1990, with one RWP, is not much better than 1989 (no job plans 

identified) or any other previous year. Although there were corporate changes taking place at that 

time, there was a lag time in policy implementation; therefore, it would be more appropriate that 

the time intervals should be broken up into 1972–1990 and 1991–1998, so that 1990 is 

considered in the era with very limited data.
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Finding 10: Data for 1990 are lacking. Therefore, 1990 should be included with the period 

of limited data, 1972–1989, and not bundled in with the year 1991.

6.2 Procedural check of RPRT-0092’s analyses of bioassay data (1990–1998)

SC&A reviewed the data in attachment C of RPRT-0092 to determine if the procedures, as 

prescribed in sections 2, 3, and 4 of RPRT-0092, for analyzing bioassay data for the period 

1990–1998 were followed. This current review does not indicate SC&A’s concurrence with the 

assumptions and methods used by NIOSH, but only a check to see if the stated procedures were 

followed. 

6.2.1 Spot check of RPRT-0092 data analyses

SC&A performed a limited review of the data in files provided by NIOSH to spot check the 

processes that were used in RPRT-0092 for the period 1990–1998. The steps SC&A used in the 

analysis are provided in appendix 2 of this report. SC&A used the information obtained from 

their analysis to manually spot check some of the individual subCTW’s bioassay records to 

verify if the information in tables C-3 through C-7 were correct. SC&A checked 13 RWPs, 

which contained a total of 74 bioassay data points involving five radionuclides (plutonium, 

strontium, uranium, americium, and neptunium) for 22 different subCTWs. From the limited 

analysis SC&A performed, SC&A found: 

• Four examples of incorrect dates in tables C-3 through C-7 of RPRT-0092. Some date 

errors amounted to a few days, other to a year or more. 

• Two errors on page 139 of RPRT-0092: 

o The referenced coworker for CTW- on sample identification (SID)- , dated 

 1995, is listed as CTW- (i.e., it referred to a coworker that is the 

CTW itself).

o The referenced coworker for CTW- on SID- , dated 1995, is 

listed as CTW- , who is not signed in on SID- , and CTW- is listed as 

needing a coworker because it was not monitored on SID- . 

• Page 103 of RPRT-0092 lists CTW- as a coworker for unmonitored CTW- on 

SID . However, the file, “Master list of Employees to CTW number for Report 

Final.xlsx” (obtained from NIOSH’s folder G, “Report Tables”), on line 182 of the 

spreadsheet, lists CTW- as “UNASSIGNED #.”

From this relatively small sampling of the data, SC&A did not locate major errors in the data 

analyses in RPRT-0092 but did locate some data errors, or inconsistences, that could have some 

effect on the reported total percentage of subCTWs monitored. 

6.2.2 Overall adherence to sampling plan

In an evaluation of implementation of procedures, SC&A found that there appears to be an 

inconsistency in the sampling plan defined in section 2.1 and in the process used to generate the 

summary tables in sections 4 and 6 of RPRT-0092. Section 2.1 states: 
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SubCTW being monitored. Worker was monitored by bioassay, which could 

include routine sampling, according to the RWP requirements. For a pulled 

subCTW, the ORAU Team used available bioassay data, including DOE data 

already in the NIOSH-Division of Compensation Analysis and Support Claims 

Tracking System (NOCTS), to determine if a worker was monitored within a 

frequency specific to the sampled radionuclide from date of RWP sign-in, 

either by urinalysis or in-vivo analysis, for all radionuclides listed on the RWP

other than tritium (3H). [Emphases added.] [(NIOSH, 2019a, p. 12)] 

However, when NIOSH analyzed the data, apparently a recorded bioassay for any one required 

radionuclide at any time was counted as fulfilling the RWP requirements and included in 

tables 4-1, 4-3, 4-4, and 6-4, regardless of the number and types of radionuclides and bioassays 

required by the RWP or the delay time between the RWP date and the bioassay. RPRT-0092 

states:

The team calculated percentages of subCTWs monitored by year having at least 

one required bioassay, even though a subCTW could have more than one; results 

are provided in Table 4-1. For example, a subCTW bioassay required for 

plutonium and strontium would be counted in this tabulation if the subCTW had 

been sampled for either. [Emphases added.] [(NIOSH, 2019a, p. 35)] 

The captions for tables 4-1 and 4-3 use the term “with at least one bioassay for any 

radionuclide,” and tables 4-4 and 6-4 use the term “with at least one bioassay.” These statements 

are contrary to the statement quoted above from section 2.1 of RPRT-0092, which requires that 

all radionuclides listed on the RWP must be sampled and within a specified frequency (i.e., time 

interval between RWP sign in and bioassay). Therefore, some of the percentages of the 

subCTWs monitored in the tables in sections 4 and 6 of RPRT-0092 are misleading. For 

example, table 4-6 for plutonium in RPRT-0092 indicates a 1990–1998 average directly 

monitored subCTW rate of 88 percent and an effective subCTW monitoring rate of 95 percent. 

However, this does not address the fact that, in addition to the required plutonium bioassay, there 

could have been other required bioassays that were not performed, which would result in the 

subCTW not being adequately monitored. 

When SC&A recreated and compared data from table 4-1 (“SubCTWs with at least one bioassay 

for any radionuclide, 1990 to 1998”) from RPRT-0092 to that obtained when considering all 

required radionuclides on an RWP (with a 2-year time limit on chest counts), it was found that 

the results adjust downward to lower percentages. For the period 1990–1998 in table 4-1 and 

table 6-4, the percentage with at least one bioassay directly monitored as required on the RWP is 

cited as 96 percent, while SC&A’s recalculated percentage with bioassay for all required 

radionuclides directly monitored as specified on the RWP is 77 percent. The values from 

table 4-1 and table 6-4 of percentage effectively monitored for at least one bioassay on the job 

plan is 98 percent, while SC&A’s recalculated percentage effectively monitored for all required 

radionuclides specified on the RWP is 89 percent. The results of SC&A’s analysis for direct 

monitoring are summarized in tables 9 and 10, and for effective monitoring in tables 11 and 12, 

which included bioassays for plutonium, fission products, uranium, americium, and neptunium, 

as required by the RWP, for 1990–1998. 
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Table 9. Summary of using all required radionuclides compared to using only at least one 

required radionuclide for subCTWs directly monitored

Category 

SC&A 

total 

or %

RPRT-0092 

table 4-1 and 

table 6-4 

total or %

SC&A comment 

Total subCTWs 

requiring bioassays 660 662

SC&A eliminated two 1994 entries because RPT0092, page 94 states Pu only, while page 112 

states Pu not applicable.

SubCTWs with direct 

bioassays 505 633

SC&A required that all required radionuclides be 

monitored for the bioassay to be complete (with 

chest counts limited to 2 years). RPRT-0092 only 

required at least one required radionuclide to be 

monitored at any time for the bioassay to be 

complete.

SubCTWs without 

complete bioassays 155 29

SC&A removed 155 entries that were not 

monitored for all required radionuclides or the 

chest count was more than 2 years (of which there 

were 19). RPRT-0092 remove 29 entries that had 

no bioassays.

SubCTWs directly 

monitored 77% 96% 19% decrease in the number of subCTWs directly monitored.

Table 10. Breakdown by year of using all required radionuclides compared to using only at least 

one required radionuclide for subCTWs directly monitored

Year

SC&A percent 

directly 

monitored 

SC&A total 

subCTWs 

requiring 

bioassays

RPRT-0092

table 4-1 

percent 

directly 

monitored

RPRT-0092 

table 4-1 total 

subCTWs 

requiring 

bioassays

1990 0% 1 NA NA

1991 72% 81 99% 82

1992 91% 106 97% 106

1993 70% 173 97% 173

1994 73% 138 94% 140

1995 68% 57 95% 57

1996 75% 24 83% 24

1997 95% 55 98% 55

1998 80% 25 92% 25
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Table 11. Summary of using all required radionuclides compared to using only at least one 

required radionuclide for subCTWs effectively monitored

Category 

SC&A 

total 

or %

RPRT-0092 

table 4-1 and 

table 6-4 

total or %

SC&A comment 

Total subCTWs 

requiring bioassays 660 662

SC&A eliminated two 1994 entries because RPT0092, page 94 states Pu only, while page 112 

states Pu not applicable.

SubCTWs with direct 

bioassays 505 633

SC&A required that all required radionuclides be 

monitored for the bioassay to be complete (with 

chest counts limited to 2 years). RPRT-0092 only 

required at least one required radionuclide to be 

monitored at any time for the bioassay to be 

complete.

SubCTWs without 

complete bioassays

155 29

SC&A removed 155 entries that were not 

monitored for all required radionuclides or the 

chest count was more than 2 years (of which there 

were 19). RPRT-0092 remove 29 entries that had 

no bioassays.

Monitored coworker

matched to 

unmonitored 

subCTW

81 19

SC&A matched coworkers as listed in the tables in 

attachment C of RPRT-0092, except SC&A did not 

use coworkers with chest counts more than 2 

years.

Percent of 

subCTWs 

effectively 

monitored

89% 98% 9% decrease in the number of subCTWs 

effectively monitored.

Table 12. Breakdown by year of using all required radionuclides compared to using only at least 

one required radionuclide for subCTWs effectively monitored

Year

SC&A percent 

effectively 

monitored 

SC&A total 

subCTWs 

requiring 

bioassays

RPRT-0092 

table 4-1 

percent 

effectively 

monitored

RPRT-0092 

table 4-1 total 

subCTWs 

requiring 

bioassays

1990 0% 1 NA NA

1991 88% 81 100% 82

1992 96% 106 100% 106

1993 83% 173 99% 173

1994 90% 138 96% 140

1995 83% 57 100% 57

1996 83% 24 83% 24

1997 98% 55 100% 55

1998 96% 25 100% 25

SubCTWs 

effectively 

monitored

89% 660 98% 662

The percentage values listed in the tables in sections 4 and 6 of RPRT-0092 are sometimes 

misleading because they do not incorporate the need for the subCTW, or the coworker, to be 

monitored for all required radionuclides, with the chest count limited to 2 years. As shown in 
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SC&A’s analysis, this results in a noticeable difference in both the directly monitored and 

effectively monitored subCTW percentages. For example, for 1993, table 4-1 lists a value of 

97 percent for directly monitored subCTWs by any one required bioassay, and table 4-6 lists 

89 percent for required plutonium; however, if all required radionuclides are included, and the 

chest counts limited to 2 years, the value drops to 70 percent, as shown in table 10. This issue, 

which applies to both periods 1972–1989 and 1990–1998, is summarized in finding 11 in the 

“Conclusions” section of this report. 

6.3 Analysis of coworker data needed to supplement CTW data

SC&A used the data from the tables in attachment C of RPRT-0092 to analyze the use of 

monitored coworker (CW) data for unmonitored subCTWs who were listed on an RWP along 

with a monitored worker. The percent of coworker data needed is an indication of the 

completeness or incompleteness of the subCTW bioassay data during the period 1990–1998. 

Table 13 summarizes the results. 

Table 13. Summary of use of coworkers for subCTWs

Radionuclide Attachment C

table

Total 

number of 

subCTWs

Total 

number of 

CWs used

Percent of 

time CW 

data used

Plutonium C-3 644 47 7.3%

Strontium C-4 429 12 2.8%

Uranium C-5 225 17 7.6%

Americium C-6 180 25 13.9%

Neptunium C-7 91 13 14.3%

Total or weighted average NA 1569 114 7.3%

These results indicate that in RPRT-0092, on average, subCTW bioassay data were 

supplemented with coworker bioassay data approximately 7 percent of the time for the period 

1990–1998. 

SC&A further analyzed the plutonium data in table C-3 of RPRT-0092 for the 47 subCTWs that 

had coworkers listed to determine if there were indications that the coworker exposure could 

reasonably represent the exposure to the unmonitored subCTW. To perform this task, SC&A 

determined if the monitored coworker and unmonitored subCTW (1) were both signed in on the 

same RWP number, (2) were both signed in on the same date, and if so, (3) both worked during 

the same time interval, and (4) both had the same job or craft title. Additionally, the results were 

then analyzed to determine if the coworker met all four of these criteria, which would be needed 

to represent a condition where a monitored coworker and an unmonitored subCTW were 

working side by side performing similar tasks at the same time, resulting in similar intakes. 

Table 14 summarizes the results.
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Table 14. Summary of use of monitored coworkers for unmonitored subCTWs for plutonium

Criterion Percent of workers that meet criterion

CW listed on same RWP 96%

CW signed in on same RWP and date 77%

CW signed in on same RWP, date, and time 66%

CW signed in on same RWP, date, time, and craft 45%

These results indicate:

• The unmonitored subCTW and the coworker were both generally listed on the same 

RWP (96 percent of the time). 

• The unmonitored subCTW and the coworker only performed work under a given RWP 

on the same date 77 percent of the time; different dates could mean different tasks and, 

therefore, different exposure potentials.

• The unmonitored subCTW and the coworker both signed in on the same RWP and same 

date and worked during the same time interval 66 percent of time. Different times of the 

day or different time intervals could mean different exposure potentials. 

• The coworker only met all four of the required criteria 45 percent of the time to indicate a 

coworker and the unmonitored subCTW were working side by side performing similar 

tasks (i.e., same craft designation) on the same date at the same time.

SC&A found that the unmonitored subCTW and the monitored coworker had the same job title 

60 percent of the time when signed in on the same RWP (regardless of sign in date or time). 

Different craft could mean different exposure potentials. 

Observation 4: SC&A’s analysis indicates that identified coworker matches may not be 

sufficiently representative of the subCTW intakes in all cases unless strict criteria are 

applied, such as the same craft designation as well as the same date and time of the 

work performed.

6.4 Implementation in the field was not a step function beginning in 1990

Although corporate and policy changes were initiated in 1990, those changes did not take place 

immediately. It took well into the 1990s to implement changes in the field, and to obtain better 

bioassay participation and record storage and retrieval. Some of the relevant issues and 

deficiencies that extend into the 1990s have been previously discussed in detail in this report 

while evaluating the 1972–1989 data. If the necessary changes had been implemented relatively 

quickly, then there would not have been issues that were being identified and addressed in the 

1990s. Most of these 1990s issues have previously been discussed by the SRS work group. 

Examples of issues that extended into the 1990s are contained in the DOE 1998 occurrence 

report, “Inadequate Participation in the Job-Specific Bioassay Program” (DOE, 1998a); the 1998 

“Root Cause Analysis for Corrective Action Report #97-CAR-07-0001” (Kornacki et al., 1998); 

and the 1999 WSRC interoffice memorandum, “Response to the Compilation of PAAA Internal 

Dosimetry Issues” (Morgan, 1999). 
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SC&A analyzed the data in table C-1 of RPRT-0092 to determine when RWPs began to state 

that a bioassay was required, and the types of radionuclides that should be bioassayed for. SC&A 

sorted the data in table C-1 according to the year of the RWP (1990–1998) and determined the 

total number of bioassays required by adding the number required by an RWP (represented by 

the symbol “R” in table C-1) plus the number assumed to be needed by NIOSH (represented by 

the symbol “A” in table C-1). The total number of RWP required bioassays (R) was then divided 

by the total number of required bioassays (R+A) to obtain the fraction of bioassays used in 

RPRP-0092 that were specifically required by the RWPs. This procedure was performed 

annually for each radionuclide. The results are summarized in table 15. 

Table 15. Percent of RWP required bioassays compared to the total number of bioassays in

RPRT-0092, table C-1 

Year 

Percent 

of Pu 

bios* 

required 

by 

RWPs

Total of 

RWP 

plus 

assumed 

Pu

bios

Percent 

of Sr/FP 

bios 

required 

by RWPs

Total of 

RWP 

plus 

assumed 

Sr/FP 

bios

Percent 

of Am 

bios 

required 

by RWPs

Total of 

RWP 

plus 

assumed 

Am bios

Percent 

of U bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

U bios

Percent 

of Np 

bios 

required 

by RWPs

Total of 

RWP 

plus 

assumed 

Np bios

1990 0% 1 0% 1 NA 0 0% 1 NA 0

1991 0% 16 0% 13 0% 4 25% 4 0% 1

1992 0% 23 0% 9 0% 12 0% 20 0% 2

1993 4% 27 0% 12 0% 13 9% 11 0% 11

1994 78% 32 72% 25 33% 9 33% 15 NA 0

1995 100% 15 100% 5 0% 2 100% 2 33% 3

1996 100% 7 100% 3 0% 2 NA 0 100% 1

1997 100% 9 100% 8 0% 1 NA 0 NA 0

1998 80% 10 71% 7 0% 1 NA 0 NA 0

Pu = plutonium, Sr/FP = strontium/fission products, Am = americium, U = uranium, Np = neptunium 

* bios = bioassays 

The results in table 15 indicate that RWPs began to specify that a bioassay was required for a 

certain radionuclide in the mid-1990s (1994 to 1995). 

Observation 5: Bioassay data in the 1990s are not entirely free of the earlier data issues.

The implementation of methods used to correct for the bioassay deficiencies seen in the 

1970s and 1980s did not take place immediately with the change in the contracting 

company in 1990. It was not a step function that took place in 1990; instead, it took a 

number of years to identify, address, and effectively implement the changes. For 

example, there was only one RWP with one subCTW listed for 1990 in RPRT-0092, and 

specific radionuclides were not required on the RWPs until the mid-1990s.
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7 Conclusions

SC&A reviewed ORAUT-RPRT-0092, revision 00, “Evaluation of Bioassay Data for 

Subcontracted Construction Trade Workers at the Savannah River Site,” from three vantage 

points: 

1. Sampling premise: From the standpoint of sampling experience and results, were the 

guiding assumptions, upon which the evaluation was planned and conducted borne out 

for the time periods in question?

2. Sampling execution: From the standpoint of sampling execution, was its primary goal 

accomplished? In other words, did it “randomly select radiological workers from the 

various areas at the Savannah River Site (SRS), such that an evaluation of monitored and 

unmonitored workers can be conducted” (NIOSH, 2018a, p. 1)? 

3. Coworker datasets: From the standpoint of NIOSH’s “Draft Criteria for the Evaluation 

and Use of Coworker Datasets” (NIOSH, 2015), did the evaluation satisfy its stated 

objective of demonstrating that “monitored subcontractor CTWs and unmonitored 

subcontractor CTWs worked side by side in the same radiological environment at the 

same time” (NIOSH, 2018a, p. 1)? 

7.1 Sampling premise

For the first vantage point concerning the sampling premise, SC&A concludes that NIOSH’s 

guiding assumptions for sampling subcontractor bioassay data for 1972–1989 have neither been 

validated in practice nor adequately grounded in actual DuPont policies, procedures, and practice 

of that time period. In vitro and in vivo bioassays were linked to SWPs and job plans without 

clear evidence that the former stemmed from the latter and were not merely incidental. None of 

the SWPs and job plans for that period reviewed by SC&A contained any bioassay requirements, 

despite the vast majority of them requiring respiratory protection. The basis for identifying 

“radionuclides of interest” for sampled permits does not account for inadequate radiological 

characterization cited by DOE. The scope of sampling is limited to one SRS facility, 773-A, for 

incomplete operational periods, and is not representative of other critical SRS facilities. The 

inclusion of incident-driven bioassays is not appropriate, given the degree of procedural 

accountability provided special bioassays, as compared with that afforded the routine and jobspecific bioassay program (for which DOE found a history of delinquent bioassays). The 

completeness of these and other radiological records is questionable, given the acknowledged 

destruction of subcontractor records, DOE findings of missing occupational dose data, and 

firsthand worker accounts regarding dose record gaps. 

For the post-1989 period, SC&A concludes there were similar concerns until such time as the 

new contractor, WSRC, was able to develop, implement, and hold SRS line management 

accountable, as part of its Radiological Improvement Plan. This plan included a spectrum of new 

and updated radiation protection and bioassay policies and procedures, including (1) the late 

1990 “Internal Dosimetry Technical Basis Manual” (WSRC, 1990b), (2) the implementation of a 

1990 RWP program requiring a job-specific bioassay program (begun in 1991) that was required 

upon respirator use (WSRC, 1992b), and (3) manual 5Q1.1 “Radiation and Contamination 

Control Procedures” (WSRC, 1992b). However, it is not clear when effective implementation 
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was actually achieved, given the persistence of the former workplace practices, as illustrated by 

the significant job-specific bioassay gaps uncovered by WSRC and DOE in 1997–1998. 

The underlying reason for these disparities lies in the difference in how job-specific permits and 

bioassays were apparently handled by DuPont in 1972–1989,29 and the premise and assumptions 

applied by NIOSH, many of which were either founded on WSRC’s policies and practices of the 

1990s, or were not grounded in contemporary policies, procedures, and practices of the DuPont 

era, as critiqued by DOE and WSRC, as the site transitioned from DuPont to Westinghouse. This 

fundamental difference between how the internal dosimetry program was defined and 

implemented between the two operational eras—1972-1989 and post-1989—along with the 

substantial absence of permit records for all but one facility, 773-A, makes the application of the 

same evaluation criteria and assumptions to survey both time frames unrealistic. 

29 As noted earlier in this report, any conclusion for 1972–1989 would likely apply also to 1990 (albeit the job 

plans evaluated only extend to March 1988).

7.2 Sampling execution

For the second vantage point concerning sampling execution, SC&A concludes that for 1972–

1989, NIOSH’s interpretation of “effective monitoring” to include coworker matches involving 

internal bioassay methods that are not used in the formulation of the coworker models presented 

in OTIB-0081 is technically inappropriate. Likewise, NIOSH’s consideration that “lack of 

bioassay samples for several years” would not be considered “unmonitored” for purposes of the 

job plan review is inconsistent with the essential purpose of permitted job-specific bioassays, as 

well as with documented NIOSH positions (e.g., NIOSH (2019a, 2018b)). Specifically, periods 

greater than 2 years for all fission product monitoring as well as chest counts for long-lived 

radionuclides (e.g., plutonium and americium) should be considered unmonitored. When SC&A 

revised the “matching” percentage in RPRT-0092 based on removing these two questionable 

adjustments, it was found that for americium, there was only one data point for 1973 (0 percent 

effectively monitored), and 33 percent effectively monitored for 1981–1987 (versus 76 percent

in RPRT-0092). For plutonium, SC&A determined that 64.7 percent were effectively monitored 

for 1972–1974 (versus 69 percent in RPRT-0092), with agreement between both SC&A and 

NIOSH on 97 percent effectively monitored for 1980–1989. For fission products, SC&A 

determined that 69.9 percent of the worker population was effectively monitored for 1972–1974 

(versus 94 percent in RPRT-0092) and 73.9 percent for 1980–1989 (versus 99 percent for 

RPRT-0092). While the question of “how complete is complete enough?” is a subjective policybased decision, the removal of these two “adjustments” from the assessment lowers the bioassay 

monitoring percentages to a level comparable to that seen in SC&A’s 2017 subcontractor 

completeness review (SC&A, 2017a) and that cited by WSRC in its self-assessments of jobspecific bioassays in 1997 (DOE, 1998b). 

From its review of the americium data, SC&A does not find that the RPRT-0092 review supports 

the premise that subcontractors on job plans that should have required internal monitoring for 

americium were either directly monitored (approximately 20 percent) or, alternately, 

appropriately represented in the derived coworker models for SRS (about 13 percent).

Likewise, SC&A found that the many workers (approximately 70–73 percent) who should have 

been monitored for fission products underwent appropriate internal sampling during the two 

 
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periods evaluated prior to 1990. However, very few of those monitored workers underwent 

in vivo counting for fission products. Thus, they are not included in the coworker model 

developed for SRS and not considered representative of the unmonitored worker.

For all periods evaluated, SC&A concludes that there is an apparent lack of adherence of the 

RPRT-0092 review to its sampling plan in that bioassays for all of the radionuclides listed on the 

RWP were not addressed in the corresponding data analyses for the specific time intervals. This 

was also the conclusion reached in section 6.2.2 of this report. Table 6-4 in the summary section 

of RPRT-0092 details the total percentage of workers “monitored for at least one radionuclide.” 

SC&A believes this is a misleading metric and that the appropriate metric would be “monitored 

for all radionuclides on the work permit/job plan.” A comparison of these values is shown below 

in table 16. 

Table 16. Comparison of monitoring percentages involving at least one radionuclide 

(RPRT-0092 value) versus all radionuclides on work permit (SC&A value)

Time period 

RPRT-0092 directly 

monitored for at 

least one 

radionuclide 

SC&A directly 

monitored for all 

radionuclides on 

work permit

RPRT-0092 

effectively 

monitored for at 

least one 

radionuclide

SC&A effectively 

monitored for all 

radionuclides on 

work permit

1972–1974 76% 47.1% 85% 55.1%

1975–1979 No data No data No data No data

1980–1989 90% 51.3% 99% 65.5%

1990–1998 96% 77% 97% 89%

Finding 11: For both the 1972–1989 and the 1990–1998 periods, when considering all 

radionuclides requiring internal monitoring per work permit, as opposed to “at least one 

radionuclide” requiring monitoring, the percentage of monitored workers drops 

significantly (particularly in the earlier periods). Directly monitored workers ranged from 

47 percent to 77 percent (in comparison to 76–96 percent in RPRT-0092), and effectively 

monitored workers ranged from 55 percent to 89 percent (in comparison to 85–99 percent

in RPRT-0092). 

SC&A also concluded that, because data are lacking for 1990 (only one RWP and one subCTW 

listed), it does not warrant bundling with the period 1990–1998 (see finding 10). 

7.3 Coworker datasets

For the third vantage point concerning establishing that unmonitored subcontractors worked side 

by side with monitored subcontractors, SC&A concludes that the current sampling effort in 

RPRT-0092 was not successful in identifying suitable coworkers for americium for 1981–1987, 

as just 13 percent of the overall population (16 percent of the unmonitored population) was 

matched based on coworker urinalysis. For fission products 1980–1989, just 1.4 percent of the 

overall population (37 percent of the unmonitored population) were effectively matched by in 

vivo. No suitable coworker matches were identified for fission products in the 1972–1974 

period, and only a single unmonitored worker was identified for americium exposure during this 

same period. No coworker evaluations for any radionuclides were possible for 1975–1979. For 

plutonium, the sampling effort identified coworker matches for about 15 percent of the worker 
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population (29 percent of the unmonitored population), which raised the effective monitored 

population from 50 percent to 65 percent for 1972–1974. 

For 1990–1998, a focused review of plutonium coworker matches during the WSRC period notes 

that while nearly 96 percent of the identified coworker matches involve the same job plan, 

inclusion of additional criteria (e.g., the same date, time, and craft) decreases this percentage 

significantly. When considering all four criteria for a coworker match (job plan, date, time, and 

craft), appropriate coworker matches for plutonium were identified in RPRT-0092 just 

45 percent of the time.

7.4 Overall conclusions

Overall, SC&A concludes that the RPRT-0092 assessment of subcontractor completeness for

1972–1998 does not reflect the policies, procedures, and practice during the DuPont operating 

era of 1972–1990 and, therefore, makes unfounded assumptions and evaluations of bioassay 

performance that lead to invalid results and conclusions. Those sitewide conditions only change 

with the advent of new and updated RWP and bioassay procedures implemented by WSRC in 

the early 1990s, at which point the RPRT-0092 assessment can be substantiated. Further, 

questions of overall data completeness persist based on destruction of subcontractor records and 

reported gaps in worker exposure records, compounded by issues of records retention and 

irretrievability.

In summary, without the validation of subcontractor data completeness that the RPRT-0092 

evaluation was to provide, there has been no substantiation that there are sufficient job-specific 

bioassay measurements available to ensure that the coworker data in OTIB-0081 are either 

bounding or representative of the exposure potential of subcontractors performing permit-driven 

work across the SRS site.
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

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NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Appendix 1: SC&A’s Analysis of OTIB-0081 NOCTS Bioassay Data per 

SRS Area (1972–1990)

SC&A performed an analysis of the NOCTS coworker data used in ORAUT-OTIB-0081, 

revision 04 (NIOSH, 2019c), to determine if those data suffered from the same lack of SRS 

facility coverage as the job plan and SWPs data do in RPRT-0092 for the period 1972–1989 

(i.e., limited to Area A). SC&A sorted approximately 47,000 in vitro bioassay records (obtained 

from the file, “SRS combined in-vitro data 051717.xlsx,” in the folder, “Bioassay Data-May 

Contain PII,” provided by NIOSH) and approximately 22,000 in vivo bioassay records (obtained 

from the file, “SRS combined in-vivo data 0083117.xlsx,” in the folder, “Bioassay Data-May 

Contain PII,” provided by NIOSH) according to the area in which the work task was located to 

determine the fraction of the total bioassays that were from the major areas at SRS. The results 

are summarized in figures A1 and A2 below. 

Figure A1. Fraction of NOCTS in vitro bioassays from areas at SRS (1972–1990)

0.0000

0.0500

0.1000

0.1500

0.2000

0.2500

221

700-771

773A

105

300-399

772

Areas <100 bios

Blank or X's

244-299

1-99

234242241

CS

200

201-211

235

400-484

232100

618-690

H-Line

Fraction of 22k Bios 

SRS Location
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NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Figure A2. Fraction of NOCTS in vivo bioassays from areas at SRS (1972–1990)

0.0000

0.0500

0.1000

0.1500

0.2000

0.2500

221

700-771

773A

105

300-399

772

Areas <100 bios

Blank or X's

244-299

1-99

234242241

CS

200

201-211

235

400-484

232100

618-690

H-Line

Fraction of 22k Bios 

SRS Location

This analysis indicates that the 1972–1990 NOCTS coworker bioassay data used in OTIB-0081 

were not concentrated in only Area A, as the RPRT-0092 1972–1989 job plan and SWP data 

were.
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NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Appendix 2: SC&A’s Analysis Used to Spot Check RPRT-0092 Data 

Process

SC&A sorted the information listed in NIOSH’s file, “CTW Bioassay Requirements Table C2.xlsx” (obtained from NIOSH’s folder G, “Report Tables”) to obtain examples of RWPs that 

covered the 9-year period of interest (1990–1998), a variety of SRS areas (Areas F, H, M, and 

Z), and various crafts. From the results of this sorting, potential SID numbers and corresponding 

CTW numbers were obtained. SC&A then used the selected SID documents from NIOSH’s 

folder E to obtain the details of the RWP, sign-in sheet, CTW name, and CTW bioassay data. 

SC&A used the NIOSH file, “Master list of Employees to CTW number for Report Final.xlsx” 

(obtained from NIOSH’s folder G, “Report Tables”), to cross-reference the CTW name on the 

sign-in sheet to the CTW number used in the tables in attachment C of RPRT-0092.