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 document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution. 

MEMORANDUM

TO: Savannah River Site Work Group 

FROM: SC&A, Inc.

DATE: May 1, 2018 

SUBJECT: Response to NIOSH’s Review of SC&A’s Evaluation of SRS Subcontractor 

Bioassay Data Completeness

Background 

SC&A was originally tasked by the Advisory Board on Radiation and Worker Health (ABRWH 

or the Board) to conduct a broad review of bioassay data completeness for subcontractor 

construction trade workers (CTWs) at the Savannah River Site (SRS), resulting in its report, 

Evaluation of Savannah River Site Subcontractor Bioassay Data Completeness (SC&A 2017). 

This completeness review was undertaken in parallel with a National Institute for Occupational 

Safety and Health (NIOSH) effort to review the completeness of bioassay data for Building 

773-A for the years 1981–1986. At the time, the 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). There were previous attempts by NIOSH to address this question (using 

NIOSH/OCAS Claims Tracking System [NOCTS] data and a database maintained by the Center 

for Construction Research and Training [CPWR], respectively), but they proved unsuccessful in 

the interim since this issue first surfaced in a 2013 interview with a senior SRS internal 

dosimetrist.

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

coworker model, as is currently proposed by NIOSH for CTWs, including subcontractors. As has 

been emphasized in various meetings and forums, SC&A finds that the rapidly changing 

operational circumstances at SRS in 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, leading to 

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

subcontractors may not have been bioassayed adequately in light of their often-intermittent work 

on site and the lack of a comprehensive termination bioassay program. This concern was 

underscored by SC&A’s finding that the U.S. Department of Energy (DOE) had, in fact, cited 

and fined Westinghouse Savannah River Company (WSRC) in 1998 for not adequately 

monitoring workers performing radiation work under job-specific Radiological Work Permits 

(RWPs) (DOE 1998a). 
Memo – Subcontractor Bioassay Data Completeness 2 SC&A – May 1, 2018 

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This commentary is in response to NIOSH’s review of SC&A’s SRS subcontractor bioassay data 

completeness report, as contained in Response to SC&A’s Evaluation of Savannah River Site 

Subcontractor Bioassay Data Completeness, SC&A-TR-2017-SEC009-SC&A (NIOSH 2018). 

NIOSH Statement, Executive Summary

In its Executive Summary, NIOSH states that “SC&A judged the SRS bioassay program as 

‘dysfunctional’ and stated that the bioassay results available for subcontractor CTWs for the 

period 1989 through 1998 did not satisfy NIOSH criteria for coworker datasets” (NIOSH 2018, 

p. 2). SC&A respectfully disagrees with this statement and finds it to be a mischaracterization of 

its conclusion. 

Instead, the conclusion in our report clearly states (emphasis added): 

While there has been some discussion of what would constitute reasonable 

“success” criteria for sampled completeness of subcontractor CTW bioassay 

records, these results and compliance history indicate a dysfunctional job-specific

bioassay program at SRS whose results are manifestly incomplete for at least the 

period 1989–1998 and should not be relied upon for coworker model 

development. [SC&A 2017, p. 7]

This is not mere parsing of terms. In its review and report, SC&A made no finding regarding the 

overall “SRS bioassay program”; its review focused exclusively on subcontractor CTWs in terms 

of bioassay data completeness, which was the scope of its tasking from the Board. In this 

context, SC&A’s caution about use of job-specific bioassay data from this period follows from 

the substantial evidence of wide and persistent monitoring gaps that were found by WSRC in 

1997, and confirmed by DOE in its Notice of Violation in 1998 (DOE 1998a). Clearly, the 

number of job-specific bioassays affected is much smaller than those of CTWs, in general, and a 

very small fraction of the overall SRS bioassay program, as illustrated in Table 1. 

Table 1. SRS Job-Specific vs. Routine Urine Samples

Urine Bioassay 1996 1997 1998 (mid-July)

Routine actinide, 

received 8,062 9,053 4,864

Routine tritium, 

received 25,691 24,210 N/A (not available)

Job-specific actinide N/A 1,500* 564

*approximate

Source: LaBone 1997.

Much of the ensuing discussion that has been led by NIOSH has been directed at whether this 

larger dataset can be applied in some fashion (e.g., through use of NOCTS CTW data for pre1989 or CTW coworker models in the WSRC era) to represent this particular job-specific cohort. 

While SC&A has raised concerns about the representativeness of this broader site monitoring 

data to bound the dose of these often transient subcontractor CTWs on RWP job-specific 
Memo – Subcontractor Bioassay Data Completeness 3 SC&A – May 1, 2018 

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bioassay, the functionality or soundness of the SRS routine or the special bioassay program itself 

have never been questioned. 

NIOSH Issue 1 

Bioassay data should have been separated into tritium and non-tritium and 

appropriate time intervals used for evaluation. [NIOSH 2018, p. 2] 

In its original sampling plan, SC&A had proposed the 30- and 90-day survey interval as the best 

“indicator” of RWP compliance and bioassay records completeness, given the often-intermittent 

nature of subcontractor CTW work at SRS. As emphasized in SC&A’s report, the inconsistent 

nature of RWPs and SRWPs at SRS, as well as the lack of explicit target radionuclides cited, 

made definitive surveying of follow-up bioassays difficult, if not impossible. Therefore, applying 

an approach using “indices” of bioassay compliance or responsiveness, SC&A’s stated approach 

was as follows:

Once the CTW compilations were available in the SRDB, SC&A commenced its 

bioassay review process. This involved matching the prescribed RWP job date 

with any corresponding urinalyses of record, either within 30 days or 90 days, 

respectively. The basis for this consideration is to provide indices of bioassay 

compliance or responsiveness, with 30 and 90 days used as measures of 

responsiveness to an RWP end-of-job bioassay requirement. For tritium 

urinalyses, such responsiveness would be essential for adequate dose 

assessments; for plutonium or uranium urinalyses, this would be considerably 

less so. This is not to draw a broad program judgment of SRS dose assessment or 

technical adequacy, but to provide an overall indicator of both monitoring 

program compliance and record completeness. [Emphasis added.] [SC&A 2017, 

p. 13] 

While acknowledging NIOSH’s later research and assessment that bioassays for longer-lived 

radionuclides (i.e., non-tritium) may be undercounted under this indexing protocol, SC&A noted 

that, given the intermittent nature of subcontractor CTW jobs, it remained important to review 

any “end-of-job” bioassays for these radionuclides, as well. If such bioassays were not 

performed, recognizing the inadequate implementation of termination bioassays at SRS at that 

time, these transient workers could leave the site without any bioassays. This is emphasized in 

SC&A’s report, as well:

It is also understood that the 30- and 90-day bioassay criteria are “indicators” of 

RWP compliance and bioassay records completeness, and that later bioassays for 

potential exposure to longer-lived nuclides such as plutonium and neptunium 

would be relevant to dose assessment but problematic for subcontractor CTWs,

given the intermittent nature of their work on site and common lack of 

compliance with termination bioassays. [Emphasis added.] [SC&A 2017, p. 15] 

Notwithstanding these explicit qualifiers in the 2017 report, SC&A agrees with the results of 

NIOSH’s subsequent data capture and research on how the job-specific bioassay program was 
Memo – Subcontractor Bioassay Data Completeness 4 SC&A – May 1, 2018 

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implemented at SRS. It is now clear from this more recent review that routine plutonium and 

uranium bioassays were collected on a biannual and annual basis, as determined by WSRC 

procedure, and were the means to satisfy RWP job-specific end-of-job bioassay requirements for 

these longer-lived radionuclides. However, with the transient nature of subcontractor CTWs 

during the 1990s at SRS and the inadequate implementation of a termination bioassay program, 

it remains unclear how many subcontractor CTWs on RWP-prescribed job-specific bioassays for 

plutonium or other longer lived radionuclides may have left the site without sampling because 

their RWP was incomplete or they missed the routine 6- or 12-month cycle of monitoring, as 

well as any termination monitoring. 

As pointed out by SC&A at both the August 2017 and December 2017 Advisory Board 

meetings, the WSRC completeness self-survey results of 1997 have become the dominant and 

overarching indicators of job-specific bioassay completeness for SRS during this timeframe.

Two contemporary WSRC self-surveys in 1997 found 21% completeness in a 100% survey of all 

job-specific surveys and 33% completeness in a more limited sampling (for the former, a 

resampling found no positive intakes). Given the lack of complete RWPs for the 1989–1996 

period, as well as the lack of Facility Evaluation Reports that could clarify what categories of 

workers were on job-specific bioassays, the 1997 self-surveys stand as the most credible 

measures of job-specific bioassay that exist at this point.1

1 NIOSH has since announced it has discovered 852 boxes of SRS RWP records at the Atlanta Federal Record 

Center, which it proposes to review in 2018. These records, if sufficiently complete for the years in question (1972–

1996), could provide a means to adequately sample for the completeness of subcontractor CTW records. 

Therefore, the assessments performed 

by SC&A, using substantially incomplete RWP monitoring data, and by NIOSH, using data for 

one facility (773-A) for 1981–1986, while useful as indicators of completeness, are not 

sufficiently sound or representative to adequately characterize the SRS-wide exposures involved 

for 1972–1995, the completeness of job-specific bioassay compliance, or the actual CTW worker 

cohort involved with RWPs and SRWPs. 

NIOSH Issue 2 

Some SRWPs should have been excluded from analysis. [NIOSH 2018, p. 2]

Upon further review, SC&A agrees that some standing radiation work permits (SRWPs) 

previously selected do contain provisions that would preclude entry of certain personnel (e.g., 

who are on tours or inspections) into controlled areas and therefore should have been excluded 

from the review. However, it is clear that this discrepancy has implications for only two of the 85 

subcontractor workers surveyed who were sampled from the SRWP signup sheets at SRS for

1989–1995. It is also apparent that SRWP signup sheets were frequently not filled out correctly, 

using outdated forms without a bioassay designation block and not always specifying specific 

work locations for entry (Stafford 1998, PDF p. 75). 

From additional research following the SC&A survey, further information was gleaned regarding 

the use of RWPs at SRS. As noted in WSRC’s ESH-HPT-98-0453: 

 
Memo – Subcontractor Bioassay Data Completeness 5 SC&A – May 1, 2018 

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An RWP is an authorization document that identifies radiological conditions, 

establishes requirements to perform the work identified on the permit, and 

contains approvals for the specified radiological work activities. Thus the RWP 

serves two major functions: (1) an administrative process for planning and 

controlling radiological work and (2) a source of information for the worker 

regarding the radiological conditions in which he/she will be working. There are 

two types of RWPs – standing and job-specific. The standing RWP is used to 

authorize work that is of a repetitive and routine nature. The job-specific RWP 

is written specifically for a certain task of limited duration. The RWP prescribes 

protective measures such as the use of protective clothing, respiratory protection, 

and RWP suspension limits for expected conditions to ensure a worker’s 

radiological safety, including the prevention of intakes. [Emphasis added.] 

[WSRC 1998, p. 1] 

Under this definition of when to use an SRWP (“work that is of a repetitive and routine nature”), 

SRWPs would not have been included in the SC&A survey, in retrospect.2

2 In its original assessment design, SC&A “performed sampling using SRS Radiation Work Permits (RWPs) for 

individual subcontractor CTWs as a means to ascertain whether corresponding job-specific bioassay results could 

be found in the SRS bioassay records (either hardcopy, microfiche, or electronic)” (SC&A 2017, p. 6). While 

SRWPs were included at the time (due to the overall lack of RWPs), it is now understood that they constituted more 

“routine” and “repetitive” radiological jobs versus certain tasks of a more unique nature. 

 Notwithstanding the 

apparent routine nature of the work, the SRWPs typically employed signup sheets where workers 

would be assigned to specific radiological jobs in an SRS facility (e.g., K Reactor or 321-M) 

over an extended period of time. Of the 85 subcontractors sampled from SRWPs, all but five had 

follow-on bioassays within either 30 or 90 days of the SRWP job date cited. For the five that did 

not, three were missing any evidence of an SRS dosimetry record (external and internal). The 

remaining two had an SRWP (K-89S-001), for which a bioassay requirement was lacking. They

had no evidence of a follow-on bioassay within 30 or 90 days of the job date listed. For the 80 

subcontractors who had follow-on bioassays, most had SWRPs that explicitly required bioassays, 

while 23 workers under SRWP K-89S-001 did not. SC&A believes this disparity—some SRWPs 

having no provision provided for required bioassays, but workers showing routine bioassays for 

tritium, nonetheless—can be explained by inconsistent implementation of SRWPs at SRS in the 

1990s, as explained below. 

WSRC performed a self-assessment of the SRWP bioassay program in 1998, as part of a root 

cause analysis regarding WSRC’s issuance Corrective Action Report 97-CAR-07-0001, “WSRC 

Radiological Control Program does not adequately ensure that workers not covered by the 

routine bioassay program provide the required job-specific bioassay samples” (Kornacki et al., 

1998, PDF p. 14). That self-assessment surveyed SWRP bioassay sampling requirements from 

all applicable SRS radiological facilities. That review found the following, in part, from various 

SRS facilities (“Consolidated Deficiencies”):

• Not all radiological facilities are using the most current approved version 

of electronic form OSR 4-639 which contains a Bioassay Requirements 

 
Memo – Subcontractor Bioassay Data Completeness 6 SC&A – May 1, 2018 

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block. Additionally, not all facilities are utilizing the Bioassay 

Requirements block to indicate bioassay sampling requirements. 

....

• There is no consistency amongst facilities when indicating bioassay 

sampling related information in the special precautions section of the 

SRWP.... 

• Some facilities require bioassay sampling only when respiratory 

protection is worn and others require bioassay sampling when there is no 

requirement for respiratory protection.... It was determined during 

previous document reviews of SRWP sign-ins that it is impossible to 

identify which workers should have left a bioassay sample and which did 

not have to in these cases because it is not apparent who wore a mask.... 

• Some SWRPs cover entry into different facilities with different bioassay 

sample requirements. It is not possible to determine by document review 

whether a worker has met the bioassay sampling requirement since there 

is no indication on the sign-in sheet as to which facility was entered....

• Some facilities are not performing airborne radioactivity monitoring or 

setting suspension limits for radionuclides identified as requiring bioassay 

sampling. [Stafford 1998, PDF p. 88] 

From the above findings, it would not necessarily be possible to identify whether specific 

workers on SWRPs entered a particular facility or area based on SRWP documentation, and 

whether they met the appropriate bioassay sampling requirement. SC&A emphasized the 

incompleteness and inconsistent implementation of RWPs and SRWPs at an early stage of 

review in Evaluation of Savannah River Site Subcontractor Bioassay Data Completeness: 

There was a wide difference between the various permits in terms of the degree of 

job requirements detailed, numbers of workers assigned, and whether bioassay 

was required. For some RWP forms, bioassay was required upon “end of shift,” 

while others required bioassay without specifying timing, and still others did not 

provide for such specification explicitly. In the last case, it has become clear from 

corrective actions required in the aftermath of a DOE Notice of Violation 

(NOV)...that RWP forms at SRS did not uniformly include a bioassay sample 

program checkoff despite such job-specific monitoring being required, and 

conducted both by procedure and practice. [SC&A 2017, p. 11]

SC&A concludes that while two of the 85 subcontractors sampled from SWRP signup sheets 

were affected by the provision cited in the example SWRP, K-89S-001, this would not have 

influenced the final results in a significant manner. The issue is also overwhelmed by the overall 

inconsistent implementation of the RWP and SWRP program itself, as documented above, and 
Memo – Subcontractor Bioassay Data Completeness 7 SC&A – May 1, 2018 

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by the later results of contemporaneous self-surveys of job-specific bioassay compliance 

conducted by WSRC. 

NIOSH Issue 3 

The Notice of Violation applied only to RWP job-specific bioassay samples which 

were not required by regulation and were only one part of an overall worker 

protection program. [NIOSH 2018, p. 3] 

First, it is not clear why NIOSH continues to question the regulatory basis of the NOV or its 

implications regarding the effectiveness of the SRS bioassay program. The strength of the SRS 

bioassay program is neither in question nor relevant to the issue of an identified potential gap in 

monitoring data (job-specific bioassays for RWP/SRWP work in 1989–1996). The apparent lack 

of job-specific bioassays at SRS for those years is also not in question: Despite extensive data 

captures since the issuance of SC&A’s July 2017 report, job-specific bioassays for those years 

have not yet been identified other than the 1997 resampling bioassays performed by WSRC 

following the initial NOV. In SC&A’s judgment, the real and only concern is, as emphasized in 

its July 2017 recommendation to the Work Group, “whether NIOSH has any available 

monitoring data or bounding approach that could ameliorate this fundamental data gap” 

(SC&A 2017, p. 22). 

Apart from this overarching consideration, SC&A continues to have objections to NIOSH’s 

characterizations of the NOV and its implications for the adequacy and completeness of the SRS 

job-specific bioassay program. NIOSH, in its discussion, appears to dispute that the NOV is 

evidence of “a chronic history of wide noncompliance with job-specific bioassay requirements” 

(SC&A 2017, p. 6).3

3 In its August 23–24, 2017, Board presentation, November 14, 2017, Work Group presentation, and December 13–

14, 2017, Board presentation, NIOSH has stressed that the NOV is not relevant to the issue of an adequate coworker 

model for subcontractor CTWs (e.g., it was characterized by NIOSH as a “distraction” during the August 16, 2017, 

Work Group call). NIOSH’s reasons for this position include that (1) the NOV did not cite 10 CFR Part 835 in terms 

of the adequacy of radiological monitoring, (2) it is based only on the assessed period of November 1995 to July 

1997, and (3) it addressed just the job-specific component of radiological surveillance. NIOSH also characterized 

the overall SRS radiological control program as representing “defense-in-depth,” with a “no intake policy” and no 

plutonium workers “likely” to receive an intake of 100 mrem committed effective dose equivalent or more. 

 The data cited by NIOSH as a basis for questioning this conclusion notes “a 

participation rate for all bioassay samples of greater than 96%” and that “all workers who did 

not provide samples in 1997 were sampled in 1998 with no identified uptakes” (NIOSH 2018, 

p. 3). However, whether the overall bioassay program had a high participation rate, or whether a 

resampling of those subcontractors who did not participate in their RWP-required bioassay 

programs in 1997 showed no intakes, are not relevant to the question of whether the job-specific 

bioassay program was compliant or complete over time at SRS. That question was settled by 

WSRC and DOE in 1997 and 1998, when DOE affirmed in the 1998 NOV that “[WSRC] 

workers and their management routinely failed, over a period of approximately two years, to 

ensure that job-specific bioassay samples were submitted for analysis as required by WSRC 

internal procedures” (emphasis added) (DOE 1998a, PDF p. 8). That NOV also emphasized that 

“these violations are not isolated instances and reflect multiple failures across several 

organizations over several years, in addition to inadequate management attention to a 

 
Memo – Subcontractor Bioassay Data Completeness 8 SC&A – May 1, 2018 

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continuing trend of failure to adhere to WSRC requirements for the bioassay program as 

identified in the radiological work control program” (emphasis added) (DOE 1998a, PDF p. 9).

SC&A’s conclusion regarding a chronic pattern of wide noncompliance (i.e., 67% and 79%) with 

job-specific bioassay requirements is no different from that reached by DOE in its enforcement 

action. 

NIOSH’s response likewise raises the issue of 10 CFR Part 835 versus 10 CFR Part 820 as the 

basis for the 1998 NOV. SC&A has not raised this as an issue nor questions the distinction 

between how DOE chose to exercise its regulatory basis for enforcement at SRS. However, 

while SC&A understands that the potential for radiation exposure in the SRS routine bioassay 

program may have been unlikely to exceed 100 millirem in a year, the potential exists to miss a 

substantial internal dose due to nonparticipation in RWP-required job-specific bioassay 

programs. This case was pointedly made by DOE in rejecting a WSRC argument similar to that 

made by NIOSH about the otherwise soundness of its routine bioassay program, particularly the 

low potential for intakes:

DOE is aware that, for all radionuclides other than [a specific material], the 

WSRC internal dosimetry program does not knowingly permit any worker to be 

exposed to airborne radioactive material. Further, it is noted that WSRC has 

implemented a rigorous program for the comprehensive use of field indicators 

during work activities to signal that an unexpected radiological condition may 

have led to potential occupation intakes of radioactive material by a worker [i.e., 

necessitating “special” bioassays]. Nonetheless, DOE also appreciates that the 

potential exists to overlook worker exposures to radioactive material due to 

unrecognized field conditions or other types of personnel error. For example, at 

[a facility] in 1996, one worker received an unsuspected intake of [radioactive 

material] that resulted in an organ dose in excess of [a specified amount], a 

dose that far exceeded DOE’s regulatory limit of 50,000 millirem. The dose to 

this worker was not identified by the WSRC field indicator program but was 

identified through the bioassay program. [Emphasis added.] [DOE 1998a, PDF 

p. 9] 

The issue is not what was required by 10 CFR Part 835, but whether and how the missing 

bioassay doses, whether actual (1995–1996) or postulated (1972–1995), can be characterized and 

bound such that a valid coworker dose can be estimated. It should be emphasized that the above 

DOE finding was reached following an enforcement conference between DOE and WSRC where 

the exact argument was made by WSRC, to no avail, that the workers on job-specific bioassays 

“were not considered part of the work force likely to receive more than 100 mrem total effective 

dose equivalent annually” (DOE 1998b, p. 7). 

Finally, SC&A respectfully disputes NIOSH’s statement that SC&A has concluded that “this 

NOV would prohibit dose reconstruction of subcontractor construction trades workers” (NIOSH 

2018, p. 23). As noted repeatedly in presentations before the Board and to NIOSH, SC&A never 

made that statement. What SC&A has concluded and recommended, is as follows: 
Memo – Subcontractor Bioassay Data Completeness 9 SC&A – May 1, 2018 

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SC&A concludes that the bioassay dataset for CTW subcontractors, specifically, 

and CTWs, generally, is demonstrably incomplete for 1989–1998 (and likely 

before that time period) and does not satisfy the criteria set forth in NIOSH’s 

Draft Criteria for the Evaluation and Use of Coworker Datasets (NIOSH 2015). 

SC&A recommends that the Work Group discuss the implications of these 

findings with NIOSH and determine whether NIOSH has any available 

monitoring data or bounding approach that could ameliorate this fundamental 

data gap. [Emphasis added.] [SC&A 2017, p. 22] 

Neither this conclusion and recommendation nor our statements before the Board assert that dose 

reconstruction would somehow be “prohibited” by the monitoring gaps cited in the NOV. 

However, as with any monitoring and record gaps identified under the Energy Employees 

Occupational Illness Compensation Program Act, there is a need to conduct additional research 

to augment available data, review the validity of existing coworker models, and to investigate 

options for bridging the identified data gaps (e.g., determining bounding dose values based on 

exposure potential for representative work activities). All of this has been underway and is 

advancing to a new phase of reviewing the 852 newly found boxes of RWP records at the 

Atlanta Federal Records Center.

NIOSH Conclusion 

NIOSH agrees with SC&A that some workers did not provide job-specific 

bioassay samples but does not agree with their conclusion that the existing 

bioassay data do not meet the NIOSH requirements for coworker analysis. 

[NOISH 2018, p. 3] 

While NIOSH and SC&A apparently agree that a gap exists in job-specific bioassays, it should 

be clarified that “some” should not be taken as a “few” workers. Workers on RWP- and SRWPrequired job-specific bioassays in the 1989–1998 timeframe represent a cohort numbering at 

least in the hundreds, if not thousands of total workers during that time period. 

As noted in SC&A’s 2017 report: 

With almost 80% of bioassays not submitted by the operating contractor’s own 

assessment, it is not feasible to know what exposure potential existed and internal 

dose resulted for CTWs performing specific radiological jobs at SRS before 

effective corrective actions were compelled in 1998 by enforcement action. As 

these were job-specific and RWP-prescribed, these jobs would have involved a

potential for potential intake of tritium, plutonium, uranium, neptunium, mixed 

FPs, and other significant SRS source terms. While an argument can be made that 

the longer-lived radionuclides would have been detected in later in vivo or in 

vitro bioassays, this does not consider that, for CTWs, their intermittent work at 

the site may have precluded such later assessments. [SC&A 2017, p. 22]

While the 256 CTWs lacking job-specific bioassays in 1997 were resampled and found to have 

no positive intakes, no earlier CTWs in the same circumstances were resampled for prior years 
Memo – Subcontractor Bioassay Data Completeness 10 SC&A – May 1, 2018 

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despite evidence of persistent nonparticipation as far back as 1995 (and likely before). Therefore, 

more than “some” CTWs are implicated before 1997 in terms of potentially lacking job-specific 

bioassays. Essentially, a whole cohort of workers numbering, at least, in the hundreds per year 

(i.e., those performing work prescribed by RWPs or SWPs, necessitating job-specific bioassays) 

have not been adequately characterized in terms of worker identity, nature of work, exposure 

potential, and bioassay completeness. 

To satisfy NIOSH’s requirements for coworker analysis, it would seem imperative to 

demonstrate that sufficient information exists to address these factors and to demonstrate that 

available monitoring data (e.g., for CTWs, overall) can be used to bound the internal doses for 

this particular cohort. One option that has been proposed by NIOSH since the SC&A report was 

issued would use NOCTS data for subcontractor CTWs prior to 1989. The issue for that option is 

whether the NOCTS dose distribution for CTWs is representative of subcontractor CTWs, many 

of whom are transient workers under RWP job-specific bioassays. While this and other proposals 

have been made, sufficient questions remain about representativeness and stratification of 

coworker CTWs to seemingly preclude a conclusion about feasibility of a coworker model at this 

point. 

NIOSH most recently has discovered 852 boxes of RWPs for SRS that encompass the years of 

interest (1972–1996). Given the paucity of RWPs identified for SRS to date, these records offer a 

means to conduct sampling for bioassay completeness and to characterize the subcontractor 

CTW cohort for the years in question. The context for all these inquiries is to address a clear 

monitoring data gap for those workers (particularly transient subcontractor CTWs) on jobspecific bioassays. Once data adequacy and completeness are demonstrated, coworker model 

development can proceed on a sound basis consistent with established guidelines. 

References

ABRWH 2016a. Transcript: Teleconference Meeting of the Advisory Board on Radiation and 

Worker Health, Savannah River Site Work Group. September 26, 2016. 

ABRWH 2016b. Transcript: 114th Meeting of the Advisory Board on Radiation and Worker 

Health, Santa Fe, NM, November 30, 2016. 

DOE 1998a. Department of Energy, Preliminary Notice of Violation and Proposed Imposition of 

Civil Penalty - $75,000 (NTS-SR—WSRC-ESH-1997-0001), letter from Peter N. Brush, Acting 

Assistant Secretary for Environment, Safety and Health, to Mr. Ambrose L. Schwallie, Manager, 

Westinghouse Savannah River Company, September 21, 1998. [SRDB Ref. ID 167497] 

DOE 1998b. Department of Energy Noncompliance Report, Main Information, NTS-SR-WSRCESH-1997-0001, Enforcement Conference Summary, Bioassay Program Deficiencies, viewed on 

the Noncompliance Tracking System on September 22, 2017. 
Memo – Subcontractor Bioassay Data Completeness 11 SC&A – May 1, 2018

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

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