Evaluation of 

Savannah River Site

Subcontractor Bioassay Data Completeness 

Joe Fitzgerald, SC&A 

Advisory Board on Radiation and Worker Health

Santa Fe, NM 

August 23–24, 2017
Work Group Members

 Bradley P. Clawson, Chair

 James E. Lockey, MD, MS

 David B. Richardson, PhD

 Phillip Schofield
Background

 SC&A tasked in Sept. 2016 to conduct broad-based sampling 

review of bioassay data completeness at SRS for subcontractor 

trade workers (CTWs).

 Adequacy and completeness of such databases are a 

cornerstone of dose reconstruction, particularly where 

coworker models are necessary.

 Question arose from interview with SRS employee, who 

indicated subcontractor records were maintained separately 

before they were merged into current SRS electronic database.
Approach

 Identified available Radiation Work Permits (RWPs) for 

subcontractor CTWs as means to determine if corresponding jobspecific bioassay results can be located in SRS records

 Broad scope – survey across variety of facilities, operations, and 

timeframes (1972–1995)

 RWPs identified for 1982–1995, with majority of records for 1989–

1995 (corresponds with Westinghouse’s early tenure as operating 

contractor)

 Onsite matching of 306 identified subcontractor CTWs with SRS 

bioassay records: electronic, fiche, hardfile

 Bioassay matching using 30- and 90-day “grace” periods following 

RWP job date
Subcontractor CTWs

 Electricians

 Pipefitters

 Painters

 Construction workers

 Laborers

 Riggers

 Millwrights

 Carpenters

 Sheetmetal workers

 Boilermakers
Survey Experience

 RWPs found to be scarce and lacking uniformity; only 13 

permits identified through searches for 1972–1995.

 Some RWPs, e.g., signup sheets, lacked explicit bioassay 

checkoffs; others did not clearly identify radiological hazard. 

 Subcontractors identifiable by payroll code, company name.

 For 243 subcontractors that had bioassay results within 90 

days, target radionuclides: tritium (75%), Pu (20%), other (5%).
Results: Completeness of Records

 Missing records: 5/324 (1.5% missing)

 Total RWPs

 30 days: 105/306 for 66% completeness (34% missing)

 90 days: 62/306 for 80% completeness (20% missing)

 RWPs with explicit bioassay requirement

 30 days: 57/197 for 71% completeness (29% missing)

 90 days: 31/197 for 84% completeness (16% missing)
1998 Notice of Violation (NOV)

 WSRC cited under 10 CFR 820 for “deficient work processes 

with respect to full worker adherence to established WSRC 

bioassay requirements.” (Action under 10 CFR 835 deferred.)

 WSRC self-surveys found worker non-participation in job- specific bioassays:

 1995: 67% non-participation (limited sample)

 1997: 79% non-participation (all workers in 2nd quarter)

 Corrective actions: worker tracking/logging, procedure 

rewrites, training, uniform RWP forms – completed Dec. 1998. 

(Resampling of 1997 missing CTWs showed no measurable 

intakes.)

 Has important implications for CTW bioassay completion 

question; NIOSH conducting further investigation.
Conclusions

 SC&A concludes bioassay dataset for subcontractor CTWs is 

demonstrably incomplete for 1989–1995 based on 16–34% 

missing results, as well as NOV findings of CTW nonparticipation in 1998. (NIOSH is determining whether nonparticipation equates to missing data for 1995–1998.)

 However, NIOSH has indicated that this range of 

incompleteness may be acceptable based on other 

considerations – ultimately, how “complete is complete” 

judgment needed.