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Response to SC&A’s Evaluation of 

Savannah River Site Subcontractor

Bioassay Data Completeness, SCA-TR2017-SEC009-SCA 

Response Paper

National Institute for Occupational 

Safety and Health

January 30, 2018

Mike Mahathy and Roger Halsey

Oak Ridge Associated Universities Team

Reviewed by Timothy Taulbee 

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 2 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

EXECUTIVE SUMMARY

Sanford Cohen & Associates (SC&A) was tasked by the Advisory Board on Radiation and 

Worker Health to conduct a review of bioassay data completeness for Construction Trade 

Workers (CTW) at the Savannah River Site (SRS), resulting in the report Evaluation of 

Savannah River Site Subcontractor Bioassay Data Completeness (Fitzgerald, 2017). In their 

report, 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.

This response to the report includes an analysis by National Institute for Occupational Safety and 

Health (NIOSH) of bioassay data completeness using workers identified by SC&A and a critique 

of the methods used by SC&A with three specific issues.

Using workers from select Radiation Work Permits (RWPs), SC&A ascertained whether their 

bioassay results were within 30-day and 90-day windows after the date the worker signed onto 

the RWP. NIOSH examined tritium workers and non-tritium workers separately and calculated 

the number of days between work and the next bioassay sample. While agreeing with the 30- 

and 90-day evaluation points for tritium workers, NIOSH considers any plutonium, uranium or 

fission products result obtained within one year of work to represent a valid internal monitoring 

interval. NIOSH also examined RWPs identified by SC&A as having workers lacking bioassay 

results for other workers doing the same tasks and found 100% of tritium and non-tritium 

subcontractor CTW workers were covered either by their own bioassay results or by coworker 

results.

NIOSH Issue 1: Bioassay data should have been separated into tritium and non-tritium and 

appropriate time intervals used for evaluation.

Some of the workers identified by SC&A to have missing bioassay results were identified from 

Standing RWPs (SRWPs) which were in place for up to a year at a time; included tens to 

hundreds of workers, most with routine bioassay results; and were typically created for entry into 

controlled areas that did not include airborne or contamination areas. 

NIOSH Issue 2: Some SRWPs should have been excluded from analysis. 

The SRS bioassay program included pre-scheduled routine sampling, special sampling for cause, 

and job-specific sampling for those workers whose routine bioassay types did not satisfy 

requirements listed on RWPs. In a 1997 Notice of Violation (NOV) the Department of Energy 

(DOE) cited SRS for failures in the job-specific bioassay program, specifically that workers did

not always provide requested samples and that the issue had been identified previously without 

satisfactory corrections. SC&A presented this NOV as evidence of “a chronic history of wide 

non-compliance with job-specific bioassay requirements.”
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 3 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Data from the first four months of 1997 that were reported to DOE, resulting in the NOV, 

indicated a participation rate for all bioassay samples of greater than 96%. All workers who did 

not provide samples in 1997 were sampled in 1998 with no identified uptakes. 

Bioassay sampling was required by DOE under 10 C.F.R. 835 for workers likely to receive an 

internal exposure exceeding 100 millirem CEDE annually. SRS determined that no worker was 

likely to exceed this level in a year but used bioassays to monitor workers who had the potential 

to exceed it. This was to verify the effectiveness of other controls such as procedures, 

engineered controls, surveys, protective clothing, respirators, job surveillance, and air 

monitoring. SRS data for 1996 through mid-1998 indicated fewer than 0.1% of the samples 

indicated a measurable uptake. DOE did not find failures of worker protection under 10 C.F.R. 

835 but instead cited SRS under 10 C.F.R. 820 for procedural issues. 

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 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. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 4 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

INTRODUCTION

SC&A’s Evaluation of Savannah River Site Subcontractor Bioassay Data Completeness

(Fitzgerald, 2017) provides the results of SC&A’s review of the Savannah River Site (SRS) 

bioassay data for subcontractor construction trade workers (subCTW) from 1989 through 1998. 

In its evaluation, SC&A non-randomly selected some RWPs and then selected certain workers 

from those RWPs; thus, neither the RWPs nor the workers were selected randomly. SC&A then 

attempted to identify bioassay results within 30 and 90 days of the RWP sign-in date regardless 

of the radionuclides tested for. SC&A also cited a 1997 Notice of Violation (NOV) relating to 

participation in the SRS bioassay program. SC&A came to a number of conclusions leading to 

the following statement in the Executive Summary: 

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. (Fitzgerald, 2017)

In this response paper, NIOSH presents its concerns of an analysis of the data used by SC&A in

its review. NIOSH also discusses the factors associated with issuance of the 1997 NOV and SRS

follow-up actions taken in response. NIOSH also provides the results of its own evaluation of 

bioassay data completeness for a different time period and discusses them vis a vis SC&A 

results/conclusions.

SUMMARY OF BIOASSAY SAMPLE TYPES

SRS implemented bioassay programs to cover 35 facilities that processed actinides, fission

products, and tritium (Thomas, 1993). During the time period covered in SC&A’s evaluation 

(1989-1998), SRS performed urine sampling for radioactive material using both routine and 

special sampling. Workers with “reasonable potential” for internal exposure were included in 

the routine bioassay program. The special bioassay program was designed for assessing

“inadvertent intakes” of radioactive material that could exceed the 100 mrem threshold (LaBone, 

2001a). 

Routine Sampling Program

SRS designed the routine sampling program to assess the adequacy of facility controls and

personnel protective measures. DOE orders in place during this period (5480.11 and later 10 

C.F.R. 835) indicated that facilities should, where feasible, be designed and operated with

engineered controls that would prevent worker intakes of radioactive materials.

The routine bioassay program had two parts, prescheduled sampling and job-specific sampling. 

The program was used in facilities where workers had a reasonable potential for exposure to 

radioactive materials (Westinghouse SRC, 1990). 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 5 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

During the period under SC&A evaluation (1989-1998), a worker’s enrollment in the routine 

bioassay program was based not only on the radioactive hazards associated with the facility 

where the individual worked, but also the type of work the worker normally performed. SRS 

considered a worker who routinely performed tasks requiring respiratory protection to be at 

greater risk of involvement in an incident resulting in an intake than, for instance, a manager who 

occasionally performed a cursory walk-through of a facility. Therefore, for the purposes of the 

bioassay program, SRS defined three categories of workers that were in effect until the 

implementation of 10 C.F.R. 835: 

• Category I: Hands-on workers with the highest intake potential. They routinely work in

Contamination or High Contamination Areas and are required to wear respiratory

protection. For these employee, the routine program typically requires quarterly urine

samples and an annual chest count.

• Category II: Supervisors, engineers, or operators who do not perform hands-on work, but

who routinely enter Radiologically Controlled Areas (RCAs) to observe work or record

data. They are typically required to submit an annual urine sample but do not receive

annual chest counts.

• Category III: Other people working on site who occasionally enter RCAs but only do so

to observe work. These employees are at little to no risk of receiving an intake. They are

not required to submit routine urine samples, nor do they receive annual chest counts

(Actinide Basis, 1993).

With the implementation of 10 C.F.R. 835, SRS defined the three categories of workers for 

actinide bioassay as:

• Those “likely” to exceed 100 mrem CEDE1

1 NOTE: To formalize the definition of who may fit this criterion, SRS performed a statistical study of bioassay data 

for the years 1999 and 2000 to test the process of judging a worker’s likelihood of exceeding 100 mrem from 

intakes of radioactive materials (LaBone, 2001a). 

• Those with “reasonable potential” to exceed 100 mrem CEDE

• Those with “no potential” to exceed 100 mrem CEDE

While useful to confirm the adequacy of workplace monitoring and worker protection programs, 

routine sampling was not required at SRS during the 1990s, either by order or by the regulations 

in place during the period of SC&A’s review. No worker at SRS was considered likely to 

exceed 100 millirem CEDE (Findley, 1998, PDF p. 6). 

For the tritium bioassay program, workers were placed on the routine program when they 

routinely entered RCAs with the potential for tritium contamination or airborne tritium activity 

(Tritium Basis, 1993).
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 6 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

For both actinide and tritium bioassay, prescheduled sampling was used to sample workers who

routinely worked in locations with Airborne Radioactivity Area postings. Samples were 

generally scheduled annually or semi-annually based on a worker’s date of birth or other 

recurring event. A large majority of routine bioassay samples were collected with prescheduled 

sampling. Data reported in the NOV showed that the greatest majority of routine bioassay (e.g., 

95% during the first four months of 1997) was requested through prescheduled sampling. 

Job-specific sampling was used to sample workers not on prescheduled sampling but who 

needed to enter locations requiring respiratory protection. Like prescheduled sampling, 

job-specific sampling was used to assess the adequacy of facility controls and personnel 

protective measures. A definition of the job-specific sampling from September 1997 described it 

as follows: 

Job-specific urine sampling is also known as “RWP (Radiation Work Permit) sampling” and 

is administered exclusively by radiological control personnel. RWPs are written to describe 

a specific scope of work to be performed. Additional information such as the expected 

radiological hazards to be encountered, respiratory protection if needed, and dosimetry 

requirements are listed on the RWP. Based on the degree and nature of the radiological 

hazards it may be necessary to request each worker performing “hands on” work to leave a 

urine bioassay sample, hence the term “job-specific sampling.” If a worker is wearing 

respiratory protection and is not on an appropriate routine sampling program then a jobspecific sample should be requested. (Findley, 1997) 

Job-specific sampling was not performed to measure a suspected intake. At SRS, dose was not 

assigned from job-specific bioassay sampling results. However, results of prescheduled and 

job-specific bioassays could flag a worker for special bioassay sampling. 

Samples collected from routine sampling for uranium, actinides, and fission products were 

generally collected over 24 hours, although some were collected as 8-hour samples. Tritium

samples were generally spot samples even when prescheduled. 

Special Bioassay Program

SRS designed the Special Bioassay program to assess “inadvertent intakes” of radioactive 

material that could exceed the 100 mrem threshold (LaBone, 2001a). Under this program, 

samples were required in response to unusual or unanticipated circumstances. For example, a 

sample was required whenever a worker was suspected of receiving an intake that would result 

in a CEDE of 100 mrem or greater (LaBone, 2001b, PDF p. 2). Intakes of radionuclides were 

assigned when positive results of special bioassay sampling were confirmed. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness

January 30, 2018

Page 7 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

REVIEW OF RADIATION WORK PERMIT WORKER BIOASSAY

To respond to SC&A comments, NIOSH used workers identified in radiation RWP data, RWP 

sign-in sheet data, and bioassay results captured by SC&A in December 2016 and February 

2017. NIOSH only considered data for the period January 1, 1989 through December 31, 1995. 

While SC&A only reported data for subCTW in their report, NIOSH considered all workers 

identified by SC&A in the RWP and sign-in sheets.

In their analysis, SC&A did not specifically break out work by area or type. NIOSH separated 

workers by tritium work and non-tritium work. Work with exposure to tritium was performed at 

SRS reactors and tritium processing areas. Non-tritium work was performed in the F and H 

canyons, M Area, Building 773-A, and at SRS reactors. For non-tritium work, NIOSH considers 

plutonium to be the radionuclide of interest for the F and H canyons and Building 773, and 

enriched uranium the radionuclide of interest for M Area.

NIOSH reviewed bioassay data available for each worker and determined the first bioassay 

sampling event after the work date. Rather than segregating results within 30- and 90-day 

periods, NIOSH calculated the number of days between work and sampling for each. SC&A 

used 30 days and 90 days as evaluation points for all bioassay radionuclides. However, by 

procedure, some SRS workers would have been sampled for plutonium either twice per year or 

once each year depending on work location, while workers routinely sampled for fission 

products would have been sampled once each year. NIOSH considers any plutonium, uranium 

or fission products result obtained within one year of work to represent a valid internal 

monitoring interval. NIOSH agrees with the use of 30- and 90-day evaluation points for tritium.

Results of SC&A’s analysis of subCTW bioassay are summarized in Table 1.

Table 1. Summary of SC&A Analyzed Bioassay Result. 

Criteria % Workers with 

Bioassay Results

All RWP, bioassay within 30 days 66

All RWP, bioassay within 90 days 80

RWP specifically indicated bioassay, bioassay within 30 days 71

RWP specifically indicated bioassay, bioassay within 90 days 84

SC&A stated in the conclusion of their report: 

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). 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 8 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Figure 1 shows the actual job-specific bioassay process (Morgan, 1998), as determined in a rootcause analysis in response to the 1997 Notice of Violation (discussed in detail below). The 

SC&A report jumps from the point where a worker signs in on an RWP at the beginning of the 

process (Box 1) to the end of the process (Box 2) to determine if the worker has a sample 30 or 

90 days after the RWP. If the contractor was not scheduled to leave a sample for 100 days, there 

would not have been a sample. 

Figure 1. SC&A Path Through the Actual Job-specific Bioassay Process

Tritium Workers

Using the SC&A set of data, tritium workers were selected from RWPs covering the period from 

1989 to 1991, and 1994 to 1995. NIOSH identified 130 subCTW workers; bioassay was not 

required from two of them. Bioassay results were identified for 124 of the 128 subCTW for 

which bioassay was required. Table 2 provides summary statistics for these workers; 

Attachment A provides details for individual workers. The mean number of days from the end 

of the daily job to the receipt of a tritium bioassay sample was 7.0 days for subCTW. No sample 

was submitted later than 70 days following the RWP job. An intake of 1500 pCi of tritium, in 

the form of HTO, yields a dose of 100 mrem. Such an intake can be detected in urine to about 

day 75 with a detection limit of 5x105 pCi (0.5 μCi)/day. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 9 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Table 2. Summary of Tritium Workers with Tritium Bioassay. 

Criteria Result

Number of subCTW 130

Number of subCTW on RWP requiring bioassay 128

Number of subCTW with H3 bioassay 124

Percentage of subCTW with data 96.9 

Mean days subCTW 7.0a

Number of subCTW on routine H3 bioassay 111

Percentage of subCTW on routine H3 bioassay 89.5 

Percentage of subCTW covered by personal or worker 100.0

a. Routine frequency for tritium determined by checking for tritium bioassay

every 30 days.

Many SRS RWPs during the period of evaluation were standing permits and remained open for 

several weeks to a full year. Generally, tens to hundreds of workers signed in to such standing 

RWPs. For example, at least 25 workers, 17 of them subCTW, signed into RWP K89S-001 from 

September 18, 1989 to December 1, 1989. Two of the four subCTW without bioassay worked 

under SRWP 89S-001 (Figure 3) which did not permit entry into posted areas of Radiation 

Control Areas (RCA) nor require bioassay. More information on this SRWP are given in 

Attachment C.

Bioassay results are available to NIOSH from coworkers working on the same job for the four 

subCTW without personal bioassay results; this translates to 100% coverage by personal or 

direct coworker bioassay. Three other subCTWs were identified without personal tritium 

bioassay. While NIOSH has not reviewed the work conditions of the RWPs those subCTW 

worked in, ORAUT identified coworkers with tritium bioassay using data captured by SC&A 

(undated). 

Table 3. Coworkers with Tritium Bioassay. 

Worker No. Job Date RWP Worker No. of Coworker

85 1/29/1990 90K-146 84

270 5/4/1995 95L-001a 240

261 9/7/1995 95C-005b 260

262 9/7/1995 95C-005b 260

a. SRS 1995a.

b. SRS 1995b.

NIOSH assumes that other workers with no results did not leave samples. Workers not leaving a 

sample occurred randomly; there is no pattern or order in missed results.

Routine urine bioassay and workplace monitoring were two parts of the complementary program 

for monitoring tritium exposure (Tritium Basis, 1993). Workplace monitoring was the primary 

method of control for all other radionuclides. Tritium bioassay was based on routine 

retrospective sampling with a frequency of one sample per month for a worker or workgroup in 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 10 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

which at least ten percent of members were sampled to represent exposures to all group members 

(Tritium Basis, 1993; Westinghouse SRC, 1990). While SC&A and NIOSH evaluated whether 

identified workers were sampled as the result of a particular job, workers were generally sampled 

frequently over the course of a year. While a few workers were not sampled, and others may 

have missed some samples, there is no impact on the use of tritium bioassay data for coworker 

analysis given the large number of samples taken and the randomness of missed samples.

In 1989, SRS reported over 125,000 tritium results; in 1990, almost 176,000. Through July 

1993, there were 62,788 samples. About 36% of those gave positive results. The average tritium 

dose was 0.05 mrem; the largest individual worker tritium dose through July 1993 was 32 mrem 

(Tritium Basis, 1993). In the 1993 tritium technical basis document, SRS reported that the last 

assimilation exceeding 100 mrem occurred in 1988. Since 1972, the 95th percentile subCTW

tritium dose has been less than 100 mrem with a downward trend, as shown in Figure 2. Since 

1980, the DuPont CTWs 95th percentile dose has been less than 100 mrem, again with a 

downward trend. Tritium monitoring of subcontractors is not a dose reconstruction problem at 

SRS.

Figure 2. SRS Tritium Dose, 95th Percentiles

Table A-1 provides the results of NIOSH’s evaluation of tritium bioassay for tritium workers. 

Using the available data and coworker intake models, NIOSH can reconstruct tritium intakes for 

subCTWs with sufficient accuracy as the 95th percentile dose is less than 100 mrem.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Non-tritium Workers

Using the SC&A set of data, non-tritium workers were selected from RWPs covering the period 

from 1992 to 1994. SC&A reported 62 non-tritium bioassay results. NIOSH identified more 

results due to looking beyond 90 days. NIOSH identified 107 subCTW workers; bioassay was 

not required from five of those 107 by the RWP. Bioassay results were identified for 99 of the 

102 subCTW for which bioassay was required. SRS plutonium monitoring required each worker 

in the workgroup to have one urine bioassay and one chest count annually. In addition, SRS 

required each member of a workgroup to leave a sample if any member of the workgroup 

received a confirmed plutonium intake (Westinghouse SRC, 1990). Table 4 shows summary 

statistics for these workers; Attachment B provides the details. The mean number of days from 

the end of the daily job to receipt of a bioassay sample is 150.1 days for subCTW, which was 

beyond the 90-day limit used by SC&A, but well within the semiannual and annual sampling 

frequencies given by SRS (Westinghouse SRC, 1990, PDF p. 234).

Table 4. Summary of Non-Tritium Workers with Plutonium Bioassay. 

Criteria Result

Number of subCTW 107 

Number of subCTW on RWP requiring bioassay 104 

Number of subCTW with bioassay 99 

Percentage of subCTW with data 95.1 

Mean days subCTW 150.1

Number of subCTW on routine bioassay 93

Percentage of subCTW on routine bioassay 89.4 

Percentage of subCTW covered by personal or worker 100.0

NIOSH found bioassay data obtained from coworkers for all five subCTW without bioassay 

results. Coworkers were identified from the same RWPs on the same day or performing the 

same task in the same location. Non-tritium bioassay results were found for two of the five 

subCTW but the samples were collected about three years after the 1994 working date. Specifics 

of the radiation work permits and the subcontractor construction trade workers and coworkers 

are presented in Attachment C, Table C-1 occurring in 1992, and Table C-2 occurring in 1994. 

Two of the coworkers identified on the RPW sheets are not in the SC&A data set. Bioassay 

results for those two workers were verified in the SRS Health Protection Radiation Exposure 

Database (HPRED). 

While this report identifies some workers without bioassay, it also demonstrates the availability 

of bioassay data from coworkers performing similar tasks in the radiological environment on the 

same job. Using available data and coworker intake models, NIOSH can reconstruct plutonium 

intakes for subCTW with sufficient accuracy.

Table 5 provides total bioassays by year for all subCTW, which includes tritium and actinide 

monitoring. NIOSH found 95.6% of all subCTW were directly monitored for intakes of 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

radionuclides, and 88.7% of those workers were on routine urine bioassay as recorded by SRS 

bioassay data reported for the individuals. One hundred (100%) of all evaluated subcontractor 

workers were either directly monitored or worked with one or more coworkers who were directly 

monitored. 

Table 5. Summary of Subcontractor Bioassay. 

Year

No. of 

subCTW

where 

Bioassay 

Required

No. with 

Bioassay Data

No. with 

Monitored 

Coworker

Total Monitored 

or with Coworker 

Monitor

No. on Routine 

Bioassay

1989 17 17 N/Aa 17 15 

1990 64 63 1 64 61

1991 11 11 N/A 11 10

1992 63 60 3 63 57 

1993 12 12 0 12 10

1994 49 46 3 49 42

1995 16 13 3 16 11

Total

(All Years) 232 222 10 232 206

a. N/A = Not applicable.

While NIOSH agrees that the use of 30- and 90-day criteria are appropriate for tritium bioassay, 

annual monitoring was usually the requirement for non-tritium (actinide samples); thus, SC&A 

excluded a significant number of monitored subcontractors from their analysis and indicated they 

were not monitored when, in fact, they were monitored. 

NIOSH Issue 1: Bioassay data should have been separated into tritium and non-tritium and 

appropriate time intervals used for evaluation. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 13 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Standing Radiation Work Permit 

Some of the workers selected by SC&A for analysis performed tasks under a Standing (longterm) Radiation Work Permit (Fitzgerald, 2017). SRWPs were issued to cover routine work, 

tours, observations, inspections, housekeeping, walkthroughs, supervisory duties, and general 

work not involving line breaks, welding or cutting, venting, grinding, drilling, or burning. These 

permits prescribed general work requirements and worker protection. Figure 3 shows a redacted 

example of such a permit, SRWP# K-89S-001, for work performed at K Reactor area. Although 

some workers listed on an SRWP may have been on the routine bioassay program, work 

instances on an SWRP should have not have been included in the evaluation. The SWRP clearly 

states that workers were not to enter Airborne Radioactivity Areas or Contamination Areas. 

Thus, there was no potential for internal exposure. 

Figure 3. Example of an SRS Standing Radiation Work Permit

NIOSH Issue 2: Some Standing RWPs (SRWPs) should have been excluded from analysis.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 14 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

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information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NOTICE OF VIOLATION OF MISSED JOB-SPECIFIC BIOASSAY SAMPLES

In their review, SC&A stated that a “chronic history of wide noncompliance with job-specific 

bioassay requirements existed at SRS, resulting in a Departmental Notice of Violation being 

levied in 1998.” They indicate that this primarily effects subcontractors.

The NOV was applied as a result of worker non-participation in the job-specific bioassay 

program. As shown above, the job-specific bioassay program consisted of SRS and 

subcontracted CTWs as well as SRS operations workers. The non-participation appears random 

from a review of names identified on the RWPs and bioassay results held by NIOSH. A majority

of CTWs were on the routine bioassay program, which was not part of the NOV and, as shown 

below, had full compliance and participation. The job-specific bioassay program formed a 

portion of the overall bioassay program and was part of a “Defense in Depth” strategy. 

In a May 1997 self-assessment, SRS found that while all workers were complying with the 

routine bioassay program, many were not following through by providing job-specific bioassay 

samples. SRS determined that the issue of worker non-participation in the job-specific bioassay 

program was a potential noncompliance with the Price-Anderson Amendments Act. This was 

reported into the Noncompliance Tracking System (NTS) on December 10, 1997, with a 

Corrective Action Report issued on December 8th, followed by a formal root cause 

determination completed in January 1998. An off-normal occurrence was entered into DOE’s 

Occurrence Reporting and Processing System (ORPS) on December 18, 1997 (DOE ORPS, 

1998). 

On September 21, 1998, the Department of Energy (DOE) issued a preliminary NOV (NTS-SRSRS-ESH-1997-0001) to Westinghouse Savannah River Company. The NOV was for a 

violation of 10 C.F.R. 830 and was titled “Inadequate Bioassay Program Participation” (Brush, 

1998). The NOV text described several issues related to workers following through with 

required job-specific bioassays, specifically that work was not performed in accordance with 

Procedure 5Q1.1-504, RWP, in that: 

...from January 1, 1996, to September 30, 1997, procedural requirements were not adhered 

to in that: (1) workers signed-in on RWPs without adhering to RWP requirements for 

bioassay ( i.e., workers failed to submit bioassay samples as required); (2) site management 

did not hold workers and the work group supervisors accountable for worker submission of 

RWP required bioassay samples; (3) the names and social security numbers of workers 

required to submit RWP, job-specific bioassay samples were not documented and the 

Bioassay Customer representative was not notified for purposes of sample tracking; and (4) 

bioassay requirements were not always identified on RWPs as required.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

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information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

The NOV stated that work was not being performed in accordance with Procedure 5Q1.1-506, In 

Vivo and In Vitro Bioassay Scheduling and Administration, in that:

...between January 1, 1996, and September 20, 1997, SRS Facility Evaluation Board reports 

identified that (1) workers were on incorrect bioassay programs, as identified by their RQB 

and consequently did not submit job-specific bioassay samples as required; (2) line 

management did not always ensure that new employees were placed on the correct bioassay 

schedule, the Bioassay Schedule Report was not always provided to line management for 

accuracy review, and job-specific bioassay sampling requirements were not always identified 

on RWPs; and (3) bioassay assignments were not always reviewed when personnel received 

an annual whole body count. 

This violation was cited as a Severity Level II problem. DOE fined SRS a civil penalty of 

$37,500 for failing to meet 10 C.F.R. 830.120(c)(2)(i), Work Processes (Findley 1998). 

Item 1 above described a disconnect between the information in the database used by the 

analytical laboratory to perform routine bioassay samples, HPRED, and the information on their 

radiation qualification badges (RQB), which were used to trigger job-specific bioassays. The 

site had found that, for a few workers, the information on their RQB did not match the 

information in HPRED. Figure 4 shows an RQB from 1994 with the bioassay code “PU-02 EU02 SR-01” indicating a routine bioassay for plutonium on a two-year schedule, enriched uranium 

on a two-year schedule, and strontium on a yearly schedule. 

On February 19, 1998, SRS sent 4000 form letters to every site employee and subcontractor 

currently on a routine bioassay program asking them to compare the bioassay codes on their 

RQB and those listed in the letter. Less than 100 discrepancies were identified (< 2.5%) 

(Morgan, 1998, PDF p. 49). 

Figure 4. Generic Example of a 1994 Radiation Qualification Badge
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

During one assessment in 1995, SRS determined that 23% of the workers evaluated had not 

provided samples as requested under the job-specific bioassay program (Brush, 1998). The 

NOV also stated: 

Contrary to the above, processes to detect and prevent quality problems were not adequately 

established and implemented and corrective actions did not prevent recurrence in that in 

November 1995, DOE identified to SRS that radiation work permit-prescribed bioassay 

sampling requirements were not effectively implemented in that 23 percent of workers did not 

submit bioassay samples as required. Corrective actions were implemented by SRS. 

However, the corrective actions were not effective to prevent recurrence in that nonparticipation by radiation workers in the job-specific portion of the bioassay program 

continued through 1996 and increased to a level of non-participation of 79 percent by the 

second quarter of 1997. 

This was also a Severity Level II problem and DOE fined SRS an additional $37,000 for failing 

to meet 10 C.F.R. 830.120(c)(1)(iii), Quality Improvement (Findley, 1998). 

A May 1997 self-assessment found that, out of a total 3,200 samples requested during first four 

months of 1997, 107 bioassay samples were not provided by workers (DOE ORPS, 1998, PDF p. 

3). Of the 3,200 samples requested, 5% were for job-specific requirements, as required on the 

job’s RWP; the remainder were routine bioassay samples. Participation for routine samples was 

found to be 100%. The 107 missing samples were all requested for job-specific requirements 

and indicated a 66% non-participation rate for job-specific bioassay samples or approximately 

3% of all bioassay samples. The overall participation rate for the first four months of 1997 was 

approximately 97%. 

A follow-up assessment in September 1997 found non-participation for job-specific samples to 

be at about 79% for the second quarter of 1997. After a series of actions, including management 

briefings, a review of the bioassay samples requested in October found only 14% to be 

outstanding as of December 8, 1997, and those were “being actively tracked.” The site identified 

256 workers who did not supply samples as requested in 1997, all under the job-specific

program. All of these workers provided samples in 1998 and none were identified to have any 

uptakes. 

In ORAUT-RPRT-0083, NIOSH reported that 68% of the subCTW evaluated for that report 

were directly monitored by bioassay, and that 92% of the evaluated subCTW have either direct 

monitoring data or a coworker on the same RWP who was directly monitored by bioassay. 

Figure 5 shows percentages of bioassay participation reported by NIOSH for the 1980s, and 

SC&A and SRS in the 1990s. In the histogram, the data for the years between 1981 and 1986 

are taken from ORAUT-RPRT-0083. The data for the years 1989 through 1995 are from 

SC&A’s report. The data for 1996 and 1997 reflect the percentage of participation in the JobSpecific bioassay program, as reported by SRS in their response to the NOV.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Figure 5. Percentage of Identified Subcontractors with Monitoring Data

On July 28, 1998, after communicating the issues to DOE (but prior to any enforcement actions), 

SRS management and staff conferred with DOE to discuss the identified issues. The NOV was 

not a violation of 10 C.F.R. 835. If workers had not been monitored properly for radiation 

exposure, the site would have been in violation of 10 C.F.R. 835.401(a)(1) Monitoring of the 

Workplace and/or 10 C.F.R.835.402(c)(1) Individual Monitoring.

Requirements for 10 C.F.R. 835.401(a)(1) Monitoring of the Workplace were stated as: 

(a) Monitoring of individuals and areas shall be performed to:

(1) Demonstrate compliance with the regulations in this part;

(2) Document radiological conditions in the workplace;

(3) Detect changes in radiological conditions;

(4) Detect the gradual buildup of radioactive material in the workplace;

(5) Verify the effectiveness of engineering and process controls in containing radioactive

material and reducing radiation exposure.

(b) Area monitoring in the workplace shall be routinely performed, as necessary, to identify

and control potential sources of personnel exposure to radiation and/or radioactive

material.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

The requirements under 10 C.F.R. 835.402(c)(1) Individual Monitoring were:

(c) For the purpose of monitoring individual exposures to internal radiation, internal dose

evaluation programs (including routine bioassay programs) shall be conducted for:

(1) Radiological workers who, under typical conditions, are likely to receive 0.1 rem

(0.001 Sievert) or more committed effective dose equivalent, and/or 5 rems (0.05 Sievert)

or more committed dose equivalent to any organ or tissue, from all occupational

radionuclide intakes in a year.

The contemporary DOE Standard, Guide of Good Practices for Occupational Radiological 

Protection in Plutonium Facilities, DOE-STD-1128-98 (DOE Standard, 1998, PDF pp. 149-150) 

states:

Workers who are considered likely to have intakes resulting in excess of 100-mrem CEDE 

are required to participate in a bioassay program. However, because of the extensive 

radiological control practices for plutonium facilities, including a high degree of engineered 

barrier containment, no typical plutonium worker is likely to have intakes of 100-mrem 

CEDE or more. However, this should not be used as an excuse to exclude workers from 

routine bioassay. Although no one should be considered likely to have intakes resulting in 

100-mrem CEDE, some workers are at significantly higher risk for incurring an intake than

others and should be on routine bioassay.

This standard indicates that workers at a higher risk should be on a routine bioassay program. 

The standard was issued in 1998 (DOE Standard, 1998), reaffirmed in May 2003 (DOE 

Standard, 2003), and reaffirmed again with some small changes in February 2005 (DOE 

Standard, 2005). It remains the standard practice for plutonium sites today. 

DOE did not assess any penalties or violation under 10 C.F.R. 835 against the site. No SRS 

workers were considered likely to exceed 0.1 rem. However, SRS included workers in “closest 

contact with radioactive materials in the routine bioassay program, including operators, 

maintenance, and health physics personnel” (DOE Standard, 1998, PDF p. 150). 

In a July 28, 1998 meeting with DOE, SRS stated it had a formal no-intake policy for 

radionuclides, other than tritium. That policy, along with its formalized workplace indicators 

program (including air sampling and contamination surveys) were the primary means of 

determining whether a worker required bioassay sampling outside the routine bioassay program. 

For these cases, special bioassay sampling was performed. The bioassay program was part of an 

overall strategy described as “Defense in Depth” and included the zero-intake policy, engineered 

and procedural controls, personnel protective equipment, and surveillance. This surveillance 

included air monitoring, facility and personnel contamination surveys, and the routine bioassay 

program. The bioassay program was used to verify the effectiveness of the controls in place 

(Labone, 1997). 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

The routine bioassay program was a check of the effectiveness of the controls and was a trigger 

for special or “for-cause” bioassay samples. Routine actinide bioassay samples were requested 

from “workers who have a reasonable potential for intakes but who we are confident did not 

have intakes in excess of 2% of a stochastic annual limit on intake” (Labone, 1997). At the July 

28, 1998 conference with DOE, SRS stated that “the workers themselves were the last line of 

defense in the workplace indicator program, which was the reason why a confirmatory program 

for workers was conducted” (Brush, 1998). 

In their root cause analysis, SRS identified several causes for non-participation in the jobspecific bioassay program. In their Root Cause Analysis Corrective Action Report (Morgan, 

1998), they illustrated the expected existing process and actual process as two flow charts, shown 

below as Figures 6 and 7. 

This figure is a flow chart with two main paths. One path shows the steps expected for workers 

providing a routine bioassay sample. The other path shows steps for a job-specific sample. Both 

have branches leading to a Delinquency Tracking system and all paths terminate at Sample 

Received.

Figure 6. Existing Process, Expected, Attachment 1 to Root Cause Analysis Corrective Action Report
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

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information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

This process for job-specific bioassay samples was described as:

The purpose of the job-specific bioassay sampling program is to collect bioassay samples 

from workers whose routine bioassay program does not include some or all of the 

radionuclides present at the work site or who are not on a routine program. For example, a 

mechanic who may be routinely sampled for plutonium and enriched uranium may be 

assigned to work on a neptunium system. A job-specific bioassay sample for neptunium 

would be required to be submitted at the end of the task. 

The job-specific bioassay requirements are specified by Radiological Control Operations 

(RCO) in the preparation of the Radiological Work Permit/Standing Radiological Work 

Permit (RWP/SRWP). It is the responsibility of the worker to review the RWP/SRWP 

bioassay requirements against their routine bioassay program (shown on their Radiological 

Qualification Badge (RQB)). If a job-specific bioassay is required, RCO is to be notified. 

Except for tritium, RCO issues the employee a yellow (job-specific) bioassay label, tells the 

employee when to submit the sample, and notifies Bioassay to enter the employee on the 

delinquency tracking system. For tritium, the employee uses a white (routine) label instead of 

a yellow label.

When the employee submits the sample, it is logged into the database to clear the record. If 

the employee fails to submit a sample, an escalating series of corrective actions are initiated 

which may result in suspending an employee's qualification to work in radiological areas.

(DOE ORPS, 1998) 

The yellow and white labels were submitted to the laboratory to indicate analyses to be 

performed in addition to the routine analyses listed for the worker in HPRED. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Figure 7. Attachment 2 to Root Cause Analysis Corrective Action Report, Expected 

Process, Actual with Added Text to Illustrate May 1997 Results

The results of the May 1997 self-assessment can be illustrated in this flowchart. It begins with 

the requested 3,200 samples; 95% of these were for routine samples and follow the path to the 

right and 5% follow the path on the left for job-specific samples. All of the requested routine 

samples were received by the analytical laboratory. For the job-specific bioassays, 3.35% or 107 

of the requested samples terminated in the hexagonal node labeled “Sample NOT received.” 

This resulted in 96.65% or 3092 samples received at the laboratory for the first four months of 

1997. 

This limited assessment of 3,200 requested bioassay samples found a 33% compliance rate for 

the job-specific samples. The follow-up assessment in September 1997 found a compliance rate 

of 21% for job-specific bioassay samples. The number of workers who did not provide samples 

in 1997 was 256. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 22 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

SRS procedures held the individual worker responsible for submitting bioassay samples. For 

job-specific samples, they were to be told to provide them at the end of the assignment. SRS did 

not find any willful noncompliance with the program but identified several reasons, including: 

1. Worker did not realize a job-specific sample was required.

2. Worker was transferred before completion of job.

3. Worker thought he was on the correct bioassay program because his RQB indicated the

correct isotopes.

4. Bioassay requirements not clear and consistent in SWRPs/RWPs.

5. RCO (Radiological Control Operations) did not always issue sample labels and notify

Bioassay of sample request.

6. Job-specific bioassay requirements not always adequately emphasized in pre-job briefings

and workers requiring job-specific samples not always identified.

During the enforcement conference, SRS provided a summary of prescheduled routine actinide 

urine bioassay for 1996, 1997, and through mid-1998, as shown in Table 6 (Labone, 1997).

Table 6. Prescheduled Routine Actinide Urine Samples. 

Criteria 1996 Results 1997 Results 1998 Results 

Through Mid-July

Number Requested 8,132 9,389 5,251

Number Received 8,062 9,053 4,864

Percent Received 99.1% 96.4% 92.6%

Number Initially Positive 79 105 82

Number Confirmed Intakes 2 2 0 

Percent Confirmed Intakes 0.025% 0.022% 0%

Approximately 1,500 job-specific routine actinide samples were also collected in 1997, and 564 

samples through the first half of 1998 with no positive results or intakes (see Table 7). The 

number of job-specific actinide samples for 1996 is not available and is not included in the sum 

of samples. For all of 1996, 1997, and through mid-July 1998, there were only four confirmed 

intakes out of approximately 24,800 routine and job-specific actinide urine samples.

Table 7. Job-Specific Actinide Urine Samples. 

Criteria 1997 Results 1998 Results 

Through Mid-July

Number Requested 1,500

(approximately)

564

Number Positive 0 0 

Number Confirmed Intakes 0 0 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

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ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Special actinide samples were collected for cause, that is, only when there was a significant 

potential for an intake or when an intake was likely. Sampling was required under 10 C.F.R. 

835.402(c)1 when an intake was expected to exceed 100 mrem under typical conditions. Special 

actinide samples were individually tracked by an SRS internal dosimetrist and used to assess 

dose. SRS provided a numerical summary of special actinide urine bioassay for 1996, 1997, and 

through mid-July 1998, as shown in Table 8. For all of 1996, 1997, and 1998 through mid-May, 

a total of 483 samples were requested and all were submitted and analyzed. Although all samples 

were collected for cases where exposures were expected to be possible only 12 samples or 2.4% 

of the Special Actinide urine samples resulted in confirmed intakes with only 8 of those or 1.6% 

resulting in intakes greater than 100 millirem CEDE. (LaBone, 1997).

Table 8. Special Actinide Urine Samples. 

Criteria 1996 Results 1997 Results 1998 Results 

Through Mid-July

Number Requested 34 249 100

Number Received 34 249 100

Percent Received 100% 100% 100%

Number Confirmed Intakes 9 3 0 

Percent Confirmed Intakes 6.7% 1.2% 0%

Number > 100 mrem 6 2 0 

Implications for Dose Reconstruction

NIOSH respectfully disagrees with SC&A’s conclusion that this NOV would prohibit dose 

reconstruction of subcontractor construction trades workers. 

The NOV concerned the job-specific bioassay sampling solely and did not indicate any failure of 

the routine bioassay sampling or special bioassay sampling. The greatest bulk of bioassay 

samples at SRS during this time were for the prescheduled routine samples. Routine or 

prescheduled bioassay monitoring was the primary method of surveillance, as indicated by the 

large number of workers on routine bioassay compared to job-specific bioassay. The 

job-specific bioassay sampling was performed to verify the adequacy of workplace and worker 

protections and was a subset of the total surveillance program. 

All workers who failed to provide bioassay samples under the job-specific program in 1997 were 

resampled and found to have no detectable intakes. In addition, the site evaluated the potential 

for those who may be missing samples in 1996 and concluded that they did not have a potential 

for intake exceeding 100 millirem CEDE (Brush, 1998). 

The number of intakes at the site is very low (less than 0.1%) in this time period. In the ORPS 

report, SRS stated that: 
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information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

To date, there is no evidence that workers have received an intake that has previously gone 

undetected due to the problems identified above. Dose is not assigned by job-specific 

bioassays. Radiological controls at SRS exist to monitor levels of radiation, contamination, 

and airborne radioactivity. If unanticipated elevated levels are measured, work is stopped 

until corrective action is taken. Any concern that a worker intake of radioactive material may 

have occurred is assessed as part of the special bioassay program (DOE ORPS, 1998).

The DOE agreed that workers were adequately monitored; the NOV described failures of 

management oversight and of the application of established procedures under 10 C.F.R. 830 

rather than under 10 C.F.R. 835, which would have indicated a failure of the site’s ability to 

estimate worker exposures. The DOE acknowledged that the site operated a rigorous 

radiological control program. In a September 21, 1998 letter to SRS (Brush, 1998), the DOE 

stated:

DOE is aware that, for all radionuclides other than tritium, the SRS internal dosimetry 

program does not knowingly permit any worker to be exposed to airborne radioactive 

material. Further, it is noted that SRS 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 occupational intakes of radioactive material 

by a worker. 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.

With the follow-up sampling of the 256 workers conducted by the site, there are no missing 

bioassay in 1997 regardless of the initial 66% non-participation rate under the “limited 

assessment” and 79% nonparticipation rate under the “full assessment.” There is no effect on the 

coworker model for 1997 because all of the worker data has been collected and evaluated. The 

site evaluated the potential for those who may be missing samples in 1996 and concluded that 

they did not have a potential for intake (Brush, 1998).

SC&A has not demonstrated that subcontractors were primarily or only monitored via 

job-specific bioassay that would bias a coworker model. The NOV affects both CTWs (SRS and 

Subcontractor) as well as operations workers (SRS) on the job-specific bioassay program. 

Significant workplace and individual monitoring information, including over 10,000 bioassay 

samples in 1997, supports the conclusion that there is no evidence of a workplace exposure nor 

an indication that there was a missed radionuclide intake at SRS. 

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.

The NOV was applied due to procedural failures under 10 C.F.R. 830. No workers were likely 

to exceed 100 millirem CEDE so bioassay monitoring was not required under DOE rules or by 

the Guide of Good Practices for Occupational Radiological Protection in Plutonium Facilities; 

DOE did not assess any violations under 10 C.F.R. 835. The job-specific bioassay sampling was 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 25 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

performed to verify the adequacy of workplace and worker protections. All workers who did not 

provide job-specific bioassay samples in 1997 were identified, samples were provided, and none 

resulted in identifiable intakes.

CONCLUSION

With respect to using routine prescheduled and job-specific bioassay to generate coworker 

distributions, the degree and direction of potential bias generated in a coworker model by 

missing samples is more important than the number of samples that were requested but not 

provided. Missing routine job‐specific samples do not automatically invalidate the radiation 

protection program at SRS and do not automatically render the vast amounts of available 

monitoring data worthless in the context of generating a coworker model. 

At SRS, routine urine bioassay was used to confirm adequacy of workplace monitoring and 

worker protection programs and consisted of prescheduled and job-specific sampling. A 

majority of workers, including subCTW, were on prescheduled urine bioassay. NIOSH 

evaluated bioassay for SRS workers identified by SC&A and found that almost 96% of the 

subCTW were monitored by personal bioassay on a timely basis, with over 88% of those being 

on routine prescheduled bioassay for actinides (see Table 4). Workers not leaving samples 

appear to be random (i.e., showing no apparent pattern). NIOSH identified coworkers on same 

RWP for another 8% of the workers identified by SC&A. Ninety-eight percent of the 

subcontractors evaluated in the SC&A report are covered by bioassay.

The NOV issued by the DOE was specific to the job-specific sampling portion of the routine 

bioassay program. The DOE concluded that SRS was not in violation of 10 C.F.R. 835 and 

found that calculation of doses to site workers was not impacted by the failure of some workers 

to leave bioassay samples. For the first four months of 1997, workers failed to leave some 

job-specific samples that accounted for about 3% of the total requested routine bioassay samples. 

All 256 of the workers who failed to leave job-specific samples in 1997 were subsequently 

sampled and found to have no identifiable uptakes. SRS collected 9,389 routine urine actinide 

bioassay samples in 1997 with two confirmed intakes, and approximately 1,500 job-specific 

samples, none of which had confirmed intakes. SRS collected over 25,000 urine tritium samples 

in 1996 and 24,000 urine tritium samples in 1997, with the highest cumulative worker dose of 52 

mrem in 1996, and 41 mrem in 1997. It is highly implausible that the results of a small 

percentage of all routine urine samples would impact range and distribution of the bioassay 

results provided by SRS and held by NIOSH. For all results in 1996, 1997, and the first half of 

1998, the fraction of actinide bioassay samples that resulted in a confirmed intake was less than 

0.1%. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 26 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

NIOSH therefore concludes that dose reconstruction is feasible and sufficiently accurate through 

the use of a coworker model. NIOSH identified the following issues. 

NIOSH Issue 1: Bioassay data should have been separated into tritium and non-tritium and 

appropriate time intervals used for evaluation. 

NIOSH Issue 2: Some Standing RWPs (SRWPs) should have been excluded from analysis. 

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. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 27 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

REFERENCES

Actinide Basis, 1993, SRS Actinide Bioassay Program Basis Document (U), ESH-HPT-93-0414, 

Westinghouse Savannah River Company, September 10. [SRDB Ref ID: 148919] 

Brush, 1998, Preliminary Notice of Violation and Propose Imposition of Civil Penalty-$75,000, 

correspondence with enclosures, Peter N. Brush, September 21. [SRDB Ref ID: 167497, PDF 

pp. 8-17] 

DOE ORPS, 1998, Occurrence Report, Inadequate Participation in the Job-Specific Bioassay 

Program, final report, Department of Energy (DOE) Occurrence Reporting and Processing 

System (ORPS), final report dated March 23. [SRDB Ref ID: 167487] 

DOE Standard, 1998, DOE Standard: Guide of Good Practices for Occupational Radiological 

Protection in Plutonium Facilities, DOE-STD-1128-98, U.S. Department of Energy, June. 

[SRDB Ref ID: 33218] 

DOE Standard, 2003, DOE Standard: Guide of Good Practices for Occupational Radiological 

Protection in Plutonium Facilities, DOE-STD-1128-98, Reaffirmation with Errata, U.S. 

Department of Energy, May. [SRDB Ref ID: 15919] 

DOE Standard, 2005, DOE Standard: Guide of Good Practices for Occupational Radiological 

Protection in Plutonium Facilities, DOE-STD-1128-98, Reaffirmation with Errata May 2003, 

Change Notice 1, U.S. Department of Energy, February. [SRDB Ref ID: 22723] 

Farrell and Findley, 1999, Specification of Urine Bioassay Requirements on RWPs (U), W. E. 

Farrell and W. M. Findley, ESH-HPT-99-0051, Savannah River Site, Aiken, South Carolina, 

March 10. [SRDB Ref ID: 167754] 

Findley, 1997, Understanding Urine Bioassay Sampling, Findley, September 19. [SRDB Ref 

ID: 167759, PDF pp. 8-10] 

Findley, 1998, Propose Changes to Administration of the Routine Urine Bioassay Program at 

the Savannah River Site, abstract and slides, Findley, September 16. [SRDB Ref ID: 167847] 

Fitzgerald, 2017, Evaluation of Savannah River Site Subcontractor Bioassay Data Completeness, 

Rev. 0, Draft, Joseph Fitzgerald and Ron Buchanan, July 13. [SRDB Ref ID: 167913] 

LaBone, 1992, Policy on the Deliberate Exposure of Workers to Radioactive Materials, ESHHPT-920181, Thomas LaBone, November 17. [SRDB Ref ID: 167845] 

LaBone, 1997, Slides Used in 1997 Enforcement Conference, slides prepared by Tom LaBone. 

[SRDB Ref ID: 167851] 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 28 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

LaBone, 2001a, Verification of Likelihood, Tom LaBone, June 26. [SRDB Ref ID: 167848] 

LaBone, 2001b, Verification of Likelihood, Tom LaBone, June 26. [SRDB Ref ID: 167848, 

PDF p.2] 

Morgan, 1998, Closure of Commitment 4-SR-SRS-HPIH-1997-0002, correspondence, C. R. 

Morgan, March 25. [SRDB Ref ID: 167757, PDF p. 49] 

ORAUT-RPRT-0083, Evaluation of Monitoring of Construction Workers Identified in HighLevel Cave Job Plans at the Savannah River Site, Oak Ridge Associated Universities, June 27. 

[SRDB Ref ID: 167136] 

Sanford Cohen & Associates (SC&A), Undated, SC&A Review—SRS Subcontractor Records. 

[SRDB Ref ID: 166053] 

Savannah River Site (SRS), 1994, Radiation Work Permits and Sign-in Sheets for 94-SRTC-410, 

Rev. 0, 94-SRTC-410, Westinghouse Savannah River Company, Savannah River Site, Aiken, 

South Carolina, November. [SRDB Ref ID: 168939] 

Savannah River Site (SRS), 1995a, Selected page from RWP 95L-101, Savannah River Site, 

Aiken, South Carolina, May 4. [SRDB Ref ID: 169441] 

Savannah River Site (SRS), 1995b, Selected page from RWP 95C-005, Savannah River Site, 

Aiken, South Carolina, September 7. [SRDB Ref ID: 169442] 

Savannah River Site (SRS), 1996, SRS Subcontractor Records and Individual In Vitro 

Monitoring 1989-1996, Savannah River Site, Aiken, South Carolina. [SRDB Ref ID: 166066] 

Thomas, 1993, Routine Bioassay Programs at the Savannah River Site, slides presented at 1993 

Radiation Safety Workshop in Las Vegas, Steven Thomas, Matthew McFee, and Thomas 

LaBone, slides presented April 14. [SRDB Ref ID: 167850] 

Tritium Basis, 1993, SRS Tritium Bioassay Basis Document (U) (Rev. 1), ESH-HPT-93-0246, 

Westinghouse Savannah River Company, August 23,. [SRDB Ref ID: 148920] 

Westinghouse Savannah River Company (Westinghouse SRC), 1990, Internal Dosimetry 

Technical Basis Manual, SRS-IM-90-139, Westinghouse Savannah River Company, issued 

December 20. [SRDB Ref ID: 11266] 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 29 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

ATTACHMENT A 

Table A-1. Detail of Tritium SubCTW with Tritium Bioassay. 

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

1 6/5/1990 6/7/1990 2 

3 11/17/1990 11/19/1990 2 

6 10/18/1990 10/18/1990 0 

7 11/3/1990 11/3/1990 0 

8 11/3/1990 11/3/1990 0 

9 10/30/1990 10/30/1990 0 

10 10/30/1990 10/30/1990 0 

11 10/30/1990 10/30/1990 0 

12 10/30/1990 10/30/1990 0 

13 10/30/1990 10/30/1990 0 

14 10/30/1990 10/30/1990 0 

15 11/30/1990 11/30/1990 0 

16 11/30/1990 11/30/1990 0 

17 12/21/1990 12/26/1990 5 

18 11/30/1990 11/30/1990 0 

19 11/30/1990 12/7/1990 7 

20 12/21/1990 12/21/1990 0 

21 12/21/1990 12/21/1990 0 

22 11/30/1990 12/1/1990 1 

23 11/30/1990 11/30/1990 0 

29 10/15/1989 10/16/1989 1 

30 10/15/1989 11/21/1989 37

32 10/15/1989 11/1/1989 17

34 11/15/1989 11/22/1989 7 

35 10/15/1989 10/27/1989 12

36 10/15/1989 10/18/1989 3 

39 11/28/1990 11/30/1990 2 

40 11/28/1990 11/29/1990 1 

41 11/28/1990 12/10/1990 12

42 11/28/1990 1/2/1991 35

43 11/29/1990 12/3/1990 4 

44 11/29/1990 12/4/1990 5 

45 11/28/1990 11/29/1990 1 

46 11/14/1990 12/7/1990 23
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 30 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

48 11/28/1990 12/4/1990 6 

50 11/28/1990 11/28/1990 0 

51 12/21/1990 12/27/1990 6

52 11/20/1990 11/27/1990 7 

53 11/20/1990 11/20/1990 0

54 11/20/1990 12/6/1990 16

55 11/20/1990 1/17/1991 58

56 12/4/1990 12/4/1990 0 

57 12/21/1990 12/21/1990 0

61 9/2/1990 9/2/1990 0 

62 9/2/1990 9/2/1990 0

63 8/31/1990 9/25/1990 25

64 8/31/1990 8/31/1990 0 

65 8/31/1990 8/31/1990 0 

68 8/31/1990 8/31/1990 0 

69 8/31/1990 8/31/1990 0 

70 8/31/1990 9/3/1990 3

71 8/31/1990 9/17/1990 17

72 8/31/1990 9/7/1990 7 

74 6/15/1989 6/16/1989 1 

75 6/15/1989 7/13/1989 28

76 1/27/1990 1/27/1990 0 

77 1/22/1990 1/22/1990 0

78 1/3/1990 1/3/1990 0 

79 1/3/1990 1/3/1990 0 

80 2/11/1990 2/12/1990 1 

82 1/31/1990 2/5/1990 5

83 1/29/1990 1/30/1990 1 

84 1/29/1990 2/3/1990 5

85 1/29/1990 Nonea N/Ab

86 1/29/1990 1/30/1990 1 

87 1/29/1990 2/1/1990 3 

169 11/15/1989 11/30/1989 15

170 10/15/1989 11/10/1989 26

171 9/28/1989 9/28/1989 0

172 10/15/1989 10/20/1989 5 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 31 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

173 10/15/1989 10/20/1989 5 

175 10/15/1989 11/9/1989 25

176 11/15/1989 11/20/1989 5

177 10/15/1989 10/20/1989 5 

178 11/15/1989 11/18/1989 3

213 7/23/1990 7/23/1990 0 

214 3/21/1994 3/24/1994 3 

215 5/30/1994 5/30/1994 0 

216 6/29/1994 7/28/1994 29

217 6/15/1991 6/17/1991 2 

218 6/15/1991 6/17/1991 2

219 6/15/1991 6/17/1991 2 

220 6/15/1991 6/21/1991 6 

221 6/15/1991 6/21/1991 6 

222 4/20/1991 4/24/1991 4 

223 6/15/1991 6/17/1991 2 

224 6/30/1991 7/2/1991 2

225 6/30/1991 7/29/1991 29

226 6/15/1991 6/18/1991 3 

227 6/15/1991 6/16/1991 1 

228 11/8/1990 11/15/1990 7

229 11/8/1990 11/9/1990 1 

230 11/8/1990 11/14/1990 6

231 10/5/1990 10/5/1990 0 

232 10/4/1990 10/4/1990 0 

238 6/22/1994 7/28/1994 36

239 6/22/1994 7/6/1994 14

240 6/3/1994 6/3/1994 0 

241 6/3/1994 6/3/1994 0

242 9/1/1994 10/7/1994 36

243 6/28/1994 7/5/1994 7 

244 8/22/1994 10/3/1994 42

245 8/22/1994 8/31/1994 9 

248 8/11/1994 8/11/1994 0 

249 8/11/1994 8/11/1994 0

250 8/11/1994 8/11/1994 0 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 32 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

251 8/18/1994 8/18/1994 0 

252 8/19/1994 8/19/1994 0 

253 8/19/1994 8/22/1994 3

254 8/19/1994 8/24/1994 5 

255 8/29/1994 None N/A

256 10/11/1994 11/16/1994 36

257 1/5/1995 1/5/1995 0 

258 1/5/1995 1/5/1995 0 

259 1/5/1995 1/5/1995 0

260 9/7/1995 11/16/1995 70

261 9/7/1995 None N/A

262 9/7/1995 None N/A

264 2/1/1995 2/1/1995 0 

265 10/9/1995 10/11/1995 2 

266 11/28/1995 1/3/1996 37

267 11/27/1995 11/27/1995 0 

268 2/14/1995 2/28/1995 14

269 2/1/1995 2/1/1995 0 

270 5/4/1995 None N/A

271 1/3/1995 1/3/1995 0 

272 1/3/1995 1/5/1995 2

273 3/7/1995 3/7/1995 0 

a. None indicates that no bioassay results were

found for the period.

b. N/A = Not applicable.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 33 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

ATTACHMENT B 

Table B-1. Detail of Non-tritium SubCTW with Plutonium/Enriched Uranium Bioassay.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

89 3/1/1993 8/16/1993 168

90 3/3/1993 5/10/1995 798

93 3/3/1993 6/7/1993 96

95 3/16/1993 5/20/1993 65

96 3/16/1993 9/16/1993 184

97 3/16/1993 1/20/1994 310

98 3/25/1992 8/9/1994 867

99 3/25/1992 8/7/1992 135

100 3/27/1992 2/11/1993 321

101 3/27/1992 Nonea N/Ab

102 3/27/1992 4/24/1992 28

103 3/25/1992 4/28/1992 34

104 3/25/1992 4/24/1992 30

105 3/25/1992 7/21/1992 0 

106 3/25/1992 5/19/1992 55

107 3/25/1992 6/8/1992 75

112 5/22/1992 6/5/1992 14

113 8/12/1992 9/8/1992 27

114 6/12/1992 12/3/1992 174

115 8/12/1992 5/3/1993 264

116 8/12/1992 11/7/1992 87

117 8/12/1992 9/9/1992 28

118 8/12/1992 None N/A

119 8/10/1992 8/10/1992 0 

120 8/10/1992 7/7/1993 331

121 8/11/1992 4/6/1993 238

122 8/14/1992 10/13/1992 60

123 8/13/1992 1/22/1993 162
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 34 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

124 8/13/1992 11/11/1992 90

125 8/14/1992 11/10/1992 88

126 8/14/1992 12/2/1992 110

127 8/14/1992 8/22/1992 8 

128 8/14/1992 3/9/1993 207

129 8/18/1992 12/10/1992 114

130 8/18/1992 11/6/1992 80

131 8/18/1992 8/20/1992 2 

132 8/18/1992 2/8/1993 174

133 8/18/1992 None N/A

134 8/18/1992 9/9/1992 22

135 8/11/1992 12/14/1992 125

136 6/2/1992 11/10/1992 161

137 5/22/1992 6/29/1992 38

138 5/22/1992 7/20/1992 59

139 5/22/1992 6/8/1992 17

140 5/22/1992 7/15/1992 54

141 5/22/1992 7/19/1992 58

143 5/22/1992 7/17/1992 56

144 5/22/1992 7/16/1992 55

145 5/22/1992 7/29/1992 68

146 5/22/1992 7/20/1992 59

147 5/18/1992 6/8/1992 21

148 5/18/1992 6/10/1992 23

149 5/18/1992 6/16/1992 29

151 5/19/1992 6/30/1992 42

152 5/19/1992 6/8/1992 20

153 5/19/1992 8/8/1992 81

154 5/19/1992 7/29/1992 71

155 5/19/1992 9/21/1992 125

156 5/19/1992 8/12/1992 85
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 35 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

157 10/13/1992 2/5/1993 115

158 10/13/1992 4/7/1993 176

160 10/13/1992 11/14/1992 32

161 10/13/1992 7/7/1993 267

162 10/13/1992 1/20/1993 99

163 4/15/1993 7/19/1993 95

164 4/15/1993 11/19/1993 218

165 4/15/1993 7/13/1993 89

166 4/15/1993 10/20/1993 188

167 4/15/1993 8/16/1993 123

168 4/15/1993 5/6/1993 21

179 6/1/1994 8/7/1995 432

180 6/1/1994 10/19/1994 140

181 5/12/1994 8/24/1994 104

182 5/12/1994 6/17/1994 36

183 5/18/1994 8/10/1994 84

184 5/17/1994 6/13/1994 27

185 5/21/1994 11/14/1994 177

186 5/21/1994 None N/A

187 6/1/1994 8/17/1994 77

189 9/21/1994 10/3/1994 12

192 5/18/1994 6/14/1994 27

193 12/12/1994 4/13/1995 122

194 12/12/1994 2/6/1996d 421

195 12/8/1994 4/7/1995 120

196 8/29/1994 4/17/1995 231

197 11/3/1994 10/17/1995 348

198 9/2/1994 11/3/1994 62

199 11/23/1994 12/4/1995d 376

200 11/23/1994 None N/A

201 11/22/1994 4/1/1995 130
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 36 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Worker 

No. Job Date Bioassay Date

No. of 

Days 

Post 

Job

202 11/22/1994 8/21/1997e 1003

203 11/22/1994 9/2/1997e 1015

204 3/16/1994 6/22/1994 98

206 11/22/1994 1/9/1995 48

207 6/6/1994 2/6/1995 245

208 3/24/1994 12/12/1994 263

209 5/29/1994 7/25/1994 57

210 3/29/1994 12/13/1994 259

211 4/12/1994 8/12/1994 122

233 4/7/1992 4/24/1992 17

234 4/7/1992 2/10/1993 309

235 4/7/1992 5/4/1992 27

236 4/7/1992 5/8/1992 31

237 4/8/1992 4/24/1992 16

a. None indicates that no bioassay results were

found for the period.

b. N/A = Not applicable.

c. Unknown = exact date not known.

d. Bioassay is slightly beyond 1 year but a routine

sample.

e. Bioassay is three years past work date though

still usable for Pu dose reconstruction.
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 37 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

ATTACHMENT C 

Detail for Coworkers with Tritium Bioassay

The expected isotopes are taken from Farrell and Findley (1999). 

Year: 1989 SRWP#: K89S-001 (Farrell and Findley, 1999) 

Location: K Area All non-posted areas within RCAs. Isotopes: None 

Description: General RCA Entry 

Respirator: No

Bioassay: Not required 

HP Monitoring: No

Special Instructions:

1) Review Status Boards prior to entering areas (If available).

2) Contact HP prior to any line breaks, welding, grinding, cutting, drilling, or venting.

3) DO NOT ENTER any Contamination, Radiation, High Radiation, Very High Radiation, or Airborne Radioactivity Areas on

this SRWP. Contact HP for an RWP or SRWP to enter posted areas.

4) Avoid liquids on floors.

5) Notify Reactor/Control Room of any unusual conditions (eg. leaks, spills, alarms, etc.).

Two workers (#33 and #174) were identified on this RWP without bioassay but tritium bioassay was not required. 
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 38 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Year: 1992 RWP#: 92HC-229 (SRS, 1996) 

Location: 221H Isotopes: Pu, Sr

Description: Upgrade Sec S for Installation of Frames 

Respirator: Full-Face Respirator

Bioassay: None 

HP Monitoring: Continuous 

Special Instructions: None 

Table C-1. RWP Worker Comparison, 1992.

Worker 

Number Department Respirator Qualified Bioassay WBCa Date Time In Time Out Time In Time Out Bioassay Isotope 

Bioassay 

Date

100 Pipe Yes Yes Yes 3/27/92 1700 1920 ND ND Pu, Sr 2/11/93

101 Pipe Yes Yes Yes 3/27/92 2030 2245 ND ND b ND

New-1c Pipe Yes Yes Yes 3/27/92 1700 1920 2030 2243 Pu, Sr 7/30/92

a. WBC = Whole Body Count.

b. Pu bioassay 10/12/95.

c. Relevant workers that were not identified in Fitzgerald (2017).
Response Paper Response to SC&A’s Evaluation of SRS 

Subcontractor Bioassay Data Completeness 

January 30, 2018

Page 39 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report 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.

Year: 1994 SRWP#: 94-SRTC-410 (SRS, 1994) 

Location: 773-A, C-001 Isotopes: Pu, Sr 

Description: Construction to cut, weld on 125# streamline outside and inside C-001. 

Respirator: Yes

Special Bioassay: Pu, Sr

HP Monitoring: Continuous 

Special Instructions:

1) Follow all instructions from RCO personnel.

2) Modesty clothing is required.

3) Housekeeping is required prior to existing area.

4) Change-out gloves per RCO instructions.

5) Personnel must don a fresh air hood after removing plastic suit.

Table C-2. RWP Worker Comparison, 1994. 

Worker 

Number Bioassay WBCa Date Time In Time Out Time In Time Out Bioassay Isotope Bioassay Date

202 Yes Yes 11/22/1994 2340 0245 ND ND Pu, Sr 8/21/1997b

203 Yes Yes 11/22/1994 2340 0245 ND ND Pu, Sr 9/2/1997b

201 Yes NDc 11/22/1994 2340 0245 ND ND Pu, Sr 8/23/1995

New-2d Yes ND 11/22/1994 2340 0245 ND ND Pu, Am, Sr 9/11/1995

199 Yes Yes 11/23/1994 1200 1430 1530 1700 Pu, Sr 12/04/1995

200 No Yes 11/23/1994 1200 1430 ND ND Pu, Sr ND

187 Yes ND 11/23/1994 1200 1430 1530 1700 Pu, Sr 8/23/1995

New-3d Yes ND 11/23/1994 1200 1500 1530 1710 Pu, Am, Sr 1/10/1995

a. WBC = Whole Body Count.

b. Bioassay is beyond 1-year interval as established in Westinghouse SRC (1990) and is treated in this report as not having bioassay for the 11/22/1994 work

event.

c. ND = No Data.

d. Relevant workers that were not identified in Fitzgerald (2017).