SC&A will determine whether the NIOSH dose reconstruction contractor appropriately
identified, evaluated, and incorporated all relevant data sources by comparing the extent to which
such information is present in the profile with what can be identified via an independent review
of such sources of information. Data sources that will be scanned include the following:

. Department of Energy
- Field Offices
- Operating contractors
- Institutional histories
- Inspector General files
- Headquarters and field oversight reports
- Radiation exposure assessments
. Atomic Weapons Establishment
° Centers for Disease Control
Nuclear Regulatory Commission
Environmental Protection Agency
General Accounting Office
Defense Nuclear Facilities Safety Board
Congressional Hearing Records
State environmental and safety regulatory agencies
National Academy of Science
Administrative/court records
Department of Defense
. Environmental Measurements Laboratory (formerly the Health and Safety
Laboratory)
. Workers compensation records
. Worker and public advocacy groups
. Historic records in private hands

.

oe ee ewe

It is anticipated that a baseline of relevant information contained in these and other data sources
will be established at the onset, facilitating subsequent comparisons with site profile information.

3.5.4 Interviewing Sources of Site Knowledge

SC&A, as necessary, will conduct one-on-one or group interviews with selected sources,
including worker representatives, worker advocacy organizations, individuals with site
“expertise” due to past employment or familiarity with operational history, and others who can
verify the adequacy of site profile information that has been collected by the NIOSH contractor.
Interviews will be conducted where convenient for these groups, including near the actual site in
question. Lines of inquiry would include the following:

. How did actual radiation protection practice compare with documented policy and
procedures?
° Were there instances of obvious “missed dose,” e.g., not wearing or improperly

wearing dosimeters, non-recording of dose, etc.?

SC&A 3-16 Sol. No. 2003-N-00768


- Dose/risk assessments for contaminated soil, aquifers, and buildings at
major DOE facilities as part of SC&A’s support to EPA in the
development of a site cleanup rule.

- Dose/risk assessment of residual radioactivity and cleanup needs for the
Republic of the Marshall Islands.

Mixed Waste Studies

Most of the studies described above involved the evaluation of both radioactive
and chemically hazardous waste. However, several SC&A studies were directed
specifically at mixed waste and mixed waste risk assessment. One of the more
challenging risk assessment projects was the development of a mixed waste
Hazard Ranking System (HRS), which was incorporated into the HRS in revised
40 CFR 300.

Airbome Pathways Risk Assessment and Source Term Characterization
These studies include:

- Radiological dose/risk assessments of airborne emissions from hundreds
of facilities throughout the United States, including DOE facilities, in
support of the radionuclide NESHAPS rulemaking.

- Inspection of several DOE facilities for compliance with the radionuclide
NESHAPS. Although this did not involve the performance of risk
assessments, SC&A did gather data pertinent to developing the source
term for risk assessments.

- The performance of radiological impact assessments as part of NEPA
documentation.

- Phase 1 of the dose reconstruction project of the Idaho National
Engineering Laboratory (INEL) for the CDC. The project involved
gathering, reviewing, abstracting, and creating a bibliographic database for
all reports, records, and data pertinent to the performance of a dose
reconstruction at INEL.

~ Reconstruction of the airborne emissions and radiation exposures
associated with INEL operations.

Aquatic (Surface Water) Pathways Dose/Risk Assessment
In addition to the assessment of surface water pathways performed in support of

RI/FS reviews, SC&A performed several special risk assessments studies
specifically for the surface water pathways, including:

SC&A

5-12 Sol. No. 2003-N-00768


2.6 Conflict of Interest Management

SC&A is fully aware of the conflict of interest (COD issues on this contract. SC&A can state
unequivocally that we comply with the Board’s OCI prerequisites, which are listed in Section
M.1 of the solicitation, as follows:

. SC&A, its team members, and the proposed key personnel are not currently
performing any work for NIOSH, ORAU, or ORAU’s primary teaming
partners, and if SC&A is a successful bidder, will not perform any such work
during the period of performance of the contract.

. If SC&A is a successful bidder on this contract, neither SC&A, its teaming
partners, nor any of the key personnel on the contract will bid on any work
for NIOSH, ORAU, or ORAU’s teaming partners.

. None of the proposed personnel have served as an expert witness (including
non testifying witness) at any time in the past in any litigation defending
worker compensation or other radiation-related claims on behalf of DOE, a
DOE contractor, an Atomic Weapons Employer, or an AWE contractor.

. None of the proposed personnel are currently working on the NIOSH Dose
Reconstruction Contract (Contract Number 200-2002-00593).

Since its founding in 1981, SC&A has been a prime contractor to many of the Federal regulatory
agencies concerned with health and safety relating to occupational and environmental radiation.
These include EPA, NRC, the Defense Nuclear Facility Safety Board (DNFSB), and CDC. The
OCT requirements imposed on us for the work for these regulatory agencies have been stringent.
For example, all seven of our large mission contracts with the EPA Office of Air and Radiation,
as well as our prime contract with the DNFSB, restricted our work for DOE and its contractors.
Moreover, SC&A has had 13 prime contracts with NRC, all of which have restricted our work
for NRC licensees, including Atomic Weapons Employers (AWEs). Many of our Federal
contracts have required formal OCI plans addressing search criteria for potential conflict of
interest: OCI avoidance, mitigation, and neutralization; OCI documentation; OCI training;
subcontractor OCL, and employee conflict of interest.

Section 2.6.1 contains a discussion of the work history of SC&A and its team members, and
additionally describes the background of each key individual on the project and includes a
disclosure statement with respect to potential conflicts of interest relating to work for DOE, DOE
contractors, AWEs, and AWE contractors. Section 2.6.2 discusses SC&A’s OCI plan. COI
forms were completed and signed by each member of the project team and are provided in
Appendix B. The forms provide a description of the work, the time period in which the work
was performed, and an identification of the organization for whom the work was performed.

The draft OCI plan presented in Exhibit 2-2 is preliminary in the sense that SC&A will work
with the Advisory Board to develop a systematic, comprehensive plan to ensure that neither

SC&A 2-14 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date: Page of

Area of
Review

Description of Technical Elements of Review

Yes/No!
NA

Comments Initials,

C4 Missing/Unmonitored External Dose: Evaluate the treatment
external dose’ if relevant to the case.

of ‘missed external dose’ and/or ‘unmonitored.

C41

[Are ‘missed/unmonitored’ external photon
doses reconstructed in accordance with 42 CFR
§82.16 and §82.17 and using guidelines and
hierarchy of data established in Section 3.1 of
OCAS-IG-001?

C42

Are data adequate for employing commonly
used practices/techniques/professional
judgments in estimating ‘missed/unmonitored’
external photon doses?

C43

Are ‘missed/unmonitored” neutron doses
reconstructed in accordance with 42 CFR
§82.16 and §82.17 and using guidelines and
hierarchy of data established in Section 3.2 of
OCAS-IG-001?

C44

‘Are data adequate for employing commonly
used practices/techniques/professional
judgments in estimating ‘missed/unmonitored’
neutron doses?

C45

Are ‘missed/unmonitored’ electron doses
reconstructed in accordance with 42 CFR
§82.16 and §82.17 and using guidelines and
hierarchy of data established in Section 3.3 of
OCAS-IG-001?

Ls

Are data adequate for employing commonly
used practices/techniques/professional
judgments in estimating ‘missed/unmonitored’
electron exposures?



BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

‘Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

wi)

C2945

Are calculations of uncertainty associated
with reconstructed electron dose using
source term data appropriate and correct?
(§3.3.3.3)

C298

Are calculations of reconstructed electron
dose to non-routine radiological workers
using radiological control limits appropriate
and correct? (§3.3.4)

C.2.9.h

‘Are calculations of uncertainty associated
with reconstructed electron dose using
radiological control limits appropriate and
correct?

C.2.10

Electron Dose Conversion to Organ Dose:
Are calculations for converting electron

dose to organ dose appropriate and correct?
(84.3)

C.2.11
C.2.11a

Annual Organ Dose and Distribution:

Are annual organ dose calculations for
photon energies <30 keV appropriate and
correct? (§5.1.1)

C.2.11.6

Are uncertainty distributions for annual
organ doses associated with photon energies
<30 keV appropriate and correct? (§5.1.2)

C.2.11.c

Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for photon energies
<30 keV? (§5.2)

a

C2114

Are annual organ dose calculations for
photon energies between 30 and 250 keV
appropriate and correct? (§5.1.2)

C-20


Information Required by Solicitation Clause L.3(c)(2

@ Solicitation Number: — 2003-N-00768

(ii) Offeror: SC&A, Inc.
6858 Old Dominion Drive
Suite 301
McLean, VA 22101
703-893-6600, fax 703-821-8236

http://www.scainc.com

(iii) Required Statement:

SC&A takes no exception to any of the terms, conditions, and provisions included in the
solicitation. Pricing is given in the cost proposals for each of the Sample Tasks.

(iv) Authorized Negotiators: Sanford Cohen, President
703-893-6600 ext 214
(fax) 703-821-8236
scohen @scainc.com

Gregory Beronja, Chief Operating Officer
703-893-6600 ext 206
(fax) 703-821-8236

beronja@scainc.com

(v) Name, Title and Signature of person authorized to sign the proposal:

Sanford Cohen, President Date


in extensive hearings (each lasting about 2 weeks), where the results of our work were presented
and litigated. Our support to the People of the Marshall Islands also included participation in
periodic meetings with the DOE and the Department of the Interior. At these meetings, SC&A
presented the findings of our investigations, reviewed the work performed by DOE on behalf of
the Marshall Islands, suggested new areas of inquiry, and assisted in the drafting of memoranda
of understanding between the Republic of the Marshall Islands and the U.S. Government.

Our work involved numerous visits to Majuro, the capital of the Marshall Islands, and the outer
islands to obtain information and present our results to the people of the northern atolls, the
President and his Cabinet, the Senators representing the atolls, and before the Nitijela (the
Parliament).

5.5 Dose Assessment Support to the Environmental Protection Agency

SC&A has supported EPA/ORIA in many of its rulemaking efforts related to the nuclear power
industry and related radiation programs, including a multi-task contract. These efforts involved
the recycling of radioactive scrap metal (RSM), cleanup criteria for sites contaminated with
radioactivity, 40 CFR Part 197 regulations for Yucca Mountain, disposal of low-activity
radioactive waste, and drinking water protective action guidelines. SC&A investigated the
technical issues associated with the rules and compiled the information into formats required by
the regulatory process, including Technical Support Documents (TSDs), Background Information
Documents (BIDs), Regulatory Impact Analyses (RIAs), Environmental Impact Statements
(EISs) and Regulatory Issues Papers.

SC&A prepared the radiological dose assessment guidance provided in EPA’s “Risk Assessment
Guidance - Human Health Evaluation Manual,” which is EPA’s guidance for deriving DCGLs,
along with “Guidance for the Development of Derived Concentration Guideline Levels for
Radionuclides in Soils: Technical Background Document,” prepared for the EPA ORIA,
Contract No. 68D20155, Work Assignment 5-23, EPA Work Assignment Manager Michael
Boyd, September 30, 1997. .

SC&A support included heiping establish the framework and overall EPA strategy for
rulemaking; evaluating the legal and regulatory framework within which rules would be
promulgated; considering the scope and alternative forms of rules; generating factors involved in
implementation of rules; and analyzing precedents established by EPA and other Federal and
state agencies. Once information on the rules or guidance was published, SC&A supported EPA
in managing, evaluating, and responding to comments.

For example, SC&A prepared a comprehensive multi-volume Background Information
Document for the Agency’s proposed rule regarding the recycling of radioactive scrap metal
(RSM) cleared from nuclear facilities. The investigations (1) compiled an inventory of DOE's
existing RSM and predicted the quantity of material that would be generated through DOE's
decontamination and decommissioning (D&D) program, (2) performed a cost/benefit analysis for
all of DOE's recycle options, and (3) assessed the impacts on certain sensitive industries of
recycling metals with residual levels of radioactivity.

SC&A 5-8 Sol. No. 2003-N-00768


depends primarily on the ability of NIOSH to perform a dose reconstruction under 42 CFR 82.
The EEOICPA states that a class of employees may be considered part of the Cohort if:

HHS determines that (1) it is not feasible to estimate with sufficient accuracy the
radiation dose that the class received; and (2) there is a reasonable likelihood
that such radiation dose may have endangered the health of members of the class.

Individuals or groups seeking to be added to the SEC must submit a petition to the DOL.
Categories of petitions are described in 42 CFR 83 as follows:

(1) Petitions from claimants in which NIOSH has already determined that a dose
reconstruction cannot be completed under 42 CFR 82. These petitioners only
need to cite this decision in their petitions, since NIOSH has already compiled an
administrative record for this class of employees. The petitioners are not
required to provide any additional information. These petitions are considered
the highest priority;

(2) Petitions from employees who have not submitted a claim for dose
reconstruction under 42 CFR 82. These petitions are considered the second
highest priority;

(3) Petitions from claimants who are currently waiting for results from dose
reconstruction under 42 CFR 82. These petitions are considered low priority.

The EEOICPA indicates that the Advisory Board will independently review a small sample of
petitions evaluated by NIOSH. These audits will allow the Board to oversee the work being done
by NIOSH. As prescribed by the proposed SEC rule and guided by the Board, the basis for a
worker to be considered a member of a class of workers for purposes of this sampling review
would include (but not be limited to):

Range of uncertainty in doses for the workers for which data are available. This
will include factors such as missing and faulty data, measurement uncertainties,
and incomplete data. For example, at Fernald, group doses have been calculated
with low uncertainty, but the same data indicate uncertainties that are very large
for individual workers. A review would include an evaluation of the statistical
procedures by which the best dose estimate is assigned to a worker who does not
have any or adequate data for a reliable dose reconstruction to be done.

How closely job descriptions fit the actual work done by workers. In some cases,
workers had particular job designations, but in practice performed other duties as
well.

Degree to which facility reviews show that the particular worker consistently
performed the work described for which relatively reliable dose reconstruction
cases are available.

SC&A

3-25 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of |Description of Technical Elements of Review | Yes/No/ Comments Initials]
Review NA

C2.11u Has an appropriate total organ dose

distribution been determined (normal versus
Jognormal distribution) for neutron energies
between 2.0 MeV and 20.0 MeV? (85.2)

C.21LY Are annual organ dose calculations for

neutron energies > 20.0 MeV appropriate
and correct? (§5.1.1)

C2.11.w ‘Are uncertainty calculations for organ doses

associated with neutron energies >20.0
MeV appropriate and correct? (§5.1.2)

C.2.1Lx Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for neutron energies
>20.0 MeV? (§5.2)

C.2.41y Are organ/tissue dose calculations for
electron energies >14 keV appropriate and
correct? (85.1.1)

C2.11z Are uncertainty calculations for organ/tissue
dose associated with electron energies >14
keV appropriate and correct? (§5.1.2)

C.2.11.aa Has an appropriate total organ dose

lognormal distribution) for electron
energies >14 keV? (§5.2)

distribution been determined (normal versus

C-23


3.8.2 Use of Specific Values of the Human Respiratory Tract Model (HRTM) Parameters

A great deal of attention is currently being given to the appropriate choice of the absorption
parameters in performing internal dose calculations. For example, though particle sizes have
been considered important since the issuance of ICRP 30, concern regarding specific absorption
parameters and their effect on bioassay is new. This issue is given particular attention in the
recently published “Guide for the Practical Application of the ICRP Human Respiratory Tract
Model,” Annals of the ICRP, Supporting Guidance No. 3, Volume 32, No. 1-2, 2002, ISN 0146-
6453, Pergamon Press, 2003.

In this document, guidance is given on applying the HRTM in situations that require specific
information on the characterization of radioactive aerosols and gases, and on determining
absorption rates from lungs to the blood. The information contained in this document is a very
important update on the ICRP 66, 68,78, (56, 67, 69) series, and should be used in the
interpretation of bioassay data and when it is desirable to obtain better dose assessments.
Examples are given illustrating the application of the HRTM in a range of situations. The
document analyzes how specific information on particle-size distribution, particle density,
absorption to blood, nose or mouth breathing, and distribution of time between sleep, sitting, and
light/heavy exercises affects the effective doses and the interpretation of bioassay measurements
(urine, feces, lungs). In general, bioassay measurements change much more than effective doses,
as the characteristics of the inhaled material change. So it may well be particularly important to
use specific information to assess intakes from measurements on workers.

Jn the reconstruction of doses we may use material-related parameters that result in a better
assessment of the dose. When particle-size distribution is unknown, and available data are not
sufficient for determining the particle size, dose should be calculated using “dose per measured
quantities” (urine excretion, feces excretion, lung, or body measurements). The quantity
“dose/measured quantity” is more robust in relation to particle sizes than the quantity
“{ntake/measured quantity,” although they come from the same ICRP models and the former
value is obtained by multiplying the last one by the quantity dose coefficient per unit intake.
Specific absorption factors, describing the rate of absorption from lungs to blood, should be used
for compounds described in this document and when a more refined dose reconstruction analysis
is required.

In any particular situation, the actual values of many of the parameters will inevitably be different
from the reference values. There can be circumstances in which it is feasible and desirable to
obtain a more accurate, or more reliable assessment of intake or dose, by using information
specific to the situation. Typically, this is likely to be the case when assessing doses
retrospectively, i.e., when the intake has already taken place, or when intakes are currently taking
place or are likely to take place in. the near future.

In general, a “closer look” at absorption parameters generally reveals that the default values used
to derive the generic dose conversion factors are overly conservative. This creates a dilemma for
this project in that it is our intent to err on the side of the claimant. As such, our audits will
identify such issues as they arise, solely for the purpose of providing a complete record of our
review, but this does not necessarily mean that NIOSH was incorrect in using the more
conservative default values in their assessments. In cases in which the reconstructed doses are

SC&A 3-36 Sol. No. 2003-N-00768


and site profiles are critical to the dose reconstructions. He will also be available to support SEC

Petition reviews. will be assisted by Mr. and Dr.
Both Mr. and Dr. have over 30 years experience, a large portion of which consisted of
working with on matters related to ES&H at DOE facilities.

will serve as lead SEC petition reviewer. is an expert in

nuclear engineering and also a nationally recognized advocate for worker rights. He will be
responsible for overseeing SEC petition reviews, with the assistance of other members of the
project team as required, to ensure that the reviews are performed in accordance with procedures
prepared specifically for this project (see Section 3), and that deviations from the SOPs receive
the proper review, approval, and documentation. In this capacity, can draw upon
any member of the project team.

Drs. and , both of whom are recognized experts in statistics and
uncertainty analysis, will serve as a resource to the other key individuals on the project in matters
pertaining to statistics and uncertainty analysis. Their primary responsibility will be to review
the distributions of the parameters used as input to IREP based on the information provided in
“the administrative record. Since the ultimate objective of dose reconstruction is to construct
distributions characterizing the uncertainty in the doses experienced by the claimants and which
serve as input to IREP, we believe that every case review must be reviewed by Dr.

or Dr.

The other members of the SC&A team are critical to the success of the project because of their
specialized expertise in each of the technical areas of this project. They will be called upon by
the Case Managers as required to ensure a complete and quality audit of each case and SEC
petition.

2.2 Flow of Work

The project calls for the performance of 70 Basic Reviews, 70 Advanced Reviews, 10 Blind
Reviews, 5 Worker Profile Reviews, and 5 Site Profile Reviews in the first year of this task order
contract. We assume that Example Tasks 1 and 2 are representative of the types of TORPs that
will be issued periodically by the Project Officer. This type of project is best managed and
performed using a matrix organization consisting of Case Managers, who are responsible for one
or more cases, and a team of technical specialists who will work on one or more cases, under the
direction of the Case Managers, depending on the technical requirements of the case. Any person
in the organization chart provided in Exhibit 2-1 could serve as a Case Manager, depending on
the nature of the task, and any person on the team could also be assigned specific technical
responsibilities on a case.

We struggled with identifying the scope, schedule, level of effort, and staffing required for a
basic review, advanced review, or a blind dose reconstruction for obvious reasons—until we see
the administrative record for a given case, such estimates would be highly speculative. We
prepared very detailed checklists (see Appendix C) to be used as we systematically perform and
document our basic and advanced reviews. Inspection of the checklists reveals that a basic

SC&A 2-4 Sol. No. 2003-N-00768


APPENDIX B

CONFLICT OF INTEREST FORMS


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials,
Review NA
C. EXTERNAL DOSE REVIEW PROCESS
C.1 External Dose Estimate Assumptions: Evaluate whether all assumptions used in the external dose

determination are appropriate for a remedial compensation program and determine whether, if, and to
what extent the benefit of the doubt was resolved in favor of the claimant. (Parenthetical number represents
the section within the “External Dose Reconstruction Implementation Guideline” (OCAS-IG-001) that provides
detailed methodology for conducting the appropriate portion of the dose reconstruction.)

Cl

Are assumptions used in the initial dose
assessment (rough estimate of exposure) for
determining whether the case falls into a very
low or very high potential exposure category
appropriate? (§1.4)

C12

Are assumptions used in the initial dose
assessment conservative (claimant friendly)?

C13
C.L3a

Photon Dose Reconstruction Using Monitoring
Data:
Are assumptions used in the determination
of photon dose/photon energies using
monitoring data (i.e., dosimeters)
appropriate? (§2.1.1)

C.1.3.b

Are assumptions used in determining
dosimeter dose uncertainty associated with
photon exposure appropriate? (§2.1.1.3)

C.i3.¢

Are assumptions used to determine dose for
incomplete/missing photon monitoring
records appropriate? (§2.1.2)

C13.d

Are assumptions used in calculating
uncertainty associated with
incomplete/missed photon monitoring dose
appropriate? (§2.1.2.4)

C.13.e

Are assumptions used in the determination
of the occupational medical dose
component of photon dose/photon energies
appropriate? (§2.1.3)

C5



ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number:

Date:

Page

of

Review

[acs of | Description of Technical Elements of Review | Yes/No/

NA

Comments

Initials

| i. ADDITIONAL INTERNAL DOSE RECONSTRUCTION REVIEWS
11

results).

.1 Consistency of Data: Evalnate whether the inter dose estimate is consistent with relevant radiological
information within the NIOSH site profile (e.g., air monitoring, wipe data are consistent with bioassay

Lil Is there reasonable consistency between.
assumptions used to estimate internal dose and
process information (e.g., radionuclides and
quantities present and processed, production
processes) provided in the Site Profile?

11.2 Is there reasonable consistency between

y assumptions used to estimate internal dose and
routine radiation monitoring practices (¢.g., air
monitoring, contamination surveys, etc.)
identified in the Site Profile?

113 Is there reasonable consistency between
assumptions used to estimate internal dose and
routine protective measures (e.g., respirators,
ventilation, etc.) identified in the Site Profile?

with relevant co-worker case information and assumptions associated with internal dose for consistency.

2.4 Is there consistency between monitoring data
1 used to calculate internal dose for the covered
worker and monitoring data used to calculate
“| internal dose for a relevant co-worker case?

| 12 Comparison of Case Information: Compare case information and assumptions associated with internal dose
1

122 Ts there consistency between assumptions used
to reconstruct unmonitored internal dose for the
covered worker and assumptions used to
reconstruct unmonitored internal dose for a
relevant co-worker case?

cao



SEC PETITION REVIEW CHECKLIST
continued

Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

Description

[vesnoma |

Comments Initials

Gii) “Primary cancer of the:

(A) Thyroid?

(B) Male or female breast?

(C) Esophagus?

(D) Stomach?

(E) Pharynx?

(F) Small intestine?

(G) Pancreas?

(H) Bile ducts?

() Gall bladder?

(B) Salivary gland?

(K) Urinary bladder?

(L) Brain?

(M) Colon?

(N) Ovary?

(O) Liver (except if cirrhosis or hepatitis B
is indicated)”?

. Has the petitioner provided proof of the cancer diagnosis

(e.g., physician’s letter, post-mortem exam results)? Note:

Proof of diagnosis is not discussed in 42 CFR 83, but it
may be important for the purposes of evaluation.

PETITION REQUIREMENTS
Sentences or phases in quotations are items taken directly from 42 CFR 83.
Does the petition indicate or contain:

. “The DOE or AWE facility at which the class worked”?

. “The location or locations at the facility covered by the
etition (c.g., building, technical area)?”

‘The job titles and/or job duties of the class members?”

4. “The period of employment relevant to the petition?”

5. “Identification of an exposure incident that was

unmonitored, unrecorded, or inadequately monitored or
recorded?” Some examples include:

(i) Records or confirmation from NIOSH or DOE that

the exposure incident occurred?

(ii) “Medical evidence that one or more members of

the class may have incurred a high-level radiation dose
from the incident, such as a depressed white blood cell

count associated with radiation exposure or the
application of chelation therapy”?

ii) “Confirmation by affidavit from two employees

who witnessed the incident, providing this evidence is

consistent with other information available to HHS?”

SC&A 3-31

Sol. No. 2003-N-00768


SC&A 2-21 Sol. No. 2003-N-00768


SC&A

4-20

Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A 2-28 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
Audit Number: Claim Number: Date: Page of
ss
[Area of | Description of Technical Elements of Review | Yes/No/ ‘Comments
Review NA
D21f When the preliminary PC results in >50%,

are calculations used in the refinement of
internal estimates appropriate and correct?
(§6.1.14 A-D and §6.5)

D22 Preliminary Internal Dose Estimate - High Dose.
D22.a | Potent
Are calculations for determining the highest

intake for each potential solubility class that
will not exceed any of the measured
bioassay values appropriate and correct?
(86.2.4)

D2.2.b If the acute scenario does not produce a
realistic curve, are calculations used in
finding a more reasonable scenario

appropriate? (§6.2.5)

D2.2.¢ Are calculations for determining the
scenario that produces the lowest 50-year
committed dose to the organ of concern
appropriate and correct? (§6.2.7)

D224 Are calculations for determining the annual
internal doses to the organ of concern
appropriate and correct? (§6.2.8)

D2.2.e When the PC calculation results in <50%,
1 are calculations to refine internal dose
estimates appropriate and correct? (§6.2.11

| A-G and §6.5)
D23 Detailed Internal Dose Reconstruction:
| D23.a ‘Are calculations for determining the

quantity of each radionuclide for each

intake based on bioassay measurement data
appropriate and correct? (see example §8.5)



radionuclides, graphs of doses as a function of lung absorption Type and AMAD reveal “areas of
invariance,” i.e., time periods where the assessment of dose is relatively insensitive to
assumptions made about lung absorption Types and AMAD. Thus, in dose reconstruction
analysis, when AMAD and/or lung absorption Types are not known or are poorly defined, the use
of monitoring data, if available, in the period of time corresponding to the invariance area, can
minimize parameter uncertainties.

Those graphs are also useful for assigning a weight to multiple bioassay results, e.g., using the
criteria of weighting data according to sensitivity in relation to dose calculations. The weight to
multiple bioassay result will also depend on the specific organ for which dose is calculated, e.g.,
urine is best correlated to systemic organs. These correlations are also well visualized in the
mentioned graphs.

The graphs may be used for defining the uncertainties related to an unknown or poorly defined
model parameter. The graphs of dose per unit measured activity also provide a tool to rapidly
compare doses derived from the same data set of bioassay results, using different assumptions.
Thus, the choice of the hypothesis that leads to the greatest dose is easily visualized and
determined.

3.6.3 Basic Approach to External Dose Reconstruction Reviews

For external dose radiation exposure, OCAS-IG-001 provides guidance on the methods of dose
reconstruction. The procedures for blind reviews will be exactly the ones specified in OCAS-IG-
001. As specified in this document, the three groups of workers who require dose reconstruction
are: workers who were not monitored, workers who were monitored inadequately, and workers
whose monitoring records are incomplete or missing.

Among the workers that were monitored inadequately, special technical attention will be given to
the results from individual monitoring done in early times, when the sensitivity and accuracy of
the dosimeters were inadequate as compared to modem standards (items 1.1.3, 2.2.1 and
2.3.1,0CAS-IG-001). We anticipate considerable uncertainties in the evaluation of low energy
photon dose, mixed photon field evaluation, electron dosimetry and neutron dosimetry.

For the Dosimeter Photon Dose (item 2.1.1.2), the evaluation of external photon doses using film
dosimetry is straightforward for photon energies above 250 keV. In this region, the energy
dependence of the film emulsion is quite low. It was, and still is, usual to perform the calibration
of the dosimetric system using only a high-energy source of photons (above 250 keV). Unless
the dosimetric system was characterized and calibrated for low energy photons, the evaluation of
external dose due to exposure to, for example, the plutonium isotopes, will be compromised.
The review of the individual monitoring reported doses for plutonium workers will include,
where possible, an evaluation of the calibration, evaluation, and dose reporting procedures. For
example, if the dose due to 17 keV photons was evaluated using the net optical density under the
lead filter, and not through the “open window dose” the lower limit of detection will be much
higher than 30 millirem (mrem), and probably closer to 500 mrem. This would increase the
“missing dose” for these cases.

SC&A 3-21 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

C284

Are calculations of uncertainty associated
with incomplete/missed electron monitoring
dose appropriate and correct? (§2.3.2.3)

C28.

Are dose calculations of skin contamination
appropriate and correct? (§2.3.3.2.2)

C286

‘Are calculations of uncertainty associated
with the dose from skin contamination
appropriate and correct? (§2.3.3.3)

C29
C2.9.a

Electron Dose Reconstruction With NO

Monitoring Data:
Are calculations of reconstructed electron

dose using co-worker data appropriate and
correct? (§3.3.1)

C.2.9.b

Are calculations of uncertainty associated
with reconstructed electron dose using co-
worker data appropriate and correct?
(§2.2.1.3)

C.2.9.c

Are calculations of reconstructed electron
dose using survey data appropriate and
correct? (§$3.3.2)

C29.

Are calculations of uncertainty associated
with reconstructed electron dose using
survey data appropriate and correct?
(§3.3.2.3)

C29.

Are calculations of reconstructed electron
dose using source term data appropriate and
correct? (§3.3.3)

C-19


SC&A

2-24

Sol. No. 2003-N-00768


and lungs. The breasts and esophagus have the same composition as the total body minus the
skeleton and lungs, with different densities.

The red bone marrow (RBM), a very important tissue to consider, is difficult to represent
mathematically due to the intricate mixture of RBM and bone in the skeleton. In this analysis,
the composition of the skeleton will be regarded as a homogeneous mixture of true bone and
marrow. The RBM will be assumed to absorb energy per gram as efficiently as the bone. The
dose to the RBM will be determined by taking the sum of the percentages of RBM found in the
different bones. These values are available in MIRD Pamphlet No. 5.

The source type, energy, and geometry (volume, planar, point, etc.) will be modeled from
available information. Conservative approximations will be assumed if information regarding the
source geometry is unavailable. The most conservative irradiation geometry (usually AP-PA
depending on source type and energy) as well as the most likely irradiation geometry will be used
for the calculations.

The organ doses will be calculated in the phantom using the energy deposition tally in MCNP4C.
Once all of the organ doses are known, the effective dose can also be calculated using the
appropriate ICRP tissue and radiation weighting factors.

3.7. Special Exposure Cohort Petition Reviews

The SEC is a specific group of employees defined by Congress in the Energy Employees
Occupational Illness Compensation Program Act (EEOICPA) who are eligible for compensation
under this Act. They are defined by the proposed rule 42 CFR 83 as follows:

. . employees of DOE, DOE contractors or subcontractors, or Atomic Weapons
Employers (AWEs) who worked an aggregate of at least 250 days before
February 1, 1992 at a gaseous diffusion plant in (1) Paducah, KY,

(2) Portsmouth, OH, or (3) Oak Ridge, TN and who were monitored using
dosimetry badges or worked in a job that had exposures comparable to a job that
is or was monitored using dosimetry badges; or (4) employees of DOE or DOE
contractors or subcontractors employed before January 1, 1974 on Amchitka
Island, AK and exposed to ionizing radiation in the performance of duty related to
the Long Shot, Milrow, or Cannikin underground nuclear tests.

If any of these employees had or has been diagnosed with one of 22 specified cancers, then they
or their survivors will receive a “lump sum payment of $150,000 and prospective medical
benefits” as compensation for illness which resulted from these radiation exposures. These
individuals are automatically eligible for compensation and do not have to undergo dose
reconstruction under 42 CFR 82 in order to determine PC of their cancers. Proposed rule 42 CFR
83, “Procedures for Designating Classes of Employees as Members of the Special Exposure
Cohort under the Energy Employees Occupational Illness Compensation Program Act of 2000:
Notice of Proposed Rulemaking,” describes the petition process that is being developed for the
addition of employees of other DOE facilities and AWEs to the SEC. Addition to the SEC

SCK&A 3-24 Sol. No. 2003-N-00768


SC&A

421

Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

adequate for assessing internal exposure?

Claim Number Dat Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials)
Review NA
D.3 Consistency of Internal Dose Data: Evaluate whether data were consistent with site radiological monitoring
protocols of the time period and determine whether the protocols were adequate for monitoring the
internal exposure.
D3.1 Are internal bioassay measurement data (e.g.,
types of bioassay, detection limits, etc.)
consistent with site radiological monitoring
protocols/procedures of the time’?
D3.2 Were internal bioassay monitoring programs

| D33

‘Are the frequencies and types of workplace
sampling and surveys (e.g., air sampling,
contamination surveys) consistent with site
workplace monitoring practices/procedures of
the time?

D34 Were site workplace monitoring protocols
adequate for assessing internal exposure?
D35 Is the use of respirators consistent with

protocols defined in the respiratory protection
program of the time?



public, and the environment. SC&A has performed a number of accident
analyses, including:

- Special studies of DOE facility safety for DNFSB.

- Nuclear power plant safety analyses for the NRC and the Congressional
OTA.

- Accident analyses in support of the development of Protective Action
Guides for the EPA.

- Chernobyl studies for EPA.

- Criticality evaluations related to both LLW and HLW management.

- Criticality evaluations of the October 16, 1959 criticality accident at INEL.
Data Collection, Analysis, and Evaluation

SC&A performed several studies pertaining to the collection of data for use in
dose/risk assessment and regulatory compliance. The studies included:

- The development of guidance for data collection for use in risk
assessments for EPA.

- Guidance on evaluating the usability of data for risk assessment for EPA.

- The review of data gathered by others at numerous DOE and non-DOE
Sites.

- The collection of field data from numerous sites for use in dose/risk
assessments and site closeout.

- The collection of license termination data from the Nuclear Energy
Institute (NED, EPRI, and ORISE in support of NRC clearance
investigations.

- Collection and analysis of environmental samples collected from the
Republic of the Marshall Islands.

Cleanup Technologies
In addition to the review of technologies performed for OTA and EPA, SC&A has

developed a soil washing system for EPA for sites containing large volumes of
soil contaminated with slightly elevated levels of naturally occurring

SC&A

5-15 Sol. No. 2003-N-00768


Adjudicated Decision

Review Ei} Review Worker
fy} Co Worker 2) and Site Profiles
Process : ive** 4 i
Descriptions Representative’ EY

* Worker-profile and site-profile reviews will be part of the basic review only if they were used
in the preparation of the original dose reconstruction prepared by NIOSH; otherwise they will
be limited to advanced reviews or stand-alone tasks authorized under a Task Order.

**We recognize that direct conversations with claimants may not be authorized.

Exhibit 3-1. Interrelationships of Activities

course of advanced reviews, all findings will be documented, regardless of their importance to a
particular dose reconstruction and adjudicated decision. We believe such findings may have
relevance to the review of other claims and to the overall dose reconstruction process. Blind
Reviews will be similar to advanced reviews, with the exception that the review team will not
have access to the dose reconstruction, IREP input, and resulting adjudicated decision. Instead,
blind reviews will include the performance of our own dose reconstruction and IREP
calculations. The outcome of the blind review will then be compared to the dose reconstruction
and JREP input/output resulting from NIOSH’s investigations.

3.2 Preparation of Technical and Cost Proposals in Response to Task Order Request
Packages .

Upon delivery to SC&A, all TORPs will be logged in, date stamped, assigned a Task Order
number, and placed into the dedicated project file which will be maintained under lock and key
pursuant to SC&A’s records management procedures (see Section 2.1). As a means of tracking

SC&A 32 Sol. No. 2003-N-00768


g
3
3
Z| ¢
Name, Title, 3 6
Anticipated Level of Effort Educational g g Familiar with Specific DOE/AWE
(key personnel only) Background > é Facilities

SC&A i Sol. No. 2003-N-00768


¥v

Dept of Labor:
‘Lead Agency

v

Exhibit 1-1. EEOICPA Regulatory Framework

It is SC&A’s understanding that NIOSH currently has approximately 12,000 claims in its
possession that require dose reconstructions. New claims are referred to NIOSH by the DOL at a
rate of about 200 per week. These dose reconstructions are being performed by NIOSH, with the
assistance of its contractors, in accordance with the requirements set forth in 42 CFR Part 82,
“Dose Reconstruction,” and the guidelines provided in OCAS-IG-001, “External Dose
Reconstruction Implementation Guide,” and OCAS-IG-002, “Internal Dose Reconstruction
Implementation Guide.” The results of these dose reconstructions, along with other claimant
information delineated in 42 CFR Part 81.5, are being used by the DOL as input into IREP to
derive the probability that a claimant’s radiogenic cancer, as delineated in 42 CFR Part 81, was

SC&A 1-2 Sol. No. 2003-N-00768


reconstruction contractors. Therefore, we are confident that our team is free of any actual or
perceived conflict of interest.

It is our understanding that the primary role of the contractor on this project is to assist the Board
in its efforts to advise the President on guidelines pertaining to Section 3623(c) of the Energy
Employees Occupational [ness Compensation Program Act of 2000, particularly in terms of
dose reconstruction and the allocation of risk. The contractor will be expected to review dose
reconstructions performed by NIOSH, review Special Exposure Cohort (SEC) petitions, review
worker and site profile databases, and provide a broad range of ad hoc technical support to the
Board as required. The SC&A team’s approach to the work required by the Board will draw
upon the three attributes described above.

Much of the work done by SC&A and its other team members is similar in many respects to the
proposed statement of work. SC&A has performed numerous health physics and nuclear safety
investigations for the DNFSB regarding the safe operations of DOE facilities and has provided
extensive health physics consulting support to NRC, the Atomic Industrial Forum, the Electric
Power Research Institute, universities, and private sector clients. SC&A conducted the Phase I
study of the INEEL dose reconstruction for CDC and is currently reconstructing the atmospheric
source terms and associated doses to the public associated with historical operations at INEEL.
In addition, SC&A has been leading the effort in support of the government of the Republic of
the Marshall Islands to reconstruct the historical thyroid and whole body doses for the people of
Rongelap and Utrik Atolls in the Marshall Islands.

Figure ES-1 presents the proposed organization chart for this project. We are proposing a
management structure that includes both a Project Manager, , and a Deputy Project
Manager, . This management construct best leverages the unusual
qualifications of these two individuals and will offer an energy and synergism to the project that
few companies can rival. As an experienced Certified Health Physicist, can provide
the technical oversight necessary to a project of this complexity. His understanding of radiation
dose assessment techniques and his experience in dose reconstruction exercises makes him the
ideal Project Manager. In addition, is the Senior Vice President of SC&A and has
over 15 years of experience in managing large task-order contracts for government agencies.
Complementing *s technical expertise will be *s unparalleled familiarity
with DOE and AWE facilities. has over 20 years of experience with DOE,
including serving as Deputy Assistant Secretary for Health and Safety. Together, and

_possess the knowledge and expertise necessary to direct any task orders issued by
the Advisory Board.

The project team consists of nine key individuals (designated by an asterisk in Exhibit ES-1) that
will be dedicated to the project and will serve as the project management team. These nine
individuals will be supported by 24 highly specialized experts in various disciplines critical to the
mission of the contract. As Task Order Request Packages (TORPs) arrive at SC&A, this team
will prepare comprehensive technical and cost proposals and will assign staff to review teams
based on the specific requirements of each case. Depending on the case and the complexity of
the review (e.g., basic versus advanced reviews versus blind dose reconstructions), a review team

SC&A ES-3 Sot. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/Nof
NA

Comments

Tnitial

C2ALe

Are uncertainty calculations for annual
organ doses associated with photon energies
between 30 keV and 250 keV appropriate
and correct? (§5.1.2)

C2E

Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for photon energies
between 30 keV and 250 keV? (§5.2)

C2.11g

Are annual organ dose calculations for
photon energies >250 keV appropriate and
correct? (§5.1.1)

C2.11b

Are uncertainty calculations for annual
organ doses associated with photon energies
>250 keV appropriate and correct? (§5.1.2)

C211

Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for photon energies
>250 keV? (§5.2)

C2115

Are annual organ dose calculations for
neutron energies <10 keV appropriate and
correct? (§5.1.1)

yoo

Ave uncertainty calculations for annual
organ doses associated with neutron
energies <10 keV appropriate and correct?

(85.1.2)

C2411

Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for neutron energies
<10 keV? (§5.2)

C-21


Exhibit 2-3. Conflict of Interest Certification (continued)

Additional Certification for Teaming Partners and Key Personnel

T understand that my participation on this contract means that I will not be permitted to bid or perform
any work for NIOSH, ORAU, or any of ORAU's primary teaming partners while performing work under
this contract.

Individual Name or Company Name

Signature

Date

SC&A 2-31 Sol. No. 2003-N-00768


|

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

[Pa

Page

of

Review

Area of | Description of Technical Elements of Review

Yes/No/
NA

Comments

D.1.6.e

Are assumptions used to compare, confirm,
or validate internal dose estimates based on
workplace monitoring with any other
supporting information sources
appropriate? (§5.2)

D.1.6.£

Are assumptions used to estimate internal
dose using workplace monitoring data
conservative (claimant friendly)?

D.1.6.2

Are assumptions associated with uncertainty
surrounding the estimated intake quantity
using workplace monitoring data
conservative (claimant friendly)?

DAT

D.L7a

Internal Dose Reconstruction Considerations
Associated Source Term Dat
Are assumptions used to determine the
radionuclide(s) of concern for each intake

using source term data (e.g., type of
material in area or handled ) appropriate?
(85.3)

D17b

Are assumptions used to determine the
concentration of each radionuclide in the
breathing zone using source term data (e.g,
dispersible quantity of material,
resuspension factors, etc.) appropriate?
(85.3)

D.1.7.c

Are assumptions used to compare, confirm,
or validate internal dose estimates based
source term data with any other supporting
information sources appropriate? (§5.3)

D7

Are assumptions used to estimate internal
dose using workplace monitoring data
conservative (claimant friendly)?



Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)
SEC PETITION REVIEW CHECKLIST

‘Audit Number: | Petition Number: Date: Page ___of.

Auditors/ Area of Review:

Person(s) who performed SEC petition evaluation and/or dose reconstruction:

Description Yes/No/NA Comments ___| Initials |
SEC ELIGIBILITY CRITERIA _
Sentences or phases in quotations are items taken directly from 42 CFR 83.
Must be able to answer yes to one or more parts of the following questions in order to qualify for SEC.
1. Are the class of employees represented by the petition
present or former employees of “Department of Energy
(DOE), DOE contractor or subcontractor, or an Atomic
Weapons Employer (AWE)”?
2. Is the petitioner:
(a) a member of the class of employees?

(b) “a surviving spouse, child, parent, grandchild or
grandparent” of an employee?

(c) “one or more labor organizations representing or
formerly having represented DOE, DOE contactors,
or subcontractors, or AWE employees”?

(d) “one or more individuals or entities authorized in
writing by one or more DOE, DOE contractor or
subcontractor, or AWE employee”?

3. Have one or more members of the class of employees been
diagnosed with one or more of the following cancers:
“ (a) “Leukemia (other than chronic lymphocytic
leukemia) provided that the onset of the disease was at
least two years after initial occupational exposure”?

(b) “Lung cancer (other than in situ lung cancer that is
discovered during or after a post mortem exam”?

———

(c) “Bone cancer”?
(d) “Renal cancers”?

(e) “The following diseases, provided onset was at
least 5 years after first exposure:

( “Multiple myeloma”?

(ii) “Lymphomas (other then Hodgkin’s
Disease)”?

SC&A 3-30 Sol. No. 2003-N-00768


3.8.7

all available data that may include incident reports, radiation surveys, radiation
work permits (RWPs), co-worker exposure data, etc.

Individualize Parameters. Dose models generally are based on reference-person
physiological and lifestyle parameters. For some radionuclides, individual-
specific parameters may profoundly alter estimates of dose. For example, the
amount of dietary intake of non-radioactive iodine inversely affects the blood-to-
thyroid transfer fraction (i.e., f, value) of radioiodine. Because dietary intake of
iodine varies greatly by geographic location as well as over time, f, values can
reasonably be expected to vary from less than 0.2 to as much as 0.8 on the basis of
dietary intakes. Equally, the uptake of iodine and its retention/excretions may also
be affected by underlying thyroid conditions/pathologies. :

Use of Air Monitoring Data as Surrogate for Bioassay Data. When internal

exposures are based on air-monitoring data, the largest source of uncertainty to a
calculated dose comes from the difference in concentration(s) in air inhaled by the
worker versus the air sampled. When air is sampled in close proximity to a
specific worker (as is the case for breathing-zone apparatus), potential differences
are minimized. Of concern, however, are air monitoring data that are based on
hard-wired, permanently installed continuous air monitors (CAMs). For example,
a glove-box worker exposed in close proximity to a pinhole release of plutonium
may be breathing air concentration(s) that are one to two orders of magnitude
higher than air concentration(s) sampled by the CAM that may be 20 to 30 feet
removed from the source.

Selected Issues Related to External Dose Reconstruction

Personnel Dosimeters/Field Survey Instruments. Contributing to the uncertainty
of derived dose estimates based on personnel dosimeters (film/TLD) are many
factors. For some factors, considerable data exist that allow for corrections to be
made that minimize their contribution to uncertainty. For example, a substantial
body of data exists that defines the energy dependence of various film emulsions
used in personnel dosimeters over time.

A major factor contributing to uncertainty of personnel dosimeter and field survey
data is the method of their calibration conditions approximate to exposure
conditions of the wearer. Common variables involving calibration include
selection of the radiation source, source-to-dosimeter/instrument geometry, use of
a phantom, etc. A significant but frequently poorly defined variable is the
difference in source geometry between the calibration of the dosimeter/survey
instrument and the radiation field to which a monitored individual was exposed.
In many instances, this involves the calibration to a point source and the
monitored exposure to a complex radiation field that may include (1) multiple
independent sources, (2) an infinite planar source, (3) isotropic (27) source, or (4)
an instantaneous exposure (one side only) from a point source (i.e., prompt
neutron/gamma exposure from a nuclear weapon test).

3.8.8 Selection of Reasonable Assumptions

SC&A

“3-39 Sol. No. 2003-N-00768


Technical Support for the Advisory Board on
Radiation and Worker Health Review of
NIOSH Dose Reconstruction Program

Volume 1: Technical Proposal
Request for Proposal (RFP) 2003-N-00768

Submitted to:

Centers for Disease Control and Prevention
Acquisition and Assistance Field Branch
Attention: RFP 2003-N-00768

P.O. Box 18070, 626 Cochrans Mill Road
Pittsburgh, PA 15236-0070

Submitted by:
SC&A, Inc.

6858 Old Dominion Drive
McLean, VA 22101

June 2, 2003



SC&A 425 Sol. No. 2003-N-00768


REVIEW CHECKLIST

‘Audit Number: Claim Number: Date: Page of
Auditor(s)/Area of Review:
Dose Reconstraction Analysis(s)/Area of Dose Reconstruction (External/Internal):

Area of |Description of Technical Elements of Review | Yes/No/ ‘Comments Tnitials

Review NA

A, DATA COLLECTION REVIEW PROCESS

A.1 Data Collection: Evaluate whether NIOSH received all requested data for the DOE or AWE site from any

relevant data source or repository. (Note: Follow protocols established in Volume 2, Section 3 of the proposal.)

ALI

Did NIOSH receive all requested data for the
DOE or AWE site from any relevant data
source (i.e., site/worker profile data from
sources such as DOE/AWE, CDC, DNFSB,
‘Congressional Records, etc.)?

A.2 Adequacy of Data: Evaluate whether the data used

by NIOSH for the case was adequate to make a

determination with regard to probability of causation. (Note: Follow protocols establish in Volume 2,
3 of proposal. Determining adequacy of data may require that the entire basic review checklist be completed first.)

Section

A21

Is there sufficient data (such as individual
monitoring, workplace monitoring, workplace
characterization, process description, co-worker
monitoring) for calculating/
interpolating/extrapolating external doses for
all periods of exposure, including monitored,
missing, and unmonitored periods?

A22

Is there sufficient information (such as co-
worker comparison data, area monitoring data,
‘instrument calibration, monitoring practice
procedures, etc.) to determine if the quality of
data used for determining POC is adequate?

C2


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials

D14h

If one ICD code describes organs
associated with more than one region
calculated by ICRP models, are
assumptions in the selection of ICRP region
and associated organ dose appropriate?
(83.1.1)

DAA

When an organ of interest is not included in
the ICRP metabolic model, are assumptions
for assigning dose to that organ
appropriate? (§3.1.1)

DAS

If an ICD code describes a type of
lymphatic cancer, are assumptions for
assigning organ dose appropriate? (§3.1.1)

DAS

D.i5.a

Internal Dose Reconstruction Considerations
Associated with Bioassay Measurements:
Are assumptions used to determine the
quantity of each radionuclide for each
intake based on bioassay measurement data
appropriate? (see example §8.5)

D.1.5.b

Are assumptions of uncertainty associated
with the quantities of each radionuclide for
each intake based on bioassay measurement
data appropriate? (§7.2)

D.1.5.c

‘Are assumptions regarding the capability of
the bioassay program in detecting all
potential radionuclides of concern
appropriate? (§5.1)

DAS

‘Are assumptions regarding the validity of
positive results (-e., determination of a
false positive result) appropriate? (§5.1)

C-30



profiles, and SEC reviews. and its associates have years of advanced health physics
experience, both at DOE and in the commercial sector. Senior associates, such as

and , are intimately familiar with historic dosimetry programs at DOE and AWE
sites, and are knowledgeable of worker dose histories and operations throughout the 60-year
history of these sites. Mr. , during his notable Federal government career at DOE, was
a pioneer in identifying past radiation program deficiencies with respect to dosimetry and record-
keeping practices, program management, and policy and standards, and identifying needed
improvements.

offers extensive experience in radiological survey and personnel dosimetry programs,
primarily for facilities associated with the National Institutes of Health. In addition, can
provide expertise in radiological training, communication, and outreach, should such services be
required on this project.

Second, the SC&A team offers vast Federal contracts experience. Throughout its history,
SC&A has administered a number of large, multi-million dollar/multi-year, task-order contracts
requiring multiple subcontractors, formal quality assurance/quality control programs, and their
attendant management and auditing systems. SC&A’s principal client is the Federal government,
although we have conducted projects for State environmental agencies and private sector clients.
About 80 percent of SC&A’s contracts, valued at more than $250 million, have been large task-
order contracts for the Environmental Protection Agency (EPA), the Centers for Disease Control
and Prevention (CDC), and the Nuclear Regulatory Commission (NRC). These contracts have
encompassed more than 500 work assignments dealing with a broad range of health physics and
radiological issues. Other clients have included the Defense Nuclear Facilities Safety Board
(DNFSB), the Department of Justice, and the Congressional Office of Technology Assessment.
Based on this experience, SC&A has developed the tools and the know how to manage large task
order contracts, including comprehensive quality assurance and quality control plans, as well as
document and software controls that have passed EPA and NRC audits.

Both and have actively supported Federal agencies, including the National
Institutes of Health, the U.S. Forest Service, and the Federal Emergency Management Agency, as
well as private clients such as Johns Hopkins University and the Federation of American
Scientists.

The third attribute of the SC&A team is perhaps the most significant. The team has neither an
actual nor perceived conflict of interest with respect to DOE. While most other radiological
consulting companies have provided direct services to DOE and the nuclear utility industry,
SC&A made a decision early in its existence to devote its resources to supporting those
government agencies that regulate DOE and the nuclear industry. Thus, we have been very
selective in our assignments and have implemented stringent conflict of interest standards within
the company.

With these standards in mind, we disclose here that the SC&A laboratory is performing
radiological analyses of environmental samples collected at DOE sites by DOE contractors.
However, we do not believe this work will in any way present a conflict to the Board. In
addition, none of the SC&A team has past or current contracts with NIOSH or its dose

SC&A ES-2 Sol. No. 2003-N-00768


4.2.1 Office and Electronic Communications Facilities

SC&A maintains its corporate headquarters in 4,200 square feet of prime office space located on
Old Dominion Drive in McLean, Virginia. This office has a 15-workstation 10/100 RJ-45 LAN,
allowing SC&A employees to work together and communicate effectively with clients and
subcontractors. The LAN operates using Windows NT 4.0 and Linux servers, and utilizes Send
Mail for electronic mail. Automated tape backup systems safeguard the network. Each
workstation has access to full-time, real-time, full-service direct connectivity over the LAN to the
Internet via our dedicated DSL line. This ensures reliable access to global Internet resources, as
well as providing the capability for communication and file transfer with remote staff,
subcontractors, and clients. Physical resources include a conference room complete with
audiovisual equipment. The building has a multi-level security system with card reader access

entry.

SC&A’s Southeastern Environmental Laboratory is located in Montgomery, Alabama and
specializes in the analysis of radionuclides in environmental media. It is fully equipped with
modern, industry-standard radiochemical and radiometric equipment and is organized according
to nationally and internationally accepted radioanalytical and treatment processing principles. A

SC&A 4-26 Sol. No. 2003-N-00768


, does business as
which is identified earlier in this proposal as . Neither nor has performed any
work for NIOSH, ORAU, or a company teamed with ORAU on NIOSH Contract No. 200-2002-
00593, including through subcontracts.

Neither nor has provided staff to serve as an expert witness (including non-testifying
witness) in any litigation defending worker compensation or other radiation-related claims on
behalf of DOE, a DOE contractor, an AWE, or an AWE contractor.

Neither nor holds any DOE prime contracts at this time. However, has provided
radiation safety-related training services for DOE facilities and contractors. These services are
listed below:

. presented a 5-day training course entitled “Practical Tools for Response to
Nuclear Terrorism,” from May 19-23, 2003, under contract to EG&G Technical
Services. The content of the course included radiation detection instruments and
their use, and the understanding of how to respond to a nuclear terrorism event.
The course was presented at the DOE Emergency Operation Training Academy in
Albuquerque, NM, and most of the attendees were members of DOE’s emergency

response program.

. presented a 5-day training class entitled “Advanced Concepts in Health
Physics,” from April 16-20, 2001, under contract to Westinghouse Savannah
River. The course covered radioactivity, regulations, instruments, internal and
external dosimetry, statistics, waste, and transportation. The purpose of the
course was to prepare participants for successful completion of professional
certification examinations.

. provided a 1-day training course entitled “Radiation Safety Seminar” for the
West Valley Nuclear Services Company, inc., on October 22, 1997. The course
covered basic principles of radioactivity, radioactive waste classification, shipping
regulations, and public health and safety considerations. It did not cover radiation
dosimetry. The course was conducted as part of a cooperative agreement between
DOE and the Seneca Nation of Indians to increase understanding of
environmental and human health, and to protect the cultural history of the Seneca
community.

This work was not related to any of the elements of the scope of work of the subject
solicitation. Therefore, it is not in conflict with the proposed work for the Advisory Board.

Neither has a current or past history of contracts or financial relationships that
would result in any actual or perceived conflict of interest under this contract.

SC&A 2-19 Sol. No. 2003-N-00768


SC&A

46

Sol. No. 2003-N-00768


4.0 PERSONNEL, FACILITIES, AND EQUIPMENT
4.1 Personnel

Exhibit 4-1 presents an overview of the relevant experience of key members of the project team.
Following Exhibit 4-1, biosketches are provided that describe the role of each key person on the
project, his or her relevant project experience, and their availability to the project. Appendix A
presents complete resumes for each member of the team. Though we have assigned specific
responsibilities to each individual on the project, it is worth noting that most personnel have
experience in several of the technical specialty areas required for this project. A specific number
of hours proposed for each key person has not been given here, as there is no way to know this
without knowing the tasks which might be issued under the contract. However, work hour
allocations and schedules are provided for the sample tasks.

SC&A 4) Sol. No. 2003-N-00768


2.0 MANAGEMENT APPROACH
21 ‘Project Organization

SC&A has assembled a large, highly responsive team to address the multi-disciplinary areas of
the statement of work (SOW). Exhibit 2-1 shows the overall organizational structure of the
project. The individuals designated with asterisks (*) are the program management team and the
key individuals on the project. A total of nine key personnel are proposed. These individuals
will not be replaced without written approval of the Contract Manager. These individuals are
prepared to commit at least half time, and, for most individuals, full time to this project for its
entire duration. Each key person has a back up. The individuals on the bottom of the chart,
many of whom are nationally and internationally recognized experts on internal and external
dosimetry, bioassay, radiation protection, and other specialized technical areas, serve as resources
to the project management team on specific task orders, cases, and Special Exposure Cohort
(SEC) petition reviews. Section 4 of this proposal presents biosketches of each of the key
individuals on the project, along with statements addressing their level of commitment.
Appendix A presents complete resumes of all individuals on the project team. Appendix B
presents signed statements by each member of the project team disclosing any potential, actual,
or perceived conflict of interest issues.

As prime contractor for the proposed effort, SC&A will oversee and manage all project activities
and carry out all work, relying on the company’s 21-plus years of Federal contracting experience
to ensure maximum performance within budgetary and contractual limitations. SC&A has a
history of close working relationships with its clients and subcontractors on Federal contracts
which will enhance our ability to communicate effectively and resolve issues that may arise in
the performance of this contract. The SC&A team will be managed by » who is
the Senior Vice President of SC&A, and Mr. , who will serve as Deputy Project
Manager. Dr. is eminently qualified to oversee the proposed effort. He has the authority
necessary to fulfill the requirements of this contract and to complete task orders on schedule and
within budget. Dr. has over 30 years experience as a consultant to the Federal
government in the area of radiation protection and has managed numerous major (multi-year,
multi-million dollar) contracts for Federal agencies, including the Environmental Protection
Agency (EPA), Nuclear Regulatory Commission (NRC), and the Centers for Disease Control
(CDC). In addition, Dr. has been fully certified by the American Board of Health Physics
since 1976.

As Project Manager, Dr. will exercise project fiscal control and bear ultimate
responsibility for ensuring that all technical contractual obligations are fully satisfied in a timely
manner. Dr. has a reputation among his clients for providing efficient service within
budget estimates, while maintaining a proactive approach to problem resolution. Should, for any
reason, Dr. become unavailable to the project, the President and CEO of SC&A, Dr.
Sanford Cohen, will assume project management responsibilities. Dr. Cohen has a Ph.D. in
Nuclear Engineering and has over 35 years experience in managing large, complex government
task order contracts concerned with radiological engineering and radiation dose assessment
issues.

SC&A 2-1 Sol. No. 2003-N-00768


3.4 Procedures for Worker Profile Reviews

SC&A will review selected worker profiles from NIOSH’s database to ascertain the quality and
completeness of that database to support individual dose reconstruction. These reviews can be
performed as part of the review of a given case, or as a stand-alone Task Order requested by the
Advisory Board and authorized by the Project Officer. To accomplish these twin objectives,
SC&A will address the following questions: (1) Are the data of sufficient quality and reliability
to be used as a means to estimate dose when individual dose records are inadequate or not
complete? (2) Have all relevant dose records with personal identifiers, such as plant records,
monitoring data, memorandums, electronic databases, and accident and occurrence reports, been
included? (3) Has there been sufficient characterization of historic radiation protection programs
in place, including personnel monitoring requirements, protective equipment practices,
dosimetric techniques and equipment in use, and procedural enforcement history?

3.4.1 Quality and Reliability of the Database

The quality and reliability of the database will be a function of the number of data points
available for a particular job category, the facility process location or time period, and the
consistency of the data entered in comparison with the original source information. As the
worker profiles are populated with data from DOE sites, some searchable fields will contain
more data than others, as will some facilities, and locations and time periods within facilities.
“Missing data” will be apparent for certain operations and time periods due to any one of the
following reasons:

. Lack of personnel monitoring data (dosimeter not assigned or not processed)
. Inadequate monitoring techniques
. Errors in transcribing dosimetry readings to official reports, historic dosimetry

practices that ignored certain exposure sources (e.g., radon, low-energy photon,
neutron), etc.

One important issue is the quality and reliability of electronic dose-record databases submitted by
DOE for a site or facility. Unless these submitted databases have been verified from a quality
assurance standpoint against the original source records at the site, they cannot be considered
fully reliable. In its September 2000 Exposure Assessment report for the Paducah Gaseous
Diffusion Plant, a review team consisting of DOE, University of Utah, and the Paper, Allied
Industrial, Chemical and Energy Workers (PACE) International Union found a number of
instances where the data on the “official” Paducah electronic historic worker dose database did
not encompass all dosimetry records over the history of the plant.

At Paducah, the aforementioned exposure assessment found that the following limitations existed
for personal external radiation exposure measurements, uranium urinalyses, and whole-body
counting in the electronic database.

SC&A 3-11 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

BA3
B.l3a

Work History Interview:

jew:
Are procedures used for work history phone
interview adequate and appropriate?

B.i3.b

Is the questionnaire used for the work
history phone interview adequate,
appropriate, and complete?

E14
B.i4a

Evaluation of Contractor:

Are NIOSH methods, procedures, and
performance analyses used to evaluate,
analyze and validate all steps of the
contractor’s dose reconstruction process
appropriate?

VE145

Are NIOSH methods, procedures, and
performance analyses for evaluating,
analyzing and validating the contractor's
tracking system for each step of the dose
reconstruction process appropriate?

B.l4c

Are NIOSH’s performance analyses
conducted on a frequency to adequately
monitoring contractor progress?

Bl4d-

Are NIOSH’s methods and procedures
adequate to ensure any data
inconsistencies/conflicts are resolved in an
appropriate manner?

C-42


SC&A 413 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
Audit Number: Claim Number: Date: Page of

=
Description of Technical Elements of Review | Yes/No/ Comments
NA

Are methods and/or statistical software used
for determining uncertainty distributions
surrounding external organ dose adequate
and appropriate?

Internal Dose Technical Basis
Documents/Methods:
Are the technical basis documents (e.g.,
ICRP reports, etc.) used in reconstructing
internal radiation doses adequate and
appropriate?

Are methods for estimating ‘missed,’
‘incomplete,’ and/or ‘unmonitored” internal
dose adequate and appropriate?

Are statistical approaches developed for
multiple internal dose reconstructions
appropriate?

Are procedures used for determining
whether data is sufficient to make a
reasonable internal dose estimate
appropriate?

Are methods/procedures used for
substituting internal exposure data for
unavailable or incomplete information
adequate and appropriate?

B.L2£ Are methods for estimating uncertainty in
dose associated with internal dose
reconstructions on a facility and time
specific basis appropriate?

WE.1.2¢ Are appropriate methodologies used to
resolve uncertainty estimates associated
with internal dose in favor of the claimant?

CAl


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST

continued

L Description

Yes/No/NA.

Comments Initials

6. “A description of the petitioner’s basis for believing
records and information available are inadequate to
estimate the radiation doses incurred by members of the
proposed class of employees with sufficient accuracy?”
Some examples include:

(@® “Documentation or statements provided by
affidavit indicating that radiation exposures and doses
to members of the proposed class were not monitored,
either through personal or area monitoring”?

(i) “Documentation or statements provided by
affidavit indicating that radiation monitoring records
for members of the proposed class have been lost,
falsified, or destroyed”?

(iii) “A report published by a scientific government
agency or published in a peer-reviewed scientific
journal that identifies dosimetry and related
information that are unavailable for estimating the
radiation doses of employees”?

INFORMATION GATHERED BY NIOSH

Sentences or phases in quotations are items taken directly from 42 CFR 83.

Does the administrative record contain information (or indicate attempts to obtain information)
from the following sources?

[i . Records and information from DOE and AWE facilities?

2. “Potential members of the class and their survivors?”

3. “Labor organizations who represent or represented
employees at the facility during the relevant time period?”

4. “Managers, radiation safety officials, and other witnesses
present during the relevant period at the facility”?

populations and records from dose reconstructions

5. “NIOSH records from epidemiological research on DOE
conducted under 42 CFR 82”?

6. “Records from research, dose reconstructions, medical
screening programs, and other related activities conducted
to evaluate the health and/or radiation exposures of
employees of DOE, DOE contractors or subcontractors,
and the AWEs”?

SC&A 3-32

Sol. No. 2003-N-00768


2.6.2 Conflict of Interest Plan

We have chosen to modify SC&A’s current OCI plan to reflect the provisions of this proposed
work. Exhibit 2-2 presents this draft plan. In addition, Exhibit 2-3 presents the Conflict of
Interest Certification that SC&A required each potential team member to sign prior to developing
this proposal. Actual signed copies of this certification for each team member proposed are
included in Appendix B.

Exhibit 2-2. SC&A Organizational Conflict of Interest Plan

PROPOSED ORGANIZATIONAL CONFLICT OF INTEREST PLAN FOR
CONTRACT RESULTING FROM CDC SOLICITATION NUMBER 2003-N-00768

SC&A 2-25 Sol. No. 2003-N-00768


individual to perform the worker and site profile reviews for those cases. However, for complex
sites, where operations were highly diverse in space and time, such as at several major Federal
facilities, the supporting worker profile and site profile reviews may be highly unique to the
operations associated with the particular worker, or category of worker, and the specific
campaign at the site at a given point in time.

As described in greater detail in the example tasks, as our team becomes more familiar with
worker and site profiles for specific sites and categories of operations, Case Managers and team
members will be assigned to each new case in a manner that takes advantage of the experience
and knowledge gained by previous reviews. As such, we expect that we will become
increasingly efficient in performing both basic and advanced reviews as we acquire experience.
However, it is important to note that we will be beginning this process with individuals who
already have a great deal of experience and knowledge of the operations and exposure histories
of many of the DOE sites (e.g., see the biosketches of

The following sections describe the checklist and procedures for performing external and internal
dosimetry reviews, worker profile reviews, claimant interview reviews, and site profile reviews.
The checklists are extensive, and, in most cases, only those portions of the checklists that apply
to a particular case will need to be completed in detail.

During the review process, there will be a great deal of interaction among the review team
members in order to evaluate and ensure internal consistency and compatibility of the dosimetric
information with the worker profile information, the claimant interview information, and with
the site (or event’) profile. We suggest that, throughout this process, SC&A have an opportunity
to obtain clarifications and discuss our preliminary findings with Advisory Board representatives,
and, if acceptable to the Advisory Board, with the original authors of the dose reconstructions.

In addition, as work proceeds, should we uncover substantial errors or deficiencies in a dose
reconstruction, we will immediately contact the Advisory Board representatives, and not wait
until our reports are completed and delivered. We hope to establish a very close and cooperative
relationship with the Board members and seek their counsel throughout the review process.

Accompanying each item in the checklist will be a narrative explaining our findings. The level
of detail of the review will differ between the basic and advanced reviews. Blind dose
reconstructions will be performed in a similar manner as the advanced reviews, except the review
team will not have access to the IREP input and output prepared by NIOSH. In this way, our
team will perform an independent dose reconstruction, the results of which can be compared to
the results provided in the administrative record.

? For some cases, a major contributor to exposure may have been a transient or accidental release, referred
to here as an “event,” which will require a more focused historical reconstruction of the exposure setting than what
would normally be contained in a site profile, where exposures occurred as a result of routine operations.

SC&A 3-5 Sol. No. 2003-N-00768


Compare these radiation doses and health risks to the applicable radiation
protection standards.

The standards included the 15 mrem/yr EDE above background standard adopted
by the EPA and by the RMI for the cleanup of sites contaminated with radioactive
materials. SC&A also evaluated the doses against the 25 mrem/yr and 100
mrem/yr standards set forth in NRC regulations and recommended by the NCRP
and ICRP.

Derive soil cleanup levels.

This involved determining the combined average concentrations of Cs-137, Sr-90,
Pu-239/240, and Am-241 in soil in survey units, considering depth of
contamination, that provide a level of assurance that the resettled populations
and/or the existing populations on each island will not receive exposures in excess
of the EPA cleanup criteria of 15 mrem/yr above background to the reasonable
maximally exposed individual for all pathways of exposure.

Evaluate the costs and effectiveness of a broad range of alternative strategies for
the remediation of the islands to the EPA cleanup criteria.

The remediation strategies include the no action alternative, natural attenuation
with monitoring (including whole body counting, urinalysis, and environmental
radiological surveillance), food avoidance, island avoidance, soil removal,
application of soil additives to suppress the uptake of radionuclides by plants
(including the application of potassium and the application of clay-like additives
to soil), soil washing, and phytoremediation. Due to the location of the islands
and the unique environmental settings, cost analysis for each remediation strategy
required unit cost information unique to the Marshall Islands.

Reconstruction of the historical radiation exposures and associated health risks to
the people of the Marshall Islands from fallout from nuclear weapons testing.

This work involved the review of hundreds of recently declassified documents
characterizing bioassay data, film badge readings, radiation survey readings, aerial
survey overflight readings, fallout patterns, and the observed clinical effects of
fallout on the populations of the northern atolls. The dose reconstructions
included derivation of the doses to the average members of the populations and
members of the critical population groups each year from 1946 to the present.
These dose reconstructions were then compared to the applicable radiation
protection standards at the time for the purpose of assessing compensable “loss of
use” claims. SC&A also derived the time integrated collective doses to the
populations in support of claims compensation for adverse impacts on public
health. This involved monetizing the detriment caused by the exposures using a
broad range of methods adopted by the EPA, NRC, and other agencies for
monetizing health detriment.

SC&A

5-6 Sol. No. 2003-N-00768


Audit Interview Forms

Besides the specifics of the audit, discussed above, we will also review the interview forms for

adequacy as applicable to a particular case. Some gaps that may hinder complete elicitation of
potentially important information from workers could include the following:

. The NIOSH questionnaire does not address food in the work place. Workers
often ate in contaminated places and may have stored their food in contaminated

places.
. There is no question about handling of badges. This could affect badge readings.
. The questions about badges imply that a worker would have worn only one badge

(except to the extent that one question asks what part of the body the badge was
worn). At Fernald, some workers had wrist badges, and some workers may also
have worn ring badges.

° The reference to monitoring of “breath” is too vague to elicit data on breathing
zone air contamination measurements. Many workers wore these portable air
samplers. The interview form asks the question about monitoring “breath” in the
context of biological monitoring, such as occurs after an inhalation of
radionuclides. This may cause a worker to miss mentioning breathing zone
measurements, which are not biological measurements, as such. Breathing zone
data could be crucial in determining internal dose in some cases, especially where
biological monitoring documentation is missing, as may be the case for many
workers at FUSRAP facilities.

. The questions may not reveal the specific ways in which the particular worker
may have come into contact with radioactive material. As is clear from the
example of workers who stamped uranium ingots at Fernald (formally called the
Feed Materials Production Center during the period of production, 1951-1989)
noted above, it is necessary to go into the physical details of how a worker
processed radioactive materials or handled them in considerable depth.

. The only question about neutrons relates to neutron-generating facilities. This
omits neutrons from spontaneous fission of various isotopes, notably Pu-240, as,
for instance, in Pantex igloos.

Audit Form Review Checklist
In order to facilitate and standardize the documentation of our reviews, the forms presented in

Appendix C will be used, in part, to explicitly evaluate the thoroughness of the completed
NIOSH questionnaires.

SC&A 3-10 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
Audit Number: Claim Number: Date: Page of

Description of Technical Elements of Review | Yes/No/ Comments Initials
NA

‘Are assumptions used to determine dose
associated with incomplete/missing neutron
monitoring data and associated neutron
energies appropriate? (§2.2.2)

C164 Are assumptions used in determining
‘uncertainty associated with
incomplete/missed neutron monitoring dose
appropriate? (§2.2.2.4)

C.1.6.¢ Are conservative (claimant friendly)
assumptions used in the calculation of
neutron dose/neutron energies using
monitoring data?

C.1.6.£ Are conservative (claimant friendly)
assumptions used in determining
uncertainty associated with neutron
monitoring dose?

Neutron Dose Reconstruction With NO
Monitoring Data:
Are assumptions incorporated in the
reconstruction of neutron dose using co-
worker data appropriate? (§3.2.1)

C.1.7.b Are assumptions for the uncertainty analysis
associated with reconstructing neutron dose
using co-worker data appropriate?
(§2.2.1.3)

C.A7.c Are assumptions incorporated in the
reconstruction of neutron dose using survey
data appropriate? (§3.2.2)

co


3.3.1 External and Internal Dosimetry Review Procedure and Checklists

The basic and advanced individual dose reconstruction review processes will each utilize a
checklist for conducting the technical reviews. The checklists are provided in Appendix C. The
checklists are designed to satisfy the basic level and additional advanced level review elements
specified by the NIOSH Advisory Board Dose Reconstruction Working Group. The checklists
allow the basic/advanced review process to be conducted in a systematic, consistent, efficient,
and transparent manner. They will also serve as a means of tracking and formally documenting
the individual steps of the audit process. When the audit is completed, the information collected
in the checklist will be entered into a database in a format that is compatible with Microsoft SQL
2000. All records/documents collected and used in the audit process that were not included in
the case file will be duplicated and provided to NIOSH.

The basic individual dose reconstruction checklist is structured to evaluate the following five
areas of review: (1) data collection process, (2) interview/claimant documentation, (3) external
dose reconstruction process, (4) internal dose reconstruction process, and (5) applicable portions
of NIOSH procedures and methodologies associated with the reconstruction of dose for each
individual case . When an advanced dose reconstruction audit is requested, a second checklist
will be completed, which incorporates elements that will provide for a more extensive review of
the data gathering, work-history interview, and external/internal dose reconstruction processes.
These checklists are designed to take into account all requirements established in the U.S. Code
of Federal Regulations (CFR) Title 42, Part 82, and follow guidelines provided in the External
and Internal Dose Reconstruction Implementation Guidelines (OCAS-IG-001 and OCAS-IG-002,
respectively), as well as other relevant technical documents. However, it is recognized that, due
to the variety of conditions associated with each individual’s exposure scenario, these checklists
may not be all inclusive. The intent of the checklists is to provide the auditor with a roadmap to
evaluate the dose reconstruction process in a stepwise, thorough, and reasonable manner.

3.3.2 Claimant Interview Review Procedure and Checklist

The claimants, their family members, and co-workers play a key role in the dose reconstruction
procéss, especially for the advanced reviews. In general, basic reviews will be limited to a
review of the completed questionnaire and the degree to which that information was
appropriately incorporated into the dose reconstruction. Advanced reviews will go beyond a
simple checking of the questionnaires. Work history interviews will be assessed for their
effectiveness and, in the cases involving survivors, will evaluate whether a reasonable effort was
made to follow up on information provided by the claimant (i.e., contacting co-workers and
tracking down historical records). Advanced reviews may also include approved follow-up
interviews.

For each claim, NIOSH will conduct a voluntary interview with the claimants or their survivors
which will allow them to collect detailed information concerning the claimant’s employment
history, work environment, and radiation monitoring history. All of this information, which will
be contained in the structured interview forms used by NIOSH, should be considered by NIOSH
when performing the dose reconstruction, and should be consistent with the information gathered
by NIOSH fromthe DOE/Atomic Weapons Employer (AWE) personnel and site-monitoring

SC&A 3-6 Sol. No. 2003-N-00768


3.8 Special Topics

The following presents a list and brief description of special technical topics that our team will be
prepared to address. Section 3.6 on Blind Dose Reconstruction also addresses many special
topics, especially those related to internal dosimetry.

3.8.1 Special Attention to Historical Bioassays and Dose Reconstructions

Historic bioassay surveillance data in workers have been evaluated at times by dosimetrists and
epidemiologists in order to reconstruct the extent of occupationally received past exposures to
one or more internally absorbed radionuclide-contaminants. Before those early data could be
employed in a meaningful interpretive manner, however, various essential defining
characteristics should have been addressed. For example, how technically accurate and precise
were the measurements, and to what extent were they representative of their associated exposure
events? Within this basic concept, we will endeavor to determine the extent to which statistical
confidence was attached to the archival surveillance data; consider any algorithm that may have
been employed for translation of older information into more current representations of
exposures; examine those programs for evaluating error terms which were attached to each of the
individual bioassay values; and consider how the original sample collection protocols were
considered for their effect on the final estimation of the time-course and magnitude of related
exposure(s).

To accomplish these aims, the approach that will be taken in this review can be represented as
falling into each of three major categories: (1) the statistical representation of analytical accuracy
and precision, (2) those factors accounting for the sample collection variability, and (3) the
biological considerations for estimating the physiological dose and significance. In the first
category, it will be necessary to statistically propagate the uncertainties associated with each of
the procedural steps (e.g., chemical and plating recoveries, detection efficiency, etc.), as well as
to consider the myriad of other factors that make up the statistical counting error (e.g.,
background variability, sample size, counting time, etc.). In addition, other sources of
uncertainty, such as the specificity of the analysis for the contaminant in question and individual
analytical procedural steps (e.g., plating problems resulting in unwarranted alpha particle
absorption), should be defined quantitatively. All of these considerations become particularly
significant when procedures entailing no tracer isotope (as frequently encountered in some of the
early methodologies) had been employed.

The second category that will be considered, i.e., the sample collection variability, includes
factors such as the magnitude, time, and frequency of the bioassay sample collection (important,
for example, to the extent defined by the changing pH of a standing urine sample, container—wall
“plateout,” magnitude of the “retention” parameter viz. effective half-life), as well as other time-
related collection factors that are relevant to the exposure scenario.

Finally, attempts at quantifying the above considerations for final radiological dose calculation
necessarily invokes knowledge of the physical absorption along with the uncertainties attached to
the magnitude of each of the metabolic transfer factors and deposition parameters of the
considered contaminant.

SC&A 3-35 Sol. No. 2003-N-00768


‘ears of Relevant

Name, Title, 6
Anticipated Level of Effort Educational 3 Familiar with Specific DOE/AWE
ersonnel onl} Bi yund Zz Facilities Availability

SC&A Sol. No. 2003-N-00768


2.7 Confidentiality and Security Provisions

SC&A fully understands the importance of protecting personal, proprietary, and other sensitive
information to which we may have access under this contract. We have reviewed the provisions
contained in HHSAR 352.224-70, Confidentiality of Information; FAR 52.224-1, Privacy Act
Notification; 52.224-2, Privacy Act; and 52.239-1, Privacy or Security Safeguards, and are
prepared to comply fully with all the requirements contained in these clauses.

Privacy Act

We will ensure that all individuals working on this contract with access to data protected by the
Privacy Act are aware of the restriction on disclosure of records maintained on individuals and
the conditions that must be met in order for disclosure to be permissible under the Privacy Act,
Section 552a(b)(1)-(12). In addition, upon contract award, SC&A will establish procedures and
policies with respect to (1) accounting for certain disclosures, (2) access to records, (3) relevant
agency requirements, and (4) relevant agency rules.

Confidentiality of Information

In addition to the requirements of the Privacy Act, we understand that we will be subject to
compliance with the provisions of HHSAR 352.224-70. We will obtain written consent from any
individual, institution, or organization prior to disclosing confidential/proprietary information or
data about that individual, institution, or organization. We will also provide the Contracting
Officer with written advance notice of at least 45 days in the event that we intend to release
findings of studies or research which have the possibility of adverse effects on the Agency.
Finally, if we are unsure of the proper handling of material or information under this contract, or
if the material in question is subject to the Privacy Act or is confidential information under
HHSAR 352.224-70, we will obtain a written determination from the Contracting Officer prior to
releasing, disclosing, disseminating, or publishing such information or material.

Security Safeguards

In the event that we develop or implement safeguards under this contract, we will not publish or
disclose these safeguards without the prior written consent of the Contracting Officer. We agree
to cooperate with the Government should it be necessary to carry out a program of inspection to
safeguard against threats and hazards to the security, integrity, and confidentiality of Government
data, and in this instance will provide the Government access to our facilities, installations,
technical capabilities, operations, documentation, records, and databases. We understand that
under this contract, should it become evident to either the Government or SC&A that existing
safeguards have ceased to function, it will be the obligation of the discovering party to bring the
situation to the attention of the other party.

All of our obligations under this section will flow down to our subcontractors at any tier.

SC&A 2-32 Sol. No. 2003-N-00768


APPENDIX C

DOSE RECONSTRUCTION AUDIT CHECKLISTS


Our private sector work has been limited primarily to the radiological characterization of
contaminated sites and providing heath physics oversight and closeout surveys. We have also
assisted many NRC licensees in obtaining and maintaining their NRC licensees. In its more than
20 years of existence, SC&A has performed work on approximately 225 contracts, including
more than 1,000 tasks for its clients.

5.1 Radiological Assessment Support to the NRC and the Nuclear Power Industry

SC&A has held 17 contracts with the NRC, either as a prime contractor or subcontractor, since
1981. Six of these contracts were completed or initiated within the past five years. Under these
contracts, SC&A fulfilled dozens of task orders, with support requirements spanning the entire
spectrum of assistance requested under this solicitation.

SC&A evaluated the impact of NRC-initiated multi-plant actions on worker radiation exposures.
A list of multi-plant actions potentially resulting in occupational radiation exposures was
compiled from the NRC “orange book" for the period 1979 through 1983. This list was
supplemented by the relevant I&E Bulletins over the same time period. The next step was to
divide the operating reactors into classes, based on distinguishing parameters, and to select
representative plants from each of the classes.

Occupational radiation exposure data were obtained from the Radiation Work Permits at ten
representative plants for tasks corresponding to the NRC multi-plant actions. The exposures
from these representative plants were used to estimate the total exposures at light water-cooled
reactors. The results were presented in a form which illustrates the contribution of dose from
NRC-initiated multi-plant actions to total worker dose. The report was published as
AIJF/NESP-033, Occupational Radiation Exposure Implications of NRC-Initiated Multi-Plant
Actions, March 1986.

In the early 1980s, the nuclear energy industry employed an increasing number of non-permanent
radiation workers at nuclear power plants, variously referred to as "temporary" or "transient"
workers. Little was known about these workers, aside from their radiation exposures, which
were alleged to be higher, on the average, than those of permanent station employees. SC&A
conducted a study to characterize the non-permanent radiation workers at nuclear power plants.
The workforce was subdivided into permanent station employees, non-station utility employees,
temporary station utility employees, permanent contractor employees, and temporary contractor
employees. For each category of workers, data were collected on numbers of individuals by
craft, age, sex, geographical origin, duration of employment, and radiation exposure.
Additionally, radiation exposures were evaluated by specific job, including steam generator
repair, control rod drive maintenance, decontamination, and waste management. Finally, the
training in radiation safety was assessed for both permanent and temporary workers.

In evaluating the job-specific radiation exposures, it was necessary to disaggregate radiation
work permits by worker category. Although this task was simplified at some plants through the
use of automated databases, tedious reviews were necessary at other plants. In total, one to three
years of exposure data were obtained for 15 units at nine stations operated by six utilities. The
work was published as a report entitled, "Characterization of the Temporary Radiation Work

SC&A 5-2 Sol. No. 2003-N-00768


DACA31-94-D-0020). The project included the segregation and removal of 611 cubic yards of
waste containing elevated levels of radioactivity (depleted and natural uranium, cobalt-60,
strontium-90, cesium-137, radium-226, and thorium-232, among others), UXO, surety agents,
and hazardous waste. All waste was characterized, deposited into containers, and shipped to
Envirocare for disposal. The work was conducted under a license and oversight of the NRC,
Maryland Department of Environmental Conservation, and DOD’s Directorate of Safety, Health
and Environment. The project was audited by the NRC twice and once by the Maryland
Department of the Environment; the agencies did not issue any citations.

Upon completion of all remedial activities, SC&A implemented a final site characterization
survey and prepared a closure report to support an application to the NRC for unrestricted
release. The NRC conducted an independent radiological survey of the site via ORISE. The
survey included in situ measurements and soil sampling and analysis. The NRC authorized the
release of the site for unrestricted use on June 22, 1998. a

5.7 Dose Assessment Experience

Since its incorporation in 1981, SC&A has performed over 500 studies which required the
assessment of the radiation doses associated with radionuclides in the workplace and the
environment. In the process, SC&A has either used or reviewéd virtually every radiological dose
assessment model developed and has also developed its own models for specific purposes. The
following outlines the range of SC&A’s dose assessment experience:

. Dose/Risk Assessments in Support of Site Cleanup

SC&A studies pertaining to dose/risk assessments in support of site cleanup
include:

- The development of guidelines and regulations pertaining to the cleanup
and assessment of sites and facilities contaminated with radioactive and
mixed waste.

- The performance of baseline risk assessments at several sites, including
Weldon Springs, Kerr McGee, and Maxey Flats.

- The evaluation of the costs and benefits of cleanup technologies.

- The review of the dose/risk assessments and the models and data used to
perform the risk assessments at several sites, including waste management
units at Savannah River, Oak Ridge, Paducah, Fernald, Mound, and Los
Alamos.

- A comprehensive dose/risk assessment of sites throughout the country
containing elevated levels of naturally occurring radionuclides.

SC&A S-11 Sol. No. 2003-N-00768


radionuclides. The studies included an evaluation of the worker and public health
tisks associated with the technology.

Database Management and GIS Systems

SC&A has developed several large database management systems and GIS
systems in support of the performance of dose/risk assessment/management and
outreach programs.

Outreach Programs

Many of the risk assessment programs performed by SC&A have had large public
outreach components, which included the coordination of Jocal and national
workshops, the preparation of newsletters, information booklets, and videos. In
addition, SC&A interacts with the Federal Advisory Committee for the INEEL
dose reconstruction.

Epidemiologic Studies

SC&A performed pilot epidemiologic studies for:

- Workers at commercial nuclear power plants for EPRI.
- Indoor radon for EPA.

Dose/Risk Assessments in Support of Policy Decision making
SC&A performed nationwide screening studies to aid:

- The EPA Office of Policy, Planning and Evaluation to set national
priorities. .

- The NRC to evaluate nuclear power plant license renewal and clearance.

- The Nuclear Safety Oversight Committee to establish a nationwide
approach to safety.

- The OTA to evaluate nationwide cleanup strategies.

- The EPA to evaluate radon mitigation strategies.

5-16 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:
———

Claim Number:

Date:

Page

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

forthe

Are annual organ dose calculations for
neutron energies between 10 and 100 keV
appropriate and correct? (§5.1.1)

C2.11a

Are uncertainty calculations for annual
organ doses associated with neutron
energies between 10 keV and 100 keV
appropriate and correct? ($5.1.2)

C.2.1L0

Has an appropriate total organ dose
distribution been determined (normal versus
Jognormal distribution) for neutron energies
between 10 keV and 100 keV? (§5.2)

C2.11p

Are annual organ dose calculations for
neutron energies between 0.1 and 2.0 MeV
appropriate and correct? (§5.1.1)

C.2.11.q

Are uncertainty calculations for annual
organ doses associated with neutron
energies between 0.1 and 2.0 MeV
appropriate and correct? (§5.1.2)

C2ALr

Has an appropriate total organ dose
distribution been determined (normal versus
lognormal distribution) for neutron energies
between 0.1 and 2.0 MeV? (§5.2)

C2.11s

Are annual organ dose calculations for
neutron energies between 2.0 and 20.0 MeV
appropriate and correct? (§5.1.1)

C2A1Lt

‘Are uncertainty distributions for annual
organ doses associated with neutron
energies between 2.0 MeV and 20.0 MeV
appropriate and correct? (§5.1.2)

C-22


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: | Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments
Review NA

D. INTERNAL DOSE REVIEW PROCESS

DA nal Dose Estimate Assumptions: Determine whether all assumptions used in the internal dose
determination are appropriate for a remedial compensation program and determine whether, if, and to
what extent the benefit of the doubt was resolved in favor of the claimant. (Parenthetical number represents
the section within the “Internal Dose Reconstruction Implementation Guideline” (OCAS-IG-002) that provides
detailed methodology for conducting the appropriate portion of the dose reconstruction.)

D.11 Preliminary Internal Dose Estimate Efficiency
Dilla Process:

‘Are assumptions. used in the preliminary
internal dose efficiency process for
determining whether the case falls into a
“clearly high’ or ‘clearly low’ category

| appropriate? (§6.0)

DA1b Are assumptions used to modify the
preliminary internal dose estimate
efficiency process appropriate for including
the case in a ‘clearly high’ or ‘clearly low’
category? (6.3 and $6.5)

D.1.1.c Are assumptions used in the preliminary
internal dose estimate efficiency process
conservative (claimant friendly)?

D2 inary Internal Dose Estimate - Low Dose
DA2a Potential:
‘Are assumptions used in the recalculation of
bioassay values for each radionuclide for
which the claimant was monitored
appropriate? (§6.1.2)

D.1.2.b Are assumptions used in the selection of all
potential solubility classes for each
radionuclide for which the claimant was
monitored appropriate? (§6.1.3)

C26


EXECUTIVE SUMMARY

S. Cohen & Associates (SC&A) has assembled a team which is uniquely qualified to provide
technical support to the Advisory Board on Radiation and Worker Health Review (the Board) as
part of the National Institute for Occupational Safety and Health’s Dose Reconstruction Program.
For the purposes of this proposal we have teamed with and with

. In keeping with the Government's commitment to assist small and
disadvantaged businesses, we have also made arrangements to bring on a qualified 8(a)
subcontractor, , upon contract award.

Three attributes of the SC&A team separate us from our competition. First, our team offers
depth of expertise. For the past 21 years, SC&A has been in the forefront of the radiation
protection community. Our company President, Sanford Cohen, has dedicated his professional
career to the radiological sciences. A nuclear engineer by training, Dr. Cohen founded SC&A in
1981. The company specializes in the assessment of radiation and radioactive materials in the
workplace and environment and its associated risks to workers and the public health. We can
provide expertise in radiological dose and risk assessment, dose reconstruction, environmental
restoration and waste management, radiation sciences, health and safety analysis, public
outreach, geographical information systems, and information management. SC&A is well known
within the radiation protection community and is respected for its objectivity, scientific expertise,
and communication abilities.

, SC&A’s proposed Project Manager, has a Ph.D. in health physics, is certified
by the American Board of Health Physics, and has over 30 years experience in providing health
physics consulting services. He has completed numerous risk assessments for several
Government and private sector clients and has been involved with historical dose reconstruction
projects involving the people of the Republic of the Marshall Islands and the Idaho National
Engineering and Environmental Laboratory (INEEL).

As acompany, SC&A maintains a staff of highly qualified, technically skilled professionals.
More than 70 percent of SC&A’s professional staff have earned advanced
degrées—approximately one-third at the Ph.D. level. The majority of staff members have 15 to
25 years of experience in solving complex scientific and technical problems. Many of our
professionals are radiobiologists, radioecologists, environmental scientists, engineers, health
physicists, chemists, and physicists. Other scientific disciplines include hydrogeology,
metallurgy, geography, biology, epidemiology, toxicology, computer science, mathematics, and
statistics. To complement our technical staff, SC&A also offers expertise in policy analysis,
economics, law, communications, information management, and public outreach and education.

SC&A’s corporate headquarters is located in McLean, Virginia with regional offices in
Montgomery, Alabama, and St. Louis, Missouri. We also maintain a full service radiological
laboratory, allowing us to empirically evaluate radiological issues.

, and its principal, , have unique expertise, experience, and
capabilities to perform key tasks identified in the solicitation, particularly those related to
Department of Energy (DOE) and Atomic Weapons Employer (AWE) site profiles, worker

SC&A ES-1 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST }

Audit Number: Claim Number:

Date:

Page of |

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Tnitial

C23.d

Are calculations of uncertainty associated
with reconstructed photon dose using
survey data appropriate and correct?
(§3.1.2.3)

C23.e

Are calculations of reconstructed photon
dose using source term data appropriate and
correct? (§3.1.3)

C236

Are calculations of uncertainty associated
with reconstructed photon dose using
source term data appropriate and correct?
(§3.1.3.3)

C23.g

Are calculations of reconstructed photon
dose using control limits appropriate and
correct? (§3.1.4)

C2.3.h

Are calculations of uncertainty associated
with reconstructed photon dose using
control limits appropriate and correct?
(§3.1.4.3)

C24
C242,

Photon Dose Conversion to ose:

Are calculations for converting monitored
photon dose to organ dose appropriate and
correct? (§4.1.1)

C2.4.b

Are calculations for converting
survey/source term data associated with
photon dose to organ dose appropriate and
correct? (§4.1.2)

C24.

Are calculations used in the energy
simplification of ICRP 74 dose conversion
factors for input into NIOSH-IREP
appropriate and correct? (§4.1.3)

C16


SC&A 4-23 Sol. No. 2003-N-00768


dosimetry was provided, a better estimate of the electron dose may be obtained through source
term investigations.

For the Photon Dose Reconstruction from a Source Term (item 3.1.3, OCAS-IG-001), it is
advisable to use a computer program, as specified in item 3.1.3.2, OCAS-IG-001. We will use
NIOSH recommended software. If the Task Order does not specify particular software, we will
use a program that uses a voxel phantom to simulate the human body and the Monte Carlo
technique to provide the organ doses for external photon fields in the energy range of 15 keV -2
MeV. The program simulates the source of the radiation, which can be of a complex geometry,
and the shielding, which can include many layers of different material. Using the Monte Carlo
technique, self-shielding and build-up are taken into account. The use of voxel phantoms is the
most modern accepted technique for the simulation of the whole body and is derived from whole
body magnetic resonance image (MRI) scan. The program reports the absorbed dose to each
organ and tissue relevant to the calculation of the effective dose as defined in ICRP 60. Ground
sources or cloud sources may be simulated. The phantom may be placed in a standing, sitting,
lying, or other geometry in relation to the source. Although the program sitnulates multi-energy
photon emission and integrates the dose in each relevant tissue over all energies, it can also be
used to determine the Hp(10) dose and the photon energy spectrum arriving at the voxel
phantom, and therefore permit the application of the Dose Conversion Factors tabled in
Appendix B of OCAS-IG-001. The software may be applied to find the “worst case geometry.”

There are few programs that have all characteristics described above. They are currently used in
different laboratories, but most of them are not commercially available. We will use software that
has been extensively benchmarked against other Monte Carlo programs for simple geometries,
and against physical phantoms with TLDs for more complex geometries. However, this will only
be done with the approval of the Task Order. All guidelines contained in document OCAS-IG-
001 will be used.

Currently, we are inclined to derive the effective dose and organ dose using anthropomorphic
phantoms with the specified ICRP tissues and organs and the radiation transport codé, MCNP4C.
Modified (to include the esophagus and skin) versions of the Pacific Northwest National
Loaboratory male and female MIRD-like anthropomorphic phantom will be used for the
calculations. These modified phantoms are similar to the Adam and Eva phantoms developed in
1982 at Germany’s National Research Center for Environment and Health, GSF.

The anthropomorphic phantoms consist of three principal sections: an elliptical cylinder
representing the arms, torso and hips; two truncated circular cones representing the two legs and
feet; and an elliptical cylinder representing the neck region and lower portion of the head, which
is topped by half an ellipsoid. The gonads and eyes are specified. The arms are not separated
from the torso, and minor appendages such as fingers, feet, ears, chin and nose are omitted.
Internal organs are approximated by simple mathematical equations describing the average
shapes and sizes. .

Each internal organ is considered to be homogeneous in composition and density. Different
compositions and densities are used for the lungs, skeleton, and the total body minus the skeleton

SC&A 3-23 Sol. No. 2003-N-00768


one week of full time work. Bone surface doses over a one-week exposure period

. would range from about 400 rem to almost 2,500 rem, depending on working
conditions and thorium solubility. We do not have a basis on which to select a
mix of solubilities based on the available data. If the work was carried out for
several weeks, then the dose estimates would be correspondingly higher.

Overall, it appears that exposures to specific workers who worked on thorium
may have been severe. We have not been able to assess cumulative thorium
exposures in a manner similar to uranium since we lack even minimally adequate
air concentration data over the requisite period of time. Our estimate of thorium
exposures corresponding to one week’s work indicates that, for some workers,
thorium exposures may have been comparable to and perhaps greater than
uranium exposures. Finally, if some workers worked on both uranium and
thorium, those exposures would be additive.

The dose estimates above were made from workplace air concentration data. Worker interviews
regarding the amount of time for which thorium was processed could be critical in cases like this
to make an estimate of the dose, since the documentation for this was not contained in the facility
profile that was available to the dose reconstruction personnel.

Example 2. Recycled Uranium

Recycled uranium was processed at a number of facilities (both DOE-owned and FUSRAP).
Trace transuranic radionuclides (Pu-239/240, Np-237) can make a significant contribution to the
worker dose. However, the levels of transuranics in recycled uranium varied by orders of
magnitude, ranging from levels which would play no significant role in the dose to important
contributors to dose. A crucial parameter in determining this would be the stage of processing at
which the worker handled the uranium. For instance, plutonium concentrations at Paducah were
higher at the fluorination tower relative to several other places and steps of processing. Specific
job descriptions are therefore very crucial, since plant air monitoring data and biological
measurement data usually do not contain radionuclide-specific information. Similarly,
information on whether respirators were used is also important.

In light of the above, estimating the contribution of transuranics in recycled uranium processing
is typically very difficult and involves carefully combining worker interviews, worker monitoring
records, plant air monitoring data, and production data in facility profiles. Auditing worker
interviews to determine whether they had adequately covered the worker’s history with recycled
uranium could be a critical component of individual dose audits at many DOE and FUSRAP
sites. Coordinating facility profile and worker interview data across facilities may also be
insightful. For example, recycled uranium at Fernald came from Paducah.

SC&A 3-9 Sol. No. 2003-N-00768


ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Coumments

F241

Are data in the Site Profile related to facility
operations and processes, which are applicable
to the claimant’s case, adequate and complete?

F22

Are data in the Site Profile related to
radiological source term characterization, which
are applicable to the claimant’s case, adequate
and complete?

Are data in the Site Profile related to workplace
conditions and monitoring practices, which are
applicable to the claimant’s case, adequate and
complete?

Are data in the Site Profile related to
incidents/accidents involving radiological
exposures, which are applicable to the
claimant’s case, adequate and complete?

Are relevant Site Profile data consistent with
information used to reconstruct external dose?

Are relevant Site Profile data consistent with
information used to reconstruct interna dose?

C-44


SC&A 418 Sol. No. 2003-N-00768


SC&A, its team members, nor the individuals working on the contract become involved in any
COI situations as they might relate to the proposed work. Thus, our plan will be finalized after it
is approved by the Advisory Board.

The Administrator of our OCI Plan will be Ms. Laurie Loomis. Ms. Loomis is Certified as a
Professional Contracts Manager and a Federal Contracts Manager by the National Contract
Management Association, and has 12 years of experience in government contracting. She is
Manager of SC&A's Administrative Services Division and reports to Dr. Sanford Cohen, the
President of SC&A. As an employee-owner of SC&A and the Contracts Manager, Ms. Loomis
will have a profound interest in ensuring the absence of conflict of interest. She is also the most
knowledgeable individual at SC&A about the extent and detail of each of our contracts. She will
work with the Advisory Board in finalizing SC&A’s OCI plan and keeping it current, and will
manage the plan internally. She will ensure that all team members and individuals working on
the project are trained in the provisions of the plan and comply with its.procedures. She will be
responsible for obtaining and filing evaluator certifications, and will work with Dr. Cohen in
identifying any potential conflicts of interest and reporting them immediately to the Advisory
Board.

It is important to point out that SC&A is a relatively small, tightly managed firm with a history of
strict compliance with COI constraints quite similar to those envisioned under this proposed
work for the Advisory Board. Our top management is acutely aware of these constraints, and
will work closely with the Board to ensure that conflicts of interest are avoided. SC&A will also
be mindful that team members who are performing extensive nondosimetry work for DOE or
DOE contractors may pose a perception concern for claimants. Such tasks will be judged on a
case-by-case basis to determine whether the nature of the work would lead to such perceptions.

2.6.1 Work History

By virtue of our work for Federal regulatory agencies described in Section 5, any work for DOE
and DOE contractors has been severely curtailed. SC&A has never held a DOE prime contract.
However, we do perform laboratory analysis services for DOE offices and contractors in our
Southeastern Environmental Laboratory located in Montgomery, AL. Samples potentially
containing very low levels of environmental contamination are shipped to the laboratory for
analysis of radionuclide content. Our longest running contract for these services is with the
Kaiser Hill Company (KH 020512), who is responsible for the remediation of the Rocky Flats
Plant. We have provided these services for approximately six years. For approximately two
years, we have held similar contracts with Bechtel Nevada Corporation (Subcontract No. 30025),
who operates the Nevada Test Site, and Westinghouse Savannah River Company (AC17824N
and AC23323N), operator of the Savannah River Site (SRS). Additionally, in January, 2003,
SC&A's Southeastern Environmental Laboratory received an order from DOE’s Golden Field
Office to analyze 12 samples. None of this work is concerned with radiation dosimetry, nor
is it related in any way to any of the elements of the scope of work of the subject
solicitation. Therefore, our laboratory work for DOE contractors is not in conflict with the
proposed work for the Advisory Board. .

SC&A 2-15 Sol. No. 2003-N-00768


The management of a large contingent of subcontractors is not a new venture for SC&A. We
have successfully managed as many as 68 subcontractors on a previous LOE contract for EPA.
Where required, we obtained consent from the Contracting Officer prior to placement, and the
subcontracted work was performed within the labor hour and cost limitations of the approved
subcontractors. With very few exceptions, subcontractor costs on individual work assignments
were maintained within the limitations of their original cost estimates.

2.4.3 Problem Resolution

It is SC&A standard operating procedure to prepare a work plan for every task order received
from its clients. Potential problems or schedule slippages arising from each task order assigned
by NIOSH will therefore be identified during the development of the technical and cost proposal
in response toa TORP. Thus, if anticipated problems should arise during the performance of a
Task Order, potential strategies will be available to deal with them. Of course, it is difficult to
predict the precise nature of a future problem. However, the intimate involvement of the Project
Manager, Deputy Project Manager, and Case Managers in all aspects of the work, from early
development of the work plan through completion of each case and Task Order, offers the
Advisory Board the confidence that problem areas will be identified as early as possible and
resolved promptly.

In addition, this proposal envisions a strong commitment on the part of the Project Manager, the
Deputy Project Manager, and the Case Managers, who will meet frequently with the Project
Officer and Advisory Board members. SC&A believes in keeping its clients informed of any
potential problems and implementing safeguards early in the process. When a schedule delay is
unavoidable, the SC&A Project Manager will work with the Project Officer and Advisory Board
to minimize the impact of any delay on the overall project goals.

Changes in Program Direction

The proposed Project Manager has considerable experience with changes in program direction.
Recently, Dr. demonstrated the capability to address change in an SC&A contract with
NRC ( NRC-04-01-049, Technical Basis Information for Clearance of Materials and Equipment;
NRC Project Officer Dr. Carl Feldman). The project scope and schedule of this contract were
modified on two separate occasions to accommodate the changing demands of the project.
SC&A’s ability to recognize changing client needs, access appropriate and highly specialized
staff through Associate arrangements, and select subcontractors who supplement SC&A skills
renders us more than able to respond to changes in program direction both quickly and
efficiently. Should a concem arise that a change may be needed in program direction, the Case
Manager will immediately inform the Project Manager, Deputy Project Manager, and the Project
Officer and/or Advisory Board representative. The issue will be discussed, and SC&A will either
continue work while the issue is being resolved or stop work until the issue is resolved.

SC&A 2-11 Sol. No. 2003-N-00768


SC&A 422 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

| Audit Number: Claim Number: Date: Page of
Set
Area of |Description of Technical Elements of Review | Yes/No/ Comments Tnitials
Review NA

Are assumptions associated with uncertainty
surrounding the estimated intake quantity
using workplace monitoring data
conservative (claimant friendly)?

Occupational Radon Exposure:

Are assumptions used to determine dose
from occupational radon exposure
appropriate?

Are assumptions associated with uncertainty
surrounding the radon dose estimate
appropriate?

‘Are assumptions used to determine dose
from occupational radon exposure
conservative (claimant friendly)?

Are assumptions used to assess the
uncertainty surrounding the occupational
radon dose conservative (claimant
friendly)?



ee

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

—<—= =

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/Nof
NA

Comments

Initials

D2.3.b

Are uncertainty calculations associated with
the quantities of each radionuclide for each

intake based on bioassay measurement data
appropriate and correct? (§7.2 and §8.7)

D23.¢

Are calculations for determining missed
internal dose associated with bioassay
Measurements below detection limits
appropriate and correct? (§7.3)

D.2.3.d

Are calculations for estimating internal
dose when there are gaps in bioassay
measurements appropriate and correct?
(86.3)

D23.e

Are calculations for reconstructed internal

dose using co-worker data appropriate and
correct? (§5.1)

D234

Are uncertainty calculations associated with

worker data appropriate and correct?

the reconstruction of internal dose using co-

D2.3.g

Are calculations to estimate the
concentration of each radionuclide in the
breathing zone using workplace monitoring
data (e.g., air samples, contamination
surveys, etc.) appropriate and correct?

(85.2)

D23.h

Are calculations to estimate internal dose
using workplace monitoring data
appropriate and correct?

2

D234

monitoring data appropriate and correct?

Are uncertainty calculations associated with
estimating intake quantities using workplace

_——— a

C-36


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials}
Review NA
E. NIOSH PROCEDURE/METHODOLOGY REVIEW PROCESS
E.1 Review of NIOSH Methods and/or Procedures: The review of each dose reconstruction shall include an

evaluation of all relevant portions of the methods and/or procedures used by NIOSH.

Ell
E.l.la

External Dose Technical Basis
Documents/Methods:
Are the technical basis documents used in
reconstructing external radiation doses
adequate and appropriate? .

E.l.1b

Are methods for estimating ‘missed,’
‘incomplete,’ and/or ‘unmonitored’ external
dose adequate and appropriate?

E.1.Lc

Are statistical approaches developed for
multiple external dose reconstructions
appropriate?

E.L.1d

‘Are procedures used for determining
whether data is sufficient to make a
reasonable external dose estimate
appropriate?

Elle

Are methods/procedures used for
substituting external exposure information
for unavailable or incomplete information
adequate and appropriate?

BLE

Are methods for estimating uncertainty in
dose associated with external dose
reconstructions on a facility and time
specific basis appropriate?

Elig

Are appropriate methodologies used to
resolve uncertainty estimates associated
with external dose in favor of the claimant?

c-40


SC&A

2-23

Sol. No. 2003-N-00768


ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
f Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

G. ADDITIONAL INTERVIEW AND CLAIMANT DOCUMENTATION REVIEWS
G.1 Interview/Claimant Documentation Review: Evaluate the effectiveness of the phone interview in ascertaining

relevant work history information.

GAL Was the phone interview effective in confirming
applicable elements of the employment history
as included in the claims package provided by
DOL?

G12 Was the phone interview effective in identifying
any relevant information on employment history
that may have been omitted?

G13 Was the phone interview effective in confirming
or supplementing monitoring data provided in
the initial radiation exposure record?

G14 Was the phone interview effective in identifying
undocumented radiation exposures as a result of
work tasks, production processes, radiological
protection and monitoring practices, and/or
incidents?

GAS Was the phone interview effective in identifying
co-workers and/or other witnesses who could
potentially supplement or confirm radiation

‘| exposure information and/or work experiences
in behalf of the covered worker?

C46


individual and collective dose assessments to determine the radiological impacts of alternatives
for the. clearance of materials and equipment. Both projects involve the development of Monte
Carlo-based multimedia dose assessment models for evaluating individual and collective doses to
workers and the public, including formal assessment of uncertainties and variabilities. The
models make extensive use of ICRP methodologies for performing internal and external
exposures.

5.2 Defense Nuclear Facilities Safety Board Support

SC&A was a technical support contractor to the DNFSB from 1993 through 1997. DNFSB was
established by Congress in 1989 as an independent agency to provide advice and
recommendations to the Secretary of Energy on public health and safety at DOE defense nuclear
facilities. Fourteen tasks were ordered during the four years that SC&A held the contract.
(DNFSB eventually brought the work in-house.)

SC&A developed a Standard Review Guide (SRG) on Radiological Training under the DNFSB
contract, which was intended to be the first of a series of guides that would comprehensively
relate to radiological protection. SC&A also reviewed several implementation guides under the
DOE rule on occupational radiation protection, 10 CFR Part 835, and compared them with
applicable commercial and government standards, assessing their technical content with the
guidance that has been given to commercial utilities. The lessons learned from these programs
provide insight into the strengths and limitations of historic DOE radiation protection programs
vis-a-vis NRC regulated programs.

It is important to note that all of these investigations that SC&A performed for our Government
clients required auditable QA/QC programs performed under fully documented pre-approved
Quality Management Plans and Quality Assurance project procedures which implemented those
plans for each project. Our documentation had to be complete, transparent, and was audited by
our clients on numerous occasions. During your review of our past performance on these
projects, you will have an opportunity to judge the responsiveness and quality of our work.

5.3 ° Dose Reconstruction Support to Centers for Disease Control

In January 1990, the Secretaries of the Departments of Energy (DOE) and Health and Human
Services (DHHS) signed a Memorandum of Understanding (MOU) transferring to DHHS
responsibility and funding for studies of chemical and radionuclide releases from DOE nuclear
facilities, and of potential exposures and health effects to the surrounding population. The
primary purpose of this transfer of responsibility was to avoid any perceived or actual conflict of
interest associated with DOE performing the historical dose evaluations for facilities for which it
has operational responsibility.

Under the authority of the MOU, the Radiation Studies Branch (RSB) of the CDC began its
independent investigations into the historical doses at the INEEL in 1992. The first phase of
these investigations began with the retrieval of approximately 15,000 boxes of records and the
creation of a bibliographic database containing titles and abstracts of reports, records, and
documents pertinent to the historical operations, radionuclide emissions, and radiation exposure

SC&A 5-4 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

Area of
Review

of

Description of Technical Elements of Review

Yes/No/
NA

Comments

C.14c

Are assumptions incorporated in the
reconstruction of photon dose using survey
data appropriate? (§3.1.2)

C14.

Are assumptions for determining
uncertainty associated with reconstructing
photon dose using survey data appropriate?
(§3.1.2.3)

C.1.4e

Are assumptions incorporated in the
reconstruction of photon dose using source
term data appropriate? (§3.1.3)

CAE

Are assumptions for the uncertainty analysis
associated with reconstructing photon dose
using source term data appropriate?
(§3.1.3.3)

C.1.4g

Are assumptions incorporated in the
reconstruction of photon dose using control
limits appropriate? (§3.1.4)

CA4h

Are assumptions for determining
uncertainty associated with reconstruction
photon dose using contro! limits
appropriate? (§3.1.4.3)

CAG

Are conservative (claimant friendly)
assumptions used for reconstruction of
photon dose, when no monitoring data were
available?

C145

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
photon dose, when no monitoring data were
available?

C7



ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review { Yes/No/ Conments Initials
Review NA

H. ADDITIONAL EXTERNAL DOSE RECONSTRUCTION REVIEWS

H.1 Consistency of Data: Evaluate whether the external dose estimate is consistent with relevant radiological
information within the NIOSH site profile.

Had

Is there reasonable consistency between.
assumptions used to estimate external dose and
process information (e.g., radionuclides and
quantities present and processed) provided in
the Site Profile?

Ts there reasonable consistency between
assumptions used to estimate external dose and
routine radiation monitoring practices identified
in the Site Profile?

H.13

Is there reasonable consistency between
assumptions used to estimate external dose and
routine protective measures used at the site (e.g.,
glove boxes, shielding, etc.) identified in the
Site Profile?

H.2 Comparison of Case Information: Compare case information and assumptions associated with external dose
with relevant co-worker case information and assumptions associated with external dose for consistency.

H.2.1 Ts there consistency between monitoring data
used to calculate external dose for the covered
worker and monitoring data used to calculate
external dose for a relevant co-worker case?

H.2.2 Is there consistency between assumptions used

to reconstruct unmonitored external dose for the
covered worker and assumptions used to
reconstruct unmonitored external dose for a
relevant co-worker case?

C48



. Historic radiation protection programs in place, including personnel monitoring
requirements, protective equipment practices, dosimetric techniques and
equipment in use, and procedural enforcement history (important to determine
whether and to what degree the dosimetry program reflected actual potential
exposures possible, given source terms involved).

. Worker rosters with identifiers, work assignments and location, as well as
summary of work histories sufficient to determine what categories of workers
were assigned to what type and locations of radiological work.

It would be useful to have data on the number of monitored workers, number of workers with
doses higher than the minimum detectable levels, average measurable recorded doses, minimum
detection levels, and whether doses below the detection limit were recorded as zero. Even better
would be to have data on the number of workers in specified dose ranges.

The foregoing information will be used in a comparative manner to ascertain whether the site
profiles are complete in how they characterize, from a historic standpoint at a particular site,
what radiological materials were present and in what concentrations and chemical forms; what
worker groups may have been in proximity with sources of exposure and whether certain
activities or unplanned events may have made such exposure likely; and what administrative
procedures, operational practices, protective equipment use, and facility conditions may have
influenced the likelihood of such exposure. The quality of the profile will be evaluated by what
can be termed “exposure mapping.”

>

3.5.2 Conducting “Exposure Mapping’

Exposure mapping will be used to evaluate the extent to which the profile provides information
that can characterize the potential radiation exposure to which workers may have been exposed
in specific work activities and locations or time periods at the site in question. Sources of
information include published site reports, memoranda, area monitoring data, process
descriptions, and general worker exposure summary information. Higher activity radiological
sources in the facility’s process streams will be linked to those worker categories and locations
where potential exposure levels were highest.

An example of the types of published information that can provide historical site information that
can be very helpful in preparing and reviewing site profiles is “Exposure Assessment Project at
the Paducah Gaseous Diffusion Plant,” prepared by PACE and the University of Utah on behalf
of the DOE Office of Environment, Safety, and Health (September 2000). Table 7-3 from that
report is one example of the outcome of an historical exposure mapping for the Paducah Gaseous
Diffusion Plant. This type of information can be compiled for virtually any site, and can be
extremely valuable in a blind dose reconstruction and in an advanced review of a NIOSH dose
reconstruction.

3.5.3 Reviewing Relevant Data Sources

SC&A 3-15 Sol. No. 2003-N-00768


5.0 CORPORATE EXPERIENCE

SC&A currently has approximately 30 employees and approximately 100 associates. More than
75 percent of SC&A’s professional staff have advanced degrees. The majority have 15 to 25
years experience solving scientific and technical problems and implementing solutions to
radiation and radiation-related issues. SC&A personnel are primarily engineers, health
physicists, chemists, and physicists. The engineering staff is composed of nuclear, chemical, and
environmental professionals, many with professional registration. About one-fourth of the health
physics staff are Certified Health Physicists, and almost all the chemists are radiochemists. Other
disciplines include computer science, metallurgy, and hydrology. The following presents
SC&A’s corporate organizational chart.

SC&A Organizational Chart

Sanford Cohen
President
f Executive Officer

Gregory Beronja Laurie Loomis
Vice President z Vice President
Chief Operating Officer ff Administrative Services

Nancy S. Johnson Linda Foley
Production Coordinator ‘Accounting Manager

John J. Mauro Charles (Chick) Phillips |g | William Ulicny, Manager [gj Patrick Kelly, Manager
Senior Vice President Vice President Radiation Field Quality Assurance

Consulting Division Laboratory Division Services Division Division

Since its founding, SC&A has provided primarily radiological consulting services to Federal
agencies under large, task order, cost plus fixed fee contracts. Our principal clients have been
and continue to be the CDC, the NRC, the EPA (particularly ORIA/EPA), and the Republic of
the Marshall Islands (RMI). We have also held large contracts with the DNFSB and the
Congressional Office of Technology Assessment (OTA). The important point is that our primary
business is providing the highest quality radiological consulting services to Federal agencies,
especially agencies that provide independent regulatory oversight to the DOE and its contractors.
From the perspective of being qualified for providing the services required by this contract, and
still being free of any real or perceived conflict of interest, SC&A is in a very unique position.
The only significant amount of work that we perform for DOE is laboratory services for some
DOE contractors, and we do no work for NIOSH.

SC&A 5-1 Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST

continued

Description

Comments | Initials

YesINo/NA_|

TYPES OF INFORMATION USED IN DOSE RECONSTRUCTION
Taken directly from 42 CFR 82.14.
This is simply a guideline. Each case is different and not all of the types
of information listed below may be necessary.

1. “Subject and employment information:”

(a) “gender”

(b) “date of birth”

() “DOE and/or AWE employment history:

(i) job title held by year

(ii) work location (site names, building numbers,
technical areas, duration of relevant
employment)”

2. “Worker monitoring data”:

(a) “external dosimetry data (film badge, TLD,
neutron dosimeters)”

(b) “pocket ionization chamber data”

3. “Internal dosimetry data:”

(a) “urinalysis results”

(b) “fecal sample results”

(c) “in vivo measurements results”

(d) “incident investigation reports”

(e) “breath radon and/or thoron results”

(f) “nasal smear results”

(g) “external contamination measurements”

(h) “other measurement results applicable to internal
dosimetry”

4. “Monitoring program data”

(a) “analytical methods used for bioassay analyses”

(b) “performance characteristics of dosimeters for
different radiation types”

(c) “historical detection limits for bioassay samples
and dosimeter badges”

(d) “bioassay sample and dosimeter
collection/exchange frequencies”

(e) “documentation of record keeping practices used
to record data and/or administratively assign dose”

(f) “other information to characterize the monitoring
‘ogram results”

SC&A

3-33

Sol. No. 2003-N-00768


. In 1995, under subcontract with SAIC, SC&A evaluated the potential of treatment
technology for soils at FUSRAP sites.

. In 1995, under subcontract with Brookhaven National Laboratory, SC&A
developed an Arctic Information System that applied to Siberian Russia (under an
EPA prime contract).

. From 1992 to 1994, under subcontract with Analytical Services Inc., SC&A
reviewed environmental impact statements for the DOE Office of NEPA
Compliance.

. In 1993, under subcontract with Battelle Pacific Northwest Laboratories, SC&A
performed tasks related to environmental management support.

. In 1993, under subcontract with Roy F. Weston Corporation, SC&A provided
environmental consulting assistance in connection with the Yucca Mountain high-
level nuclear waste repository.

Since none of this work is concerned with radiation dosimetry nor with any of the elements
of the scope of work of the subject solicitation, it does not constitute a conflict with the
proposed work for the Advisory Board. Moreover, only one small project (for Argonne
National Laboratory) was performed within the last two years.

SC&A has also searched its records to identify any work performed for AWEs and AWE
contractors,’ searching its contracts’ records against the list of AWEs given in the Federal
Register on December 27, 2002. SC&A identified the following AWEs for which work was
performed over the past 10 years:

° SC&A is currently providing, and has provided on several occasions, _
environmental support to General Electric Corporation, none of which is related to
atomic energy or radioactivity.

. In 1997, under subcontract with Raytheon Engineers and Constructors, SC&A
performed environmental analysis support to the West Valley Demonstration
Project (this was also listed above under work performed for DOE contractors).

3 Please note that SC&A used its best efforts to identify AWE contractors for which it has performed work.
In particular, SC&A believes that it has identified all instances of its work over the past 10 years performed for
AWEs using contractual vehicles with AWE contractors. However, SC&A does not certify that it has identified all
of its work for AWE contractors, since the list of all AWE contractors is not available, to the best of SC&A’s
knowledge. Moreover, SC&A does not believe that the Advisory Board is necessarily interested in work for AWE
contractors unless the work is related to AWEs.

SC&A 217 Sol. No. 2003-N-00768


SC&A 41 Sol. No. 2003-N-00768


caused by exposure to radiation received by the claimant during the course of performing his or
her duties at a DOE facility or Atomic Weapons Employer (AWE) facility as listed in the
Federal Register, Volume 66, Number 112, page 31218, June 11, 2001, and as revised in
subsequent notices. In accordance with 42 CFR Part 82, the results of these probability-of-
causation calculations, as derived using IREP, are used by the DOL for determining whether the
individual with cancer is found “at least as likely as not” to have sustained the cancer from work-
related exposures to ionizing radiation.

We understand that the reconstruction of doses is concemed with the dose delivered to particular
organs over specific time periods and not the total effective dose commitment. In addition,
“missed dose” is of particular concern to a dose reconstruction. As such, this program differs in
many important ways from the dose assessments performed for the purpose of demonstrating
compliance with radiation protection standards.

SC&A understands that a critical factor affecting how doses are reconstructed is the amount of
time available to adjudicate the claims. The claimants, because of their medical conditions, are
especially entitled to a speedy resolution of their claims. In response to the EEOICPA, the dose
reconstruction process is not a research project, as it is for many of the offsite dose
reconstructions being performed by the Centers for Disease Control and Prevention (CDC).
Under the NIOSH program, a delicate balance must be struck between efficacy and precision. A
high level of precision, when not required to support an adjudicated decision, will only
unnecessarily delay the decision-making process. SC&A believes that implementing dose
reconstructions with a full appreciation of this balance is critical to the success of this project.
This overarching principle applies to the dose reconstructions performed by NIOSH, the reviews
of the dose reconstructions that will be performed on this project on behalf of the Advisory
Board, and the review of SEC petitions. Nevertheless, the dose reconstructions and reviews of

SEC petitions must be fair, consistent, and well grounded in the best scientific knowledge. They
must also give the benefit of the doubt to the claimant.

It is SC&A’s understanding that our role on this project is to assist the Advisory Board in the
fulfillment of its mission under Section 3624 of the EEOJCPA, specifically Section (b)(2), which
states, “The Board shall advise the President on the scientific validity and quality of dose
estimation and reconstruction efforts being performed for purposes of the compensation
program.” In addition, our role is to assist the Board in fulfillment of its mission under Section
3626 of the EEOICPA (and draft 42 CFR Part 83) related to the review of SEC petitions.

In formulating our concept of operations for this project, we struggled with the degree to which
we, as consultants to the Advisory Board, will comment on the validity of any given adjudicated
decision. Unless specifically requested by the Board, we believe that such commentary goes well
beyond our mandate. It is our understanding that we are not part of an appeals process. We are
simply to help the Board probe technical issues, to reveal and gain insight into areas where the
dose reconstructions may have had problems, and to seek out possible systematic errors or biases
in the way in which the doses are reconstructed. We believe we can best serve the Board by
being a source of highly credible analysts that, in the end, will provide confidence to all

SC&A 1-3 Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST
continued

Description [_YeyNo/NA Comments Initials |
5. “Workplace monitoring data”

I

(a) “surface contamination surveys”

(b) “general area air sampling results”

(c) “breathing zone air sampling results”

(d) “radon and/or thoron monitoring results”

(e) “area radiation survey measurements (beta, gamma
and neutron)”

(f) “fixed location dosimeter results (beta, gamma, and
neutron)”

(g) “other workplace monitoring results”

6. “Workplace characterization data”

(a) “information on the external exposure
environment:

(i) radiation type (gamma, X-ray, proton, neutron,
beta, other charged particles)

Gi) radiation energy spectrum

(iii) uniformity of exposure (whole body vs.
partial body exposure)

(iv) irradiation geometry”

(b) “information on work-required medical screening
X-rays”

(c) “other information useful for characterizing
workplace radiation exposures”

“Information characterizing internal exposures”
(a) “radionuclides and associated chemical forms”

(b) “results of particle size distribution studies”

(©) “respiratory protection practices’

(d) “other information useful for characterizing
internal exposures”

8. “Process descriptions for each work location”

(a) “general description of the process”

(b) “characterization of the source term (radionuclide
and its quantity)”

(c) “extent of encapsulation”
(d) “methods of containment”

(e) “other information to assess potential for
irradiation by source or airborne dispersion of
radioactive material”

SC&A 3-34 Sol. No. 2003-N-00768


Due to the importance of ensuring that assumptions used to estimate doses are fair, consistent,
and scientifically grounded, a special topic that must be re-emphasized is the need to compare all
available data (i.e., worker profile data, site profile data, work history interview, claimant
documentation, etc.) and evaluate them for consistency and reasonableness. Data comparisons
should not be limited to information available for an individual case, but when applicable, should
also include comparisons between similar cases.

3.8.9 Auditor’s Assessment of a Case Significantly Differs with NIOSH’s Dose Reconstruction
Results

There may be cases during the basic, advanced, or blind review where the auditor identifies new
information or uncovers inappropriate/unreasonable assumptions, calculational errors,
inconsistencies in data, etc., that will substantially increase the dose and potentially change the
outcome of a denied claim. When it appears that the auditor’s findings could result in a PC of
greater than 50 percent, it is recommended that the auditor(s) have an opportunity to present this
case to the Advisory Board for further review.

SC&A 3-40 Sol. No. 2003-N-00768


TABLE OF CONTENTS

1.0 | UNDERSTANDING THE PURPOSE AND OBJECTIVES .......--------0+0-+ 1-1
2.0 | MANAGEMENT APPROACH ..........-020-000 eee e eee e cence eee eens
2.1 Project Organization ...
2.2 Flowof Work ......... .
2.3. Procedures and Training .................20--
2.4 | SC&A Methodology to Ensure Completion of Tasks
2.4.1 Management of Complex, Multi-Task and Multi-Disciplinary
Contracts 2.0.2.0... 02. eee eee eee
2.4.2 Subcontractor Management ..
2.4.3 Problem Resolution
2.44 Flexibility of the SC&A Organization
2.5 Quality Control Procedures :
2.6 Conflict of Interest Management .............. 0600 e eee eee eee eee
2.6.1 Work History ... 2.2.0.0... ect eee ee
2.6.1.1 Subcontractor Work History . :
2.6.1.2 Key Personnel Work History .......---..-0+--2e eee 2-20
27 Confidentiality and Security Provisions ........-..6- 402+ eee e cere eens 2-32
3.0 TECHNICAL APPROACH .
3.1 Concept of Operations
3.2. Preparation of Technical and Cost Proposals in Response to Task Order
Request Packages .......... 0. 2c cece cece cee eee eee eens 2+. 3-2
3.3 Procedures for Performing Basic and Advanced Reviews 34
3.3.1 External and Internal Dosimetry Review Procedure and Checklist . .. . 3-6
3.3.2 Claimant Interview Review Procedure and Checklist . 3-6
3.4 Procedures for Worker Profile Reviews ........-..--- .
3.4.1 Quality and Reliability of the Database
3.4.2 Completeness of Records Incorporated
3.4.3 Characterization of Historic Radiation Protection and Dosimetric
Practices 2.2... ccc eee eee ete ne ees 3-13
3.5 Reviewing Site Profiles ... 2.0... 20. o cece eee eee eee 3-13
3.5.1 Reviewing Site Operational History 3-14
3.5.2 Conducting “Exposure Mapping”
3.5.3. Reviewing Relevant Data Sources ...-..-. 2-2 ++ 0-2 sees e eee eee 3-15
3.5.4 Interviewing Sources of Site Knowledge . 3-16
3.6 Blind Dose Reconstruction .. 3-17
3.7 Special Exposure Cohort Petition Reviews .
3.8 Special Topics
3.8.1 Special Attention to Historical Bioassays and Dose Reconsiructions - 3-35
3.8.2 Use of Specific Values of the Human Respiratory Tract Model
(HRTM) Parameters .. 2... eee 3-36
SC&A i Sol. No. 2003-N-00768




these developments, so that they can be given appropriate consideration as the Board fulfills its
mandate. New developments that are worth mentioning include:

.

HAT - The new model for the Human Alimentary Tract, in substitution to the
ICRP 30 Gi Tract Model, is in its final draft. It is probably going to be released in
early 2004. The new HAT model will be used in the future by ICRP in
substitution for the ICRP 30 model.

Publication of a new document, Occupational Intakes of Radionuclides: Dose
Assessment and Monitoring (Revision of Publications 30, 54, 68, 78). The new
document will contain revisions of the systemic models; most of the models will
be recycling models for easier bioassay interpretation. Whenever information is
available, physiologically based models will be recommended.

In relation to inhalation, information relating to absorption rates from the lungs to the
blood for important compounds will be recommended and other compounds will be
assigned to the three absorptions: Types F, M, S. In addition, the gender-specific
doses will be calculated using realistic computational models (phantoms), derived
from medical images, with organ sizes consistent with the new reference person
(ICRP 89, 2002).

A review of individual monitoring methods and programs, as well as interpretation of
bioassay results, will be given. A review of sources of uncertainty in the estimate of
intakes and doses will be included. A technical document on Interpretation of
Bioassay Monitoring will be published at the same time as the main document.

The biokinetic models for radionuclide contaminated wounds, which are being
developed by the National Council on Radiation Protection (NCRP), will be
reviewed by the ICRP and possibly be adopted.

A complete review of tritium compounds biokinetics is being performed and a
complete review of radon dosimetry is expected in the near future.

3.8.6' Additional Issues Related to Internal Dose Reconstruction

The reconstruction of internal dose is frequently complex, highly individualized, and defined by
variables that are largely unknown. Even when credible bioassay data exist, estimates of internal
dose(s) may, nevertheless, require process knowledge and professional judgment regarding the
applicability of standard dose models in terms of the assigned chemical form, solubility,
exposure pathway(s) for a radio-contaminant, etc. Among the variables that may profoundly
affect the uncertainty of internal dose estimates are the following:

Time of Uptake. Whole-body counting (WBC) and/or in-vitro bioassay data are
of limited value if the “day(s) of uptake” is not known. This uncertainty is
particularly problematic if the WBC/bioassay is one that is termed routine (i.e.,
conducted annually/periodically or upon termination). To assist in narrowing the
window of exposure to a most probable time period, the reviewer must consider

SC&A

3-38 Sol. No. 2003-N-00768


SC&A 424 Sol. No. 2003-N-00768


SC&A 49 Sol. No. 2003-N-00768


. Were there any incidents involving potential radiation exposure, whether reported
or unreported?

. Were there special work activities or facility modifications which constituted
process changes that increased radiation exposure potential?

. Were workers concerned about past exposure or radiation protection practices?
How did management respond and what, if any, changes occurred in onsite
practice?

. Did workers wear protective equipment, as required?

° Were radiological jobs planned for exposure minimization (e.g., ALARA)?

. What was the general housekeeping in the facility; was radiological contamination

common during the history of the facility?

. Were there special feed materials introduced or contaminants of concern
identified from which radiation exposures may have resulted?

. Were there certain work activities at the facility that were considered “hotter” jobs
from the standpoint of potential radiation exposure?

. Were safety procedures followed literally and did management assure that they
were enforced uniformly?

° In terms of conduct of operation, were workers permitted to smoke, eat, or drink
in control areas? Was protective clothing and equipment worn in these areas; was
egress monitoring conducted?

. Were negative or “zero” doses recorded on periodic dosimetric records despite
known exposure to significant radiation sources?

. Were records and other documentation of radiation exposure discarded or retained
by management?
. Were there cases of over-exposed film and how were they treated?

The information extracted from these interviews will be used to ascertain the completeness and
representation of that in the NIOSH site profiles.

3.6 Blind Dose Reconstruction
A great deal of information, procedures, and guidelines are provided throughout this proposal

that demonstrate how we will go about performing basic and advanced reviews, worker profile
reviews, and site profile reviews. Given this as background, suffice it to say that our procedures

SC&A 3-17 Sol. No. 2003-N-00768


source records exist. For many sites, source records, such as old dosimeter readouts, microfiche
urinalysis results, and incident reports with estimated exposures can be located through deliberate
inquiry and onsite searching. In other instances, databases have been compiled in the past as part
of broader worker dose surveys, epidemiological studies, or summary radiation dose reporting. It
needs to be ascertained that all such databases have accessible identifiers. Some summary
teports, such as the Radiation Exposure Information Reporting System (REIRS), have originating
identifiers that are maintained by the project manager.

To determine the completeness of records available to the NIOSH worker profile, it may be
necessary to make inquiries of workers and records management personnel] at some sites. The
purpose of these inquiries is to identify the possible availability of records (with identifiers)
based on recollections of programs, incidents, or procedures where monitoring may have taken
place, and where corresponding records may have been maintained. In the early years, these are
often at the facility or operations level and may not have been compiled in formal radiation dose
records. SC&A will make inquiries to independently verify that the profile is complete from this
standpoint.

3.4.3 Characterization of Historic Radiation Protection and Dosimetric Practice:

Another issue is whether the appropriate caveats and limitations of the profile data are reflected.
Each site radiation dosimetry program had a unique history and technical evolution. Some sites
have conducted retrospective dose reconstructions to develop a reliable historic worker dose
database and have reflected the limitations and qualifications associated with the dose values
cited for individuals. Others have simply collected and reproduced available dose records
without any effort to acknowledge or compensate for the inadequacies or incompleteness of the
resulting database. Tritium and neutron doses were included and recorded for the first time at
varying times at different sites. Urinalysis policy and recording thresholds vary widely as a
function of radionuclide, operation, and site. Certain radiological source terms, such as trace
contaminants in process streams, were not measured routinely, and what exposure records exist
can be found in operational reports estimating doses to workers on a particular process line.
SC&A will review the historic status of site radiation records for selected worker profiles and
ascertain whether the dose information provided is consistent with them.

3.5. Reviewing Site Profiles

SC&A will review selected site profiles as determined first by NIOSH direction, and second by
relevant aspects of site profiles associated with cases undergoing advanced dose reconstruction
review (the latter will provide a two-for-one economy of work that will support both sampling
objectives).

The NIOSH site profile database is designed to support the conduct of individual dose
reconstructions by compiling data other ‘than dosimetric information, such as that related to
facility operations and processes over time, radiological source term characterization, chemical
and physical forms of the radionuclides, historic workplace conditions and practices, and
incidents and accidents involving potential exposures. SC&A will evaluate the quality and

SC&A 3-13 Sol. No. 2003-N-00768


2.4 SC&A Methodology to Ensure Completion of Tasks

2.4.1 Management of Complex, Multi-Task and Multi-Disciplinary Contracts

SC&A has a wealth of experience managing complex, multi-task, and multi-disciplinary
contracts. Over its 22-year history, SC&A has managed more than 20 such contracts, involving
complex subject matter and numerous and simultaneous task orders (often more than 25 at a
time), requiring teams of staff comprised of scientists, health physicists, regulatory specialists,
engineers, and public outreach and communications specialists. Many of these contracts have
been shanaged by SC&A’s proposed Project Manager, Dr. . For this effort, SC&A has
assembled a team capable of responding to the technical requirements encompassed by the SOW.
However, should additional or more diverse specialized expertise be required, SC&A's active list
of Associates could be utilized. Or, if an unanticipated work requirement should arise, SC&A is
willing to subcontract outside of the team assembled for the purposes of this proposal. (SC&A
has established procedures for competitive procurement of new subcontractors.) A gap in
existing expertise should be recognizable very early in the performance of a task order (most
likely at the work plan development phase), thus allowing sufficient time for SC&A to respond.
SC&A will implement the following procedures to ensure effective management of the contract
SOW areas.

Review and Distribution of Task Orders in a Timely Manner
SC&A has time-tested procedures to ensure the timely review and distribution of task orders.
The following procedures will be performed within 14 calendar days after receipt of a TORP:

. When the Project Manager receives a TORP from the Project Officer, he will first
review it for Organizational Conflict of Interest (OCD), assess its requirements for
resources with the key members of the team, and then determine how best to meet
the requirements of the TORP, without impacting the resources available for
ongoing tasks. At this point in the process, the Project Manager, in consultation
with the Deputy Project Manager, will make a first attempt at sorting the tasks
into categories regarding scope and level of effort.

. After the allocation of SC&A resources has been established, the Project Manager
will select the Case Managers, who will perform or oversee the performance of
the specific cases that comprise the TORP.

. If necessary, the SC&A Project Manager, Deputy Project Manager, and Case
Managers will contact the Project Officer or his designee to clarify any issues that
are unclear in the TORP and to gain a more complete understanding of the scope
of work. After that interaction (which may be in person or by telephone), the
Project Manager, in consultation with the Deputy Project Manager and the
designated Case Managers, will commence preparation of the technical and cost
proposal for the TORP.

SC&A 2-7 Sol. No. 2003-N-00768


reviewing the dose reconstruction of a person who experienced internal exposures
to inhaled plutonium and the associated bioassay data). The administrative
records provided with the cases will be used to define the qualifications of the
Case Managers and technical specialists who will be assigned to each case.

For basic reviews, it may only be necessary to assign a single individual to perform the review.
However, for advanced reviews and blind dose reconstructions, a minimum of three individuals
will be assigned to each case. As required by the TORP, these individuals will have the
following assigned functions: Dose Reconstruction Reviewer (perhaps separated into internal
and external doses), Worker Profile Reviewer, Interview Records Reviewer, and Site Profile
Reviewer. One of these individuals will also be the designated Case Manager. We recognize
that some of the basic reviews will not require access to the NIOSH worker profile or site profile
database; however, we will be prepared to review these sources of information as required to
complete the basic or advanced reviews, or blind dose reconstructions. The individuals assigned
to each case can draw upon any of the other specialists on the project team, The teams will be
assembled using the following criteria:

. Familiarity with the site

. Familiarity with the health physics issues at the site
. Ongoing case commitments
. Consistency of team makeup

In general, for basic reviews, the Case Manager will likely be a health physicist with specialized
expertise in the primary types of exposure of concer (e.g., external exposure versus inhalation of
plutonium) and the associated dosimetric records. For advanced reviews, the Case Manager
could be an appropriately qualified health physicist or an individual with in-depth experience
with the site or types of operations responsible for the exposures.

3.3. Procedures for Performing Basic and Advanced Reviews

Following approval of the technical and cost proposal, the Government will issue a Task Order
and work will commence. For basic and advanced reviews, the individuals comprising each of
the teams assigned to each case will review the IREP input and results to determine technical
areas of emphasis (e.g., acute versus chronic exposures, external gamma or neutron exposures,
internal exposures and radionuclides of concern, etc.) that are the primary drivers for the outcome
of the IREP calculations. Based on this initial review, additional specialty resources (see

Section 2-1, the charts and biosketches in Section 4, and the resumes in Appendix A) will be
drawn upon as needed to perform the review. The review of each case will then commence
under the direction of its assigned Case Manager.

Each case will be reviewed by the team assigned to the case, and, depending on the complexity of
the case, review responsibilities may be divided into internal and external dose reconstruction
reviews (which will include a review of the claimant interview record). In addition, for some
basic reviews and all advanced reviews, the review process will also include worker and site
profile reviews, as required by the technical proposal and Task Order. If several cases are from
the same site, there may be efficiencies we can incorporate into the process by assigning a single

SC&A 34 Sol. No. 2003-N-00768


General Elements

When a sufficient number of worker interviews and records have been audited for specific
facilities or processes (such as uranium chemical processing or machining, plutonium processing
or machining, etc.), a check will be made about whether and how the worker interview data have
been used in conjunction with facility profiles. Consistent worker testimony about the frequency
of badge use or internal monitoring, for instance, could lead to discovery of gaps in facility
documentation. Hence, worker interview data can be pooled to provide insight into the quality of
and uncertainties in dose estimates for specific facilities or processes. The audit will examine
whether the worker interview data have been used to the extent possible to improve the quality of
dose estimates for groups of people who worked in specific processes or places.

When the audits of worker interviews and dose records from a sufficient number of different
facilities and processes are complete, worker interviews can then be used to determine the
adequacy of dose records across the nuclear weapons complex as a whole for specific time
periods and processes.

This pooling of worker interview and dose data will allow an analysis of possible patterns in the
discrepancies between worker accounts and dose data at specific facilities and over the entire
complex. The dose reconstruction methodology will be audited to determine whether the worker
interview and records have adequately taken these patterns into account in order to improve dose
estimates, and possibly to develop correction factors to dose estimates, in case they are
warranted.

Examples of Importance of the Interview Process

Example 1. Thorium-232 Processing

Thorium was processed at a number of facilities, such as the Simonds Saw & Steel Co.,
Lockport, NY (a FUSRAP site) and at the Femald plant. The following quote from the study
performed for USA Today about this (and two other sites) is illustrative of the importance of the
interviews. This quote is about Simonds Saw & Steel:

Thorium processing operations may have taken as little as one week and possibly
much longer”! Based on available data, it is not possible for us to estimate the
total number of full time equivalent days for which the thorium milling operation
was conducted. We have therefore calculated thorium doses corresponding to

? The study was unable to make a reasonable estimate of the number of days for which thorium was
processed. Hence, there is a corresponding uncertainty concerning worker exposures to thorium. The lowest
estimate of working time was one week of full time work for thorium processing based on a comparison with
uranium processing rates. The thorium throughput per hour would be about 40 percent of the uranium throughput
per hour due to the difference in mill sizes (10 inches versus 16 inches, yielding a cross-sectional area ratio of about
40 percent). A June 8, 1953, document indicates that thorium processing rates may have been somewhere between
roughly 1,000 pounds and 4,000 pounds per day, assuming that all work indicated in a month’s period was done in a
single full working day. On this basis, the total thorium processing time can be estimated to be between 10 and 40
working days—that is, 2 to 8 weeks. [Survey of Accounting Control over Source and Fissionable Material, Simonds
Saw and Steel Company, Lockport, New York, with cover letter dated June 8, 1954.]

SC&A 3-8 Sol. No. 2003-N-00768


based on dose conversion factors that are clearly conservative based on the records, but the doses
are still found to be low, we will provide documentation of this fact.

Sometimes the opposite occurs and the use of specific factors gives a higher dose than using
default parameters. In the ICRP technical document, several examples are cited where the use of
the specific absorption factors from lung to blood gives a higher dose than when assigning the
default absorption type. All examples are related to effective doses, but the same applies with
organ doses. In cases in which there is reason to believe that the physical and chemical
composition of the inhaled or ingested material is such that the doses may be higher than
reported, this finding will be reported and given special attention with regard to its implications
not only to the dose reconstruction under investigation, but also to other related dose
reconstructions.

3.8.3 Intercomparisons of Bioassay Results among Different Laboratories

Recent intercomparisons have revealed that different laboratories can obtain different estimates
of intakes and doses when provided with the same bioassay data. In these exercises, in which the
participants had largely used ICRP models, differences in dose assessments of up to five orders
of magnitude had been reported. The differences were largely due to assumptions regarding
absorption fractions and retention models. [[AEA, “Intercomparison and Biokinetic Model
Validation of Radionuclide Intake Assessment,” IAEA-TECDOC-1071, 1999; H. Doerfel, A.
Andrasi, MLR. Bailey, A. Birchall., C.M. Castellani, C. Hurtgen, N. Jarvis, L. Johansson, B.
LeGuen, G. Tarroni,. “Third European Intercomparison Exercise on Internal Dose Assessment:
Results of a Research Pprogramme in the Framework of the EULEP/EURADOS Action Group,”
FZKA 6457, Forschungszentrum Karlsruhe, 2000.] Such findings are very disturbing, but
indicate how much the choice made by the internal dosimetry expert on “reasonable
assumptions” for missing information can affect the interpretation of bioassay results.

3.8.4 Dose per Unit Measurement for Dose Reconstruction

Graphs of committed effective dose per unit measured activity (in the body or in excreta) versus
times after intake, as a function of lung absorption Type and AMAD, reveal “areas of
invariance,” i.e., time periods where the assessment of dose is relatively insensitive to
assumptions made about lung absorption Types and AMAD. Thus, in dose-reconstruction
analysis, when AMAD and/or lung absorption Types are not known or are poorly defined, the use
of monitoring data, if available, in the period of time corresponding to the invariance area can
minimize parameter uncertainties in modeling. The effective dose per unit measured activity
also provides a tool to compare bioassay methods in relation to uncertainties in dose calculations
as a function of differences in lung absorption parameters for specific compounds. These data
are useful when choosing a bioassay method, when assigning a weight to multiple bioassay
results, and when defining the uncertainties related to an unknown or poorly known lung
absorption parameter.

3.8.5 Upcoming Developments with ICRP Internal Dosimetry

Though the current ICRP models have been adopted for use by NIOSH, ICRP is continually re-
evaluating their recommendations and models. Dr. will keep the Board appraised of

SC&A 3-37 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST |

Audit Number: Claim Number:

Date:

Page of |

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

tnt]

C.1.10j

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
electron dose, when no monitoring data
were available?

C1
C.liLa

Electron Dose Conversion to Organ Dose:
Are assumptions used to convert electron
dose to organ dose appropriate? ($4.3)

CLILD

Are assumptions used to convert electron
dose to organ dose conservative (claimant
friendly)?

CLA

Dose Conversion Factors Based on Exposure
Geometry:
Are assumptions used to determine the most.
credible geometries for dosimeter and
missed dose appropriate? ($4.4.1)

C.AALd

Do assumptions used in determining
geometries associated with dosimetry and
missed dose give the benefit of doubt to the
claimant?

C.Lile

Are assumptions used to determine
exposure geometry uncertainty associated
with specific job functions appropriate?
(84.5.2)

CALLE

Do assumptions used in determining
uncertainty associated with exposure
geometries for specific tasks give the
benefit of doubt to the claimant?

Cig

Are assumptions used to determine the most
credible geometry for occupational medical
exposure appropriate? (§4.4.2)

es ee a Ss |



Tr ————

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
‘Audit Number: Claim Number: Date: Page of
L |
| ‘Area of | Description of Technical Elements of Review | Yes/No/ ‘Comments Tnitials
Review NA
C13E ‘Are assumptions used in determining

uncertainty associated with the occupational
medical dose component of photon
dose/photon energies appropriate?
(§2.1.3.3)

C.i3.g Are assumptions used in the calculation of
the environmental dose component of
photon dose appropriate? (§2.1.4)

C.13.h Are assumptions used in determining
uncertainty for the environmental dose
component of the photon dose calculation
appropriate? (§2.1.4.3)

C134 Are conservative (claimant friendly)
assumptions used in the determination of
photon dose/photon energies, when
monitoring records were available? |

C13, Are conservative (claimant friendly)
assumptions used to determine uncertainty
associated with photon dose, when.
monitoring records were available?

C.1.4 "  |Photon Dose Reconstruction With NO {

C.1.4.a _|Monitoring Data:
‘Are assumptions incorporated in the

reconstruction of photon dose using co-
worker data appropriate? (§3.1.1)

CA14b Are assumptions for the uncertainty analysis
associated with reconstructing photon dose
using co-worker data appropriate?
(§2.1.1.3)



We have assigned as Deputy Project Manager working alongside Dr. on
every aspect of this project. We elected to take this approach because is
intimately familiar with DOE and AWE facilities as a result of his 21 years of experience with
DOE in the area of health and safety oversight of DOE programs. *s understanding
of DOE and AWE sites, coupled with qualifications in health physics and
experience managing large Government task order contracts, creates an extremely powerful
project management team.

Dr. will be responsible for maintaining quality and configuration control over all
standard operating procedures (SOPs) used on the project Section 3 presents the technical
approach and review/auditing procedures that will be used on the project) and for QA audits
verifying and documenting that all work is being performed and documented in accordance with
approved procedures. His internal audits of SC&A’s task orders will also ensure that areas for
which deviations from the SOPs are needed and implemented are documented (in accordance
with the SOPs) and that, if necessary, revisions to the SOPs to accommodate lessons learned are

SC&A 2-2 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page of

Description of Technical Elements of Review

Yes/No/
NA

Comments

———
Tnitial

Photon Dose Conversion to Organ Dose:
Are assumptions used to convert monitored
photon dose to organ dose appropriate?
(84.1.1)

C.A5.b

Are assumptions used to covert
survey/source term data associated with
photon dose to organ dose appropriate?
(84.1.2)

C.1S.c

Are assumptions used in the energy
simplification of ICRP 74 dose conversion
factors for input into NIOSH-IREP
appropriate? (§4.1.3)

C15.

Are assumptions regarding uncertainty
associated with the energy simplification
process appropriate? (§4.5.1)

C15.

Are conservative (claimant friendly)
assumptions used in the conversion of
photon dose to organ dose?

CASA

Are conservative (claimant friendly)
assumptions used in determining the
uncertainty resulting from the energy
simplification process?

C16
C.1.6.a

Neutron Dose Reconstruction Using
Monitoring Data:
Are assumptions used in the determination

of neutron dose/neutron energy using
personal monitoring data (dosimeters)
appropriate? (§2.2.1)

C.1.6.b

‘Are assumptions used in the deterinination
of uncertainty associated with neutron
personal monitoring data appropriate?
(§2.2.1.3)

nnn

C8


° While early health physics reports indicate that limited in-vitro bioassay
monitoring for transuranics was conducted, there are no urinalysis data in the
electronic databases prior to 1989.

. The historical urinalysis databases did not indicate the type of sampling (routine,
special, etc.) or the solubility class of material being monitored.

. The databases have not been verified against any of the original records.
. The databases have not had any quality assurance/quality control evaluations.
. The databases are not complete; for example, it was determined that at least some

elevated data from exposures as a result of incidents and accidents were not
included in the electronic database. The database may contain data-entry errors.

. Some of the units used in the database are not clearly documented.

. Not all department numbers found in the health physics reports could be
correlated with the department numbers recorded in the electronic databases.

The evaluation team in this case concluded that, “based on the above, the databases should not be
used at this time to estimate individual worker doses.”

As the NIOSH worker profiles will initially consist of many of these historic site electronic
databases, SC&A intends to do sufficient “sampling” quality verification checks to assure that
their reliability can support application to individual dose estimation. This will be accomplished
by identifying the original source data and comparing them with the submitted electronic or hard
copy data used in selected worker profiles. The degree and nature of potential “missing doses”
will be determined as a means to ascertain the representativeness and usability of profile data.
As dose reconstructions proceed over time and reconstructed individual doses are added to the
database, the representativeness of the database will steadily improve, aided by these quality
verification reviews.

3.4.2 Completeness of Records Incorporated

Each DOE site, if not facility, has a unique operational, radiological, and managerial history.
While DOE and its predecessor agencies (Manhattan Engineering District, Atomic Energy
Commission, Energy Research and Development Administration) issued directives governing
radiation protection standards, dosimetry and record keeping in the early decades (1940s~1980s)
were typically general and left to individual contractor interpretation and implementation. To
gauge the completeness of records reflected in the NIOSH worker profile, SC&A will verify the
“universe” of radiological data having identifiers for a particular facility or site, and compare that
data with what is entered in the selected profile.

For this review, it will be essential to identify what monitoring was conducted for different types
of radiation, for what worker categories and time periods, and in what form and condition the

SC&A 3-12 Sol. No. 2003-N-00768


Exhibit ES-1. Organizational Chart

(* indicates key personnel)

might consist of only one or two persons or it might consist of several individuals working under
the direction of a Case Manager. In forming these teams, we will draw from the specialized
technical resources identified in Exhibit ES-1. All work will be performed under a highly
structured and transparent quality assurance/quality control and documentation process, which
includes audit forms and checklists that correspond to the requirements of Part 81 of Title 42 of
the U.S. Code of Federal Regulations (CFR), “Probability of Causation,” 42 CFR 82, “Dose
Reconstruction,” 42 CFR 83, “Special Exposure Cohorts,” OCAS-IG-001, “External Dose
Reconstruction and Implementation Guideline,” and OCAS-IG-002, “Internal Dose
Reconstruction and Implementation Guideline.”

Under this organization, Drs. will be responsible for ensuring that all basic
and advanced reviews and blind dose reconstructions are performed in a fair and consistent
manner, are well-grounded in the best available scientific knowledge, and give the benefit of the

SC&A ES4 Sol. No. 2003-N-00768


ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: | Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

F.3 Review of All Relevant Sources of Data: Evaluate whether, to the extent practicable, all relevant sources of

data (e.g., DOE, AWE, CDC, EML, NRC, EPA, External Health and Safety Regulators, GAO, DNFSB,
Congressional Hearing Records, other research program, research publications, publication regarding the
history of the DOE complex, or administrative/court records) were identified, evaluated and where
appropriate, included within the Site Profile database and, where appropriate, were used in the assessment of

the individual dose reconstruction case.

F31

Has a thorough search been conducted to
identify all potentially relevant sources of data
as they apply to the individual dose
reconstruction case? (Note: This may require
conducting interviews with employees,
employee representatives, site ‘experts,’ etc.)

F32

Have relevant data identified in the literature
search been evaluated and, where appropriate,
included in the Site Profile database?

B33

Have relevant data identified in the Jiterature
search been used in the assessment of the
individual dose reconstruction, where
appropriate?

C45


[ BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
i Audit Number: Claim Number: Date: Page of

Area of |Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

D.2._ Internal Dose Calculations: Verify internal dose calculations are appropriate for purposes of determination
of POC. (Parenthetical number represents the section within the “Internal Dose Reconstruction Implementation

Guideline” (OCAS-IG-002) that provides detailed methodology for conducting the appropriate portion of the dose
reconstruction.)

Internal Estimate - Low Dose

D2.La Potential:
Are recalculations of bioassay values
appropriate and correct? (§6.1.2)

D2.1.b Are calculations for determining the highest
intake associated with each potential
solubility class that will produce a predicted
bioassay value equal to at least one of the
recalculated bioassay values from step
§6.1.2 appropriate and correct? (§6.1.4)

D.2.Le Are calculations for determining the highest
intake (using a constant chronic exposure
period) that will produce a predicted
bioassay value equal to at least one of the
recalculated bioassay values from step
§6.1.2 for each potential solubility class
appropriate and correct? (§6.1.5)

D2.1.d Are calculations for determining a scenario
(for each radionuclide for which the
claimant was monitored) that produces the
highest 50-year committed dose to the
organ of concern appropriate and correct?
(86.1.7)

D.2.1.e Are calculations for determining annual
doses to the organ of concern using the
scenario selected in step §6.1.7 (for each
radionuclide for which the claimant was
monitored) appropriate and correct?
(§6.1.8)



Exhibit 3-2. SEC Petition Audit Report and Checklist

SEC PETITION AUDIT REPORT

Page. of,

Audit Number:

Petition Number:

==

Date:

Auditor(s):

Audit Record Summary (Describe below what records you examined, to whom you submitted them, the

conclusions you arrived at, and how you arrived at them):

List of documents reviewed:

record to this report.)

List of new documents identified: (Attach a copy of all documents not included in the original administrative

List of person(s) interviewed: (Attach a copy of the interview documentation to this report.)

Audit conclusions: A gree/disagree
(Note: Attach all audit checklists
and supporting documents.)

Agree:, (Initials)
Additional comments should be
entered in the ‘Summary’ below.

__ (initials)
If petition evaluation is rejected,
complete next section.

Disagree.

Provide a summary discussion of the reasons for disagreeing with the petition evaluation: (Attach all calculations,
notes, reports, etc., used in your conclusions.)

General Comments:

Signature of Auditor(s):

Area of Review:

Date:

:

SC&A

3-29

Sol. No. 2003-N-00768


SC&A has only one nonlaboratory project with a DOE contractor. This contract is with the S.M.
Stoller Corporation (SMS-SCA1002), who is a subcontractor to Portage Environmental Inc., who
in turn is a prime contractor to the DOE Carlsbad Area Office. The work, which is to conduct
field quality assurance audits of the nondestructive assay of transuranic waste prior to its
shipment to the Waste Isolation Pilot Plant (WIPP), involves only one SC&A individual. The
work has been ongoing for approximately two and one-half years (prior to this year under
subcontract to Portage Environmental Inc.). This work is not concerned with radiation
dosimetry, nor is it related in any way to any of the elements of the scope of work of the
subject solicitation. Therefore, it is not in conflict with the proposed work for the Advisory
Board.

SC&A has performed some work for DOE contractors in the past, and for completeness, the
following describes all of this work performed over the past 10 years:

° In 2001, under subcontract with Argonne National Laboratory, SC&A assisted in
the evaluation of a radiation monitoring system for the transborder detection of
radioactive materials (under a DOE prime contract).

. In 2000, under subcontract with CH2M HILL, SC&A performed a statistical
analysis of contamination around the Hanford Tanks.

. In 1999 and 2000, under subcontract with Walcoff, Inc., SC&A evaluated the
environmental impact of nuclear power plant operation.

. In 1999, SC&A received a small subcontract with Lockheed Martin Idaho
Technologies Company to reimburse us for allowing them the use of a low-
signature cart that we had designed for nonintrusive UXO data collection, and to
provide technical assistance related to the use of the cart.

. From 1995 through 1998, under subcontract with the Consortium for Risk
Evaluation and Stakeholder Participation (a university grant), SC&A evaluated
methods for risk assessment applicable to DOE sites.

. In 1997, under subcontract with Raytheon Engineers and Constructors, SC&A
performed environmental analysis support to the West Valley Demonstration
Project.

° Jn 1996, under subcontract with Brookhaven National Laboratory, SC&A.
evaluated decision-support software (EPA prime contract).

. From 1995 to 1997, under a subcontract with the Environmental Evaluation
Group (EEG), SC&A reviewed certain safety features of the WIPP. Although
EEG receives its funding from the DOE, it is an independent watchdog group.

SC&A 2-16 Sol. No. 2003-N-00768


adequacy, given the inherent difficulty of establishing routine tritium exposure and what internal
residence times can be assumed.

For an SEC evaluation, the circumstances at Paducah Gaseous Diffusion plant exemplify how
“missed dose” must be ascertained and evaluated. A number of sources of missed dose existed
that made it less feasible to estimate individual worker doses, including:

. A lack of documentation. At Paducah, this included doses that were never
recorded, may have been discarded, or records that could not be located after an
extensive search.

. A failure to monitor the exposure. There were numerous examples at Paducah
during the history of the plant where the potential for radiological exposure may
have existed, but was not monitored, or not adequately monitored.

. A failure to recognize an opportunity for a radiological exposure. For example, at
Paducah, it was assumed that nearly all uranium ingested or inhaled was soluble
and quickly excreted from the body without harm or long-term effects. In fact,
aerosols of insoluble uranium compounds were generated in a number of work
areas.

. Lack of sensitivity of the radiation monitoring or bioassay techniques. For
example, a worker who had been exposed to elevated airborne concentrations of
“poorly soluble” uranium was given in vivo radiation monitoring and determined
to be below standard detection limits for the site, when, in fact, the determined
lung burden was equivalent to a “significant internal deposition” according to
corporate radiation protection criteria.

. Movement of workers between job assignments and between facilities without
any documentation or changes in dosimetry to reflect differences in radiation
source terms. It was also obvious that, over time, buildings were used for
different purposes and the potential for worker radiation exposure was not
recognized.

The above contributory sources of inadequate, missing, or inaccurate dose records illustrates the
need to systematically review the dosimetric history, operational practice, and management
policy over the lifetime of the plant for which an SEC petition has been received, and to assure
through sampling that this probing is thorough.

The checklist in Exhibit 3-2 is divided into three sections. The first two sections allow the
auditor to review the information provided by the petitioner. The last section allows the auditor
to review the work performed by NIOSH during the petition evaluations. The first section, “SEC
eligibility criteria,” presents the conditions which must be met, by law, in order to qualify as a
member of the SEC. The second section, “Petition requirements,” presents information which
42 CER 83 states must be included in the petition in order to perform a complete evaluation. The
third section, “Information gathered by NIOSH,” is a list of sources described in 42 CFR 83 that

SC&A 3-27 Sol. No. 2003-N-00768


| BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

| Audit Number: Claim Number:
Area of |Description of Technical Elements of Review | Yes/No/ Comments Initials,
Review NA
C244 Are calculations of uncertainty associated

with the energy simplification process
appropriate and correct? (§4.5.1)

C25 Neutron

C.2.5.a  jMonitoring Data:
Are calculations of neutron dose using
personal monitoring data (dosimeters)
appropriate and correct? (§2.2.1)

C25.b Are calculations of uncertainty associated
with neutron personal monitoring data
appropriate and correct? (§2.2.1.3)

C.2.5.¢ Are calculations of dose associated with
incomplete/missing neutron monitoring data
appropriate and correct? (§2.2.2)

C25. Are calculations of uncertainty associated
with incomplete/missed neutron monitoring
dose appropriate and correct? (§2.2.2.4)

C.2.6 ‘Neutron Dose Reconstruction With NO
C.2.6.a | Monitoring Data:

Are calculations of reconstructed neutron
dose using co-worker data appropriate and
correct? (§3.2.1)

C.2.6.b Are calculations of uncertainty associated
with reconstructed neutron dose using co-
worker data appropriate and correct?
(§2.2.1.3)

I} C.2.6.c Are calculations of reconstructed neutron
dose using survey data appropriate and
correct? (§3.2.2)

C-17


and to estimate the workers’ intake. If physical-chemical characteristics of the aerosol are not
known, ICRP default parameters will be used. Organ doses will be calculated using ICRP CD-
ROM, The ICRP Database of Dose Coefficients: Workers and Members of the Public, Version
2.01, Elsevier Science Ltd., 1998.

The same applies to the estimation of doses using information on the source term, as specified in
item 5.3 of OCAS-IG-02. The software used for calculating organ doses from bioassay
measurement may also be used for calculating organ doses from calculated intakes. It will be
used to calculate doses when the use of specific absorption factors from lungs to blood is
necessary (item 4.3 of OCAS-IG-02).

The software is thus a very efficient tool to perform blind reviews of internal doses in accordance
with OCAS-IG-02. All guidelines contained in the document will be followed: the ICRP
models; the collection of data for the individual case; the calculation of the dose to the organ or
tissue of interest, including the correlation of ICD-9 Codes to ICRP Models; the collection of
work area data; the collection of the individual dosimetry data; the preliminary dose estimates
and the detailed dose estimates that include the estimate of the date of intake; the estimation of
the uncertainty in the internal dose calculation; the treatment of missed doses; and the estimation
of radon and progeny doses. All information given in the examples for item 8.0 will be used.

3.6.2 Dose Per Unit Measured Activity in the Body or in the Excreta:_A Tool to Minimize
Uncertainties

When multiple data points from bioassay monitoring collected at different times after intake or
resulting from different bioassay monitoring methods are used to estimate the dose, the fitting
procedure chosen for the analysis is very important. In a recent intercomparison among the most
recently developed software that utilizes the most current ICRP models, a discrepancy was noted
related to the different methods of fitting to calculate the best estimate of the intake and dose.
The second reason for the discrepancy was due to the level of expertise and the choice made by
the user on “reasonable” assumptions such as particle sizes; choice of solubility types as
exemplified in item 4.3 of OCAS-IG-02; treatment of rogue data, as exemplified in item 5.1 of
OCAS-IG-02; weight given to some bioassay results or to a particular bioassay method; etc.
[Review of Methods and Computer Codes for Bioassay Data Interpretation,” E.Ansoborlo,
P.Bérard, M. Bailey, V. Berkovski, A. Birchall, F. Fry, R. Guilmette, G. Miller, N. Ishigure,

J. Lipsztein, and D.Nosske, presented at the Workshop on Intakes of Radionuclides, Oxford, UK,
2002, which will be published in 2003 in “Radiation Protection Dosimetry.”] Thus, we should
not be surprised if we find different dose estimates from the same data, unless very specific
instructions are given in the Task Order. Alternatively, these issues could be addressed as part of
the uncertainty analysis in the reconstructed doses.

Tabulations and graphs of dose per unit-measured activity (in the body or in excreta) at specified
times after intake will be used. The variable dose per unit measured bioassay quantity is
obtained using the most recent published ICRP dosimetric and metabolic models. Those
tabulations and graphs are very helpful in determination of the best estimate of a dose (organ
dose or effective dose) from results collected at different times, or from different monitoring
techniques, e.g., urine, fecal, and direct measurements data. For example, for some

SC&A 3-20 Sol. No. 2003-N-00768


time sheets and Associate invoices are certified by the individual and reviewed by the Case
Managers, the Project Manager, and the accounting department. Other direct costs (ODCs), after
being checked for correct authorization, are processed in the same way. Subcontractors follow
similar procedures.

This system of reporting and approving contract expenditures is used to produce a Cost
Management Report for comparison to the Cost Plan. The Cost Management Report is used for
project monitoring and control to determine accrued costs for the current reporting period, to
forecast accrued costs for subsequent reporting periods, and to anticipate total costs for project
completion.

The Cost Plan provides a baseline for measuring cost variance on a contract and basic
information for projecting costs and re-budgeting, if necessary. It also addresses each specific
task order, case, subtask, project phase, or any other work elements required by the contract,
since planning and reporting by elements of cost may be required, in addition to planning and
reporting by elements of work.

The Project Manager checks the costs against the Cost Plan to ensure that the work is proceeding
within budget. Weekly informal review meetings (by telephone, if necessary) are held among the
Project Manager, Deputy Project Manager, the Case Managers, and technical staff to discuss
technical progress and expenditure rates in order to keep these two aspects of the project in
balance. Potential problem areas are flagged so that they can be dealt with at the earliest possible
stage to minimize the impact on the project. At least one of the weekly meetings each month
includes a formal review of progress and budget.

Using either the accounting system or the MIS, SC&A will be able to provide the NIOSH Project
Officer or Contracting Officer with any kind of ad hoc report or cost projection. Although the
complete range of such requests may vary, listed below are some of the ad hoc reports requested
and provided under previous contracts:

° Estimates of costs and hours to complete near the end of the period of
performance
. Reconciliation of booked versus billed costs for a contract as a whole or for a

specific task order
° Schedules of ODCs by cost element

. Labor costs and ODCs by cost element for specific subcontractors under specific
task orders, cases, and/or subtask

. List of task orders with ODC costs greater than a specified percentage of total
estimated cost

2-9


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

! This conflict of interest plan will flow down to team members in their subcontracts.

SC&A 2-26 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number:

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials|

DAZ
D.13.a

Preliminary Dose Estimate - High Dose
Potential:
‘Are assumptions for the selection of
radionuclides that will deliver the most dose
per unit intake or one with the highest
bioassay results appropriate? (§6.2.1)

D.1.3.b

Is the assumption used to determine the date
for an inhalation appropriate? (§6.2.2)

D.1.3.¢

Are assumptions associated with the
selection of all potential solubility classes
appropriate? (§6.2.3)

ee ee

D.1.3.d

‘Are assumptions used to determine the
highest intake for each potential solubility
class that will not exceed any of the
measured bioassay values appropriate?
(§6.2.4)

D.1.3.e

If the acute scenario does not produce a
realistic curve, are assumptions used in
finding a more reasonable scenario
appropriate? (§6.2.5)

DABL

Are assumptions used to determine the
scenario that produces the lowest 50-year
committed dose to the organ of concern
appropriate? (§6.2.7)

D13.g

Are assumptions used to determine the
annual doses to the organ of concern
appropriate? (§6.2.8)

D.1.3.h

When the PC calculation results in <50%,
are assumptions used in the refinement of
internal dose estimates appropriate?
(86.2.11 A-G and §6.5)

C-28


completeness of this information to ascertain the adequacy of the information contained in the
NIOSH site profiles.

SC&A will identify and evaluate the approach taken in compiling the site profiles through a
‘comprehensive process of (1) independently identifying the selected site’s operational history,
(2) conducting an “exposure mapping” exercise to identify historic work processes and worker
categories, (3) reviewing all relevant data sources, such as occurrence reports, inspection
documentation, safety analyses, etc., and (4) interviewing worker representatives, worker
advocacy groups, and other individuals having knowledge or expertise on site operational or
radiological history.

3.5.1 Reviewing Site Operational History

For many DOE and AWE sites, reliable dosimetry records may be lacking, particularly for
workers from the 1940s through 1960s. In these instances, historic operational information that
includes the nature of operations, radiological source terms in use, process material
concentrations, and location and time periods of worker activities may be the only data available
for dose estimations. Such information can be extracted from historic records and documentation
being collected by (or accessible from) DOE, including operational records, material inventories,
safety and health inspections and assessments, occurrence reports, and routine memoranda and
facility reports. This possible source of information will be surveyed at the DOE site or AWE
records collection point to ascertain whether the site profiles adequately reflect at least the
following information, where feasible:

. Operational processes over time, including improvements, upgrades,
modifications and terminations (important because worker exposures are often
higher during major process changes).

. Historic radiological inventory, source terms, and movement through facility
(“mass balance”) to include feed material, products, and byproduct and waste
streams.

. Any unplanned events, including radiological over-exposures, contaminations,

releases, spills, criticality incidents, and unusual occurrences.

. Changes in contractor management and attendant changes in safety policies,
procedures, and practices (important because new contractors import new
radiation protection programs).

. Applicable standard operating procedures, memoranda, directives or recorded
practices governing onsite management of radioactive materials and processes.

. Actual historic operational practices established by first hand accounts (e.g.,
worker representatives, site “experts,” etc.) (important because actual facility
practices often varied from official procedures).

SC&A 3-14 Sol. No. 2003-N-00768


Responding to Increased Workloads

Because of the depth of SC&A’s personnel resources in a broad range of disciplines, increased
and widely fluctuating work loads will not pose a problem. There is a sufficiently large staff to
fill the case load requirements as estimated in the solicitation. The total number of available and
qualified personnel employed by SC&A provides a large margin of comfort. SC&A’s previous
contracts with the Government demonstrate the Company’s ability to absorb increased and
widely fluctuating work loads.

2.4.4 Flexibility of the SC&A Organization

SC&A was initiated as, and has continued to evolve into, one of the most flexible and responsive
organizations in the professional services market. SC&A’s staffing structure of full-time and
part-time employees, as well as Associates, provides us with a resource pool that can be easily
expanded or contracted depending on the volume of work or the schedule required to complete a
project. The Company’s simple corporate management structure ensures that problem solving is
tackled expediently and efficiently, as described above. SC&A’s flexibility and responsiveness
is also evidenced in our ability to provide quick turnaround support.

During its 22-year history, SC&A has provided services to the Government through more than
250 contracts, many of which were accomplished through task order type contracts. Many of
these task orders required quick turnaround response, which in some cases translated into
24-hour turnaround. The majority of these tasks have involved activities similar to those
required under the SOW (i.e., dose assessments). In all cases, SC&A was able to respond to
these quick turnaround requests simply and efficiently, due to the Company’s resource pool
consisting of SC&A staff and Associates and the resources of subcontractors. For this effort, the
SC&A team is proposing a fixed staff of 35 individuals who will be formulated into review
teams assigned to each case and will work under the direction of a Case Manager. Staff can be
mobilized effortlessly and will be available within hours of a request for a quick turnaround task.

As a minority owner and member of the Board of Directors of SC&A, the proposed Project
Manager, Dr. , has the authority to obtain resources as needed. Upon receipt of a request
for quick turnaround support, Dr. will immediately contact the Project Officer and/or
Advisory Board representative to define or clarify the objectives of the task and provide a
preliminary estimate of the resources necessary to complete the work in the specified time frame.
He will then work with the Deputy Project Manager, Case Managers, and other team members to
identify the existing workload and to assess the need for extra staff or equipment. Should extra
resources be necessary, Dr. will arrange for their timely provision. These resources will
then be made available to the Case Manager (or Task Manager, if the activity does not involve a
case) to complete the activity. Dr. will monitor the activity throughout its performance
and will adjust resources as necessary to ensure that the schedule is met. It is not uncommon for
SC&A to handle more than one quick turnaround project at a time by using these procedures.

SC&A 2-12 Sol. No. 2003-N-00768


| BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

| ‘Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ ‘Comments Tnitials
Review NA
C224 ‘Are calculations of uncertainty associated

with incomplete/missed photon monitoring
dose appropriate and correct? (§2.1.2.4)

C.2.2.¢ Are calculations associated with the
occupational medical dose component of
photon dose appropriate and correct?
(§2.1.3)

C225 Are calculations of uncertainty associated
with the occupational medical dose
component of photon dose appropriate and
correct? (§2.1.3.3)

C222 Are calculations associated with the
environmental dose component of photon
dose appropriate and correct? (§2.1.4)

C2.2h Are calculations of uncertainty for the
environmental dose component of photon
dose appropriate and correct? (§2.1.4.3)

Photon Dose Reconstruction With NO
Monitoring Data:
Are calculations of reconstructed photon
dose using co-worker data appropriate and
correct? (§3.1.1)

C.2.3.b Are calculations of uncertainty associated.
with reconstructed photon dose using co-
worker data appropriate and correct?
(82.1.1.3)

C.2.3.¢ Are calculations of reconstructed photon
dose using survey data appropriaté and
correct? (§3.1.2)



SC&A

Sol. No. 2003-N-00768


ADVANCED INDIVIDUAL DOSE RECONSTRUCTION
REVIEW CHECKLIST
(Note: The Basic Individual Dose Reconstruction Review checklist
should be completed prior to the Advanced Review)

‘Audit Number: Claim Number: Date: Page of

Auditor(s)/Area of Review:

Dose Reconstruction Analysts(s)/Area of Dose Reconstruction (External/Internal):

Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA
F. ADDITIONAL DATA GATHERING REVIEWS
F.1 Review of Entire Administrative Record: Review the entire administrative record to evaluate if relevant
information exists which was not considered by NIOSH.
Fl Does the administrative record contain data that

are relevant to the reconstruction of external
dose, which were not considered by NIOSH?

FA2 Does the administrative record contain data that
are relevant to the reconstruction of internal
dose, which were not considered by NIOSH?

P13 Does the administrative record contain data that
could be used to evaluate the completeness and
adequacy of individual monitoring data, which
were not considered by NIOSH?

Fld Does the administrative record contain data that
could be used to evaluate the completeness and
adequacy of monitoring programs, which were
not considered by NIOSH?

Fis Does the administrative record contain data that
could be used to reconcile discrepancies or
uncertainties associated with any aspect of the
dose reconstruction, which were not considered
by NIOSH?

F.2 Review of the Site Profile: Review the relevant aspects of the Site Profile as they apply to the individual case
and evaluate the adequacy and completeness of the site profile and evalnate whether the information from the
site profile is consistent with the information used for the individual dose estimate.

C43


3.0 TECHNICAL APPROACH'*

This section describes our technical approach to performing basic and advanced case reviews,
blind dose reconstructions, and Special Exposure Cohort (SEC) petition reviews. In addition,
our approaches to performing reviews of worker-profile and site-profile databases, independent
of the review of specific cases, and ad hoc reports are also described. Imbedded in the
discussions are anticipated major problem areas, together with recommended approaches for
their resolution. The section concludes with “Special Topics,” which highlights those issues and
technical strategies that we believe are worth noting, especially with regard to internal dosimetry.

3.1 Concept of Operations

SC&A is proposing a highly structured, transparent, and well-documented approach to reviewing
dose reconstructions and SEC petitions. Exhibit 3-1 presents our understanding of the
interrelationships between the various tasks that comprise the review of dose reconstructions.
Our technical approach to the project assumes that, whether the Task Order Request Package
(TORP) requires a basic or advanced review, or a blind dose reconstruction, the administrative
record and other pertinent technical material, in hard copy and/or electronic form, will
accompany the TORP. These records, and any other information provided by NIOSH or
uncovered as a result of our investigations, will be loaded into our relational database, which will
be designed to be compatible and consistent with the relational database being employed by
NIOSH.

In brief, for Basic Reviews, the focus of attention will be on the relevant portions of the
administrative record and ensuring the completeness and internal consistency of the dose
reconstruction, interview record, and, to the extent applicable to the basic review, NIOSH worker
and site profiles. Primary attention will be given to the appropriateness of any assumptions that
were used in the determination of dose as well as the completeness and internal consistency of
the NIOSH dose reconstruction with Office of Compensation Analysis and Support (OCAS)
guidelines in support of the dose reconstruction and the adjudicated decision. :

Advanced Reviews will evaluate the entire administrative record and review pertinent worker and
site profiles, seek out primary records (original log books, work permits, strip chart recorders,
etc.), co-worker records, and supplemental information obtained from the claimant and co-
workers (if authorized by the Board) as required to verify the dose reconstruction in those areas
that could have a significant impact on the dose estimates and adjudicated decision. In order to
perform advanced reviews in a manageable time period, advanced reviews will be limited to
those exposure settings and occurrences that have the potential to significantly influence the
ability to reconstruct doses and the resulting adjudicated decision. Nevertheless, during the

1 This section, which describes our technical approach to the project, and Volumes 2 and 3 of the proposal
which describe our technical approach to the two example tasks, cover many of the same points. We tried to avoid
repetition. As such, we request that the committee reviewing our technical approach to this project consider Section
3.0 of Volume I of the proposal, as well as Volumes 2 and 3 in their entirety. Taken together, this information will
offer the review panel a solid understanding of how we would approach tasks issued under this contract.

SC&A 3-1 Sol. No. 2003-N-00768


z
3
3 :
Fa §
Name, Title, SI &
Anticipated Level of Effort Educational zg 3 Familiar with Specific DOE/AWE
(key personnel only) Background i Facilities Availabili
Key Personnel :
SC&A, Inc.

a ee oa

SCEA

Sol. No. 2003-N-00768


ADVANCED INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

G.2 Adequacy of Research for Co-Workers/Historical Records: Evaluate whether, for the cases involving

survivors, there has been an adequate effort to research co-located workers and other historical records to

chai

acterize the individual’s work history.

G21

Does it appear that there was an adequate effort
to identify, locate, and contact co-worker,
supervisors, and/or any other individuals
identified by the claimant who could provide
data that would supplement/confirm the dose
reconstruction?

G.2.2

Does it appear that there was an adequate effort
to research historical records to characterize the
work history, radiation incidents, and other
relevant information provided by the claimant?

C47


(AMAD or absorption parameters) and choice between default and specific values (items 4.3 and
4.4, OCAS-IG-02). Radioactive progeny that grow in after an intake of a parent radionuclide are
treated as recommended by the ICRP. Generally, it is assumed that the biokinetic behavior of the
decay products is the same as that of the parent nuclide. However, in the biokinetic models for
tellurium, lead, radium, thorium and uranium, separate systemic biokinetics are applied to the
parent and its decay products, as specified in ICRP 71. An input for the intake of progeny is
available, in an optional basis, with chosen equilibrium factors (item 4.2.3, OCAS-IG-02). This
feature is very important when decay products are used to assess intakes of the parent.

The software calculates excretion rates and accumulation of radioactive material per unit intake
in all organs described in ICRP current models for single intakes, chronic intakes, and exposures
during a certain period of time. Thus, it is possible for all those scenarios to produce annual
doses, committed doses until date of diagnosis of cancer or throughout the individual's entire
employment, for all organs and tissues described by ICRP models as specified in OCAS-IG-02,
as well as 50-year committed doses. In addition to calculating organ doses for the most probable
intake scenarios, results from all those scenarios may be easily and rapidly compared, as required
in items 6.1 and 6.2 of OCAS-IG-02.

When detailed dose reconstruction is required, a special feature, workers’ chronic intakes (x days
a week, y hours per day, and w days of vacation—for example, 5 days per week, 8 hours per day
exposure, 2 days weekend and 20 days vacation) may be used. The workers’ pattern of exposure
takes into account the smaller activity excreted after a weekend or after a non-working period,
typical of certain compounds. In some cases, as for example '*'J, the urinary excretion functions
diminish by orders of magnitude within a few days, and therefore the choice of the time pattern
of intake can influence the assessed dose by that same order of magnitude.

The information on the working history is very important. For long-lived nuclides, the amount

present in the body and the amount excreted depends on the time the individual has been

exposed. Following a chronic intake of 1 Bq per day of type S ?”Th, 5 days a week, its

concentration in the lungs after 20 years of work is expected to increase by a factor of 4.4 in

relation to the concentration after one year of work, for both AMAD 5 micron and 1 micron. On

the other hand, the concentration excreted in the feces is supposed to be constant throughout that
- time period.

The software accepts the input of a series of data points from bioassay results collected at
different times after intake and determines the best estimate of an intake using a least squares fit,
maximum likelihood fit, or Bayesian approach. Thus, multiple data points may be used to
estimate the actual intake, as specified in item 5.1 of OCAS-IG-02. The software will also
determine the best estimate of an intake from information on different monitoring techniques,
e.g. urine, fecal, and in vivo monitoring. The simultaneous use of multiple data from different
monitoring techniques may be used as a tool to infer the route(s) of intake and the date(s) of
intake and in refining preliminary estimates of intake (items 4.1.2 , 5.1 and 6.5 of OCAS-IG-02).

If bioassay data are not adequate to evaluate the individual's internal dose, workplace monitoring
data will be used, if available, as specified in item 5.2 of OCAS-IG-02. All recommendations in
item 5.2 will be followed to determine the concentration of the radionuclide in the breathing zone

SC&A 3-19 Sol. No. 2003-N-00768


2
3
3 .
& 5
Name, Title, S 6
Anticipated Level of Effort Educational gE 3 Familiar with Specific DOE/:
(key personnel only) Background = & Facilities

SC&A H Sol. No. 2003-N-00768


. NESHAPS Background Information Document on Rulemaking for NRC and
Agreement State Licensees other than Nuclear Power Reactors, 430-R-92-011

. Radiation and Mixed Waste Incineration Background Information Document,
520/1-91-010

5.6 Selected Private Sector Experience

Starting with the most recent, the following presents brief descriptions of SC&A’s experience in
deriving cleanup standards using a broad range of dosimetric models and designing and
implementing facility and site characterization and closeout surveys for the private sector. All
field work is performed by SC&A personnel, using SC&A equipment, and all laboratory work is
performed by SC&A’s radiological laboratory.

New Jersey Industrial Sites

SC&A is currently involved with five New Jersey sites that are contaminated with radioactivity,
including U-238, Th-232, Ra-226, and tritium. SC&A’s role involves site investigation, waste
characterization and disposal, radiation health and safety, field procedures, oversight functions,
and assisting in the development and negotiations with NJDEP for site-specific cleanup criteria.
The New Jersey sites are located in Teterboro, Hopewell, Lodi, Riverton, and Sayreville. SC&A
has derived DCGLs for both commercial/industrial and residential uses of the sites and designed
and implemented the MARSSIM site characterization and closeout survey programs.

Curtis Bay FUSRAP Site in Baltimore, MD

SC&A served as consultant and radiological subcontractor to EA Engineering (under a contract
with the Army Corps of Engineers) to provide health physics oversight, site characterization
services, and the preparation of the baseline risk assessment of Building 23 (a large five-story
industrial building) and the Radioactive Waste Disposal Area (a seven-acre site used for waste
disposal) contaminated with residual levels of Th-232 and U-238 series radionuclides. The work
included the collection and analysis of wipe samples, air particulate samples, measurement of
direct gamma exposure rates, radon emanation analyses, and the collection and analysis of soil
samples. SC&A also monitored workers for external exposure (TLDs) and inhalation exposures
(breathing zone samplers and low volume air samplers). All work was performed by SC&A field
technicians and health physics personnel, under the direction of a Certified Health Physicist. Ail
samples were analyzed by SC&A’s radiological laboratory. All data were compiled and
reviewed under SC&A’s data verification procedures and Quality Assurance Project Plan. The
data are being used to evaluate compliance with the established radiation protection standards,
the ARARs, and to support MARSSIM evaluations.

Regulatory Approval of a Removal Action
SC&A completed a removal action for the U.S. Army Corps of Engineers (Baltimore District

under contract with Foster Wheeler Environmental Corp.) for the cleanup of the 26th Street
Disposal Site located at the Edgewood Area, Aberdeen Proving Ground, MD (Contract No.

SC&A 5-10 Sot. No. 2003-N-00768


Dose/risk assessments in support of the development of Protective Action
Guides and Derived Response Levels for the water pathways.

Dose/risk assessments of the discharge of produced water (water
containing elevated levels of naturally occurring radionuclides) from
coastal and offshore oil and gas drilling platforms in the Gulf of Mexico.
Dose/risk assessments in support of the drinking water standards.

Assessments of the radiosensitivity of aquatic organisms.

. Review and Development of Multimedia Models and Computer Codes for Use in
Risk Assessment

Support in the development of regulations and guidelines for the EPA required
extensive model review and development, including:

The review of 25 multimedia models for possible use in support of the soil
cleanup rule. This resulted in the selection and use of RESRAD,
PRESTO, and HHEM Part B.

The verification and validation of AIRDOS-EPA for use in support of the
radionuclide NESHAPS.

The development of guidance on the selection and use of groundwater
flow and transport models for use in support of remedial decision making
at radioactively contaminated sites.

Participation in multimedia model evaluation for the DOE Programmatic
Environmental Impact Statement (PEIS) for the DOE Environmental
Restoration program.

Development of computer codes to supplement existing codes for
assessing the doses and risks to workers and the public from recycling and
site cleanup.

. Decontamination/Decommissioning/Recycling Studies

Both the NRC and EPA are engaged in the promulgation of regulations pertaining
to the decommissioning of structures and the possible recycling of metal and
concrete. SC&A has performed several worker and public health dose/risk
assessment studies for both agencies in support of these rulemakings.

SC&A

5-13 Sol. No. 2003-N-00768


, Inc. will participate in this contract as a small, disadvantaged business
subcontractor. has never performed any work for NIOSH, ORAU, or a company teamed
with ORAU on NIOSH Contract No. 200-2002-00593, including through subcontracts.

, Inc. has never provided staff to serve as an expert witness (including non-
testifying witness) in any litigation defending worker compensation or other radiation-related
claims on behalf of DOE, a DOE contractor, an AWE, or an AWE contractor.

, Inc. does not hold any DOE prime contracts at this time. However,
and its principal, , have provided radiation-related training and other services for
DOE facilities and contractors. These services are listed below:

. provided a trainer for the Rocky Flats Environmental Technology Site
(RFETS) Plutonium Stabilization and Packaging System project. This project,
performed in 2000 under subcontract to BNFL, Inc., and Safe Sites of Colorado,
did not involve any radiation dosimetry.

. served as an environmental scientist for Jacobs Engineering
Group at the Weldon Spring Site in Missouri between 1986 and 1988. This work
did not involve any radiation dosimetry. °

. served as the Health and Safety Manager for Bendix Field
Engineering at DOE’s Grand Junction facility in Colorado in 1983 and 1984.
This job included radiation dosimetry for personnel.

In addition, was an employee of Rockwell International at the RFETS between
1978 and 1980.

This work was not related to any of the elements of the scope of work of the subject
solicitation. Therefore, it is not in conflict with the proposed work for the Advisory Board.

, Inc. has no current or past history of contracts or financial relationships that
would result in any actual or perceived conflict of interest under this contract.

2.6.1.2 Key Personnel Work History

Key personnel were also asked to review their work histories with respect to their work for DOE,
DOE contractors, AWEs, AWE contractors, NIOSH, ORAU, and ORAU primary teaming
partners. They also certified that they will not bid or perform any work for NIOSH, ORAU, or
any of ORAU’s primary teaming partners while performing work under this contract. Their
signed certifications are provided in Appendix B; summaries of this information are provided
below.

SC&A 2-20 Soi. No. 2003-N-00768


a

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

[Farea of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials|

D122.

‘Are assumptions for determining the highest
intake associated with each potential
solubility class that will produce a predicted
bioassay value equal to at least one of the
recalculated bioassay values from step
§6.1.2 appropriate? (§6.1.4)

tt
D.12d

Are assumptions used to determine the
highest intake (using a constant chronic
exposure period) that will produce a
predicted bioassay value equal to at least
one of the recalculated bioassay values from
step §6.1.2 for each potential solubility
class appropriate? (§6.1.5)

D.12e

Are assumptions used in the determination
of a scenario for each radionuclide for
which the claimant was monitored that
produces the highest 50-year committed
dose to the organ or concern appropriate?
(86.1.7)

D.1.2.£

Are assumptions used to determine annual
doses to the organ of concern using the
scenario selected in step §6.1.7 for each
radionuclide for which the claimant was
monitored appropriate? (§6.1.8)

D1.2.g

When the preliminary PC results in 250%,
are assumptions used in the refinement of
internal estimates appropriate? (§6.1.14 A-
Dand §6.5)

DA2h

Are all assumptions used in the ‘low dose’
preliminary internal dose estimate
conservative (claimant friendly)?

C-27



1.0 UNDERSTANDING THE PURPOSE AND OBJECTIVES

Exhibit 1-1 graphically presents our understanding of the overall statutory/regulatory framework
within which this contract will be implemented. Within this framework, compensation is
provided to covered employees via two administrative categories of procedures: (1) those that are
used if the individual is a member of a Special Exposure Cohort (SEC), and (2) those that are
based on a dose reconstruction and an assessment of probability of causation (PC) and are used,
in part, to determine whether compensation is warranted. The former process requires
appropriate filings and administrative determinations, but does not require a dose reconstruction.
The latter process also requires appropriate filings and administrative determinations, but will
include dose reconstructions and an assessment of PC. This proposal of work is concerned
primarily with the latter category of claimants.

Potential claimants file Forms EE-1, 2, 3, 4, and 7, as applicable, along with a narrative medical
report, with the U.S. Department of Labor (DOL). The DOL, as lead agency, authorizes the
Department of Energy (DOE) to compile all applicable records. The DOL also authorizes the
National Institute for Occupational Safety and Health (NIOSH) to begin the dose reconstruction
process. The reconstructed doses are provided to the DOL, along with documentation, in a form
appropriate for input to the computer code, Interactive RadioEpidemiological Program (IREP).
The output of IREP is used to support the adjudication process for claimant compensation.
Within this process, Section 3624 of the Energy Employees Occupational IIness Compensation
Program Act (EEOICPA) requires: (1) the formation of the Advisory Board on Radiation and
Worker Health, (2) the President to make appointments to the Board, including its chairman, and
(3) the Board to advise the President on guidelines pertaining to Section 3623(c) of the
EEOICPA (i.e., dose reconstruction and the allocation of risk), evaluate the validity of the
reconstructed doses, and evaluate other related matters. It is our understanding that the primary
role of the contractor on this project is to assist the Board in reviewing the dose reconstructions
performed in support of adjudicated claims and their accompanying administrative records.

Section 3626 of the Act also requires the Board to advise the President whether there are classes
of employees at any DOE facility that should be treated as members of an SEC. In fulfilling
these’ responsibilities, the Board will be required to make certain radiological determinations
regarding the records and exposures experienced by that cohort. The Board will also be called
upon to review SEC petitions filed under Part 83 of Title 42 of the U.S. Code of Federal
Regulations (CFR), “Special Exposure Cohort.” It is our understanding that the contractor will
be required to assist the Board in fulfilling its mission on matters related to SEC petitions. SEC
petition reviews could require a substantial level of effort and the services of highly specialized,
technically diverse, and experienced personnel. In addition, this work will need to be performed
simultaneously with basic and advanced reviews, and perhaps blind dose reconstructions. It is
for this reason that we have formed a large, technically diverse team. In addition, we are
prepared to expand upon the resources of the team members or add new tearm members, as
needed. This can be accomplished by drawing from the existing resources within our team,
adding new associates, or bringing aboard new subcontractors. SC&A is very experienced in
efficiently responding to surges of unique and highly specialized work under task order contracts.

SC&A 1-1 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials}
Review NA

C174 ‘Are assumptions for determining

uncertainty associated with reconstructing
neutron dose using survey data appropriate
(83.2.2.3)

PH

C17.

Are assumptions incorporated in the
reconstruction of neutron dose using source
term data appropriate? (§3.2.3)

CATE

Are assumptions for the uncertainty analysis
associated with reconstructing neutron dose.
using source term data appropriate?
(§3.2.3.3)

C.1.7.g

Are conservative (claimant friendly)
assumptions used for reconstruction of
neutron dose, when no monitoring data
were available?

CATb

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
neutron dose, when no monitoring data
were available?

C.18
C18.

Neutron Dose Conversion to Organ Dose:

Are assumptions used to convert area
monitoring data associated with neutron
dose to organ dose appropriate? (§4.2.1)

C.1.8.b

Are assumptions used to convert personal
monitoring data associated with neutron
dose to organ dose appropriate? (§4.2.2)

C.1.8.c

Are conservative (claimant friendly)
assumptions used to convert neutron dose to
organ dose?



BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

Are calculations of uncertainty associated
with reconstructed neutron dose using
survey data appropriate and correct?
(§3.2.2.3)

Are calculations of reconstructed neutron
dose using source term data appropriate and
correct? (§3.2.3)

Are calculations of uncertainty associated
with reconstructed neutron dose using
source term data appropriate and correct?
(§3.2.3.3)

Neutron Dose Conversion to Organ Dose:

Are calculations for converting area
monitoring data associated with neutron
dose to organ dose appropriate and correct?
(84.2.1)

C.2.7.b

Are calculations for converting personal
monitoring data associated with neutron
dose to organ dose appropriate and correct?
(84.2.2)

C28
C.28.a

Electron Dose Reconstruction Using
Monitoring Data:
Are calculations of electron dose using
dosimeters appropriate and correct?
(§2.3.1)

C.2.8.b

Are calculations of uncertainty for the beta
dosimetry results appropriate and correct?
(§2.3.1.3)

C.2.8.c

Are calculations of dose for incomplete/
missing electron monitoring records
appropriate and correct? (§2.3.2)

C-18



BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of |Description of Technical Elements of Review | Yes/No/ Comments Initials}
Review NA

C3 Consistency of External Dose Data: Evaluate whether data were consistent with site radiological

the external exposure.

C3.1

Are external dosimetry data (e.g., monitoring
periods, detection limits, etc.) consistent with
site radiological monitoring
protocols/procedures?

monitoring protocols of the time period and determine whether the protocols were adequate for monte

Were external dosimetry monitoring protocols
adequate for assessing external exposure?

Are external dose estimates based on workplace
monitoring data (¢.g., surveys, air sampling,
fixed location dosimeters) consistent with site
workplace monitoring practices/procedures?

Were site workplace monitoring protocols
adequate for assessing external exposure?

Are assessments of environmental dose
consistent with area monitoring
procedures/protocols at the site?

Were environmental dose monitoring protocols
adequate for assessing the environmental
exposure?

C-24


performance of each case or task comprising the TORP, the TORP will be subdivided into
individual cases and/or tasks, and, as required by each case, may be further subdivided into
Jower-tier tasks, such as external and internal dose-reconstruction review, worker profile review,
interview record review, and site profile review. Filing and tracking the cost and performance of
each TORP will be performed under the following work breakdown structure:

Tier 1: Task Order Number

Tier 2: Case Number
Tier 3: Dose Reconstruction
Tier 3: Worker Profile
Tier 3: Interviews
Tier 3: Site Profile

Tier 2: SEC Petition Review

Tier 2: Worker Profile Review

Tier 2: Site Profile Review

Tier 2: Ad Hoc Investigations

Using a relational database, we will be able to sort according to site (e.g., Hanford, Savannah
River, etc.), category of site (e.g., FUSRAP site, uranium processing facilities, etc.) category of
exposure (e.g., external gamma, plutonium inhalation, etc.), or any other parameter that may
serve the Advisory Board’s purposes.

While the TORP filing system is being set up, each key member of the project team (see

Section 2.1) will receive copies of the TORP for initial inspection with respect to scope,
schedule, resource requirements, and conflict of interest (COD) issues. A meeting will be held
among the key members of the project team to discuss the TORP and any supporting records and.
documentation provided with it. The meeting will be designed to accomplish the following
objectives:

° Identify questions and concerns to be discussed with the Project Officer and/or
Advisory Board representatives. If acceptable to the Project Officer and the
Board, it may also be useful to begin discussions at this time with the NIOSH
contractors who prepared the dose reconstructions.

. Identify the Case Managers and/or Task Managers and assemble the teams for
performing the work required by each case or task contained in the TORP.

° Prepare a schedule for completion and delivery of the technical and cost proposal.
Under the direction of the Project Manager, a comprehensive technical and cost
proposal will be prepared that meets the requirements of Section H.20 of the
solicitation and that will be delivered to the Project Officer within 14 calendar
days of receiving the TORP. The first step in the preparation of the technical and
cost proposals for both basic and advanced reviews is to inspect the input and
output of the IREP computer run for each case. Case Managers will then be
selected based on either their familiarity with the site or category of the site and/or
special technical issues associated with the exposures (e.g., the case is limited to

SC&A 3-3 Sol. No. 2003-N-00768


TABLE OF CONTENTS
(continued)

3.8.3 Intercomparisons of Bioassay Results among Different Laboratories . 3-37
3.8.4 Dose per Unit Measurement for Dose Reconstruction
3.8.5 Upcoming Developments with ICRP Internal Dosimetry .
3.8.6 Additional Issues Related to Internal Dose Reconstruction . .

3.8.7 Selected Issues Related to External Dose Reconstruction . +. 3-39
3.8.8 Selection of Reasonable Assumptions ........-.--.+-+-++++-05- 3-39
3.8.9 Auditor’s Assessment of a Case Significantly Differs with
NIOSH’s Dose Reconstruction Results .........-+--+++-+--+-5- 3-40
4.0 | PERSONNEL, FACILITIES, AND EQUIPMENT ........--.-2- 20 eee eee eeeee 41
4.1 Personnel ..........---++ 20s eee
4.2 Facilities and Equipment -.
4.2.1 Office and Electronic Communications Facilities .
4.2.2 Graphic and Reproduction Facilities .........-.-..2+2- esses eee
5.0 CORPORATE EXPERIENCE .........-. 000s e cece eee e cece ence eee ences 5-1
3.1 Radiological Assessment Support to the NRC and the Nuclear Power
Industry... 2... eee eee eee eee eee
5.2 Defense Nuclear Facilities Safety Board Support
5.3 Dose Reconstruction Support to Centers for Disease Control ...........-++ 5-4
5.4 Dose Reconstruction Support to the Republic of the Marshall Islands ....... 5-5
5.5 Dose Assessment Support to the Environmental Protection Agency
5.6 Selected Private Sector Experience . 2.1.0.6... cece eee eee eee eens
5.7 Dose Assessment Experience .......... 0. 0c cece eee eee tee nee
APPENDIX A: RESUMES
APPENDIX B: CONFLICT OF INTEREST FORMS
APPENDIX C: DOSE RECONSTRUCTION AUDIT CHECKLISTS
LIST OF EXHIBITS
Exhibit ES-1. Organizational Chart ..........-.- . ES-4
Exhibit 1-1. EEOICPA Regulatory Framework 1-2
Exhibit 2-1. Project Organizational Chart ............... 22. e scene 2-2

Exhibit 2-2. _SC&A Organizational Conflict of Interest Plan ............

Exhibit 2-3. Conflict of Interest Certification .........
Exhibit 3-1. Interrelationships of Activities .. . .

Exhibit 3-2. SEC Petition Audit Report and Checklist .........-...-0-20-0-----05+ 3-29

SC&A

ii Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A

2-29 Sol. No. 2003-N-00768


SC&A was a prime contractor to EPA ORIA over a 15-year period (1986 to 2000). EPA 402-B-
02-001 (October 2002) lists over 700 reports published by ORIA. SC&A was a principal
contributor to many of those reports dealing with radiological issues. Noteworthy among those
reports include:

Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), 402-
R-97-016

Environmental Characteristics of EPA, NRC, and DOE Sites Contaminated with
Radioactive Substances, 402-R-93-011, March 1993

Computer Models Used to Support Cleanup Decision Making at Hazardous and
Radioactive Waste Sites, 402-R-93-005, March 1993

Risk Assessment Guidance for Superfund (RAGS): Part A (Volume 1 - Human
Health Evaluation Manual), 540-1-89-002, December 1989

Radiation Site Cleanup Regulations: Technical Support Document for the
Development of Radionuclide Cleanup Levels for Soil, 402-R-96-011, Volumes
A,B,C,D

Radiation Exposure and Risk Assessment Manual (RERAM), 402-R-96-016

Background Information Document to Support NESHAPS Rulemaking on
Nuclear Power Reactors, 402-R-94-015

Fact Sheet: Computer Models Used to Support Cleanup Decision Making at
Hazardous and Radioactive Waste Sites, 540-F-94-022

Fact Sheet: Environmental Characteristics of EPA, NRC, and DOE Sites
Contaminated with Radioactive Substances, 540-F-94-023

Fact Sheet: Environmental Pathway Models — Ground-Water Modeling in
Support of Remedial Decision Making at Sites Contaminated with Radioactive
Material, 540-F-94-024

Fact Sheet: A Technical Guide to Ground-Water Model Selection at Sites
Contaminated with Radioactive Substances, 540-F-94-025

A Technical Guide to Ground-Water Model Selection at Sites Contaminated with
Radioactive Substances, 402-R-94-012 (prepared as a cooperative effort by EPA,
the NRC Office of Nuclear Material Safety and Safeguards, and the DOE Office
of Environmental Restoration)

Evaluating Technical Capabilities of Groundwater Models Used to Support the
Cleanup of Low-Level Radioactive Waste Sites, 402-R-93-010

SC&A

5-9 Sol. No. 2003-N-00768


At no time will SC&A delay the initiation of TORPs. Work will commence when the technical
and cost proposal for the TORP is approved and SC&A receives notice to proceed.

Tracking Progress of Cases and Task Orders

Once the TORP is approved, a Task Order will be issued. The Project Manager will oversee the
Task Order in accordance with established management, QA, and information system
requirements. Technical and administrative communications will be maintained within the
SC&A team and with the Project Officer by the SC&A Project Manager, Deputy Project
Manager and/or Case Managers, under the cognizance and direction of the Project Manager.

The level of effort for each participant on each case and on the overall Task Order will be stated
in the technical and cost proposal for the associated TORP, and each participant will be informed
of the scope of the effort and the estimate made for his/her time on the project. Moreover, the
performance of each participant will be judged in part by his/her satisfaction of the commitment
made to and performance on the project. Each participant’s actual level of effort will be
monitored carefully each month through the job-cost reports by the Case Manager and the Project
Manager, who will hold conferences to discuss issues, problems, and potential solutions related
to the project as needed, but at least weekly.

There are three basic stages to the successful tracking and controlling of contracts involving
multiple task orders and multiple cases and/or subtasks within each task order: (1) defining the
cases and/or subtasks comprising the task order; (2) entering and analyzing the activity data for
each task order, case, and subtask (cost and performance measures); and (3) updating and
reporting these data. These activities can be more easily accomplished with the aid of modem
software packages, and SC&A will use its existing automated Project Management System
(PMS) and Management Information System (MIS) programs.

Cost Projection Accuracy

One of the most important lessons learned in previous task order contracts was the need to
develop a comprehensive MIS and supporting databases to assist in cost projection and
management. The system that SC&A has developed for use on earlier task order contracts
supports invoices and monthly progress and projection reports. Moreover, the system is
extremely valuable in tracking and controlling cost and schedule performance for individual task
orders at both the task, case, and subtask level. It is supported by input data from the SC&A
accounting system. A separate database is used to track subcontractor hours and costs.

SC&A has proven systems and procedures in place for cost control. At the time a task order is
issued, SC&A assigns a job identifier to the project. If necessary, an identifier is assigned to
each case and/or subtask within the task order. Uniquely identified time sheets are routinely
issued in advance to each employee. Time sheets, Associate invoices, and subcontractor invoices
are received and posted on a monthly basis. Individuals working on a project charge their time
each day to the appropriate job identifiers. For quick-response task orders, charges are obtained
by the Case Managers weekly or even daily, if required for budget control. Project charges on

SC&A 28 Sol. No. 2003-N-00768


made. Dr. has over 20 years experience in assessing, integrating, and implementing
diverse new technologies; managing departments; and directing specialists with advanced
degrees in projects and programs, ranging from small studies to billion dollar, first-of-a-kind,
mega-projects for commercial companies, electric utilities, government agencies, and
universities. He was formerly Manager and Chief Engineer of Nuclear Engineering, responsible
for personnel and technical direction of all nuclear engineering activities, for a major
architectural/engineering firm.

Ms. will serve as the project’s Records Management specialist. Ms.

has served as records management specialist at SC&A for the past 13 years and was responsible
for health physics records management at GPU Nuclear for 10 years. She will be the central
repository for all documents and records received from the Project Officer pertaining to all Task
Order Request Packages (TORPs), all project procedures, all project deliverables, and all internal
and external correspondence. She will establish a hard copy and electronic filing system that will
maintain the confidentiality of information, while still making it accessibié to authorized
individuals in accordance with project SOPs.

Dr. and Dr. will serve as the co-lead dose reconstruction reviewers.
Dr. has extensive experience in dose reconstruction in the Marshall Islands and served as
the Radiation Protection Manager at GPU Nuclear during the cleanup of Three Mile Island
Nuclear Generating Station Unit 2. As a result, he is intimately familiar with external and
internal dosimetry issues associated with complex health physics operations. Dr. is an
internationally recognized expert on internal dosimetry. Drs. will be
directly responsible for all dose reconstruction reviews and blind dose reconstruction performed
on this project, ensuring that any individual assigned to perform dose reconstruction reviews and
blind dose reconstructions does so in accordance with the SOPs, and that deviations from the
SOPs receive the proper review, approval, and documentation.

Messrs. and and will serve as Case
Managers. Because of the large number of basic and advanced reviews required by this project,
we have elected to designate at least three Case Managers to the project reporting directly to
Drs.’ . Additional Case Managers will be assigned as the number of cases
increase. In many cases, a single person may be able to manage more than one case; while in
others, such as advanced reviews and blind dose reconstructions, one person may only be able to
manage a single case at a time. We believe strongly in the concept of a “Case Manager,” because
it helps to ensure accountability and transparency for each case.

will wear two hats on this project. In addition to his role as Deputy Project

Manager, he will serve as lead reviewer of worker and site profiles. As explained earlier,

has extensive knowledge of the health and safety issues at DOE and AWE
facilities, and is therefore especially well qualified to provide independent reviews of worker and
site profiles, as directed by the Board. ~ served as DOE’s Deputy Assistant
Secretary for Health and Safety and is intimately familiar with DOE operations and radiation
protection practices across the DOE complex. He will also support the Case Managers in the
performance of both basic and advanced reviews and blind dose reconstructions, where worker

SC&A 23 Sol. No. 2003-N-00768


doubt to the claimant. They will either serve as case managers themselves or direct reviews
performed by other case managers. In Exhibit ES-1, we have identified three case managers, but
arly member of the project team can serve as a case manager, depending on the nature of the case.

Because of their familiarity with DOE and AWE facilities, worker profile and site profile reviews

will be performed by , which will also support Drs. in advanced
reviews and blind dose reconstructions. SEC petition reviews will be performed under the
direction of is known not only for his expertise in nuclear

engineering, but also as an advocate for worker rights. We believe that his presence on the
SC&A team will enhance the credibility of our findings with the SEC applicants.

For basic reviews, the emphasis will be placed on ensuring that dose reconstructions were
performed in accordance with 42 CFR 82, as well as NIOSH procedures and guidelines, using a
hierarchy of methods (i.e., highest priority given to complete and adequate dosimetry records
and, lacking adequate dosimetry records, falling back to co-worker records and, lacking that,
falling back to area dosimeters, etc.). Basic reviews will evaluate (1) the data collection process,
(2) the claimant interview, (3) external and internal dose reconstruction, and (4) relevant NIOSH
procedures and methods. If the dose reconstruction utilized worker profile and site profile
databases, the basic reviews will also review those portions of the databases used to perform the
dose reconstructions. Our basic and advanced reviews will be performed in accordance with the
review procedures provided in Appendix C of this proposal.

Advanced reviews will go beyond the basic reviews in that they will require a much more
extensive assessment of the data collection process performed on behalf of the case. We will
critically review the records upon which the dose reconstructions were performed for
completeness and adequacy, and will compare them with the claimant interview forms and with
the worker profile and site profile databases. For the important contributors to exposure, we will
draw upon the highly specialized expertise of the members of the project team (i.e., neutron
dosimetry, criticality dosimetry, uranium and TRU internal dosimetry and bioassay, film badge
dosimetry). Our objective for both basic and advanced reviews will be to assess the consistency
and reasonableness of the assumptions and determine whether patterns emerge which reveal
fundamental flaws or systematic biases in the dose reconstruction process.

For blind dose reconstructions and advanced reviews, we will employ the entire administrative
record, perhaps visit with DOE and DOE contractor personnel, if needed, and perform
supplemental interviews, if needed and if authorized by the Board. In the case of blind dose
reconstructions, unlike basic and advanced reviews, we assume that we will not have access to
the dose reconstruction or IREP input/output prepared by NIOSH.

SC&A ES-5 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

ee

Audit Number: Claim Number:

Date: Page of

—I|

—
Area of
Review

Description of Technical Elements of Review

Yes/No!
NA

B. WORK HISTORY INTERVIEW AND CLAIMANT DO!

JCUMENTATION REVIEW PROCESS

‘Comments =

B.1 _Interview/Claimant Documentation: Evaluate whether NIOSH appropriately addressed all of the reported

work history and events represented by the claimant
occurrences, (b) actual monitoring practices, (c) personal pro’

including but not limited to (a) incidents or

tection practices, and (d) work practices.

B.1.1

Did NIOSH compare the dates of employment
at all applicable facilities provided by the
claimant to those reported by DOE/Contractor
or AWE site records?

Did NIOSH compare the locations of
employment throughout the work history as
declared by the claimant to those reported by
DOE/Contractor or AWE site records?

7

Did NIOSH review site profile data/facility
records to identify radiation incidents (such as
contamination or over-exposures) declared by
the claimant?

Did NIOSH compare radiation monitoring
practices (such as monitoring frequency,
bioassay monitoring programs, etc.) as
described by claimant to facility monitoring
procedures/records?

BAS

Were facility records associated with personal
protection practices (e.g., the use of shielding,
glove boxes, respirators, etc.) compared to
those described by claimant?

B16

Did NIOSH compare work practices as
described by the claimant to site profile
data/facility records?

B17

Did NIOSH review worker/facility data to
identify work-required medical screening x-rays
records declared by the claimant?

C3


significant inventory of factory-calibrated field sampling devices and health and safety
equipment is maintained at the laboratory. This inventory includes a full complement of
radiation survey equipment, including alpha scintillation probes, beta/gamma survey meters, and
gamma scintillation probes. The laboratory is pre-qualified with the U.S. Army Industrial
Operations Command under the category of “Characterization and Verification.” The laboratory
holds a radioactive materials license (No. 1150) with the Office of Radiation Control in the
Alabama Department of Public Health and is certified in several other states to characterize
radioactive waste.

SC&A also operates a regional office in St. Louis, Missouri, which provides quality assurance
and auditing services.

4.2.2 Graphic and Reproduction Facilities

SC&A’s production department creates a wide range of documents, presentations, and exhibit
materials. Our word processing and graphics capabilities include state-of-the-art desktop
publishing software, enabling us to create high-quality documents in a variety of formats. Using
graphics software such as Adobe Hlustrator, Adobe PhotoShop, Microsoft PowerPoint, Aldus
PageMaker, Claris Draw, Corel Draw, and T/Maker ClickArt, SC&A staff are also able to
illustrate documents and create effective presentation and exhibit materials.

The McLean office of SC&A is equipped with two Canon ImageRunner 550 reproduction
machines, one of which is networked for access from the individual workstations. These high-
volume copiers produce high-quality copies at rates of up to 83 copies per minute and are used
for reproduction of technical reports, manuals, and handbooks. They are equipped with
automatic feed and sorters, and can produce double-sided copies. Both machines are maintained
by factory-trained technicians and are serviced regularly. SC&A maintains a full complement of
laser and inkjet color and black-and-white printers.

SC&A 4-27 Sol. No. 2003-N-00768


. Time period for which data are available compared to the period for which the
worker in question worked a particular job.

. Whether a worker also performed other jobs that are not typical of those who are
members of a group for whom dose data are available.

. Solubility information regarding the chemical form of radionuclides to which a
particular worker or group of workers were exposed.

° How frequently bioassay data were taken for individual workers or for workers
belonging to the group from which dose for an individual might be imputed.

. When, how much, and in what form, recycled uranium was processed or present,
and whether data exist from which the transuranic and fission product
contamination of the recycled uranium can be determined or reasonably inferred.

. Handling of film badges and use of correction factors.

The checklist presented in Exhibit 3-2 provides a systematic review of the above considerations
and other specific information that SC&A proposes to use in performing these reviews.
However, this checklist is simply a guideline and may not contain all of these elements that can
and may be used for an audit. Each petition, and the information required for its review, will be
considered on a case-by-case basis. A “Comments” section is provided in the checklist if the
auditor chooses to elaborate or describe information which is not contained in the checklist.

The need to combine both a systematic review of criteria, such as that contained in the checklist,
with expert judgment of the radiological dosimetry and operation history of a facility can be
illustrated at any number of DOE sites.

For example, at Fernald, “blowouts” occurred in furnaces at Fernald, where UF, was reduced to
U metal. Workers present during blowouts or who were given the job of cleanup immediately
afterwards (if they were from the production area) might be in a different subcategory than the
other production workers in this area. Witness information can be useful not only in determining
unusual accidents, but also for determining accidents and process upsets that were not so
unusual, but nonetheless not part of the planned normal production process. Another example of
this kind of problem would be uranium chip fires, which were prevalent at a number of DOE
sites handling uranium metal.

At Los Alamos TA-33 (Tritium Facility), workers frequently lacked respirator protection while
working in tritium-contaminated atmospheres. When significant exposures occurred, some
workers would expedite urinary excretion by consuming large amounts of liquids; others would
delay routine bioassay monitoring. Exposure would vary by the particular job being performed,
the individual worker’s work practice, and ventilation present in the work area at the time. The
only area monitoring was an area tritium alarm set at relatively high activity levels. A
determination of the ability to reconstruct these doses would hinge on a combination of witness
interviews, historic area alarming data, and available dose records, and a judgment on their

SC&A 3-26 Sol. No. 2003-N-00768


2.5 Quality Control Procedures

SC&A strictly adheres to a time-tested corporate Quality Management Plan (QMP) and
implementing procedures. For the past three years, SC&A has been performing work on several
NRC contracts under project-specific Quality Assurance Project Plans (QAPPs) approved by the
Office of Nuclear Regulatory Research of the NRC.”

SC&A’s corporate QMP mandates the use of the American National Standard Institute’s
ANSI/ASQC E4-1994, “Specifications and Guidelines for Quality Systems for Environmental
Data Collection and Environmental Technology Programs,” which is a national consensus
document that sets forth mandatory specifications and nonmandatory guidelines for the planning,
implementation, and assessment of a quality system for programs involving environmental data
collection and environmental technology. SC&A’s QMP, developed in October 1997, specifies
the requirements, responsibilities, and guidance pertaining to total quality management and is
intended, to the extent practical, to adopt verbatim the language of ANSI/ASQC E4-1994.
Therefore, SC&A considers the QMP to be an over-arching blueprint for conducting quality
work. A copy of this QMP is available for review upon request.

As discussed in detail in the example tasks, and provided in Section 3 and Appendix C of this
proposal, SC&A has prepared a detailed set of SOPs and checklists for the basic and advanced
review of cases and SEC petitions.:'The procedures are tied to the Office of Compensation
Analysis and Support (OCAS) guidelines for dose reconstruction for external and internal
exposures, and the requirements set forth in 42 CFR Parts 82 and 83. These procedures
constitute SC&A’s draft project-specific QAPP. Specifically, the QAPP and associated SOPs
document that following has been done:

. The task's technical and quality objectives are identified and agreed upon.

. Activities affecting the achievement of the quality objectives are identified and,
via SOPs, conducted in a controlled manner. ‘

. SOPs implementing quality requirements are identified and in place prior to the
start of work.
. The intended measurements or data acquisition methods are appropriate for

achieving task objectives; the assessment procedures are sufficient for confirming
that data of the type and quality needed and expected are obtained; and that any
limitations on the use of the data can be identified and documented.

? NRC-04-01-049, Technical Basis Information for Clearance of Materials and Equipment, NRC Project
Officer Dr. Carl Feldman and NRC-04-01-065, Technical Assistance in Finalizing NUREG-1640, NRC Project
Officer Dr. Robert Meck.

SC&A 2-13, Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

| ‘Audit Number: Claim Number:

Date: Page of

Description of Technical Elements of Review | Yes/No/

NA

Comments

Initials

Do assumptions used in determining
occupational medical exposure geometry
give the benefit of doubt to the claimant?

CAALI

Are assumptions used to determine the most
credible geometry for environmental
exposure appropriate? (§4.4.3)

CLlij

Do assumptions used in determining
environmental exposure geometry give the
benefit of doubt to the claimant?

Dose

C.2_ External Dose Calculations: Verify external dose calculations are appropriate for purposes of
determination of POC using NIOSH-IREP. (Parenthetical number represents the section within the “Ext

Reconstruction Implementation Guideline” (OCAS-IG-001

conducting the appropriate portion of the dose reconstruction.)

) that provides detailed methodology for

ternal

C21

Are calculations in the initial dose assessment
(ie., rough estimate of exposure) for
determining whether the case falls into a very
low or very high potential exposure category
appropriate and correct? (§1.4)

Photon Dose Reconstruction Using Monitoring

Are calculations of photon dose using
monitoring data (i.e., dosimeters)
appropriate and correct? (§2.1.1)

C22.b Are calculations of dosimeter dose
uncertainty associated with photon exposure
appropriate and correct? (§2.1.1.3)

C.2.2.¢ Are calculations of dose for incomplete/

missing photon monitoring records
appropriate and correct? (§2.1.2)



concerned that the decisions being made under the Act are fair, consistent, and well grounded in
the best scientific knowledge, and that they give the benefit of the doubt to the claimant.

SC&A 14 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

C.1.10.b

Are assumptions for the uncertainty analysis
associated with reconstructing electron dose
using co-worker data appropriate?
(§2.2.1.3)

C.1.10.c

‘Are assumptions incorporated in the
reconstruction of electron dose using survey
data appropriate? (§3.3.2)

C1100

Are assumptions for determining
uncertainty associated with reconstructing
electron dose using survey data appropriate
(83.3.2.3)

C.1.10.€

Are assumptions incorporated in the
reconstruction of electron dose using source
term data appropriate? (§3.3.3)

C.1.10£

‘Are assumptions for the uncertainty analysis
associated with reconstructing electron dose
using source term data appropriate?
(§3.3.3.3)

C.1.10.g

Are assumptions incorporated in the
reconstruction of electron dose to non-
routine radiological workers using
radiological control limits appropriate?
(§3.3.4)

C.1.10.b

Are assumptions for the uncertainty
associated with reconstructing electron dose
using radiological control limits
appropriate?

C1104

‘Are conservative (claimant friendly)
assumptions used for reconstruction of
electron dose, when no monitoring data
were available?

C-12



. From 1994 through 1996, under contract with the Continental Minerals
Processing Division of Alcoa, SC&A performed a radiological characterization of
zirconia sands.

Since none of this work is concerned with radiation dosimetry nor with any of the elements
of the scope of work of the subject solicitation, it does not constitute a conflict with the
proposed work for the Advisory Board.

Finally, SC&A has never performed work under contract with NIOSH, ORAU, or the
ORAU primary teaming partners (performing under Contract #200-2002-00593).

2.6.1.1 Subcontractor Work History

During preparation of this proposal, subcontractors and their personnel were asked to review
their work histories with respect to their work for DOE, DOE contractors, AWEs, AWE
contractors, NIOSH, Oak Ridge Associated Universities (ORAU), and ORAU primary teaming
partners. They also certified that they will not bid or perform any work for NIOSH, ORAU, or
any of ORAU’s primary teaming partners while performing work under this contract. Their
signed certifications are provided in Appendix B; summaries of this information are provided
below.

» Inc.

, Inc., being a relatively new small business (incorporated in 2001), has had no contracts
with Federal agencies including DOE and its operating contractors. It has one active contract,
with Johns Hopkins University, in support of biodefense activities at the Center for Civilian
Biodefense Strategies. *s first government contract proposal will be as a subcontractor
member of the SC&A bid team.

, Inc., has never performed any work for NIOSH, ORAU, or a company teamed with
ORAU on NIOSH Contract No. 200-2002-00593, including through subcontracts.

, Inc. has never held contracts to provide expert witnesses (including non-testifying
witness) in any litigation defending worker compensation or other radiation-related claims on
behalf of DOE, a DOE contractor, an AWE, or an AWE contractor.

, Inc. has never performed work for DOE, a DOE contractor, an AWE, or an AWE
contractor, including through subcontracts.

, Inc. has never worked at a DOE or AWE site under contract to DOE, a DOE contractor,
an AWE, or an AWE contractor, including through subcontracts.

, Inc. has no current or past history of contracts or financial relationships that would result
in any actual or perceived conflict of interest under this contract.

SC&A 2-18 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials’

D235

Ate calculations to determine the
concentration of each radionuclide in the
breathing zone using source term data (¢.g.,
dispersible quantity of material, .
resuspension factors, etc.) appropriate and
correct? (§5.3)

D23.k«

Are calculations to estimate internal dose

using workplace monitoring data
appropriate and correct?

D.2.3.1

Are uncertainty calculations associated with
the estimated intake quantity using
workplace monitoring data appropriate and
correct?

D.2.3.m

Are calculations to determine dose from

occupational radon exposure appropriate
and correct? (§7.4)

D23.0

Are uncertainty calculations associated with

occupational radon exposure appropriate
and correct? (§7.4)

D224

Are all internal dose calculations performed in
accordance with 42 CFR §82.18?

Le

C-37


SC&A

4-15

Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

=

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials,

C.19.a

Electron Dose Reconstruction Using
Monitoring Data:
Are assumptions used in the calculation of
electron dose using dosimeters appropriate?
(§2.3.1)

C.1.9.b

‘Are assumptions used in the uncertainty
analysis for the beta dosimetry results
appropriate? (§2.3.1.3)

C.1.9.¢

Are assumptions used to calculate dose for
incomplete/missing electron monitoring
records appropriate? (§2.3.2)

C.1.9.d

Are assumptions used in determining the
uncertainty associated with
incomplete/missed electron monitoring dose
appropriate? (§2.3.2.3)

C19.

Are assumptions used in the dose
calculation from skin contamination
appropriate? (§2.3.3.2.2)

C1OF

Are assumptions used in determining
uncertainty associated with the calculation
of dose from skin contamination
appropriate? (§2.3.3.3)

C19g

‘Are assumptions used in calculating dose
from electron exposure and associated
uncertainty conservative (claimant
friendly)?

C.1.10
C.1.10.a
it

Electron Dose Reconstruction With NO

Monitoring Data:
Are assumptions incorporated in the
reconstruction of electron dose using co-
worker data appropriate? (§3.3.1)

C-1l



SC&A 48 Sol. No. 2003-N-00768


SC&A 1-5 Sol. No. 2003-N-00768


SC&A 4-14 Sol. No. 2003-N-00768


SC&A 4-19 Sol. No. 2003-N-00768


This particular task, which lasted two years at a cost of about $500,000, required
retrieval and in depth review of hundreds of recently declassified documents,
which included data logs, telegraph communications, redacted documents, hand
written reports, very old overflight radiological surveys, film badge readings,
results of radiological surveys performed using primitive and poorly calibrated
instrumentation, and the review of bioassay data that was sparse, used primitive
techniques, and was contradictory. We visited remote atolls of the Marshall
Islands and spent extensive periods of time (weeks) interviewing these people to
elicit their personal experience and recollection of events that took place almost
50 years ago. This experience is invaluable in terms of the lessons learned with
regard to what it means to reconstruct historical doses under difficult situations.

As a result of this work, we believe we have uncovered major discrepancies
between the whole body, thyroid, and GI tract doses experienced by the
Marshallese as compared to the doses reported by the Government at that time and
to this day. The people of the Marshall Islands have learned to trust us to
objectively report our findings and defend our work before government tribunals
and the DOE. We believe that, in providing these services, we have not only
earned the respect of the people of the Marshall Islands, but also our counterparts
at the DOE and the various independent consultants that have been reviewing our
work. The two key individuals that were responsible for this work, Drs.

, are key individuals on this proposed project for the
Advisory Board.

. Performance of MARSSIM radiological surveys for selected northern atolls for
the purpose of determining whether remediation is required or to certify that the
islands comply with the cleanup criteria.

This involved sending a survey team to collect samples of soil, water, and food
items on the Island of Ailuk. The samples were analyzed at SC&A’s laboratory in
Montgomery, Alabama and in the RMI laboratory in Majuro. Before analyzing
the samples in the Majuro lab, SC&A refurbished the lab, and installed and
calibrated new counting equipment. As part of the project, SC&A trained six
Marshallese in field sampling procedures and worked closely with Marshallese
laboratory personnel in performing sample analyses at the Majuro lab.

. Evaluation of the northern atolls for PCB contamination.

Concern was expressed by the people of Enewetak and Bikini that their atolls may
have also been contaminated with PCBs resulting from the facilities constructed
on Enewetak and the ships that were sunk in the lagoon of Bikini atoll. SC&A
collected soil, lagoon sediment, and fish and analyzed the samples for a broad
range of PCB congeners and trace heavy metals.

Our scope of work included defending our analyses before the Nuclear Claims Tribunal for
claims amounting to over $1 billion. On four separate occasions, SC&A consultants participated

SC&A 5-7 Sol. No. 2003-N-00768


In the cases in which a worker handled, in the same monitoring period, two or more
radionuclides that emit both high and low photon energies, the evaluation of the external photon
dose using photographic dosimetry becomes more difficult. For early dosimetric systems, it is
possible that only the high energy or only the low energy component of the dose was reported.
Again, if the calibration, evaluation, and dose reporting procedures are available, the uncertainty
in the dose estimates may be assessed. With the advent of LiF TLD monitoring systems, this
problem no longer exists due to the lower energy dependence of LiF.

To evaluate the organ dose, it is necessary to discriminate the energy spectrum of the photon field
into the three‘energy bands established in OCAS-IG-001. The evaluation of dose through film
dosimetry or TLDs normally requires the previous evaluation of the average energy of the photon
field that is being measured. This energy is, however, not always reported together with the
dose. In these cases, it is necessary to determine the radionuclide or radionuclides the worker
handled over the monitoring period to determine the relevant energy spectrum. The
determination of the relative distribution using the site relative inventory or the review of
historical operations is recommended in item 2.1.1.2 of OCAS-IG-001.

As for the neutron dose (item 2.2, OCAS-IG-001), even today, neutron dosimetry is subject to
large uncertainties. The main problem is that film and TLD neutron dosimeters have a large
energy dependence, together with the fact that the energy range of neutron fields is huge (a few
eVs to many MeVs—around seven orders of magnitude). The dosimeter may be typically
calibrated for one energy spectrum, and to the others a “calibration factor” was applied. Even
today, an uncertainty of + 100% and - 50% for any neutron dose, would be considered an
“acceptable result.” All procedures recommended in item 2.2 of OCAS-IG-001 will be followed.
The OCAS-IG-001 document defines five energy ranges for neutron fields. The establishment of
the neutron field energy spectrum is therefore important for the calculation of the organ dose.

All data available will be carefully analyzed. All sources of complementary data will be used, for
example, neutron energy spectrum studies made at a number of work places using Bonner
Spheres and published in the literature. These studies might even be applied to early dates if
conditions remained the same. Another example is the use of the ratio of neutron to gamma dose
in workplace situations for which it has been well-established.’ Also, when TLD techniques were
used'to determine the neutron dose, the photon dose was also evaluated and should have been
recorded. In these cases, the ratio can serve as an estimate of the missing neutron dose for cases
when the neutron source geometry and the laboratory moderation are relatively unchanged and
where only the photon dose was evaluated and recorded.

For electron dose reconstruction using film dosimeter records (item 2.3.1, OCAS-IG-001), it is
important to determine whether the worker was also exposed to low energy (15 - 25 keV) photon
fields, as these can leave an image similar to an electron irradiation on film dosimeters.

Although the calibration process and energy dependence of the film emulsion lead to
uncertainties in the electron dose evaluation process, the main source of uncertainty is due to the
short range of electrons in air and clothing and the irradiation geometry. For example, consider a
worker doing decontamination work and directly handling a source of beta-gamma radiation.

The electron dose registered on the thorax dosimeter would be quite low, and the electron dose to
the skin of the thorax could be considered zero due to the shielding of the worker's clothing.
However, the electron dose to the hands would be much greater, and, unless reliable extremity

SC&A 3-22 Sol. No. 2003-N-00768


may be used by NIOSH during its evaluation. NIOSH is responsible for collecting all relevant
information in order to accurately and fairly evaluate petitions for SEC. By definition, addition
to the SEC depends on NIOSH’s ability to do a dose reconstruction, therefore the auditor must be
able to decide if NIOSH exhausted all of the information sources and elements that make up an
accurate dose reconstruction. In most cases, performing an audit on an SEC petition evaluation
moust also involve an audit of the dose reconstruction (see the Dose Reconstruction Review
Checklist).

These completed forms will be filed in hard copy and electronic form under our records
management system, and auditable under our quality control/quality assurance program. All
audit findings are documented on the forms, and traceable back to the auditor and the documents
upon which the audit review was performed.

SC&A 3-28 Sol. No. 2003-N-00768


review, and especially an advanced review or a blind dose reconstruction, could require a
considerable level of effort. Because we expect that the level of effort required for each case that
comprises a TORP can vary widely, we have elected to begin the process of preparing technical
and cost proposals by first sorting the cases into two categories: those requiring a relatively large
level of effort with several staff members, and those that could be performed by a single
individual in a relatively short period of time.

Notwithstanding uncertainties in the scope of a given review, we also understand that we must
make the best estimates we can in the scope, schedule, and resources required, given the limited
information currently available to us. We believe that the basic reviews of many cases could be
performed by a single person in a matter of a few days. However, some basic reviews may
require several technical specialists and a week or more to complete. We believe that all
advanced reviews will require a minimum of a three-person team, including the Case Manager,
and several weeks to complete.

The functional-areas that will be performed in a basic review will include dose reconstruction
reviews and claimant interview record reviews (according to the checklists in Appendix C). But
it is our understanding that, if the dose reconstruction for a given case also required the
utilization of worker and site profile information, even our basic reviews will require us to
review at least a portion of the worker profile and site profile databases.

We believe that advanced reviews, using our procedures in Appendix C, will be much more
extensive than the basic reviews because they will require ensuring that all sources of potentially
relevant information and records were considered. This could include meetings with site
personnel and cross-checking the claimant interview questionnaire with the data used for the
dose reconstruction and with the worker profile and site profile databases. If authorized by the
Board, advanced reviews and blind dose reconstructions may require meetings with site
personnel,' requests for additional information, and perhaps supplemental claimant interviews
(again, if authorized by the Board and if approved by the claimant or the claimant’s
representative). We will likely also review co-worker records and interview co-workers,
especially if dosimetry records are deficient.

Such reviews certainly sound like they could easily grow into very large efforts, and, in theory,
they can. However, at the same time, as stated earlier, these reviews are not research projects.
Our objective is not to reconstruct highly precise and complete historical doses. Rather, our goal
is to perform reviews that will identify areas in which the method used to reconstruct the doses
(1) may have errors or systematic biases, and/or (2) could have resulted in substantively errant
reconstructed doses. We believe that, on average, each team will be able to complete a basic
review and deliver its work product to the Board within one week from the date of authorization
to proceed. However, some cases may require a somewhat longer period of time. For advanced
reviews and blind dose reconstructions, we believe that we will be able to deliver our work

1 We understand, based on our review of the pre- proposal conference meeting minutes, that visits to DOE.
sites will not be necessary, but offsite meetings with key DOE and DOE contractor personnel may be required as part
of advanced reviews and blind dose reconstructions.

SC&A 2-5 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

‘Audit Number: Claim Number: Date: Page of
[Area of | Description of Technical Elements of Review | Yes/No/ ‘Comments
Review NA
D.15.e Are assumptions used to determine missed

internal dose associated with bioassay
measurements below detection limits
appropriate? (§7.3 and §8.3)

DASA Are assumptions used to estimate internal
dose when there are gaps in bioassay
measurements appropriate? (§6.3)

DAi5.g Are assumptions used in the reconstruction
of internal dose using co-worker data
appropriate? (85.1)

D.1S.h Are assumptions used to reconstruct
internal dose using bioassay measurements
conservative (claimant friendly)?

D.1.6 Internal Dose Reconstruction Considerations
Associated with Workplace Mor 2. Data:
D.1.6.a Are assumptions used to determine the

radionuclide(s) of concern for each intake
using workplace monitoring data (¢.g., air
samples, contamination surveys, etc.)
appropriate? (§5.2)

E

D.1.6.b Are assumptions used to estimate the
concentration of each radionuclide in the
breathing zone using workplace monitoring
data (e.g., air samples, contamination
surveys, etc.) appropriate? (§5.2)

D.1.6.c Are assumptions regarding the use of
respirators and respiratory protection
factors appropriate? ($5.2)

D.1.6.d Ave assumptions regarding the effectiveness

of the respirator program (i.e., whether a
qualitative fit test was performed and
whether the respirator was worn during the
time of intake) appropriate? (§5.2)



SC&A

4-16

Sol. No. 2003-N-00768


Finally, SC&A has in place an approved Government Property Control System which will
govern the management of any government-furnished property under this contract.

2.4.2 Subcontractor Management

As the prime contractor, SC&A will be responsible for overall project management. SC&A's
ability to manage, control, and ensure the performance of subcontractors is demonstrated by the
very substantial experience that SC&A has amassed in utilizing subcontractors in the
performance of work for the Federal government over the past 22 years. In the case of task
orders with substantial subcontractor participation, SC&A exercises rigorous oversight of
subcontractor work, closely monitoring costs and deliverables. Subcontractors are held to tight
adherence with deliverable schedules. SC&A Case Managers will participate in all subcontractor
meetings with NIOSH and the Advisory Board, and directions will come directly from SC&A.

SC&A will have a subcontract with each team subcontractor. The subcontracts will contain our
standard terms and conditions and any particular clauses required by our contract with CDC.
SC&A’s Contracts Manager, in consultation with the Program Manager, will be responsible for
ensuring that the subcontractors follow contract requirements.

The management of the subcontractors is the responsibility of SC&A’s Project Manager,

Dr. . He will regularly interface with the Subcontractor Project Managers. The
Subcontractor Project Manager serves several roles. He or she will be responsible for the
subcontractor’s performance in completing work assignments under the contract; in this capacity,
the Subcontractor Project Manager will serve as the “point person” for the subcontractor
company. The Subcontractor Project Manager will also serve as a technical specialist on work
assignments. and will serve as the Subcontractor Project
Managers for and » Tespectively. , President of >
Inc., our 8(a), woman-owned business subcontractor, will serve as the Subcontractor Project
Manager for

The previous discussion applies to subcontractors who are already on the SC&A team. However,
for work requiring a specialty niche contractor, SC&A would search for the capabilities required
and solicit proposals from qualified firms. A sole-source award will be made if the requirement
is not excessively large and it is clear that, by virtue of location and capabilities, a particular
offeror is eminently qualified to perform the work. In this case, a cost proposal will be solicited
from the offeror and a subcontract negotiated and submitted to the Contracting Officer for
approval (if a level-of-effort (LOE) subcontract is negotiated—consent is not required from the
Contracting Officer if the subcontract is under $25,000 and is fixed price). If a sole-source award
is not appropriate, a competition of a few (probably three) firms will be held over a short time
period. Proposals would be evaluated and a subcontract awarded to the firm that offers the most
advantageous proposal to the Government, considering both technical and cost factors. If
consent is required, the subcontract would be submitted to the NIOSH Contracting Officer prior
to its execution by SC&A.

SC&A 2-10 Sol. No. 2003-N-00768


records. The following describes our approach to basic and advanced claimant-interview
reviews, including the checklist in Appendix C that includes elements addressing the NIOSH
questionnaire. This will be used to evaluate the completeness of the NIOSH questionnaire and to
compare the information provided by the claimant or survivor during the interview with the other
information in the administrative record.

The audit of worker and family interviews will include (1) specific elements relating to the use of
each worker interview that is audited in the process of dose reconstruction, and (2) general
elements relating to the methodological aspects of the relationship of interviews to dose
reconstruction.

Specific Elements

The audit of every worker interview will be closely coordinated in each case with the various
elements of the overall audit of the dose reconstruction for that worker. Specifically, the audit
will involve:

. Determining whether the elements of the worker interview regarding frequency of
film badge changes, the components and frequency of various types of monitoring
of internal burdens of radionuclides, and the monitoring of the general air in the
work environment have been checked against the facility profiles for the period in
question and against the dose records of the worker.

. Checking how the discrepancies between the worker’s account, the dose records,
and facility profiles have been dealt with in regard to the estimation of the
uncertainties in the dose estimates from particular radionuclides.

Depending on the results of the dose reconstruction, highly specific “forensic health physics”
follow-up inquiries may be required. For instance, a worker job description might include sitting
astride uranium metal ingots to stamp serial numbers on them (as was the practice at Fernald).
The film badge doses could seriously underestimate external exposure to the gonads, and hence
the total effective dose equivalent (TEDE), and misrepresent the doses to specific organs of
interest. As another example, the time at which urine samples are taken may influence the
concentration of uranium in the urine. For instance, Monday morning urine samples taken after
coffee would tend to reduce reported concentrations relative to actual averages. In addition,
depending on the solubility of the compound, Monday morning urine or feces samples may also
result in an underestimate of doses. Such practices could distort dose estimates, especially if
samples were taken infrequently. Other important questions include: (1) Did the worker collect
24-hour excreta samples or just an aliquot? and (2) Was the worker under medication (diuretics,
for example, may affect the excreted activity and other drugs may affect the analytical processing
of the samples)? Worker interviews will be used as a way of checking on the completeness of
specific aspects of workers’ dose records and to help focus follow-up inquiries to find records
that may be missing or misplaced and which could be critical to the dose reconstruction and the
resulting PC calculations. The audit will include an evaluation of the adequacy of such efforts
deriving from worker interviews.

SC&A 3-7 Sol. No. 2003-N-00768


SC&A 412 Sol. No. 2003-N-00768


SC&A 2-22 Sol. No. 2003-N-00768


a

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

[ Area of | Description of Technical Elements of Review | Yes/No/
Review NA

Comments

Tnitial

D.4 Missing/Unmonitored Internal Dose: Evaluate the treatment of ‘missed internal dose’ and/or ‘unmonitored
|| _ internal dose’ if relevant to the case.

DAL Are ‘missed/unmonitored’ internal doses
reconstructed in accordance with 42 CFR
§82.16 and using guidelines established in
OCAS-IG-002?

D42 Are the types of information used to

substitute/supplement ‘missed/unmonitored’
internal doses reconstructed in accordance with
specifications in 42 CFR §82.17 and using
guidance in OCAS-IG-002?

D43

‘Were all relevant factors surrounding the
claimant’ s exposure scenario (e.g., distance
from source, work activities, etc.) properly
taken into account when evaluating
‘missed/unmonitored’ internal dose?

D44

Was the bioassay program at the time
considered when selecting the most appropriate
method for estimating ‘missed/unmonitored’
internal dose?

D45

Are data adequate for employing commonly
used practices/techniques/professional
judgments in estimating ‘missed/unmonitored’
intemal doses?

C39


|||
BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials,
Review NA

B.2 Data Consistency: Assure that interview information is consistent with data used for dose estimate.

B.2.1 Is there consistency between the dates of

employment at all applicable facilities provided
by the claimant and the DOE/Contractor or
AWE site records?

B22 Is there consistency between the locations of
employment throughout the work history as
declared by the claimant and the
DOE/Contractor or AWE site records?

B23 Is there consistency between facility records
and radiation incidents identified by claimant?

B.2.4 Is there consistency between radiation
monitoring practices described by claimant and
site radiological monitoring protocols?

B25 Is there consistency between personnel
protection practices described by claimant and
site profile data?

=

B.2.6 Is there consistency between claimant’s
description of work practices and facility
procedures/records?

C4


product to the Board within four weeks from authorization to proceed. In cases in which the
review reveals unresolved data inconsistencies, questionable assumptions, calculational errors, or
similar discrepancies, it may be beneficial and expeditious to develop a working relationship
with the original authors of the dose reconstructions that we are requested to review.

It is our expectation that the first few basic and advanced reviews will require more time to
complete because we will be on a learning curve. However, as we become more familiar with
worker and site profiles, our efficiency will continually increase and the level of effort and time
required to perform basic, advanced, and blind dose reconstructions will continually decrease.

Assuming each advanced review and blind dose reconstruction will require a three-person team
and four weeks to complete (not all team members will be devoted to each review for the entire
duration of the review), and given that our project team consists of 35 individuals, SC&A will be
able to form as many as 10 teams to readily meet the solicitation requirements of 70 Basic
Reviews, 70 Advanced Reviews, 10 Blind Reviews, 5 Worker Profile Reviews, and 5 Site
Profile Reviews during the first year, including tasks related to worker profile and site profile
reviews, SEC petition reviews, and other ad hoc investigations. We have assembled'a large team
with the specific objective of providing the ability to handle widely varying work loads and
highly diverse cases, some of which may require very unique and specialized expertise.

Dr. and Mr. will interact directly with the Case Managers on technical progress
and issues pertaining to their specific work products. The Case Managers will be responsible for
their respective cases, including planning, scheduling, and cost control, as well as the technical
quality of the deliverables. They will be accountable to the Project Manager for ensuring the
timely and cost-effective preparation of high-quality deliverables. More specifically, the Case
Managers will be responsible for the following:

° Supervising all work performed by the staff assigned to their cases

. Ensuring that work is performed in conformance with project SOPs and quality
assurance (QA) requirements

. Reporting the status of assigned work to the Project Manager
2.3 Procedures and Training

All reviews and audits performed on the project will be performed and-documented in
accordance with SOPs for auditing external and internal dose reconstructions, worker profiles,
claimant interviews, site profiles, and SEC petitions (see Section 3). Each of the key members of
the project team and each Case Manager will be trained in the use of these procedures at SC&A’s
expense.

SC&A 2-6 Sol. No. 2003-N-00768


for performing blind reviews will be in accord with OCAS-IG-001 and OCAS-IG-002, with all
the qualifiers for ensuring quality that are described in depth in the other sections of this
proposal. Upon completion of each blind review, the work products will receive the same
independent advanced review audits as performed for NIOSH dose reconstructions as a form of
quality assurance documentation.

3.6.1 Internal Dosimetry Procedures and Software.

For internal exposures, the document OCAS-IG-002 recommends for dose reconstruction
purposes the use of the International Commission on Radiological Protection’s (ICRP) most
recent biokinetic and dosimetric models. Bioassay measurements, when available and reliable,
should be used as a basis for relevant dose calculations. The interpretation of monitoring
bioassay results, using ICRP models, requires the derivation and use of intake retention functions
(describing body and organ contents) and excretion functions (describing activity in excreta), as a
function of time following intake. Once the intake is estimated, the committed effective dose
and the annual/committed organ dose are calculated by multiplying the intake by the appropriate
dose coefficient.

As the models describing the uptake, distribution, and retention of radionuclides taken into the
body are complex, the interpretation of bioassay data requires the use of a computational code
that is based on the recommendations of the ICRP. Publication 78 of the ICRP [Individual
Monitoring for Internal Exposure of Workers, Annals of the ICRP 27 (3-4), Pergamon, 1997.]
gives limited information on the interpretation of bioassay data for selected radionuclides, for
selected times after an acute intake and some graphical information on chronic intakes.

We will use NIOSH guidelines to perform blind reconstructions, and NIOSH-recommended
software. If the Task Order does not specify particular software, we will use a computational
code that uses the ICRP’s most recent biokinetic and dosimetric models. There are few computer
codes that utilize the new ICRP models. Most of them are not commercially available, were
developed by ICRP members, and are used in their home institutions. The ICRP does not
recommend the use of any particular software. The one we will use, if agreed by the Task Order,
was developed by ICRP members and was officially adopted by the International Atomic Energy
Agency (IAEA), for use in Latin America in its program for Harmonization of Internal Dosimetry
Programs, involving 10 countries in Latin America. This software has been benchmarked against
ICRP 78 for all radionuclides and all times contained in the publication and reproduces ICRP 78
graphs for chronic intakes. It has all features necessary to reconstruct occupational radiation dose
from internally deposited radionuclides as specified in OCAS-IG-002.

This software accepts input information on various types of measurements, e.g., urine, feces,
lung, thyroid, bone, whole body, etc. Urine activities may be given as 24-hour excretion rates or
on a per liter excretion rate. If given on a per liter basis, unless otherwise specified, a nominal
excretion rate of 1400 milliliters (ml( of urine per day will be used. Fecal excretion activities
may also be given as 24-hour excretion or on a per gram or per gram of fecal ash basis. Unless
otherwise specified, the nominal excretion rate of the ICRP reference man will be used. The
software accepts inhalation of gases and particles, ingestion, and injection as routes of entry. It
accepts inputs on information on the elements or compounds, such as number of radionuclides
available for intake (item 4.2, OCAS-IG-02), physical-chemical characteristics of the compound

SC&A 3-18 Sol. No. 2003-N-00768


APPENDIX C

DOSE RECONSTRUCTION AUDIT REPORT

Page of

Audit Number:

| Claim Number:

| Date:

Auditor(s)/Area of Review:

Audit Record Summary (Describe below what records you examined, person contacted/interviewed, what
conclusions were drawn, and how you arrived at your conclusions): .

List the type of records reviewed (e.g., administrative record):

List of persons contacted/interviewed:

List of new documents identified: (Attach a copy of all documents not included in the original dose reconstruction

to this report.)

Audit Conclusions: Agree/Disagree
‘Note: Attach all audit checklists and
supporting documents.)

Agree: nitial)
Include any additional comments
in ‘General Comments’ below.

Disagree: (Initial)
Additional discussion should be
provided in the next section.

Provide a summary discussion of reasons for disagreeing with the dose reconstruction results:
(Attach all calculations, notes, reports, etc. used in your conclusions.)

General Comments:

iz

Signature of Auditor(s):

Area of Review:

Date:

—

BASIC INDIVIDUAL DOSE RECONSTRUCTION

Ci



Force at U.S. Nuclear Power Plants," AIF/NESP-028, May 1984. This experience has many
similarities to the development of worker and site profiles.

SC&A developed for the nuclear power industry methods for predicting worker doses. The
objective was to determine how accurate are current state-of-the-art estimates, and to develop a
method which improves the accuracy of these estimates. Initially, using data collected from
representative nuclear power plants, estimated doses were compared with actual doses in an
attempt to explain the reasons for discrepancies. The results of these comparisons were used to
guide the development of a method to improve the accuracy of these estimates.

The developed method comprises three building blocks--an overall logic, checklists, and
worksheets. A logic diagram guides the estimator through a series of steps, each of which
involves the completion of a checklist or worksheet. The checklist systematically solicits the
information needed to prepare the estimate, including appropriate adjustment factors. The
worksheets are used to organize information and perform calculations needed to construct the
dose estimate. The final report described the application of the method to the engineering design
process, and presented a sample problem which illustrates its application.

The report was published as AIF/NESP-039, Estimating Doses in Nuclear Facilities with
Emphasis on the Design Process, January 1987. The method was also programmed for
implementation on a desk-top computer. The program is contained on a floppy disk included
with the program description in NUMARC/NESP-001, DOSES: A System for the Personal
Computer to Estimate Radiation Exposure at Nuclear Facilities.

Though these investigations were performed on behalf of NRC and its licensees many years
ago, the experience and lessons learned have applicability to historical exposures
experienced by workers at DOE and AWE facilities at that time.

SC&A is currently supporting NRC's effort to develop the technical basis for a rulemaking
establishing residual radioactivity contamination standards for the clearance of materials and
equipment from licensed facilities. SC&A is characterizing the quantities and radiological
composition of materials and equipment that may be affected by the rule, and supporting the
development of cost models for use in determining material dispositions for the collective
dose/risk assessment and the cost/benefit analysis portion of the Regulatory Impact Analysis.

As part of the characterization investigations, SC&A was instrumental in the development of a
database characterizing the quantities, types, and radionuclide composition of systems, facilities,
and equipment for more than 11,000 facilities in a number of industrial and government sectors.
SC&A is currently working on two follow-on contracts. The first is to finalize NUREG-1640,
entitled “Radiological Assessments for Clearance of Equipment and Materials from Nuclear
Facilities,” for the Office of Nuclear Regulatory Research. NUREG-1640 contains methods for
translation of concentrations of radioactivity in or on certain metals and concrete into radiation
doses as a result of decontamination and survey of these materials. SC&A is performing an
analysis of individual dose assessments for the clearance of materials and equipment, resolving
public comments on NUREG-1640, and preparing the manuscripts and other materials for final
publication. Under the second contract, SC&A is providing technical assistance for both

SC&A 5-3 Sol. No. 2003-N-00768


of members of the public on and offsite since the commencement of operations in 1949. This
bibliographic database was designed to facilitate research into the historical non-occupational
exposures at INEEL. Based on this experience, SC&A understands the challenges associated
with the retrieval of critical historical records related to dose reconstruction.

On June 21, 2002, CDC authorized SC&A, in cooperation with SENES Oak Ridge, to proceed
with a research project that included:

. Calculation of the chronic and episodic airborne radionuclide releases from the
Idaho Chemical Processing Plant (ICPP) for the years 1957, 1958, and 1959, from
the criticality accident that occurred in October 1959, and from the series of 31
Initial Engine Tests of the Aircraft Nuclear Propulsion Program (ANP).

° Determination of the historical doses to members of the public both on and offsite
from these releases.

The project also involves the search for additional records as required for the above research and.
adding them to the bibliographic database, attending meetings of the INEEL Health Effects
Subcommittee (a Federal Advisory Committee), and preparing fact sheets regarding the project
and our findings. The results of this research are to be used by CDC to determine the need for
follow-up investigations into the potential impact of these radiation doses on public health.

5.4 Dose Reconstruction Support to the Republic of the Marshall Islands

SC&A provided technical support to the Office of the Public Advocate, Central Government, and
the Local Government Councils of Enewetak, Bikini, Rongelap, and Utrik Atolls of the
Republic of the Marshall Islands in matters relating to the resettlement of the northern atolls and
public health and land claims compensation due to radioactive contamination and radiation
exposures resulting from nuclear weapons testing in the Central Pacific. These services included
the following: .

. Evaluate the current and future, and actual and potential, radiation doses and
radiological health risks to the critical population groups and the average members
of the populations of the northern atolls of the Marshall Islands from
radionuclides in the environment due to nuclear weapons testing.

The evaluations used existing data (supplemented in some cases by confirmatory
sampling and analyses) characterizing the radionuclide concentrations in soil,
foods, air, and water to develop three-dimensional representations of the
contamination profiles on the islands. Radiation doses and health risks were then
derived using the methodologies recommended by the EPA and site specific
information regarding diets, living habits, and environmental transfer constants on
the islands.

SC&A 5-5 Sol. No. 2003-N-00768


Finally, we assume that we may be called upon to
review worker and site profile databases and
perform special studies as requested by the
Board. It is for this reason that we have
assembled a large, highly experienced project
team. With the SC&A team, the Board can be
assured of a contractor who is dedicated to the
pursuit of information, technical and scientific
integrity, and high standards of quality. This will
be an important contract to SC&A, and it will
receive the timely attention of senior
management. The resources assembled for this
proposal are among the best in the world and can
be relied upon to recognize, understand, and meet
the substantial challenges of conducting reviews
and audits that will withstand the most intense
scientific scrutiny and be accepted by the
claimants as fair and unbiased. In addition, the
three attributes of the SC&A team—depth of
expertise, vast Federal contracts experience, and
no conflict of interest—make us the best possible
choice to fulfill the requirements of this proposal.
The project team stands ready to assist the Board
in any way possible.

Unique Qualifications

SC&A staff represent some of the most
experienced and nationally recognized experts
in health physics and internal and external
dosimetry.

SC&A has vast experience in managing large
task-order contracts, particularly those dealing
with radiological issues.

SC&A has extensive experience in historical
document retrieval for the purposes of dose.
reconstruction.

SC&A has a corporate Quality Management
Pian and Standard Cyvrating Procedures that
meet ANSI and EPA requirements.

By teaming with , we bring to the
project extensive knowledge of the DOE
complex and AWE facilities and its historical
practices.

By teaming with , we bring to the project a
vast amount of hands-on experience in radiation
protection practices.

SC&A ES-6

Sol. No. 2003-N-00768


SC&A 4-10 Sol. No. 2003-N-00768


Exhibit 2-2. SC&A Organizational Conflict of Interest Plan
(continued)

SC&A 2-27 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials
Review NA

DA3A Are all assumptions used in the ‘high dose’

preliminary internal dose estimate
conservative (claimant friendly)?

D4 Detailed Internal Dose Reconstruction - Key

Initial Considerations:

DlAa Are assumptions used to determine the date
of uptake(s) appropriate? ($7.1)

D.1.4.b Are assumptions used to determine the
route of entry of applicable radionuclides
into the body appropriate? (§4.1)

D.1.4.c Are assumptions used in the selection of
applicable solubility class(es) for each
radionuclide appropriate? (§4.3)

D.1.4.d Are assumptions used to determine whether
the exposure was chronic or acute
appropriate?

D.14¢e Are assumptions used to determine particle
size of all inhaled radionuclides
appropriate? (§4.4)

DAF Are assumptions used to select the
applicable ICRP biokinetic model for each
radionuclide appropriate? (§2.0)

D148 If more than one ICD code describes organs

associated with only one region calculated
by ICRP models, are assumptions in the
calculation of organ dose appropriate?
(§3.1.1)

C-29


High-Level Waste Studies

SC&A performed numerous studies for EPA on the risks associated with the
management of high-level radioactive waste (HLW). These studies included:

- Waste characterization.
- The review of performance assessment models.
- Uncertainty analysis.

- The evaluation of release and exposure scenarios, their probabilities, and
the associated radionuclide releases to the accessible environment.

- Waste transportation studies.
Uranium Mill Tailings

In addition to the NORM risk assessments, SC&A performed several studies in
support of the uranium mill tailings standards. These studies included the
modeling of the risks from radon, dust suspension, direct radiation, and the
contamination of groundwater.

Low-level Radioactive Waste (LLW)

SC&A assisted the EPA in the promulgation of 40 CFR 193. This work involved
revising PRESTO to reflect updated waste characteristics, site characteristics, and
disposal technologies. SC&A has also performed risk assessments in support of
the siting of LLW storage facilities for NRC licensees.

Radiation Worker Dose/Risk Assessment
SC&A performed several worker radiation dose studies in support of:

- The revised 10 CFR 20 for the NRC.

- Worker training requirements for the NRC.

- Radiation protection guidelines for EPA workers.

- Health physics consulting for NRC licensees.

- ALARA studies for NUMARC and AIF.

- Dose/risks to workers due to site cleanup at numerous NORM sites.

Safety Analysis and Emergency Planning
Except for the HLW studies, the above studies are oriented toward exposures

associated with normal, as opposed to transient or accident, conditions. Accidents
or severe external events can be the limiting scenario for the risks to workers, the

SC&A

5-14 Sol. No. 2003-N-00768


SC&A

4-17

Sol. No. 2003-N-00768


Exhibit 2-3. Conflict of Interest Certification

TEAM MEMBER AND INDIVIDUAL CONFLICT OF INTEREST CERTIFICATION
CONTRACT RESULTING FROM CDC SOLICITATION NUMBER 2003-N-00768

SC&A 2-30 Sol. No. 2003-N-00768