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


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


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


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


, 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


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


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


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


SC&A 2-21 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


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


. 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


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


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


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


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


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


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


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



¥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


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


. 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 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


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


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


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


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


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


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


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


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


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


, 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


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


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


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