Department of Energy

Office of Worker Protection Programs and Hazards Management

Radiological Control Technical Position

RCTP 95-07

Conformance with Department of Energy Laboratory Accreditation Program Requirements

Issue:

Title 10, Code of Federal Regulations, Part 835, Section 402 (10 CFR 835.402), Occupational Radiation Protection, establishes requirements for monitoring individual exposures to ionizing radiation. Section 402(b) requires that personnel external dosimetry programs be adequate to demonstrate compliance with the occupational exposure limits in section 202 and to demonstrate conformance with the requirements of the Department of Energy Laboratory Accreditation Program (DOELAP) for personnel dosimetry. Since the publication of 10 CFR 835 and its requirement for DOELAP conformance, some contractors have questioned the status of their previously established program exceptions and whether or not these programs meet the requirements of 10 CFR 835.402(b).

Introduction:

Section 402(b) requires that personnel external dosimetry programs be adequate to demonstrate conformance with DOELAP requirements. This provision is supported by article 512 of the DOE Radiological Control (RadCon) Manual, which refers the user to DOE Order 5480.15 for DOELAP accreditation requirements.

Discussion:

The DOELAP was established by the Department to ensure the integrity of personnel dosimetry results. The accreditation process includes both an evaluation of dosimeter performance against established criteria and an onsite assessment of system quality assurance, documentation, and technical adequacy. The program is administered under DOE Order 5480.15, DOELAP for Personnel Dosimetry, which establishes general guidelines for program administration. Detailed implementation guidance is provided in DOE/EH-0026, Handbook for the DOELAP for Personnel Dosimetry Systems and DOE/EH-0027, DOE Standard for the Performance Testing of Personnel Dosimetry Systems.

Both DOE Order 5480.15 and DOE/EH-0026 indicate that certain programs may be excepted from DOELAP accreditation. These programs include those administered by:

  • Some B-clause contractors. These contractors conduct DOE activities under contracts that include the Radiation Protection and Nuclear Criticality clause. Such contractors typically use contracted dosimetry services accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) and do not report significant personnel doses; and
  • Other contractors specifically excepted by the Headquarters DOELAP Administrator.
Article 512 of the RadCon Manual requires that the External Dosimetry Program Technical Basis Document address dosimeters monitoring radiation outside the scope of DOELAP. Chapter IV, section G.1 of G-10 CFR 835/C2, External Dosimetry Program Implementation Guide (IG) indicates that the Technical Basis Document should address quality assurance procedures for these dosimeters.

Technical Position:

Based upon the information cited above and the requirements of 10 CFR 835 and the RadCon Manual, programs excepted from DOELAP under the specific exception criteria established in the governing documents of that program are considered to be operated in conformance with the program. However, these programs would not be considered to be in conformance with DOELAP if conditions established in granting that exception, such as maintenance of NVLAP accreditation, were not maintained by the contractor. In accordance with the IG and the RadCon Manual, the External Dosimetry Program Technical Basis Document should reflect the basis for these exceptions and define acceptable quality assurance measures to be implemented in lieu of DOELAP accreditation.

References:

  1. 10 CFR 835, Occupational Radiation Protection, U.S. Department of Energy, December 14, 1993. 
  2. DOE/EH-0256T, DOE Radiological Control Manual, Revision 1, U.S. Department of Energy, April 1994. 
  3. DOE Order 5480.15, Department of Energy Laboratory Accreditation Program or Personnel Dosimetry, U.S. Department of Energy, December 1987. 
  4. DOE/EH-0026, Handbook for the Department of Energy Laboratory Accreditation Program or Personnel Dosimetry Systems, U.S. Department of Energy, December 1986. 
  5. DOE/EH-0027, Department of Energy Standard for the Performance Testing of Personnel Dosimetry Systems, U.S. Department of Energy, December 1986. 
  6. G-10 CFR 835/C2, External Dosimetry Program Implementation Guide, Revision 1, November 1994. 
http://www.hss.energy.gov/HealthSafety/WSHP/radiation/doelaptp.html
Last modified: Wednesday May 21 2008