Radiation Protection: Occupational Radiation Protection Program

Draft 12/20/2006

FUNCTIONAL AREA GOAL: This CRAD is intended to provide guidance for evaluation of the occupational radiation protection program. The goal of the criteria is to answer two fundamental questions:

Is the Operating Contractor or DOE Entity implementing, and effectively managing an occupational radiation protection that meets the requirements of Title 10 Code of Federal Regulations, Part 835 (10 CFR 835), Occupational Radiation Protection?
Is the DOE Field Element providing effective oversight, program direction, guidance, and requirements to the Operating Contractor or DOE Entity?

REQUIREMENTS:

10 CFR Part 835, Occupational Radiation Protection (Final Rule)
DOE Order 231.1, ES&H Reporting
DOE Order 231.1A, Environment, Safety and Health Reporting
DOE Policy 411.1, Safety Management Functions, Responsibilities, and Authorities Policy
DOE Order 5480.19, Conduct of Operations Requirements for DOE Facilities
DOE Order 5480.20A, Personnel Selection, Qualification, and Training. Requirements for DOE Nuclear Facilities
DOE Policy 450.4, Safety Management System Policy 450.4
DOE Acquisition Regulations (DEAR, 48 CFR 970.5223-1, 970.5204-2, and 970.5215-3)
DOE Policy 450.5, Line Environment, Safety and Health Oversight

GUIDANCE:

Radiation Protection Guides
DOE G 441.1-10 (Guide, 05/24/1999, EH) Posting and Labeling for Radiological Control Guide
DOE G 441.1-11 (Guide, 05/20/1999, EH) Occupational Radiation Protection Record-Keeping and Reporting Guide
DOE G 441.1-12 (Guide, 03/17/1999, EH) Radiation Safety Training Guide
DOE G 441.1-13 (Guide, 04/15/1999, EH) Radioactive Sealed Source Accountability Guide
DOE G 441.1-2 (Guide, 03/17/1999, EH) Occupational ALARA Program Guide
DOE G 441.1-3A (Guide, 06/11/2005, EH) Internal Dosimetry Program Guide
DOE G 441.1-4A (Guide, 06/11/2005, EH) External Dosimetry Program Guide
DOE G 441.1-5 (Guide, 04/15/1999, EH) Radiation-Generating Devices Guide
DOE G 441.1-6 (Guide, 04/29/1999, EH) Evaluation and Control of Radiation Dose to the Embryo/Fetus Guide
DOE G 441.1-7 (Guide, 6/17/1999, EH Portable Monitoring Instrument Calibration Guide
DOE G 441.1-8 (Guide, 03/17/1999, EH) Air Monitoring Guide
DOE G 441.1-9 (Guide, 6/17/1999, EH) Radioactive Contamination Control Guide

Radiation Protection Standards

Radiological Control Programs for Special Tritium Compounds (DOE-HDBK-1184-2004)
Guide of Good Practices for Occupational Radiological Protection in Uranium Facilities, DOE-STD-1136-2004
Guide of Good Practices for Occupational Radiological Protection in Plutonium Facilities, DOE-STD-1128-98 Change Notice 1, February 2005
Internal Dosimetry Technical Standard, DOE-STD-1121-98, Reaffirmed May 2003
Radiological Control Standard, DOE-STD-1098-99, Reaffirmed December 2004

Training - Radiation Protection Standards

DOE HDBK-1145-2001 Radiological Safety Training for Plutonium Facilities
DOE HDBK-1143-2001 Radiological Control Training for Supervisors
DOE HDBK-1141-2001 Radiological Assessor Training
DOE HDBK 1110-97 ALARA Training for Technical Support Personnel, Change Notice 1, November 2004
DOE STD-1107-97 Knowledge, Skills, and Abilities for Key Radiation Protection Positions at DOE Facilities, Reaffirmed with Erratta, June 2005
DOE HDBK-1108-2002 Radiological Safety Training for Accelerator Facilities
DOE HDBK-1106-97 Radiological Contamination Control for Laboratory Research, Change Notice 1, December 2004
DOE HDBK-1105-2002 Radiological Training for Tritium Facilities (Handbook and Overheads)
DOE HDBK-1109-97 Radiological Safety Training for Radiation-Producing (X-Ray) Devices, Reaffirmation with Errata, July 2002
DOE HDBK-1113-98 Radiological Safety Training for Uranium Facilities, Reaffirmation April 2005
DOE HDBK 1130-98 Radiological Worker (RW) Training (Reaffirmed May 2004)
DOE-HDBK-1122-99 Radiological Control Technician (RCT) Training (Reaffirmed November 2004)
DOE HDBK 1131-98 General Employee Radiological Training (GERT) (Reaffirmed April 2004))

Other Guidance

Radiological Control Technical Position Papers

Performance Objective 1: Contractor Program Documentation

DOE expects under its Integrated Safety Management System (ISMS) philosophy that; line management has documented a formalized, and effective organization for managing the occupational radiation protection program.

Criteria:

The Operating Contractor's Safety and Health Organization has a documented occupational radiation protection management program in place based on DOE Regulations and Directives and recognized consensus standards, i.e. the American National Standards Institute (ANSI). The program defines the technical areas and the frequency at which each technical area is assessed. For each technical area there is a procedure for performing the occupational radiation protection assessment which defines the purpose, scope, responsibilities, assessment criteria, and references. The assessment documentation includes; the occupational radiation protection assessment and sampling methodology, laboratory analysis method used, report findings, corrective actions, review, and distribution of reports.
The Operating Contractor has documented clear definition of responsibility for decisions by senior management, provision for escalation of occupational radiation protection matters involving significant occupational radiation exposures and hazards to DOE in an appropriate time frame.
The Operating Contractor has a documented site wide planning and budgeting process include priorities for managing occupational radiation exposures and hazards.
The Operating Contractor's Safety and Health Organization has documented implementation plans for the occupational radiation protection program.
The Operating Contractor has established formal documentation defining clear lines of authority and responsibility for management of the occupational radiation protection program. Responsibilities of each staff position are defined for worker health activities. Internal and external interfaces within and between the DOE Field Element, the Operating Contractor, and with outside groups (i.e., State, local, and regional health officials and other government agencies) are clearly and formally defined for each position.
The Head of the Operating Contractor's Safety and Health Organization ensures that they develop and maintain a written occupational radiation protection program in conformance with 10 CFR 835.

Performance Objective 2: Operating Contractor's Program Implementation

DOE expects under DOE Directives that the Operating Contractor manage, implement, and verify a technically sound occupational radiation protection program.

Criteria:

The Operating Contractor has fully integrated its occupational radiation protection program into the Contractor's work planning and execution process.
The Operating Contractor's Safety and Health Organization prepares an annual schedule showing the occupational radiation protection assessments planned.
The Operating Contractor's Safety and Health Organization submits to the DOE Field Element, a list of the dates on which occupational radiation protection technical assessments were preformed.
The Operating Contractor's audit tools include; procedures for performing occupational radiation protection assessments, worksheets, periodic standard report formats, reference material, training material, which are provided to staff performing assessments.
The Operating Contractor's Safety and Health Organization has a system in place to control, maintain occupational radiation protection procedures and guides current. This system includes a mechanism for updating and distributing procedures, and internal guides on a specified schedule.
The Operating Contractor's Safety and Health Organization performs analyses on significant occupational radiation protection assessment findings. The Operating Contractor has identified people responsible for correcting an occupational radiation protection deficiency. The actions necessary to correct that deficiency are addressed and a schedule for implementing corrective actions established.
The Operating Contractor's Safety and Health Organization performs trend analysis of findings from the occupational radiation protection programs. Identifiable trends are communicated to the DOE Field Element. Corrective actions are identified and mutually agreement is reached.
The Operating Contractor's Safety and Health Organization has a tracking system that includes all occupational radiation protection findings. The system identifies corrective actions, schedules, and progress made on corrective actions. Other information such as results of root cause analyses is also included in the tracking system. A method to flag or highlight significant events or actions is included in the tracking system.
The Operating Contractor's Safety and Health Organization ensures that management processes, activity hazards identification and analysis, and functional technical appraisals in specific occupational radiation protection subject areas are included in the contractor's program and are integrated into the Contractor's safety management, work planning and execution system. This might include: activity hazards analysis, exposure assessments, hazard controls and, the specific technical program elements (e.g., ALARA, training, internal exposure, external exposure, posting, labeling, access control, work control, instrumentation, records, reports).
The Operating Contractor line management tracks the effectiveness of its implementation of the occupational radiation protection program by reviewing the findings of its internal assessments of the program. Problem areas identified are addressed promptly.
The Operating Contractor has an effective corrective action program and organizational structure for resolving related action items. Contractor performance with respect to completing corrective actions is documented, reported, and tracked.
The Operating Contractor's Safety and Health Organization has adequate staff with a level of professional training, experience commensurate with the requirements for implementation of the occupational radiation protection program.
The Head of the Operating Contractor's Safety and Health Organization ensures that internal self-assessments of occupational radiation protection are conducted.
The Head of the Operating Contractor's Safety and Health Organization ensure compliance with mandatory standards for assessing and managing occupational radiation protection hazards.
The Operating Contractor's occupational radiation protection assessment staff is adequately trained in occupational radiation protection assessment. The training addresses familiarization with all mandatory regulations, DOE/ANSI standards, guidance documents, and other references that are pertinent to the technical area; use of procedures for conducting the assessment and, instructions on preparing reports and related documentation.
The Operating Contractor's Occupational Radiation Protection Organization prepares performance indicator reports, utilizes performance indicators involving occupational radiation exposures, and other operations information. This includes; radiation exposure monitoring, NTS reports, ORPS reportable occurrences, for performing trending and analysis to provide early identification of potential exposure hazards and/or deteriorating/improving occupational radiation protection conditions.
The Operating Contractor provides management periodic summaries of performance on the assessment and management of occupational radiation protection hazards.
The Operating Contractor has developed program management goals related to occupational radiation protection hazards. The goals are measurable and include short-term (annual) and long-term goals (several year period) to assess and manage occupational radiation protection hazards. Progress towards goals is monitored regularly and goals adjusted as necessary. Line managers have performance elements in their personnel appraisal relating to successful attainment of program management goals.

Performance Objective 3. DOE Oversight

DOE expects under its ISMS philosophy and the Department of Energy Acquisition Regulations (DEAR) that, DOE program elements conduct formal oversight and contractual control of the radiation protection program.

Criteria:

The DOE has provided the Operating Contractor with adequate program direction guidance, standards, orders, clear priorities, and goals to facilitate meeting 10 CFR 835 requirements.
The DOE Field Element Safety and Health Organization review the follow up of corrective actions involving occupational exposures and ensure that root causes are documented. The DOE Field Element Safety and Health Organization independently tracks the findings from the contractor's audits.
The DOE Field Element Safety and Health Organization verify that the contractor has assigned qualified staff to perform internal audits of the radiation protection program.
The DOE Field Element Safety and Health Organization verify that contractor audit personnel are adequately trained to perform their duties related to occupational exposures. Training includes conduct of audits and overview of procedures as well as training to ensure technical expertise.
The DOE Field Element review of corrective action plans related to occupational radiation protection program deficiencies address all findings, issues, and root causes.
The DOE Field Element Safety and Health Organization has verified that the Contractor has ensured that management processes, activity hazards identification and analysis, functional technical appraisals in specific subject areas are included in the contractor's program and are integrated into the Contractor's safety management, work planning and execution system. This might include conducting independent review or sampling of the Contractor's: management concerns (e.g., policy, directives, organization, communication, operating procedures, coordination, staffing and professional development, facilities, equipment, and support, budget review, accident/incident investigation, performance analysis, quality assurance); activity hazards analysis, exposure assessments, hazard controls and, the specific technical program elements (e.g., ALARA, training, internal exposure, external exposure, posting, labeling, access control, work control, instrumentation, records, reports).
The DOE Safety and Health Organization conducts technical appraisals of Operating Contractors radiation protection program at least once every 3 years.
The DOE Field Element provides effective oversight and implementation of the contractor award fee evaluation. The DOE also ensures that appropriate percentages are applied to the evaluation of program performance against agreed objectives and requirements. The DOE Field Organization award fee determinations are consistent with audit reports and self-assessments. The DOE award fee determinations are integrated with performance indicator reports, occurrence reports, accident, illness, injury data, corrective action plans, and closeout of findings.
The DOE Field Element has an adequate number of staff with technical skills assigned to carry out oversight of the radiation protection.
The DOE Safety and Health Organization prepares an annual schedule showing the oversight of the Contractor's radiation protection program planned for the following year.

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