Department of Energy (DOE) Radiological Control Manual

Chapter 1 - Excellence in Radiological Control

Part 1 - Department of Energy (DOE) Radiological Control Manual

Table of Contents (Articles 11x)

• 111 Radiological Control Policy
• 112 Manual Applicability and Control
• 113 Compliance
• 114 Site-Specific Manual
• 115 Application of Requirements
• 116 User Groups

Article 111 - Radiological Control Policy

A key element of the Radiation Protection Guidance to the Federal Agencies for Occupational Exposure approved by President Reagan on January 20, 1987, and a fundamental principle underlying this Manual is:

"There should not be any occupational exposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causing the exposure."

The Department of Energy is firmly committed to having a Radiological Control Program of the highest quality. This applies to those DOE activities that manage radiation and radioactive materials and that may potentially result in radiation exposure to workers, the public and the environment.

The Department of Energy Radiological Control Policy shown below summarizes the elements of the Department of Energy Radiological Health and Safety Policy and is intended to guide the actions of every person involved in radiological work throughout the Department.

Personal radiation exposure shall be maintained As-Low-As- Reasonably-Achievable (ALARA).

Radiation exposure of the work force and public shall be controlled such that radiation exposures are well below regulatory limits and that there is no radiation exposure without commensurate benefit.

Each person involved in radiological work is expected to demonstrate responsibility and accountability through an informed, disciplined and cautious attitude toward radiation and radioactivity.

Excellent performance is evident when radiation exposures are maintained well below regulatory limits, contamination is minimal, radioactivity is well controlled and radiological spills or uncontrolled releases are prevented.

Continuing improvement is essential to excellence in radiological control.

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Article 112 - Manual Applicability and Control

This Manual establishes practices for the conduct of Department of Energy radiological control activities. The Manual states DOE's positions and views on the best courses of action currently available in the area of radiological controls. Accordingly, the provisions in the Manual should be viewed by contractors as an acceptable technique, method or solution for fulfilling their duties and responsibilities. This Manual shall be used by DOE in evaluating the performance of its contractors.

The Manual is not a substitute for Regulations; it is intended to be consistent with all relevant statutory and regulatory requirements and shall be revised whenever necessary to ensure such consistency. Some of the Manual provisions, however, challenge the user to go well beyond minimum requirements. Following the course of action delineated in the Manual will result in achieving and surpassing related statutory or regulatory requirements.

1. The provisions of this Manual apply to DOE or DOE-funded activities performed at DOE sites or facilities, where radiation or radioactive material is present or being used.

2. The provisions of this Manual also apply in those cases where contractors or subcontractors are used to conduct DOE- funded radiological activities at non-DOE sites or facilities, and such organizations do not possess one of the following:
   1. A U.S. Nuclear Regulatory Commission (NRC) license
   2. An Agreement State license
   3. An appropriate state license, registration, or certification with a documented radiation protection program, plan, and procedures which provide a level of protection equivalent to that required by DOE, NRC or other appropriate Federal standards.

   The lead Secretarial Officer and the Office of Environment, Safety and Health shall be included in the review and concurrence process in these situations. In those cases at non-DOE sites or facilities where a specific radiological activity is being conducted pursuant to an NRC or Agreement State license, or appropriate state license, registration, or certification, the provisions of this Manual are not binding to that activity.

3. The provisions of this Manual are not binding upon activities at DOE sites that are mandated by legislation to be performed pursuant to an NRC license including activities certified by the NRC under section 1701 of the Atomic Energy Act.

4. This Manual is a living document. DOE intends to review and update provisions on a periodic basis to incorporate lessons learned and suggestions for improvement. The Assistant Secretary for Environment, Safety and Health is responsible for this task. Recommendations to correct or improve this Manual are encouraged and should be sent to the Radiological Control Program Advisor (Article 151) of the Secretarial Officer responsible for the affected work activity. Information copies should also be sent to the other members of the Radiological Control Coordinating Committee (Article 153). The Secretarial Officer will transmit such recommendations to the Office of Environment, Safety and Health for consideration. The recommended wording of the change, as well as the basis and justification for the change, should be included.

5. The Department of Energy intends to incorporate by reference the provisions in this Manual into contracts or regulatory plans, as appropriate. These incorporated provisions shall be enforceable pursuant to the contract or underlying regulations. No exception to or interpretation of an incorporated provision shall be provided pursuant to the contract. When incorporating a provision, DOE shall approve an implementation plan that includes a compliance schedule. It is expected that implementation of this Manual will occur in a phased manner over a period of time consistent with the schedules and resources identified in the DOE-approved implementation plan.

6. This Manual shall be kept current and should be entered into the contractor document control system. The Office of Environment, Safety and Health shall ensure that a current version of this Manual is maintained on the DOE Safety Performance Measurement System (SPMS).

7. The provisions of this Manual do not apply to facilities and activities of the Naval Nuclear Propulsion Program, which are separately covered under Executive Order 12344 (42 U.S.C 7158, note) and patients undergoing medical treatment at a DOE or DOE-funded facility.

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Article 113 - Compliance

1. This Manual sets forth DOE's views on the proper course of action in the area of radiological control within the scope of DOE sponsored activities. If a user fully implements a provision, the user will have complied with, and most likely exceeded, any related statutory, regulatory, or contractual requirement. When incorporated into contracts, the provisions of the Manual are binding requirements. The words "shall" and "should" have the meaning below when a provision is incorporated into a contract.

2. The word "shall" identifies those elements and requirements that have been considered and found by DOE to be mandatory unless prior approval of an alternative approach is obtained from DOE Headquarters. If a contractor wishes to implement an alternative approach, the contractor shall submit the suggested alternative approach to the lead Secretarial Officer for review. Prior to final approval by the lead Secretarial Officer, other affected Secretarial Officers and the Office of Environment, Safety and Health shall concur on the suggested alternative approach. The submittal shall contain the description of the alternative approach, the technical rationale and basis, the suggested wording and justification that the alternative will achieve equal or improved performance employing equal or better techniques, solutions or methods.

3. The word "should" means the contractor has the responsibility of either following the provision or demonstrating technical equivalency by an alternative solution. The use of "should" recognizes that there may be site- or facility-specific attributes that warrant special treatment and that literal compliance with the elements and requirements of the provision may not achieve the desired level of radiological control performance. In those cases where a contractor decides to follow an alternative technique, approach or method in lieu of the "should" provision, the following actions are required:

4. The alternative solution shall be documented, with supporting technical basis, analysis and justification to demonstrate technical equivalency.

5. Prior to implementation, the approval of the Radiological Control Manager and the contractor's senior line manager responsible for operations shall be required. DOE approval is not required nor expected.

6. The documented justification, including the required approvals, shall be readily retrievable for review and audit by DOE.

7. At the conclusion of each calendar year each contractor shall provide to the DOE Operations Office Manager and the lead Secretarial Officer a tabulation of all such equivalency determinations approved within the past 12 months. For ease of reference, these may be referred to as Article 113 determinations.

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Article 114 - Site-Specific Manual

1. A Site-Specific Radiological Control Manual that invokes the requirements of this Manual shall be issued and endorsed by the contractor senior site executive. The Site-Specific Radiological Control Manual does not require review or approval by the DOE. One approach in the development of Site-Specific Radiological Control Manuals is to invoke the provisions of this Manual as written with site specific additions, supplements and clarifications clearly indicated, included in the appropriate chapters and directly referenced to the corresponding Article. Additions and supplements to address unique situations or to provide more detailed or prescriptive direction may be included only if these additions do not conflict with or diminish the requirements of this Manual. The contractor senior site executive is that person at a DOE contractor-operated facility or site who has final on-site corporate authority and is often called President, General Manager, Site Manager or Director.

2. Management policies, requirements, expectations and objectives for the site Radiological Control Program should be clearly and unambiguously stated.

3. The Site-Specific Manual shall be kept current and entered into the contractor document control system.

4. Where a site has multiple facilities, there should be one manual for the site and one Radiological Control Organization. If a prime contractor manages several DOE sites, effort should be made to have one corporate Radiological Control Manual that applies to all of that prime contractor's DOE sites. For a site that has multiple prime contractors, a common manual, with facility, contractor or building specific guidance to accommodate unique considerations, should be issued and endorsed by each contractor's senior site executive. For prime contractors who manage several sites but who also operate sites with more than one prime contractor, the site manual should take precedence over the corporate Radiological Control Manual.

5. Subcontractors shall comply with the Site-Specific Radiological Control Manual.

6. Where DOE employees are conducting the transport of nuclear devices or components, a Program Specific Radiological Control Manual, based upon the provisions of this Manual, shall be issued and approved by the DOE Operations Office Manager. Controlled copies of such Manuals shall be provided to the lead Secretarial Officer.

Article 115 - Application of Requirements

1. This Manual assumes that most facilities or sites have organizations in place that generally meet the requirements presented in the text. It is not the intent of this Manual to unnecessarily create new or separate organizations if those functions can be incorporated into existing ones. For example, the Radiological Awareness Committee functions of Article 132.3 may be performed by an existing safety committee. It is expected, however, that the existing committee charter be revised to reflect the requirements and emphasis of this Manual. Similarly, titles such as Radiological Control Manager and Radiological Control Technician that are used in the Manual may locally be designated differently. A phased approach to transition to the use of the titles of positions in this Manual should be adopted. Corresponding position descriptions and organizational charts should be revised to accurately reflect required radiological responsibilities.

2. The degree of program formality and extent of the associated administrative process are expected to be commensurate with the radioactive material contamination and dose potential. For example, a site with an annual collective effective dose equivalent of one person-rem or less, that works with small quantities of unsealed radioactive material, would not be expected to have an ALARA program as complex as one required at higher dose sites. At low dose sites some program elements may be satisfied by brief policy statements.

Article 116 - User Groups

1. Contractors are encouraged to establish informal working associations that promote dialogue among the Radiological Control Organizations from similar or comparable facilities. User Groups should include representation from various contractors. Assignment of members to the user groups should be on a rotating basis.

2. To assist contractors in identifying and adopting proven practices and implementing procedures in a timely manner within the DOE Complex, contractors are encouraged to develop through the User Groups Radiological Work Practices Handbooks that can be used by a given category or class of facilities associated with the User Group.

   Suggested User Group categories are as follows:

   • Reactors
   • Uranium
   • Environmental Restoration/Waste Management
   • Plutonium
   • Tritium
   • Accelerators
   • Large Research and Development Laboratory Operations
   • Small Research and Development Laboratory Operations (annual collective effective dose equivalent of one person-rem or less)

   The development of such Handbooks should be coordinated with the Office of Environment, Safety and Health.