Department of Energy (DOE) Radiological Control Manual

Chapter 1 - Excellence in Radiological Control

Part 3 - Improving Radiological Performance

Table of Contents (Articles 13x)

• 131 Radiological Performance Goals
• 132 Management of Radiological Performance Goals
• 133 Radiological Performance Reports
• 134 Assessments
• 135 Workplace Awareness
• 136 Internal Exposures
• 137 Neutron Exposures
• 138 ALARA Committee

Article 131 - Radiological Performance Goals

Goals are intended as a measure of and a motivation for improvement, not an end in themselves. These performance indicators are not to be viewed narrowly as numerical goals. These indicators should be used as tools to assist management in focusing their priorities and attention. The following are examples of goals that may be appropriate:

1. Collective Dose (person-rem): This goal should be based upon planned activities and historical performance. For those sites that have neutron radiation, a goal for collective neutron dose should also be established.

2. Skin and Personal Clothing Contamination Occurrences (number): Personnel contaminations may indicate a breakdown of controls intended to prevent the spread of contamination.

3. Intakes of Radioactive Material (number): Personnel intakes of radioactive material should be minimized and management should focus attention on any failure of the controls that results in intakes.

4. Contaminated Area Within Buildings (square feet): Operating with a smaller contaminated area results in less radioactive waste, fewer personnel contaminations and improved productivity. The reduction of existing contaminated areas needs to be balanced by the recognition that this generates radioactive waste. Goals for both should be correlated.

5. Radioactive Waste (cubic feet): Minimizing the generation of radioactive waste reduces the environmental impact of DOE operations, helps reduce personnel exposure and reduces costs associated with handling, packaging and disposal.

6. Liquid and Airborne Radioactivity Released (curies): Minimizing effluents reduces the environmental impact of DOE operations and reduces the costs associated with remediation.

Article 132 - Management of Radiological Performance Goals

1. The contractor senior site executive shall establish, approve and maintain a radiological performance goals program.

2. The performance goals should be measurable, achievable, auditable challenging, and meaningful in promoting improvement.

3. Goals need to be developed primarily by those responsible for performing the work. Forming a Radiological Awareness Committee that includes the active participation of the work force is encouraged.

4. Radiological performance goals should be reviewed at least annually and revised as appropriate. Normally, more stringent goals should be set annually to reflect the improved radiological performance at the facility. Occasionally, a goal may be made less stringent to accommodate changes in work load or mission.

Article 133 - Radiological Performance Reports

1. The Radiological Control Manager should provide a periodic summary report to the contractor senior site executive for sites which exceed an annual collective dose of one person- rem. This report is suggested to be monthly but should not be less frequent than quarterly. This report should include at least the radiological performance goals established in accordance with Article 131. Examples of indicators that provide a more detailed analysis of performance are identified in Table 1-1. Indicators should be contained in the report for the month as well as tracking and trending for the prior twelve-month period.

2. The Radiological Control Manager should provide radiation exposure information, such as supplemental dosimeter readings or volume of waste generated, to supervisors and managers on a frequent enough basis to permit priority management of exposure control. The frequency should be consistent with the nature of the workload and the radiation exposure potential.

3. To promote worker awareness of their radiation exposure status, selected indicators related to their work group should be posted in the workplace.

Table 1-1 Suggested Radiological Performance Indicators

Exposure control

1. Collective dose in person-rem
2. Average worker dose in rem
3. Maximum dose to a worker in rem
4. Number of unplanned exposures resulting in doses greater than the Administrative Control Level
5. Number of dose assessments for lost or damaged dosimeters
6. Maximum neutron dose to a worker in rem

Personnel contamination

1. Number of skin and personal clothing contaminations
2. Number of contaminated wounds
3. Number of facial contaminations

Control of internal exposure

1. Number of new confirmed depositions
2. Number of airborne events
3. Number of alarms on airborne monitors (actual and false)
4. Number of Airborne Radioactivity Areas
5. Area of Airborne Radioactivity Areas in square feet

Control of contaminated areas in operational areas

1. Number of Contamination and High Contamination Areas
2. Area of Contamination Areas in square feet
3. Area of High Contamination Areas in square feet
4. Number of spills

Minimization of radioactive waste

1. Volume and activity of radioactive waste in cubic feet and curies, respectively
2. Number of cubic feet not subject to volume reduction by incineration, compaction or other means

Control of radioactive discharges

1. Activity of liquid radioactivity discharges in curies
2. Activity of airborne radioactivity discharges in curies

Article 134 - Assessments

Assessment, as used in this Manual, refers to the process of providing independent feedback to senior line managers to indicate the adequacy of the Radiological Control Program.

1. Inspections, audits, reviews, investigations and self-assessments are part of the numerous checks and balances needed in a good Radiological Control Program. Internal audits of the Radiological Control Program shall be conducted such that over a 3-year period, all functional elements are assessed for program performance, applicability, content and implementation. These should be performed by the Radiological Control Organization, the Quality Assurance Organization and other organizations.

2. Managers, supervisors and workers should look upon assessments as helpful. It is desirable to approach assessments with nothing to hide and with the Radiological Control Program as an open book. Results of assessments should be incorporated into the ongoing process of improving radiological control.

3. Managers should encourage the positive view that identifying even minor deficiencies represents an opportunity for further improvement. The number of deficiencies do not in themselves measure the overall quality of the Radiological Control Program. A prioritization system to implement actions for resolving the deficiencies should be implemented.

4. In developing corrective action plans for assessment activities, managers should address basic underlying reasons for the identified deficiencies or concerns, not just the specific symptoms identified by the reviewer.

5. Feedback on findings from assessments, root-cause analyses, status of corrective actions and adherence to action plan schedules should be frequently provided to management.

Article 135 - Workplace Awareness

1. Management initiatives to facilitate the expression of concerns on the part of the work force, to address such concerns and to solve them are strongly encouraged to ensure the proper respect for and understanding of radiation.

2. A radiological awareness reports system should be established and supported by management. To enhance work force awareness, the program should encourage continuous evaluation and improvements, track resolution of concerns, provide feedback to employees, and post results and trends. This system may be integrated with similar reporting systems for other than radiological concerns.

Article 136 - Internal Exposures

Control and prevention of internal exposure from long-lived radionuclides in the workplace present special challenges to a Radiological Control Program and warrant particular attention. Due to the difficulty of measuring transuranic uptakes that result in low doses, specific actions are required to minimize the risks of internal exposure.

Administration of internal dose assessment is costly in dollars and worker time. Control and analysis of samples is also more complicated than the elements of external dosimetry.

In order to minimize internal exposures, managers should take deliberate actions to control contamination at the source and reduce Airborne Radioactivity, Contamination and High Contamination Areas. Work should be planned to avoid the routine use of respiratory protection devices. Internal exposures should be reduced to the minimum practicable level and the following should be considered:

• Workers may be exposed to unanticipated levels of elevated airborne radioactivity. Collecting representative airborne radioactivity samples and the time required for technicians or automated instruments to determine the airborne concentration of radionuclides may contribute to worker intakes of radioactivity.

• If controls fail, internal depositions of radionuclides can occur in a short period of time.

• The continued exposure of workers to airborne radioactivity over extended periods of time can create worker concerns.

• Doses from some internal radionuclides are difficult to measure. Although some radionuclides, such as cesium and tritium, can be readily measured at levels that produce only a few mrem, some long-lived radionuclides, like plutonium, require years for accurate measurements of hundreds of mrem.

• Medical intervention, such as the administration of blocking and chelating agents, to mitigate internal deposition adds risks by introducing additional chemicals into the body.

• Sampling of body excretions and whole-body or organ counting techniques encourage worker perceptions of internal exposure significance.

Article 137 - Neutron Exposures

Neutron exposures have the following characteristics which require attention:

• The specific biological effects of neutrons are not as well understood as the effects of gammas.

• Neutron dose equivalent is more difficult to assess than gamma dose equivalent.

As a result, those sites and facilities with neutron radiation should focus particular attention on minimizing collective neutron dose through setting aggressive goals (Article 131).

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Article 138 - ALARA Committee

An ALARA Committee should be established. The membership should include managers and workers from the line, the technical support organization and the Radiological Control Organization. It is more effective if a line manager, such as Director of Operations, Research, or Maintenance serves as the Chair. This Committee may be part of a general safety or radiation safety committee whose functions include ALARA activities and possibly be combined with the Radiological Awareness Committee (see Article 132) for smaller facilities.

The ALARA Committee should make recommendations to management to improve progress toward minimizing radiation exposure and radiological releases. The Committee should evaluate items such as construction and design of facilities and systems, planned major modifications or work activities, as well as experimental test plans for exposure, waste and release minimization. The Committee should also receive, as a minimum, the results of all reviews and audits, both internal and external, and should review the overall conduct of the Radiological Control Program.

The As-Low-As-Reasonably-Achievable (ALARA) process of reducing radiation exposures is a fundamental requirement of every radiological control program. There is considerable leeway in determining how far is reasonable. Reducing exposure is desirable because of the direct relation to the health and safety of workers and the public. Reducing radiation exposure improves the quality of the workplace and in the long run saves resources.

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