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Department of Energy DOE G 441.1-1C
Washington, DC
5-19-08
RADIATION PROTECTION PROGRAMS GUIDE for Use with
Title 10, Code of Federal Regulations, Part 835,
Occupational Radiation Protection
[This Guide describes nonmandatory approaches for meeting
requirements. Guides are not requirements documents and are not
to be construed as requirements in any audit or appraisal for
compliance with the parent Rule, Policy, Order, Notice, or
Manual.]
1.0 PURPOSE AND APPLICABILITY
In March 2007 the U.S. Department of Energy (DOE) published
an updated implementation Guide which discussed acceptable
methods for ensuring that the functional elements of
radiological activities will be managed and administered in
accordance with Title 10, Code of Federal Regulations (CFR),
Part 835, Occupational Radiation Protection (DOE 2007a),
hereinafter referred to as 10 CFR 835. The March 2007 Guide
was part of DOE’s efforts to eliminate redundant
requirements and guidance and compiled the guidance
previously provided in a set of 13 Implementation Guides.
On June 8, 2007, the DOE published an amendment to
10 CFR 835. This Guide reflects the June 8, 2007, amendment
to 10 CFR 835 and continues to provide cross-references to
other Guides, DOE-STD-1098-99, RADIOLOGICAL CONTROL (DOE
1999a), hereinafter referred to as the RCS, DOE directives,
and industry consensus standards that provide detailed
guidance for implementing specific requirements in
10 CFR 835.
DOE is in the process of updating all of its guidance
documents for occupational radiation protection to reflect
the 2007 amendment to 10 CFR 835. This Guide is one of the
first documents to be updated, and as such, the cross-
references to other DOE guidance documents will change as
additional updated guidance documents are finalized. The
references to other DOE guidance documents, which are
scheduled to be updated, will include the notation “Use the
revised version, reflecting the 2007 amendment to 10 CFR
835, when available.”
This Guide provides guidance with respect to implementing
the provisions of all the functional areas contained in
10 CFR 835. These are listed in Chapter 3 of this Guide.
Specific regulatory citations are provided in the body of
the Guide.
This Guide amplifies the regulatory requirements of
10 CFR 835 and provides explanations and examples of the
basic requirements for implementing the requirements of
10 CFR 835. The requirements of 10 CFR 835 are enforceable
under the provisions of Sections 223(c) and 234A of the
Atomic Energy Act of 1954, as amended (AEC 1954).
This Guide was developed consistent with DOE M 251.1-1B,
Departmental Directives Program Manual, (DOE 2006a) which
states that guides: (1) Provide preferred, nonmandatory,
supplemental information about acceptable methods for
implementing requirements, including lessons learned,
suggested practices, instructions, and suggested performance
measures; (2) Do not impose requirements but may quote
requirements if the sources are adequately cited; and (3)
Provide alternate methods that may be used if it can be
demonstrated that they provide an equivalent or better level
of performance.
Except for requirements established by a regulation,
contract, or administrative means, the provisions in this
Guide are DOE's views on acceptable methods of program
implementation and are not mandatory. Conformance with this
Guide will, however, create an inference of compliance with
the related regulatory requirements. Alternate methods that
are demonstrated to provide an equivalent or better level of
protection are acceptable. DOE encourages its contractors to
go beyond the minimum regulatory requirements and to pursue
excellence in their programs.
The word "shall" is used in this Guide in reference to
requirements from 10 CFR 835. Compliance with 10 CFR 835 is
mandatory except to the extent an exemption has been granted
pursuant to 10 CFR 820, Procedural Rules for DOE Nuclear
Activities (DOE 2007b). The words "should" and "may" are
used to denote optional program recommendations and
allowable alternatives, respectively.
This Guide may be used by all DOE activities that are
subject to the requirements of 10 CFR 835. The Administrator
of the National Nuclear Security Administration (NNSA) will
assure that NNSA employees and contractors comply with their
respective responsibilities under this Guide.
1.1 USE OF CONSENSUS STANDARDS
As discussed in the Department of Energy's Radiological
Health and Safety Policy DOE P 441.1, (DOE 1996), DOE has
established a system of regulatory policy and guidance
reflective of national and international radiation
protection standards and recommendations. Consistent with
this policy, this Guide endorses the use of several national
and international recommendations and standards, including
several from the International Commission on Radiological
Protection, the National Council on Radiation Protection and
Measurements, the American National Standards Institute. In
regards to national consensus standards, to the extent
possible, this guidance document endorses and is written to
be consistent with following non-governmental national
consensus standards for radiation protection:
· ANSI N13.3, Dosimetry for Criticality Accidents
· ANSI N43.3-1993, General Radiation Safety -Installations
Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies up
to 10 MeV
· ANSI N323A-1997, American National Standard Radiation
Protection Instrumentation Test and Calibration, Portable Survey
Instruments
· ANSI N13.5-R1989, American National Standard Performance
Specifications for Direct Reading and Indirect Reading Pocket
Dosimeters
· ANSI N42.17A-1989, Performance Specifications for Health
Physics Instrumentation - Portable Instrumentation for Use in
Normal Environmental Conditions
· ANSI N42.17C-1989, Performance Specifications for Health
Physics Instrumentation - Portable Instrumentation for Use in
Extreme Environmental Conditions
· ANSI N42.17B, Performance Specifications for Health Physics
Instrumentation - Occupational Airborne Radioactivity Monitoring
Instrumentation
· ANSI N2.1-1971(R1989), Radiation Symbol
· ANSI N13.27, Performance Specifications for Pocket-sized
Alarming Dosimeter/Ratemeters
· ANSI Z88.2-1992, Practices for Respiratory Protection
· ANSI/HPS N13.30-1996, Performance Criteria for Radiobioassay
· ANSI/HPS N13.41-1997, Criteria for Performing Multiple
Dosimetry
· ANSI/HPS N43.6-1997, Sealed Radioactive Sources
Classification
· ANSI /HPS N13.6-1999, Practice for Occupational Radiation
Exposure Records Systems
· ANSI/HPS N43.2-2001, Radiation Safety for X-Ray Diffraction
and Fluorescence Analysis Equipment
· ANSI/HPS N13.49-2001, Performance and Documentation of
Radiological Surveys
· ANSI/HPS N43.5-2005, Radiological Safety Standard for the
Design of Radiographic and Fluoroscopic Industrial X-Ray
Equipment
· ANSI/NCSL Z540-1-1994, American National Standard for
Calibration - Calibration Laboratories and Measuring and Test
Equipment -General Requirements
· ANSI N322, American National Standard Inspection, Test,
Construction, and Performance Requirements for Direct Reading
Electrostatic/Electroscope Type Dosimeters
· ANSI N320, American National Standard Performance
Specifications for Reactor Emergency Radiological Monitoring
Instrumentation
1.2 ACRONYMS
The following are the acronyms frequently used in this document.
AEC U.S. Atomic Energy Commission
ALARA Low As Is Reasonably Achievable
ALI Annual Limit on Intake
ANS American Nuclear Society
ANSI American National Standards Institute
BEIR Biological Effects of Ionizing Radiations
BRH Bureau of Radiological Health
BZ Breathing Zone
CAM Continuous Air Monitor
CED Committed Effective Dose
CFR Code of Federal Regulations
CSO Cognizant Secretarial Officer
CTED Cumulative Total Effective Dose
DAC Derived Air Concentration
DIL Derived Investigation Level
DL Decision Level
DOE Department of Energy
DOE G DOE Guide
DOE O DOE Order
DOE P DOE Policy
DOELAP Department of Energy Laboratory Accreditation
Program
DOE-STD DOE Standard
DPM Disintegrations per Minute
EPA Environmental Protection Agency
FOIA Freedom of Information Act
FR Federal Register
GERT General Employee Radiological Training
HEPA High Efficiency Particulate Air (filter)
HPS Health Physics Society
ICRP International Commission on Radiological
Protection
ICRU International Commission on Radiation Units and
Measurements
IL Investigation Level
ISO International Organization for Standardization
MDA Minimum Detectable Amount/Activity
NCRP National Council on Radiation Protection and
Measurements
NCSL National Conference of Standards Laboratories
NIST National Institute of Standards and Technologies
NRC Nuclear Regulatory Commission
PNL Pacific Northwest Laboratory
PSE Planned Special Exposure
PSO Program Secretarial Office
RCO Radiological Control Organization
RCS DOE-STD-1098-99, RADIOLOGICAL CONTROL
RCT Radiological Control Technician
RGD Radiation-Generating Device
RMA Radioactive Material Area
RPP Radiation Protection Program
RWP Radiological Work Permit
RWT Radiological Worker Training
SLAC Stanford Linear Accelerator Center
TED Total Effective Dose
TEDE Total Effective Dose Equivalent
TLD Thermo Luminescent Dosimeter
TWD Technical Work Document
UNSCEAR United Nations Scientific Committee on the Effects
of Atomic Radiation
USLW United States Law Week
2.0 DEFINITIONS
Terms from 10 CFR 835 are used consistent with their
regulatory definition.
Acceptance testing: Evaluation or measurement of performance
characteristics to verify that certain stated specifications
and contractual requirements are met.
Air monitoring: Actions to detect and quantify airborne
radiological conditions by the collection of an air sample
and the subsequent analysis, either in real-time or offline
laboratory analysis, of the amount and type of radioactive
material present in the atmosphere.
Air sampling: A form of air monitoring in which an air
sample is collected and analyzed at a later time, sometimes
referred to as retrospective air monitoring.
ALARA committee: The multi-disciplined forum that reviews
and advises management on improving progress towards
minimizing radiation dose and radiological releases.
ALARA design review: A systematic review to ensure that
ALARA considerations are evaluated, incorporated if
reasonable, and documented for the design of new facilities
and modifications to existing facilities that involve the
potential for exposure to ionizing radiation.
ALARA job/task/experiment review: A systematic pre- and
post-job review of high-dose and potentially high-dose
activities to ensure that ALARA controls are planned,
evaluated, implemented where reasonable, and documented.
Alarm set point: The count rate or concentration at which a
real-time air monitor will alarm, usually set to correspond
to a specific airborne radioactive material concentration
averaged over time (e.g., DAC-hour alarm equivalent) by
calculating the sample buildup rate on the collection
medium.
Alpha (á): The probability (not to be confused with an alpha
particle) of a Type I error or false positive. This is also
called the false positive probability.
Analyte: The particular radionuclide to be determined in a
sample of interest.
Baseline bioassay: An appropriate bioassay measurement
obtained from a radiobioassay program participant prior to
beginning or resuming work with radioactive material.
Beta (â): The probability (not to be confused with a beta
particle) of a Type II error or false negative. This is also
called the non-detection probability.
Boundary identifier: A hazard identifier that is used to
define the boundary of an area.
Boundary: The line that defines the transition from one
specified area to another.
Breathing zone air monitoring: A form of air monitoring that
is used to detect and quantify the radiological conditions
of air from the general volume of air breathed by the
individual, usually at a height of 1 to 2 meters. See
"personal air monitoring."
Cabinet X-ray system: An X-ray system with the X-ray tube
installed in an enclosure (hereinafter termed "cabinet")
which, independently of existing architectural structures
except the floor on which it may be placed, is intended to
contain at least that portion of a material being
irradiated, provide radiation attenuation, and exclude
individuals from its interior during generation of
X-radiation. Included are all the X-ray systems designed
primarily for inspection of carry-on baggage at airline,
railroad, and bus terminals, and in similar facilities. An
X-ray tube used within a shielded part of a building or
X-ray equipment which may temporarily or occasionally
incorporate portable shielding is not considered a cabinet
X-ray system.
Challenge examination: An examination administered to
ascertain the knowledge of a worker with respect to
radiation safety and provide an exception to the required
training.
Check source: A radioactive source, not necessarily
calibrated, that is used to confirm the continuing
satisfactory operation of an instrument.
Confirmed intake: An intake confirmed by follow-up
radiobioassay, by association with a known incident, or by
investigation.
Contaminated area: Any area meeting the definition of
“contamination area,” “high contamination area,” or
“airborne radioactivity area” provided in 10 CFR 835.2(a).
Continuous air monitor (CAM): An instrument that
continuously samples and measures the levels of airborne
radioactive material on a "real-time" basis and has alarm
capabilities at preset alarm set points.
Decision level (Lc): The amount of a count (Lc or Lc) as
final instrument measurement of a quantity of analyte (Dc or
Dc) at or above which a decision is made that the analyte is
definitely present.
Derived investigation level (DIL): A value of a
radiobioassay or air monitoring measurement that indicates
an intake resulting in a dose exceeding an Investigation
Level (IL).
Detector: A device or component designed to produce a
quantifiable response to ionizing radiation, normally
measured electronically.
Direct (in vivo) radiobioassay: The measurement of
radioactive material in the human body utilizing
instrumentation that detects radiation emitted from the
radioactive material in the body.
DOELAP: The Department of Energy Laboratory Accreditation
Program. This program defines a set of reference performance
tests and provides a description of the minimum levels of
acceptable performance for personnel dosimetry systems and
radiobioassay programs under either DOE STD-1111-98, THE
DEPARTMENT OF ENERGY LABORATORY ACCREDITATION PROGRAM
ADMINISTRATION (DOE 1998A), or DOE STD-1112-98, THE
DEPARTMENT OF ENERGY LABORATORY ACCREDITATION PROGRAM FOR
RADIOBIOASSAY (DOE 1998b).
Dose assessment: The process of determining radiological
dose and uncertainty included in the dose estimate, through
the use of exposure scenarios, bioassay results, monitoring
data, source term information, and pathway analysis.
Elimination: The biological removal of a radionuclide from
the body by excretion, perspiration, exhalation, secretion
(e.g., breast milk), exfoliation (sloughing of dead tissue),
or excision.
Embryo/fetus: A developing human organism from conception
until birth.
Escort: An individual with the prerequisite training
necessary for unescorted access to the area(s) where the
escort activities will be performed and who is authorized to
accompany and ensure the safety of individuals who lack such
training.
Evaluation: The process of arriving at a value for intake or
dose that uses, among other inputs, measurement results.
Excretion: The biological removal of a radionuclide from the
body via one or more excretion pathways: urine and feces.
Exempt sealed radioactive source: A sealed radioactive
source that does not meet the accountability criteria
established in the definition of the term “accountable
sealed radioactive source” provided in 10 CFR 835.2(a).
Exposure: The general condition of being subjected to
ionizing radiation, such as by proximity to external sources
of ionizing radiation or through intake of radioactive
material into the body. In this document, exposure does not
refer to the radiological physics concept of charge
liberated per unit mass of air.
False negative: A Type II (â) error, that is, concluding
that analyte is not present when in fact it is.
False positive: A Type I (á) error, that is, concluding that
there is analyte present when it is not.
Fixed contamination: Radioactive material that cannot be
readily removed from surfaces by nondestructive means, such
as casual contact, wiping, or brushing.
Fixed-location sampler: An air sampler located at a fixed
location in the workplace.
Frisk or frisking: Process of monitoring individuals or
surfaces for contamination by directly scanning the surface
with a suitable radiation detector.
Functional tests: Tests (often qualitative) to determine
that an instrument is operational and capable of performing
its intended function. Such tests may include, for example,
battery check, zero setting, or source response checks.
Geotropism: A change in an instrument's reading as its
orientation changes, due to gravitational effects.
Gestation period: The time from conception to birth; usually
40 weeks or approximately 9 months.
Grab sampling: A single sample removed from the air over a
short time interval, typically a few minutes for high volume
air samplers and less than one hour for low volume air
samplers.
Hot particles: Small, discrete, highly radioactive particles
that can cause extremely high dose rates to a localized
area.
Indirect (in vitro) radiobioassay: The measurement or
analysis of radionuclides in excreta or other biological
samples removed from the body.
Instrument (radiation detection): A complete system
consisting of one or more subassemblies (e.g., detector,
readout, etc.) designed to quantify one or more
characteristics of ionizing radiation or radioactive
material.
Intake: The amount of radionuclide taken into the body by
inhalation, absorption through intact skin, injection,
ingestion, or through wounds. Depending on the radionuclide
involved, intakes may be reported in mass (e.g., ìg, mg),
activity (e.g., ìCi, Bq), or potential alpha energy (e.g.,
MeV, J) units.
Interlock: A device for precluding access to an area of
radiation hazard by either preventing entry or by
automatically removing the hazard. One example is an
electro-mechanical control mechanism that interrupts the
beam of ionizing radiation or shuts down the radiation
installation whenever the interlock is challenged.
Internal audits: Reviews and evaluations of the content and
implementation of the documented radiation protection
program conducted by an organization neither responsible nor
accountable for developing program content or implementing
the program.
Investigation level (IL): The value of the committed
effective dose from an intake(s) of a radioactive material
by a worker at or above which, for regulatory purposes, is
regarded as sufficiently important to justify further
investigation
Irradiator: Any gamma- or neutron-emitting sealed
radioactive material that has the potential to create a
radiation level exceeding 500 rads (5 grays) in 1 hour at 1
meter and is operated within the requirements of an RGD
installation.
Minimum detectable amount (MDA): The smallest amount
(activity or mass) of an analyte in a sample that will be
detected with a probability, â, of non-detection (Type II
error) while accepting a probability, á, of erroneously
deciding that a positive (non-zero) quantity of analyte is
present in an appropriate blank sample (Type I error). The
MDA is computed using the same value of á as used for the
Lc. The MDA depends on both á and â. Measurement results are
compared to the Lc, not the MDA; the MDA is used to
determine whether a program has adequate detection
capability. The MDA will be greater than or equal to the Lc.
Modification: Any alteration of the shielding configuration,
device or installation operating practices, or the replace
ment of the original RGD (or component part thereof) with
another that has not been previously evaluated, inspected,
monitored, and documented by the radiological control
organization. This definition also includes the collocation
of additional or multiple unevaluated RGDs within a
previously evaluated installation.
Normal operation: Operation under conditions as recommended
by the manufacturer of the RGD with recommended shielding
and barriers in place, and as specified in the operating
procedures and requirements for the RGD installation.
Occupied (occupiable) area: An area or location that may be
physically accessible by individuals (or body parts thereof)
while a radiation-generating device is in operation.
Off-normal operation: An event or condition that adversely
affects, potentially affects, or indicates degradation in
the safety, security, environmental, or health-protection
performance or operation of an RGD installation.
Optimization methodology: A documented methodology which
describes how the factors affecting a protection decision,
i.e., social, technical, economic, practical, and public
policy, are assigned values to compare detriment and
benefits.
Performance demonstration: A demonstration by a student of
the skills required to perform certain designated
activities.
Performance tests: Tests performed periodically over the
life of an instrument to verify that it continues to meet
operational requirements. Examples of performance tests are
response time and geotropism.
Personal air monitoring: A form of breathing zone air
monitoring that involves the sampling of air in the
immediate vicinity (typically within one foot) of an
individual’s nose and mouth, usually by a portable sampling
pump and collection tube (e.g., a lapel sampler) worn on the
body.
Physical barrier: A bounding physical obstruction that
prevents unimpeded access to an area.
Portable air sampler: An air sampler designed to be moved
from area to area.
Portable monitoring instrument: An instrument intended to be
operated while being carried by an individual.
Qualified expert: An individual having the knowledge,
training, and recognition of such by management to measure
ionizing radiation, to evaluate safety techniques, to design
RGD installations, and to provide advice on radiation
protection requirements.
Radiation protection program (RPP): The documented program,
approved by DOE, including, but not limited to, the plans,
schedules, and other measures developed and implemented to
achieve and ensure continuing compliance with 10 CFR 835 and
to apply the as low as is reasonably achievable (ALARA)
process to occupational dose.
Radiation-generating device (RGD): Collective term for
devices which produce ionizing radiation, including, certain
sealed radioactive sources, small particle accelerators used
for single purpose applications which produce ionizing
radiation (e.g., radiography), and electron generating
devices that produce X-rays incidentally.
Radiography: Examination of the structure of materials by
nondestructive methods, using a RGD.
Radiological control organization (RCO): An organization
responsible for radiation protection activities.
Radiological engineer: An individual who is responsible for
providing technical support and assistance to supervisors,
planners, schedulers, principal investigators, and design
engineers to reduce occupational doses and the spread of
radioactive materials.
Radiological work permit (RWP): The document that identifies
radiological conditions, establishes worker protection and
monitoring requirements, and contains specific approvals for
radiological work activities. The RWP serves as an
administrative process for planning and controlling
radiological work and informing the worker of the
radiological conditions.
Radon: Unless otherwise specified, the isotope 222Rn.
Real time air monitor: An instrument that measures the
levels of airborne radioactive material on a "real-time"
basis.
Refresher training: Periodic (usually annual) training that
provides current information on changes to radiation
protection policies and procedures or changes in facility
conditions, or to promote awareness of infrequently
encountered radiological safety matters.
Removable contamination: Radioactive material that can be
removed from surfaces by nondestructive means, such as
casual contact, wiping, or brushing.
Representative air sampling: The sampling of airborne
radioactive material in a manner such that the sample
collected closely approximates both the amount of activity
and the physical and chemical properties (e.g., particle
size and solubility) of the contaminant to which the
individuals may be exposed.
Retention: The amount of material which, after being taken
into the body by inhalation, ingestion, entry through an
open wound, or absorption through the skin, exists in the
whole body, a compartment, an organ, or a tissue at a
specified time.
RGD Custodian: An individual who is trained and designated
to maintain cognizance over accountability control of
radiation-generating devices assigned to him or her.
RGD installation: The sum of the radiation source (e.g.,
sealed radioactive material or x-ray tube), the associated
equipment and component items, and the space in which they
are operated.
Five types of installations are defined as follows:
(1) Shielded installations are those designed to use the
room-within-a-room concept to limit access to the RGD
beam and to place more emphasis on distance as opposed
to shielding for radiation protection and include
shielded, exempt shielded, and cabinet x-ray
installations;
(2) Unattended installations are those designed for a
specific purpose and that do not require personnel in
attendance for operation and include unattended gauge
and other unattended installations;
(3) Open installations are those designed to accommodate a
specimen that is so large as to make an exempt shielded
installation impractical;
(4) X-ray diffraction & fluorescence analysis equipment,
including both open and closed beam installations; and
(5) Incidental, including devices that emit low levels of
ionizing radiation as a byproduct of their normal
function, such as electron beam welders, electronic
microscopes, and pulse generators.
RGD Operator: An individual who is trained and deemed
qualified to use a radiation-generating device.
Routine radiobioassay monitoring: Any radiobioassay
measurement made on a predetermined, periodic schedule, to
establish whether a worker has had any intake of radioactive
material since previous radiobioassay measurements.
Source custodian: An individual who is trained and
designated to maintain cognizance over accountability and
control of assigned sealed radioactive sources.
Source response check: A functional test that includes the
observation of the response of an instrument to a check
source.
Source user: An individual who is trained and authorized to
use sealed radioactive sources.
Source-specific air sampling: Collection of an air sample
near an actual or likely release point.
Special radiobioassay monitoring: Any radiobioassay
measurement that is required for confirmation of a suspected
intake of radionuclides, or is required for follow-up
evaluation of confirmed intakes.
State-of-the-art: The most advanced technology that is
commercially available and successfully field tested.
Technical work document (TWD): A term used to generically
identify formally approved documents that direct work, such
as procedures, work packages, or job or research plans. TWDs
provide radiological and ALARA controls applicable to the
task.
Technology shortfall: A technology shortfall for routine
radiobioassay exists when the derived investigation level
(DIL) for a well-designed and appropriate routine
radiobioassay program, using current or state-of-the-art
methods and equipment, is less than the minimum detectable
amount/activity of the routine monitoring method (e.g., the
DIL is less than the MDA).
Termination radiobioassay: A radiobioassay measurement
performed for the purpose of documenting the retention of
radioactive materials in the body due to occupational
exposure either upon termination of employment or upon the
cessation of potential exposure to a specific nuclide.
Test: A procedure whereby an instrument, component, or
circuit is evaluated against certain criteria for
satisfactory operation.
Thoron: Unless otherwise specified, the isotope 220Rn.
Traceability: The ability to show, through documentation,
that a particular instrument or radiation source has been
calibrated using either the national standard or a transfer
standard in a chain or echelon of calibrations, ultimately
leading to a comparison with the national standard.
Type test: An initial test of one or more production
instruments made to a specific design to show that the
design meets certain specifications.
Type I error: Incorrectly concluding from a result that
there is analyte present; the probability (á) of a Type I
error is usually taken as 0.05. The decision level is
determined on the basis of an acceptable level of Type I
errors.
Type II error: Incorrectly concluding from a result that
there is no analyte present; its probability (â) is usually
taken as 0.05.
Uniform exposure: Hypothetical radiation field in which the
fluence and its angular and energy distributions are the
same throughout the volume of interest.
Useful beam: That part of the primary and secondary
radiation beam that passes through the aperture, cone, or
other device used for collimation.
3.0 RADIATION PROTECTION PROGRAMS
10 CFR 835 establishes specific requirements for the
development, content, revision, and approval of the
documented RPP for a DOE activity. These requirements
include identifying existing and/or anticipated operational
tasks and formal plans and measures for maintaining
occupational radiation doses ALARA. Guidance provided in
this Guide, in combination with the provisions of site
radiological control manuals developed and implemented
consistent with guidance provided by the RCS for those
regulatory provisions not addressed by this Guide, provide
reasonable assurance that a site RPP will meet the
requirements of 10 CFR 835.
The RPP for a specific DOE activity is approved by the DOE,
typically by the cognizant DOE Headquarters Program Office.
The RPP is intended to provide DOE reasonable assurance that
the DOE activity will be conducted in compliance with the
provisions of 10 CFR 835. The RPP also satisfies the
requirement for an Implementation Plan found in other DOE
directives. Guidance concerning the specific documentation
required for DOE approval of RPPs as required in
10 CFR 835.101(f), (g), and (h) is provided in Appendix 3.A,
PREPARATION, REVIEW AND APPROVAL OF RADIATION PROTECTION
PROGRAMS. Appendix 3.A is based on guidance which previously
was provided in DOE-STD-1082-94, PREPARATION, REVIEW, AND
APPROVAL OF IMPLEMENTATION PLANS FOR NUCLEAR SAFETY
REQUIREMENTS. Guidance is also provided by the cognizant DOE
Headquarters Program Office.
Program Offices will also provide guidance should DOE need
to direct or make modifications to an RPP as provided under
10 CFR 835.101(b). 10 CFR 835 permits changes, additions, or
updates to an RPP to become effective without prior DOE
approval only if the changes do not decrease the
effectiveness of the RPP and the RPP, as changed, continues
to meet the requirements of the rule. Proposed changes that
decrease the effectiveness of the RPP shall not be
implemented without submittal to and approval by DOE
[10 CFR 835.101(h)]. Guidance regarding the process for
submitting and approving changes will be provided by the
appropriate DOE Headquarters Program Office.
The RPP is the basis for implementing operational radiation
protection program requirements for a DOE activity. A
combination of various methods which can be used to achieve
regulatory compliance is discussed in this Guide. DOE
recognizes that many of the requirements of 10 CFR 835 are
not new. Equivalent requirements were previously promulgated
in DOE Orders and the DOE Radiological Control Manual, which
were implemented under contractual obligations for most DOE
activities involving occupational exposure to ionizing
radiation. Therefore, much of the RPP documentation required
to ensure compliance with 10 CFR 835 has already been
developed to ensure compliance with contractually-imposed
radiation protection standards. DOE recognizes that
significant effort was expended in upgrading radiation
protection of the work force and does not intend for its
contractors to expend significant additional effort to
develop and implement a separate, redundant program to
satisfy the RPP requirements of 10 CFR 835. The RPP should
rely on existing documents, such as the site radiological
control manual, contractual agreements, procedures, and
memoranda, to effectively administer and manage regulatory
commitments. However, the completeness of these existing
documents should be verified to ensure that all 10 CFR 835
requirements are satisfied. This chapter of this Guide
provides guidance on the management and administrative
aspects of the RPP to achieve and maintain compliance with
specific requirements in 10 CFR 835.
Internal audits of the radiation protection program,
including examination of program content and
implementation, shall be conducted through a process that
ensures that all functional elements of the program are
reviewed no less frequently than every 36 months
(10 CFR 835.102). This Guide discusses the role of an
internal audit program in effectively managing and
administering an RPP that complies with 10 CFR 835. These
internal audits may also be incorporated into quality
assurance programs developed under 10 CFR 830 Subpart A,
Quality Assurance Requirements (DOE 2001a) and/or DOE
Order 414.1C, Quality Assurance (DOE 2005a). Functional
elements of a comprehensive RPP are identified and
discussed throughout Section 3.2 of this Guide. The
specific functional elements for a DOE activity will
depend upon the types of radiological work being
performed and the radiological hazards present. Other
functional elements necessary for an integrated worker
health and safety program are not addressed in this
Guide, but should be integrated with a radiological
control program. These other functional elements include:
respiratory protection, radioactive material shipment and
receipt, radioactive waste management, and emergency
response.
3.1 Implementation Guidance
The approved RPP details how a DOE activity shall be in
compliance with 10 CFR 835 and should identify the
functional elements appropriate for that activity.
Additional documentation should be developed and maintained
to supplement the approved RPP to demonstrate that an RPP
can be effectively managed and administered to achieve
compliance with 10 CFR 835. This documentation typically
includes a site radiological control manual developed to the
guidance contained in the RCS, as well as detailed
implementing procedures, appropriate management policy
statements, and technical basis documentation. While this
documentation need not be part of the RPP, it should be
clearly linked to the compliance commitments contained in
the RPP.
DOE has developed technical guidance to support effective
implementation of programs to ensure compliance with
10 CFR 835. The RCS was developed to provide detailed
guidance on and best practices for line management
implementation of DOE's radiation protection requirements.
DOE has also developed a set of technical standards and
handbooks addressing radiation protection issues, such as
training, internal dosimetry, or plutonium operations.
Additionally, DOE has developed a set of Radiological
Control Technical Positions (RCTPs). The RCTPs provide
acceptable approaches to implementing specific provisions,
or otherwise address specific issues, of the Rule (available
at
http://www.hss.energy.gov/HealthSafety/WSHP/radiation/tpp.ht
ml). In addition, this Guide provides acceptable methods for
achieving compliance with a variety of technical and
administrative requirements.
RPP changes may be implemented without prior DOE approval
only if the RPP continues to meet 10 CFR 835 requirements
and the changes do not reduce program effectiveness
[10 CFR 835.101(h)]. Due to the wide range of activities
subject to 10 CFR 835 and the variety of methods used by
these activities to ensure compliance, no specific criteria
exist by which DOE may predetermine whether an RPP change
results in a reduction in program effectiveness. Factors
that should be considered include the impact of the proposed
change(s) on:
· radiological conditions in occupied areas;
· individual and collective doses;
· worker awareness of radiological conditions and controls;
· management oversight and control of routine and non-routine
radiological work activities;
· sufficiency of area and personnel monitoring programs;
· completeness and irretrievability of records;
· radiological control performance indicators;
· adherence to consensus standards; and
· other factors that ensure full implementation of the RPP.
Documentation of the rationale applied to RPP changes
implemented without prior DOE approval should be retained
for future reference and demonstration of compliance.
The terms "likely" and "potential" have been used
judiciously throughout the rule to allow the use of
professional judgment and experience in making decisions
in specific circumstances and provide the flexibility
necessary to implement the regulatory requirements under
a broad range of activities. The technical bases and
other considerations should be documented when
professional judgment is exercised. This documentation
should provide sufficient detail to permit individuals
who are responsible for implementing and assessing the
RPP to clearly understand how regulatory compliance is
achieved and maintained. The RCS, Guides, and other DOE
technical standards and handbooks are designed to
facilitate development and implementation of a
comprehensive RPP commensurate with the radiological
hazards associated with the DOE activity. In addition,
consensus standards, such as those developed by the
American National Standards Institute (ANSI) and the
Health Physics Society (HPS), may provide additional
guidance concerning technical issues not specifically
addressed by the Guides, RCS, DOE technical standards, or
other DOE guidance documents.
3.2 Organization and Administration
The RPP shall include plans, schedules, and other measures
for achieving compliance with 10 CFR 835
[10 CFR 835.101(f)]. Plans should include establishing the
organization and administration of the RPP to ensure that
the program is effectively implementing appropriate measures
that ensure regulatory compliance can be achieved and
sustained. The authority and responsibility for radiation
protection should originate at the highest levels of line
management and should be emphasized throughout the
organization. Ultimately, workers should be aware of their
individual responsibilities for radiation protection.
Programmatic documentation should be developed to document
the organizational and administrative aspects of the RPP.
3.2.0 Administrative Processes
The degree of formality and scope of the associated
administrative processes should be commensurate with the
radiological hazards encountered and complexity of the
associated control measures. More rigorous administrative
processes should be implemented for more complex or
hazardous DOE activities. Administrative processes should
include a hierarchy of documents that clearly and
unambiguously delineate management policies, requirements,
expectations, and objectives for the RPP. This documentation
should typically include the following:
· Policy statement: The policy statement should articulate
management’s commitment to conduct radiological operations in a
manner that will ensure the health and safety of all its
employees, contractors, and the general public. This policy
statement should be patterned after DOE P 441.1, Department of
Energy Radiological Health and Safety Policy (DOE 1996).
· Site-specific radiological control manual or handbook: This
document should be issued and endorsed by senior management for a
DOE activity. This manual or handbook should address all
functional elements of the RPP for the DOE activity.
· Procedures: These documents should provide detailed
instructions for implementing various functional elements of the
RPP. Responsibilities and actions required of management and
workers should be clearly and unambiguously stated. Written
procedures shall be developed and implemented as necessary to
ensure compliance with 10 CFR 835, commensurate with the
radiological hazards created by the activity and consistent with
the education, training, and skills of the individuals exposed to
those hazards (10 CFR 835.104).
It is not necessary for written procedures to be
developed and implemented for all of the requirements
of 10 CFR 835. Written procedures should be developed
and employed under the following circumstances:
– worker health and safety are directly affected;
– the expected outcome for the process or operation requires
that a specific method be followed;
– the process or operation is infrequently used and competence
training cannot assure adequate implementation; or
– to document the approved method to implement specific
processes or operations. In evaluating the need for written
procedures, consideration shall be given to the level and extent
of the radiological hazards, the complexity of the measures
required to achieve compliance, and the education, training and
skills of the individuals who must implement those measures
(10 CFR 835.104). Under such a regimen, a low hazard activity
employing a stable staff of highly educated and skilled workers
having demonstrated an advanced knowledge of radiation protection
principles and practices could have fewer and less detailed
procedures than a higher hazard activity employing a transient
workforce with less knowledge of radiation protection practices
and principles. This Guide provides additional guidance regarding
specific procedural aspects of the RPP.
· Technical basis documents: Document decisions and approaches
used to achieve regulatory compliance, such as those decisions
where professional judgment has been exercised. The document
should include supporting analyses and justifications sufficient
to demonstrate that regulatory compliance can be achieved and
maintained. This Guide contains specific recommendations for
documenting the technical basis for various RPP functional
elements.
10 CFR 835 specifies the frequency for performing certain
activities. Internal audits shall be conducted on a 36 month
cycle (10 CFR 835.102); radiation safety training shall be
conducted every twenty four months [10 CFR 835.901(e)]; and
accountable sealed radioactive sources shall be inventoried
and leak tested every six months [10 CFR 835.1202(a) and
(b)]. DOE expects that those entities responsible for
ensuring compliance with the rule will undertake those
measures necessary to perform the required activities within
the prescribed time frame (e.g., if a sealed radioactive
source is leak tested on January 15, DOE would expect the
subsequent leak test to be performed on or before July 15 of
the same year). 10 CFR 835.3(e) allows a grace period of up
to 30 days when operational or scheduling considerations
preclude adherence to the required schedule (e.g., the leak
test could be performed no later than August 14 of the same
year). If the provisions of 10 CFR 835.3(e) are exercised,
documentation of the schedule deviation should be developed
and include a discussion of the specific activity involved
and the reason for the schedule deviation. Schedule
extensions beyond the 30 day grace period can only be
granted through the regulatory exemption process under
10 CFR 820.62.
3.2.1 Radiological Control Organization
A radiological control organization should be established to
support line managers and workers. To function effectively
and be consistent, as necessary, with the requirements in
DOE O 226.1, Implementation of Department of Energy
Oversight Policy (DOE 2005b) the radiological control
organization should be independent of the line
organizational element responsible for production,
operation, or research activities, and should have an
equivalent reporting level. Radiological control
organization function is discussed in detail in the RCS.
Other organizational schemes that allow effective compliance
with the standards set forth in 10 CFR 835 should be
considered to address site- or facility-specific needs.
3.2.2 Education, Training, and Skills
Individuals responsible for developing and implementing
measures necessary for ensuring compliance with the
requirements of 10 CFR 835 shall have the appropriate
education, training and skills to discharge these
responsibilities (10 CFR 835.103). These individuals can
include technical and management personnel within the
radiological control organization, independent assessors,
and line managers responsible for radiological work
activities. In addition, 10 CFR 830.122(b), Quality
Assurance Criteria, specifies that nuclear facility
personnel shall be trained and qualified to ensure they are
capable of performing their assigned work.
DOE previously issued requirements and guidance with regard
to education, training, and skills for many categories of
personnel, including individuals responsible for developing
and implementing measures necessary for ensuring compliance
with the requirements of 10 CFR 835. Some of these
requirements are addressed in DOE 5480.20A, Ch. 1, Personnel
Selection, Qualification, and Training Requirements for DOE
Nuclear Facilities (DOE 2001b). This order establishes
training and qualification requirements for technical
professionals and management personnel operating defense
nuclear facilities. While these requirements are not
mandatory for all DOE facilities, this information may be
useful for all DOE facilities in developing training
programs and standards for the education, training, and
skills appropriate for personnel to achieve compliance with
the requirements of 10 CFR 835.103 and 10 CFR 830.122(b).
Key radiation protection positions are identified in DOE
STD-1107-97, KNOWLEDGE, SKILLS AND ABILITIES FOR KEY
RADIATION POSITIONS AT DOE FACILITIES (DOE 1997a). This
document supplements the requirements discussed above by
synthesizing guidance from several source documents into a
single reference. DOE STD-1107-97 describes the level of
knowledge, skills, and abilities for personnel in key
radiation protection involved with DOE activities. The
approach taken in DOE STD-1107-97 reinforces the DOE’s
emphasis on establishing a system of criteria for key
radiation protection positions that reflects the increasing
levels of education, training, and skills needed for
positions of increasing responsibility. The information
contained in this standard should be strongly considered
when evaluating the education, training, and skills of
personnel in key radiation protection positions.
The standards in DOE 5480.20A and DOE STD-1107-97 are based
on DOE, Nuclear Regulatory Commission, and related industry
standards and provide an acceptable method for achieving
compliance with the requirements of 10 CFR 835.103.
DOE STD-1107-97 includes radiological control technicians
(RCTs) in the list of key radiation protection positions.
While 10 CFR 835 does not establish specific requirements
for RCT training, DOE considers the typical job functions
associated with RCTs to be critical in implementing an
acceptable RPP. These typical job functions include:
prescribing and implementing radiological work controls,
performing radiological monitoring, responding to
radiological incidents, or evaluating radiological
conditions in the workplace. Individuals performing these
functions shall meet the provisions of 10 CFR 835.103.
Chapter 6, Part 4, of the RCS discusses the essential
elements of RCT training and qualification, including
qualification standards, oral examination boards, and
continuing training. In support of these elements, DOE has
developed and maintains the core course for RCTs. DOE
considers the DOE-developed core course for RCTs, augmented
with site specific training, an acceptable level of training
for individuals performing the typical job functions
associated with RCTs. As is the case with using any of the
DOE-developed training courses, sites need to evaluate the
individual’s job functions and ensure the adequacy of the
training provided.
To ensure that the work performed by RCTs receives the
appropriate level of review and evaluation, it is important
that RCT Supervisors receive a higher level of training and
maintain a higher level of knowledge than those expected of
RCTs. Chapter 6, Part 4 of the RCS also provides guidance on
the essential elements of RCT Supervisor training and
qualification, including continuing training and oral
examination boards.
DOE developed and implemented core courses to enhance the
content of training provided to general employees,
radiological workers, and radiological control technicians
across the DOE complex and bring these core training
programs up to a standard consistent with the commercial
industry. The use of the core courses is not mandatory.
However, these courses should strongly be considered as a
basis for developing and implementing radiation safety and
radiological control technician training programs.
Additional guidance regarding compliance with the Subpart J
requirements is provided in Chapter 14 of this Guide.
DOE has also sponsored development of additional training
courses and guidance. DOE strongly encourages its operating
entities to implement these courses and guidance. These
courses and guidance, when augmented with site specific
information and appropriately revised to reflect the most
current regulatory requirements, provide acceptable
approaches for providing radiation safety training or
training for individuals responsible for developing and
implementing measures necessary for ensuring compliance with
the rule. These courses include:
· DOE-HDBK-1143-2001; RADIOLOGICAL CONTROL TRAINING FOR
SUPERVISORS (DOE 2001c)
· DOE-HDBK-1145-2001; RADIOLOGICAL SAFETY TRAINING FOR
PLUTONIUM FACILITIES (DOE 2001d)
· DOE-HDBK-1141-2001; RADIOLOGICAL ASSESSOR TRAINING (DOE
2001e)
· DOE-HDBK-1105-2002; RADIOLOGICAL SAFETY TRAINING FOR TRITIUM
FACILITIES (DOE 2002a)
· DOE-HDBK-1106-97; RADIOLOGICAL CONTAMINATION CONTROL
TRAINING FOR LABORATORY RESEARCH (DOE 1997b)
· DOE-HDBK-1108-2002; RADIOLOGICAL SAFETY TRAINING FOR
ACCELERATOR FACILITIES (DOE 2002b)
· DOE-HDBK-1109-97; RADIOLOGICAL SAFETY TRAINING FOR
RADIATION-PRODUCING (X-RAY) DEVICES (DOE 1997c)
· DOE-HDBK 1110-2008; ALARA TRAINING FOR TECHNICAL SUPPORT
PERSONNEL (DOE 2008)
· DOE-HDBK-1113-98 RADIOLOGICAL SAFETY TRAINING FOR URANIUM
FACILITIES (DOE 1998c)
· DOE-HDBK-1122-99 RADIOLOGICAL CONTROL TECHNICIAN TRAINING
(DOE 1999b)
3.2.3 Internal Audit and Self Assessment
Internal audits and self assessments are two of the numerous
checks and balances needed in an effective RPP. Internal
audits of the RPP, including examination of program content
and implementation, shall be conducted through a process
that ensures that all functional elements of the program are
reviewed no less frequently than every 36 months
(10 CFR 835.102). The RCS discusses how assessments,
including internal audits, provide independent feedback to
senior line managers concerning the implementation of the
RPP.
An audit plan or mechanism should be developed that
identifies the functional elements of the RPP and the
schedule for review to ensure that over a 36 month period,
all of the functional elements are reviewed. Internal audits
should be conducted on a continuing basis. DOE cautions
against conducting a single comprehensive internal audit of
the entire RPP once every three years. DOE does not believe
that such an approach is effective in assuring that a DOE
activity will be conducted in conformance with its approved
RPP. DOE recommends that, at a minimum, an annual, broad
scope audit of the program be conducted. Under this
approach, the audit plan would identify each functional
element to be reviewed during the annual audit and ensure
that all functional elements would be reviewed during a 36
month cycle. Thus, the RPP is under continuing review and
deficiencies can be identified and corrected in a timely
manner.
The functional elements of a comprehensive RPP are discussed
in this Guide. All of these functional elements may not be
applicable to a specific DOE activity, but should be
selected based upon the type of radiological work being
performed and the radiological hazards encountered.
Internal audits should be conducted by individuals who are
organizationally independent from the organizations
responsible for developing and implementing the RPP.
3.2.4 Radioactive Material Transportation Exclusion
10 CFR part 835 excludes radioactive material transportation
not performed by DOE or a DOE contractor (10 CFR
835.1(b)(7)). The intent is to exclude from 10 CFR part 835
transportation by the U. S. Postal Service or a commercial
carrier, such as FedEx or UPS, which transport radioactive
material as part of their normal operations. A company or
subsidiary of a corporation that operates a DOE facility
would not be considered a commercial carrier - even if such
an organization transports radioactive material as part of
its contractual agreement with DOE. Activities related to
transportation such as the preparation of material or
packaging for transportation, storage of material awaiting
transportation, or application of markings and labels
required for transportation is not included in the exclusion
(See 10 CFR 835.2, Definitions, Radioactive material
transportation).
Subparts F (Entry Control Program) and G (Posting and
Labeling) do not apply to radioactive material
transportation conducted by a DOE individual or DOE
contractor, when the radioactive material is under the
continuous observation and control of an individual who is
knowledgeable of and implements required exposure control
measures or when conducted in accordance with Department of
Transportation regulations or DOE orders that govern such
movements (10 CFR 835.1(d)). This does not affect the
application of requirements to radioactive material
transportation in the other subparts of 10 CFR part 835. In
accordance with the definition of “radioactive material
transportation,” the exclusion applies while the material is
in the process of undergoing movement, including nominal
stoppages such as for traffic considerations or refueling
activities.
Occupational doses received as a result of radioactive
material transportation performed by other than the DOE or a
DOE contractor, shall be considered to the extent
practicable when determining compliance with the
occupational dose limits (10 CFR 835.1(c)). Occupational
doses received by DOE or DOE contractor employees while
conducting radioactive material transportation shall be
considered when determining compliance with the occupational
dose limits.
3.3 RPP Functional Elements
This section identifies the programmatic functional elements
of a comprehensive RPP. For each element, the following
table identifies the applicable regulatory provisions,
contractual requirements, and recommended guidance
document(s) which are useful in achieving compliance with
these provisions.
Functional Element Regulatory Provision Contractual/Guidance Document
1. Organization and
Administration 10 CFR 835, Subpart B Chapter 3.0 of this Guide
2. ALARA Program 10 CFR 835.101(c), Subpart K Chapter 4.0 of this Guide.
3. External Dosimetry Program 10 CFR 835.401 (a), 402(a), (b) Chapter 6.0 of this Guide.
4. Internal Dosimetry Program 10 CFR 835.401(a), 402(c), (d) Chapter 5.0 of this Guide.
5. Area Monitoring and Control
a. Area Radiation Monitoring 10 CFR 835.401(a) Chapter 6.0 of this Guide.
b. Airborne Radioactivity
Monitoring 10 CFR 835.209, 401(a), 403 Chapter 10.0 of this Guide.
c. Contamination Monitoring
and Control 10 CFR 835.401(a), Subpart L Chapter 11.0 of this Guide.
d. Instrument Calibration
and Maintenance 10 CFR 835.401(b) Chapter 9.0 of this Guide.
6. Radiological Controls
a. Radiological Work Planning 10 CFR 835.501(d), 1001(b), 1003 DOE?STD?1098?99,
RADIOLOGICAL CONTROL
b. Entry and Exit Controls 10 CFR 835, Subpart F Chapter 7.0 of this Guide.
c. Radiological Work Controls 10 CFR 835, Subpart F, 1003 Chapter 7.0 of this Guide.
d. Posting and Labeling 10 CFR 835, Subpart G Chapter 12.0 of this Guide.
e. Release of Materials
and Equipment 10 CFR 835.1101 Chapter 11.0 of this Guide.
f. Sealed Radioactive Source
Accountability and Control 10 CFR 835, Subpart M Chapter 15.0 of this Guide.
7.Emergency Exposure Situations 10 CFR 835.1301, 1302 DOE O 151.1-1C, Comprehensive
Emergency Management System
(DOE 2005c)
8. Nuclear Accident Dosimetry 10 CFR 835.1304 Chapter 6.0 of this Guide.
9. Records 10 CFR 835, Subpart H Chapter 13.0 of this Guide.
10. Reports to Individuals 10 CFR 835, Subpart I Chapter 13.0 of this Guide.
11. Radiation Safety Training 10 CFR 835, Subpart J Chapter 14.0 of this Guide.
12. Limits for the Embryo/Fetus 10 CFR 835, Subpart C Chapter 8.0 of this Guide.
Appendix 3.A
PREPARATION, REVIEW, AND APPROVAL OF
RADIATION PROTECTION PROGRAMS
3.A 1. PREPARATION OF RPPs
The RPPs detail how the site, facility, or activity has met
or will meet the requirements of 10 CFR 835. The format for
the RPP is not specified. This flexibility will permit the
RPP submitting organizations to take advantage of
pre-existing documents. The following sections describe the
minimum content expected in RPPs.
Note: The term “Operations Office” is used throughout
this document. Where it is used, the term “Field
Office,” “Site Office” or the term “Area Office,” as
appropriate, should be substituted where there is no
Operations Office.
3.A 1.1 RPP SUMMARY
Each RPP should contain a summary section in the front to
allow DOE management and reviewers to quickly assess the
more significant information contained in the RPP. The
summary should identify the following minimum information:
(1) Any requests for exemptions contained in the RPP;
(2) The total additional funding required to meet the
commitments of the RPP and the expected sources of
funding by fiscal year;
(3) Any significant new programs or activities needed to
meet the requirements;
(4) Any significant impacts to other programs or activities
not included in the RPP;
(5) Any constraints to implementing the RPP; and
(6) Those areas where there is currently full compliance
with the requirements.
3.A 1.2 GENERAL INFORMATION
The RPP should include general information which: (1)
identifies that the RPP addresses the requirements of 10 CFR
835; (2) identifies whether the RPP is the initial submittal
or a revision; (3) identifies the facilities or activities,
missions, and organizations involved; and (4) briefly
discusses the content and format of the RPP.
3.A 1.3 APPLICABILITY OF REGULATORY REQUIREMENTS
The RPP should identify the specific facilities or
activities covered by the RPP. Any determination that a
specific requirement is not applicable to the facilities
or activities addressed in the RPP should be documented
in the RPP to ensure that the determination is clearly
communicated. DOE approval of the RPP will constitute
agreement with applicability statements contained
therein.
Applicability statements may not be used to provide
relief where the requirements are clearly stated to be
applicable in 10 CFR 835. Relief from 10 CFR 835 can
only be granted by an approved exemption granted in
accordance with 10 CFR Part 820, Subpart E as discussed
in Section 3.A 1.8 of this technical document.
The information provided in the plan should clearly
identify which of the following three categories applies
to each requirement for a given facility, site, or
activity:
(1) The requirement is applicable and the RPP defines
the actions and schedules for compliance;
(2) The requirement is applicable and an exemption is
being requested; or
(3) The requirement is not applicable for the reasons
documented in the RPP.
The RPP should also identify any requirements that are
only partially applicable, the limits of the
applicability, and the reasons for the limitation.
Individuals should contact the appropriate Operations
Office to assist with any needed clarification of
applicability statements. The Operations Office should
contact the Office of Health and Safety for any needed
technical clarifications or the Office of the General
Counsel for legal interpretations of 10 CFR 835.
For example, the DOE General Counsel responded to a
question concerning what activities are intended to be
included within the scope of the 10 CFR 835.1(b)(3)
exclusion. In response, General Counsel Ruling 95-1
stated "This exclusion is drafted narrowly to cover only
those activities necessary to prevent an accidental or
unauthorized nuclear detonation (that is, where the
component parts of a nuclear weapon have been assembled
in a manner such that a nuclear detonation could take
place)."
There are potential situations where a DOE protective
force individual could receive an exposure to ionizing
radiation in excess of the 10 CFR 835 limits (or be in
noncompliance with other 10 CFR 835 provisions) as a
result of emergency actions taken to protect nuclear or
other material from theft or diversion. Per General
Counsel Ruling 95-1, these situations would not be
included within the scope of the 10 CFR 835.1(b)(3)
exclusion. However, these situations, if conducted as
part of an emergency response to a threat to nuclear or
other material, would likely fall within the scope of 10
CFR 835.3(d) which states that "Nothing in this part
shall be construed as limiting actions that may be
necessary to protect health and safety."
3.A 1.4 GUIDES AND TECHNICAL STANDARDS
The RPP should identify the guides and technical standards
that are to be adopted as the means to meet 10 CFR 835. The
use of guides and technical standards is not required;
however, it is encouraged for the following reasons:
(1) The use of previously approved methodologies will
streamline the review and approval process; and
(2) The use of guides and technical standards will enhance
the consistent and successful implementation of
requirements across the DOE complex.
The implementing organization should consider methods and
guidance from guides and technical standards when developing
the RPPs; however, alternative methods that achieve
equivalent or better results are acceptable. When an
implementing organization identifies an alternate way to
implement the requirements, a reasonable opportunity will
always be provided to demonstrate compliance with the
requirements using the alternate method. Demonstration of
compliance does not require an organization to address the
differences between the alternate method and the method in
the guide or technical standard unless the comparison is
necessary to demonstrate acceptability.
When guides or technical standards are used, the RPP should
indicate if they are adopted in their entirety or adopted
with exceptions. The exceptions, if any, should be
specifically noted. Methodologies and guidance that are
adopted with exceptions will be reviewed on a case-by-case
basis.
The adopted guides and technical standards should be listed
either by:
(1) Including a list of applicable guides and technical
standards in the RPP, or
(2) Incorporating a list of guides and technical standards
by reference.
Commitments in an RPP to meet all or parts of guides and
technical standards are enforceable as part of the RPP.
3.A 1.5 RESOURCE ASSESSMENT
New RPPs should contain an estimate of the additional
life cycle costs to implement 10 CFR 835. Revised RPPs
may contain an estimate of the change in life cycle costs
associated with the revision, if the change in life cycle
cost is significant. The goals of this element of the RPP
are as follows: (1) to communicate the expected new costs
of implementation to DOE management for the purposes of
budget planning and prioritization; (2) to identify the
need to explore more cost effective means of achieving
compliance; and (3) to identify cases where exemptions
should be requested on the basis of insufficient benefit
versus the expected implementation costs. Identification
of required resources should also serve to open a
dialogue between DOE and the RPP submitting organization
on adjusting costs and activities to the available
resources.
When performing the assessments, the estimator should
consider monetary costs, as well as non-monetary resource
considerations such as the limited availability of special
job capabilities (e.g., health physicists). The assessment
should (1) be guided by available quantitative and
qualitative information; (2) reflect the current status of
plant conditions, configurations, and processes; (3)
consider the availability of materials and resources; and
(4) consider any other information that is relevant to the
radiation protection requirements.
RPP submitting organizations should seek to achieve the
broadest consistency in the methods used to evaluate the
resource requirements so that the assumptions, evaluations,
and results of the assessment can be objectively compared
with the equivalent parameters of other resource
assessments. This will assist DOE and RPP activity
management to determine priorities for the use of funding.
All assumptions and estimates should be made using the best
available knowledge and information.
After evaluating the resource impacts, consideration should
be given if a more cost-effective means of achieving the
intent of the requirement is available. As a minimum, the
use of more cost-effective methods of compliance, or
exemptions (see section 3.A 3.1.6.7 of this attachment),
should be considered whenever the resource expenditures
necessary to meet a requirement are not commensurate with
the expected safety improvements. One of the criteria for
granting an exemption to a nuclear safety requirements is
that the requirement results in resource impacts which are
not justified by safety improvements. In the past DOE has
granted exemptions on this basis for such topics as
radiological postings and recording tritium intakes, see
http://www.eh.doe.gov/whs/rhmwp/exemption.html.
There should be limited effort used to develop the resource
assessments to only that level of detail necessary to
achieve the goals of the assessment as stated above.
3.A 1.6 PRIORITIZATION
The RPP should include a discussion of the prioritization
process used to integrate the proposed activities into a
facility or site schedule of activities. The prioritization
process is to be used to develop the proposed schedules and
should be sufficiently flexible to accommodate changes at
later dates.
The prioritization process should consider available
information from safety analyses and other sources and give
primary attention to controlling and reducing risks to the
public, the environment, and the workers to an acceptable
level. It should also consider other factors such as mission
needs, outage schedules, and external regulations.
The prioritization process should be selected in
consultation with the applicable DOE Operations Office and
Program Offices to ensure that the prioritization of efforts
meets DOE expectations. The prioritization schedule should
tie budgets to schedules.
3.A 1.7 MILESTONES AND SCHEDULES
Per 10 CFR 835.101(f), the RPP must identify proposed
milestones with achievable schedules developed in accordance
with the prioritization process identified in the RPP (see
Section 3.A 1.6 above). In developing the schedules,
consider the resources available to support the work, as
well as any major work reductions or schedule changes in
other areas that will be required in order to meet the
proposed schedules. The RPP should identify major impacts to
activities or commitments outside the scope of the RPP that
will be caused by the proposed additional activities.
Schedules should be developed using the best information
available with any assumptions on availability of resources
(monetary or non-monetary) clearly stated. The milestones
and schedules will be enforceable commitments upon approval
of the RPP. Schedule commitments should be firm commitments
and consequently, should not be listed as contingent on
funding. Thus, it is essential that line program
representatives participate in the review and approval of
RPPs that involve additional funding needs. Following
approval of the RPPs, DOE has a responsibility to provide
appropriate funding to support the RPP schedules, the RPPs
should be revised to reflect the new schedules supported by
funding (provided any schedules specifically prescribed in
the DOE requirements documents are met or schedule
exemptions are approved). Such revisions should be submitted
to DOE for review and approval.
Alternatively, RPP developers may consider requesting an
exemption for unfunded activities, if the criteria for
granting an exemption are met (see Section 3.A 1.8 of this
attachment).
3A 1.8 EXEMPTIONS
Exemptions are to be requested whenever relief is sought
from an applicable DOE requirement. The RPP should clearly
identify any exemptions that have been approved or are being
requested from the subject requirements. The organization
conducting RPP activities may submit requests for exemptions
as part of the RPP provided that they relate to the same
requirements. Requests for exemption that are submitted as
part of the RPP should be identified in the RPP summary for
early recognition. Early identification of exemption
requests is important because they may need to follow a
separate review and approval process.
The provisions for requesting and granting exemptions to
rules are stated in 10 CFR Part 820, Subpart E,
Exemption-Relief.
3.A 2 SUBMITTAL OF RPPS
Per 10 CFR 835.101, RPPs must be submitted to the designated
DOE point-of-contact within the schedule specified in 10 CFR
835.
Normally, the RPP is submitted to a point-of-contact located
in a DOE Operations Office. The Operations Office
point-of-contact should date stamp the receipt of the RPP.
Contact the Operations Office point-of-contact in advance of
the submittal date to determine the number of copies to be
submitted. Documents that are incorporated by reference
should be submitted with the RPP unless other arrangements
are made with the Operations Office point-of-contact. In
addition, if the RPP is not a stand-alone document (able to
be reviewed independent of other documents), contact the
Operations Office point-of-contact prior to submittal of the
RPP to discuss which supporting documents are to be
transmitted with the RPP or made available for onsite
review.
Also see section 3.A 4 below for additional submittal
requirements for final RPPs.
3.A 3. REVIEW AND APPROVAL OF RPPs
3.A 3.1 REVIEW AND APPROVAL PROTOCOL
The Department’s protocol for review and approval of RPPs is
described below. The protocol defines the roles, interfaces,
and responsibilities of Department organizations with
respect to review and approval of RPPs. Organizations who
prepare the RPPs and the DOE organizations responsible for
review and approval of the RPPs should have a shared vision
of what should be in the completed RPPs before submission of
the RPP to DOE. In order to ensure this shared vision and
the development of successful RPPs, early and continual
dialogue between the RPP submitting organization and the
Review Team is essential. This dialogue should begin well
before the RPP is submitted to DOE. The process described
below was built on the lessons learned in similar efforts
and was designed to facilitate that dialogue.
Because review and approval of the RPPs will often involve
multiple Departmental organizations, the review and approval
process should provide for coordination, consistency of
review, and resolution of issues among those offices. In
addition, the review and approval process should address
both the technical adequacy of the proposed RPPs and the
programmatic responsibilities (i.e., funding and mission).
These responsibilities will require additional coordination
within the Department as they may reside in different
organizations.
The review and approval process should be sufficiently
flexible to accommodate the subjects addressed by 10 CFR 835
and adequately structured to permit efficient completion of
the review and approval within the 180 days [See
10 CFR 835.101(i)]. Table 1, at the end of this attachment,
provides recommended time periods to meet this 180-day
requirement.
In the review and approval process, the Operations Office
should be responsible for coordination between the RPP
submitting organization and the Department’s Headquarters
staff. This focused interface will ensure consistency in the
information provided to the RPP submitting organization and
allow interaction with a single point-of-contact. In
addition, the Operations Office should be responsible for
coordinating PSO (Program Secretarial Officer) approvals. It
should be noted that this attachment contains a detailed
protocol. However, individual steps may be modified to or
eliminated, based on local conditions, as long as the
process involves appropriate review and approval. For
example, approval authority may have been delegated to the
Manager of the Field Element (or lower), which would obviate
the need for specific PSO approval
A RPP Review Team should be formed for each RPP to conduct
the review of the RPP. The Review Team members should
include DOE Headquarters and Field Operations personnel with
technical expertise and coordinating responsibility for
program decisions (e.g., funding, schedule). Operations
Office personnel should serve as points-of-contact and
Review Team Leaders for RPP reviews applicable to their
sites. Individual participation in Review Team activities
will vary in level of effort and time frame based on review
and approval needs.
The Operations Office point-of-contact plays a key role in
coordinating all RPP review and approval activities between
DOE Headquarters and the RPP submitting organization.
The process for the development, review, and approval of
RPPs is discussed below. The provisions of 10 CFR 835.101(i)
state that “an initial RPP or an update shall be considered
approved 180 days after its submission unless rejected by
DOE at an earlier date.” See Table 1 for a typical schedule
of activities to meet this provision.
3.A 3.1.1 Identifications of Responsible Review Staff
3.A 3.1.1.1 Points-of-Contact
Each Operations Office Manager should identify a
point-of-contact for the RPP. The Operations Office
point-of-contact should be the primary interface for all
activities associated with the development, submittal,
review, and approval of the RPPs. The Operations Office
point-of-contact should also be the Review Team Leader.
The Review Team Leader should coordinate assignment of
Review Team members with the PSOs and the Operations Office.
3.A 3.1.1.2 RPP Review Teams
As discussed in the previous paragraph, the Operations
Office point-of-contact should normally be the Review Team
Leader. The Operations Office Manager may provide additional
team members and technical assistance as necessary. In
addition, each affected PSO should identify the Program
Office representatives for each Review Team to the Review
Team Leaders. The PSO may assign multiple reviewers to a
single site or a single reviewer.
3.A 3.1.2. Review Planning
3.A 3.1.2.1 RPP Guide
Each responsible PSO should prepare an RPP Guide that
defines DOE’s specific technical and programmatic
expectations for the RPPs internal to their organization.
The guide should include the following types of information:
(1) criteria and/or checklists of items to be considered
during the review, (2) approaches to key issues, (3)
direction on use of existing RPPs and approvals, (4) review
and approval authorities, and (5) specific issues relating
to Headquarters or Operations Office review
responsibilities. The guide should be as brief as possible,
should be user friendly, and should not repeat general
guidance available in other guidance documents such as this
attachment. The PSO should provide assistance and/or
training to the Review Teams on the use of the guide.
3.A 3.1.2.2 Implementation Action Plan
For each RPP, the Review Team Group should prepare an
Implementation Action Plan that defines the Review Team
activities, priorities, and schedule. A copy of the plan
should be provided for information.
3.A 3.1.2.3 Responsibility and Interface Matrix
The PSO should prepare and maintain a matrix that identifies
the Review Team Leader, Review Team members, and DOE
programmatic and technical contacts for each RPP.
3.A 3.1.3 Meetings, Conference Calls, and Status Reports
3.A3.1.3.1 Initial Site Meeting
The Review Team should meet with the RPP submitting
organization at the earliest feasible date to discuss the
basic expectations for implementation of the DOE
requirements document and to discuss any issues that might
impact the timely and acceptable completion of the RPP.
Issues to be discussed should include (1) how to best use
existing plans or other information in developing the RPP;
(2) potential exemptions; (3) plans and schedules for
ongoing interactions; and (4) funding sources for new
activities identified as necessary to come into
compliance. The Operations Office point-of-contact has
primary responsibility for planning and coordinating this
meeting.
3.A 3.1.3.2 Status Meetings
Periodic status meetings should be held with the RPP
submitting organization to fully discuss all elements of
the proposed RPPs that could affect the acceptability of
the RPPs.
3.A3.1.3.3 Periodic Conference Calls
The Operations Office point-of-contact should coordinate
regular conference calls with the RPP submitting
organization and the Program Offices to address and resolve
issues as they arise. As necessary, site or headquarters
meetings should be held to resolve difficult issues. The
Operations Office point-of-contact has primary
responsibility for coordinating phone conferences, as well
as necessary meetings to resolve issues.
3.A 3.1.4 Submittal and Distribution of RPPs
As discussed in Section3.A 2 of this attachment, RPPs should
be submitted directly to the Operation Office
point-of-contact. The Operations Office point-of-contact
should transmit a copy of the RPP to the Review Team members
and a copy of the transmittal memorandum to the affected
PSOs within four working days of the receipt of the RPP. The
transmittal memorandum should identify the required date for
completing the review.
3.A 3.1.5 Review
3.A 3.1.5.1 Review to Review Teams
RPPs should be reviewed by an integrated Review Team with
Program and Operations Office representatives, as discussed
in Section3.A 3.1.1.2 above. Program Office team members and
their contacts should, as a minimum, participate in the
review of issues involving funding, missions, schedules,
priorities, and exemptions. The Review Team Leader should
facilitate resolution of unique or difficult issues not
addressed in the RPP Guide.
Review Team members should assist the RPP submitting
organization in clearly understanding what actions or
changes are necessary to result in an acceptable RPP. DOE
comments and feedback should be routed through the Review
Team Leader to ensure consistent feedback. The Review Team
Leader should also be responsible for resolving conflicts
prior to communication with the RPP submitter.
All reviewers should expedite their reviews to allow closure
on an acceptable RPP as early as possible.
3.A 3.1.5.2 Delegated Approval Authority for RPPs
The PSO may delegate the authority to approve specific RPPs.
Any such delegation should be provided in writing to the
designee and documented in the Functions, Responsibilities,
and Authorities (FRA) document for that organization.
Wherever the authority to approve an RPP has been delegated
to the Operations Office by all of the affected PSOs, the
Operations Office may choose to have the Review Team consist
entirely of Operations Office personnel provided any
technical and programmatic requirements can be handled by
the designated team.
Per 10 CFR Part 820, Subpart E, the authority to approve
exemptions to 10 CFR 835 cannot be delegated.
3.A 3.1.6 Approval
3.A 3.1.6.1 Approval Recommendations by the Review Team
The Review Team Leader is responsible for ensuring that the
Operation’s Office Manager receives the Review Team’s final
recommendation for approval within 145 days after receipt of
the RPP. That recommendation should either endorse
acceptance of the RPP as submitted (or changed through
negotiations during the review process) or, if issues cannot
be resolved, provide recommendations regarding specific
additional commitments or changes to be incorporated in the
RPP.
3.A 3.1.6.2 Operations Office Review of the Review Team
Recommendations
The Operations Office Manager, or equivalent, should review
the recommendation of the Review Team and either endorse the
recommendation or provide specific recommendations for an
acceptable RPP. The Operations Office Manager is responsible
for ensuring that the PSO receives the recommendations of
the Review Team along with any recommendations from the
Operations Office no later than 159 days after receipt of
the RPP [with information copy to the affected CSOs
[Cognizant Secretarial Officer)].
In some cases involving multiple PSOs, approval authority
may be delegated by one or more PSOs, but not all PSOs. In
such cases, the Operations Office Manager should coordinate
the remaining approvals with the PSOs.
For cases in which the approval authority has been delegated
by all affected PSOs to the Operations Office Manager, the
Operations Office Manager should skip to step 3.A 3.1.6.4
Approval Letter, below.
3.A 3.1.6.3 PSO Approval Memorandum
In order to ensure the Operations Office has a week to
transmit the approval or disapproval of the RPP before it
becomes automatically effective 180 days after receipt of
the RPP by DOE, each affected PSO should indicate approval
or disapproval of the RPP in a memorandum to the Operations
Office within 173 days of receipt of the RPP by DOE.
3.A 3.1.6.4 Approval Letter
The Operations Office Manager should transmit the approval
memorandum by letter to the RPP submitting organization no
later than 180 days after receipt of the RPP by DOE.
3.A 3.1.6.5 Imposition of RPPs
The Review Team will endeavor to resolve any issues
identified during the review process. If conflicts exist
which cannot be resolved, the Department may exercise its
authority [see 10 CFR 835.101(b)] to modify proposed RPPs to
include those actions and schedules that the Department
finds appropriate for achieving full compliance in a
reasonable and timely manner. In such cases, the PSO
approval memorandum should be replaced with a memorandum
imposing a revised RPP. The revised RPP should be
transmitted to the RPP submitting organization by the
Operations Office Manager. The RPPs may be renegotiated at a
later date, but until it is replaced by another approved
RPP, it will be the enforceable basis for implementation of
10 CFR 835.
3.A 3.1.6.6 RPPs which are not Approved by Final Date
Per 10 CFR 835.101(I), RPPs which are not approved within
the approval period specified in the DOE requirements
document should be considered to be approved unless another
RPP is imposed by the Department. These RPPs may be
renegotiated at a later date, but until they are replaced by
another approved RPP, they will be the enforceable basis for
implementation of 10 CFR 835.
3.A3.1.6.7 Approval of RPPs Containing Exemption Requests
RPPs may contain requests for exemptions. When they do, the
requests may be granted in the approval memorandum for the
RPP, provided that all of the requirements for processing
exemptions are met, including the approval of the DOE
Headquarters official designated by 10 CFR Part 820 Subpart
E. When exemptions are approved as part of an RPP, the
approval document should state how the provisions of
10 CFR Part 820, Subpart E were met. Alternatively,
exemptions may be approved separately and referenced in the
RPP approval letter.
Upon submittal of the RPPs, the Review Team Leader should
determine if any exemption requests submitted in the RPPs
need to be reviewed and approved separate from the RPPs.
Where separate review and approval is necessary, the Review
Team Leader should alert the PSO Review Team representatives
to initiate a separate and expeditious review of the
exemption requests.
The provision in 10 CFR 835.101(i) that states that RPPs are
considered approved 180 days after submission, does not
apply to exemptions.
Approval of an RPP pending granting of an exemption does not
constitute or imply approval of the exemptions contained
therein.
3.A 3.2 DISTRIBUTION OF COPIES OF THE FINAL RPP
The Operations Office Manager should be responsible for
distributing approved RPPs (if changed from the originally
submitted RPP) to the Office of the Docketing Clerk (in the
Office of Price Anderson Enforcement) and to the affected
PSOs. Copies of approved RPPs transmitted to the Office of
the Docketing Clerk should include both a hard copy and an
electronic copy. As required by 10 CFR Part 820, the Office
of Docketing Clerk will maintain a file of enforceable
actions based upon rule violations and noncompliance with
RPPs.
3.A 3.3 REVIEW RESPONSIBILITIES
The Review Team should determine if the RPP provides an
acceptable method to meet 10 CFR 835. The Review Team should
also determine if the RPP adequately addresses the elements
discussed in Section 3.A 1 of this attachment (Preparation
of RPPs). RPP submitting organizations are encouraged to use
the methodologies contained in this Guide for implementation
of 10 CFR 835 where they are reasonable and economical;
however, one may elect to propose an alternate way to meet
the requirements. In cases where an alternate method is
proposed, the Review Team should evaluate the proposed
method to ensure that it will be adequate to meet the
requirements and provide a comparable level of safety.
The Review Team should verify that the RPP provides
sufficient detail to permit DOE to measure the progress
towards meeting the DOE requirements.
The Review Team should also ensure that (1) the projected
budget and schedule information contained in the RPP is
reasonable and consistent with the funding projects, (2) the
prioritization of efforts meets the DOE expectations, (3)
the proposed milestones and schedules will meet DOE needs,
(4) the applicability of the requirements is correctly
identified, and (5) the compensatory actions are acceptable.
The Review Team should expect to see significant variations
in the level of detail and size of individual RPPs because
of the diversity of types, sizes, and missions of DOE
facilities. In order to facilitate timely reviews and
agreements on complex RPPs, the members of the Review Team
should visit the site and/or facility and have frequent
communication during both the preparation and the review of
the RPP.
3.A 3.4 APPROVAL RESPONSIBILITIES
DOE approval of the RPP constitutes acceptance by the PSO
that:
(1) The proposed activities represent an acceptable
method to meet the requirements;
(2) The resources identified in the RPP are necessary and
sufficient to ensure completion of the activities
contained in the RPP and are expected to be available
to support the proposed schedules;
(3) The proposed milestones and schedules are acceptable;
(4) The applicability of the requirements is correctly
identified; and
(5) The identified compensatory actions are acceptable.
3A 4. REVISIONS TO RPPs
The RPPs will probably need to be revised and updated during
the life cycle of the site, facility, or activity. Approved
RPPs should be revised as needed to reflect the addition or
deletion of other work at a facility or other factors that
affect the ability to meet the approved schedule, such as
prospective changes in the level of funding or assumptions
regarding the availability of materials and other resources.
The provisions in 10 CFR 835.101(h) contain conditions under
which RPPs may be revised without prior approval from DOE.
In such cases, submit the revised RPP to DOE within 30 days
of the effective date of the RPP. All other changes to RPPs
should be reviewed and approved by DOE prior to the
effective date of the change. Revised RPPs should be
submitted in a timely manner for DOE approval (at least 180
days before the change is to be effective), along with
justification for the revision. As noted previously,
proposed revisions will be considered approved 180 days
after submittal to DOE, unless they are approved or rejected
by DOE.
The changes to the RPP should be clearly indicated (e.g.,
sidebars) to facilitate timely review. Revised RPPs are to
be submitted to DOE in the manner described in this section
and reviewed and approved in the manner described in section
3.A.3 above.
Any changes to RPPs which will result in a requirement not
being met, require an approved exemption.
3.A 5. EXTENSIONS TO THE SUBMITTAL SCHEDULE FOR RPPS
Extensions to the schedule for submitting an RPP will
generally require an exemption processed in accordance with
10 CFR Part 820, Subpart E, and approved by the Secretarial
Officer responsible for environment, safety and health
matters (i.e., the Chief Health, Safety and Security
Officer).
3.A 6. IMPLEMENTATION TRACKING
Following approval of the RPP and during the implementation
process, the DOE Operations Office should oversee progress
in meeting the commitments in the RPP (for example,
schedules, milestones, and costs) and maintain a dialogue on
any problems that arise.
3.A 7. INCORPORATION BY REFERENCE
The RPP submitting organization may choose to incorporate
information into the RPP by referencing all or selected
portions of other documents. In such cases, the portions of
the referenced documents that are incorporated into the RPP
are also subject to the provisions of this Guide and
attachment.
However there are situations when a citation or reference is
used to indicate the origin of some of the text in a
document. For example, in this Guide, 10 CFR 835 is cited to
indicate the basis for statements containing the word
“should” or “shall” (i.e., requirements). Consequently, the
RPP submitting organization should clearly indicate which
documents (or portions of documents) are considered part of
the RPP commitments. The RPP submittal should maintain a
file of all documents incorporated by reference and should
make non-DOE documents available to DOE upon their request.
See also section 3.A 1.2 above for submittal criteria.
Table 1. TYPICAL SCHEDULE FOR REVIEW AND APPROVAL OF RPPS
Submittal of RPP to Operations Office 0 days
Operations Office send RPP to Review Team/PSOs/Environment, Safety and Health 4 days
Review Team sends recommendation to Operations Office Manager 145 days
Operations Office Manager sends recommendation to PSO* 159 days
PSO Approval to Operations Office* 173 days
Operations Office Manager issues approval/disapproval to RPP submitting organization 180 days
*If approval authority not delegated to the Operations Office by
the PSO.
4.0 ALARA
In promulgating 10 CFR 835, DOE considered alternatives to
reduce the risk from radiation exposure to workers that
included retaining the current occupational dose limits,
reducing these limits, and emphasizing efforts to maintain
occupational doses As Low As is Reasonably Achievable
(ALARA). After considering public comments on this issue,
DOE elected to emphasize the ALARA process to maintain
occupational dose for DOE and contractor employees as far
below the current regulatory occupational dose limits as
reasonably achievable. Adopting the ALARA process in DOE
occupational radiation protection regulations also provides
consistency with recommendations provided in the President’s
Radiation Protection Guidance to Federal Agencies For
Occupational Exposure (EPA 1987), which endorsed the ALARA
process.
The importance of the ALARA concept was further stressed in
DOE P 441.1, DOE Radiological Health and Safety Policy (DOE
1996), which states:
It is the policy of the Department of Energy to
conduct its radiological operations in a manner that
ensures the health and safety of all its employees,
contractors, and the general public. In achieving
this objective, the Department shall ensure that
radiation exposures to its workers and the public
and releases of radioactivity to the environment are
maintained below regulatory limits and deliberate
efforts are taken to further reduce exposures and
releases as low as reasonably achievable. The
Department is fully committed to implementing a
radiological control program of the highest quality
that consistently reflects this policy.
10 CFR 835 requires formal plans and measures for
maintaining occupational exposures ALARA as part of the
documented radiation protection program (RPP). Measures
include incorporating ALARA considerations into the design
of new facilities and modifications of existing facilities,
as well as activities that pose the potential for
significant occupational dose. Additionally, administrative
controls are addressed as measures which supplement
engineered controls and are integrated into the work
planning process. Record keeping and training requirements
related to ALARA are also specified. This chapter of this
Guide discusses acceptable methods for implementing the
ALARA process provisions in 10 CFR 835.
Due to the complex nature of many DOE activities, a
combination of radiological and non-radiological hazards may
be encountered. Identification of non-radiological hazards
is critical to the ALARA process, because efforts to apply
the ALARA process may inadvertently increase risks from
non-radiological hazards. An integrated safety management
approach that optimizes worker protection from all hazards
should be considered in the ALARA process for a given DOE
activity.
4.1 Implementation Guidance
Subpart B of 10 CFR 835 requires that a DOE activity shall
be conducted in compliance with an RPP approved by DOE
[10 CFR 835.101(a)]. The content of the RPP shall be
commensurate with the nature of the activities performed and
shall include formal plans and measures for applying the
ALARA process to occupational exposure [10 CFR 835.101(c)].
Subpart K of the rule provides requirements for design and
control for maintaining radiation exposures ALARA. The
primary methods used for maintaining radiation exposures
ALARA in controlled areas shall be engineered controls;
administrative controls may be used as supplemental features
and for specific activities where engineered controls are
impractical [10 CFR 835.1001(a) and (b)]. The rule specifies
objectives for design of new facilities or modifications to
existing facilities (10 CFR 835.1002) and the integration of
work controls during routine operations (10 CFR 835.1003).
Additionally, the rule requires documentation of the actions
taken to maintain occupational exposures ALARA, including
actions required by the RPP, as well as facility design and
control actions [10 CFR 835.704(b)].
Guidance on complying with the training requirements of
10 CFR 835.103 and 835.901 is provided in Chapters 3 and 14
of this Guide.
This chapter provides the basic guidelines for conducting an
occupational ALARA program. It includes the requirements and
guidance for developing, implementing, documenting, and
providing feedback and lessons learned for improving the
program to reduce individual doses to levels that are ALARA.
4.2 ALARA Programs
4.2.0 Formal Plans and Measures
The method of implementing an ALARA program is highly
dependent on the complexity and magnitude of potential
radiological hazards associated with the DOE activity. The
elements of an effective ALARA program should be identified
in a formal ALARA plan or procedure. The RPP shall clearly
identify the ALARA plans and measures employed by the DOE
activity [10 CFR 835.101(c)]. The degree of formality and
the level of detail contained in these plans and measures
and other pertinent documentation should be commensurate
with the magnitude of the radiological hazard associated
with the DOE activity. A DOE activity with higher collective
dose and/or potential for significant occupational doses
should have more detailed ALARA documentation than an
activity with low collective doses and/or potential for
significant occupational doses. ALARA plans and measures
should address the following elements at a level
commensurate with the radiological hazards associated with
the DOE activity:
· Policy and Management Commitment: Establish commitment and
participation of all line management and all levels of the work
force;
· ALARA Training: Require ALARA training for all employees,
including managers involved with any aspect of radiological
operations. Guidance is provided in Chapters 4 and 14 of this
Guide and the RCS;
· Plans and Procedures: Consider administrative and engineered
controls and optimization methods during work procedure
development to assure that the ALARA process is fully integrated
into the development of operational/experimental plans,
procedures, and protocols. Document formal plans and measures for
applying the ALARA process to occupational doses;
· Internal Assessments/Audits: Conduct comprehensive internal
reviews, audits, and evaluations periodically and report the
results to the highest levels of site management. Guidance is
provided in Chapter 3;
· ALARA Design Review: Ensure the integration of appropriate
methods and considerations during the design phase to maintain
occupational exposures ALARA during subsequent construction,
modification, and operation of the equipment or facility;
· Radiological Work/Experiment Administration and Planning:
Implement controls and use optimization methods to assure that
occupational dose is maintained ALARA for routine and special
operations or experiments; and
· Records: Maintain documents that demonstrate compliance and
that the program is adequately carried out. Guidance is provided
in Chapter 13.
4.2.1 Policy and Management Commitment
Management commitment to ALARA, consistent with the DOE
Radiological Health and Safety Policy (DOE 1996), is a
critical element in ensuring a successful ALARA program.
This commitment should take the form of a formal, written,
policy statement from a high level of corporate management,
generally the senior site executive or company officer
responsible for radiological activities that cause the
exposures. This commitment should hold all levels of
management and individual workers responsible for adhering
to the company's ALARA policy. If appropriate, union
leadership endorsement of the ALARA policy should be
considered.
Senior site and line management should demonstrate their
support of the ALARA program through direct communication,
instruction, inspection of the workplace, and actions
including:
· management decisions that place ALARA considerations before
cost or schedule considerations (in accordance with numerical
criteria; see section 4.2.5 below);
· encouragement of and praise for workers who identify ALARA
solutions;
· support of the ALARA Committee; and
· publication of ALARA success stories.
All site personnel should be made aware of management's
commitment to ALARA and radiological workers should be
instructed on their responsibility to comply. Management’s
ALARA commitment statement should be periodically updated
and reaffirmed.
4.2.2 ALARA Training
Specialized ALARA training should be developed for
personnel who plan, prepare, schedule, estimate, or
engineer jobs that have the potential for significant
radiological consequences. The purpose of training these
personnel in ALARA concepts and techniques is to empower
them to include ALARA considerations in the early phases
of job planning and engineering. This training should
provide the basics of ALARA concepts and the use of ALARA
related equipment such as containment devices, shielding,
ventilation, and special tools. Topics such as
radiological waste minimization, application of
decontamination efforts, and basic contingency planning
for mitigation of accidental spills and releases may also
be appropriate. DOE has developed specialized training
material for these types of positions in DOE HDBK
1110-2008, ALARA TRAINING FOR TECHNICAL SUPPORT PERSONNEL
(DOE 2008).
Discipline-specific ALARA training may be appropriate for
some organizations including: operations, maintenance,
engineering, production, and construction (craft workers).
Chapter 3 provides additional guidance with respect to
training for such individuals under 10 CFR 835.103. Mock-up
training may be appropriate for craft workers and others to
prepare them for unique and/or high dose jobs.
4.2.3 Plans and Procedures
10 CFR 835.101(c) requires that the content of each RPP be
commensurate with the nature of the activities performed and
include formal plans and measures for applying the ALARA
process to occupational exposures. The RPP (approved by
facility management and DOE) and supporting procedures
(approved by facility management) should describe the
organization, responsibilities, and method of operation of
the ALARA program. These documents should be reviewed and
updated according to an established schedule. Chapter 3
provides additional guidance with respect to procedures
required under 10 CFR 835.104.
4.2.4 Internal Assessments/Audits
10 CFR 835.102 requires that internal audits of the RPP be
conducted such that all functional elements are reviewed no
less frequently than every 36 months and shall include
program content and implementation. The ALARA program is one
of these functional elements. Chapter 3 provides detailed
guidance concerning internal audits. Management's
responsibilities for reviewing, auditing, and evaluating the
ALARA program should be clearly documented. The occupational
ALARA program should be evaluated by an individual(s) or
members of the ALARA Committee with no direct responsibility
for implementing the program.
4.2.5 ALARA Design Review
10 CFR 835.1001 requires that measures be taken to maintain
radiation exposures in controlled areas ALARA. The primary
method used shall be engineered controls (e.g., confinement,
ventilation, remote handling, and shielding); administrative
controls shall be incorporated only as supplemental methods
and for specific activities where engineered controls are
demonstrated to be impractical (10 CFR 835.1001).
10 CFR 835.1003 further requires that during routine
operations, the combination of engineered controls and
administrative controls shall provide that the anticipated
occupational dose to general employees does not exceed
regulatory limits and that the ALARA process is utilized for
personnel exposures to ionizing radiation. Engineered
controls typically include features that are used to control
the work environment, such as permanent structures, systems,
and controls, including shielding, filtered ventilation
systems, remote controls, containment devices, and the use
of designs and materials that facilitate operations,
maintenance, and other activities. They may also include
controls (e.g., temporary shielding, confinement and
ventilation systems) that are typically used to facilitate
short-term or emergent operations when the installed
engineered controls do not provide the desired level of
protection. In addition to the engineered controls, initial
consideration should be given to elimination or substitution
of the hazards where feasible and appropriate. This could
include use of non-radioactive material or sources.
Administrative controls typically include controls that are
implemented by the individual at the work site, including
written procedures, technical work documents, work
authorizations, and other controls that are used to guide
individual actions in a manner that will facilitate
implementation of the ALARA process.
DOE has an approved set of directives concerning
radiological design criteria for the design, construction,
operation, and decommissioning phases of its nuclear
facilities. (See list below.) The appropriate ALARA design
features should be incorporated into modifications of
existing facilities and/or equipment and designs of new
facilities and/or equipment as early as possible in the
engineering and design process. From early in the design
phase and throughout the project, a radiological engineer or
representative of the radiation protection staff should be
assigned to the design team. This individual should ensure
that reasonable radiological considerations have been
integrated into the design, construction procedures,
proposed operating procedures, and plans for
decommissioning. Numerical criteria (e.g., dollars per rem
avoided) developed for site ALARA decisions should be used
to determine those design features that are reasonable. An
individual with expertise in radiation protection,
preferably from the site staff, but at least familiar with
the site program, should perform an independent ALARA design
review that includes the following elements:
· review the general configuration of the facility and/or
equipment, considering traffic patterns, location of radiation
areas, location and size of changing rooms, adequacy of personnel
decontamination facilities, location of fixed monitoring
equipment, and adequacy of space for anticipated operations,
maintenance, production, research, and decommissioning. Facility
design and selection of materials shall include features that
facilitate operations, maintenance, decontamination, and
decommissioning [10 CFR 835.1002(d)]. The RCS provides additional
guidance;
· verify that radiological design criteria are consistent with
applicable federal/state regulations, recognized standards and
guides, and with the following DOE directives relating to
radiological safety in design:
– 10 CFR 835;
– DOE 5400.5; Radiation Protection of the Public and the
Environment (DOE 1993a);
– DOE P 441.1; Department of Energy Radiological Health and
Safety Policy (DOE 1996)
– DOE O 420.2B, Safety of Accelerator Facilities (DOE 2004a);
– DOE 5480.30, Nuclear Reactor Safety Design Criteria (DOE
1993b);
– DOE O 420.1B, Facility Safety (DOE 2005d);
– DOE O 413.3A, Program and Project Management for the
Acquisition of Capital Assets (DOE 2006b);
– DOE 435.1, Radioactive Waste Management (DOE 2001f); and
– the RCS.
· verify that the design of the confinement and ventilation
systems provides the required level of protection from airborne
contamination, giving particular attention to patterns of air
flow and to the locations of air inlets, penetrations, and
exhausts. Releases of radioactive material to the workplace
atmosphere should be avoided under normal operating conditions
and inhalation of such materials by workers should be controlled
to the extent reasonably achievable;
· evaluate and confirm the adequacy of specific control
devices for reducing occupational doses, including shielding,
hoods, glove boxes, containments, interlocks, barricades,
shielded cells, decontamination features, and remote operations.
External sources of radiation in areas of continuous occupational
occupancy (2,000 hours/year) shall be maintained below an average
of 0.5 millirem (0.005 mSv) per hour and as far below this
average as is reasonably achievable. For areas where occupancy
differs from the above, external dose rates should be ALARA and
should be maintained at a rate so as not to exceed 20% of the
limits in 10 CFR 835.202;
· verify that the design will be able to maintain personnel
entry control for each radiological area, commensurate with
existing or potential radiological hazards within the area, by
using one or more of the methods listed in 10 CFR 835.501;
· verify that each entrance or each access point to high and
very high radiation areas will have the control features required
by 10 CFR 835.502; and
· assess the adequacy of planned radiological monitoring and
nuclear criticality safety instrumentation and determine whether
the proposed instrumentation is appropriate for the expected
types, levels, and energies of the radiation(s) to be
encountered, and whether it has sufficient redundancy and
capability for operation under normal operating conditions and
during emergencies [10 CFR 835.401(b)].
The ALARA design review should have six discrete phases:
· dose assessment;
· review of projected radiological conditions against the
trigger points or numerical criteria established by management to
initiate a review (e.g., creation of a new radiation source or an
increase in the dose rates from an existing source that causes
increased projected facility lifetime collective dose of greater
than 5,000 millirem (50 mSv) or annual collective dose of 1,000
millirem (10 mSv), from operations, maintenance, production,
research, inspection and decommissioning activities);
· identification of the applicable radiological design
criteria;
· review of similar facilities, designs, and processes to
assist in the selection of optimum ALARA design features and less
costly alternatives using approved numerical criteria; and,
· incorporation and documentation in the design package of
features to reduce the: exposure of personnel; spread of
radioactive contamination; release of radioactive effluent; and
creation of radioactive waste; and
· post-construction review of effectiveness of ALARA
engineering features to provide feedback to the design engineers
and help refine the design process. The ALARA design review
should be conducted and documented in accordance with an approved
procedure and the design review package should be readily
retrievable. Detailed radiological design considerations are
discussed in PNL-6577, Health Physics Good Practices for Reducing
Radiation Exposures to as Low as Reasonably Achievable (ALARA)
(PNL 1988a).
Optimization Methodology
Optimization methods are required to assure that
occupational exposure is maintained ALARA in developing
and justifying facility designs or modifications and
physical controls. Optimization methodology provides the
technical and managerial basis for setting numerical
criteria for ALARA decisions in the design of facilities,
development or review of work processes, and the
design/purchase of special tools and equipment. Selection
of an appropriate cost benefit factor for reducing
occupational dose involves a judgment of the relative
value of dose, normally in terms of dollars per rem
avoided. Additionally, guidance on optimization
methodology will also provide the basis for selection of
trigger points or collective dose values (facility
lifetime, facility annual, job lifetime, one time job,
etc.) above which an ALARA design review or job review is
appropriate. Numerical criteria for ALARA decision making
should include radioactive waste volume, radioactive
effluent, contamination levels, and airborne
radioactivity levels. Optimization methodology has led to
a multi-attribute analysis technique which is discussed
extensively in ICRP Publication 37, Cost-Benefit Analysis
in Optimization of Radiation Protection (ICRP 1982) and
ICRP Publication 55, Optimization and Decision-making in
Radiological Protection (ICRP 1990).
At sites with significant collective dose, formally
documented optimization methodologies should be developed
for ALARA reviews and decisions on implementation of ALARA
efforts should be developed. This may be on a site- or
facility-specific basis. Application of optimization
methodologies to the ALARA process should lead to
consistent, rational, repeatable decisions as to which ALARA
efforts are justifiable. The level of effort involved in
documenting ALARA decisions should be commensurate with the
potential dose savings to be realized. A detailed evaluation
need not be made if its cost, including the cost of
documentation, outweighs the potential value of the
benefits. The procedure used to evaluate the
"appropriateness" of dose-reduction and contamination
minimization decisions should be maintained. The RCS and
PNL-6577 provide additional guidance on optimization
methodologies.
4.2.6 Radiological Work/Experiment Administration
and Planning
10 CFR 835.1003 requires that during routine operations, the
combination of engineered and administrative controls shall
provide that the anticipated occupational dose to general
employees shall not exceed the limits established in
10 CFR 835.202 and that the ALARA process is utilized for
personnel exposures to ionizing radiation. Additionally,
10 CFR 835.501(d) requires written authorizations to control
entry into and perform work within radiological areas.
Often, these written authorizations take the form of
radiological work permits (RWP) or technical work documents
(TWD) associated with jobs or experiments. These written
authorizations provide a convenient mechanism to integrate
ALARA review of work tasks if the requirement for ALARA
review is embodied in the written authorization.
Optimization methodologies and appropriate radiological
judgment should be used to develop numerical criteria and/or
trigger points for determining when a formal ALARA review of
planned radiological work activities is required. Once
conducted, the completed ALARA review should be incorporated
into the written authorizations for the work activity.
4.2.6.0 Job/Task/Experiment Reviews
A formal ALARA job/task/experiment review should be
performed for work or experiments with the potential to
exceed the established numerical radiological criteria. The
following are examples of criteria that should trigger a
formal ALARA review.
· the estimated individual or collective dose is greater than
pre-established criteria.
· the predicted concentrations of airborne radioactivity could
exceed pre-established criteria (such as 100 times the DAC values
provided in 10 CFR 835 Appendices A and C).
· there is potential for significant radiological exposures.
· the removable contamination in work areas could exceed
pre-established criteria (such as 100 times the values provided
in 10 CFR 835 Appendix D).
· individuals will enter areas where exposure rates could
exceed pre-established criteria [such as 1 rem/hour (0.01
Sv/hr)].
The ALARA job/task/experiment review should encompass three
discrete phases: (1) pre-job planning and dose assessment;
(2) specification and implementation of ALARA controls and
dose tracking; and (3) post-job review.
Pre-job Planning and Dose Assessment
Pre-job planning should include an estimate of the
collective dose resulting from the job/task/experiment and a
determination regarding whether the numerical criteria for
an ALARA job/task/experiment review will be exceeded. The
estimates may be based on actual or historical radiological
monitoring results. If a review is required, the next step
is to identify appropriate ALARA controls and alternatives.
This should include an assessment of the cost of controls
against numerical criteria.
ALARA Controls
During the work or experiment, periodic inspections should
be made to ensure that ALARA controls are being implemented
and are effective. Typical ALARA controls implemented in the
field include: appropriate use of shielding and personal
protective equipment (including respiratory protection
devices), monitoring of stay times, minimization of time in
radiological areas, maximizing distances from radioactive
sources, and effective use of mock-up training and pre-job
briefings. In addition, individual and collective doses
should be tracked and periodically compared to the dose
estimates to determine if intervention is needed.
Post-Job Review
Criteria should be established to trigger a formal post-job
review. Examples include:
· an actual collective dose equivalent of 5 person-rem or
greater,
· actual doses outside the range of ?25% of pre-job estimates,
· use of the stop radiological work authority,
· issuance of a radiological occurrence/deficiency report, or
· identification of significant lessons learned.
The post-job review should compare the actual person-hours
and person-rem with the estimates, evaluate the
effectiveness and cost of the ALARA controls, document the
lessons learned, and make recommendations on ways to control
dose and contamination for similar activities. The ALARA
review should be documented and records should be readily
retrievable.
In the special case of an ALARA review for a planned special
exposure, additional requirements are described under
10 CFR 835.204.
4.2.6.1 Consideration of Non-radiological Hazards
The work planning process should integrate the consideration
of other industrial, physical, and chemical hazards that an
individual may encounter. Efforts to maintain worker doses
ALARA should ensure that the risk of personnel injury from
other hazards is not disproportionately increased. The ALARA
process should consider the impact of other occupational
hazards when optimizing worker radiation dose. For example:
· excessive protective clothing to control personnel
contamination events may lead to heat stress situations.
· respiratory protective devices used to reduce intakes of
radionuclides may impair visual acuity and communications
capabilities between workers.
· protective clothing to protect workers from chemical hazards
may slow work down leading to increased worker dose.
An integrated approach during the work planning process will
ensure that all occupational hazards are appropriately
considered and the ALARA process is followed.
10 CFR 851, Worker Safety and Health Program (DOE 2006c)
provides requirements for worker safety and health. The
worker safety and health program must integrate the Rule’s
requirements with other site worker protection activities
and the integrated safety management system (ISMS)
[851.11(a)(3)(ii)]. Coordination should be established,
maintained, and documented among worker safety and health
technical disciplines and other safety and health
organizations (e.g., radiation control) at a site to ensure
successful implementation of the worker safety and health
program.
Additional information concerning DOE expectations for
integrating safety management can be found in Department of
Energy Acquisition Regulations (DEAR) clause
48 CFR 970.5223-1, Integration of Environment, Safety and
Health into Work Planning and Execution. This states that
“the contractor will manage and perform work in accordance
with a documented Safety Management System (System).”
DOE G 440.1-8, Implementation Guide for Use with Title 10
Code of Federal Regulations Part 851 (DOE 2006d) provides
guidance for establishing and implementing an ISMS program.
4.3 Records
Actions taken to maintain occupational exposures ALARA shall
be documented and retained [10 CFR 835.701(a) and
835.704(b)]. Administrative controls discussed in this Guide
should include the systematic generation and retention of
those auditable records and reports that document major
actions considered or taken to attain and maintain
occupational doses and the spread of radioactive
contamination ALARA. The RCS and Chapter 13 provide detailed
guidance on record-keeping.
All documents and legal records used to demonstrate
compliance with ALARA program requirements should be
reviewed and approved by supervisory or line management.
5.0 INTERNAL DOSIMETRY PROGRAM
In the 2007 amendment to 10 CFR 835 DOE changed most of the
dosimetric terms used in 10 CFR 835 to reflect the
recommendations for assessing dose and associated
terminology from ICRP Publication 60, 1990 Recommendations
of the ICRP on Radiological Protection (ICRP 1991), and ICRP
Publication 68, Dose Coefficients for Intakes of
Radionuclides by Workers (ICRP 1995). DOE made this change
mainly because these recommendations are based on updated
scientific models and more accurately reflect the
occupational doses to workers than the models currently used
by DOE.
During the rulemaking process DOE received a comment that,
under certain circumstances, when an individual conducts
multiple activities involving both activities under 10 CFR
835.1(b)(1) and excluded activities (e.g., activities
involving NRC licensed activities) it is ambiguous as to how
the rule would be applied when using different dose
coefficients and weighting factors to calculate the total
effective dose for the worker from both activities. DOE
agreed that guidance was needed for this provision. In the
preamble for the final rule DOE stated that for the purpose
of compliance with 10 CFR 835.1(b)(1) and (c), DOE considers
the following terms to be equivalent:
Dosimetric Term as Defined by
Excluded Activity Cognizant Regulator DOE Amended Dosimetric Term
Committed effective dose equivalent Committed effective dose
Committed dose equivalent Committed equivalent dose
Cumulative total effective dose equivalent Cumulative total effective dose
Deep dose equivalent Equivalent dose to the whole body
Dose equivalent Equivalent dose
Effective dose equivalent Effective dose
Lens of the eye dose equivalent Equivalent dose to the lens of the eye
Quality factor Radiation weighting factor
Shallow dose equivalent Equivalent dose to the skin or Equivalent dose to any extremity
Weighting factor Tissue weighting factor
Total effective dose equivalent Total effective dose
Accordingly, for the purpose of compliance with the
requirement in 10 CFR 835.1(c) for the inclusion of doses
from excluded activities in determining compliance with the
limits, DOE considers it acceptable to sum the equivalent
dosimetric terms (per the above table) without further
adjustment. DOE recognizes that, for some situations, such
as evaluation of uranium intakes, this approach will
overestimate radiation doses from excluded activities as
compared to those assessed using ICRP 60 values. For other
situations, such as the evaluation of certain neutron
exposures or for intakes of selected radionuclides, this
approach may underestimate radiation doses from excluded
activities as compared to those assessed using ICRP 60
values.
In cases where doses from excluded activities are expected
to have been over estimated, no additional activities above
the standard radiological controls are required because this
dose estimate is unlikely to have resulted in a dose less
than that estimated using ICRP 60 methods.
Regarding cases where doses from excluded activities are
expected to have been underestimated, a review of doses over
the past several recent y