Department of Energy (DOE) Radiological Control Manual

Chapter 1 - Excellence in Radiological Control

Part 2 - Leadership in Radiological Control

Table of Contents (Articles 12x)

• Forward
• 121 Senior Management Commitment
• 122 Worker Attitude
• 123 Worker Responsibilities
• 124 Radiation and Risk Communications
• 125 Conduct of Radiological Operations
• 126 Improving Worker Awareness of Radiological Conditions
• 127 Critiques
• 128 Facility Modifications and Radiological Design Considerations

Forward

Superior, consistent performance is achieved when qualified personnel use approved procedures and management actively monitors the workplace and assesses ongoing activities. Such activities include, but are not limited to, operations, remediation, laboratory work, research and development and cleanup. Constant review and informed interest by senior management is required to achieve a superior Radiological Control Program. Management leads by example. What management does speaks louder than what management says. Management at all levels should emphasize the need for high standards for radiological control through direct communication, instruction and inspection of the work space. The DOE Operations Office Manager and the contractor senior site executive responsible for the site should have a basic knowledge of radiation, its effects and radiological control requirements. The DOE Operations Office Manager and the contractor senior site executive should also be familiar with the current radiological performance record. Key principles common in a successful, well-managed Radiological Control Program are provided in this Chapter.

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Article 121 - Senior Management Commitment

1. Senior managers should establish high standards for the performance of radiological control. These standards and management expectations should be frequently communicated to the work force.

2. Senior managers should state in writing their firm commitment to a Radiological Control Program of the highest quality. Management commitment and support are demonstrated by allocating sufficient resources including personnel and providing for training to ensure workers are qualified for their assigned duties.

3. Managers should ensure that orientation, training and indoctrination reinforce rules and guidelines for each worker to minimize radiation exposure and control radiological conditions, such as contamination.

4. Managers should hold workers and their supervisors accountable for radiological control performance. Relevant knowledge and performance should be assessed as a specific part of each person's performance evaluation. This assessment should not be limited to those who perform radioactive work, since many other workers have an impact on the Radiological Control Program.

5. Senior managers should solicit feedback from their radiological control professionals, line management and workers on radiological control performance.

6. Senior managers should adopt and promote a positive attitude toward radiological control that encourages initiatives to identify concerns at an early stage, to prevent problems from deteriorating and to promote doing the right job correctly the first time.

7. Prevention of the spread of radioactivity is less costly than remediation. Management should be willing to accept change that will improve radiological control and should foster this mindset throughout the organization.

8. Senior managers shall require and approve radiological improvement goals. Goals should be measurable, realistic, auditable and challenging. Established goals should not be changed without technical justification and senior management approval. Senior management shall review progress toward the goals at least quarterly.

9. A performance indicator program for measuring and trending the effectiveness of the Radiological Control Program against predetermined goals should be established and maintained.

10. The authority and responsibility to establish a comprehensive and effective radiological control training program should be assigned to line managers and their subordinates. Training, in most cases, should be provided by a dedicated training organization, but the responsibility for quality and effectiveness rests with line management.

11. Senior managers should be alert to opportunities for minimizing the generation of radiological waste and discharges to the environment, controlling contamination at its source and reducing radiation exposure to workers and the public.

12. Reporting a problem to a superior (contractor or DOE) does not absolve the manager from promptly fixing or mitigating a situation.

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Article 122 - Worker Attitude

Minimizing worker radiation exposure can be achieved only if all persons involved in radiological activities have an understanding of and the proper respect for radiation.

1. Each worker should understand that proper radiological control is an integral part of their daily duties.

2. Improving the attitude of the work force should be supported by the training program. To achieve this, training personnel need to be knowledgeable about the work environment and those aspects of radiological control that are important to developing a better worker attitude and perspective.

3. The attitude that constant improvement is required in radiological work needs to be developed at all levels of management and in the work force. Cooperation between the work force and the Radiological Control Organization has to be developed and fostered. The workers should not look upon radiological controls as hurdles or restrictions to be bypassed.

4. Radiological Control Organization personnel should be helpful in showing workers how to follow the rules. This spirit of cooperation needs to be developed without subverting the control functions of the Radiological Control Technicians. A situation in which radiological controls are left solely to the Radiological Control Organization is unacceptable.

Article 123 - Worker Responsibilities

Trained personnel should recognize that their actions directly affect contamination control, personnel radiation exposure and the overall radiological environment associated with their work. The following radiological control rules are applicable to each person in the workplace. A poster that displays the worker responsibilities listed below should be produced and displayed at appropriate access points and work areas.

TO MINIMIZE YOUR RADIATION EXPOSURE AND CONTROL RADIOACTIVE MATERIAL, OBSERVE THE FOLLOWING RULES:

OBEY

• Posted, written and oral radiological control instructions and procedures, including instructions on Radiological Work Permits.

• "Evacuate" and "stop work" orders from radiological control personnel promptly.

DO NOT

• Loiter in radiation areas.

• Smoke, eat, drink or chew in Contamination Areas, High Contamination Areas and Airborne Radioactivity Areas.

BE SURE TO

• Wear personnel monitoring devices where required by Radiological Work Permits, signs, procedures or by radiological control personnel. Report immediately the loss, damage or unexpected exposure of personnel monitoring devices or off-scale readings of self- reading dosimeters to the Radiological Control Organization.

• Keep track of your radiation exposure status and avoid exceeding radiological Administrative Control Levels.

• Wear Personal Protective Equipment and Clothing properly whenever required by Radiological Work Permits or postings.

• Minimize the spread of potential radioactive spills and promptly notify the appropriate personnel of all spills.

• Avoid contact of skin, clothing and equipment with contaminated surfaces.

• Place contaminated tools, equipment and solid waste items on disposable surfaces, such as plastic sheets, when not in use.

• Notify radiological control personnel of alarming or faulty radiological control equipment.

• Notify radiological control personnel of off-site occupational radiation exposures so that worker dosimetry records can be updated.

PRIOR TO ENTERING AREA

1. Assure that you are mentally alert and in physically sound condition.

2. Limit the amount of material taken into contaminated areas to minimize radioactive waste and future decontamination.

3. Have necessary materials and equipment on hand to complete your task, thereby minimizing time and exposure.

4. Notify radiological control personnel of the presence of open wounds, sores or rashes before entering an area where contamination exists and exit immediately if a wound occurs while in such an area.

UPON LEAVING AREA

1. Properly remove Personal Protective Equipment and Clothing to minimize the spread of contamination.

2. Frisk or be frisked for contamination when entering an uncontaminated area after exiting posted Contamination, High Contamination or Airborne Radioactivity Areas and associated Radiological Buffer Areas and notify radiological control personnel when contamination is found.

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Article 124 - Radiation and Risk Communications

Due to the continuing concerns of many people related to low radiation exposure and health impacts, managers should be trained to deal with the perception of personnel concerning radiation risks. Managers and first-line supervisors should be sensitive to the fact that workers have to understand the fundamentals of radiation, its risks and their role in minimizing exposure. It is not sufficient to rely solely on regulatory limits for establishing or defining acceptable work practices and work environments.

1. Appropriate personnel should receive training which is helpful in their dealing with workers who have anxiety about radiation. This training should include the following:

2. Guidance on handling such personnel interactions
3. Emphasis on being factual
4. Fundamentals of communicating risks
5. Importance of keeping management informed.

• Some personnel, such as those who may have internal deposition of radionuclides from prior years, are concerned about future exposures. Such instances warrant special attention on the part of the manager. Counseling with such personnel should be the preferred way to consider relevant factors. In some cases Special Control Levels (Article 216) should be applied.

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Article 125 - Conduct of Radiological Operations

1. This Manual is consistent with the guidance in DOE 5480.19, "Conduct of Operations Requirements for DOE Facilities." The concepts of all chapters of DOE 5480.19 apply to the conduct of radiological control.

2. Managers at all levels are expected to be involved in the planning, scheduling and conduct of radiological work. Assurance of adequate radiological safety should not be compromised to achieve production, remediation or research objectives.

3. Supervisors should be technically knowledgeable and inquisitive and should ask questions of the work force concerning radiological work details to verify worker comprehension.

4. Line managers should periodically monitor work areas to observe personnel at work and to identify radiological deficiencies and concerns. Frequent inspections and walk- throughs, including off-hours and weekends (where appropriate), are essential to reinforce management expectations to the work force.

5. Managers, supervisors and workers should be involved in the development of accurate, clear, written procedures for performing radiological work. If during the use of procedures a written requirement cannot be responsibly followed, the work should be stopped and guidance obtained.

6. Supervisors and managers should encourage the work force to identify radiological control deficiencies and concerns. Prompt action should be taken to address and eliminate identified issues and prevent recurrence. Retraining, indoctrination and procedure review are useful in addressing these issues.

7. Managers and supervisors should establish working conditions that encourage improved radiological control. This includes temperature, humidity and lighting as well as the more difficult considerations of accessibility. Work conditions should be considered in planning work.

8. Cleanliness and good housekeeping are essential. A good Radiological Control Program cannot exist in a sloppy, dirty workplace. Cleaning up after operations should be automatic for each person. It is not reasonable to expect radiological control to be separated from the work environment; they go together.

9. Subcontractors and subcontracted employees should be treated the same as facility staff in the area of radiological matters, should have comparable training and shall meet the same requirements and expectations.

10. Conditions that could cause or promote the spread of contamination, such as a leaking roof or piping, should be identified and corrected on a priority basis.

Article 126 - Improving Worker Awareness of Radiological Conditions

In performing assigned duties within radiological areas, workers should be familiar with the area radiological conditions and be aware of the possibility that changes may occur due to unforeseen reasons. Although the conduct of radiological surveys is viewed as a traditional role of Radiological Control Technicians, experience has shown that properly trained and qualified workers are capable of performing supplemental radiological surveys in the course of work. This process results in exposure savings and improved contamination control.

Specific examples of surveys that may be effectively performed by workers and result in exposure reductions include self-monitoring of dose rates during High Radiation Area entries and the monitoring of tools and equipment for contamination as a qualitative check during work in Contamination Areas. The performance of legal record surveys such as release surveys remains the responsibility of the Radiological Control Organization.

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Article 127 - Critiques

It is the Department's desire and expectation, based on concern for the safety and well-being of workers and the general public, that radiological work practices be continually scrutinized and questioned so that opportunities for improvement can be identified, assessed and applied.

A formal critique process should be established to obtain pertinent facts following an unusual radiological situation or at the satisfactory conclusion of a new or unusual operation involving radiological controls. This process complements the Occurrence Reporting and Processing System (ORPS) of DOE 5000.3B. The process should be used to quickly establish facts in chronological order so that the underlying reasons or causes for the success or failure are well understood. Work force participation should be encouraged. Critiques are a management tool and should not be used to "fix blame" or "shoot the messenger."

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Article 128 - Facility Modifications and Radiological Design Considerations

1. Radiological control performance is affected by human performance and engineered design features. This Manual primarily addresses the way people operate and use existing facilities and sites. General design criteria for new facilities and major modifications to existing facilities are contained in 10 CFR 835 and DOE Order 6430.1A. In addition, the following radiological control design criteria are provided for new facilities and major modifications to existing facilities:

2. Individual worker dose shall be ALARA and should be less than 500 mrem per year
3. Discharges of radioactive liquid to the environment are covered by the provisions of DOE 5400.5 and should not degrade the groundwater
4. Control of contamination should be achieved by containment of radioactive material
5. Efficiency of maintenance, decontamination, operations, and decommissioning shall be maximized
6. Components should be selected to minimize the buildup of radioactivity
7. Support facilities shall be provided for donning and removal of protective clothing and for personnel monitoring, when required
8. Neutron quality factor of 20 for conditions of unknown spectra (or doubling of the neutron quality factor associated with known neutron energies) should be used for design purposes. Design analyses based on these neutron quality factors are intended to be used to estimate the additional construction cost that would result if the neutron quality factor was increased. The results of these analyses should be used to ascertain the economic feasibility for incorporating such modifications in the final design.

• Facilities currently under construction should be evaluated and the above criteria applied where practicable.

• Existing facility designs that have office space and lunchrooms or eating areas within Radiation Areas, High and Very High Radiation Areas, Contamination and High Contamination Areas, Airborne Radioactivity Areas, Radioactive Material Areas and Radiological Buffer Areas require priority attention. Generally:

• Locating lunch rooms or eating areas, restrooms, drinking fountains, showers and similar facilities and devices is strongly discouraged within these areas
• Locating office spaces within these areas is strongly discouraged; to the extent that such space is essential to support radiological work, steps should be taken to preclude unnecessary occupancy. Return to Chapter 1, Part 2 Table of Contents