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ES&H
Manual Radiation Control Supplement |
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Chapter 1 – Excellence in Radiological Control |
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100
Radiation
Control Department
Mission Statement
The Radiation Control Department (RCD) supports the
Laboratory mission by protecting workers and the surrounding public and environment
from unnecessary ionizing
radiation exposure
resulting from Jefferson Lab operations.
110
Mission
Implementation Strategy
Jefferson Lab, operated for the Department of
Energy by Jefferson Science Associates, LLC (JSA), is committed to having a
high quality radiation protection program.
The program is carried out using sound industry practice in a
cost-effective manner. The Standard of
Care will be the applicable regulations
and orders (e.g., 10
CFR 835), and As Low As
Reasonably Achievable (ALARA) will be the guiding principle. The ALARA process includes consideration,
planning, and implementation of both physical design features (engineered and
administrative controls) to balance the risks of occupational radiation
exposure against the benefits arising from the work activity. The process incorporates training, workplace
monitoring, radiation
work controls, radioactive
materials control, and environmental
monitoring. Radiation Control
(RadCon) professional and technical staff, assisted in certain routine
activities by other specially trained lab staff, implement the program. The RDC makes recommendations to line
management on radiation safety, conducts radiation surveys, directly monitors
personnel and radiation related work activities, evaluates the effectiveness of
controls and processes, and ensures that the program is conducted in accordance
with all applicable legal requirements.
111
Radiological Control Policy
Jefferson
Lab makes the following policy statements in support of its radiological
control program and applicable legal requirements:
111-01)
JSA/Jefferson Lab management is responsible for compliance with
the requirements of 10
CFR 835 and implementation of related programs, plans
and schedules [§835.3(b)].
111-02)
No employee or contractor of
JSA/Jefferson Lab, any Department of Energy (DOE) employee, or other person
shall take or cause to be taken any action inconsistent with the requirements
of 10 CFR 835 or any related program, plan, schedule, or other process
established or required by 10 CFR 835 [§835.3(a)(1),
(2)].
111-03)
Nothing in this document or any part of 10 CFR 835 shall be construed as limiting actions that may be necessary to protect
health and safety [§835.3(d)].
111-04)
Radiation dose shall not exceed the statutory limits established
in 10 CFR 835
111-05)
Measures
shall be taken to maintain exposure to ionizing
radiation ALARA, taking into account
the net benefit obtained as a result of the exposure. There should not be any occupational radiation exposure of workers to ionizing
radiation without the expectation of an overall benefit
from the activity causing the exposure. This policy is applied to personnel and
environmental radiation protection.
111-06)
Jefferson Lab has established
action levels and design goals consistent with ALARA. Action levels (also called Administrative
Control Levels) are established below the statutory limits in regulations and
orders to control and minimize individual and collective dose. No planned activity shall cause an individual
to exceed an action level without written consent of the Laboratory Director. Design goals were utilized in the design of
Jefferson Lab and are used in any subsequent modification or new
construction. They are lower than action
levels and are intended to provide assurance that ALARA is included in the basic design and operation. Design goals include considerations for:
a)
maintaining individual worker dose less
than 250 mrem (0.25 rem) per year (implemented
through the exposure Alert system),
b)
preventing degradation of groundwater quality,
c)
controlling contamination by
engineered means where possible, and
d)
minimizing the generation of radioactive material.
111-07) The Jefferson Lab Radiation Review Panel (JRRP) serves as an ALARA Committee. The membership includes managers and workers from the scientific and technical Divisions and Departments and the RCD. The Jefferson Lab Radiation Review Panel Charter is found in the Jefferson Lab Environmental, Safety, and Health (ES&H) Manual Chapter 2240 ES&H Committees. The JRRP makes recommendations to management to improve processes in minimizing radiation exposure and preventing radiological releases. This committee may evaluate items such as construction, design, and modification of laboratory facilities and systems and planned major modifications or work activities.
112
Manual Use for
Statutory Compliance and Sound Industry Practice
This ES&H Manual Radiation Control Supplement (RadCon Manual) establishes practices for the conduct of radiological control activities at Jefferson Lab. Jefferson Lab’s Radiation Protection Program (RPP) is based on the required elements of 10 CFR 835 and is implemented through various elements of this manual and other documented measures identified in the RPP [§835.101(a)]. The Radiation Control Department ensures that radiation control activities are conducted in accord with this RPP as approved by the DOE. The content of Jefferson Lab’s RPP is commensurate with the nature of the activities performed and includes formal plans and measures for applying the ALARA process to occupational exposure and for implementing the requirements of 10 CFR 835 [§835.101(c)].
The word “shall” identifies those elements considered to be mandatory due to statutory requirements or laboratory policy. The Radiation Control Manager (RCM), as defined in Radiation Control Supplement Chapter 1 Excellence in Radiological Control Part 4 Radiation Control Group, may authorize exceptions to laboratory policy if an acceptable alternative approach is obtained without decreasing the effectiveness of the approved RPP. Proposed changes that decrease the effectiveness of the RPP shall not be implemented until they have been submitted to and approved by DOE.
The word “should” means that the provision is a proven practice that supports compliance with the basic requirements found in applicable regulations or DOE Orders or their underlying basis documents for occupational radiation protection. The use of “should” recognizes that: 1) there may be site- or facility-specific attributes that warrant special treatment; 2) the safety benefit derived from implementation of the provision may not in all cases be commensurate with the associated detriments (e.g., financial cost, worker discomfort, schedule conflicts, etc.); and 3) literal compliance with the provision may not achieve the desired level of radiological performance.
This manual is also intended to
be consistent with other relevant statutory and regulatory requirements and is
revised whenever necessary to help maintain consistency. Terms defined in the Atomic Energy Act of
1954 or in 10 CFR 820 and not defined in 10 CFR 835 are used consistent with
the meanings given in the Atomic Energy Act of 1954 or in 10 CFR 820. The content of the RPP shall address, but
shall not necessarily be limited to, each requirement in 10 CFR 835 [§835.101(e)]. The manual incorporates other requirements
and recommendations based on generally accepted sound industry practices for
the conduct of radiological controls.
The provisions in the manual should be viewed by Jefferson Lab personnel
as an acceptable technique, method or solution for fulfilling their duties and
responsibilities. This manual is
applicable to the conduct of all radiological operations at Jefferson Lab,
including subcontracted operations on-site.
DOE employees at Jefferson Lab are subject to and shall adhere to the
provisions of this manual.
For
those activities that are required by §§835.102, 835.901(e), 835.1202 (a), and
835.1202(b), the time interval to conduct these activities may be extended by a
period not to exceed 30 days to accommodate scheduling needs [§835.3(e)].
Changes to
this RadCon Manual may occur from time to time.
Jefferson Lab promotes active communication with similar research
laboratories and attempts to ensure that “lessons learned” are incorporated
into the manual and into routine practice.
Recommendations for change related to statutory requirements shall be
submitted to the Laboratory Director for concurrence before incorporation into
the manual. Changes in statutory
requirements shall not be implemented until an update of the Jefferson Lab RPP
and related parts of the manual are approved by DOE as required by 10
CFR 835. The DOE may
direct or make modifications to an RPP [§835.101(b)]. Changes, additions, or
updates to the RPP may 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 10 CFR 835. Proposed changes that decrease the effectiveness
of the RPP shall not be implemented until they have been submitted to and
approved by DOE [§835.101(h)].
The RPP shall
include plans, schedules, and other measures for achieving compliance with 10
CFR 835 [§835.101(f)]. An initial RPP or an update shall be
considered approved 180 days after its submittal unless rejected by DOE at an
earlier date [§835.101(i)]. Unless rejected or otherwise specified in 10
CFR 835, compliance with the amendments to 10 CFR 835 published on June 8, 2007
shall be achieved no later than July 8, 2010.
An update of the RPP shall be submitted to DOE whenever a change or
addition to the RPP is made and prior to the initiation of a task not within
the scope of the RPP or within 180 days of the effective date of any modification
to 10 CFR 835 [§835.101(d), (g)(1), (g)(2), (g)(3)].
This
is a controlled document and shall be kept current. Note that the RPP is a separate entity from
the manual; various sections of the manual serve as evidence and means of
implementation of the RPP.
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Part 2
Radiological Controls and Responsibilities in the Laboratory Organization |
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A successful RadCon program can be achieved when qualified personnel use approved procedures and management actively monitors the workplace and assesses ongoing activities. Regular review and informed interest by line management is necessary to ensure a successful radiological control program. Management is responsible for ensuring adequate implementation of the radiological control program. Management at all levels should emphasize by involvement the need for high standards for radiological control through planning, instructions and communication, and regular inspection of the workspace. Key principles for ensuring a well-managed RadCon program are provided in this Chapter. As a guiding principle for Integrated Safety Management (ISM), managers at all levels are expected to be involved in the planning, scheduling and conduct of radiological work to ensure effective ISM and ALARA processes.
Assurance of adequate radiological safety shall not be compromised to achieve research objectives. Rather, a successful research program promotes radiological safety and supports the ALARA process.
121
Laboratory
Senior Management Roles and Responsibilities
121-01) The Laboratory Director approves overall goals for radiation protection at the Lab and monitors the overall radiological performance by external peer reviews, self and independent assessments, and by written or verbal communication with the Radiological Control Manager (RCM). The Director shall ensure that the application of statutory and laboratory practice in radiological controls is not impeded by conflicts of interest and should concur in any job performance rating given to the RCM.
121-02) The Environment, Safety, Health and Quality Associate Director (ESH&Q AD) shall ensure that adequate resources are available to meet all laboratory-wide statutory radiological control requirements, such as Radiation Worker Training and environmental permits. The ESH&Q AD should establish realistic, challenging, measurable goals and objectives for the performance of radiological control activities. Performance on these goals should be reviewed at least annually. Each Division Manager/Associate Director shall ensure that sufficient resources are allocated, including personnel, and workers are properly trained and qualified for radiological controls associated with their assigned duties.
121-03) The ESH&Q AD is responsible for immediate oversight of Radiation Control Department activities. This manager shall ensure that adequate resources and authority exist to specify radiation controls and to monitor work throughout the Laboratory.
121-04) The ESH&Q AD should ensure that opportunities for minimizing the generation of radioactive waste and discharges to the environment, controlling contamination at its source, and reducing radiation exposure to workers and the public are incorporated into laboratory work practices.
121-05) Line managers and their subordinates are responsible for ensuring that laboratory staff has received appropriate radiological control training. Training, in most cases, will be provided by the RCD, but the responsibility for effective translation to work practice rests with line management.
121-06) Managers and first-line supervisors should be sensitive to the fact that workers perform radiological duties and ensure that the workers 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. Managers should refer individuals who are concerned about radiation exposure to the ESH&Q AD or the RCM.
121-07) Line managers should solicit feedback from radiological control professionals, line supervisors, and workers on radiological control performance, and 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, as applicable.
121-08) Supervisors should be involved in the scheduling and conduct of radiological work, and also ensure that workers understand the controls associated with the radiological work that they are to perform.
121-09) Line managers should periodically monitor work areas to observe personnel at work and to identify radiological deficiencies and concerns.
121-010) 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.
121-011) Managers and supervisors should establish working conditions that encourage improved radiological control. Work conditions such as temperature, humidity, lighting, and accessibility should be considered in planning work. Cleanliness and good housekeeping are essential to a good radiological control program.
121-012) Subcontractors, subcontracted employees, and Physics users (or other members of the scientific community utilizing Jefferson Lab facilities) 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.
122
Laboratory
Worker Roles and Responsibilities
Minimizing worker radiation exposure requires that all persons involved in radiological activities have an understanding of radiation hazards and mitigating measures.
122-01) Each worker should understand the radiation control aspects of his or her daily duties and integrate proper radiological controls into those duties.
122-02) Cooperation between the work force and the RCD has to be developed and fostered. Workers should not look upon radiological controls as hurdles or restrictions to be bypassed. Concerns regarding radiological controls that appear to be overly restrictive or too lax should be immediately brought to the attention of line management for review by the RCD.
122-03) A situation in which radiological controls are left solely to the RCD is unacceptable. Line managers are ultimately responsible for ensuring that radiological controls are properly implemented and radiation exposures are maintained ALARA. RCD personnel should be helpful in showing workers how to keep their exposures ALARA. This spirit of cooperation, however, should be developed without subverting the control functions of the Radiological Control Technologists (RCTs).
123
Enhanced
Worker Training and Increased Awareness of Radiological Conditions
In performing assigned duties within radiological areas, workers should be familiar with the area’s radiological conditions and be aware of the possibility that unforeseen changes may occur. Although the conduct of radiological surveys is viewed as a traditional role of RCTs, experience has shown that properly trained and qualified workers are capable of performing supplemental radiological surveys in the course of work. Jefferson Lab employs the use of specially trained staff members called Assigned Radiation Monitors (ARMs) to provide supplemental radiological control support. ARM duties include performing surveys in accelerator enclosures and other areas, and review of general conditions for conformance to radiological control requirements. Specific duties and limitations of ARMs’ responsibilities are described in Accelerator Operations Directives, RadCon implementing procedures and work control documents such as RWPs.
The
performance of surveys of complex, first time activities and where a broader
knowledge of survey techniques or legal requirements is necessary, such as
release surveys, remains the responsibility of qualified RCTs. ARMs will not be responsible for surveys or
radiological oversight for work in high radiation areas or contamination areas.
124
Marginal
Radiological Control Performance
121-01) When radiological control performance is less than adequate, consideration should be given to strengthening line management oversight and increased oversight by the RCD.
121-02) In cases where the work force does not have the required level of sensitivity for radiological work practices, additional management attention is needed to assure the proper outcome. Line management will be held accountable for implementation of the radiological control program. Initial remedial actions may include:
a) More direct line supervision in the workspace
b) Curtailment of work schedules
c) Deferral of work
d) Additional radiological control personnel assigned to monitor work
e) Conduct additional training
121-03) When the workers and supervisors achieve the proper level of radiological performance, the number of radiological control personnel and additional control measures should be evaluated and revised to reflect performance.
It is Jefferson Lab management’s desire and expectation, based on concern for the safety and well-being of workers and the general public, that radiological work practices be reviewed so that opportunities for improvement can be incorporated into work practices.
Formal processes are established to obtain pertinent facts following a report of unsafe practices or unusual radiological situations. Causal analysis procedures can be used to quickly establish facts so that the underlying reasons or causes for the success or failure are well understood. Work force participation is encouraged. Critiques are a management tool and should not be used to “fix blame” or to “shoot the messenger.”
Note that the Notable Event reporting process of ES&H Manual Chapter 5200 Appendix T1 Event Investigation and Causal Analysis Procedure using the Notable Event Worksheet should be used to document anomalous radiological conditions (such as unusual or inexplicable radioanalytical results not exceeding a regulatory limit). Violations of regulations, procedures or policy leading to a reduction in radiation safety should be evaluated through the Occurrence Reporting and Processing System (ORPS) of ES&H Manual Chapter 5300 Occurrence Reporting to Department of Energy (DOE) . The Notable Event reporting process can also be used for isolated minor radiological concerns that do not have the potential for a significant reduction in radiation safety.
The Jefferson Lab Radiation Review Panel (JRRP) functions as the organization for critiques dealing with internal radiological control matters. The responsibilities and guidelines for the JRRP are incorporated into the Jefferson Lab ES&H Manual.
A formal review process, such as the Accelerator Readiness Review Process or the Experiment Equipment Review Process, serves to review radiation controls at the beginning of a new or unusual phase of operations or at the satisfactory conclusion of a new or unusual operation involving radiological controls.
131
Radiological
Performance Goals
Goals are intended as a measure of, and a motivation for, improvement, not as an end in themselves. These performance indicators are not to be viewed narrowly as numerical goals. These indicators are used as tools to assist management in focusing their priorities and attention. The following are some examples of the goals that may be appropriate:
131-01) Reducing collective dose (person-rem), based on planned activities and historical performance.
131-02) Minimal personnel contamination or intakes of radioactivity.
131-03) Minimizing the number and total area of contaminated spaces.
131-04) Minimizing the generation of liquid or solid radioactive waste.
131-05) Minimizing the unnecessary storage of activated material.
Other goals may be selected as the scope or conduct of operations changes.
132
Metrics
and Management of Radiological Performance Goals
132-01) The ESH&Q AD should establish, approve and review radiological performance goals. These may include those used for contract performance metrics.
132-02) The performance goals should be measurable, achievable, and auditable.
132-03) Radiological performance goals should be reviewed periodically and revised as appropriate.
133
Radiological
Performance Reports
133-01) The Radiation Control Manager should provide a periodic summary report to the Laboratory Director. This report should be made at least annually and should include any pertinent information related to radiological performance goals.
133-02) The Radiation Control Manager should provide appropriate feedback to supervisors and managers on a basis frequent enough to permit management of any associated exposure control. The frequency should be consistent with the nature of the workload and the radiation exposure potential.
133-03) To promote worker awareness of their radiation exposure status, selected indicators related to their work group may be incorporated into technical work documents.
134-01) Internal audits of the radiation protection program shall be conducted such that, over a 36-month period, all functional elements are assessed [§835.102]. The audits should address program performance, applicability, content, and implementation. The audits should be performed by the radiological control organization, the quality assurance organization or other organizations (including subject matter experts from outside the lab) having the requisite knowledge to adequately assess radiological control activities. Based on 10 CFR 835, the following functional elements should be considered for inclusion in the assessment program:
a) Personal dosimetry and dose assessment,
b) Portable and fixed instrumentation,
c) Contamination control,
d) Radiological monitoring (area and item monitoring),
e) ALARA program,
f) Accident and emergency dose controls,
g) Radioactive material control, including sealed radioactive source control and material release,
h) Entry controls,
i) Training,
j) Posting and labeling,
k) Records and reports, and
l) Radiological design and administrative controls.
134-02) An audit should be conducted in accordance with the Laboratory’s Independent Assessment Procedure or Management Self Assessment Procedure, which require an approved assessment plan. The RCD may generate a preliminary plan for use by the auditor.
134-03) The ESH&Q AD and the Radiation Control Manager should approve the audit plan.
134-04) The ESH&Q AD should be made aware of any immediate hazards on the day of any audit and should review the results of the audit within one week. The ESH&Q AD should receive a copy of all audit results. The subject of the audit (group or individual) should prepare a written response within one week addressing the findings of the audit. The Jefferson Lab Radiation Review Panel (JRRP) Chair should be provided the results of internal audits at the next scheduled meeting.
134-05) The internal audits referred to in this section do not preclude, and may be mutually substituted for, other audits (by Jefferson Lab organizations) covering the same operational areas in order to separately satisfy their own organizational requirements.
135 Independent
Verification
Assessments by knowledgeable peer-experts are valuable tools for assessment of the RadCon program. Peer reviews should be used whenever feasible as part of the internal audit program, and are the preferred means for performing independent verification (IV) assessments. Independent verification activities are coordinated through the Thomas Jefferson Site Office (TJSO). These efforts are applicable to assessment of facility decommissioning activities and the processes used for survey and evaluation of material and equipment for release.
141
Radiation Control Department
141-01) The Radiation Control Manager (RCM) heads the RCD and is responsible for administering the Jefferson Lab Radiological Control Program. The RCM reports to the ESH&Q AD. The RCM shall have direct access to the Division Associate Directors and to the Laboratory Director to ensure all radiological controls associated with laboratory operations are properly implemented.
141-02) Radiological control staff are tasked with monitoring adherence to the Jefferson Lab Radiological Control Manual and are available to the facility line management for radiological support to the work force. To ensure independence in making correct radiological decisions, the RCD is directly accountable to the RCM.
142
RCD Functions
and Staffing
142-01) The RCM and/or designee is responsible for developing and implementing measures necessary for compliance with the requirements of 10 CFR 835 and shall have the appropriate education, training, and skills to discharge these responsibilities [§835.103]. The RCM shall be an experienced professional in radiological control and shall be familiar with the design features and operations of the facility that affect the potential for exposures of persons to radiation. Qualifications for the position should include a bachelor’s degree in science or engineering, at least five years of professional experience, and certification by the American Board of Health Physics.
142-02) The senior staff of the Radiation Control Department (RCD) includes health physicists and may include professionals with degrees in physics, science, or engineering. Pursuit of certification by the American Board of Health Physics for senior and professional staff members is encouraged.
142-03) Radiological Control Technologists (RCTs) are support personnel who provide health physics and radiological engineering, dosimetry, independent oversight, instrumentation, and calibration functions. RCTs conduct work planning and radiological surveillance, assist in the implementation of radiological control, perform radiological analyses, and support the environmental monitoring program. RCTs have the responsibility and authority to stop work or mitigate the effect of an activity if they suspect that continued performance of a job or evolution or test will result in the violation of radiological control standards, result in imminent danger or unacceptable risk, or result in the inadvertent release of radioactive material to the environment. This responsibility is in addition to the stop work authority possessed by all Laboratory staff in accordance with the Jefferson Lab ES&H Manual. RCTs should possess a high school degree and some post-secondary education or technical training, such as programs conducted military or specialized training institutions. Pursuit of registry by The National Registry of Radiation Protection Technologists is encouraged.
143
Relationship
Between RCTs and Workers
RCTs
and their supervisors assist and guide workers in the radiological aspects of
the job.
143-01) Radiological workers are sufficiently qualified to recognize the symptoms of deteriorating radiological conditions and to seek advice from their supervisors and from RCTs.
143-02) RCTs and their supervisors have the responsibility and authority to stop radiological work or mitigate the effect of an activity if they suspect that the initiation or continued performance of a job, evolution or test will result in the violation of radiological control standards or result in imminent danger or unacceptable risk. Through his or her supervisor, any worker also has stop work authority in accordance with Article 345.
143-03) The actions or presence of radiological control personnel does not absolve the workers of their responsibility for properly conducting radiological aspects of the job. Radiological control personnel are not present to compensate for poor management of the work force and should not be required to do so. A poorly trained work force should participate in an accelerated training program.
144
Quantities
and Units Used in Radiation Control
Unless otherwise specified, the quantities used in the records required by 10 CFR 835 and in the Radiation Control Program at Jefferson Lab (except as noted below) shall be clearly indicated in special units of curie, rad, roentgen or rem, including multiples and subdivisions of these units or other conventional units such as dpm, dpm/100 cm2 or mass units. The Standard International (SI) units Becquerel (Bq), gray (Gy), and sievert (Sv) may be provided parenthetically for reference with scientific standards. SI units should not be used in records required by DOE for the Radiation Control Program at Jefferson Lab. SI units shall be used whenever required by DOT hazardous materials regulations.
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ISSUING
AUTHORITY |
CHAPTER
AUTHOR |
APPROVAL
DATE |
EFFECTIVE
DATE |
EXPIRATION
DATE |
REV. |
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RadCon Dept |
07/01/10 |
07/01/10 |
07/01/13 |
4 |
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