Radiation Protection: Occupational Radiation Protection Program

Draft 12/20/2006

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

• Review the manuals of practice and selected records that define the procedures and interactions required for the radiation protection area at the facility or activity level.
• Assess the adequacy of the documents to meet the CRADS and determine that the radiation protection area is effectively integrated into the facility or activity procedures.
• Review any lessons learned to determine if lessons learned have been effectively used within the radiation protection area.
• Review training records of personnel in the radiation protection area to determine that they meet competency standards.
• Review the manuals of practice and selected records that define the procedures and interactions required for radiation protection program at the facility or activity level. The review will also consider the adequacy of the sites documents to meet the CRAD and to determine that the radiation protection is effectively integrated into facility or activity hazards analysis and conduct of operations.
• Review any lessons learned, occurrence reports, DOELAP assessments, or NTS reports that may provide an opportunity to determine if lessons learned have been effectively used, and corrective actions implemented, within the radiation protection area.
• Review position descriptions, training records, and qualification standards of personnel in the radiation protection area to determine that they meet competency standards.
• Review the following documents prior to the assessors arriving on-site, to the extent possible.
  • Radiation Protection Program
  • Radiation Protection Operating Procedures and Technical Basis Documents
  • Work Request/Work Order Process
  • RWPs
  • Conduct of Operations Documentation and Procedures
  • Work Scheduling Procedures
  • Training Plans/Qualification Matrices
  • Functional Position Descriptions
  • ES&H and Line Manager Performance Appraisal Elements
  • Craft Qualifications for Operators
  • Qualifications Program and Examples for Radiation Protection Technical Staff
  • Lessons Learned Program Documentation
  • ALARA Reviews
  • ESH Contract Clause, Annual Goals, and Award Fee Determinations
  • Performance Indicator, Trending, and Goals System
  • Site ES&H Budget and Program Plans
  • Site Radiological Control Manual
  • Radiation Exposure Assessment Procedures, Reports, Databases
  • Internal and external Radiation Protection Program Audit Reports and Findings Closure

Performance Objective 2: Operating Contractor's Program Implementation

Lines of Inquiry

• TBD

Performance Objective 3: DOE Oversight

• Interview personnel, responsible DOE, and contractor managers in the radiation protection area assigned.
• Interview line managers to assess; management commitment, the establishment of accountability, clear roles, responsibilities, and the level support provided to mitigate exposures and health hazards to workers.
• Interview personnel assigned to the radiation protection area to assess depth and scope of practice, and the level of competence.

General example of questions for interviews:

• Facility Reps
  • What rad con training - experience do you have?
  • What aspects of rad con do you review?
  • How do you review these areas?
  • How are observations/concerns noted and resolved?
• Rad Con Specialists
  • What aspects of rad con do you review?
  • How do you review these areas?
  • What planning activities do you review (procedures, permits)?
  • Do you bring in outside reviews periodically?
  • What review do you do of the contractor audits?
  • How are observations/concerns noted and resolved?
• Managers
  • How often do you do walkdowns?
  • What do you look for?
  • What are ongoing issues?
  • How are observations/concerns noted and resolved?
• Field work managers
  • Who does rad con oversight?
  • How is it done?
  • What are ongoing issues?
  • How are observations/concerns noted and resolved?

In addition, the Office of Health developed lines of inquiry for assessing compliance with 10 CFR 835. These may be found at: http://www.hss.energy.gov/healthsafety/wshp/radiation/rule.html

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