Administrative Controls cont'd - doe-std-1136-20040049

DOE-STD-1136-2004

Guide of Good Practices for Occupational Radiological Protection in Uranium Facilities

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 should 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. 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. The DOE G 441.1 series of Guides provide

additional guidance regarding specific procedural aspects of the RPP.

All radiation protection procedures and controls should have formal, recognizable technical bases

for limits, methods, and personnel protection standards. Procedures should be adequately documented,

updated periodically, and maintained in a centralized historical file. A control system should be

established to account for all copies and ensure all new procedures are included in the historical files. A

designated period of time for maintaining historical files should be established. ANSI/HPS N13.6, Practice

for Occupational Radiation Exposure Records Systems (ANSI/HPS 1999) provides guidance on

maintain ing historical files. In addition, radiation protection procedures should have a documented

approval system and established intervals for review and/or revision. A tracking system should be

developed to ensure that the required reviews and revisions occur. Guidance for writing procedures can be

found in DOE/NE/SP-0001T, Writer's Guide for Technical Procedures (DOE 1991a).

Management Commitment

Management commitment to safety is the most important characteristic of an effective radiological

control program. If the management commitment to safety is strong, the radiological control program will

be valued and respected. The radiological control program should be provided adequate authority to permit

performance of necessary assignments and program implementation. Management commitment to the

ALARA concept is particularly important (see Article 111 of the RCS). Adequate personnel, equipment,

and funding should be available as a part of this commitment.

Radiological Control Organization

The radiological control organization should be structured so that all of the activities required to

provide support to line management and workers can be accomplished.

Radiological Control Organization Independence and Reporting Level

The radiological control organization should be independent of the line organization responsible

for production, operation, or research activities and should have an equivalent reporting level. Because

radiological control personnel should have the authority to balance operations with safety, they should not

report directly to the administrators of operations. When shift work is involved, the operations shift

supervisor may make minor radiological control decisions in support of the shift's Radiological Control

Technicians (RCTs); however, decisions involving basic policies and procedures should be directed to a

separate radiological control organization.

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