Administrative Systems

DOE-HDBK-1184-2004

6.2.1

Administrative Systems

An adequate structure of administrative systems is necessary to ensure that

projects are completed safely, satisfactorily, and in compliance with applicable

requirements. The actual components of the administrative systems, and the

content of those systems, is dependent on a number of factors, including the nature

of the work to be performed, education, skills and training of the individuals

performing the work, and the magnitude of any associated hazards. Management

oversight is required to achieve the appropriate balance between the various

components of the administrative systems. For example, certain high-hazard work

may require extensive pre-job planning and rigid adherence to detailed written

procedures and radiological work permits (RWPs). For lower hazard work, or more

routine and repetitive work, it may be appropriate to place more reliance on

employee training and experience. The appropriateness of the balance achieved

should be routinely assured through a rigid system of management oversight that

closely examines the work processes , and detects potential problems before they

adversely affect safety and achievement of the facility's mission.

10 CFR 835.501 requires written authorizations to enter into and perform work in

radiological areas. While there is a great deal of flexibility provided for establishing

the exact nature of and details provided in these authorizations, they generally fall

into one or more of the classifications discussed below.

Policies and Procedures

Facility requirements for safe work with STCs should be clearly delineated in written

policies and procedures. These requirements may be established in either

generally applicable procedures, or in procedures that are established and limited in

scope to address STC affected areas and topics only. For example, requirements

for controlling access to STC-contaminated areas may be specified in procedures

that apply only to the specified areas, or the requirements may be established as a

sub-section of a generally applicable procedure that addresses control of access to

a wide variety of hazardous areas. Likewise, there need not be a separate ALARA

policy addressing only exposure to STCs if the existing ALARA policy adequately

addresses all radiation exposures, including STC exposure.

In addition to any procedures that may be implemented to ensure compliance with

10 CFR 835.501, 10 CFR 835.104 requires that written procedures be developed

and implemented as necessary to ensure compliance with the applicable regulatory

requirements of that rule. The procedures should be written in sufficient detail to

ensure that the user is able to complete the relevant task properly, and in

compliance with applicable requirements. The style of writing should be

appropriate to the assigned procedure user.