Administrative Controls - doe-std-1136-20040048

DOE-STD-1136-2004

Guide of Good Practices for Occupational Radiological Protection in Uranium Facilities

Although 10 CFR 835.101 requires that DOE activities be conducted in compliance with a

documented RPP, the rule does not establish specific requirements for RPP format and content. Due to

the wide range of activities undertaken by and for DOE, there is significant flexibility in these provisions.

Cognizant DOE line management determines the acceptable format and content of the documented RPP.

However, the documented RPP shall address each requirement of 10 CFR 835 and shall be approved by

DOE (10 CFR835.101). Any changes that decrease the effectiveness of the RPP shall be approved by

DOE before implementation (10 CFR835.101).

Internal audits of the RPP, including examination of program content and implementation, shall

be conducted through a process that ensures all functional elements are reviewed no less frequently that

every 36 months (10 CFR 835.102). An effective quality assurance program for radiation protection

should include establishment of appropriate standards of performance for essential activities and

equipment, with an effective system of documentation and traceability of those activit ies and of the use of

the equipment. Proper maintenance of those records will be necessary for reference purposes. Additional

requirements and guidance are provided in 10 CFR 830, Nuclear Safety Requirements (DOE 2001d),

DOE O 414.1B (DOE 2004), Quality Assurance, and their associated guides. Specific guidance

applicable to RPPs is provided in DOE G 441.1-1A.

3.2.1.1 Administrative Controls

In any facility that handles radioactive materials, the major controls protecting workers, the public,

and the environment are physical design features, such as structures and installed equipment, that shield,

contain, and confine the radioactive materials. However, to allow useful work to be performed in the

facility and to ensure that its protective features remain effective, a number of administrative controls are

ordinarily required. These controls are usually described in and implemented through a series of policy

statements and procedures related to the operations and maintenance activities to be carried out in the

facility. All personnel who work in controlled areas should be familiar with the administrative controls that

apply to their work. Changes or additions to administrative controls should be effectively communicated to

all persons who may be affected.

Radiation Protection Procedures

A uranium facility should have a written policy on radiation protection, including a policy on

keeping exposures ALARA.

To ensure facility activities are executed safely and in a manner that consistently meets

management expectations, documented procedures should provide detailed instructions for implementing

various functional elements of the RPP. Written procedures shall be developed and implemented as

necessary to ensure compliance with 10 CFR 835, commensurate with the radiological hazards created by

the activity and consistent with the education, training, and skills of the individuals exposed to those

hazards (10 CFR 835.104). Responsibilities and actions required of management and workers should be

clearly and unambiguously stated. It is not necessary for written procedures to be developed and

implemented for all of the requirements of 10 CFR 835. Written procedures should be developed and

employed under the following circumstances:

Worker health and safety are directly affected;

the expected outcome for the process or operation requires that a specific method be

followed;

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