DOE-HDBK-1130-2008 Chg Notice 2, Radiological Worker Training, Appendix A
Functional areas: Radiological Worker, Radiation Protection, Safety, Radiation Training, Radiation Safety
This Handbook describes an implementation process for core training as recommended in chapter 14 to Implementation Guide G441.1-1B , Radiation Protection Programs for Use with Title 10, Code of Federal Regulations, Part 835, Occupational Radiation Protection, and as outlined in the DOE standard, Radiological Control (RCS). The Handbook is meant to assist those individuals within the Department of Energy, Managing and Operating contractors, and Managing and Integrating contractors identified as having responsibility for implementing core training recommended by the RCS. Change Notice 2/Reaffirmed 2013.
Related To:
Version history and related documents
Superseded by
A newer version replaces this document.
- DOE-HDBK-1130-2022Radiological Worker Training (Nov 08, 2022)
Related documents
- DOE-HDBK-1130-2008 Chg Notice 2 (Reaffirmed 2013)Radiological Worker Training (Part 1 of 5, links to all Parts)
- DOE-HDBK-1130-2008 Chg Notice 2Radiological Worker Training, Appendix B
- DOE-HDBK-1130-2008 Chg Notice 2Radiological Worker Training, Appendix C
- DOE-HDBK-1130-2008 Chg Notice 2Radiological Worker Training, Overheads
Document text
Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
NOT MEASUREMENT
SENSITIVE
DOE-HDBK-1130-2008
Appendix A
Change Notice 2
Reaffirmed 2013
DOE HANDBOOK
Radiological Worker Training
Radiological Control Training for Supervisors
U.S. Department of Energy AREA TRNG
Washington, D.C. 20585
DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.
Radiological Worker Training - Appendix A
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
This document is available on the
Department of Energy
Technical Standards Program
Web Site at
http://www.hss.energy.gov/nuclearsafety/techstds/
ii
Radiological Worker Training - Appendix A
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
Foreword
This Handbook describes an implementation process for training as recommended in
Implementation Guide G441.1-1C, Chapter 14, Radiation Safety Training Guide, and as outlined
in DOE-STD-1098-99, DOE Radiological Control (the Radiological Control Standard - RCS).
The Handbook is meant to assist those individuals within the Department of Energy, Managing
and Operating contractors, and Managing and Integrating contractors identified as having
responsibility for implementing training required by Title 10 Code of Federal Regulations Part
835 Occupational Radiation Protection (10 CFR 835) and training recommended by the RCS
(Article 651). This training is intended for line managers who manage, supervise, or provide
oversight of radiological workers and develop and implement measures necessary for ensuring
compliance with 10 CFR 835. This training is not intended to be technical training for
Radiological Control Supervisors (i.e. individuals responsible for supervising radiological control
staff).
While this Handbook addresses many requirements of 10 CFR 835 and recommendations of
the RCS, it must be supplemented with facility-specific information to achieve full compliance.
This Handbook contains recommended training materials consistent with other DOE radiological
safety training materials. The training material consists of the following five parts:
Program Management Material - This part contains detailed information on how to use the
Handbook material.
Instructor’s Material - This part contains lesson plans for instructor use, including notation
of key points for inclusion of facility-specific information and parenthetical recommendations
for teaching points.
Overheads - This part contains overheads for instructor use corresponding to the
Instructor's Material.
Student’s Material - This part contains student handout material and also should be
augmented by facility-specific information.
Handouts - This part contains several student handouts providing supporting information
for various modules.
This training material is targeted for individuals with a basic knowledge of radiological control.
At a minimum, trainees should have completed Radiological Worker II training.
This Handbook was produced in Microsoft Word. Overheads were produced in Powerpoint.
Copies of this Handbook may be obtained from the DOE Radiation Safety Training Home Page
Internet site (http://www.hss.energy.gov/HealthSafety/WSHP/radiation/RST/rstmater.htm) or the
DOE Technical Standards Program Internet site
(http://www.hss.energy.gov/NuclearSafety/techstds/standard/standard.html).
iii
http://www.hss.energy.gov/NuclearSafety/techstds/standard/standard.html
http://www.hss.energy.gov/HealthSafety/WSHP/radiation/RST/rstmater.htm
Radiological Worker Training - Appendix A
Section 2
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
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Part 1 of 5
Radiological Worker Training Appendix A
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
Program Management
Office of Health, Safety and Security
U.S. Department of Energy
Radiological Worker Training Appendix A
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
Program Management
Table of Contents
Page
Introduction, General Training Information
1
Course Specific Program Description
10
Target Audience
11
Prerequisites
11
Instructor Qualifications
11
References and Supporting Documents
12
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Program Management
Introduction
Purpose and Scope
This program management guide provides guidance for proper implementation of additional
standardized training as outlined in the DOE Radiological Control Standard (RCS). The guide is
meant to assist those individuals within the Department of Energy, Managing and Operating
(M&O) contractors, and Managing and Integrating (M&I) contractors identified as having
responsibility for implementing the additional standardized training recommended by the RCS.
Facilities should determine the applicability of this material to support existing programs meant
to comply with the training required by 10 CFR 835. Facilities are encouraged to revise these
materials as appropriate.
Management Content
The management guide is divided into the following sections:
- Introduction
- Instructional Materials Development
- Training Program Standards and Policies
- Course-Specific Information
Core Training Goal
The goal of the additional standardized training program is to provide a standardized, baseline
knowledge for those individuals completing the core training. Standardization of the knowledge
provides personnel with the information necessary to perform their assigned duties at a
predetermined level of expertise. Implementing a standardized training program ensures
consistent and appropriate training of personnel.
Organizational Relationships and Reporting Structure
The DOE Office of Worker Safety and Health Policy (HS-11) is responsible for approving and
maintaining the additional standardized training materials.
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Program Management
The establishment of a comprehensive and effective contractor site radiological safety training
program is the responsibility of line management and their subordinates. The training function
can be performed by a separate training organization, but the responsibility for quality and
effectiveness rests with the line management.
Target Audience
Course instructional materials were developed for specific employees who are responsible for
knowing or using the knowledge or skills for each course. With this in mind, the participant
should never ask the question, “Why do I need to learn this?” However, this question is often
asked when the participant cannot apply the content of the program. It is the responsibility of
management to select and send workers to training who need the content of the program. When
workers can benefit from the course, they can be motivated to learn the content and apply it on
their jobs. Care should be taken to read the course descriptions along with the information about
Section 3
who should attend. Participants and DOE facilities alike will not benefit from workers attending
training programs unsuitable for their needs.
Prerequisites
A background and foundation of knowledge facilitates the trainee in learning new knowledge or
skills. It is much easier to learn new material if it can be connected or associated to what was
previously learned or experienced. Curriculum developers who have been involved in preparing
instructional materials for the core training know this and have established what is referred to as
“prerequisites” for each course.
Certain competencies or experiences of participants were also identified as necessary prior to
participants attending a course. Without these competencies or experiences, the participants
would be at a great disadvantage and could be easily discouraged and possibly fail the course. It
is not fair to the other participants, the unprepared participant, and the instructor to have this
misunderstanding.
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Program Management
Training Material
Training materials for this training program consist of a program management guide, an
instructor’s guide, and a student’s guide. This material is designed to be supplemented with
facility-specific information.
Supplemental material and training aids may be developed to address facility-specific
radiological concerns and to suit individual training styles. References are cited in each lesson
plan and may be used as a resource in preparing facility-specific information and training aids.
Each site is responsible for establishing a method to differentiate the facility-specific information
from the standardized lesson plan material. When additional or facility-specific information is
added to the text of the core lesson plan material, a method should be used to differentiate facility
information from standardized material.
Exemptions
Qualified personnel can be exempted from training if they have satisfactorily completed training
programs (i.e., facility, college or university, military, or vendor programs) comparable in
instructional objectives, content, and performance criteria. Documentation of the applicable and
exempted portions of training should be maintained.
Qualification of Instructors
The technical instructor plays a key role in the safe and efficient operation of DOE facilities.
Workers must be well qualified and have a thorough understanding of the facility's operation,
such as use and maintenance of radiation-producing devices. Workers must know how to
correctly perform their duties and why they are doing them. They must know how their actions
influence other workers’ responsibilities. Because workers' actions are so critical to their own
safety and the safety of others, their trainers must be of the highest caliber. The technical
instructor must understand thoroughly all aspects of the subjects being taught and the relationship
of the subject content to the total facility. Additionally, the instructor must have the skills and
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Program Management
knowledge to employ the instructional methods and techniques that will enhance learning and
successful job performance. While the required technical and instructional qualifications are
Section 4
listed separately, it is the combination of these two factors that produces a qualified technical
instructor.
The qualifications are based on the best industry practices that employ performance-based
instruction and quality assurance. These qualifications are not intended to be restrictive, but to
help ensure that workers receive the highest quality training possible. This is only possible when
technical instructors possess the technical competence and instructional skills to perform assigned
instructional duties in a manner that promotes safe and reliable DOE facility operations.
Technical Qualifications
Instructors must possess technical competence (theoretical and practical knowledge along with
work experience) in the subject areas in which they conduct training. The foundation for
determining the instructor's technical qualifications is based on two factors:
- the trainees being instructed and
- the subject being presented.
The following is an example of a target audience, subject to be taught, and instructor technical
qualifications.
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Program Management
TARGET AUDIENCE SUBJECT BEING
TAUGHT
INSTRUCTOR QUALIFICATIONS
Individuals (supervisors)
responsible for
supervising radiological
workers and developing
and implementing
measures necessary for
ensuring compliance with
10 CFR 835 at a DOE site
or facility.
Radiological
Control Training
for Supervisors.
Demonstrated knowledge and skills in
radiation protection, above the level to be
achieved by the trainees, as evidenced by
previous training/education and through
job performance.
Methods for verifying the appropriate level of technical competence may include review of prior
training and education, observation, and evaluation of recent related job performance, and oral or
written examination. Other factors that may be appropriate for consideration include DOE, NRC,
or other government license or certification; vendor or facility certification; and most importantly,
job experience. To maintain technical competence, a technical instructor should continue to
perform satisfactorily on the job and participate in continuing technical training.
Instructional Capability and Qualifications
Qualifications of instructional capability should be based on demonstrated performance of the
instructional tasks for the specific course requirements and the instructor's position. Successful
completion of instructor training and education programs, as well as an evaluation of on-the-job
performance, is necessary for verification of instructional capability. Instructional capability
qualification should be granted as the successful completion of an approved professional
development program for training instructors. The program should contain theory and practice of
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Program Management
instructional skills and techniques; adult learning; and planning, conducting, and evaluating
classroom, simulator, laboratory, and on-the-job training activities.
Illustrated talks, demonstrations, discussions, role playing, case studies, coaching, and individual
projects and presentations should be used as the principal instructional methods for presenting the
Section 5
instructional training program. Each instructional method should incorporate the applicable
performance-based principles and practices. Every effort should be made to apply the content to
actual on-the-job experience or to simulate the content in the classroom/ laboratory. The
appropriate methodology required to present the instructional content will indicate a required
level of instructional qualification and skill.
Current instructors' training, education, and job performance should be reviewed to determine
their training needs for particular courses. Based on this review, management may provide
exemptions based on demonstrated proficiency in performing technical instructor's tasks.
Through training or experience, technical instructors should be able to*:
- Review instructional materials and modify to fully meet the needs of the training group.
- Arrange the training facility (classroom/laboratory or other instructional setting) to meet the
requirements for the training sessions.
- Effectively communicate, verbally and non-verbally, lessons to enhance learning.
- Invoke student interaction through questions and student activity.
- Respond to students’ questions.
- Provide positive feedback to students.
- Use appropriate instructional materials and visual aids to meet the lesson objectives.
- Administer performance and written tests.
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Program Management
- Ensure evaluation materials and class rosters are maintained and forwarded to the appropriate
administrative personnel.
- Evaluate training program effectiveness.
- Modify training materials based on evaluation of training program.
*Stein, F. Instructor Competencies: The Standards. International Board of Standards for
Training, Performance and Instruction; 1992.
Selection of Instructors
Selection of instructors should be based on the technical and instructional qualifications specified
in the Course-Specific Information section of this guide. In addition to technical and instructional
qualifications, oral and written communication skills and interpersonal skills should be included
in the process of selecting and approving instructors.
Since selection of instructors is an important task, those who share in the responsibility for
ensuring program effectiveness should:
- interview possible instructors to ensure they understand the importance of the roles and
responsibilities of technical instructors and are willing to accept and fulfill their responsibilities in
a professional manner.
- maintain records of previous training, education, and work experience.
Procedures for program evaluation will include documentation of providing qualified instructors
for generic and facility-specific training programs.
Test Administration
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A test bank of questions for each course that has an exam should be developed and content
validated. As the test banks are used, statistical validation of the test bank should be performed to
fully refine the questions and make the tests as effective as possible. The questions contained in
the test bank are linked directly to the objectives for each course. In this way, trainee weaknesses
can be readily identified and remedial procedures can be put into place. The test outcomes can
Section 6
also be used to document competence and the acquisition of knowledge.
The test banks should also be used by the instructors to identify possible weaknesses in the
instruction. If numerous trainees fail to correctly answer a valid set of questions for an objective,
the instruction for that objective needs to be reviewed for deficiencies.
Written examinations may be used to demonstrate satisfactory completion of theoretical
classroom instruction. The following are some recommended minimal requirements for the test
banks and tests:
- Tests are randomly generated from the test bank.
- Test items represent all objectives in the course.
- All test bank items are content-validated by a subject matter expert.
- Test banks are secured and not released either before or after the test is administered.
- Trainees should receive feedback on their test performance.
- For the first administrations of tests, a minimum of 80% should be required for a passing
score. As statistical analyses of test results are performed, a more accurate percentage for a
passing score should be identified.
Test administration is critical in accurately assessing the trainee's acquisition of knowledge being
tested. Generally, the following rules should be followed:
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Program Management
- Tests should be announced at the beginning of the training sessions.
- Instructors should continuously monitor trainees during examinations.
- All tests and answers should be collected at the conclusion of each test.
- No notes can be made by trainees concerning the test items.
- No talking (aside from questions) should be allowed.
- Answers to questions during a test should be provided, but answers to test items should not be
or alluded to or otherwise provided.
- Where possible, multiple versions of each test should be produced from the test bank
for each test administration.
- After test completion, trainees may turn in their materials and leave the room while other
trainees complete their tests.
- Trainee scores on the tests should be held as confidential.
Program Records and Administration
Training records and documentation shall meet the requirements of 10 CFR 835.704.
Training Program Development/Change Requests
All requests for program changes and revisions should be done in accordance with the DOE
Technical Standards Program.
Audit (internal and external)
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Program Management
Internal verification of training effectiveness should be accomplished through senior instructor or
supervisor observation of practical applications and discussions of course material. All results
should be documented and maintained by the organization responsible for Radiological Control
training.
The additional standardized training program materials and processes should be evaluated on a
periodic basis by DOE-HQ. The evaluation should include a comparison of program elements
with applicable industry standards and requirements.
Evaluating Training Program Effectiveness
Verification of the effectiveness of Radiological Control training should be accomplished per
DOE-HDBK-1131-2007, “General Employee Radiological Training,” and DOE-HDBK-1130-
2008, “Radiological Worker Training.” In addition, DOE has issued guidelines for evaluating the
Section 7
effectiveness of radiological training through the DOE Operations Offices and DOE Field
Offices. For additional guidance, refer to DOE-STD-1070-94, “Guide for Evaluation of Nuclear
Facility Training Programs.”
Course-Specific Information
Purpose
This handbook describes a Radiological Control Training for Supervisors program. It includes
standards and policies as well as recommendations for material development and program
administration. It is intended for use by DOE and DOE contractors for the development of
facility-specific radiological control training for supervisors.
Course Goal
The goal of the training program is to provide a basic understanding of the skills required to
supervise radiological workers in a safe and effective manner. Upon completion, trainees will be
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Program Management
able to discuss DOE's radiation protection requirements and guidance and the manager's roles and
responsibilities for implementing those requirements and guidance.
Target Audience
Radiological Control Training for Supervisors may be provided to individuals (supervisors)
responsible for supervising radiological workers and developing and implementing measures
necessary for ensuring compliance with 10 CFR 835 at a DOE site or facility.
Prerequisites
The material is targeted for individuals with a fundamental knowledge of radiation protection
concepts, such as successful completion of Radiological Worker II Training.
Proficiency Requirements
An examination or performance demonstration is not required. Instructors are encouraged to
evaluate the effectiveness of the training through use of classroom participation and/or a quiz at
the end of the training.
Retraining
Sites are encouraged to develop periodic training and retraining for supervisors. Retraining
should focus on lessons learned and site specific events as necessary.
Materials developed in support of training should be documented in accordance with 10 CFR 835
Subpart H "Records.”
Instructor Qualifications
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Program Management
All classroom instruction should be provided by instructors qualified in accordance with the
contractor’s site instructor qualification program. Training staff (contractor and subcontractor, if
used) should possess both technical knowledge and experience, and the developmental and
instructional skills required to fulfill their assigned duties.
1. Training staff responsible for program management, supervision, and development should have
and maintain the education, experience, and technical qualifications required for their jobs.
2. Instructors should have the technical qualifications, including adequate theory, practical
knowledge, and experience, for the subject matter that they are assigned to teach. It may be
advisable to use more than one instructor for this material: an instructor with a technical
radiological control background to cover modules one and two and an instructor with a
management background (e.g., experience in teaching motivational techniques, communications,
decision making, and leadership) to cover the remaining modules.
3. Methods should be in place at each contractor site to ensure that individual instructors meet
and maintain position qualification requirements.
Section 8
4. Subject matter experts without instructor qualification may provide training in their area of
expertise. However, if these subject matter experts are to be permanent instructors, they should
be trained as instructors in the next practical training cycle.
DOE Order 5480.20A, Personnel Selection, Qualification, and Training Requirements for DOE
Nuclear Facilities, discusses qualification requirements for instructors.
DOE has also provided guidance on qualifications of radiological instructors in DOE STD-1107-
97, Knowledge, Skills, and Abilities for Key Radiation Protection Positions at DOE Facilities.
Training Material Presentation
Training materials consist of lesson plans, overheads, student guides, and handouts. To ensure
appropriate training, facility-specific materials must be added to the materials when necessary to
adequately train individuals for facility-specific radiological hazards.
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It is estimated that this material could be presented in 12 hours.
References and Supporting Documents
National Council on Radiation Protection and Measurement, Report Number 134, Operational
Radiation Safety Training, October 2000.
U.S. Department of Energy, DOE Order 5480.20A, Personnel Selection, Qualification, and
Training Requirements for DOE Nuclear Facilities, November 1994.
U.S. Department of Energy, DOE-STD-1070-94, Guidelines for Evaluation of Nuclear Facility
Training Programs, June 1994.
U.S. Department of Energy, Occupational Radiation Protection, 10 CFR 835, June 2007.
U.S. Department of Energy, DOE-STD-1107-97, Ch 1. Knowledge, Skills, and Abilities for Key
Radiation Protection Positions at DOE Facilities, 2007.
U.S. Department of Energy, Implementation Guidance for Use with 10 CFR 835, Occupational
Radiation Protection. DOE G 441.1-1C, 2008.
U.S. Department of Energy, DOE-STD-1098-2008, Radiological Control, 2008.
U.S. Department of Energy, DOE-HDBK-1122-1999, Radiological Control Technician Training,
15
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Radiological Worker Training Appendix A
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Instructor's Material
Office of Health, Safety, and Security
U.S. Department of Energy
Radiological Worker Training Appendix A
Radiological Control Training for Supervisors
DOE-HDBK-1130-2008
Instructor's Material
Table of Contents
Page
Occupational Radiation Protection Program Policy and Guidance Review .................. 1–1
10 CFR Part 835, Background and Focus .................................................................. 2–1
Administrative Policies and Procedures ....................................................................... 3–1
Fitness for Duty ............................................................................................................ 4–1
Interpersonal Communication ...................................................................................... 5–1
Problem Analysis and Decision Making ....................................................................... 6–1
Motivation .................................................................................................................... 7–1
Leadership ................................................................................................................... 8–1
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Section 9
DOE-HDBK-1130-2008
Instructor's Material
DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Occupational Radiation Protection
Program Policy and Guidance
Review
Objectives:
Upon completion of this training, the participant will be able to:
1. Identify the hierarchy of regulatory documents.
2. Define the purposes of 10 CFR Parts 820, 830 and 835.
3. Define the purpose of the DOE Radiological Control Standard.
4. Define the terms “shall” and “should” as used in the above documents.
5. Describe the role of the Defense Nuclear Facilities Safety Board (DNFSB) at
DOE sites and facilities.
Training Aids:
Overhead Transparencies (OTs): OT 1.1 – OT 1.17 (may be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
Flip chart
Markers
Masking tape
Student Materials:
Student’s Material
Module 1 - 1
Radiological Worker Training Appendix A
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Instructor's Material
References:
U.S. Department of Energy, 10 CFR Part 820, Procedural Rules for DOE
Nuclear Facilities.
U.S. Department of Energy, 10 CFR Part 830, Nuclear Safety Management.
U.S. Department of Energy, 10 CFR Part 835, Occupational Radiation
Protection.
U.S. Department of Energy, 10 CFR 850, Chronic Beryllium Disease
Prevention Program.
U.S. Department of Energy, 10 CFR 851, Worker Safety and Health Program.
U.S. Department of Energy, Radiological Control, DOE-STD-1098-2008.
U.S. Department of Energy, DOE Radiological Health and Safety Policy,
DOE P 441.1, April 26, 1996.
U.S. Department of Energy, DOE P 411.1, Safety Management Functions,
Responsibilities, and Authorities Policy, 1997.
Module 1 - 2
Radiological Worker Training Appendix A
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Instructor's Material
I. Introduction
(Show OT 1.1 and OT 1.2. State objectives)
II. DOE radiological health and safety (Discuss that this is from DOE P 441.1)
A. Policy (some key points in summary)
Conduct oversight to ensure Departmental requirements are being
complied with and appropriate radiological work practices are being
implemented. (Show OT 1.3)
Ensure radiological measurements, analyses, worker monitoring
results, and estimates of public exposures are accurate and
appropriately made. (Show OT 1.4)
Incorporate dose reduction, contamination reduction, and waste
minimization features into the design of new facilities and significant
modifications to existing facilities in the earliest planning stages.
Establish and maintain, from the lowest to the highest levels, line
management involvement and accountability for Departmental
radiological performance.
Establish and maintain a system of regulatory policy and guidance.
Ensure appropriate training is developed and delivered and the
technical competence of the DOE workforce and their technical
competence.
Conduct radiological operations in a manner that controls the spread
of radioactive materials and reduces exposure to the work force and
the general public and utilizes a process that seeks exposure level as
low as reasonably achievable (ALARA).
B. History (Show OT 1.5)
DOE has provided numerous written standards for on-site radiological
protection, the most recent regulation being 10 CFR Part 835,
Occupational Radiation Protection. This regulation was preceded by:
Section 10
DOE Notice 5480.6 of June 17, 1992, Radiological Control, which
specified that the DOE Radiological Control Manual (DOE/EH-0256T)
would supersede DOE Order 5480.11.
Module 1 - 3
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Instructor's Material
DOE Order 5480.11, Radiation Protection for Occupational Workers
(effective December, 1988). The purpose was to establish radiation
protection standards and program requirements for DOE and DOE
contractors for the protection of workers from ionizing radiation.
The establishment of DOE radiological protection standards did not start
with these documents. A chronology of dose limits of DOE and its
predecessor agencies, the Atomic Energy Commission (1946-1975) and
the Energy Research and Development Administration (1975-1977),
demonstrate a lowering of whole body dose limits over the last 50 years.
In the establishment of these dose limits, DOE has followed
recommendations of national and international radiological protection
groups, notably the International Commission on Radiological Protection
(ICRP) and the National Council on Radiation Protection and
Measurements (NCRP).
C. Hierarchy of requirements (Show OT 1.6)
Currently within DOE there are two parallel hierarchies of requirements:
Rules and/or regulations (these terms are used interchangeably in this
training)
DOE Orders
Rules are codified in the Code of Federal Regulations (CFR) and may be
subject to enforcement action including civil and criminal penalties. (Show
OT 1.7) DOE Orders are contractually implemented and enforced through an
award/fee contractual arrangement between DOE and the contractor.
III. Rules and regulations
In response to the enforcement authority in the Price-Anderson Amendments
Act (PAAA) of 1988, DOE is converting its contractual requirement in orders
to enforceable rules to enhance contractor accountability for safety.
10 CFR 830 governs the conduct of DOE contractors, DOE personnel, and
other persons conducting activities (including providing items and services)
that affect, or may affect, the safety of DOE nuclear facilities. It includes
quality assurance requirements and Technical Safety Requirements.
A. DOE enforcement of rules under PAAA
Module 1 - 4
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Instructor's Material
10 CFR Part 820 (effective on September 16, 1993) sets forth the
procedures to implement the provisions of the PAAA. Part 820 requires
contractors to comply with DOE Nuclear Safety Requirements.
PAAA demands a “large stick” to enhance contractor accountability for
safety. Rules provide authority for the assessment of civil and criminal
penalties and thus provide the large stick
B. Penalties under Part 820
1. Civil penalties
DOE may assess civil penalties against any person subject to Part
820, for violations of:
Codified rules in the CFR
Compliance orders
Any program or plan required by a rule or compliance order
Note: Certain nonprofit educational institutions and other listed
institutions are exempt from assessment of civil penalties.
2. Criminal penalties
If a person subject to the Atomic Energy Act of 1954, as amended, or
Nuclear Safety Requirements, has by action or omission knowingly
and willfully violated, caused to be violated, attempted to violate, or
conspired to violate any section of the Atomic Energy Act of 1954, as
amended, or applicable DOE Nuclear Safety Requirements, the
person shall be subject to criminal sanctions.
Section 11
3. The “carrot and stick” approach
DOE may provide monetary incentives in its management and
operating (M&O) contracts for actions consistent with or exceeding
requirements, and to penalize actions and activities that were not in
compliance with requirements.
Noncompliance with the Radiation Protection Program can subject a
contractor to PAAA enforcement. There are provisions to mitigate
penalties for self-identifying and reporting violations.
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C. DOE Nuclear Safety Requirements
DOE Nuclear Safety Requirements are the set of enforceable rules,
regulations, or orders relating to nuclear safety that have been adopted
by DOE (or by another agency if DOE specifically identifies it).
Compliance orders are issued by the Secretary. They identify a situation
that violates, potentially violates, or otherwise is inconsistent with the:
Atomic Energy Act of 1954, as amended
Nuclear statutes
Nuclear Safety Requirements
Compliance orders:
Mandate a remedy or other action
States the reason for the remedy or other action
D. 10 CFR Part 835 (Show OT 1.8)
On December 14, 1993, DOE published a final rule in the Federal
Register (58 FR 65458) Title 10 Code of Federal Regulations Part 835,
Occupational Radiation Protection (10 CFR 835). On June 8, 2007, the
latest amendment to 10 CFR 835 was published in the Federal Register
(72 FR 31904).
The purpose of 10 CFR 835 is the codification of radiological protection
requirements. It contains “shall” statements, which are legally binding. It
also contains:
Prescriptive language
Added emphasis on ALARA
Requirements for a Radiation Protection Program (RPP)
Federal law
Criminal and civil penalties for violations
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E. Radiation Protection Program (10 CFR Part 835) (Show OT 1.9)
Each site, under Part 835, must submit to DOE a written Radiation
Protection Program (RPP). The cognizant DOE program office reviews
submitted RPPs for approval.
The RPP requires careful consideration because noncompliance may
subject a contractor to PAAA enforcement
F. Guidance documents for 10 CFR Part 835 (Show OT 1.10)
Two types of regulatory guidance documents have been developed:
Guidance for implementing the provisions of 10 CFR Part 835.
Guidance providing technical positions.
The above are available through the DOE HS-11 website at:
http://www.hss.energy.gov/HealthSafety/WSHP/radiation/regs.htm
Unlike the requirements specifically set forth in 10 CFR Part 835, the
provisions in guidance documents are not mandatory. They are intended
solely to describe the rationale for, and the objectives of, regulatory
requirements and/or to identify acceptable methods for implementing
regulatory requirements.
Failure to follow a guidance document does not in itself indicate
noncompliance with a specific requirement of the rule. A finding of
noncompliance is found for a failure to satisfy the regulatory requirement.
Following a guidance document in the prescribed manner will ordinarily
create a presumption of compliance with a related regulatory
requirement.
1. Technical guidance
Section 12
Technical guidance describes and disseminates technical methods
and techniques for fulfilling implementation and, in turn, the
requirements in 10 CFR Part 835. Examples of these guidance
documents are DOE Technical Standards and DOE Radiological
Control Technical Positions (RCTPs).
2. Implementation guide (IG)
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Implementation guidance is intended to identify and make available to
DOE contractors basic program elements and acceptable methods for
implementing specific provisions of the final rule. An implementation
guide has been developed for 10 CFR Part 835.
G. Relationship between 10 CFR Part 835 and 10 CFR Part 20 (Show OT
1.11)
10 CFR Part 20 is the occupational radiological regulation issued by the
Nuclear Regulatory Commission (NRC).
The question of consistency among federal agencies in their occupational
radiological protection regulations became a major point of discussion
during the rule making process.
While agreeing with the goal of consistency, DOE believes that it must
promulgate its own regulations because of the unique nature and
diversity of radiological activities within the DOE complex. The final rule
allows DOE to establish more rigorous requirements in areas of particular
concern. Overall 10 CFR Part 835 has many similarities as 10 CFR Part
20.
IV. DOE STD Radiological Control (Show OT 1.12)
A. Radiological Control
In January 1992, a memorandum was sent to the heads of DOE
elements involved in managing radiological control programs. In the
memorandum, the Secretary directed a series of initiatives to enhance
the conduct of radiological operations within the Department of Energy.
Also in this memo, the Assistant Secretary of Environment, Safety and
Health was directed to develop a comprehensive and definitive
radiological control manual. The DOE Radiological Control Manual was
developed to meet that directive and was approved by the Secretary and
promulgated with DOE Notice 5480.6, Radiological Control, in July 1992.
After the issuance of 10 CFR 835 as a final rule in December 1993, DOE
Notice N441.1, Radiological Protection for DOE Activities, was issued on
9-30-95. This cancelled the notice which made the Radiological Control
Manual a requirements document. However, the notice stated that
"cancelled orders that are incorporated by reference in a contract shall
remain in effect until the contract is modified to delete the reference.
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N441.1 also retained some of the radiation protection requirements from
the Radiological Control Manual that were not included in 10 CFR 835.
In July, 1999, the Radiological Control Manual was replaced by the
standard, DOE-STD-1098-99, Radiological Control. Many DOE sites
contractually must still adhere to the provisions of either the Radiological
Control Manual or the Radiological Control Standard. Subsequent to the
1998 amendment to 10 CFR 835, the effective date of N441.1 has
passed.
The DOE Radiological Control Standard is not regulatory in nature. It is a
guidance document that describes DOE’s policy and expectations for an
excellent radiological control program.
1. Implementation
Section 13
If a site fully implements a provision of the DOE Radiological Control
Standard, the user will have most likely complied with any related
statutory, regulatory, or contractual requirements. Users are
cautioned that they must review the source document (10 CFR 835)
to ensure compliance.
2. Enforceability
When incorporated into contracts, the provisions of the DOE
Radiological Control Standard or Manual are binding requirements.
If portions of the Site-Specific Radiological Control Manual are
incorporated in the RPP under Part 835 and approved by DOE, they
are also binding.
B. The Site-Specific Radiological Control Manual
The DOE Radiological Control Standard states that a Site-Specific
Radiological Control Manual should be written and followed.
C. Relationship between 10 CFR Part 835 and the DOE Radiological
Control Standard (Show OT 1.13)
1. Compliance
The Office of Enforcement (HS - 40) will enforce 10 CFR Part
835. It can assess fines and penalties.
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The Program Offices will audit for both compliance with 10 CFR
835 and contractual agreements including the DOE Radiological
Control Standard or Manual, Orders, etc. Results of these audits
can affect the contractor’s award fee.
2. What if there are conflicts? (Show OT 1.14)
10 CFR Part 835 takes precedence over the DOE Radiological Control
Standard and DOE orders. It is unlikely that there will be a conflict
between the two documents, although one document may contain
provisions that are not addressed in the other.
It is planned that all requirements for nuclear safety will be incorporated
into rules.
3. “Shall” and “should” statements
10 CFR Part 835 contains “shall” statements. “Shall” statements in
Part 835 are legally binding.
Processes for exemption relief from Part 835 are set forth in
Subpart E to Part 820. If relief is requested from provisions of Part
835, the exemption must be considered and granted, if
appropriate, by the Chief Health, Safety and Security Officer (HS -
1).
The use of “should” in the DOE Radiological Control Standard
recognizes that there may be site- or facility-specific attributes that
warrant special treatment. It also recognizes that literal
compliance with the elements and requirements of the provision
may not achieve the desired level of radiological control
performance.
D. DOE Standards (Show OT 1.15)
DOE has developed several technical standards for occupational
radiation protection. Depending on the site-specific application, some
standards are required to be followed. For example, sites which need to
monitor individual external exposures to ionizing radiation need to follow
the DOE Laboratory Accreditation Program (DOELAP) standards. Other
standards may be incorporated by reference in the site RPP.
Other standards provide technical guidance on specific applications, but
adherence to the standard may not be required.
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E. Other Safety Policy and Orders
In addition to the occupational radiation protection requirements and
recommendations previously discussed, DOE has established
requirements for worker protection from other hazards. Some of these
include:
DOE P 411.1 Safety Management Functions, Responsibilities, and
Authorities Policy
Section 14
10 CFR 851 Worker Safety and Health Program
10 CFR 850 Chronic Beryllium Disease Prevention Program
V. Defense Nuclear Facilities Safety Board (Show OT 1.16)
A. Establishment
The Atomic Energy Act of 1954 was amended by adding Chapter 21,
Defense Nuclear Facilities Safety Board (DNFSB). This amendment
established an independent board in the executive branch to provide
oversight of some DOE operations at DOE facilities and sites.
B. Members
The DNFSB consists of five members appointed by the President with
consent of the Senate.
The Board shall:
Review and evaluate standards
Investigate any event or practice at a DOE defense nuclear facility
that the Board determines has adversely affected or may adversely
affect public health and safety.
The Board may:
Establish reporting requirements for the Secretary of Energy
By evaluating how well DOE meets its objectives, the DNFSB helps DOE
achieve and maintain excellence in radiological protection.
C. Secretary of Energy
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The Secretary of Energy shall fully cooperate with the Board.
D. DNFSB Recommendations (Show OT 1.17)
DNFSB provides DOE with recommendations for improving safety at
DOE defense nuclear facilities. Examples include:
DNFSB Recommendation 91-6 dealt with radiological protection
concerns throughout the DOE defense nuclear facilities complex, and
identified several actions to be taken by the Department to improve
radiological protection performance.
DNFSB Recommendation 92-7 dealt with training and qualification at
DOE sites and facilities.
DNFSB Recommendation 98-1 dealt with resolution of internal audit
findings.
DNFSB Recommendation 99-1 dealt with safe storage of fissionable
materials.
Implementation of DOE and site commitments made in response to
DNFSB recommendations are areas to review during an assessment.
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: 10 CFR Part 835, Background
and Focus
Objectives:
Upon completion of this training, the participant will be able to:
1. Describe the contents of 10 CFR Part 835.
2. Identify the site requirements of 10 CFR Part 835.
Training Aids:
Overhead Transparencies (OTs): OT 2.1 – OT 2.32 (may be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
Student Materials:
Student’s Material
10 CFR 835
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References:
U.S. Department of Energy, 10 CFR Part 820, Procedural Rules for DOE
Nuclear Facilities.
U.S. Department of Energy, 10 CFR Part 835, Occupational Radiation
Protection.
U.S. Department of Energy, Order 458.1, Ch 2, Radiation Protection of the
Public and the Environment, 2011.
U.S. Department of Energy, DOE-STD-1107-97 Knowledge, Skills, and
Abilities for Key Radiation Protection Positions at DOE Facilities, 1997.
U.S. Department of Energy, DOE G 441.1-1C, 10 CFR 835 Implementation
Guide, 2008.
U.S. Department of Energy, DOE O 231.1, Change 2, Environment, Safety
and Health Reporting, 2000.
Section 15
U.S. Department of Energy, DOE M 231.1-1, Change 2, Environment, Safety
and Health Reporting Manual, 2000.
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I. Introduction (Introduce module. State objectives. Show OT 2.1.)
(Emphasize that this lesson is an overview of major areas of 10 CFR Part 835. Not
every provision is addressed in this module 10 CFR 835 should be reviewed in its
entirety to ensure compliance. Provide copies of 10 CFR 835 for reference.)
This module provides an overview of many of the provisions of 10 CFR 835.
For completeness, individuals should always reference back to 10 CFR 835
for the complete text.
II. Outline of 10 CFR Part 835 (Show OT 2.2)
(Obj. 1 Describe the contents of 10 CFR Part 835.)
Part 835 is the codification of radiological protection requirements. Part 835
contains 14 subparts and five appendices. The outline consists of the
following subparts:
A — General Provisions
B — Management and Administrative Requirements
C — Standards for Internal and External Exposure
D — Reserved
E — Monitoring of Individuals and Areas
F — Entry Control Program
G — Posting and Labeling
H — Records (Show OT 2.3)
I — Reports to Individuals
J — Radiation Safety Training
K — Design and Control
L — Radioactive Contamination Control
M — Sealed Radioactive Source Control
N — Emergency Exposure Situations
Under 10 CFR Part 835, each site must submit a Radiation Protection
Program (RPP).
(Obj. 2 Identify the site requirements of 10 CFR Part 835.)
Part 835 helps to ensure that DOE facilities are operated in a manner such
that occupational radiological exposure of workers is maintained within
acceptable limits and as low as is reasonably achievable (ALARA).
A. Subpart A - General Provisions (Show OT 2.4)
Subpart A contains the scope of the rule. The rule in this part establishes
radiological protection standards, limits, and program requirements for
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protecting individuals from ionizing radiation resulting from the conduct of
DOE activities.
It also includes activities excluded from the provisions of the rule. (Show
OT 2.5) Activities that are excluded include the following (summarized):
Activities regulated through a license by the Nuclear Regulatory
Commission (NRC) or a state under an agreement with the NRC.
Activities conducted under the authority of the Director, Naval Nuclear
Propulsion Program.
Specified activities conducted under the Nuclear Explosives and
Weapons Surety Program.
DOE activities in other countries with acceptable radiation protection
program.
Background radiation.
Radioactive material on or within material, equipment, and real
property which is approved for release when the radiological
conditions of the material, equipment, and real property have been
documented to comply with the criteria for release set forth in a DOE
authorized limit which has been approved by a Secretarial Officer in
consultation with the Chief Health, Safety and Security Officer.
Radioactive material transportation not performed by DOE or a DOE
contractor.
(Discuss radioactive material transportation definition.)
Section 16
Occupational doses received as a result of excluded activities and
radioactive material transportation, as listed above, shall be considered
when determining compliance with the occupational dose limits (835.202
and 835.207), and with the limits for the embryo/fetus (835.206).
Subpart A also addresses:
Definitions
Radiological units (Curie, rad, roentgen, rem, other conventional units,
and multiples)
B. Subpart B - Management and Administrative Requirements (Show OT
2.6)
The RPP shall:
Include formal plans and measures for applying the ALARA process
to occupational exposures.
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Specify the existing and/or anticipated operational task.
Address, but not be limited to, each requirement in Part 835.
Include plans, schedules, and other measures for achieving
compliance.
DOE may direct or make modifications to an RPP. An initial RPP or
update shall be considered approved 180 days after its submission
unless rejected by DOE at an earlier date.
Internal Audits (10 CFR 835.102)
(Discuss again DOE’s 10 CFR 835 Implementation Guide and its purpose.)
Internal audits of the radiation protection program, including examination
of program content and implementation, shall be conducted through a
process that ensures that all functional elements are reviewed no less
frequently than every 36 months. This training material and DOE G
441.1-1C provide guidance on DOE's expectations.
Education, Training and Skills (10 CFR 835.103)
Individuals responsible for developing and implementing measures
necessary for ensuring compliance with the requirements of this part shall
have the appropriate education, training, and skills to discharge these
responsibilities. DOE STD-1107-97 Knowledge, Skills, and Abilities for
Key Radiation Protection Positions at DOE Facilities, provides guidance
on DOE's expectations.
Written Procedures (10 CFR 835.104)
Written procedures are required, as necessary, to ensure compliance
with 835, commensurate with radiological hazards and education, training
and skills of exposed individuals.
C. Subpart C - Standards for Internal and External Exposure (Show OT 2.7)
This subpart addresses limits for:
General employees (occupational)
Embryos/fetus of declared pregnant worker (i.e., A woman who has
voluntarily declared to her employer, in writing, her pregnancy for the
purpose of being subject to the occupational dose limits to the
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embryo/fetus. This declaration may be revoked, in writing, at any time
by the declared pregnant worker.)
Occupationally exposed minors
General public in a controlled area
It also addresses:
Planned special exposures
Nonuniform exposures of the skin
Concentrations of radioactive material in air
1. Summary of dose limits (Show OT 2.8) (Show OT 2.9)
10 CFR Part 835 employs the rem unit for several different physical
quantities (i.e. absorbed dose, effective dose, total effective dose,
equivalent dose, committed equivalent dose, committed effective
dose). For information about these quantities refer to 10 CFR Part
835 definitions. This training will use the term “dose” as a general
term for all the above terms.
Section 17
These are the Federal limits. DOE encourages sites to adopt more
restrictive Administrative Control Levels (ACLs). For most facilities
an ACL of 500 mrem or less will be challenging for radiological
workers.
Exposed Individual Annual Limit
General Employee: Whole Body (internal and external) 5.0 rem
General Employee: Lens of Eye 15.0 rem
General Employee: Extremity (below elbow and knees) and skin 50.0 rem
General Employee: Any Organ or Tissue (other than lens of eye) 50.0 rem
Declared Pregnant Worker: Embryo/Fetus (gestation period) 0.5 rem
Occupationally Exposed Minors (under age 18): 0.1 rem *
Members of the Public in Controlled Areas: 0.1 rem
And 10% of other general employee limit
2. Planned special exposures (PSEs) (Show OT 2.10)
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It is acknowledged that unusual conditions can arise in which well
documented higher-than-normal doses can be justified. In these well-
planned, well-controlled, and highly infrequent and unusual conditions
operating management would be permitted to allow specified
individual exposures exceeding the occupational limit.
The term "unusual conditions" is made clear by specifying that
alternatives which would preclude exposures higher than the
prescribed dose limits must be either unavailable or impractical.
10 CFR 835.204 specifies requirements for annual and lifetime dose
from PSEs. It also specifies requirements for determining previous
individual exposures prior to allowing a PSE.
Every PSE must be approved in advance by DOE and requires the
informed consent of the employee involved.
3. Concentration of radioactive material in air (Show OT 2.11)
(Define DAC in terms of equivalent dose.)
Appendices A and C contain the derived air concentration (DAC)
values used in the control of occupational exposure to airborne
radioactive material.
DACs are listed in appendices A and C of 10 CFR 835. For intakes
(appendix A), they are the airborne concentration that equals the
annual limit on intake (ALI) divided by the volume of air breathed by
an average worker for a working year of 2000 hours (assuming a
breathing volume of 2400 m3).
The ALI is the smaller value of intake of a given radionuclide in a year
by a standardized man that would result in a committed effective doe
of 5 rems or a committed equivalent dose of 50 rems to any individual
organ or tissue.
Appendix C contains DACs for controlling external dose from being
immersed in a cloud of airborne radioactive material.
Estimation of internal dose shall be based on bioassay data rather
than air concentration values unless bioassay data are:
Unavailable (e.g., radon or very short lived radioisotopes)
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Less accurate than internal dose estimates based on
representative air concentration values
Inadequate
D. Subpart D - Reserved
E. Subpart E - Monitoring of Individuals and Areas (Show OT 2.12)
This subpart addresses:
General requirements
Instrumentation
Individual monitoring - external
Individual monitoring - internal
Air monitoring
Receipt of packages containing radioactive material
1. General requirements (10 CFR 835.401)
Monitoring of individuals and areas shall be performed to:
Demonstrate compliance with Part 835.
Section 18
Document radiological conditions.
Detect changes in the radiological conditions.
Detect the gradual buildup of radioactive material.
Verify the effectiveness of engineering and process controls in
containing radioactive material and reducing radiation
exposure.
Identify and control potential sources of individual exposure to
radiation and/or radioactive material.
2. Instrumentation (Show OT 2.13)
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Instruments and equipment used for monitoring and contamination
control shall be:
Periodically maintained and calibrated on an established
frequency.
Appropriate for the type(s), levels, and energies of the
radiation(s) encountered.
Appropriate for existing environmental conditions.
Routinely tested for operability.
3. Individual monitoring - external (10 CFR 835.402) (Show OT 2.14)
For the purpose of monitoring individual exposure to external
radiation, personnel dosimetry shall be provided to and used by:
Radiological Workers likely to receive:
– An effective dose to the whole body of 0.1 rem (100 mrem)
or more in a year
– An equivalent dose to the skin or to any extremity of 5 rem
or more in a year
– An equivalent dose to the lens of the eye of 1.5 rem or more
in a year
Declared Pregnant Workers who are likely to receive from
external sources an equivalent dose to the embryo/fetus in
excess of 10 percent of the applicable limit in 10 CFR
835.206(a).
Members of the public in a controlled area and occupationally
exposed minors likely to receive, in one year, from external
sources, a dose in excess of 50 percent of the applicable limit
in 10 CFR 835 Subpart C.
Individuals entering a High or Very High Radiation Area.
DOE Laboratory Accreditation for Personnel Dosimetry is required
for external dose monitoring programs implemented to
demonstrate compliance with 10 CFR 835.
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4. Individual monitoring - internal (10 CFR 835.402) (Show OT 2.15)
(Emphasize how it is important to integrate several aspects of the
radiological control program into an effective internal dose
monitoring program. These include: bioassay (selection of
participants and isotopes to be monitored), air monitoring, and
contamination monitoring (both personnel and area).)
Internal dose evaluation programs (including routine bioassay
programs) shall be conducted for:
Radiological Workers who, under typical conditions, are likely
to receive 0.1 rem or more committed effective dose from all
occupational radionuclide intakes in a year.
Declared Pregnant Workers likely to receive an intake or
intakes resulting in an equivalent dose to the embryo/fetus in
excess of 10 percent of the limit stated in 10 CFR 835.206(a).
Members of the public in a controlled area and occupationally
exposed minors who are likely to receive a committed effective
dose in excess of 50 percent of the applicable limit in 10 CFR
835 Subpart C from all intakes in a year.
DOE Laboratory Accreditation for Radiobioassay is required for
internal dose monitoring programs implemented to demonstrate
compliance with 10 CFR 835.
5. Air monitoring (10 CFR 835.403)
Measurements of radioactivity concentrations in the ambient air of
the workplace shall be performed as follows:
Section 19
Air sampling shall be performed in occupied areas where an
individual is likely to receive an exposure of 40 DAC-hrs or
more in a year (i.e. an annual intake of 2 percent or more of the
specific ALI value) for the mixture of isotopes.
Samples shall be taken as necessary to characterize the levels
or concentration of airborne radioactive material when
respirators are worn for radiation protection purposes.
Real-time air monitoring shall be performed when there is a
need to alert potentially exposed individuals to unexpected
increases in airborne radioactivity levels such that immediate
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action is necessary in order to minimize or stop inhalation
exposures.
6. Receipt of Packages Containing Radioactive Material (10 CFR
835.405) (Show OT 2.16)
Establishes requirements to monitor certain types of packages and
sets a time limit of not later than 8 hours after the beginning of the
working day following receipt of the package.
F. Subpart F - Entry Control Program (10 CFR 835.501) (Show OT 2.17)
Subpart F addresses entry into:
Radiological Areas
(Discuss different types of radiological areas.)
High Radiation Areas
Very High Radiation Areas
1. Radiological Areas
The degree of control shall be commensurate with existing and
potential radiological hazards within the area.
One or more of the following methods shall be used to ensure
control: (Show OT 2.18)
Signs and barricades
Control devices on entrances
Conspicuous visual and/or audible alarms
Locked entrance ways
Administrative controls
“No control(s) shall be installed at any radiological area exit that
would prevent rapid evacuation of personnel under emergency
conditions.” (Show OT 2.19)
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2. High Radiation Areas (Show OT 2.20)
A High Radiation Area is an area where radiation levels exist such
that an individual could exceed an equivalent dose to the whole
body of 0.1 rem in any one hour at 30 centimeters from the source
or from any surface that the radiation penetrates.
If an individual could receive an equivalent dose exceeding 1.0
rem in an hour (at 30 cm), a High Radiation Area shall have one or
more of the following:
A control device that prevents entry to the area when high
radiation levels exist or that, upon entry, causes the radiation
level to be reduced below that level that defines a High
Radiation Area.
A device that functions automatically to prevent use or
operation of the radiation source or field while individuals are in
the area.
A control device that energizes a conspicuous visible or audible
alarm signal so that the individual entering the High Radiation
Area and the supervisor of the activity are made aware of the
entry.
Entryways that are locked. During periods when access to the
area is required, positive control over each entry is maintained.
Continuous direct or electronic surveillance that is capable of
preventing unauthorized entry.
A control device generating audible and visual alarm signals to
alert personnel in the area before use or operation of the
radiation source and in sufficient time to permit evacuation of
the area or activation of a secondary control device that will
prevent use or operation of the source.
Section 20
3. Very High Radiation Areas (Show OT 2.21)
A Very High Radiation Area is an area in which an individual could
receive a dose in excess of 500 rad in one hour at 1 meter from
the radiation source or from any surface that the radiation
penetrates.
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In addition to the requirements for a High Radiation Area,
additional measures shall be implemented to ensure individuals
are not able to gain unauthorized access to Very High Radiation
Areas. (Show OT 2.22)
“No control(s) shall be established in a High or Very High Radiation
Area that would prevent rapid evacuation of personnel.”
G. Subpart G - Posting and Labeling (Show OT 2.23)
Subpart G addresses the general requirements for signs:
Yellow background
Black or magenta radiation symbol
Clear and conspicuous signs
In addition, Subpart G addresses specific posting requirements for:
Controlled Areas
Radiation Areas
High Radiation Areas
Very High Radiation Areas
Airborne Radioactivity Areas
Contamination Areas
High Contamination Areas
Radioactive Material Areas
This subpart also addresses exceptions to posting and labeling.
(Discuss posting and labeling exceptions.)
H. Subpart H - Records (Show OT 2.24)
Subpart H addresses requirements for records documenting compliance
with Part 835 and with the Radiation Protection Program.
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Records that are specifically required include those necessary to
demonstrate compliance with the ALARA provisions of the rule.
10 CFR 835 also requires that certain records be maintained, including
records of:
Individual monitoring
Sealed source inventory and control
Results of surveys for the release of material and equipment
Results of specified monitoring for radiation and radioactive material
Maintenance and calibration of radiation monitoring instruments
Internal audits
Each individual’s training as a general employee and as a Radiological
Worker must be recorded. Where appropriate, demonstration and
documentation of proficiency is required.
Refer to 10 CFR 835 Subpart H for a complete listing of required records.
Chapter 13 of DOE G 441.1-1C, Record-Keeping and Reporting,
provides additional guidance on record-keeping requirements, including
reference to DOE O 231.1, Change 2, Environment, Safety and Health
Reporting, and DOE M 231.1-1, Change 2, Environment, Safety and
Health Reporting Manual. This order and manual specify radiation
protection reporting requirements that may be applicable to the site or
facility being assessed.
I. Subpart I - Reports to Individuals (10 CFR 835.801)
(Discuss applicability of O 231.1 to the site or facility.)
Subpart I addresses reports to individuals and their accessibility to
reports, including:
On an annual basis, each DOE or DOE contractor-operated site or facility
must provide each individual monitored for occupational exposure a
radiation dose report of his/her occupational exposure at that site or
facility.
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Section 21
Upon the request from an individual terminating employment, records of
exposure shall be provided to that individual as soon as the data are
available, but not later than 90 days after termination. A written estimate
of the radiation dose received by that employee based on available
information shall be provided at the time of termination, if requested.
J. Subpart J - Radiation Safety Training (Show OT 2.26)
This subpart addresses radiation safety training. The tailored approach
to training requirements is based on:
Unescorted access to or receiving occupational dose in controlled
areas (e.g., General Employees)
Unescorted access to radiological areas or unescorted assignment as
Radiological Workers
Requirements of Part 835 include:
Verification by examination for certain training (e.g., Radiological
Worker Training)
Intervals of training not to exceed twenty four months
List of topics which must be included in training
Provisions for limited use of escorts in lieu of training
Chapter 14 of DOE G 441.1-1C, Radiation Safety Training, provides
additional guidance on DOE's expectations on radiation safety training.
K. Subpart K - Design and Control (Show OT 2.27)
Subpart K addresses added emphasis on facility and equipment design
and administrative controls to maintain radiological exposures ALARA.
1. Facility design and modifications (10 CFR 835.1001)
During the design of new facilities or modification of old facilities, the
following objectives shall be adopted:
Optimal methods shall be used to assure ALARA
Maintain exposure levels below an average of 0.5 mrem/hr
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Avoid release of radioactivity to the workplace atmosphere
The design or modification of a facility and the selection of materials shall
include features that facilitate operations, maintenance, decontamination,
and decommissioning
2. Workplace controls (10 CFR 835.1003) (Show OT 2.28)
During routine operations, the combination of engineered and
administrative control shall provide that:
The anticipated occupational dose to general employees shall not
exceed the limits
The ALARA process is utilized for personnel exposures to ionizing
radiation
L. Subpart L - Radioactive Contamination Control (Show OT 2.29)
1. Control of material and equipment
This section addresses the requirements for release of materials and
equipment from radiological areas to controlled areas. Releases to
uncontrolled areas are addressed in DOE O 458.1 and are not
addressed in this training. Some of the provisions of 10 CFR 835
Subpart L:
Specifies conditions for material and equipment in contamination
areas (CAs), high contamination areas (HCAs), and airborne
radioactivity areas (ARAs) to be released to a controlled area
Addresses movement of material and equipment with removable
surface contamination, on-site from one radiological area for
immediate placement in another radiological area
Specifies conditions for material and equipment with fixed
contamination to be released for use in controlled areas outside of
radiological areas
Control of Areas (10 CFR 835.1102) addresses
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Prevention of inadvertent transfer or removal of contamination
to locations outside radiological areas under normal conditions
Section 22
Where contamination levels exceed values in Appendix D, the
area is controlled commensurate with hazards
Areas with fixed contamination exceeding radioactivity values
may be located outside radiological areas, provided certain
controls, conditions, or provisions are met
Personnel monitoring for contamination upon exiting CAs,
HCAs, or ARAs
Use of protective clothing in CAs and HCAs
M. Subpart M - Sealed Radioactive Source Control (Show OT 2.30)
Sealed radioactive sources shall be used, handled and stored in a
manner commensurate with the hazard.
Specifies values (Appendix E) for sources by isotope and Curie content
which must be inventoried and leak tested at intervals not to exceed six
months.
N. Subpart N - Emergency Exposure Situations (Show OT 2.31)
This subpart addresses:
Employees who have exceeded dose limits as result of authorized
emergency exposure
Nuclear accident dosimetry (Show OT 2.32)
Individuals whose occupational exposures have exceeded any
limits as a result of an authorized emergency exposure may be
permitted to return to work provided that certain conditions are
met.
Nuclear accident dosimetry
Nuclear accident dosimetry involves installations possessing
sufficient quantities of fissile material to constitute a critical mass,
and shall include;
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Method to conduct initial screening of personnel involved
Method and equipment for analysis of biological materials
A system of fixed nuclear accident dosimeter units
Personal nuclear accident dosimeters
(Summarize lesson.
Review objectives.
Ask for questions.)
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Administrative Policies and
Procedures
Objectives:
Upon completion of this training, the student will be able to:
1. Identify the radiological controlled areas a person should be allowed to enter
after successfully completing General Employee Radiological Training,
Radiological Worker I training, and Radiological Worker II training.
2. List five actions used to increase the awareness level of workers relating to
proper radiological work practices.
3. Identify three conditions when a “Stop Radiological Work” should be
initiated.
4. Identify the actions that should be performed, prior to recommencement of
work, after a “Stop Radiological Work” order has been initiated.
5. Identify when termination bioassay monitoring should be conducted.
Training Aids:
Overhead Transparencies (OTs): OT 3.1 - OT 3.12 (May be supplemented or
substituted with updated or
site-specific information)
Handout
Equipment Needs:
Overhead projector/Screen
Flip chart/Markers
Masking tape
Student Materials:
Student’s Material
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Administrative Policies and
Procedures
References:
U.S. Department of Energy, Order 5480.20A, Personnel Selection, Qualification,
and Training Requirements for DOE Nuclear Facilities, 1994.
U.S. Department of Energy, 10 CFR Part 835, Occupational Radiation Protection.
U.S. Department of Energy, Radiological Control, DOE-STD-1098-2008.
Section 23
Lau & Shani, Behavior in Organization, 1992.
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I. Introduction
(Introduce module. State objectives. Show OT 3.1.) (Show OT 3.2)
II. A. The RadCon Standard (DOE-STD-1098-2008) is a guidance document
that describes DOE's policy and expectations for an excellent radiological
control program, including radiation safety training for general employees,
radiological workers and Radiological Control Technicians (RCTs).
Radiological safety training (Show OT 3.3)
General Employee Radiological Training
Personnel who may routinely enter controlled areas unescorted or receive
occupational exposure during access to controlled areas should receive
General Employee Radiological Training (GERT). GERT is generally
recommended for all employees.
Radiological Worker I and II
(Obj. 1 Identify the radiological controlled areas a person should be allowed to
enter after successfully completing General Employee Radiological Training,
Radiological Worker I training, and Radiological Worker II training.)
Workers whose job assignments require access to radiological buffer
areas and radiation areas should complete Radiological Worker I training.
Workers whose job assignments involve entry to the following areas
should complete Radiological Worker II training:
– Radiological buffer areas
– Radiation areas
– High and very high radiation areas
– Contamination and high contamination areas
– Soil contamination areas
– Airborne radioactivity areas
(Review: “Radiological Control Training Guidelines” (RadCon Standard, Table
3-1, page 3-15) Insert site-specific information.)
Radiological Worker I training is not a prerequisite for Radiological
Worker II training.
The following apply to specialized radiological worker training:
– Completed for nonroutine operations or work in areas with
changing radiological conditions
– Taken in addition to Radiological Worker II training
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– Recommended for personnel planning, preparing, and
performing jobs that have the potential for high radiological
consequences
RCTs – Chapter 6 of the Radiological Control Standard provides
guidance on training of RCTs.
B. Radiological Controls Program (Show OT 3.4)
Line managers who manage, supervise or provide oversight of a
Radiological Controls Program should receive training that is helpful in
dealing with workers who have anxiety about radiation. This training
should include the following:
Guidance on handling such personnel interactions
Emphasis on being factual
Fundamentals of communicating risks
Importance of keeping management informed
(Insert site-specific training provided to managers.)
C. Radiological operations (Show OT 3.5)
Conduct radiological operations in a manner that controls the spread of
radioactive materials, reduces exposure of the work force and the general
public, and utilizes a process that seeks exposure levels that are as low as
reasonably achievable.
Responsibilities
1. Supervisors should ensure that orientation, training, and indoctrination
reinforce rules and guidelines for each worker to minimize radiation
exposure and control radioactivity.
Section 24
2. Prevention of the spread of radioactivity is less costly than
remediation. Management should be willing to accept changes that
will improve radiological control and should foster this mindset
throughout the organization.
3. Supervisors and managers should encourage the work force to
identify radiological control deficiencies and concerns. Prompt action
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should be taken to address and eliminate identified issues and
prevent recurrence. (Show OT 3.6 Emphasize prompt action.)
4. In cases where the work force does not have the required level of
sensitivity for radiological work practices, additional management
attention is needed to ensure the proper outcome. Actions should
include the following:
More direct line supervision
Curtailment of work schedules
Deferral of work
Addition of extra radiological control personnel
Conduct of additional training
5. As part of their normal work review, work supervisors should
periodically review ongoing jobs to ensure prescribed radiological
controls are being implemented and periodically monitor those work
areas.
6. Identify conditions that could lead to or promote the spread of
contamination, or unsafe work and ensure corrections are
implemented on a priority basis
(Insert site-specific information.)
7. “Stop Radiological Work” authority (Show OT 3.7)
“Stop Radiological Work” authority may be initiated for the
following reasons:
(Reference RadCon Standard Article 345 Obj. 3 Identify three conditions when a
“Stop Radiological Work” should be initiated.)
– Radiological controls are inadequate.
– Radiological controls not being implemented.
– Radiological control hold points not being satisfied.
– Job scope changed.
– Area conditions changed.
Once stopped, work should not be resumed until proper
radiological controls have been established.
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Resumption of radiological work should have the approval of the
manager responsible for the work and the Radiological Control
Manager.
(Insert site-specific information. Obj. 4 Identify the actions that should be
performed, prior to recommencement of work, after a “Stop Radiological Work”
order has been initiated.)
D. Radiological measurements (Show OT 3.8)
Ensure radiological measurements, analyses, worker monitoring results,
and estimates of public exposure are accurately and appropriately made
and documented.
1. Personnel radiological records include the following:
(Review:“Personnel Radiological Records” (RadCon Standard, page 7-5))
Records of doses received by individuals monitored
Records containing information to identify individuals
External dose records shall include the following:
– Applicable extremity, skin, eye, and whole body dose results
– Evaluations resulting from anomalous dose results
– Dose reconstruction
– Evaluation of nonuniform doses
Internal dose records shall include the following:
– Applicable whole body and lung counting results
– Applicable bioassay results
– Dose assessment
Records of equivalent dose to any organ
Total effective dose on annual bases
Equivalent dose to embryo/fetus of declared pregnant worker
Lifetime occupational dose, including cumulative total
Section 25
Documented counseling of persons about radiological concerns
Records for authorization to exceed administrative control levels
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Emergency dose (shall be accounted for separately, but
maintained with individual’s record)
Records of dose to skin caused by contamination
Radiological incidents
Radiological safety concerns, formally investigated
Records of formal written declaration of pregnancy
2. Internal monitoring
(Emphasize how it is important to integrate several aspects of the radiological
control program into an effective internal dose monitoring program. These
include: bioassay (selection of participants and isotopes to be monitored), air
monitoring, and contamination monitoring (both personnel and area).)
Baseline bioassay monitoring of personnel who are likely to
receive intakes resulting in a committed effective dose of 100
mrem or more should be conducted. This must be done before
beginning any work that may expose them to internal radiation
exposure.
Management should require termination bioassay monitoring when
a person who participated in the bioassay program terminates
employment or concludes work that involves the potential for
internal exposure.
Bioassay analyses (routine bioassay) are performed at site
specified frequencies following certain work activities
(Discuss site program for routine bioassay.)
Bioassay analyses (special bioassay) should be performed when
any of the following occur: (Show OT 3.9)
(Obj. 5 Identify when termination bioassay monitoring should be conducted.)
Facial or nasal contamination is detected that indicates the
potential for internal contamination.
Airborne monitoring indicates the potential for intakes
exceeding 100 mrem committed effective dose.
Any contaminated wound.
Contamination on protective clothing, skin or facial area or
unplanned spread of contamination on accessible areas
above site specified thresholds. (Show OT 3.10)
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Detectable contamination inside a respirator after its
removal.
The Radiological Control Organization directs that bioassay
analyses be performed when an intake is suspected.
(See page 55 of DOE-STD-1121-98 for recommended values for
thresholds.)
E. Reducing exposure
Incorporate dose reduction, contamination reduction, and waste
minimization features into the design of new facilities, or modification of
existing facilities. (Show OT 3.11)
1. Maintenance and modification plans and procedures should be
reviewed to identify and incorporate radiological requirements, such
as the following:
Engineered controls
Dose reduction considerations
Contamination reduction considerations
(Review: “Checklist for Reducing Occupational Radiation Exposure” (RadCon
Standard, page 3-29))
F. Radiological performance (Show OT 3.12)
Establish and maintain, from the lowest to the highest levels, line
management involvement and accountability for Departmental
radiological performance.
1. Radiological performance goals
(Show and discuss site-specific goals.)
Goals are intended as a measure of and a motivation for
improvement, and not an end in themselves.
Section 26
Performance goals should have these characteristics:
– Measurable
– Achievable
– Auditable
– Challenging
– Meaningful in promoting improvement
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Goals need to be developed primarily by those responsible for
performing the work.
Site-specific goals need to be developed.
(Identify other site-specific goals. List on flip chart.)
2. Performance indicators
Performance indicators should be used as tools to assist
management in focusing their priorities and attention.
Performance indicators should be tracked and trended for
the prior 12-month period.
To promote worker awareness of their radiation exposure
status, selected indicators related to their work group should
be posted in the workplace.
Site-specific indicator status reports should be tracked.
(If available, show a recent site-specific indicator status report.
Summarize lesson.
Ask for questions.
Review objectives.)
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Fitness for Duty
Objectives:
Upon completion of this training, the student will be able to:
1. Identify ways to verify employee- and operation-specific training requirements
for personnel.
2. Identify methods to determine an employee's dose status.
3. Describe how the Lifetime Control Level is calculated for radiological workers.
4. Describe the requirements in order for a female worker to be considered a
declared pregnant worker.
5. Identify the dose limits established for a declared pregnant worker.
6. List the three main conditions an employee must meet in order to be
issued respiratory protection equipment.
7. Identify the actions that should be taken if intakes of radioactive materials
are indicated that could result in a committed effective dose of
greater than 100 mrem.
8. Describe the conditions that can induce heat stress and other adverse
physical conditions for radiological workers.
9. Describe the actions that should be taken if a worker exhibits symptoms of
heat stress or other adverse stress conditions while working in a radiological
area.
Training Aids:
Overhead Transparencies (OTs): OT 4.1 - OT 4.12 (May be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
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Student Materials:
Student’s Material
Student Handouts
DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Fitness for Duty
References:
U.S. Department of Energy, 10 CFR Part 835, Occupational Radiation Protection.
U.S. Department of Energy, Radiological Control, DOE-STD-1098-2008.
Lau & Shani, Behavior in Organization, 1992.
Module 4–2
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DOE-HDBK-1130-2008
Instructor's Material
I. Introduction
(Introduce module. State objectives. Show OT 4.1.) (Show OT 4.2) (Show
OT 4.3) (Show OT 4.4)
II. Overview
Section 27
The workers participate in the organization radiation protection program and
have some responsibility to protect themselves, however, they must rely
upon the organization to provide a safe work environment, minimize
exposure, and provide adequate training.
The first line supervisor has the final responsibility that supervised workers
are fit and prepared for their work in radiological areas. Supervisors should
not assume that the organization has assured that the worker is adequately
trained and physically and mentally ready for the work. This responsibility, in
addition to seeing that the job or task is completed properly, is placed upon
the supervisor.
III. Work force
To maintain a healthy work force, it is imperative that individual employees
arrive at the workplace mentally and physically prepared to act in a safe and
effective manner. Problems that raise doubt regarding an employee's ability
to act in a safe manner must be dealt with in a straightforward process that
encourages the employee to seek the help needed and ensure that the
safety of all workers is maintained. Such problems may include alcoholism,
drug abuse, mental health disorders, and personal crises.
For the radiological workers, there are additional considerations that may
also affect a worker's fitness for duty. These may include the ability to wear
respiratory protection, pregnancies, exceeding exposure limits, and heat
stress during work in protective clothing. Supervisors of radiological workers
must be conscious of these considerations to ensure that their employees
are able to perform radiological work in a safe and effective manner.
IV. Training/qualification (Show OT 4.5)
(Obj. 1 Identify ways to verify employee- and operation-specific training
requirements for personnel.
Review: “Relationship between Radiological Control Technicians and Workers”
(RadCon Standard, article 144))
Radiological workers should be sufficiently qualified to recognize the
symptoms of deteriorating radiological conditions and seek advice from
Radiological Control Technicians and their supervisors.
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Training requirements have been established to ensure that personnel have
the training to work safely in and around radiological areas and to maintain
exposure as low as reasonably achievable.
Examinations for Radiological Worker I and II training, and Radiological
Control Technician Qualification shall be used to demonstrate satisfactory
completion of theoretical and classroom material. Examinations should be
written. However, alternatives may be used to accommodate special needs.
(Review: “General Requirements” (RadCon Standard, article 613))
In addition, workers may need job-specific radiological training including
specific procedure and hands-on tools/equipment training.
(Instructor may want to insert site-specific alternatives, if any.)
Formal records of training and qualification shall be readily available to first
line supervisors of involved personnel to aid in making work assignments.
(RadCon Standard, article 725)
V. Dose limits and control levels
A. General
Dose limits provided in Subpart C of 10 CFR 835 shall not be exceeded.
Administrative control levels are established to maintain personnel
radiation exposure well below regulatory dose limits. These levels are
multitiered. Increasing levels of authority are required to approve higher
administrative control levels. Special consideration must be taken for
radiological workers who are approaching administrative control levels.
Section 28
(Review: “Administrative Control Level” (RadCon Standard, article 211)
Obj. 2 Identify methods to determine an employee’s dose status.
Insert site-specific administrative control levels here.
Insert site-specific information as to how supervisors can ascertain the dose status
of their employees.)
B. Lifetime control levels (Show OT 4.6)
(Review: “Lifetime Control Levels” (RadCon Standard, article 212))
To administratively control a worker's lifetime occupational radiation
exposure, a lifetime control level of N rem should be established where N
is the age of the person in years. Special control levels (see Article 216
of RadCon Standard) should be established for personnel who have
doses exceeding N rem.
(Obj. 3 Describe how the Lifetime Control Level is calculated for radiological
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workers. Insert site-specific levels here.)
A special control level for annual occupational exposure shall be
established for each person with a lifetime occupational dose exceeding
N rem. The special control level should not exceed 1 rem in a year and
should allow the person's lifetime occupational dose to approach N rem
as additional occupational exposure is received.
C. Medical exposures
(Site-specific policy for workers receiving medical exposures may be added.)
An employer should be attentive to special circumstances of employees,
such as those undergoing radiation therapy, and should establish an
appropriate special control level.
D. Off-site exposures (Show OT 4.7)
(Review: “Occupational Dose Limits” (RadCon Standard, page 2-5).)
Workers are responsible for notifying radiological control personnel of off-
site occupational exposures so that individual dosimetry records can be
updated.
(DOE administrative levels apply to DOE activities (Art. 211 of the RadCon
Standard), while the lifetime control level applies to all occupational exposures.
Your site policy should be checked regarding doses incurred from non-DOE
activities (e.g., Nuclear Regulatory Commission (NRC) or hospital work).)
VI. Declared pregnant employee (Show OT 4.8)
(Review: “Embryo/Fetus Dose Limits” (RadCon Standard, article 215))
A. Notification of employer
After a female radiological worker voluntarily notifies her employer in
writing that she is pregnant, for the purposes of embryo/fetal dose
protection, she shall be considered a declared pregnant worker.
Declarations of pregnancy may be revoked, in writing, by the declared
pregnant employee at any time.
1. The employer should provide the option of a mutually agreeable
reassignment of work tasks, without loss of pay or promotional
opportunity, so that further occupational radiation exposure is unlikely.
(Obj. 4 Describe the requirements in order for a female worker to be considered a
declared pregnant worker.)
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2. For a declared pregnant worker who chooses to continue working as
a radiological worker the following apply:
(Obj. 5 Identify the dose limits established for a declared pregnant worker.)
The dose limit for the embryo/fetus for the entire gestation period
shall be no greater than 500 mrem.
Substantial variation above a uniform exposure rate that would
satisfy the limits shall be avoided (e.g. 50 mrem/month).
Section 29
3. If the dose to the embryo/fetus is determined to have already
exceeded 500 mrem when a worker notifies her employer of her
pregnancy, the worker shall not be assigned to tasks where additional
occupational radiation exposure is likely during the remainder of the
gestation period.
VII. Respirator protection (Show OT 4.9)
There are three main requirements that must be met by personnel prior to
being issued a respirator. Personnel must be trained, fitted, and medically
qualified to wear that specific type of respirator. Training and qualification
testing shall be performed annually.
(Review: “Respiratory Protection Program Requirements” (RadCon Standard,
page 5-10))
A. Respirator use
While using respiratory protection, personnel are expected to:
(Obj. 6 List the three main conditions an employee must meet in order to be
issued respiratory protection equipment.
Review: “Use of Respiratory Protection” (RadCon Standard, article 533))
1. Perform fit checks of their respirators to ensure a proper seal before
entering areas requiring respirator use.
2. Be clean shaven in the area of the fit.
3. Use corrective lenses, if needed, that are approved for respirators.
4. Be instructed to leave the work area when experiencing respirator
failure.
5. Be instructed to remove their respirators to avoid life-threatening
situations when exiting an area after respirator failure.
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B. Exposure to airborne radioactive materials (Show OT 4.10)
(Review: “Handling Individuals Exposed to Airborne Radioactivity” (RadCon
Standard, article 543))
10 CFR 835 establishes dose limits which includes internal dose from
inhaling radioactive material. Use of engineering and administrative
controls and proper use of personal protective equipment results in most
planned internal doses being very low.
In cases of unplanned internal doses, potential intakes of radioactive
material are suspected when personnel without respiratory protection are
exposed to airborne radioactive materials or when respiratory protection
has been compromised. If unplanned intakes of radioactive material are
indicated that could result in a committed effective dose of 100 mrem or
more, the following actions should be taken:
(Obj. 7 Identify the actions that should be taken if intakes of radioactive materials
are indicated that could result in a committed effective dose greater than 100
mrem.)
1. Identify personnel potentially exposed.
2. Determine the duration of potential exposure to airborne radioactivity.
3. Have dose evaluated prior to permitting the worker to return to
radiological work.
VIII. Adverse work conditions
A. Heat stress (Show OT 4.11)
(Review: “Heat Stress” (RadCon Standard, article 534))
Heat stress may result from working in areas of high temperature,
humidity, and radiant heat; working in protective clothing; and using
respirators, particularly where other protective equipment is required.
Heat stress has occurred at ambient temperatures less than 70oF when
multiple sets of protective clothing or plastic suits were in use or
strenuous work was involved.
(Obj. 8 Describe the conditions that can induce heat stress and other adverse
physical conditions for radiological workers.)
1. Heat stress controls should be addressed in the planning stages for
work.
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2. Recommended work time limits and use of body cooling devices
should be considered to reduce heat stress.
3. Job supervisors should inform their personnel of heat stress
precautions prior to work on job assignments where heat stress may
be a factor.
4. (Show OT 4.12) If a person begins to feel symptoms of heat stress,
the person should immediately notify the nearest coworker, exit the
area, remove personal protective equipment, notify the supervisor,
and rest in a cool area. In such cases, medical assistance should be
provided.
(Obj. 9 Describe the actions that should be taken if a worker exhibits symptoms of
heat stress or other adverse stress conditions while working in a radiological
area.)
B. Other adverse physical conditions
(Review: “Contaminated Wounds” (RadCon Standard, article 542) Instructor
may want to insert any site-specific policies regarding adverse conditions such as
cold weather, etc.)
Medical treatment of injuries takes precedence over radiological
considerations. A worker with a contaminated injury should receive
treatment by medically qualified personnel. An assessment should be
made on the need for bioassay monitoring or further medical treatment.
Until this assessment is completed, work restrictions may be needed.
The worker should be counseled promptly on the medical and
radiological implications resulting from the contaminated wound.
IX. Group activity
(Divide class into smaller groups (3-5 people). Refer students to page 1 of
handouts and allow them to determine the appropriate job assignments for their
personnel based on an assessment of each individual's fitness to perform each
task.
Discuss answers.
Summarize lesson.
Ask for questions.
Review objectives.)
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Interpersonal Communication
Objectives:
Upon completion of this training, the student will be able to:
1. Identify the components of a communication process model.
2. Describe filters/barriers that distort the communication process.
3. Identify active listening behaviors.
4. Describe the various portions of a conflict resolution model presented in class.
5. Describe some of the key elements in communicating radiation risks to
workers.
6. Identify the skills required to conduct a pre-job briefing.
7. Identify the benefits of a successful critique/lessons learned program as
described in the Radiological Control Standard.
Training Aids:
Overhead Transparencies (OTs): OT 5.1 - OT 5.10 (May be supplemented or
substituted with updated or
site-specific information)
Exercise (optional)
Equipment Needs:
Overhead projector
Screen
Flip chart
Markers
Masking tape
Student Materials:
Student’s Material
Student Handouts
References:
Lau & Shani, Behavior in Organization, 1992.
U.S. Department of Energy, 10 CFR Part 835, Occupational Radiation Protection.
U.S. Department of Energy, Radiological Control, DOE STD-1098-2008.
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I. Introduction (Introduce module. State objectives. Show OT 5.1.) (Show OT
5.2)
Section 31
II. Communication
(Ask students for their definition of communication. Write responses on flip chart.
Communication is the process of transferring information from one person to
another.)
A. Communicating is one of the basic functions human beings must perform.
Since it is basic, often it is assumed that everyone communicates
proficiently. That is not always the case. Often, everyday problems can
be traced back to communication as a primary or contributing cause.
III. Interpersonal communication
A. Communication styles
Studies show that people tend to communicate in a style that best suits
their given personality. There are many personality trait assessments
available that give us a better understanding of who we are. Some
examples are Myers-Briggs, Herman’s Brain Dominance, and Birkman
Methods.
B. The communication process
(Refer students to page 2 of handouts, “The Communication Process.” Obj. 1
Identify the components of a communication process model. Use an example to
“walk” through the process from sender to receiver.)
1. Sender’s filters
The sender has an idea that must be transmitted to a receiver.
Perceptions, assumptions, attitudes, and past experiences are
filters through which the sender’s messages must travel. These
can distort the idea.
The sender’s message is the focus of the process. It must have
an objective (i.e., deliver information, motivate, stimulate,
get/provide feedback). It must be concise, logical, and clear.
(Site-specific communication models may be substituted.)
2. Receiver’s filters
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Similar to the sender, the receiver has his/her own filters that can
also distort the message.
3. Understanding the message
It is not the logic of the sender’s message that is important, but the
logic of the received message. The sender must consider how his
message will sound to the receiver.
The accuracy of message interpretation depends upon how well the
sender projects the intent, motivation, values, and emotions of the
message.
4. Medium
The medium used for communication can definitely distort the
message.
(Types: Oral, written, symbols, gestures, etc.
Introduce exercise.
Exercise should be approximately 30 min., including the debriefing.
Participant activity - The objective of the activity is to have each member realize
barriers associated with the communication process.
Split the group into pairs.
Have each pair designate a sender and a receiver. Have the sender and
receiver sit back-to-back.
General rules
– The sender must provide instructions to the receiver in order to reproduce
a predetermined geometric shape.
– The sender must not show the receiver the shape.
– The receiver or sender cannot provide any feedback (verbal or physical)
to his/her partner.
– Set a time limit of 3 to 5 minutes.
– Be sure to point out that the drawings should match exactly.
After each pair is finished, have them compare drawings.
Debrief the exercise by asking the senders and receivers these questions:
– How did you feel about your role during the exercise?
– What barriers were imposed on you?
– How could you have done better?
Write responses on the flip chart. Encourage students to write answers in the
Student’s Material.)
C. Barriers/filters (Show OT 5.3)
1. Five types of communication barriers/filters
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(Obj. 2Describe filters/barriers that distort the communication process. Relate the
barriers/filters to the activity above.)
There are two categories of social barriers:
– Verbal - The use of words with emotional content can interfere
with the reception of the intended message (e.g., politics,
religion, race).
– Nonverbal - Nonverbal barriers are usually involuntary or
symbolic (e.g., clothes, grooming, or office setup).
Physical barriers include elements such as noise, distance, data
overload, time, media, handicaps, etc.
Psychological barriers include elements such as tendency to
smother information, difference in opinion, lack of trust,
assumptions, attitudes, stress, and attention level.
(Give examples.)
Individual barriers include elements such as needs, beliefs,
education, religion, socioeconomics, culture, values, and self-
concept.
Neurological barriers occur as a result of the way the nervous
system filters, distorts, deletes, and interprets information.
D. Listening skills
1. What is the role of the receiver in regard to listening?
(List roles on flip chart. Encourage students to write responses in the Student’s
Material.
Responses should include the following:
By your actions, show interest in the individual to whom you are listening.
Show your desire to listen.
Take time to listen, and be sure you are ready to listen.
Try to learn something. Be positive rather than negative.
Get the whole message. Ask the sender to repeat or clarify. Ask who,
what, why, where, when, and how.
Do not interrupt the sender in mid-sentence. Wait for an appropriate
pause.
Concentrate on listening. Ward off distractions.)
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2. Types of listening
(Ask students for the types of listening. List answers on flip chart. Answers
should include the following:
Appreciative: Hearing what is being said
Discriminating: Sorting stimuli
Critical: Judging
Comprehensive: Understanding
Empathetic: Putting yourself in the sender’s position)
3. Deterrents to effective listening
(Ask students for their responses. List on flip chart. Answers should include the
following:
Assuming the subject is unimportant
Mentally criticizing the speaker’s delivery
Getting over stimulated when opposing an idea
Overreacting to certain words or phrases
Listening only for facts, not overall meaning
Permitting the speaker to be inaudible or incomplete
Avoiding technical messages
Daydreaming
Dual focusing)
4. Elements of active listening
(Obj. 3Identify active listening behaviors.
Ask participants for their responses. List on flip chart. Answers should include
the following:
Pay close attention.
Label nonverbal “clues” (“You appear upset.”).
Put the speaker’s words into your own words.
Ask open-ended questions for clarification.
Use prompts for nonverbal reinforcement.
Try to empathize and really feel what the other is feeling.)
E. Dealing with confrontation
(Obj. 4 Describe the various portions of a conflict resolution model presented in
class.)
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Section 33
Whenever people come together in any environment, there will be
opportunities for confrontation. Confrontation can either stimulate or
demoralize individuals. As a supervisor, it is essential that you learn how
to deal with these situations appropriately.
Following is a model that illustrates the various approaches to deal with
conflict.
Accommodation Collaboration
Cooperation Compromise
Assertion Competition
Assertion
1. There are many styles of conflict management: (Show OT 5.4)
(Discuss the conflict management styles.)
Avoidance - This style is considered the least cooperative and the
least assertive. In this situation, conflict is not addressed. As a
short-term strategy, it may work, but as a permanent strategy,
problems may never get solved.
Accommodation - This style is characterized by cooperative,
unassertive behavior. It means to place the needs and concerns
of others above your own needs and concerns.
Competition - This style is considered the most assertive. It
reflects one's desire to meet his or her needs at the expense of
others.
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Compromise - This style is between competition and collaboration
and avoidance and accommodation. The objective is partial
fulfillment of the needs, concerns, and goals of all parties
concerned. The solution should be mutually acceptable and
partially satisfying to everyone involved. Nobody wins and nobody
loses.
Collaboration - This style uses both cooperation and assertiveness
in an effort to satisfy the needs of all parties concerned.
Collaboration includes the following:
– Acknowledgment that conflict exists
– Identification and acknowledgment of others’ needs, concerns,
and goals
– Identification of alternative resolutions and consequences for
each party involved
– Selection of the alternative that meets the needs and concerns
of all parties
– Implementation of the alternative selected
2. Effective conflict resolution (Show OT 5.5)
For effective conflict resolution, establish rules in advance. Rules
might include the following:
When controversy arises, have one party who is not directly
involved state the issues before further discussion is allowed.
All parties must agree on the problem and specifically identify the
common goal or solution.
Each party must be able to restate the other's position to the
satisfaction of the individual before any evaluation discussion is
allowed.
All parties will identify and agree upon the criteria to be used in
resolving the controversy.
In conflict resolution, it is important to focus on issues--not people.
When conflicts arise, keep the focus on the issues and not on the
personalities involved.
The key to reaching collaboration is effective communication. The
key to communication is trust, and the key to trust is honesty.
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IV. Risk communication
(Obj. 5 Describe some of the key elements in communicating radiation risks to
workers.)
A. Communicating risk
Due to the continuing concerns related to low-level radiation exposure
and health effects, managers should be trained to deal with the
perceptions that personnel have concerning radiation risks. Managers
and first line supervisors should ensure that workers understand the
fundamentals of radiation, its risks, and their role in minimizing exposure.
Section 34
It is not sufficient to rely solely on regulatory limits for establishing or
defining acceptable work practices and work environments.
Some personnel, such as those who may have internal deposition of
radionuclides from prior years, are concerned about future exposures.
Such instances warrant special attention on the part of the manager.
Counseling with such personnel should be the preferred way to consider
relevant factors. In some cases, special control levels should be applied.
B. Motivation to achieve excellence in radiological control (Show OT 5.6)
1. No one should be exposed to radiation unless an overall benefit from
the associated activity is expected to be realized. As a corollary, the
benefit should be maximized and the risk (exposure) minimized.
2. Some workers and members of the public perceive any radiation
exposure as an unduly hazardous risk. Making an effort to reduce
doses and documenting the actual doses received can reassure these
people and reduce the prospects of litigation.
3. A side effect of trying to reduce doses is often an increase in
efficiency and a decrease in incidents in performing radiological jobs,
since greater planning is required. Records of past similar jobs can
assist in planning future jobs and reduce dose further. (Show OT 5.7)
C. Fostering positive worker attitudes toward achieving excellence
Worker attitudes are key to radiological performance. A positive attitude
makes a person take that one extra step. When everyone’s attitude
embraces radiological excellence, and the performance is excellent, the
program will reduce exposure and environmental burdens.
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(Discuss students’ perception of workers’ responsibilities. List on flip chart.
Encourage students to write answers in the Student’s Material.
Answers may include the following:
Workers understand that they are responsible for control of radiological
work that they perform.
Workers understand the risks of radiation. They convey confidence to
family and others.
Improving attitude is part of training.
Radiological control is perceived as integral to the job.
Mechanisms exist to improve worker attitudes, such as a Radiological
Awareness Committee and the use of performance indicators.
Constant improvement in radiological performance is occurring.
Cooperation between the work force and radiological control
organization is stressed. Radiological control cannot be left solely to the
Health Physicists.)
D. Reducing risk (Show OT 5.8)
The following are elements of a radiological control program that help
reduce risk:
1. Training must be aimed at what the worker should know in order to do
his/her job rather than passing a quiz. The training needs to be
documented and recorded accurately.
2. Records and reports are needed for every aspect of the program.
Records must be accurate and understandable because they may be
used to recreate events that are questioned in the future. Those who
fill out, file, review, or otherwise handle records must understand their
use and importance.
3. Radiological deficiencies and improvements must be used to develop
plans that will further promote radiological excellence. Self-
assessments, use of critiques, thorough investigations, and a
willingness to be self-critical and accept responsibility are needed.
When a radiological deficiency is identified, there should be an honest
effort to understand, correct, document, and follow it to closure.
Trending deficiencies aids in planning where resources are to be
spent to make improvements.
Section 35
V. Meetings/briefings/critiques (Show OT 5.9)
(Ask students what types of meetings they conduct as supervisors. List responses
on flip chart.)
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A. Running an effective meeting
In today’s business environment, meetings have become a way of life.
Today’s work force spends a great deal of time “stuck” in meetings. It is
essential for those people leading these meetings to become proficient in
chairing a meeting. The following are considerations when conducting a
meeting:
1. Objective(s)
Is a meeting the best way to handle this? If not, don’t have a
meeting.
What do you want to achieve by the end of the meeting? Ensure
that participants are aware of your expectations.
2. Persons attending?
Who needs the information?
Who can contribute?
Who would expect to be involved?
3. Amount of prior notice
How much preparation time is required?
Should any pre-work be sent? Pre-work (i.e., history, data,
graphs, etc.) can cut down on the time spent in the meeting.
4. Agenda
Establish a reasonable amount of work that you expect can be
accomplished in the specified time.
Provide the agenda to participants prior to the meeting.
Have enough information in the agenda so that people understand
what discussion topics are going to be covered.
Establish time limits for each item and attempt to meet them.
5. During the meeting
Determine who will be responsible for the meeting minutes.
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Review the agenda and emphasize time limits.
Keep discussions focused on the topics associated with the
meeting.
If action items are established, ensure individuals understand what
is to be accomplished and when it is required to be done.
Summarize upon completion of the meeting.
Prepare and distribute the meeting results
B. Pre-job briefings
(Obj. 6 Identify the skills required to conduct a pre-job briefing. Ask students
when a pre-job briefing should be held.)
“Planning the work” is an essential part of an effective Integrated Safety
Management program. During pre-job work planning meetings, all
appropriate safety disciplines must be engaged to ensure that all work
hazards are adequately addressed. The following addresses pre-job
briefings for radiological controls. Other work hazards should be
integrated using a similar approach.
(Review: “Pre-job Briefings” (RadCon Standard, article 324))
Article 324 of the RadCon Standard recommends pre-job briefings be
held prior to the conduct of work anticipated to exceed the site ALARA
trigger levels. (This practice further establishes excellence in regard to
radiological operations.)
1. The pre-job briefing should be conducted by the cognizant work
supervisor. Workers and supervisors directly participating in the job,
cognizant radiological control personnel, and representatives from
involved support organizations should attend the briefing. A summary
of the topics discussed and attendance at the pre-job briefing should
be documented.
2. As a minimum, the pre-job briefing should include the following:
Scope of the work to be performed
Radiological conditions of the work place
Procedural and Radiological Work Permit requirements
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Special radiological control requirements
Radiological limiting conditions, such as contamination or radiation
levels that may void the RWP
(Add site-specific information.)
Radiological control hold points
Communication and coordination activities with other groups
Provisions for housekeeping and final cleanup
Emergency response provisions
C. Post-job evaluations
During the conduct of radiological work and the handling of radioactive
materials, abnormal events may occur that could indicate a weakness or
area of programmatic breakdown of radiological controls. Prompt,
consistent gathering of facts related to such events is required to satisfy
reporting and investigation requirements and to formulate corrective
actions to prevent recurrence.
In addition, successful performance or completion of unique activities
should be evaluated to identify and incorporate appropriate lessons
learned. Analysis of the facts should reveal areas where improvements
can be made or identify methods to prevent the recurrence of undesired
results.
1. (Show OT 5.10) Critiques are meetings that document a chronological
listing of the facts of an event. The purpose of the critique is not to
assign blame. The following guidelines should be followed regarding
critiques/occurrence investigations:
(Obj. 7 Identify the benefits of a successful critique/lessons learned program as
described in the Radiological Control Standard. Critiques are described in the
RadCon Standard, article 351.)
Critique meetings should be conducted for successes and
abnormal events.
Properly trained critique leaders should facilitate the critique
process.
Critique meetings should be conducted as soon as practical after
the event or situation is stabilized or completed.
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Minutes of the meeting must be kept.
All who can contribute should attend.
Supporting materials should be brought to the critique.
Refer to RadCon Standard Article 351 for a complete list.
2. Post-job ALARA reviews may take the form of a debriefing or may be
a review by one or more designated individuals and should be
performed in the following cases:
After completion of a nonroutine radiological job or operation
After completion of a nonroutine or complex radiological job or
operation if a pre-job formal radiological review was required or if
an ALARA trigger level was exceeded in the course of the work
(Ask when this is required and what these levels are at their sites (e.g., as given in
the RadCon Standard).
Sites may add site-specific information depending on the involvement of
supervisors in the post-job ALARA review.
Ask what is done at students’ sites. For example, is the post-job evaluation
performed by the site ALARA group?)
3. Lessons learned are available from post-job reviews, critique minutes,
and occurrence reports (using the Occurrence Reporting and
Processing System [ORPS]). Organizations responsible for
radiological work and line management should evaluate lessons
learned, provide prompt distribution, and incorporate the lessons into
the Radiological Control Program.
(Summarize lesson.
Ask for questions.
Review objectives).
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Problem Analysis and Decision
Making
Objectives:
Upon completion of this training, the student will be able to do the following:
1. Identify problems or decisions faced by supervisors of radiological workers.
2. Identify the components of decision making.
Training Aids:
Overhead Transparencies (OTs): OT 6.1 - OT 6.4 (May be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
Flip chart
Markers
Masking tape
Student Materials:
Student’s Material
Student Handouts
References:
Lau & Shani, Behavior in Organization, 1992.
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I. Introduction
(Introduce module. State objectives. Show OT 6.1.) (Introduce module. State
objectives.)
II. Problem analysis
Supervisors of radiological workers are often faced with critical decisions.
Providing a model for strategic decision making will ensure that these critical
decisions are made in an efficient, rational manner.
A. Stating the mission
In making decisions, the organization’s mission and resultant goals
should always be considered. Decisions should be consistent with the
stated mission of the organization. Prior to decision making, the
organization’s mission must be defined. This may be difficult if the
organization’s mission has not been defined or if there are conflicting
goals within the organization.
(Obj. 1 Identify problems or decisions faced by supervisors of radiological
workers.
Ask students about typical problems faced or decisions made each day as Rad
Worker Supervisors.
Take 15-20 minutes and brainstorm inputs. Encourage students to write
responses in the Student’s Material. List these on flip chart and post for
reference through the rest of the module.
Divide the inputs into categories that are specific to Rad Worker Supervisor and
General Supervisor issues.
Typical inputs:
Contamination
Exposure limits exceeded
Training
Scheduling
Union relations
Promotions
Performance evaluations
Pregnant workers
Rad work permits
Operating procedure interpretation
Budget
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As the rest of the module progresses, refer back to problems identified by students
for examples.)
B. Assessing internal and external environments (Obj. 2 Identify the components of
decision making. Show OT 6.2)
Prior to making a decision or solving a problem, the problem must be
identified and evaluated to ensure that all factors have been included in
the problem statement.
1. Problem diagnosis - Identify the problem.
2. Problem specification - Clarify the specific nature of the problem.
3. Problem framing - Frame the problem in a nonjudgmental way.
4. Problem formulation and reformulation - Restructure the problem in a
way that will make it easier to solve. This can be done by introducing
accurate assumptions.
III. Decision making
A. Developing strategy (Show OT 6.3.)
Once the problem has been identified, alternative solutions must be
generated. A general rule for decision making is as follows: if an
acceptable standard solution is available to a problem, then it should be
used instead of spending time and resources reinventing a solution. If a
standard solution is not available, alternatives must be developed.
Section 38
1. Standard solutions involve using standard operating procedures as
well as available alternatives. Optimization techniques, which include
cost-benefit analysis, are a fundamental part of work reviews and of
radiological analyses for new designs and modifications. For review
of minor or routine activities with low associated doses, a cost-benefit
evaluation may be an intrinsic part of the engineering or operations
review process, so a detailed evaluation is usually not necessary. For
review and planning of major tasks involving higher collective dose
expenditures, a detailed and documented evaluation should be
performed.
2. A simple optimization decision may be made by choosing a low-
current-dose worker instead of a high-dose worker or by declining to
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spend a large sum to save only a few mrem. Note that the writing of
work planning documents (e..g., Radiological Work Permits, work
packages, procedures, etc.) is also an optimization evaluation, in
which the line supervisor must usually concur.
Although the supervisor may not have to perform detailed optimization
evaluation, that information may need to be provided to the person(s)
who will do the evaluation.
Such information will often be based on past operating experience
and may include costs of equipment, person-hours, number of people,
amount of time spent in radiological areas, and even subjective
judgments regarding the feasibility of alternatives.
(Emphasize that if supervisors are involved in cost-benefit analysis,
they should seek additional training in this area.)
B. Limits on decision making
1. When supervisors make decisions, they need to determine how much
power they have in reaching a final decision and how much influence
they have over the process. This is important information when
considering the most appropriate alternatives.
2. The decision maker must also determine what the political impact of
various decisions will be. There may be political reasons why the
most rational solution is not feasible.
3. When selecting an alternative, it is important to consider the
repercussions of not selecting various alternatives. If there is strong
opposition to a selected alternative, the decision maker needs to be
able to support the current decision and explain why the competing
solution is less feasible or less desirable.
C. Making the decision (Show OT 6.4.)
The formal decision analysis will be as follows:
Define alternative courses of action, determine the criteria to use in
evaluating the alternatives, and identify key uncertainties in the
decision.
Assess the consequences of selecting each alternative.
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Assess the probabilities and preferences by looking at the
uncertainties and utilities of each outcome.
Evaluate alternatives in terms of the stated criteria.
Analyze the optimal solutions for any adverse consequences.
Select the most effective solution based on problem analysis.
D. Implementation and controlling execution of strategy
Once a decision is made, the decision will be implemented and
evaluated. It is important to monitor events after implementation to
ensure that the outcomes are as expected. If not, it may be necessary to
revise the original decision. Monitoring outcomes of decisions will also
provide lessons learned for future decision making.
Section 39
E. Case studies
(Refer students to “Internal Exposure and Contamination During Pump
Removal,” page 3 of handouts. Allow approximately 30 minutes.
Read the case and allow a few minutes for students to review the facts. Facilitate
discussion and application by working through the steps on the flip chart. Allow
15-20 minutes for discussion of this case.
Using the decision-making model, solicit inputs from the class for each step:
1. Alternative courses of action might include cutting the pump mount bolts,
repairing the pump in place, or removing the mounting plate.
2. Assess the consequences of each alternative (e.g., possible damage to the
pump, etc.).
3. Examine the uncertainties and utilities of each outcome. Can the bolts be
cut without damage? Has the pump ever been repaired in place?
4. Evaluate alternatives.
5. Analyze optimal solutions for any adverse consequences. Should possible
hidden contamination have been considered? What about records?
6. Select the most effective solution.
Refer students to “Fire in a Contaminated Cutting Facility,” page 4 of handouts.
Suggest they take 5-10 minutes to review the case and 15-20 minutes to discuss
the alternatives.
The class will then divide into small groups and discuss the second case. Each
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group will select a spokesperson to present the group’s decision and explain the
process to the class.
Each spokesperson will then briefly outline his/her group’s decision. The
instructor should act as a facilitator at this point, keeping discussion going and
on the subject.
Summarize lesson.
Ask for questions.
Review objectives.)
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Motivation
Objectives:
Upon completion of this training, the student will be able to do the following:
1. Identify motivation issues faced by radiological worker supervisors.
2. Identify several ways to motivate personnel.
3. Identify several tools of motivation.
Training Aids:
Overhead Transparencies (OTs): OT 7.1 - OT 7.9 (May be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
Flip chart
Markers
Masking tape
Student Materials:
Student’s Material
References:
Lau & Shani, Behavior in Organization, 1992.
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I. Introduction (Introduce module. State objectives. Show OT 7.1.)
II. Motivation
The roles and responsibilities of a supervisor include motivating personnel to
perform quality work. There are many theories of motivation. Some have
been found to be effective and some have not. It is important for supervisors
to understand which theories of motivation are valid and which techniques
will be most effective.
III. Why are people motivated?
(Obj. 1 Identify motivation issues faced by radiological worker supervisors.
How do you motivate your employees?
Students will brainstorm a list. Write responses on flip chart. Typical responses:
Rewards (pay, bonus)
Recognition
Interesting jobs
Work ethic
List various theories.)
A. Needs fulfillment theories
Section 40
Need fulfillment theories of motivation state that people are motivated by
inherent needs and specifically by unmet needs. Behavior is based on
inherent needs.
1. Maslow's hierarchy of needs
1. Physiological
2. Safety
3. Belongingness
4. Love
5. Self-actualization
(Show OT 7.2. Define “self-actualization” and give examples.)
In an organization, one typically assumes that an individual's basic
needs have been met (food, shelter, clothing). However, other needs
may not have been met. Supervisors should be aware of employees'
need for a safe and secure working environment. This is a critical
issue for supervisors of radiological workers.
It is not the organization's responsibility to fulfill higher level needs
(belongingness, love, self-actualization). However, supervisors
should understand how these needs translate into motivation. If
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employees feel like they are part of a work team, they will be more
loyal, and perhaps be motivated to work harder. The need for self-
actualization can often be encouraged by providing employees with
the authority to make decisions that are critical to their working
environment.
2. Job enrichment theory
(Show OT 7.3. Obj. 2 Identify several ways to motivate personnel.)
The job enrichment theory of motivation states that certain job
dimensions will motivate employees to work more effectively.
Job dimensions include the following:
Skill variety
Task identity
Task significance
Autonomy
Feedback
These job dimensions will provide meaning to the job, make an
employee responsible for the job, and provide feedback concerning
how the job is progressing.
Supervisors should evaluate the jobs of their workers to determine if
these dimensions are part of the job. If not, the need for job redesign
may be indicated.
3. Need for achievement theory
(Show OT 7.4.)
In this theory, it is believed that some employees have a need for
achievement, while others do not. If a person has a high need for
achievement, he/she will do better in "achieving situations." These
situations may be characterized as follows:
Personal responsibility is evident. The individual will receive credit
for a job well done.
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The task should be at an intermediate to average level of difficulty.
There should be a good chance of success.
The individual needs to receive feedback.
The individual needs to feel challenged.
The situation should be ongoing, with consequences in the future.
Although a supervisor cannot change an individual's need for
achievement, understanding this theory may explain what motivates
some employees.
B. Cognitive theories (Show OT 7.5.)
Cognitive theories of motivation state that a person's behavior is based
on a cognitive process. People think before they act.
1. Equity (justice) theory
This theory is based on the equity of input (work) and output
(rewards). Employees' output is based on their perceived level of
their own input, as well as their perception of the input and output of
others.
If employees believe that their input is greater than that of others (or
their output is less), they will try to balance the situation by doing the
following:
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Reducing their input (decreased productivity, absenteeism,
tardiness)
Increasing their rewards (employee theft, i.e., supplies, phone
calls, inflated expense statements)
Leaving the job in search of a more equitable situation
Supervisors should be aware of this theory and assess whether there
is equity in the workplace for each worker as well as across the team.
By understanding the equity theory, supervisors can understand
behaviors stemming from real or perceived inequities.
2. Expectancy (choice) theory
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For the expectancy theory, the primary motivation is the attainment of
goals. Behavior is based on a person's expectation that his or her
effort will lead to a certain type of performance. This in turn will lead
to a certain level of reward (e.g., If I work hard, I will do a good job
and get a good reward). Employees make clear choices about the
level of effort they will exert based on these expectations.
For employees to be motivated, there must be a clearly defined
relationship between performance and rewards (compensation
system). There also has to be a link between effort and performance.
The supervisor must be aware of an individual's effort and consequent
performance.
The supervisor must provide feedback to the employee that will
enable the link between effort and performance to be more direct.
C. Reinforcement theories
The basic tenet underlying reinforcement theories is that people are
motivated by rewards for their behavior. People work because they are
rewarded. A reward is considered something of value to the employee.
The most basic is compensation (pay, benefits, leave time). Other
rewards include recognition and job prerequisites. Following this theory,
supervisors should assess the rewards and recognition given to their
employees.
IV. Tools of motivation
(Obj. 3
Identify several tools of motivation.
(Ask students for types of motivational tools. List on flip chart. Encourage students to
write responses in the Student’s Material. Allow 30 min. for this activity.
Responses may include the following:
Goal setting
Empowerment
Recognition
Rewards
Coaching and mentoring (covered in leadership module))
A. Goal setting
Goal setting is one of the most researched areas of motivation, the basic
conclusion is that goals motivate people. A goal is something that a
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person tries to attain, achieve, or accomplish. Once a goal is set,
behavior is based on the attainment of that goal. Specific goal-setting
techniques will be presented later.
Why do goals work?
(Show OT 7.6.)
Goals give an employee direction.
Goals influence the intensity with which an individual works toward
attainment of a goal.
Goals influence the persistence with which an individual works toward
attainment of a goal.
Goals typically require individuals to develop a strategy for goal
attainment.
For goals to be effective motivators, they must have the following
characteristics:
1. Goal difficulty (Show OT 7.7.)
Employees become more committed to difficult goals. If a goal is too
easy, employees will not seriously commit to goal attainment because
there is no challenge.
Section 42
However, if the goal is too difficult, employees will not make a
commitment because they don't believe they can accomplish the goal.
2. Goal specificity
The more specific a goal, the easier it is to achieve. Specific goals
provide more detailed direction toward attaining that goal.
3. Employee participation in goal setting
An individual must internalize a given goal before it becomes a
motivation. The best way to do this is for the individual to participate
in setting the goal. When employees are involved in goal setting, they
have a much better understanding of the goal, as well as how to
achieve it.
4. Feedback
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An individual must know when he or she has achieved a set goal. It is
important to have progressive feedback on goal attainment.
B. Empowerment
Employee empowerment is a philosophy of transferring power from
management to employees. By doing this, employees become more
involved in their work and accept responsibility for their actions.
Employees will be more motivated to do quality work if they have been
involved in critical decisions and have a sense of ownership in the job.
Even though empowerment is a strategy that affects the entire
organization, the basic empowering relationship is between a supervisor
and subordinate. It is the immediate supervisor who transfers power to
an employee.
The steps toward empowerment are listed below: (Show OT 7.8.)
1. Develop an operational definition of empowerment. The definition
should be very clear as to what empowerment means from both the
manager's perspective and the employee's perspective. The goals
and objectives of empowerment should be stated clearly and be
behaviorally based in order to evaluate the success of any
intervention.
2. Assess strategies used to empower employees. Identify techniques
that would be appropriate for your group. This list will be tentative and
will be refined as more information is gathered. Techniques include
participative decision making, job enrichment, redesign of internal
processes, etc.
3. Clarify and communicate organization/division mission. (Show OT
7.9.) An underlying assumption in empowering employees is that their
actions will support the company's goals and objectives. To ensure
that this happens, employees need to be very clear on the company's
goals and objectives. All employees should know what their mission
is and how it fits into the overall mission of the organization.
The goals and objectives of the division should be concrete and
expressed as specific outcomes to be achieved. Employees will need
some guidelines for the decisions they will be asked to make. The
division goals and objectives provide global guidance.
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4. Determine the boundaries and limitations of each strategy used.
Decisions can be classified into executive decisions and operational
decisions. Executive decisions involve the overall mission of the
organization, the political climate, and the global strategy. Operational
decisions are day-to-day decisions made in developing the "product."
It is important to know which decisions employees will be able to make
on their own.
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There are also organizational and regulatory restrictions in decision
making that must be clarified. These decisions include fiscal
decisions, standard operating procedures within the organization,
restrictions imposed by DOE, etc. Identifying decisions that are not
appropriate for participative decision making will narrow down those
decisions that are appropriate.
5. Assuming participative decision making is to be used, determine what
decisions are appropriate to delegate. Once boundaries and
limitations are defined, come up with a tentative outline for the types
of decisions that are appropriate for sharing with employees and
those that are not appropriate. This outline is tentative and requires
input from other managers, employees, and the administration prior to
being implemented.
6. Decide whether empowerment strategies will be required or voluntary.
Will a manager or employee have a choice of whether he/she will
participate? What degree of delegation/empowerment will be
required?
7. Communicate the tentative plan to managers, supervisors, and the
administration. Prior to getting input from employees, get initial input
from managers, supervisors, and the administration. This information
will help determine the feasibility of employee empowerment.
8. Get input from employees. Find out their concept of empowerment.
Determine to what degree employees already feel empowered. This
can be done through a survey (preferably anonymously). This step is
risky because it can raise expectations. This should only be done if
you have definite plans to proceed. However, it should be done prior
to developing an elaborate strategy for empowering employees.
If the goal of empowerment is motivational, you have to find out what
the employees want. On the other hand, if the goal of empowerment
is to reduce the work load of middle management, you have to get
employee buy-in; otherwise, it will flop.
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9. Determine skills necessary for empowerment. It cannot be assumed
that managers and employees have the skills necessary to transfer
power. The first step is to determine what skills are necessary for
shifting power. Managers will need the skills necessary to determine
what decisions are appropriate for staff to make.
Employees must know how to make decisions, how to prioritize, when
not to make decisions, what the boundaries are, etc. Once the skills
have been identified, it is important to know who has the requisite
skills and who doesn't. Some type of assessment is necessary.
10. Communicate plan to employees and provide a mechanism for
feedback. Introduction to the plan should be low-key and not raise
expectations. Consider having each program, or supervisor,
communicate the plan as opposed to an announcement from the
division office. This will help keep the focus on the program.
11. Provide training if needed. Based on the assessment of skills, training
may be necessary for those managers and employees lacking
requisite skills.
C. What other tools could be used to motivate employees?
(Students will brainstorm a list. List on flip chart.
Encourage students to write the list in the Student’s Material.
Summarize lesson.
Ask for questions.
Review objectives.)
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DEPARTMENT OF ENERGY LESSON PLAN
Course Material Topic: Leadership
Objectives:
Upon completion of this training, the student will be able to do the following:
1. Identify leadership issues faced by radiological worker supervisors.
2. Identify characteristics of a good leader.
3. Describe the various types of power and influence in organizations.
4. Identify several tools of leadership.
Training Aids:
Overhead Transparencies (OTs): OT 8.1 - OT 8.10 (May be supplemented or
substituted with updated or
site-specific information)
Equipment Needs:
Overhead projector
Screen
Flip chart
Markers
Masking tape
Student Materials:
Student’s Material
Student Handouts
References:
Lau & Shani, Behavior in Organization, 1992.
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Introduction (Introduce module. State objectives. Show OT 8.1.)
II. Leadership
(Ask students to state what their definition of leadership is. Write definitions on
flip chart. Comment on the diverse responses.
Obj. 1 Identify leadership issues faced by radiological worker supervisors.
Refer to the definition of leadership, and ask for examples under each bullet.
Ask students what issues their employees bring to them. List on flip chart.)
A supervisor is more than just a person who sees that a job is conducted and
a task completed in accord with directions; he/she is also a leader. The
more an organization rewards it’s effective leaders, the fewer employee
problems they will have.
A. Definition of leadership
Leadership is a process that includes influencing:
The objectives and strategies of a group or organization
People in the organization to implement the strategies and achieve
the objectives
Group maintenance and identification
The culture of the organization.
B. Characteristics of good leadership
(Show OT 8.2. Obj. 2 Identify characteristics of a good leader.)
The characteristics of good leadership can be placed in the following
categories:
Leadership traits
Motives of leaders
Leadership skills
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1. Leadership traits (Show OT 8.3)
High energy level
Stress tolerance
Integrity
Emotional maturity
Self-confidence
2. Motives of leaders (Show OT 8.4)
Need for power
Need for achievement
Need for affiliation
3. Effective leadership skills (Show OT 8.5)
Planning and organizing
Problem solving
Clarifying and monitoring
Informing
Motivating and consulting
Recognizing and supporting
Team building, networking, and delegating
Developing and mentoring
Rewarding
(Show OT 8.6. This section should be followed by a discussion of what the
students believe the characteristics of a good leader to be.)
C. Power/influence
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1. Types of power
(Show OT 8.7. Obj. 3 List the various types of power and influence in
organizations.)
Legitimate power - Supervisors have legitimate power based on
their position in the organization.
Section 45
Coercive power - Supervisors have coercive power based on their
control (real or perceived) over punishment.
Reward power - Supervisors have reward power based on their
control (real or perceived) over rewards.
Expert power - Supervisors have expert power based on their level
of technical expertise.
(This section should be followed by a discussion on how students believe power
influences leadership.)
2. Influence tactics include the following:
(Show OT 8.8.)
Rational persuasion
Inspirational appeals
Consultation
Ingratiating
Personal appeals
Upward appeals
III. Tools of leadership
(Show OT 8.9. Obj. 4 Identify several tools of leadership.)
A. Providing vision
A good leader provides vision for the work unit. The vision is a clear,
concise view of what the work unit is striving to accomplish. The vision
for the work unit should be consistent with the vision of the organization.
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Ideally, the vision for the work unit will be developed with input by the
work unit.
If a vision is clearly stated and accepted by the work unit, it becomes a
goal of each member of the unit.
B. Coaching/mentoring
One of the roles of a leader is to develop his or her workers. Leaders are
in the best position to see individual efforts and how they help to achieve
or hinder goals. By coaching or mentoring, a leader can guide a worker
toward goal attainment.
Coaching and mentoring include the following:
Help each worker set goals and identify barriers to overcome.
Solicit ideas and assistance from workers in solving problems that
arise in the organization.
Know the deficiencies of employees and develop a plan for them to
acquire the knowledge and skill needed. Feedback and training will
facilitate development of employee knowledge and skills.
Reinforce positive behavior changes that increase productivity.
C. Delegating
Part of a leader's role is to delegate tasks and decisions to employees.
The level of delegation typically depends on one's style of leadership.
Some leaders feel comfortable in delegating responsibility along with the
delegated tasks, while others feel more comfortable delegating only the
task.
Prior to delegating, a leader must consider the following:
Is the employee capable of completing the assigned task?
Does the employee have the necessary resources to complete the
task (human resources, financial resources, training)?
What are the consequences of failure? The supervisor will have to
assess the level of risk in the task and determine whether the
organization can assume the risk of error.
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What type of supervision is necessary? The supervisor should decide
how closely he or she should be involved. This will be contingent on
the competency of the employee, the level of risk associated with the
task, and the leadership style of the supervisor.
(Ask students for other items that might need to be considered prior to
delegating. List on flip chart.)
D. Team building
An effective way of leading a group of individuals is to allow them to lead
themselves. The use of self-managed work teams can be an effective
way to motivate employees to work more efficiently and to work together.
Section 46
The concept of self-managed work teams focuses on the team member
as the expert. By allowing the team to make and implement decisions,
decisions are being made by those individuals with the most knowledge
and experience.
The following organizational context factors will increase the likelihood of
success for teams:
(Show OT 8.10. Review and discuss page 6 of Student Handout "Supervisor's
Responsibilities".)
Management support
Mission clarity
Autonomy
Rewards for the team
Team training
Feedback on performance
Organization culture conducive to teamwork
Appropriate physical facility
The following team development factors will increase the likelihood of
success:
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Communication
Cohesion
Developed norms
Role clarity
Cooperation
Participation
Conflict resolution
(Summarize lesson.
Ask for questions.
Review objectives.)
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Office of Health, Safety, and Security
U.S. Department of Energy
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Table of Contents
Page
Occupational Radiation Protection Program Policy and Guidance Review .................. 1–1
10 CFR Part 835, Background and Focus .................................................................. 2–1
Administrative Policies and Procedures ....................................................................... 3–1
Fitness for Duty ............................................................................................................ 4–1
Interpersonal Communication ...................................................................................... 5–1
Problem Analysis and Decision Making ....................................................................... 6–1
Motivation .................................................................................................................... 7–1
Leadership ................................................................................................................... 8–1
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I. Introduction
II. DOE radiological health and safety
A. Policy (some key points in summary)
Conduct oversight to ensure Departmental requirements are being
complied with and appropriate radiological work practices are being
implemented.
Ensure radiological measurements, analyses, worker monitoring
results, and estimates of public exposures are accurate and
appropriately made.
Incorporate dose reduction, contamination reduction, and waste
minimization features into the design of new facilities and significant
modifications to existing facilities in the earliest planning stages.
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Establish and maintain, from the lowest to the highest levels, line
management involvement and accountability for Departmental
radiological performance.
Establish and maintain a system of regulatory policy and guidance.
Ensure appropriate training is developed and delivered and the
technical competence of the DOE workforce and their technical
competence.
Conduct radiological operations in a manner that controls the spread
of radioactive materials and reduces exposure to the work force and
the general public and utilizes a process that seeks exposure level as
low as reasonably achievable (ALARA).
B. History
DOE has provided numerous written standards for on-site radiological
protection, the most recent regulation being 10 CFR Part 835,
Occupational Radiation Protection. This regulation was preceded by:
DOE Notice 5480.6 of June 17, 1992, Radiological Control, which
specified that the DOE Radiological Control Manual (DOE/EH-0256T)
would supersede DOE Order 5480.11.
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DOE Order 5480.11, Radiation Protection for Occupational Workers
(effective December, 1988). The purpose was to establish radiation
protection standards and program requirements for DOE and DOE
contractors for the protection of workers from ionizing radiation.
The establishment of DOE radiological protection standards did not start
with these documents. A chronology of dose limits of DOE and its
predecessor agencies, the Atomic Energy Commission (1946-1975) and
the Energy Research and Development Administration (1975-1977),
demonstrate a lowering of whole body dose limits over the last 50 years.
In the establishment of these dose limits, DOE has followed
recommendations of national and international radiological protection
groups, notably the International Commission on Radiological Protection
(ICRP) and the National Council on Radiation Protection and
Measurements (NCRP).
C. Hierarchy of requirements
Currently within DOE there are two parallel hierarchies of requirements:
Rules and/or regulations (these terms are used interchangeably in this
training)
DOE Orders
Rules are codified in the Code of Federal Regulations (CFR) and may be
subject to enforcement action including civil and criminal penalties. DOE
Orders are contractually implemented and enforced through an award/fee
contractual arrangement between DOE and the contractor.
III. Rules and regulations
In response to the enforcement authority in the Price-Anderson Amendments
Act (PAAA) of 1988, DOE is converting its contractual requirement in orders
to enforceable rules to enhance contractor accountability for safety.
10 CFR 830 governs the conduct of DOE contractors, DOE personnel, and
other persons conducting activities (including providing items and services)
that affect, or may affect, the safety of DOE nuclear facilities. It includes
quality assurance requirements and Technical Safety Requirements.
A. DOE enforcement of rules under PAAA
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10 CFR Part 820 (effective on September 16, 1993) sets forth the
procedures to implement the provisions of the PAAA. Part 820 requires
contractors to comply with DOE Nuclear Safety Requirements.
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PAAA demands a “large stick” to enhance contractor accountability for
safety. Rules provide authority for the assessment of civil and criminal
penalties and thus provide the large stick
B. Penalties under Part 820
1. Civil penalties
DOE may assess civil penalties against any person subject to Part
820, for violations of:
Codified rules in the CFR
Compliance orders
Any program or plan required by a rule or compliance order
Note: Certain nonprofit educational institutions and other listed
institutions are exempt from assessment of civil penalties.
2. Criminal penalties
If a person subject to the Atomic Energy Act of 1954, as amended, or
Nuclear Safety Requirements, has by action or omission knowingly
and willfully violated, caused to be violated, attempted to violate, or
conspired to violate any section of the Atomic Energy Act of 1954, as
amended, or applicable DOE Nuclear Safety Requirements, the
person shall be subject to criminal sanctions.
3. The “carrot and stick” approach
DOE may provide monetary incentives in its management and
operating (M&O) contracts for actions consistent with or exceeding
requirements, and to penalize actions and activities that were not in
compliance with requirements.
Noncompliance with the Radiation Protection Program can subject a
contractor to PAAA enforcement. There are provisions to mitigate
penalties for self-identifying and reporting violations.
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C. DOE Nuclear Safety Requirements
DOE Nuclear Safety Requirements are the set of enforceable rules,
regulations, or orders relating to nuclear safety that have been adopted
by DOE (or by another agency if DOE specifically identifies it).
Compliance orders are issued by the Secretary. They identify a situation
that violates, potentially violates, or otherwise is inconsistent with the:
Atomic Energy Act of 1954, as amended
Nuclear statutes
Nuclear Safety Requirements
Compliance orders:
Mandate a remedy or other action
States the reason for the remedy or other action
D. 10 CFR Part 835
On December 14, 1993, DOE published a final rule in the Federal
Register (58 FR 65458) Title 10 Code of Federal Regulations Part 835,
Occupational Radiation Protection (10 CFR 835). On June 8, 2007, the
latest amendment to 10 CFR 835 was published in the Federal Register
(72 FR 31904).
The purpose of 10 CFR 835 is the codification of radiological protection
requirements. It contains “shall” statements, which are legally binding. It
also contains:
Prescriptive language
Added emphasis on ALARA
Requirements for a Radiation Protection Program (RPP)
Federal law
Criminal and civil penalties for violations
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E. Radiation Protection Program (10 CFR Part 835)
Each site, under Part 835, must submit to DOE a written Radiation
Protection Program (RPP). The cognizant DOE program office reviews
submitted RPPs for approval.
The RPP requires careful consideration because noncompliance may
subject a contractor to PAAA enforcement
F. Guidance documents for 10 CFR Part 835
Two types of regulatory guidance documents have been developed:
Guidance for implementing the provisions of 10 CFR Part 835.
Guidance providing technical positions.
Section 49
The above are available through the DOE HS-11 website at:
http://www.hss.energy.gov/HealthSafety/WSHP/radiation/regs.htm
Unlike the requirements specifically set forth in 10 CFR Part 835, the
provisions in guidance documents are not mandatory. They are intended
solely to describe the rationale for, and the objectives of, regulatory
requirements and/or to identify acceptable methods for implementing
regulatory requirements.
Failure to follow a guidance document does not in itself indicate
noncompliance with a specific requirement of the rule. A finding of
noncompliance is found for a failure to satisfy the regulatory requirement.
Following a guidance document in the prescribed manner will ordinarily
create a presumption of compliance with a related regulatory
requirement.
1. Technical guidance
Technical guidance describes and disseminates technical methods
and techniques for fulfilling implementation and, in turn, the
requirements in 10 CFR Part 835. Examples of these guidance are
DOE Technical Standards and DOE Radiological Control Technical
Positions (RCTPs).
2. Implementation guide (IG)
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Implementation guidance is intended to identify and make available to
DOE contractors basic program elements and acceptable methods for
implementing specific provisions of the final rule. An implementation
guide has been developed for 10 CFR Part 835.
G. Relationship between 10 CFR Part 835 and
10 CFR Part 20
10 CFR Part 20 is the occupational radiological regulation issued by the
Nuclear Regulatory Commission (NRC).
The question of consistency among federal agencies in their occupational
radiological protection regulations became a major point of discussion
during the rule making process.
While agreeing with the goal of consistency, DOE believes that it must
promulgate its own regulations because of the unique nature and
diversity of radiological activities within the DOE complex. The final rule
allows DOE to establish more rigorous requirements in areas of particular
concern. Overall 10 CFR Part 835 has many similarities as 10 CFR Part
20.
IV. DOE STD Radiological Control
A. Radiological Control
In January 1992, a memorandum was sent to the heads of DOE
elements involved in managing radiological control programs. In the
memorandum, the Secretary directed a series of initiatives to enhance
the conduct of radiological operations within the Department of Energy.
Also in this memo, the Assistant Secretary of Environment, Safety and
Health was directed to develop a comprehensive and definitive
radiological control manual. The DOE Radiological Control Manual was
developed to meet that directive and was approved by the Secretary and
promulgated with DOE Notice 5480.6, Radiological Control, in July 1992.
After the issuance of 10 CFR 835 as a final rule in December 1993, DOE
Notice N441.1, Radiological Protection for DOE Activities, was issued on
9-30-95. This cancelled the notice which made the Radiological Control
Manual a requirements document. However, the notice stated that
"cancelled orders that are incorporated by reference in a contract shall
remain in effect until the contract is modified to delete the reference.
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N441.1 also retained some of the radiation protection requirements from
the Radiological Control Manual that were not included in 10 CFR 835.
In July, 1999, the Radiological Control Manual was replaced by the
standard, DOE-STD-1098-99, Radiological Control. Many DOE sites
contractually must still adhere to the provisions of either the Radiological
Control Manual or the Radiological Control Standard. Subsequent to the
1998 amendment to 10 CFR 835, the effective date of N441.1 has
passed.
The DOE Radiological Control Standard is not regulatory in nature. It is a
guidance document that describes DOE’s policy and expectations for an
excellent radiological control program.
1. Implementation
If a site fully implements a provision of the DOE Radiological Control
Standard, the user will have most likely complied with any related
statutory, regulatory, or contractual requirements. Users are
cautioned that they must review the source document (10 CFR 835)
to ensure compliance.
2. Enforceability
When incorporated into contracts, the provisions of the DOE
Radiological Control Standard or Manual are binding requirements.
If portions of the Site-Specific Radiological Control Manual are
incorporated in the RPP under Part 835 and approved by DOE, they
are also binding.
B. The Site-Specific Radiological Control Manual
The DOE Radiological Control Standard states that a Site-Specific
Radiological Control Manual should be written and followed.
C. Relationship between 10 CFR Part 835 and the DOE Radiological
Control Standard
1. Compliance
The Office of Enforcement (HS - 40) will enforce 10 CFR Part
835. It can assess fines and penalties.
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The Program Offices will audit for both compliance with 10 CFR
835 and contractual agreements including the DOE Radiological
Control Standard or Manual, Orders, etc. Results of these audits
can affect the contractor’s award fee.
2. What if there are conflicts?
10 CFR Part 835 takes precedence over the DOE Radiological Control
Standard and DOE orders. It is unlikely that there will be a conflict
between the two documents, although one document may contain
provisions that are not addressed in the other.
It is planned that all requirements for nuclear safety will be incorporated
into rules.
3. “Shall” and “should” statements
10 CFR Part 835 contains “shall” statements. “Shall” statements in
Part 835 are legally binding.
Processes for exemption relief from Part 835 are set forth in
Subpart E to Part 820. If relief is requested from provisions of Part
835, the exemption must be considered and granted, if
appropriate, by the Chief Health, Safety and Security Officer (HS -
1).
The use of “should” in the DOE Radiological Control Standard
recognizes that there may be site- or facility-specific attributes that
warrant special treatment. It also recognizes that literal
compliance with the elements and requirements of the provision
may not achieve the desired level of radiological control
performance.
D. DOE Standards
DOE has developed several technical standards for occupational
radiation protection. Depending on the site-specific application, some
standards are required to be followed. For example, sites which need to
monitor individual external exposures to ionizing radiation need to follow
the DOE Laboratory Accreditation Program (DOELAP) standards. Other
standards may be incorporated by reference in the site RPP.
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Other standards provide technical guidance on specific applications, but
adherence to the standard may not be required.
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E. Other Safety Policy and Orders
In addition to the occupational radiation protection requirements and
recommendations previously discussed, DOE has established
requirements for worker protection from other hazards. Some of these
include:
DOE P 411.1 Safety Management Functions, Responsibilities, and
Authorities Policy
10 CFR 851 Worker Safety and Health Program
10 CFR 850 Chronic Beryllium Disease Prevention Program
V. Defense Nuclear Facilities Safety Board
A. Establishment
The Atomic Energy Act of 1954 was amended by adding Chapter 21,
Defense Nuclear Facilities Safety Board (DNFSB). This amendment
established an independent board in the executive branch to provide
oversight of some DOE operations at DOE facilities and sites.
B. Members
The DNFSB consists of five members appointed by the President with
consent of the Senate.
The Board shall:
Review and evaluate standards
Investigate any event or practice at a DOE defense nuclear facility
that the Board determines has adversely affected or may adversely
affect public health and safety.
The Board may:
Establish reporting requirements for the Secretary of Energy
By evaluating how well DOE meets its objectives, the DNFSB helps DOE
achieve and maintain excellence in radiological protection.
C. Secretary of Energy
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The Secretary of Energy shall fully cooperate with the Board.
D. DNFSB Recommendations
DNFSB provides DOE with recommendations for improving safety at
DOE defense nuclear facilities. Examples include:
DNFSB Recommendation 91-6 dealt with radiological protection
concerns throughout the DOE defense nuclear facilities complex, and
identified several actions to be taken by the Department to improve
radiological protection performance.
DNFSB Recommendation 92-7 dealt with training and qualification at
DOE sites and facilities.
DNFSB Recommendation 98-1 dealt with resolution of internal audit
findings.
DNFSB Recommendation 99-1 dealt with safe storage of fissionable
materials.
Implementation of DOE and site commitments made in response to
DNFSB recommendations are areas to review during an assessment.
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I. Introduction
This module provides an overview of many of the provisions of 10 CFR 835.
For completeness, individuals should always reference back to 10 CFR 835
for the complete text.
II. Outline of 10 CFR Part 835
Part 835 is the codification of radiological protection requirements. Part 835
contains 14 subparts and five appendices. The outline consists of the
following subparts:
A — General Provisions
B — Management and Administrative Requirements
C — Standards for Internal and External Exposure
D — Reserved
E — Monitoring of Individuals and Areas
F — Entry Control Program
G — Posting and Labeling
H — Records
I — Reports to Individuals
J — Radiation Safety Training
K — Design and Control
L — Radioactive Contamination Control
M — Sealed Radioactive Source Control
N — Emergency Exposure Situations
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Under 10 CFR Part 835, each site must submit a Radiation Protection
Program (RPP).
Part 835 helps to ensure that DOE facilities are operated in a manner such
that occupational radiological exposure of workers is maintained within
acceptable limits and as low as is reasonably achievable (ALARA).
A. Subpart A - General Provisions
Subpart A contains the scope of the rule. The rule in this part establishes
radiological protection standards, limits, and program requirements for
protecting individuals from ionizing radiation resulting from the conduct of
DOE activities.
It also includes activities excluded from the provisions of the rule.
Activities that are excluded include the following (summarized):
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Activities regulated through a license by the Nuclear Regulatory
Commission (NRC) or a state under an agreement with the NRC.
Activities conducted under the authority of the Director, Naval Nuclear
Propulsion Program.
Specified activities conducted under the Nuclear Explosives and
Weapons Surety Program.
DOE activities in other countries with acceptable radiation protection
program.
Background radiation.
Radioactive material on or within material, equipment, and real
property which is approved for release when the radiological
conditions of the material, equipment, and real property have been
documented to comply with the criteria for release set forth in a DOE
authorized limit which has been approved by a Secretarial Officer in
consultation with the Chief Health, Safety and Security Officer.
Radioactive material transportation not performed by DOE or a DOE
contractor.
Occupational doses received as a result of excluded activities and
radioactive material transportation, as listed above, shall be considered
when determining compliance with the occupational dose limits (835.202
and 835.207), and with the limits for the embryo/fetus (835.206).
Subpart A also addresses:
Definitions
Radiological units (Curie, rad, roentgen, rem, other conventional units,
and multiples)
B. Subpart B - Management and Administrative Requirements
The RPP shall:
Include formal plans and measures for applying the ALARA process
to occupational exposures.
Specify the existing and/or anticipated operational task.
Address, but not be limited to, each requirement in Part 835.
Include plans, schedules, and other measures for achieving
compliance.
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DOE may direct or make modifications to an RPP. An initial RPP or
update shall be considered approved 180 days after its submission
unless rejected by DOE at an earlier date.
Internal Audits (10 CFR 835.102)
Internal audits of the radiation protection program, including examination
of program content and implementation, shall be conducted through a
process that ensures that all functional elements are reviewed no less
frequently than every 36 months. This training material and DOE G
441.1.1C provide guidance on DOE's expectations.
Education, Training and Skills (10 CFR 835.103)
Individuals responsible for developing and implementing measures
necessary for ensuring compliance with the requirements of this part shall
have the appropriate education, training, and skills to discharge these
responsibilities. DOE STD-1107-97 Knowledge, Skills, and Abilities for
Key Radiation Protection Positions at DOE Facilities, provides guidance
on DOE's expectations.
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Written Procedures (10 CFR 835.104)
Written procedures are required, as necessary, to ensure compliance
with 835, commensurate with radiological hazards and education, training
and skills of exposed individuals.
C. Subpart C - Standards for Internal and External Exposure
This subpart addresses limits for:
General employees (occupational)
Embryos/fetus of declared pregnant worker (i.e., A woman who has
voluntarily declared to her employer, in writing, her pregnancy for the
purpose of being subject to the occupational dose limits to the
embryo/fetus. This declaration may be revoked, in writing, at any time
by the declared pregnant worker.)
Occupationally exposed minors
General public in a controlled area
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It also addresses:
Planned special exposures
Nonuniform exposures of the skin
Concentrations of radioactive material in air
2. Summary of dose limits
10 CFR Part 835 employs the rem unit for several different physical
quantities (i.e. absorbed dose, effective dose, total effective dose,
equivalent dose, committed equivalent dose, committed effective
dose). For information about these quantities refer to 10 CFR Part
835 definitions. This training will use the term “dose” as a general
term for all the above terms.
These are the Federal limits. DOE encourages sites to adopt more
restrictive Administrative Control Levels (ACLs). For most facilities
an ACL of 500 mrem or less will be challenging for radiological
workers.
Exposed Individual Annual Limit
General Employee: Whole Body (internal and external) 5.0 rem
General Employee: Lens of Eye 15.0 rem
General Employee: Extremity (below elbow and knees) and skin 50.0 rem
General Employee: Any Organ or Tissue (other than lens of eye) 50.0 rem
Declared Pregnant Worker: Embryo/Fetus (gestation period) 0.5 rem
Occupationally Exposed Minors (under age 18): 0.1 rem *
Members of the Public in Controlled Areas: 0.1 rem
And 10% of other general employee limit
2. Planned special exposures (PSEs)
It is acknowledged that unusual conditions can arise in which well
documented higher-than-normal doses can be justified. In these well-
planned, well-controlled, and highly infrequent and unusual conditions
operating management would be permitted to allow specified
individual exposures exceeding the occupational limit.
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The term "unusual conditions" is made clear by specifying that
alternatives which would preclude exposures higher than the
prescribed dose limits must be either unavailable or impractical.
10 CFR 835.204 specifies requirements for annual and lifetime dose
from PSEs. It also specifies requirements for determining previous
individual exposures prior to allowing a PSE.
Every PSE must be approved in advance by DOE and requires the
informed consent of the employee involved.
3. Concentration of radioactive material in air
Appendices A and C contain the derived air concentration (DAC)
values used in the control of occupational exposure to airborne
radioactive material.
DACs are listed in appendices A and C of 10 CFR 835. For intakes
(appendix A), they are the airborne concentration that equals the
annual limit on intake (ALI) divided by the volume of air breathed by
an average worker for a working year of 2000 hours (assuming a
breathing volume of 2400 m3).
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The ALI is the smaller value of intake of a given radionuclide in a year
by a standardized man that would result in a committed effective doe
of 5 rems or a committed equivalent dose of 50 rems to any individual
organ or tissue.
Appendix C contains DACs for controlling external dose from being
immersed in a cloud of airborne radioactive material.
Estimation of internal dose shall be based on bioassay data rather
than air concentration values unless bioassay data are:
Unavailable (e.g., radon or very short lived radioisotopes)
Less accurate than internal dose estimates based on
representative air concentration values
Inadequate
D. Subpart D - Reserved
E. Subpart E - Monitoring of Individuals and Areas
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This subpart addresses:
General requirements
Instrumentation
Individual monitoring - external
Individual monitoring - internal
Air monitoring
Receipt of packages containing radioactive material
1. General requirements (10 CFR 835.401)
Monitoring of individuals and areas shall be performed to:
Demonstrate compliance with Part 835.
Document radiological conditions.
Detect changes in the radiological conditions.
Detect the gradual buildup of radioactive material.
Verify the effectiveness of engineering and process controls in
containing radioactive material and reducing radiation
exposure.
Identify and control potential sources of individual exposure to
radiation and/or radioactive material.
2. Instrumentation
Instruments and equipment used for monitoring and contamination
control shall be:
Periodically maintained and calibrated on an established
frequency.
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Appropriate for the type(s), levels, and energies of the
radiation(s) encountered.
Appropriate for existing environmental conditions.
Routinely tested for operability.
3. Individual monitoring - external (10 CFR 835.402)
For the purpose of monitoring individual