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Ed Adams, Manager Radiological Controls January 13, 2014

Radiological Controls Safety Management Program. Ed Adams, Manager Radiological Controls January 13, 2014. Purpose. To provide the conclusions and actions resulting from the annual Safety Management Program (SMP) review for the Radiological Controls (RadCon) program.

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Ed Adams, Manager Radiological Controls January 13, 2014

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  1. Radiological Controls Safety Management Program Ed Adams, Manager Radiological Controls January 13, 2014

  2. Purpose • To provide the conclusions and actions resulting from the annual Safety Management Program (SMP) review for the Radiological Controls (RadCon) program. • The RadCon SMP is evaluated against HNF-5183, Tank Farms Radiological Control Manual,(TFRCM) requirements as the bases for each element. • (1) Excellence in Radiological Controls. • (2) Radiological Standards. • (3) Conduct of Radiological Work. • (4) Radioactive Materials. • (5) Radiological Health Support Organizations. • (6) Training and Qualifications. • (7) Radiological Records. 2

  3. Summary • The RadCon SMP is concluded to be effectively implemented. • Continuing emphasis needed to improve the conduct of radiological operations, worker awareness, and conduct of radiological work. • The health of the RadCon SMP was determined by a comprehensive self-assessment program and periodic external reviews. • The most recent health determination for this SMP was provided to the ESRB on November 2, 2012, and concluded that the program was effectively implemented, with continuing emphasis needed to improve the conduct of radiological operations. 3

  4. Requirements for Radiological Control • 10 CFR 835, Occupational Radiation Protection. • DOE/RL-2002-12, Hanford Radiological Health and Safety Document (HSD). • DOE M 231.1-1A, Chg. 2, Environment, Safety and Health Reporting Manual – Occupational Radiation Exposure Reports; Annual Individual Radiation Exposure Records. • DOE N 234.1, Reporting of Radioactive Sealed Sources. • DOE O 5400.5, Chg. 2, Radiation Protection of the Public and the Environment (DOE O 458.1). 4

  5. Requirements Flow-down • HNF-MP-5184, Radiation Protection Program, links 10 CFR 835 requirements to the TFRCM. • All 10 CFR 835 and HSD requirements are included verbatim in the TFRCM. • Crosswalk matrices for each RadCon functional area link TFRCM requirements with implementing procedures. • TFC-PLN-119, Radiation Protection Program Assessment Plan, requires company technical authorities to review/update the crosswalk matrices on an annual basis. 5

  6. SMP Implementation Effectiveness • RadCon-related PERs are trended to evaluate program effectiveness. During FY13, 335 RadCon program-related PERs were generated. • Program oversight identified 206 of the 335 issues: • 125 PERs generated from 1050 RadCon organization MOPs performed. • 35 PERs written from ten Specialty Assessments. • 24 PERs written from Facility Rep observations. • 22 PERs written from three 10 CFR 835 triennial assessments. • 129 PERs generated from non-oversight field observations. 6

  7. Excellence in Radiological Control Flow-down of regulatory and contractual requirements, RadCon conduct of operations and worker awareness, improving radiological performance, and the qualifications of the staff (included in 33% of PERs written in FY13). • Weaknesses: • RadCon worker awareness issues and conduct of operations issues remain the areas needing most improvement, notably control-point operations and procedure compliance. • Strengths: • Flow-down of requirements into the WRPS RadCon program and the RadCon self-assessment and corrective action management program. 7

  8. Radiological Standards Administrative Control Levels, dose limits, contamination control, and radiological postings (included in 16% of PERs written in FY13). • Weakness: • Maintaining outdoor radiological postings. • Compliance Team improving this area. • Strengths: • Effective contamination control: Four non-reportable clothing contaminations and no skin contaminations reported in past 12 months. • No internal depositions have been recorded during the WRPS contract period. 8

  9. Conduct of Radiological Work Conduct of radiological work, work preparation, entry and exit requirements, and radiological work controls (included in 21% of PERs written in FY13). • Weakness: • Improvement in Rad Work planning has been observed but continued improvement is warranted. • Strengths: • The company’s overall collective dose is low in comparison to other DOE contractors of comparable work/size. Contamination control and dose reduction are well planned into the work planning process. 9

  10. Average Worker Dose Comparison – DOE Sites Page 10

  11. Radioactive Materials Radioactive material (RAM) identification, storage, packaging, and control; release of materials and equipment; source controls; and solid radioactive waste management (included in 13% of PERs written in FY13). • Weakness: • Issues related to environmental degradation of RAM labels have been reduced but continue to be a challenge to maintain. • Strengths: • Significant improvement in packaging and control of reusable contaminated equipment. Corrective actions on previous source control issues have been effective. 11

  12. Radiological Health Support Operations Internal and external dosimetry, respiratory protection, radiological monitoring and surveys, and instrumentation maintenance and calibration (included in 13% of PERs written in FY13). • Weakness: • Setup and issuance of electronic personnel dosimeters need improvement (adverse trend self-identified in August). • Strengths: • Strong dosimetry program. Initiative to self-perform Dosimetry Operations has been successful. 12

  13. Training and Qualifications General Employee Radiological Training, radiological worker training, RadCon technician training, and management and technical support training (included in 1% of PERs written in FY13). • Weakness: • Flow of communication regarding program changes to the HPTs needs to be improved. • Strength: • Completed alignment of TOC RadCon staff training and qualification with DOE training requirements for key RadCon personnel. 13

  14. Radiological Records Radiological records, RadCon procedures, RadCon surveys, instrument and calibration records, and records management (included in 6% of PERs written in FY13). • Weakness: • Maintaining error-free radiological records continues to be an issue. Implementation of Survey Simple will significantly help correct this issue. • Strength: • RadCon procedure process strengthened. Issues requiring a procedure modification have been significantly reduced. 14

  15. Benchmarking Related to SMP • Material and Equipment Release Program. • Purpose: To identify strengths and efficiencies for incorporation during DOE O 458.1 implementation changes. • Benchmark contractor programs made up of Hanford Site and URS affiliates: • WRPS’ program compares favorably and consistently with CHPRC, ICP, LLNL, SRS, and WIPP. • Results of benchmarking presented to WRPS RadCon Forum. • No major changes proposed as a result of benchmarking. 15

  16. SMP Opportunities • Survey Simple. • Radiological survey records are being moved to electronic records that will reduce error rates and improve the ability to search for specific items in a survey report. (Full implementation scheduled for 1/15/2014.) • Equipment and Material Radiological Release. • The radiological release program is being revised to meet DOE 458.1. Minimal impacts are anticipated. (Full implementation scheduled for 3/1/2014.) • Eliminating the wait times for ACES entries. • Efficiency improvements in ACES operations. 16

  17. SMP Threats • Inconsistency of the TOC RadCon program across project lines. • Management and exempt staff movement initiated. • Organization focus on compliance leading to missed efficiency and operational support improvement opportunities. • Non-compliance based assessment program starting in CY14. • Over-reliance on written communication (required reading, lessons learned, “Rad Happenings”) resulting in less face time between HPTs and first-line managers (FLM). • Program providing information for morning meetings being developed. 17

  18. SMP Improvement Initiatives • Reduction in the overall number of Radiological Areas in TOC-managed facilities/areas. (Award Fee item) • Down-posting plan being developed with support from the line organizations. • Reduction of litter/debris and vegetation growth in TOC radiologically posted areas. (Award Fee item) • Initiated an FLM weekly walk-down MOP to evaluate facility status. • Create an environment where rad workers actively monitor each other and help improve performance. (Award Fee item) • Developed a FY14 peer-to-peer communication plan. 18

  19. Conclusion • The Radiological Controls SMP is concluded to be effectively implemented. • Continuing emphasis needed to improve the conduct of radiological operations, worker awareness, and conduct of radiological work. • Average worker dose, maximum worker dose, internal depositions, and skin and clothing contamination indicators among the best in the complex. 19

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