Advantages of Using External Assessors

1. Advantages of Using External Assessors C. Schaefer, BNL H. Kahnhauser, BNL

2. Advantages of Using External Assessors • Management system compliance audits represent organizational learning opportunities for management system owners • One of the more effective processes for evaluating fundamental ISM implementation • A significant investment is made in planning for, scheduling and conducting assessments • Assessments cross multiple organizational boundaries • Program owners are resource constrained and need to optimize assessments

3. Advantages of Using External Assessors • Factors affecting assessment optimization include: • Assessment scope • Assessment duration • # of Assessors (i.e., do I need one person or a small team?) • Assessment Team composition (on-site SMEs, external SMEs or both?)

4. RCD’s Approach to its Triennial Assessment Program • 10CFR835 issued in 1993; 1st amendment issued in 1999: requires each M&O Contractor to audit each functional element of its radiological protection plan (RPP) every 3 years • The BNL RPP covers a wide array of radiological operations and activities

5. RCD’s Approach to its Triennial Assessment Program • Scope of BNL RPP • Multi-purpose Laboratory • Large and small accelerators (C-AD, NSLS, ATF, Cyclotrons) • Bench top applications • Radiation generating devices • Isotope Production and Synthesis • Waste operations • Environmental Restoration

6. BNL RPP Functional Elements • Radiological Work Planning and Radiological Controls • Entry and Exit Controls • Posting and Labeling • Release of Materials and Equipment • Area Monitoring (Contamination, Airborne) • Sealed Source Control • Instrumentation and Calibration • Internal and External Dosimetry • ALARA • Radiological Training • Nuclear Accident Dosimetry and Emergency Response • Reports to Individuals, Records

7. RCD’s Initial Approach to its Triennial Assessment Program (pre-1999) • Utilize team of 3 support staff • Massive checklists based on 10CFR835 requirements and implementing guides • No reliance on line organizations or external organizations to provide program assessment support • every 3rd year dedicate 3-4 months for team to assess each BNL facility • Nothing done during the intervening years

8. A Change in Approach • 1998: HFBR Tritium leak discovered • During the investigation discovered a Lab-wide RPP problem: lack of uniformity of program implementation • Self assessment approach found to be inadequate: not helpful in understanding underlying issues regarding program improvement • BSA awarded the M&O contract • 1st Task: Overhaul the BNL RPP • Huge expectations for immediate improvement

9. A Change in Approach • Working group formed • Multi-year effort to rewrite the BNL Radiological Control Manual and author site-wide Radcon procedures to drive uniformity of implementation • Massive retraining effort • Issue: How to measure the progress being made and the adequacy of the newly structured program? • Decided to bring in SMEs from other Labs to review/benchmark specific functional elements • Help us understand where we needed to be

10. A Change in Approach • External assessors brought in: • PNNL (Radiological Training) • PNNL (Radiation Generating Devices) • PNNL (Contamination Monitoring) • PNNL (Emergency Exposures) • Battelle (Records) • ORNL (Airborne Radioactivity Monitoring) • Consulting companies (Internal Dosimetry, Reports to Individuals)

11. The First Couple of Years • Broke up the 3-month “Team Approach” into targeted topical assessments • Initial assessments very “painful” • External assessors exposed additional program weaknesses • Submitted several NTS Reports • Not even close to implementing “best practices” • Use of external assessors to benchmark progress enabled a dialogue on what other labs were doing and why

12. Additional Benefits • BNL Program no longer “insular” • Avoid the temptation to believe that all is well; rely on an independent opinion based on program document reviews coupled with field verification • Began to understand how other sites were addressing the same requirements • Networking • Time saved in “borrowing” and implementing approaches developed by other Labs • More aware of DOE’s general expectations

13. Examples of What We have Learned/Adopted • Restructured Sealed Source Program tracking thresholds • Need to balance professional judgment and procedural prescription • Requirements implementation matrix to better manage program documents

14. Current Approach • Continue to rely on external SMEs to conduct assessments of functional elements where they have expertise (e.g., Dosimetry, Bioassay, Instrumentation, Radiological Work Controls, etc.) • Use in-house assessors for areas where assessment criteria are simple (e.g., Records, Reports to Individuals, etc.)

15. Current Approach • Conduct 2-4 assessments each year • This allows Management to sample program performance/maturity on an on-going basis • Make it a part of the Division’s Business Plan (pay for travel expenses, housing, per diem) • Provide “Reciprocity”

16. Using External Assessors: Conclusion • Keeps the Program from becoming insular (“theological inbreeding”) • Provides an independent opinion • Helps uncover more subtle program weaknesses • Provides networking opportunities • Faster identification of best practices  faster program maturity

17. Questions?