**Radiation Protection: Lines of Inquiry**

**FUNCTIONAL AREA GOAL:** A program which assures the successful conduct
of occupational radiation protection operations consistent with the
requirements of 10 CFR 835.

**Requirements:**

10 CFR 835 -- Occupational Radiation Protection

**Lines of Inquiry:**

**Performance Objective 1: Organization and Administration**

-   Is there a DOE approved RPP?

-   Does the RPP adequately address the requirements of 10 CFR 835?

-   Does the RPP include formal plans and measures for applying the as
    low as reasonably achievable (ALARA) process to occupational
    exposure?

-   Are radiological activities being conducted in accordance with the
    RPP?

-   Are identified guides and technical standards, that are to be
    adopted as the means to meet 10 CFR Part 835, being followed?

-   Does the RPP clearly identify any exemptions that have been approved
    from the subject requirements?

-   If yes, are the conditions on the exemption decision being
    implemented?

-   Does the site RPP adequately cover all the types of radiological
    activities conducted?

-   Are updates of the RPP submitted to DOE as required?

-   Are changes submitted whenever a change or an addition to the RPP is
    made?

-   Are changes submitted prior to the initiation of a task not within
    the scope of the RPP?

-   Are subcontractor activities addressed in an approved RPP (are they
    covered under a single site-wide RPP or do subcontractors have their
    own RPPs)?

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-   Do the audit plans and completed audits include examination of
    program content and implementation?

-   Are assessors who review program content qualified ( per 835.103)?

-   Do the audit plans and completed audits reflect that the process
    ensures that all functional elements are reviewed no less frequently
    than every 36 months?

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-   Are there adequate qualification standards for the personnel
    reviewed?

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-   Do the records show that, for the personnel reviewed, personnel meet
    qualification standards and have completed required training and
    retraining?

-   Are procedures commensurate with the radiological hazards created by
    the activity?

    -   Are procedures technically adequate?

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    -   Are the procedures consistent with the education, training, and
        skills of the individuals exposed to those hazards?

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    -   Are affected personnel knowledgeable of procedure requirements
        and understand their role in effectively implementing
        requirements?

-   Are procedures effectively implemented?

**Performance Objective 2: [ALARA]{.smallcaps} Program**

-   Is there evidence of management commitment to the ALARA program?

-   Is there evidence of ALARA training consistent with the provisions
    of 10 CFR 835 103 and 835.901?

-   Are the plans and measures for applying the ALARA process to
    occupational exposures reflected in procedures that are commensurate
    with the expected level of exposure, per §835.104?

-   Are the design and control provisions in 10 CFR 835 subpart K being
    met?

-   Is there evidence of either physical design features (e.g.
    confinement ventilation, remote handling, shielding) or
    administrative controls in radiological work areas?

-   Were optimization methods used to ensure that exposure is maintained
    ALARA in developing facility design and physical controls?

-   Do the dose rates in facilities built or modified after 1995 meet
    the design objectives? -- ALARA and less than 0.5 mrem/hr for a
    continuously occupied area

-   In facilities built or modified after 1995 are there design feature
    that minimize the chance of releases of airborne radioactive
    materials and should a release occur, do these features control
    intakes to levels that are ALARA?

-   During routine operations are doses in any workplace greater than
    the limits in 835.202?

-   Do the physical and administrative controls in place implement the
    ALARA process?

**Performance Objective 3: External Dosimetry**

-   Is there adequate staff provided with appropriate technical
    training?

-   How many employees work in the program and what is their education
    and experience in external dosimetry?

-   Is there a technical basis document that explains each program
    element?

-   What is the latest technical basis document and is it adequate?

-   Are there procedures that address each step in the activities that
    determine external dose?

-   Are there written procedures for dosimeter processing?

-   Are there adequate criteria and methods for identifying individuals
    who require individual monitoring?

    -   What are the criteria for badging individuals?

    -   What are the criteria for issuing supplemental dosimeters?

-   Are there appropriate personnel dosimeter measurement methods and
    frequencies?

    -   Are correct dosimeters used for given radiation exposures?

    -   Are the frequencies for dosimeter exchange correct?

-   Are there adequate methods for control, accountability, and safe
    handling of dosimeters?

-   Are control, accountability and safe handling of dosimeters in
    effect?

-   Is there evidence of proper placement of dosimeters?

    -   Are workers wearing dosimeters correctly?

-   Are appropriate dosimetric models and default parameters for
    evaluating external dose used?

    -   Are appropriate dosimetric and default parameters used for
        estimating doses when dosimeters are unavailable?

-   Is there timely analysis of personnel dosimeter measurements and
    trans­mission of results, dose evaluation, and recommendations to
    monitored individuals, management, and DOE, as appropriate?

    -   When are results of processing dosimeters available?

    -   When are external doses provided to individuals?

-   Is there a quality assurance (QA) program that covers all steps in
    the activities that determine individual external dose?

-   Is the program accredited by DOE?

-   Are the proper categories tested?

**Performance Objective 4: Internal Dosimetry**

-   Is there adequate staff with appropriate technical training?

    -   How many employees work in the program and what is their
        education and experience in internal dosimetry?

-   Is there an internal dosimetry technical basis documentation
    providing scientific information and other rationale explaining
    essential elements of the internal dosimetry program to support dose
    evaluation methods?

-   What is the latest technical basis document and is it adequate?

-   Are there written policies and procedures covering essential steps
    in the activities used to determine worker internal dose?

-   Are there written procedures for determining internal doses?

-   Is there defined criteria for identifying workers who need to
    participate in the individual monitoring program?

    -   What are the criteria for enrolling individuals in the bioassay
        program?

-   Are there appropriate radiobioassay measurement methods and
    frequencies;

-   Are correct measurement methods used for given radiation exposures?

-   Are the frequencies for sample collection correct?

-   Are there methods for control, accountability, and safe handling of
    samples;

-   Are control, accountability and safe handling of samples in effect?

-   Are appropriate dosimetric models and default parameters for
    evaluating internal dose used?

-   Are appropriate dosimetric and default parameters used for
    estimating doses?

-   Is there timely analysis of radiobioassay samples and measurements,
    transmission of results, dose evaluation, and recommendations to
    operations management;

    -   When are results of bioassay available?

    -   When are internal doses provided to individuals?

-   Is there adequate detection capability and quality of radiobioassay
    measurements;

-   Are the procedures adequate to determine levels present?

    -   What is the L~C~ or MDA for the procedures?

    -   Is the correct quantity being used to determine positive
        results?

-   Are there defined criteria and actions for identifying individuals
    with suspected intakes, based on workplace measurements and
    radiobioassay measurements?

-   How are suspected intakes identified?

-   Are there appropriate action level guidelines?

    -   What are the guidelines for taking action?

-   Is there a defined program to report internal doses to workers,
    management, and DOE?

    -   When are internal doses reported to individuals?

    -   When are internal doses reported to management?

-   Is there a quality assurance program covering essential steps in the
    activities that determine worker internal dose?

-   Is the program accredited by DOE?

-   Are the proper categories tested?

**Performance Objective 5: Area/Workplace Monitoring**

-   Is area monitoring performed to: (1) Document radiological
    conditions, (2)Detect changes in radiological conditions, (4) Detect
    the gradual buildup of radioactive material;(5) Verify the
    effectiveness of engineering and process controls in containing
    radioactive material and reducing radiation exposure; and (6)
    Identify and control potential sources of individual exposure to
    radiation and/or radioactive materials?

-   Through documents reviews and interviews determine the frequencies
    of radioactive surface contamination surveys. Are these frequencies
    appropriate?

-   For the radionuclide being measured, are the field or laboratory
    instruments used to analyze surface swipes or to take direct surface
    contamination measurements sufficiently sensitive to detect the
    surface contamination at the levels specified in Appendix D of 10
    CFR 835?

-   Are the instruments and equipment used for monitoring: (1)
    Periodically maintained and calibrated on an established
    frequency; (2) Appropriate for the type(s), levels, and energies of
    the radiation(s) encountered; (3) Appropriate for existing
    environmental conditions; and (4) Routinely tested for operability?

-   Is airborne radioactivity monitored where an individual is likely to
    receive an exposure of 40 or more DAC-hours in a year?

-   Is airborne radioactivity monitored as necessary to characterize the
    airborne radioactivity hazard where respiratory protective devices
    are required for protection against airborne radionuclides?

-   Is real-time air monitoring performed as necessary to detect and
    provide warning of airborne radioactivity concentrations that
    warrant immediate action to terminate inhalation of airborne
    radioactive material?

-   Are packages received from transportation containing radioactive
    material exceeding a Type A quantity (as defined in 10 CFR 71.4)
    monitored for external radiation levels?

-   Are packages received from transportation containing radioactive
    material (other than special form or gaseous materials) monitored
    for surface contamination?

-   Is the monitoring of packages containing radioactive material
    described above completed as soon as practicable following receipt
    of the package, but not later than 8 hours after the beginning of
    the working day following receipt of the package?

**Performance Objective 6: Radiological Control**

-   Are RWPs required for:

    -   Entry into radiological areas?

    -   Handling of materials with removable contamination that exceed
        the values of 10 CFR 835?

    -   Work in localized benchtop areas, laboratory fume hoods, sample
        sinks, and containment devices that has the potential to
        generate contamination in areas that are otherwise free of
        contamination?

    -   Work that disturbs the soil in soil contamination areas?

    -   Work that involves digging in underground radioactive material
        areas?

-   Do the RWPs adequately describe the:

    -   Work activities?

    -   Work area radiological conditions?

    -   Dose rate?

    -   Contamination levels?

    -   Airborne levels?

    -   Dosimetry requirements?

    -   Pre-job briefing requirements?

    -   Training requirements for entry?

    -   Protective clothing and respiratory protection requirements?

    -   Radiological Control coverage requirements and stay time
        controls?

    -   Limiting radiological conditions that may void the RWP?

    -   Special dose or contamination reduction considerations(ALARA
        reviews)?

    -   Special personnel frisking considerations?

-   Do the RWPs have authorizing signatures?

-   Have people signed in on out on the RWPs as required?

-   Observe ongoing work -- are people adhering to RWP requirements?

-   Discuss with workers and RCTs -- are they knowledgeable about their
    RWP and its requirements and the work area radiological conditions?

-   Do individuals have GERT equivalent prior to unescorted access to
    controlled areas \[see 835.901(a)\]?

-   Are personnel entry controls maintained for each radiological area?

-   Is the degree of control commensurate with existing and potential
    radiological hazards within the area?

-   Does access to radiological areas require appropriate training?

-   Are one or more of the following methods used to ensure control?

    -   Signs and barricades

    -   Control devices on entrances

    -   Conspicuous visual and/or audible alarms

    -   Locked entrance ways

    -   Administrative controls

-   Are control(s) installed at radiological area exits such that they
    will not prevent rapid evacuation of personnel under emergency
    conditions?

-   For each entry into a high radiation area:

    -   Is the area monitored as necessary during access to determine
        the exposure rates to which the individuals are exposed?

    -   Is each individual monitored by a supplemental dosimetry device
        or other means capable of providing an immediate estimate of the
        individual\'s integrated deep dose equivalent during the entry?

-   Are adequate controls established (per 10 CFR 835.502(b)) for each
    entrance or access point to a high radiation area where radiation
    levels exist such that an individual could exceed a deep dose
    equivalent to the whole body of 1 rem (0.01 sievert) in any one hour
    at 30 centimeters from the source or from any surface that the
    radiation penetrates?

-   Are additional measures implemented (per 10 CFR 835.502(c)) to
    ensure individuals are not able to gain unauthorized or inadvertent
    access to very high radiation areas?

-   Is protective clothing required for entry to areas in which
    removable contamination exists at levels exceeding the removable
    surface contamination values specified in 10 CFR 835?

-   Is the selection and use of the protective clothing appropriate for
    the hazard?

-   Are individuals exiting contamination, high contamination, or
    airborne radioactivity areas monitored for the presence of surface
    contamination?

-   Is the monitoring adequate?

-   Do postings and labels include the standard radiation warning
    trefoil in black or magenta imposed upon a yellow background?

-   Are signs clearly and conspicuously posted and do they include
    radiological protection instructions?

-   Do site procedures adequately require posting and labeling
    consistent with 10 CFR 835?

-   Are areas posted as required by 10 CFR 835?

-   Are items and containers appropriately labeled?

-   Do labels provide sufficient information to permit individuals
    handling, using, or working in the vicinity of the items or
    containers, to take precautions to avoid or control exposures?

-   Does the site control the release of material and equipment with
    removable surface contamination levels on accessible surfaces
    exceeding the removable surface contamination values specified in 10
    CFR 835?

-   Does the site control the release of material and equipment if prior
    use suggests that the removable surface contamination levels on
    inaccessible surfaces are likely to exceed the removable surface
    contamination values specified in 10 CFR 835?

-   Does the site implement appropriate monitoring and controls for the
    movement on-site from one radiological area for immediate placement
    in another radiological area of material and equipment with
    removable surface contamination values exceeding the values
    specified in 10 CFR 835?

-   Does the site control material and equipment with fixed
    contamination levels that exceed the total surface contamination
    values specified in 10 CFR 835 which is released for use in
    controlled areas outside of radiological areas?

-   Are removable surface contamination levels are below the removable
    surface contamination values specified in 10 CFR 835?

-   Is the material or equipment routinely monitored and clearly marked
    or labeled to alert personnel of the contaminated status?

-   Are appropriate controls maintained and verified which prevent the
    inadvertent transfer of removable contamination to locations outside
    of radiological areas under normal operating conditions?

-   Are areas in which contamination levels exceed the values specified
    in 10 CFR 835 controlled in a manner commensurate with the physical
    and chemical characteristics of the contaminant, the radionuclides
    present, and the fixed and removable surface contamination levels?

-   Are areas accessible to individuals where the measured total surface
    contamination levels exceed, but the removable surface contamination
    levels are less than, corresponding surface contamination values
    specified in 10 CFR 835 adequately controlled when located outside
    of radiological areas?

-   Are the areas routinely monitored to ensure the removable surface
    contamination level remains below the removable surface
    contamination values specified in 10 CFR 835?

-   Are the areas conspicuously marked to warn individuals of the
    contaminated status?

-   Is each accountable sealed radioactive source inventoried at
    intervals not to exceed six months?

-   Does the inventory establish the physical location of each
    accountable sealed radioactive source, verify the presence and
    adequacy of associated postings and labels; and establish the
    adequacy of storage locations, containers, and devices?

-   Is each accountable sealed radioactive source subject to a source
    leak test upon receipt, when damage is suspected, and at intervals
    not to exceed six months?

-   Is the source leak test capable of detecting radioactive material
    leakage equal to or exceeding 0.005 microcurie?

-   Are sources stored in a controlled location, subject to periodic
    inventory and subject to source leak testing prior to being returned
    to service?

-   Are accountable sealed radioactive sources, found to be leaking
    radioactive material, controlled in a manner that minimizes the
    spread of radioactive contamination?

> **Performance Objective 7: Emergency Exposure Situations**

-   Was the risk of injury to those individuals involved in rescue and
    recovery operations minimized?

-   Did operating management weigh actual and potential risks against
    the benefits to be gained?

-   Was any individual required to perform rescue actions that might
    involve substantial personal risk?

-   Did any employees receive emergency exposures in the last five
    years?

-   Were they permitted to return to work during the calendar year in
    which the emergency occurred?

    -   Did contractor management and DOE field management approve in
        advance?

    -   Was the employee counseled regarding additional exposure?

    -   Did the employee sign a statement to agree to return to work?

    -   Were all doses exceeding the limits recorded in the employee's
        file?

    -   Did contractor management notify the DOE field organization when
        the conditions resulting in an emergency dose in excess of the
        limits was eliminated?

> **Performance Objective 8: Nuclear Accident Dosimetry**

-   How are individuals involved in a nuclear accident screened for
    follow-up?

-   What methods are available for analysis of biological materials?

-   What fixed nuclear accident dosimeters are in place?

-   How are PNADs assigned and were employees wearing them during any
    criticality event?

> **Performance Objective 9: Records**

-   Does the site have a records retention program?

-   Per §835.1(c), are individual monitoring records collected and
    maintained for occupational exposure resulting from activities
    excluded from 10 CFR 835 (e.g. work for the NRC)?

-   Are these records used to asses compliance with the dose limits in
    §835.202?

-   Per §835.4, are the quantities for radioactivity, absorbed dose,
    dose equivalent and exposure, used in records indicated in units of
    curie, rad, roentgen, or rem?

-   Are records maintained to document doses received by all individuals
    for whom monitoring was required pursuant to § 835.402 and to
    document doses received during planned special exposures, unplanned
    doses exceeding the monitoring thresholds of § 835.402, and
    authorized emergency exposures?

-   Are the results of individual external and internal dose monitoring
    that is performed, but not required by § 835.402, recorded?
    Recording of nonuniform shallow dose equivalent to the skin is not
    required if the dose is less than 2 percent of the limit specified
    for the skin at § 835.202(a)(4).

-   Are the records sufficient to evaluate compliance with the dose
    limits in subpart C of 10 CFR 835?

-   Are the records sufficient to provide dose information necessary to
    complete reports required by subpart I of 10 CFR 835?

-   Do the records include the following quantities for external dose
    received during the year: (i) The effective dose equivalent from
    external sources of radiation (deep dose equivalent may be used as
    effective dose equivalent for external exposure); (ii) The lens of
    the eye dose equivalent; (iii) The shallow dose equivalent to the
    skin; and (iv) The shallow dose equivalent to the extremities?

-   Do the records include the following information for internal dose
    resulting from intakes received during the year: (i) Committed
    effective dose equivalent; (ii) Committed dose equivalent to any
    organ or tissue of concern; and (iii) Identity of radionuclides?

-   Do the records include the following quantities for the summation of
    the external and internal dose: (i) Total effective dose equivalent
    in a year; (ii) For any organ or tissue assigned an internal dose
    during the year, the sum of the deep dose equivalent from external
    exposures and the committed dose equivalent to that organ or tissue;
    and (iii) Cumulative total effective dose equivalent?

-   Do the records include the dose equivalent to the embryo/fetus of a
    declared pregnant worker?

-   Has documentation of all occupational doses received during the
    current year, (except for doses from planned special exposures and
    emergency exposures) been obtained to demonstrate compliance with
    the dose limits in § 835.202(a)?

-   Have reasonable efforts shall be made to obtain complete records of
    prior years occupational internal and external doses for workers
    monitored in accordance with § 835.402?

-   Are the records specified in this section that are identified with a
    specific individual shall be readily available to that individual?

-   Have data necessary to allow future verification or reassessment of
    the recorded doses been recorded?

-   Does the records management program include a process to ensure that
    all records required by this section will be transferred to the DOE
    upon cessation of activities at the site that could cause exposure
    to individuals?

-   Have the results of monitoring for radiation and radioactive
    material as required by subparts E and L of this part (except for
    monitoring required by § 835.1102(d)) been documented and
    maintained?

-   Have the results of monitoring used to determine individual
    occupational dose from external and internal sources been documented
    and maintained?

-   Have the results of monitoring for the release and control of
    material and equipment (as required by § 835.1101(d)) been
    documented and maintained?

-   Have the results of maintenance and calibration performed on
    instruments and equipment (as required by § 835.401(b)).been
    documented and maintained?

-   Have training records been maintained, to demonstrate compliance
    with § 835.901?

-   Have actions taken to maintain occupational exposures ALARA
    (including the actions required for this purpose by § 835.101, as
    well as facility design and control actions required by §§ 835.1001,
    835.1002, and 835.1003), been documented?

-   Have records been maintained to document the results of internal
    audits and other reviews of program content and implementation?

-   Have records containing written declarations of pregnancy, including
    the estimated date of conception, and revocations of declarations of
    pregnancy been maintained?

-   Have changes in equipment, techniques, and procedures used for
    monitoring been documented?

-   Have records been maintained to demonstrate compliance with the
    requirements o for sealed radioactive source control, inventory, and
    source leak tests?

**Performance Objective10: Reports to Individuals**

-   Have annual reports of dose been sent to individuals?

-   Did the reports contain the required information?

-   Did any unmonitored individuals receive occupational dose and
    receive an annual reports?

-   Were terminated employees provided termination reports?

-   Were employees provided their records upon request?

**Performance Objective 11: Radiation Safety Training**

-   For GERT equivalent, has each individual completed radiation safety
    training on the topics established at § 835.901(c) commensurate with
    the hazards in the area and the required controls?

-   Was the training provided/required before individuals were permitted
    unescorted access to controlled areas?

-   Was the training provided/required before individuals received
    occupational dose during access to controlled areas at a DOE site or
    facility?

-   Was the training provided/required before individuals were permitted
    unescorted access to radiological areas?

-   Was the training provided/required before performing unescorted
    assignments as a radiological worker?

-   Have individuals completed radiation safety training, examinations,
    and performance demonstrations required for entry to the area and
    performance of the work?

-   Do procedures require that all escorted individuals comply with the
    documented radiation protection program?

-   Does the retraining include successful completion of an examination?

**Performance Objective 12: Limits for Embryo/Fetus**

-   Were any written declarations of pregnancy submitted?

-   Were any written declarations of pregnancy withdrawn?

-   Do records indicate that continuation of the work assignment would
    lead to doses that exceed 0.5 rem?

-   Were work restrictions developed to avoid exceeding 0.5 rem
    exposure?

-   Are doses properly calculated?