DEFENSE NUCLEAR FACILITIES SAFETY BOARD
                                                                         
August 24, 1994

MEMORANDUM FOR:  G. W. Cunningham, Technical Director

COPIES:          Board Members

FROM:            J. W. Troan

SUBJECT:         Report on the Radiation Protection Program at the Rocky
                 Flats Environmental Technology Site

1.   Purpose:  This memorandum documents the Defense Nuclear Facilities
     Safety Board (DNFSB) technical staff and outside expert follow-up review
     of the Radiation Protection Program at the Rocky Flats Environmental
     Technology Site (RFETS).  The review was conducted May 4 through 6,
     1994.

2.   Summary:  Elements of the radiation protection program at the RFETS were
     reviewed as a follow-up to a review conducted in August 1993. 
     Highlights include:  

     a.    EG&G is developing an internal surveillance program to assess
           Radiological Control Manual adherence based compliance. This
           should contribute to improving their program.

     b.    Radiological Control Technician training will not be complete by
           December 1994, the DOE commitment date in the Recommendation 91-6
           Implementation Plan.

     c.    Bioassay delinquency may impact program effectiveness.

     d.    The number of radioactive sources that have not been accounted for
           has been significantly reduced since the staff's visit in August
           1993.  Improvements in the accountability program are being
           instituted.  However, comprehensive technical assessments and
           management follow through appeared to require improvement.

     e.    Equipment used for monitoring air for radioactivity does not meet
           the Manual's sensitivity requirements, but short and long term
           improvement efforts are in progress.  

     f.    Radiation levels at dosimeter storage boards are being
           investigated following higher than expected readings.  Results to-
           date do not indicate a problem, but the assessment is not complete
           and data collection continues.   

3.   Background:  DOE Order 5480.11, Radiation Protection for Occupational
     Workers, DOE Notice 5480.6, Radiological Control (Radiological Control
     Manual), and DOE Order 5400.5, Radiation Protection of the Public and
     the Environment, establish the requirements for radiation protection for
     workers, the public and the environment, and provided the basis for the
     radiation protection review at the RFETS.  The review was conducted by:
     James Troan DNFSB Staff; and Ted Quale, DNFSB Outside Expert.

4.  Discussion/Observations:

     a.    DOE Recommendation 91-6 Training -  In the DOE Implementation Plan
           (Rev 2) for Recommendation 91-6, DOE committed to complete General
           Employee Radiological Training, Radiation Worker I and II, and
           Radiological Control Technician Training for all affected workers
           using the standardized core training material by December 1994. 
           However, it is the DNFSB staff's understanding that the
           contractor, EG&G, has not been tasked by the DOE Rocky Flats (DOE-
           RF) to accelerate the training from the originally planned
           completion date of September 1995.

     b.    DOE Recommendation 91-6 Radiological Control Manual Implementation
           - In the DOE Implementation Plan (Rev 2) for Recommendation 91-6,
           the DOE committed to full implementation of the DOE Radiological
           Control Manual (Manual) at the RFETS by October 1997.  However,
           the Board found this date unacceptable from a safety perspective,
           and expected that it be brought into conformity with the deadlines
           for the majority of other defense nuclear facilities.  The
           Secretary of Energy reported in May 1994, that full implementation
           of the Manual at the RFETS is scheduled for December 1, 1996.   

           Implementation of the Manual was discussed during the review, and
           it appeared that implementation may be impacted without additional
           staffing.  It is the DNFSB staff's understanding that this concern
           is due to a hiring freeze, and is further compounded by the
           administrative effort required to assess and implement 10 CFR 835. 
           Both EG&G and DOE-RF personnel appeared to be working to resolve
           this issue.

           An internal surveillance program to assess Manual adherence based
           compliance is being developed.  This should lead to a data base
           that will provide up-to-date evidence and status of compliance. 

     c.    Implementation of Radiological Control Requirements - EG&G
           personnel reported that DOE Order 5480.11, Radiation Protection
           for Occupational Workers and its adherence based compliance
           assessment was complete except for one Short Term Compliance
           Schedule that was superseded by the Manual's requirement.  The
           DNFSB staff requested information to assess subcontractor(s)
           compliance, but data provided has not been adequate to assess
           compliance to DOE Order 5480.11.

     d.    Bioassay Program - Elements of the Bioassay Program were reviewed. 
           A Bioassay Accomplishment Tracking System was initiated in October
           1993.  The DNFSB staff  believes that program performance is poor,
           and that the Tracking System had some shortfalls.  For example,
           EG&G personnel identified that the bioassay delinquency rate is 10
           to 12 percent, and that some delinquencies durations are at a
           point where analysis sensitivity may be impacted.  EG&G personnel
           noted that the program has not been fully effective because the
           procedure has only recently been promulgated.  The DNFSB staff
           believes that these delinquencies may be undermining the
           effectiveness of the program, and dose may be missed. 
           Additionally, it was not apparent to the DNFSB staff that the
           program encompasses all applicable personnel.  For example, EG&G
           personnel described that the program's data base is derived from
           the list of personnel trained on site, and would not track
           visiting workers.  In this case, EG&G personnel explained that it
           would be a sponsors responsibility to see that the bioassay had
           been accomplished.

           EG&G has recently changed the program from fecal sampling for all
           employees to urine sampling for most employees, and fecal sampling
           only for personnel qualified as Radiological Workers II and
           Radiological Control Technicians.  This change has resulted in a
           significant reduction in the internal dosimetry workload.  The
           changes to the internal dosimetry technical basis document are not
           scheduled for issue until September 1994.

     e.    Source Accountability - The number of unaccounted for radioactive
           sources have been significantly reduced since the staff's visit in
           August 1993.  Currently, EG&G personnel report that there are
           fifteen unaccounted for radioactive sources.  Program and training
           improvements have been, and are continuing to be put into place. 
           However, it is the DNFSB staff's opinion that management of
           unaccounted for sources has not fully improved, since a follow-up
           report had not been made to a January 1994 Occurrence Report on
           the subject, and a clear radiological assessment was not
           presented.   

     f.    Air Monitoring - EG&G personnel described the Selective Alpha Air
           Monitors (SAAMs) currently in use as not capable of meeting the
           sensitivity requirements of the Manual (i.e., 8 DAC-hours under
           laboratory conditions).  In the near term, EG&G is making
           improvements to the existing SAAMs (e.g., increase sensitivity to
           approximately 15 DAC-hours).  Additionally, they have a long-term
           effort underway to procure a new monitor that meets the Manual's
           requirement.  The original plans to have monitors delivered in
           mid-1996 have slipped into 1997, and further schedule delays may
           have an impact since the existing SAAMs no longer have repair part
           support and rely on a cannibalization program that is not expected
           to be viable past 1997.  Technical justification of the existing
           system was not presented in the Manual compliance assessment, but
           EG&G personnel indicated that this information was available.

     g.    Radiation Monitoring - During the August 1993 review, EG&G
           personnel noted that there was reason to believe that background
           radiation at a dosimeter storage board in Building 771 were higher
           than expected.  Since then, gamma radiation levels have been
           measured at the dosimeter storage boards and in the vicinity of
           the adjacent Guard Station; and background dosimeter gamma
           radiation results have been trended.  Additional measurement of
           neutron radiation at the storage boards is in progress.  To date,
           gamma radiation results do not indicate higher than expected
           radiation levels. The issue of the use of personal dosimeters for
           personnel who spend a majority of their time in the area (e.g.,
           Guards) was addressed, and EG&G personnel stated that the
           dosimeter was considered to be part of the Guard's equipment and
           was worn when on watch.  Data provided by EG&G personnel indicated
           that Guards wore dosimetry during the fourth quarter 1993, and the
           first quarter 1994.
     
5.   Future Staff Actions:  The DNFSB staff intends to continue to follow
     various aspects of the radiation protection program at the RFETS.  These
     are expected to include:                               
     a.    Assessment of the Manual implementation process, and status of
           compliance.

     b.    Assessment of compliance to Radiological Control requirements at
           the subcontractor levels.

     c.    Assessment of bioassay program performance.

     d.    Monitoring management of locating radioactive sources that are
           unaccounted for.

     e.    Reviewing the progress made in the SAAM upgrade program, and
           assessment of the technical basis for the system.

     f.    Monitoring the results of background radiation level assessments
           at dosimeter storage boards, and verifying that Guards in Building
           771 were wearing appropriate dosimetry in August 1993.