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

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

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?)

RCD’s Approach to its Triennial Assessment Program 10CFR835 issued in 1993; 1 st 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

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

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

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 3 rd year dedicate 3-4 months for team to assess each BNL facility Nothing done during the intervening years

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 1 st Task: Overhaul the BNL RPP Huge expectations for immediate improvement

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

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)

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

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

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

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.)

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”

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

Questions?