1. Brookhaven Science Associates U.S. Department of Energy Sustaining Excellence in Radiological Operations Through Peer Surveillance C. Schaefer, CHP D. Ryan, CHMM

2. Brookhaven Science Associates U.S. Department of Energy 2 Surveillance vs. Assessment n A sufficient amount of data must be collected on an on-going basis to establish that a management system is uniformly implemented, functioning well and continually improving n Periodic compliance assessments typically do not provide enough data to allow this conclusion to be drawn

3. Brookhaven Science Associates U.S. Department of Energy 3 Surveillance vs. Assessment (cont.) n 10CFR835.102 is the driver for BNL’s Triennial Assessment Program n All functional elements (19) must be audited for both content and implementation every 36 months n These assessments demonstrate compliance to requirements, but have limited impact on improving: consistency of implementation organizational performance in radiological operations

4. Brookhaven Science Associates U.S. Department of Energy 4 RCD’s Peer Surveillance Program n Surveillances are checklists containing 10-20 questions developed directly from implementing procedures (removes ambiguity from the surveillance process) n Effective mechanism for identifying trends or recurrences n Designed to be used by field-deployed professionals and Radiological Control Technicians n Typically require 2-4 hours to complete n Can be used when observing work or reviewing field program documents (e.g., RWPs, surveys, ALARA records, etc.)

5. Brookhaven Science Associates U.S. Department of Energy 5 RCD’s Peer Surveillance Program n RCD has eleven (11) approved Surveillance Checklists: Posting and Labeling Sealed Source Control & Radiation Generating Device Programs Radiological Work Control & Area Monitoring Programs Radioactive Material Control Airborne Radioactivity Sampling and Analysis Radiological Records ALARA & Bioassay Programs Radiological Survey Program

6. Brookhaven Science Associates U.S. Department of Energy 6 RCD’s Peer Surveillance Program n Each surveillance is available electronically through the RCD Homepage to improve document control (no hoarding of outdated surveillance forms on individual PCs) n Surveillance questions are answered either as “Yes”, “No” or “N/A” n In most cases, a “No” response means a procedural requirement is not being implemented n A “No” response requires the assessor to provide written comments

7. Brookhaven Science Associates U.S. Department of Energy 7 RCD’s Peer Surveillance Program n RCD Self-Assessment web page RCD Self-Assessment web page

8. Brookhaven Science Associates U.S. Department of Energy 8 RCD’s Peer Surveillance Program n The assessor provides comments and suggestions to improve programs, implementing procedures, and/or clarifications to surveillance questions. n After signing the surveillance, the assessor forwards it to the RCD Quality Assurance representative for review. n RCD Self-Assessment web page RCD Self-Assessment web page

9. Brookhaven Science Associates U.S. Department of Energy 9 RCD’s Surveillance Process n 7 Facility Support Representatives (field- deployed professionals) are assigned to conduct a quarterly surveillance of their assigned facilities n 7 Radiological Control Technicians conduct quarterly surveillances of peer facilities n Total: 14 surveillances per quarter which generate ~ 200-250 radiological control program sampling events

10. Brookhaven Science Associates U.S. Department of Energy 10 RCD’s Surveillance Process n Completed surveillances are turned in to the Division’s Quality Assurance Representative (QAR) n The QAR assigns a tracking #, trends low-level issues, signs each surveillance and forwards the surveillance to the Facility Support (FS) Manager n QAR periodically provides RCD Management with surveillance trending results so that appropriate follow up action(s) can be taken

11. Brookhaven Science Associates U.S. Department of Energy 11 RCD’s Surveillance Process n FS Manager reviews and signs each surveillance, and assists the RCD Manager in developing corrective actions and follow up to opportunities for improvement n RCD Manager reviews each surveillance for PAAA applicability, approves each surveillance, and forwards appropriate surveillances to the BNL PAAA Coordinator n RCD Manager forwards approved surveillances to the RCD FATS Coordinator for tracking of corrective actions n The FS Manager periodically disseminates results to FS personnel during staff meetings

12. Brookhaven Science Associates U.S. Department of Energy 12 Recent Surveillance Program Issues n RWP dose estimates not always completed IAW procedure requirements n No objective evidence that the FS Rep. and Line Management annually reviewing individuals for inclusion in the BNL Confirmatory Bioassay Program n PPE Donning and Doffing instructions not always posted at work sites n PPE Donning and Doffing instructions not always consistent with RWP PPE requirements

13. Brookhaven Science Associates U.S. Department of Energy 13 Recent Surveillance Program Issues n Frisking instructions not always posted at Frisking Stations (some confusion when RCT continuous coverage provided) n Radiation Generating Device (RGD) User Lists not always available n Dose rate (mrem/hr) and exposure rate (mR/hr) units recorded on radiological surveys inappropriate for the instrumentation used n BNL Sealed Source Database contains outdated information

14. Brookhaven Science Associates U.S. Department of Energy 14 Recent Opportunities for Improvement n To improve consistency, all ERP radiological area postings modified to state “Contact HP for RWP” n Posting surveillance identified opportunity to reduce Collider-Accelerator Radiation Area footprint in Bldg. 912 n Sealed Source Database does not reflect recent BNL organizational changes (e.g., transfer of PET from Chemistry to Medical) n Some organizations not using BTMS to track staff qualifications (share with Training Coordinator) n Include BNL ALARA Program Coordinator on distribution of monthly safety meeting minutes

15. Brookhaven Science Associates U.S. Department of Energy 15 Recent Opportunities for Improvement n Simplify the RGD Program by merging the System-Specific Checklist and Authorized Users List (completed 11/2007) n Clarify requirements for participation in BNL Confirmatory Bioassay Program (Plant Engineering TBD approved in 2007) n Review proper response to EPD alarms as part of pre-job briefing when EPDs are worn for RWP work in High Radiation Areas

16. Brookhaven Science Associates U.S. Department of Energy 16 Conclusion n RCD’s Surveillance Program provides several advantages: Provides Management with additional data on management system performance Allows for early identification of adverse trends Helps promote uniformity of implementation across multiple organizations Provides field-deployed staff with a venue for offering Opportunities for Improvement

17. Brookhaven Science Associates U.S. Department of Energy 17 Questions?