Expert Solutions to Compliance with the Revised 10 CFR 835

New Requirements for DOE Prime Contractors

With publication of the revised final rule, 10 CFR 835 (Occupational Radiation Protection), in June 2007, DOE prime contractors are now required to:

• Revise their Radiation Protection Programs by January 4, 2008, to include a plan that will explain how the site will achieve compliance with the revised rule, and
• Implement the plan and achieve full compliance with the revised rule by July 9, 2010.

What Does This Mean for DOE Prime Contractors?

The revision will impact several site operations:

SIGNIFICANT IMPACTS: Shifts from ICRP 26 and 30 methodologies to ICRP 60. This could require sites to recalculate doses, change technical basis documents, develop new computer models, train dosimetrists, and create new recordkeeping methods.

INTERMEDIATE IMPACTS: Lowers the threshold for labeling radioactive material for nearly 20 radionuclides. Some areas, facilities, and equipment on site may now require labeling.

INTERMEDIATE IMPACTS: Recognizes DOE-approved authorized limits, which may impact DOE contractors who would like to pursue DOE authorized limits — a process typically involving dose modeling and negotiation with DOE.

INTERMEDIATE IMPACTS: Requires DOE contractors to maintain bioassay and air monitoring results to estimate unrecorded internal dose. This may require some sites to change the way they calculate internal doses.

How can Dade Moeller & Associates Help?

• Strategy. We will develop an implementation plan, schedule, and milestones for successfully achieving compliance with the revised rule.
• Analysis. We will perform a gap analysis, comparing the current radiological control program to the new requirements.
• Budget. We will assist in determining the costs associated with implementation.
• Documentation. We will identify procedures and technical basis documents needing revision in order to implement the revised rule.
• Training. We will develop and revise training modules for staff impacted by the rule.
• Communication. We will effectively communicate the changes to staff and managers.
• Implementation. We will assist in implementing the radiological control program changes.
• Verification. We will perform a follow-up assessment to ensure compliance.

Why Dade Moeller & Associates?

We offer an extensive range of professional consulting services for radiation protection program management, dosimetry-related services, and radiological operations. Our staff includes 34 Certified Health Physicists — more than any other private entity in the United States.

• Experience. We have extensive corporate and individual experience with 10 CFR Part 835 that has spanned the years since the original issuance of the rule.
• Reputation. We have a solid reputation throughout the DOE complex for supporting contractors with the development and review of their Radiation Protection Programs — Hanford, SNL, LLNL, Yucca Mountain, ANL, and West Valley.
• Expertise. In addition to the development and review of contractors' radiation protection plans, we also have considerable knowledge of working with DOE's internal and external dosimetry programs and records, as well as developing authorized limits and clearance levels.