The Health Physics Program at the MK-Ferguson of Oak Ridge Company
“Putting the logical back in radiological.”
Laurence F. Friedman, Ph.D., C.H.P.
Health Physics Manager
MK-Ferguson of Oak Ridge Company, Inc.
P. O. Box 2011
Oak Ridge, TN37831-2011
Phone: (615) 576-2236
Fax: (615) 241-2298
Table of Contents
DESCRIPTION OF PROGRAM1
Support for construction...... 1
Five-site structure...... 2
Importance of interfaces...... 2
PRINCIPLES ON WHICH PROGRAM OPERATES3
Clearly defined mission...... 3
Highly qualified and aggressive staff...... 3
“Not unto us…”...... 4
HISTORY OF PROGRAM5
Performance evaluation...... 6
Cost savings, ALARA...... 6
Zero-budget contract...... 7
The author wishes to thank the following members of his staff who made significant contributions to the preparation of this paper:
M. Bradford Graves, Operations Manager
Marty L. Jamison, CHP, CIH, CSP, Technical Support
Doug Farver, CHP, Dosimetry and Records Manager
Gordon Goos, Instrument Supervisor
W. David Gill, K-25 Health Physics Supervisor
Gary A. Damschen, Radiological Training Specialist
James East, ORNL Health Physics Supervisor
The author also wishes to thank his supervisor, Don K. Artean, Deputy General Manager for Safety and Health, and Frank C. Larvie, President and General Manager, for their support.
The Health Physics Program at MK-Ferguson Page 1
The Health Physics Program at the MK-Ferguson of Oak Ridge Company
“Putting the logical back in radiological.”
It is for this that man was created alone: to teach us that he who causes the death of a single soul is accounted by Scripture as if he had caused the loss of an entire world, and he who sustains a single soul is accounted by Scripture as if he had sustained an entire world.
Mishna, Tractate Sanhedrin
Description of program
MK-Ferguson of Oak Ridge Company (MK-F) is the construction management contractor at six Department of Energy (DOE) sites, five of which have health physics concerns. Up to October 1 of this year, we were a prime and M&O contractor for DOE. As of October 1, we became a subcontractor to Lockheed Martin Energy Systems, Inc. (LMES), the facility manager at the three DOE Oak Ridge sites, plus the Portsmouth, Ohio, and Paducah, Kentucky, gaseous diffusion plants. MK-F provides its own health physics services for all construction activities at the five LMES sites. The sixth site is the Superconducting Supercollider in Texas, at which there are no health physics concerns.
Most of you have a pretty good idea of what goes into a health physics program. The program starts with basic requirements like 10 CFR Part 835, which in turn are derived from ICRP and NCRP recommendations. The program has a set of procedures which implement the requirements. It involves personnel- and workplace- monitoring and protective measures and equipment.
The health physics program at MK-F has all these elements. But the heart of the program, what makes it so unique and effective, is the staff, the staff’s passionate commitment to worker protection, and the staff’s willingness to assume the risks of charting new directions.
Support for construction
The goal of the MK-F Health Physics (HP) Department is to protect MK-F’s workers from the hazards of radiation with a minimum of interference with the progress of construction activities. To accomplish this the HP supervisor at each site works very closely with the construction managers. The supervisor participates in the planning of each job that has radiological concerns and makes sure that allowance for the cost of health physics services is included before the job is put out for bid. The HP supervisor monitors the construction schedule and ensures that the resources needed to cover the job are available when needed. The HP supervisor or members of his/her staff prescribe the protective equipment and procedures that are necessary to achieve a requisite and “reasonably achievable” level of radiological protection for the job.
As indicated above, most of the construction work done by MK-F is performed at sites operated by LMES. At each of these sites, LMES has its own health physics program, its own procedures, its own definitions of the various radiological areas, and its own radiological posting system. In addition, the Portsmouth and Paducah facilities belong to the United States Enrichment Corporation (USEC) and are operated by Lockheed Martin Utility Services (LMUS). USEC is “certified” (as opposed to “licensed”) by the US Nuclear Regulatory Commission (NRC) and operates its HP program according to UEO-1013 [rather than the DOE Radiological Control Manual (RadCon Manual or RCM), DOE/EH-0256T]. There is also a LMES HP presence at Portsmouth and Paducah.
By the end of June 1994, MK-F had fully implemented the RCM. The MK-F Health Physics Department has a single set of procedures that define its program everywhere, although flexibility has been written into the procedures to accommodate differences among the sites. At Portsmouth and Paducah, for example, an Airborne Radioactivity Area is defined at half the concentrations for this type of area in the RCM.
In order to be as responsive as possible to the needs of construction and to deal with variations among the LMES sites, the MK-F Health Physics Department has placed a Health Physics Supervisor in charge of the health physics program at each site. (See Figure 1, page 4) These supervisors are fully qualified to assess hazards and interpret regulations without having to seek authorization or guidance. They have full responsibility for the health physics program at their sites.
Importance of interfaces
Given the complicated environment in which the health physics program operates at each site, the ability to get along with people, particularly people with conflicting agendas, is very important. This is true for all members of the HP staff, not just the supervisors and managers. In addition, the mission of the MKF HP Department is to be responsive to the needs of construction management without compromise of radiological safety. HP staff must be able to listen to construction management, explain the purpose of proposed radiological protection requirements, and negotiate alternate means of providing equivalent protection with less negative impact on construction.
Having multiple health physics programs at a single site can result in disagreements concerning certain radiation protection issues. The comments are not always communicated in the most tactful manner. This makes for an emotionally charged work environment. We have learned to stay focused on our primary goal (i.e., radiation protection), rather than respond emotionally in a way that will exacerbate the conflict. We try to reach win-win solutions to conflicts.
Communication with DOE auditors can be delicate. It helps to have highly qualified people at the site level who can explain the efficacy of the radiological protection requirements that have been adopted, or why certain requirements were not imposed. It is sometimes possible to avoid a finding by tactful but firm and confident communication.
Principles on which program operates
Clearly defined mission
The mission of the MK-Ferguson health physics program is to protect our workers from the effects of radiation and radioactive material in the workplace, no more, no less. This mission derives, in turn, from the sanctity of human life, as articulated in the Talmud (see epigraph) and the corresponding literature of other traditions. The sanctity of human life is a nontrivial concern, and the realization of the overriding importance (i.e., sanctity) of our mission adds a sense of urgency and commitment not found in a typical health physics program. It elevates our profession to the level of a calling, a ministry.
One of the problems with the DOE compliance program is that it starts with a requirements document, goes through an implementing document, and then audits to see if the implementing document is being followed. At no point is the intent of the requirements document considered. There is no provision for evaluating whether field practice accomplishes or promotes the original purpose of the requirement, assuming the requirement is understood.
Making the protection of the workers a paramount concern protects the integrity of the MK-F health physics program. We credit DOE with having had radiation protection in mind when it promulgated documents like Part 835 and the RCM. We interpret and implement these, and other requirements, in a way that promotes that purpose. This consideration of purpose in our interpretation of requirements helps us avoid the pitfalls of too many DOE programs. What we do has to make good health physics sense or we do not do it. We are professionals and we have the training and experience to judge what is worth doing. We have been able to maintain this stance in the face of DOE audits.
For us, ALARA cuts both ways. We take any action that produces a cost-effective reduction in dose. We avoid any action that does not produce a cost-effective reduction in dose. In this way, we avoid burdening our construction work with impediments that do not contribute to worker protection.
Highly qualified and aggressive staff
To run a program based on HP principles you need a staff that is well versed in those principles and can apply them. The staff must have the courage and self-confidence to apply requirements in a way that promotes worker protection and to defend those decisions against questions from any quarter. Each staff member must have his or her own vision of what a health physics program should be. MK-F has assembled such a staff (see Figure 1 below). As you can see from the figure, four members of the staff are certified by the American Board of Health Physics and thirteen are listed on the National Registry of Radiation Protection Technologists. In all, 71 percent of the staff holds at least one of these certifications.
Figure 1 Dark Grey=CHP Grey=NRRPTHeavy Border=RCT
Not shown in this figure are subcontractor radiological technicians. During the peak of the construction season, the Oak Ridge HP staff is augmented by as many as 25-30 technicians supplied by a subcontractor.
In order to make the HP program as responsive as possible to construction management’s changing needs, site HP Supervisors must be able to work independently and with minimum supervision. They are responsible for the HP component of the construction project from the initial planning stages through the ALARA plan and budget through field coverage of the work and post-job analysis. They have complete control of their resources and are responsible for adding or cutting subcontractor techs as needed. They serve as a technical resource for their HP personnel.
“Not unto us…”
A number of things came together for us, without which we would not have enjoyed the success we have had. These factors were not under the direct control of the HP department, and some of them are outside the control of the company. In most cases, it was simply our good fortune. In the case of senior management support, I checked before agreeing to take on the job knowing that this was a sine qua non for a health physics program (or any safety program).
Support from MK-F management
We could not have done it without strong support from MK-F’s senior management. While many companies acknowledge the importance of safety in the abstract, the nature of a safety program (invariably funded out of overhead) puts it at odds with production goals. Unless top management makes safety a company goal on a par with production, the safety program will not succeed. Management support for safety includes providing adequate staffing and funding for the safety departments. Our senior management backed us all the way.
Support from MK-F line supervision
Construction projects at MK-F are managed by a Construction Engineer (CE) for a subcontracted job or Superintendent if the job is done with direct-hire labor. In either case, the CE or Superintendent is totally responsible for the project and is the cost account manager. For the CE or Superintendent, the introduction of health physics concerns means additional costs, work slowed by special precautions and protective equipment, and waits for surveys and other services. Nevertheless, the HP department needs the cooperation of the CE or Superintendent in order to implement the required precautions. MK-F’s HP department has been fortunate in that we have had very good cooperation from the CEs and Superintendents. This is partly due to a clear message from upper management that safety is a top priority and that non-cooperation would not be tolerated. The HP department does its part by providing prompt service and designing protection on a job-by-job basis to minimize cost and intrusiveness.
We were aided by some very sharp, knowledgeable, and competent health physicists in the DOE Oak Ridge Operations office. They understood and supported what we were trying to do. Their audits were based on sound health physics and were very helpful. Without taking away from the sincerity of our management’s commitment to worker protection, the stress that DOE has put on radiation protection certainly contributed to the level of support our department received from management.
One of the difficulties in upgrading a health physics program in the DOE community is the existence of large groups of workers who were hired and trained (or not trained, as the case may be) before the current HP qualification standards were promulgated. Bringing some of these workers up to the new standards has proved to be difficult to impossible and has created some very vexing problems. More on that later. Most of our staff was hired in the past two years, since the inception of our program. This gave us the opportunity to hire against the new standards and made the job of training and qualification much easier.
History of program
The health physics program at MK-Ferguson of Oak Ridge Company is unusual in that we provide our own health physics coverage while working on a site managed by a contractor who also has a health physics program. MK-F’s experience prior to the inception of its HP program in July 1993 was that LMES support was not always responsive to the rapidly changing needs of a construction program. This appeared to be a result of the presence of individual HP organizations at each LMES site, each with its own procedures, and the fact that MK-F had to compete with other LMES programs for HP services. Support for construction was usually not a high priority for LMES and heavy equipment sometimes sat for days, incurring high rental charges, waiting for a HP survey to clear it off site.
MK-F has had a skeleton HP staff since our arrival on site October 1, 1990. In July 1993, DOE gave us the funding and the authority to establish our own HP program. By February 1994 the senior staff was complete. By the end of June 1994 the RadCon Manual had been implemented.
On October 1, 1995, MK-Ferguson entered into a “Strategic Alliance” with LMES at the five sites LMES operates. Under this alliance, MK-F became a subcontractor to LMES, rather than a prime contractor to DOE. This has the effect of relieving MK-F of certain tasks, such as the maintenance of a compliance program, and gives MKF access to services at LMES that are more economical because of scale. The purpose of the alliance is to reduce duplication between the two companies and to assign tasks to the company that can do them faster, better, and cheaper. Under the alliance, MK-F retains its corporate identity and continues to provide its own health physics and safety support to construction. As of this writing, the alliance appears to be working well.
For the first half of FY 1995, the MK-F Health Physics Department received a performance evaluation rating of 90 percent, reportedly the highest rating a department has received within the purview of the Oak Ridge Operations Office (ORO). Our performance evaluation rating for the second half of FY 1995 is 92 percent, another record. Our audit experience has also been excellent. We view this as a vote of confidence from DOE and evidence that our approach is working.
Cost savings, ALARA
The MK-F Health Physics Department, with all but the senior staff billed on a full-cost-recovery basis, has an hourly charge for health physics services that is just over half of the lowest charge of other programs in the area. We have reduced the cost of construction by minimizing the waiting time for health physics services (such as surveys to release equipment) and by reducing protective equipment and other precautions to the minimum needed to do the job. We have accomplished all this without any sacrifice of radiological protection standards.
Our cumulative dose is very low and is driven mostly by “hot” jobs at the Oak Ridge National Laboratory (ORNL). The other performance measures that we track (personnel contamination, radiological awareness reports) also indicate excellent performance.