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Overview of Fermilab’s Price Anderson Amendments Act (PAAA)

Program

Don Cossairt & Martha Michels

Initial Version: August 21, 2001Updated: June 2009

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What is PAAA?

PAAA is a Federal Law that, among other functions, authorizes DOE regulations on “nuclear safety”.

Currently applicable to Fermilab: 10 CFR 820-Enforcement Procedures 10 CFR 835-Occupational Radiation Protection 10 CFR 850 – Chronic Beryllium Disease Prevention

Program 10 CFR 851-Worker Safety and Health Program

Otherwise existing or planned: 10 CFR 830-Nuclear Safety Management (N/A @FNAL since

applies to nuclear facilities that are defined not to include accelerators.)

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Office of Price Anderson Enforcement (“OE”)

Issues reporting criteria and “interpretations”. Conducts program reviews at all DOE facilities

(not yet here, but could happen at any time). Issues Program Letters, Enforcement Actions,

Preliminary Notices of Violations-all with press releases published openly on the web.

Levies civil penalties, there are some limitations placed on what can be levied, but the “public relations” impacts are considerable.

Encourages self-reporting of noncompliances; usually reduces penalties if self-reporting judged to be “good”.

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Self Identification Formalism

Each DOE site has one or more “DOE PAAA Coordinator” (DOE-FSO: Berline Short).

Each DOE Contractor has one or more “Contractor PAAA Coordinator” (FNAL: Don Cossairt/Kathy Graden for 10 CFR 835, Martha Michels/Bill James for 10 CFR 851).

Urged to use DOE’s Noncompliance Tracking System (NTS) for issues above specified thresholds (“programmatic” and repetitive issues, “serious” violations and exposures, etc.)

NTS system is similar to ORPS; one needs to identify and complete corrective actions, etc.

Encouraged to use a “local” system for minor issues; ESHTRK is chosen here.

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Condition of Fermilab PAAA Program

Our program has been kept simple, with limited formality. • SLAC’s, JLAB’s, & LBNL’s are simple. • ANL’s is of medium formality.• LLNL’s, BNL’s, LANL’s, & ORNL’s are

heavily formalized. Rely on good communications and

management “awareness” to identify possible noncompliances.

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Condition of Fermilab PAAA Program

Examples of NTS in the last few years 4/2009 – Deficiency in tracking radiation protection

instrument calibration

3/2009 – Slipping results in a broken forearm

10/2008 – Technician receives mild shock while disconnecting power leads

07/2006 – Violation of beam enclosure access procedures

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Key Elements of Program

1. Identification of problems/issues: Formal assessments led by the ES&H Section Discussions at meetings like the weekly Scheduling

Meeting, Laboratory Safety Committee, Senior Safety Officers Meetings, Radiation Safety Subcommittee, etc.

Notifications and observations of events and issues by ES&H, DOE-FSO, and other personnel including employee concerns expressed formally or otherwise

Awareness of events at other facilities, particularly other accelerators

ESHTRK entries made by divisions/sections

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Program Elements-Fermilab PAAA Coordinator Activities2. The Fermilab PAAA Coordinators:

Screen “issues” for true potential regulatory noncompliances, identifies candidates for NTS.

Presents NTS candidates to ESH Director for review by Directorate.

Coordinates with ORPS, other regulatory notifications. Yes, there is double (or triple) reporting!

Notifies DOE-FSO in advance of NTS submittals. Tracks NTS submittals to closure, DOE-FSO

verifies closures for OE. Promotes awareness of these issues.

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You Can Help Keep Our Formal Program Simple!

Be aware of Radiation Protection Program requirements. (DOE-FSO does notice management attention!)

Be aware of the Workers Safety and Health program requirements.

Continue support for Laboratory implementation of DOE requirements & use of ESHTRK.

Support good communication between ES&H staff and others. Notify the ES&H Section promptly if you find deficiencies or have

questions. Cooperate with DOE-FSO or OE reviewers. Contact me with your questions/problems.