TITLE:	ES&H Manual
DOCUMENT ID:	5300 Appendix T2 Worker Radiation Protection Event Reporting (10 CFR 835) under Price Anderson Amendments Act (PAAA)

1.0 Purpose

Jefferson Lab identifies, evaluates, and reports worker radiation protection events for reporting under the specific requirements established in 10 CFR 820 under the Price Anderson Amendments Act (PAAA). It is common for these events to be reported under both the Department of Energy (DOE) Occurrence Reporting and Processing System (ORPS) and the DOE Noncompliance Tracking System (NTS) (see ES&H Manual Chapter 5300 Appendix T1 Occurrence Reporting to Department of Energy (DOE) and Notification Procedures).

2.0 Scope

Jefferson Lab is a “…low-hazard non-nuclear accelerator facility,” as determined by the responsible Principal Secretarial Office (PSO) and the Office of Science (SC, formerly the Office of Energy Research). However, since radiation and radioactive sources are features of our operations and a Radiation Protection Program (RPP) has been developed to ensure compliance with DOE’s occupational radiation protection requirements; the DOE Office of Enforcement (OE) has determined that Jefferson Lab must comply with 10 CFR 835 under PAAA.

3.0 Responsibilities

NOTE: Management authority may be delegated at the discretion of the responsible manager.

3.1 ESH&Q Reporting Officer

· PAAA Coordinator designate.

· Reviews events for NTS.

· Manages activities for 10 CFR 835 reporting

· Advises line management

Qualifications:

· Substantial work experience in a DOE or U.S. Nuclear Regulatory Commission Completion of PAAA Coordinator training course (equivalent regulated radiological facility work experience may be substituted until training can be completed).

4.0 Process Steps

Unless otherwise specified, the ESH&Q Reporting Officer performs all process steps.

Step 1 - Discovery: A potential worker radiation protection event/trend is discovered.

· A member of the Radiation Control Group drafts a Radiation Safety Deviation Report (RSDR) for review by the Radiation Control Manager (RCM).

· The RSDR is provided to the ESH&Q Reporting Officer to determine if the event/trend is an actual PAAA noncompliance.

· The event/trend is determined to be noncompliant using the Jefferson Lab 10 CFR 835 Noncompliance Screening Form. It is categorized as either:

o NTS-reportable (i.e., significant),

o site-reportable (i.e., minor), or

o Non event/trend.

The RSDR can be accessed at:

Alternate Step 1 - Identification: Potential worker radiation protection events are identified and evaluated for possible compliance issues. Sources include but are not limited to:

· Discussions at regular meetings such as the daily Operations Meeting, the Director’s Safety Council and its committees including the Jefferson Lab Radiation Review Panel (JRRP).

· Discussions with the RCM, ESH&Q staff, and line management.

· Notifications by concerned individuals of events and issues as they arise.

· Reviews of occurrences and programmatic issues identified at other facilities including but not limited to the U.S. Nuclear Regulatory Commission and the Health Physics Society.

· Results of formal assessments and reviews with special attention to the RSDRs submitted by the RCM.

· Results of external assessments that deal with or are related to worker radiation protection matters.

Step 2 - Communication. Communication is provided as necessary to appropriate DOE PAAA staff in the Thomas Jefferson Site Office (TJSO), the DOE Oak Ridge Office, SC, and OE functions.

Step 3 - Reportability. NTS-reportable events exceed thresholds specified by DOE Enforcement Guidance Supplement 03-02.

· NTS Reportable – Noncompliances beneath those thresholds. These are also tracked internally using the Jefferson Lab Corrective Actions Tracking System (CATS).

· Non-NTS-Reportable – Noncompliances with the RPP are tracked internally using the CATS.

· Radiological events with the potential of leading to a 10 CFR 835 noncompliance are tracked for continuous improvement using the CATS.

4.1 Appropriate tracking of radiological event is conducted by the ESH&Q Reporting Officer when necessary to identify potential programmatic issues. A programmatic event exist when:

1. Several non-NTS-reportable noncompliances that are related but not necessarily identical have occurred, indicating a common breakdown in a program or program area, or

2. The similar noncompliances are caused by systematic problems having an underlying common cause involving some weakness in administrative or management controls or the implementation of such controls.

ISSUING AUTHORITY	APPENDIX AUTHOR	APPROVAL DATE	EFFECTIVE DATE	EXPIRATION DATE	REV.
ESH&Q Division	Stephen Smith	10/19/09	10/19/09	10/19/12	1

This document is controlled as an on line file. It may be printed but the print copy is not a controlled document. It is the user’s responsibility to ensure that the document is the same revision as the current on line file. This copy was printed on 10/27/2009.