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Flip Chart Bullets – Collected During August 18 Panel Discussion regarding Role of Accelerator Safety Order. David Freeman Accelerator Safety Workshop August 18, 2009 Plz send corrections, additions, and deletions to freemandw@ornl.gov. Flip Chart Comments – ASO Role.

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David Freeman Accelerator Safety Workshop August 18, 2009

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Flip Chart Bullets – Collected During August 18 Panel Discussion regarding Role of Accelerator Safety Order

David Freeman

Accelerator Safety Workshop

August 18, 2009

Plz send corrections, additions, and deletions to freemandw@ornl.gov


Flip Chart Comments – ASO Role

  • Can we set Order 420.2B aside; i.e. can we do without Order 420.2B?

  • Order has great value – great deal of community expertise has been invested in developing Order

  • Order has community ownership and buy-in

  • Deleting the Order would create a “regulatory vacuum” – great concern

  • Perhaps we could accommodate deleting Order by folding its content into 10CFR835 and 10CFR851

  • If the Order is deleted, Guide would necessarily be deleted also.

  • We should refrain from arguing that ASO keeps us out of “10CFR830 space” – could be viewed as a weak argument

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Flip Chart Comments – ASO Role

  • It is essential to retain:

    • requirements for Hazard Analysis and Controls

    • the definition of an accelerator

    • approvals needed for startup and restart,

  • Do we need some “conduct of ops” requirements?

  • Authorization basis needs to be clearly defined.

  • Disadvantage to earlier suggestion that we fold 420.2B content into 851 and 835 is that 851 and 835 are in “enforcement space”

  • Should we consider raising the stature of 420.2B to the level of a rule?

  • Pre-5480.xx era was a difficult mess

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Flip Chart Comments – ASO Role

  • Order works well, we all understand how to function under the Order

  • How can DOE evaluate and accept risk associated with decisions if NRC acts as external regulator?

  • What is rationale for removing the Order? What are the advantages? We don’t understand motivation.

  • Are we exchanging a well thought out and crafted regulatory framework for a “crap shoot” of what we might get if the Order is removed?

  • We must address what would really happen if the ASO is removed from existence.

  • Under NRC rule, and agreement states, it is possible that the City of Berkley could become regulator at LBNL

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Flip Chart Comments – ASO Role

  • Should we codify Order to regulation status? - It would add credibility; would such a move drive us to external regulation?

  • For Site Offices, doing away with order offers not advantages, only disadvantages

  • Small facilities could be put out of business if they have to cope with transition to external regulation – not enough resources to deal with it

  • Could we make Order a Technical Standard rather than loosing it all together? Same for the Guide? It might make it easier to revise

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