Flip Chart Bullets

1
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_at_ornl.gov

2
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

3
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

4
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 dont 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

5
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