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OFFICE OF SCIENCE. Accelerator Safety Workshop SLAC. Access Control and Posting Issue Break-out Summary August 19 , 2010. John Blaikie Health Physics Program Manager – SC- 31.1 Office of Science, U.S. Department of Energy. Issue Review. Statement of issue
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OFFICE OFSCIENCE Accelerator Safety Workshop SLAC Access Control and Posting Issue Break-out Summary August 19, 2010 John Blaikie Health Physics Program Manager – SC- 31.1 Office of Science, U.S. Department of Energy
Issue Review • Statement of issue • Posting requirements during accelerator operations • There is no issue with posting while accelerator is NOT operating • Issue was identified at TJNAF during a 10 CFR 835 Review • Is enclosure considered accessible during accelerator operations • Discussion • Reviewed posting guidance • Reviewed practices at each site • Attempted to determine extent of conditions
Talking Points • GC – How would you post? Post for legitimate allowable entry • Do not want to dilute significance of radiological postings by over-posting • Define accessibility probability when beam is on • What resolution provides the best long-term solution—define end state—best for DOE—what makes sense that is reasonable, credible state for requirement • What is a defensible solution and the path to get there and the best bang for the buck? • Conditional posting would meet requirement for 10CFR835. Could not agree on whether “beam on” light is required at EVERY door. Conditional posting would not work at all facilities
Talking Points • Need to determine if we are NOT in compliance—break-out group was only one-fourth of workshop—need to determine who else would be affected • Possible resolution—amend 835—exemption request • Are we expecting contractors to self-ID and file NTS?
Outcome • TJ issued finding for not posting IAW 10CFR835 • All sites represented in break-out acknowledged they post the same way • GC representative does not agree that the enclosure doors can be legally described as inaccessible—subject to further discussions at HQ • GC has first draft of official guidance—has agreed to delay issuance to allow sites time to review and assess issue. • We know there is DOE issued conflicting guidance • Need to advise management of potential issue • HS & SC to discuss with Enforcement • DOE HQ needs to provide official guidance