+--------------------+----------------------+---+---------------------+
|                    |                      |   | ** **               |
|                    |                      |   |                     |
| **BROOKHAVEN       |                      |   | Procedure No:       |
| NATIONAL           |                      |   | IO-SOP-10           |
| LABORATORY**       |                      |   |                     |
|                    |                      |   |                     |
| **INTERNAL AUDIT   |                      |   |                     |
| AND OVERSIGHT      |                      |   | Revision No: 5      |
| OFFICE**           |                      |   |                     |
|                    |                      |   |                     |
|                    |                      |   |                     |
|                    |                      |   | Page 1 of 9         |
|                    |                      |   |                     |
|                    |                      |   | ** **               |
|                    |                      |   |                     |
|                    |                      |   |                     |
+--------------------+----------------------+---+---------------------+
| **Title:**         |                      |   |                     |
|                    |                      |   |                     |
| ** **              |                      |   |                     |
|                    |                      |   |                     |
| **PAAA REVIEW AND  |                      |   |                     |
| REPORTING          |                      |   |                     |
| PROCEDURE**        |                      |   |                     |
|                    |                      |   |                     |
|                    |                      |   |                     |
+--------------------+----------------------+---+---------------------+
| ** **              |                      |   |                     |
|                    |                      |   |                     |
| ** **              |                      |   |                     |
|                    |                      |   |                     |
| ** **              |                      |   |                     |
|                    |                      |   |                     |
| [Table of          |                      |   |                     |
| Con                |                      |   |                     |
| tents]{.underline} |                      |   |                     |
|                    |                      |   |                     |
| > [Se              |                      |   |                     |
| ction]{.underline} |                      |   |                     |
| >                  |                      |   |                     |
| [Page]{.underline} |                      |   |                     |
|                    |                      |   |                     |
|                    |                      |   |                     |
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| > 1.0 PURPOSE 2    |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 2.0              |                      |   |                     |
| > RESPONSIBILITIES |                      |   |                     |
| > 2                |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 3.0 DEFINITIONS  |                      |   |                     |
| > 3                |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 4.0              |                      |   |                     |
| > PREREQUISITES 4  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 5.0 PRECAUTIONS  |                      |   |                     |
| > 4                |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 6.0 PROCEDURE 5  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 7.0 RECORDS 7    |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 8.0 REFERENCES 8 |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
| > 9.0 ATTACHMENTS  |                      |   |                     |
| > 8                |                      |   |                     |
| >                  |                      |   |                     |
| >                  |                      |   |                     |
|                    |                      |   |                     |
|                    |                      |   |                     |
+--------------------+----------------------+---+---------------------+
|                    |                      |   |                     |
|                    |                      |   |                     |
| **PREPARED BY:**   | **REVIEWED BY:**     | * |                     |
|                    |                      | * |                     |
| ** **Signature on  | ** **Signature on    | A |                     |
| File               | File                 | P |                     |
|                    |                      | P |                     |
| **\_\_\_\_         |  **                  | R |                     |
| \_\_\_\_\_\_\_\_\_ | \_\_\_\_\_\_\_\_\_\_ | O |                     |
| \_\_\_\_\_\_\_\_** | \_\_\_\_\_\_\_\_\_** | V |                     |
|                    |                      | E |                     |
| Author/Date        | R. C. McNair         | D |                     |
|                    |                      | B |                     |
| C. Dimino          | Manager, Internal    | Y |                     |
|                    | Audit & Oversight    | : |                     |
| PAAA Coordinator   |                      | * |                     |
|                    |                      | * |                     |
|                    |                      |   |                     |
|                    |  Signature on File   |   |                     |
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|                    | \_\_\_\_\_\_\_\_\_   | i |                     |
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+--------------------+----------------------+---+---------------------+

+------------------------------------------------+---------------------+
|                                                | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                |                     |
|                                                |                     |
|                                                | Page 2 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

**1.0 PURPOSE**

 

The purpose of this procedure is to prescribe the mechanisms for
identification, evaluation, and reporting of PAAA noncompliances.
Specifically it includes:

> Methods for identification of noncompliances,
>
> Criteria for evaluation of noncompliances to determine if a
> Noncompliance Tracking System (NTS) report is necessary,
>
> Methods for documenting and tracking PAAA reviews of potential
> noncompliances,

-   Notifying responsible organizations of non-reportable PAAA
    noncompliances,

> Notification and reporting of NTS reports, including Directorate
> review and approval,
>
> Tracking corrective actions,
>
> Verification/validation of NTS corrective action closure,
>
> Maintaining associated PAAA records.\
>  

####### 2.0 RESPONSIBILITIES 

>  
>
> **IA&O Manager**: The BNL PAAA Program resides within the Internal
> Audit and Oversight Office. The IA&O Manager provides management
> support to, and oversight of, the PAAA Coordinator. Additional
> responsibilities include the following:
>
>  
>
>        Evaluates potential candidates for the PAAA Coordinator
> Position based upon education and experience and recommends a
> candidate for appointment by the Deputy Director for Operations (DDO),
>
>        Serves as Alternate PAAA Coordinator and Alternate Chair of
> PAAA WG,
>
>        Interfaces with Laboratory Senior Management on the status of
> the PAAA Program and significant PAAA issues,
>
>        Interfaces with the DOE Office of Price-Anderson Enforcement on
> the status of the PAAA Program and significant PAAA issues.
>
> **PAAA Coordinator:** Oversees BNL's compliance with PAAA Rules. The
> Coordinator is responsible for the following:

 

> Independently reviewing sources of potential noncompliances for PAAA
> applicability and reportability,
>
>        Chairing the PAAA Working Group (WG) Meetings,
>
> Coordinating the PAAA WG review of potential reportable
> noncompliances,
>
> Notification to responsible organizations of nonreportable PAAA
> noncompliances,
>
> Entering reportable PAAA noncompliances into the DOE NTS,
>
> Communication of NTS corrective action to PAAA Administrator for
> incorporation into Institutional Assessment Tracking System (ATS),
>
> Updating status of noncompliance corrective action in NTS,
>
>        Recommendation to DDO regarding independent validation of
> corrective actions from NTS reports,
>
> Communicating potential lessons learned to the Laboratory Lessons
> Learned Coordinator,

-   Development and issuance of a Quarterly PAAA Summary and Trend
    Analysis,

> Identifying potential trends involving PAAA noncompliances,

-   Interfacing with the DOE BHSO PAAA Coordinator and the DOE Office of
    Price-Anderson Enforcement. 

+------------------------------------------------+---------------------+
| **BROOKHAVEN NATIONAL LABORATORY**             | ** **               |
|                                                |                     |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        | Procedure No:       |
|                                                | IO-SOP-10           |
|                                                |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 3 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

> **PAAA Administrator and WG Secretary:** Provides administrative
> support to the PAAA Coordinator. The Administrator is responsible for
> the following:
>
> Docketing and data entry into PAAA Database of various source
> documents received for PAAA review,

-   Creating and maintaining the hardcopy file for each new docketed
    item, and interfacing with the BNL Records Management Office
    regarding PAAA files,

> Generating notification letters to responsible organizations for
> nonreportable PAAA noncompliances,
>
>        Generating follow-up communications to responsible
> organizations for closure of corrective actions associated with
> non-reportable PAAA noncompliances,

-   Coordinating PAAA WG meetings and distributing meeting agenda and
    materials,

-   Attending meetings and records and maintains meeting minutes,

-   Disseminating draft meeting minutes,

-   Maintaining records of decision,

```{=html}
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-   Preparing initial draft of Quarterly PAAA Summary and Trend Analysis
    Report including graphical presentation of data and coordinates
    finalization of report with PAAA Coordinator.

######## **PAAA Working Group:** Reviews issues considered by the PAAA Coordinator to be potentially reportable noncompliances, to determine whether these issues are NTS reportable. The WG may request independent investigations by IA&O of noncompliances to further clarify the issue. In addition, the WG approves minutes of PAAA WG meetings.

####### 3.0        DEFINITIONS

 

> **ATS:** Assessment Tracking System database tool consisting of three
> levels of information related to an assessment -
> Assessments/Conditions/Corrective Actions.
>
> **BNL PAAA Coordinator:** The person appointed by the DDO, and
> accountable to the IA&O Manager, who will manage the day-to-day
> operation of the PAAA Office, coordinate the submission of NTS
> reports, maintain access to the NTS database, and advise line
> management on the information that is needed for NTS reports. This
> person supports the PAAA WG by scheduling and conducting WG meetings,
> maintaining WG meeting minutes, and generally supporting requests of
> the WG.
>
> **DOE BHSO PAAA Coordinator:** A person in the DOE Brookhaven Site
> Office who is the liaison with BSA for actions related to PAAA issues.
> The DOE BHSO PAAA Coordinator is informed when a noncompliance is
> identified that might be NTS reportable and is updated on the progress
> of NTS corrective action development and implementation. This person
> conducts independent verification of completed corrective action and
> makes recommendations to DOE OE regarding closure of the NTS.
>
> **DOE Noncompliance Tracking System (NTS):** A DOE database
> established to manage submitted reports of \"reportable\"
> noncompliances with Nuclear Safety Rules and track the status of
> corrective actions.

+------------------------------------------------+---------------------+
|                                                | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 4 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

> **Noncompliance:** Any action that is deemed to be deficient in
> meeting a commitment in the Nuclear Safety Rules, the Radiation
> Protection Plan, or the QA Program Description.

**Nonreportable**: A noncompliance that does not meet the threshold for
reportability as defined in the DOE Office of Price-Anderson Enforcement
(OE) Operational Procedure for "Identifying, Reporting, and Tracking
Nuclear Safety Noncompliances under Price-Anderson Amendments Act of
1988."

> **Reportable**: A noncompliance that meets the threshold for
> reportability as defined in the Operational Procedure for
> "Identifying, Reporting, and Tracking Nuclear Safety Noncompliances
> under the Price-Anderson Amendments Act of 1988."
>
> **Nuclear Safety Rules:** Those rules specifically codified as
> 10CFR820, Procedural Rules for DOE Nuclear Activities, 10CFR835,
> Occupational Radiation Protection, 10CFR830, Nuclear Safety
> Management, and 10CFR708, DOE Contractor Employee Protection Program.
>
> **[PAAA Working
> G](https://sbms.bnl.gov/ld/ld16/ld16d401.htm)[roup]{.underline}:** A
> group, appointed by the Laboratory Director, responsible for
> determining reportability of potential PAAA noncompliances, ensuring
> that NTS Reports are submitted as appropriate, and overseeing the
> noncompliance determination and reporting process.
>
> **Price-Anderson Amendments Act (PAAA):** The Federal Law that
> authorizes DOE to establish an enforcement program subjecting DOE
> contractors, subcontractors and suppliers to potential civil and
> criminal penalties for violation of DOE rules, regulations, and
> compliance orders establishing the Nuclear Safety Rules.

**4.0 PREREQUISITES**

** **

> The staff member selected to serve as the PAAA Coordinator will have
> the appropriate level of training and qualifications as described
> below:
>
> Education - A minimum of a bachelor's degree from an accredited
> institution of higher education.
>
> Experience - A minimum of five to seven years senior technical and/or
> management experience in nuclear facility safety, environmental
> radiation protection, nuclear quality assurance in a DOE facility or a
> facility under a Nuclear Regulatory Commission material license, or a
> minimum of five years' experience as an attorney supporting one or
> more of the areas listed above. The DDO can make exceptions to these
> criteria on a case-by-case basis.
>
> Training - Accomplished through the following mandatory required
> reading:

• DOE Operational Procedures for Enforcement (Supersedes
DOE-HDBK-1087-95),

-   DOE-HDBK-1085-95, DOE Enforcement Program Roles and
    Responsibilities,

-   DOE Operational Procedure: Identifying, Reporting, and Tracking
    Nuclear Safety Noncompliances (Supersedes DOE-HDBK-1089-95).

**5.0        PRECAUTIONS**

> None

+------------------------------------------------+---------------------+
| ** **                                          | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 5 of 9         |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

**6.0        PROCEDURE**

> The procedural steps for identification, evaluation, and reporting of
> PAAA noncompliances are described below and depicted in the [PAAA
> Process
> Flowchart](https://sbms.bnl.gov/draft/progdesc/PAAA/PAAA_exh1.pdf).

**6.1 Receipt and Initial Screening of Potential Noncompliances**

** **

**6.1.1** The PAAA Coordinator is responsible to review various sources
of information provided that identify potential noncompliance with
nuclear safety rules. Typical source documents include:

>          Occurrence Reports
>
>          Independent Audits/Assessments and Self-Assessments
>
>          External Assessment Reports
>
>          Surveillances
>
>          Inspections
>
>          Employee Concerns
>
>          Nonconformance Reports
>
>          Radiological Awareness Reports

-   Investigations

>  

**6.1.2** Upon receipt of any of the source documents noted above, the
PAAA Coordinator conducts an initial informal screening to determine if
the document represents a PAAA noncompliance potentially reportable in
the DOE NTS. At the same time, a copy of the document will be provided
to the PAAA Administrator for docketing into the PAAA database.

 

**6.1.3** The PAAA Coordinator will immediately act upon noncompliances
believed to be reportable in order to accommodate prompt reporting in
NTS (within 20 calendar days of determination of the noncompliance).
This may include initiation of a PAAA WG (WG) meeting or initiation of
an NTS report without WG review, in accordance with Section 6.2.5.

** **

**6.1.4** Items believed not to be reportable at the initial screening
will be formally reviewed at the PAAA Coordinator's earliest
convenience.

 

**6.1.5** Docket numbers will be assigned by the PAAA Administrator
based upon year and consecutive number; i.e., "PA01-02," represents the
second document in calendar year 2001.

 ** **

**6.2 Review of Potential PAAA Noncompliances**

**6.2.1** The PAAA Coordinator will review potential noncompliances for
PAAA applicability and reportability. Items will be categorized as one
of the following:

>  
>
>       No PAAA Noncompliance

-   Nonreportable PAAA Noncompliance

-   Reportable Noncompliance

**6.2.2** Items that do not represent a noncompliance with a Nuclear
Safety Rule will be categorized as "No PAAA Noncompliance" in the PAAA
Database. The PAAA Administrator will place a printout of the "PAAA
Review Summary" into the PAAA file folder under its respective Docket
Number.

+------------------------------------------------+---------------------+
| ** **                                          | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 6 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

 

3.  Items that do represent noncompliance with a Nuclear Safety Rule but
    do not meet the threshold for reportability to DOE in the DOE NTS
    will be categorized as "Nonreportable PAAA Noncompliance." A
    memorandum will be issued to the responsible organization notifying
    them of the noncompliance and directing them to identify cause and
    corrective and preventive actions and to track actions in ATS or an
    equivalent tracking system. Nonreportable PAAA Noncompliance will be
    reviewed during a quarterly trend analysis to identify repetitive
    noncompliance indicating a programmatic deficiency, as discussed in
    Section 6.6.1.

 

**6.2.4** Items will be categorized as a "Reportable Noncompliance" or
"NTS" when they represent noncompliance with a Nuclear Safety Rule and
meet the threshold for reportability in Tables 3.1, "Programmatic
Deficiencies" or Table 3.2, "Noncompliances Involving DOE Manual
232.1A-2 Occurrences," in the DOE Operational Procedure for
\"Identifying, Reporting and Tracking Nuclear Safety Noncompliances
Under PAAA of 1988.\"

 

**6.2.5** The PAAA Coordinator will decide if the issue believed to be
reportable should be presented to the PAAA WG for review and
concurrence, or be reported without WG review. Typically, items that
fall within DOE Table 3.1, "Programmatic Deficiencies," should be
presented to the WG, while items that fall within Table 3.2,
"Noncompliances Involving DOE Manual 232.11A-2 Occurrences," should be
reported by obtaining concurrence of the DDO, the applicable ALD, and
BNL Legal Counsel.

 

**6.2.6** PAAA WG meetings will be scheduled by the PAAA Coordinator on
an as-needed basis to support prompt reporting of reportable
noncompliances. A meeting agenda will be prepared, copied, and
distributed to WG members prior to the meeting. Draft minutes of WG
meetings will be distributed for comment to WG members within
approximately 1 week of the meeting.

 

**6.2.7** Issues reported without WG review will be presented at the
next WG meeting.

**6.3** **Reporting PAAA Noncompliances in the DOE Noncompliance
Tracking System (NTS)**

** **

**6.3.1** Upon determining that a noncompliance is reportable in
accordance with Section 6.2, an NTS report will be prepared by the
responsible organization with the assistance of the PAAA Coordinator.

**6.3.2** Prior to submission of an NTS report to DOE, Level 1 and 2
Managers review and approve the report. Formal signatures are obtained
on the attached NTS Approval form (Attachment 1).

 

**6.3.3** Reports submitted without WG review shall be approved by the
DDO, the applicable ALD, BNL Legal Counsel, and the PAAA Coordinator on
the attached NTS Approval form (Attachment 1).

** **

**6.3.4** Copies of newly issued NTS Reports are normally distributed
via e-mail to applicable Level 2 Manager(s) and the DOE-BHSO PAAA
Coordinator.

** **

**6.4 Tracking PAAA Noncompliances**

**6.4.1** The PAAA Administrator will assure that PAAA noncompliances
are tracked to closure as follows: Nonreportable PAAA Noncompliances are
tracked in the Institutional ATS, the Family ATS, or equivalent tracking
system. All Reportable Noncompliances (NTS) will be tracked in the BNL
Institutional ATS.

>  

**6.4.2** The PAAA Coordinator will assure that Reportable
Noncompliances are tracked to closure in the DOE Noncompliance Tracking
System (NTS). The PAAA Coordinator will update the NTS as ATS corrective
actions are completed. The PAAA Coordinator provides approval to the ATS
Administrator prior to closing ATS actions that correspond to NTS
reports.

+------------------------------------------------+---------------------+
|                                                | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 7 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

** **

**6.4.3** Copies of updated NTS Reports are normally distributed via
e-mail to applicable Level 2 Manager(s) and the DOE-BHSO PAAA
Coordinator.

 

**6.4.4** The PAAA Coordinator will verify, through objective evidence
submitted, that all corrective actions associated with NTS reportable
noncompliances have been completed as specified. In addition, the PAAA
Coordinator will consider the need for an independent validation of
corrective action and, where appropriate, will recommend to the DDO that
an independent effectiveness evaluation be performed. This is typically
done for corrective action that is designed to address the root cause(s)
and prevent recurrence of the problem and:

 

>       is so complex that further evaluation is necessary to assure
> that it is complete and effective; or

 

>       involves several different independent organizations or groups,
> such that its success is dependent
>
> upon the satisfactory completion of the integrated actions of each.
>
> Where necessary, the PAAA Coordinator will recommend the validation be
> scheduled after sufficient time has passed to establish an adequate
> baseline of implementation data in order to ensure a meaningful
> assessment. The PAAA Coordinator will maintain documented results of
> independent validations in the corresponding NTS file.

**6.4.5** If it is determined by the DDO that an independent validation
of corrective action will not be performed, the PAAA Coordinator will
include documentation of the DDO decision in the NTS.

 

**6.5 Lessons Learned Communications**

** **

**6.5.1** PAAA noncompliances will be communicated to the Laboratory
Lessons Learned Coordinator to determine if there is value in developing
and disseminating a Laboratory Lessons Learned Communication. In
addition, when considered useful, the PAAA Coordinator may present
lessons learned to the EFCOG PAAA WG.

 

**6.6 Trending & Analysis**

1.  On a quarterly basis, the PAAA Coordinator will review PAAA
    noncompliances for potential adverse trends that may warrant further
    analysis. A Quarterly PAAA Review Summary and Trend Analysis will be
    developed and issued in accordance with IO-SOP-12. Adverse trends
    that indicate a potential Programmatic Deficiency will be identified
    and reviewed by the PAAA WG for PAAA reportability

**7.0 Records**

** **

> Records that are created as a result of this procedure are maintained
> in a central PAAA records filing area under the control of the PAAA
> Administrator. These records include but are not limited to the
> following:

** **

> Quarterly PAAA Summary and Trend Analysis
>
> PAAA Review Summaries
>
> PAAA WG Meeting Minutes
>
> PAAA WG Meeting Agendas
>
> NTS Approval forms
>
> NTS Reports
>
>        Training and Qualification Records

 

** **

+------------------------------------------------+---------------------+
|                                                | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 8 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

**8.0 References**

**8.1         **Price-Anderson Amendments Act Compliance Validation and
Noncompliance Reporting Program Description

** **

**8.2** DOE Operational Procedure, "Identifying, Reporting and Tracking
Nuclear Safety Noncompliances under Price Anderson Amendments Act of
1988." ** **

3.  IO-SOP-12, "Conducting PAAA Trend Analysis."

4.  DOE Office of Enforcement, Enforcement Guidance Supplements (EGSs).

**9.0 Attachments**

 

1.  NTS Approval Form (Attachment 1)

+------------------------------------------------+---------------------+
|                                                | ** **               |
|                                                |                     |
| **BROOKHAVEN NATIONAL LABORATORY**             | Procedure No:       |
|                                                | IO-SOP-10           |
| **INTERNAL AUDIT AND OVERSIGHT OFFICE**        |                     |
|                                                |                     |
|                                                |                     |
|                                                | Revision No: 5      |
|                                                |                     |
|                                                | Page 9 of 9         |
|                                                |                     |
|                                                | ** **               |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+
| **Title:**                                     |                     |
|                                                |                     |
| ** **                                          |                     |
|                                                |                     |
| **PAAA REVIEW AND REPORTING PROCEDURE**        |                     |
|                                                |                     |
|                                                |                     |
+------------------------------------------------+---------------------+

**Attachment 1**

 

# Nuclear Safety Rule Noncompliance Report

######### Brookhaven National Laboratory

** **

**Report Title:**

** **

**NTS Number (after submission) NTS-CH-BH-BNL-**

** **

**Date:**

** **

The attached report, including corrective actions, is approved by the
persons listed below as an accurate representation of the noncompliance
event in accordance with the requirement in 10 CFR 820.11 Information
Requirement. This report is approved for submission to the DOE
Noncompliance Tracking System (NTS).

 

[Prepared By]{.underline}:

 

[Approved By]{.underline}:

  

C. Dimino
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_

PAAA Coordinator

 

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_

 

 

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_

 

 

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_

 

 

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_