The DOE Office of Enforcement and Investigation
(EH Enforcement) invoked a 120-day suspension of PAAA enforcement actions for
issues associated with contractor Internal Dose Evaluation Programs (IDEP). Prior
to initiation of the suspension, EH Enforcement had identified deficiencies in DOEcontractor
implemented bioassay programs at numerous sites within the DOE
complex. The commonality of the IDEP deficiencies at the various sites, as well as
the possibility of the existence of similar deficiencies at other DOE sites, led EH
Enforcement to the conclusion that a suspension of enforcement actions would be
appropriate to provide DOE-contractors an opportunity to review their own IDEPs to
determine whether similar or other program deficiencies existed, and, if so, to take
appropriate corrective action.
Contractors were alerted to review their IDEP during the 120-day suspension
period. If program deficiencies were identified, and if they met the Noncompliance
Tracking System (NTS) criteria, these issues were to be reported into the NTS,
along with proposed corrective actions and the anticipated target completion dates.
EH Enforcement did not plan to take enforcement action against the contractor for
identified IDEP problems if bioassay program deficiencies were identified and
reported and if corrective actions, as identified by the contractor, were implemented.
However, failure of the contractor to implement proposed corrective actions would
permit EH Enforcement to re-open PAAA enforcement action for any of these issues
in the future.