ASO Revision Key Discussion Topics

Session A

Key Topics

• Equivalencies/Exemptions• Responsibilities• Definitions

– USI• CRD content and structure

Equivalencies/Exemptions

• Started with current language – modified as needed to address the following:

• ‘Exclusions’ have become ‘Equivalencies and Exemptions’– Make explicitly clear that though exempt or subject to an

equivalent requirement, still defined as accelerators

• Clarify relationship to 835– Radiation generating devices, etc.– Anticipate new technologies

• Clarify relationship to 830

835/ASO

420.2B

• Unmodified commercially available units that are acceptable for industrial applications, including (but not limited to) electron microscopes, ion implant devices, and x-ray generators

• Accelerator facilities not capable of creating radiological areas as defined in 10 CFR 835

420.2C

Non-complex facilities with local work area impacts only and managed under 10 CFR 835, for example:

• Radiation generating devices• A room-sized accelerator with a single

external/extractable beam, an active safety system, and a single point of entry into the room

• X-ray or neutron generators that are bench top in size and that have a single external/extractable beam and a single operator

• Unmodified commercially available units that are designed for industrial applications, including but not limited to, electron microscopes, ion implant devices, and x-ray generators.

830/ASO

830.2 Definitions:• “Nonreactor nuclear facility means…. but does not include accelerators and

their operations….”

DOE General Counsel Interpretation (8/4/06):• “The exclusion of ‘accelerators and their operations’ is not limited in any

way…”• “Thus, Part 830 cannot be applied to accelerators, including accelerator

targets, even if they meet the criteria of DOE-STD-1027-92”

NNSA General Counsel Interpretation (11/26/08):• “To summarize, Part 830 provides for the safe operation of nuclear facilities,

defines ‘nuclear facilities’ as a ‘reactor or a nonreactor nuclear facility’, but exempts ‘accelerators and their operations’ from the definition of a ‘nonreactor nuclear facility’.”

but notes that

• “the guidance does not invite unrelated nuclear operations that do not constitute ‘accelerators and their operations’ to evade the regulations by being conducted in the same facility where an accelerator is located.”

830/ASO

Interpretation:• If an operation is legitimately a part of an ‘accelerator and its operations’,

then 830 regulations do not apply – period.

Goal:• Create enough flexibility in ASO language to allow Site Offices/PSOs to

apply appropriate rigor in analysis and controls

Examined:• 830-like language• Criticality language

Propose:• Use current SAD/ASE framework and contracting flexibility to allow for

tailoring in these special cases

Criticality

420.2B

• Entire DOE/NNSA accelerator facilities or modules thereof when and only when accelerators and their operations involve or produce a sufficient inventory of fissionable materials to create the potential for criticality.

420.2C

• Accelerator facilities or modules thereof and their operations when they contain or produce a sufficient inventory of fissionable materials to create the potential for criticality based on the configuration of the materials.

If: quantity of nuclear material sufficient to sustain a chain reaction – based on its configuration – independent of use of ionizing beams from an accelerator

Then: other Orders should be applied

Others

420.2B

• Nonmedical x-ray devices with the capability of accelerating particles to energies not greater than 10 MeV, which are operated in accordance with American National Standards Institute N43.3-1993, General Radiation Safety Standard for Installations Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies Up to 10 MeV, or in accordance with another applicable consensus standard as directed by the cognizant field element manager/NNSA field manager.

• Low-voltage neutron generators incapable of creating high-radiation areas (as defined in 10 CFR 835, “Occupational Radiation Protection; Final Rule,”), which are operated in accordance with National Council on Radiation Protection Report 72-1983, Radiation Protection and Measurements for Low-Voltage Neutron Generators, or in accordance with another applicable consensus standard as directed by the cognizant DOE/NNSA field manager. For the purpose of this Order, a low-voltage neutron generator is defined as a bench-top scale, single-purpose device generating neutrons by accelerating deuterons or tritons into targets through a maximum accelerating potential not greater than 600 kV.

420.2C

• Nonmedical x-ray devices with the capability of accelerating electrons to energies not greater than 10 MeV, which are operated in accordance with American National Standards Institute (ANSI) N43.3-2008, General Radiation Safety Standard for Installations Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies Up to 10 MeV, or in accordance with another applicable consensus standard as directed by the cognizant DOE field manager.

• Low-voltage neutron generators, which are operated in accordance with National Council on Radiation Protection and Measurements (NCRP) Report 72-1983, Radiation Protection and Measurements for Low-Voltage Neutron Generators, or in accordance with another applicable consensus standard as directed by the cognizant DOE/NNSA field manager.

Responsibilities

• Clear philosophy of pushing responsibilities to Field Office level– The only PSO level responsibility is to approve ASE for ‘higher

consequence’ accelerator operations– All other approvals at Field Office level

• ARR, start-ups, re-starts, decommissioning• Need to:

– clarify re-starts (to be those after a DOE-ordered shutdown)– clean up language on exemptions

• Threshold• Desire to change from qualitative to quantitative• Goal is not risk calculation; just to figure out approval

authority

Responsibilities

(1) Oversee the safe operation of accelerator facilities….

(2) Approve items listed in 5.b.(2)(a) for accelerator facilities where site boundary consequences for credible postulated accident scenarios that potentially exceed 1 rem (0.01 Sv) and/or ERPG-2

(3) Grant equivalencies or exemptions from the requirements of this Order, unless otherwise specified in this DOE Directive

(1) Ensure the safe operation of accelerator facilities….

(2) Except as provided in Section 5.a.(2), approves the following activities:

a) ASE

b) Start of commissioning activities after ensure that an appropriate ARR has been conducted

c) Start of routine operations

d) Restart of an accelerator facility after a shutdown because of an unreviewed safety issue or ASE violation

e) Decommissioning activities

f) Equivalence/exemption requests

Section 5 (a) PSOs Section 5 (b) Field elements

Reconsideration of ERPG Order Criterion (D. Freeman, ORNL)

• Chemical toxicity hazards addressed in other regulations and standards (e.g. DOE O 151.1C) we have policy of not duplicating other standard requirements.

• No need to draw chemical standards into the Order for accelerator safety since 1 rem is consistent with current standards and accelerator community operations.

• If we include chemical standards in the Order, it must be explained that this is a chemical toxicity limit and references added. Related issues may need to be addressed.

• Since ERPG-2 levels exist for over 150 common lab chemicals, we create the confusion associated with demonstrating that none of these chemicals could exceed the ERPG criteria.

• How do we handle chemicals not listed in ERPG tables? AIHA provides path for developing ERPG-2 values (~2-yr process).

• ERPG-2 is only applicable to 1 facility and is better handled as a local criterion rather than a general criterion applicable to all facilities.

Definitions• Started with language from Guide – modified as needed to address

the following:

• More general definition of Facility and Operation– 830

• ASE – Introduce concepts of ‘readily verifiable’ and ‘credited’

– Need better linkage with CRD

• Criticality*– Beamline induced

• USI– Recognize current variability across DOE

– Establish that there is a structured process that identifies these

Accelerator definitions

• Accelerator – a device employing electrostatic or electromagnetic fields to impart kinetic energy to molecular, atomic or sub-atomic particles and capable of creating a radiological area as defined in 10 CFR Part 835.

• Accelerator Facility – the accelerator and associated roads, plant and equipment utilizing, or supporting the production of, accelerated particle beams and the radioactive material created by those beams to which access is controlled to protect the safety and health of persons. It includes injectors, targets, beam dumps, detectors, experimental halls, non-contiguous support and analysis facilities, experimental enclosures and experimental apparatus utilizing the accelerator, etc, regardless of where that apparatus may have been designed, fabricated, or constructed – in sum all systems, components and activities that are bounded by the hazard analysis and controls.

• Accelerator Operations – those activities of an accelerator and any associated accelerator facilities that are bounded by the Safety Assessment Document Accelerator operations (and post operations) include the production; dispensing analysis, movement, processing, handling and other uses; and storage of radioactive material within the accelerator facility.

ASE

Definitions:

• is a set of readily verifiable physical and administrative credited controls that define the bounding conditions for safe operation and address the accelerator facility hazards and risks.

CRD:

• A documented ASE must define the physical and administrative bounding conditions and controls for safe operations based on the hazard/safety analysis documented in the SAD.

Definitions - continued

Criticality:• the condition in which a nuclear chain reaction becomes self-sustaining

without the use of external beams of ionizing radiation from an accelerator.

USI:• the determination that there is a significant increase in the

probability of or consequences from of a previously analyzed postulated accident or of a new, previously un-analyzed postulated accident that could result in a significant adverse consequence. This determination is part of a structured process to identify and evaluate whether planned or as-found conditions, equipment, or processes may exceed the bounds of an accelerator’s ASE. Activities that exceed the bounds of the ASE must not be performed until restart is approved by DOE.

Contractor Requirements Document

• Consolidate

• Remove overlap with other requirements

• Link to contractor assurance

CRD content

420.2b

• SAD

• ASE

• USI

• ARR

• Training/Qualification– 3 subparts

• Written Procedures– 8 procedures

• Internal Safety Review System

• Shielding Policy

420.2c

• ASE

• SAD

• USI

• ARR– Contractor Assurance System– Configuration management

program– Appropriate administrative

processes related to accelerator safety