Implementation of DOE Order 420.2C Safety of Accelerator Facilities

Sandia National Laboratories is a multi-program laboratory managed and operated by Sandia Corporation, a wholly owned subsidiary of Lockheed Martin Corporation, for

the U.S. Department of Energy’s National Nuclear Security Administration under contract DE-AC04-94AL85000.

Implementation of DOE Order 420.2C

Safety of Accelerator Facilities

Timothy S. StirrupIndustrial Facilities Safety Basis

Sandia National Laboratories, New Mexico

Background Update to Department of Energy (DOE) Order (O)

DOE O 5480.25 – November 1992 DOE O 420.2 – November 1998 DOE O 420.2A – January 2001 DOE O 420.2B – July 2004 DOE O 420.2C – July 2011

Update Drafted Through Cooperative Effort DOE Office of Safety, Security, & Infrastructure (Lead by Scott Davis, SC-31.1) Accelerator Safety Workshop(s) Planned Re-Write Meetings

Update to Encourage Dialog with Site Office

Background

Formal Revision Process Justification Memo (JM) – 09/2010 Directives Review Board (DRB) – 05/2011 Formal Revision of the Order (RevCom) – 03/2011

Order Revisions Included: Accelerator Definitions Approval Authorities Minimum Program Requirements Exemptions/Equivalencies Removed Duplications

No New Significant Requirements for Applicable/Regulated Accelerators

Background

Exclusions Are Now Exemptions All “Accelerators” Are Now In Device/Facility Exemption from Section 4 Requirements Meant to Establish Minimum Criteria Where 420.2C Applicable Meant to Exempt Devices Already Exempted in Other Directives (e.g., RGDs)

Exemptions May Create Potential 10 CFR 830 Implications Exempted Devices are Still Accelerators 10 CFR 830 Definition of Nonreactor Nuclear Facility “…Does Not Include Accelerators

And Their Operations…”

Background

Equivalency (to Address 10 CFR 830 Implications)

The DOE PSO/NNSA Administrator may specify alternate safety standards, requirements or DOE Directives that provide equivalent (or greater) protection in lieu of or in addition to the requirements of this Order

These alternate standards would be primarily for those accelerator facilities or modules thereof and their operations when they contain, use or produce fissionable materials in amounts sufficient to create the potential for criticality based on the configuration of the materials

Primary NNSA/DNFSB Issue During RevCom

If Accelerator Begins to Reach Potential for Criticality – Then Discuss with Site Office to Determine Course of Action

Essential Order Requirements

Section 4 Requirements for Applicable/Regulated Accelerators

(1) Accelerator Safety Envelope (2) Safety Assessment Document (3) Clearly Defined Roles & Responsibilities (Training) (4) Unreviewed Safety Issue (5) Accelerator Readiness Review (6) Current Listing of Accelerators

Including 3.c.[2] Exemptions Including 3.c.[3] Equivalency

Implementation

All Accelerator Devices In The Order

Changes How Look at Definition of Accelerator

Creates “New Class” of Accelerators May Include Radiation Generating Devices (RGDs) Not Traditionally

Considered Accelerators Under Old Order

Exemptions Closely Follow Previous Exclusions

No Expected Changes to Currently Identified “Regulated” Accelerators

Implementation

Two Types of Exemptions

3.c.[1] Non-Complex & Local Area Impacts Majority of RGDs Contractor Approved Internally Maintain List

3.c.[2] DOE Local Field Office Approval Limited # of Accelerators DOE Site Office Approval Provide List to Site Office

Implementation – Applicability

Applicability Logic Step #1 (Accelerator Definition)

Applicability: RGD Create A Radiological Area Radiation Area, High Radiation Area, or Very High Radiation Area Accessible to Individuals

Define Accessible to Individuals Likely Site Specific

– Area Within Shield Walls ~ Yes– Area Within Equipment ~ No

Applicability: RGD Create an Airborne Radiological Area

No Radiological Area or Airborne Radiological Area – Then Not Accelerator

Implementation – 3.c.[1] Exemption

Applicability Logic Step #2 (Non-Complex & Local Area Impacts)

Define Non-Complex (site specific) Equivalent to a device in a “single-room” or defined area with access

control that can be operated by a single operator either proximate to the device or from a single control area

Define Local Area Impact (site specific) Area within 100 m of the facility Corresponds with “low hazard classification”

3.c.[1] Exemption Applies Only If Non-Complex AND Local Area Impacts


Listed Examples – Order Lists As Examples Only

3.c.[1] (a) (#1) Current Generating Device Device’s primary function is to generate electrical current

3.c.[1] (a) (#2) Exempt RGD Device is an exempt-shielded or shielded class radiation generating device

(RGD). An exempt-shielded or shielded class RGD may be considered as one of the following examples:

– Inherently safe– Certified cabinet– X-ray diffraction or fluorescence analysis equipment– Other shielded RGD– Portable or mobile radiography RGD not using a radiological source


Listed Examples (cont)

3.c.[1] (c) (#1) X-ray <10 MeV Device is a single beam, “bench-top” sized, x-ray generator, with an

accelerating potential below 10 MeV and may be operated by a single operator in accordance with American National Standards Institute (ANSI) N43.3 or other consensus standard.

3.c.[1] (c) (#2) Neutron Generator < 600 keV (accelerating potential) Device is a “bench-top” sized, neutron generator, with an accelerating

potential below 600 keV and may be operated by a single operator in accordance with the National Council on Radiation Protection and Measurements (NCRP) or other consensus standard.


Listed Examples (cont)

3.c.[1] (b) Single Room Device Device is a room-sized accelerator with a single external and/or

extractable beam, an active safety system, and the room has a single point of entry

3.c.[1] (d) Unmodified Commercially Available Device is unmodified and commercially available Examples include, but are not limited to, electron microscopes, ion

implant devices, and x-ray generators; additional equipment may also include other types of semiconductor equipment and commercially available research accelerators


Reviewed & Approved Exemption

Sandia Implementation Recommendation

3.c.[1] Other Contractor Safety Basis Approved Non-Complex AND Local Area Impacts Only Submittal of Exemption Request to SB Long lead time for Evaluation and Justification

– Non-Complex– Local Area Impacts Only

Dialog with Site Office


Site Office Review & Approval

DOE O 420.2C 3.c.(2) Exemption DOE May Approve Other Accelerator Exemptions, In Addition To Those

Examples Listed In Paragraph 3.C.(1), From The Requirements Of This Order In Accordance With The Provisions Of Paragraph 5 Of This Order

DOE Field Element Manager Approval

No Documented Approval Process To Date Long Lead Time For Contractor SB Review & Justification Longer Lead Time For DOE Site Office Review & Approval Likely Iterative Process

Sandia Implementation

Use of Existing Primary Hazard Screen (PHS) System/Process Logic Based Question & Answer Hazards Identification Tool Used to Evaluate and Assign Hazard Classification

Additional Question Added Question 1k. Does the operation involve a device capable of creating a

radiological area? Note: By definition, radiological areas must be accessible to individuals -

otherwise the area is not a radiological area.

Answers If “no,” then not an accelerator. If “yes,” then fill out logic table to determine applicability.

https://www.directives.doe.gov/directives/441.1-EGuide-10/view

Sandia PHS Question Logic

Non-complex & Local?

C(1) Exempt?(7 SNL)

RGD creates

Rad Area?

C(2) Exempt?

(SSO)

Accelerator

C(2) ExemptAccelerator

C(1) ExemptAccelerator

Y

Y

Y

YN

N

OKN





One Year Implementation for Incorporation of Annual PHS Updates

PHS Documents Decision Process

PHS Generates Required List Regulated Accelerators 3.c.[2] Exemptions 3.c.[3] Equivalency

Supporting Slides

Other Changes/Issues

DOE Secretarial Officer/NNSA Administrative Approvals

5.a.[2] #1 - Approve the Safety Envelope for accelerator facilities where site boundary consequences for credible postulated accident scenarios potentially exceed 1 rem (0.01Sv)

5.a.[2] #2 - Approve the Safety Envelope for accelerator facilities where site boundary consequences for credible postulated accident scenarios potentially exceed Emergency Response Planning Guide ERPG-2


DOE Secretarial Officer/NNSA Administrative Approvals

5.a.[3] Approve Field Element Manager recommendations that require alternate safety standards, requirements or DOE Directives as they are applied to accelerator facilities in accordance with paragraph 3.c.(3) and ensure the appropriate DOE and ANSI standards are adequate to address the hazard.

5.a.[4] Grant equivalencies or exemptions from the requirements of this Order, as requested by the Field Element Managers.


DOE Field Element Managers Approve The Following Except As Provided In Paragraph 5.a.(2): (a) Accelerator Safety Envelope (ASE); (b) Start of commissioning activities after ensuring that an appropriate

Accelerator Readiness Review (ARR) has been conducted; (c) Start of routine operations; (d) Restart of an accelerator facility or activity after a DOE-mandated

shutdown because of an USI or ASE violation; (e) Activities that justify a USI; (f) Decommissioning activities; and (g) Exemption/Equivalency request in accordance with paragraphs 3.c.

(2) and 3.c.(3).

Definitions

Radiation Generating Device: A device that generates ionizing radiation (e.g., neutrons, x-rays, or bremsstrahlung) intentionally or incidentally when energized.

Accelerator: A device [e.g., RGD] employing electrostatic or electromagnetic fields to impart kinetic energy to molecular, atomic or sub-atomic particles and capable of creating a radiological area [DOE O 420.2C]

Radiological Area: Any area within a controlled area defined in 10 CFR 835 as a radiation area, high radiation area, very high radiation area, contamination area, high contamination area, or airborne radioactivity area [10 CFR 835]

Definitions

Controlled Area: Any area to which access is managed by or for DOE to protect individuals from exposure to radiation and/or radioactive material [10 CFR 835]

Radiation Area: Any area, accessible to individuals, in which radiation levels could result in an individual receiving an equivalent dose to the whole body in excess of 0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the source or from any surface that the radiation penetrates [10 CFR 835]

Airborne Radioactivity Area: (1) The concentration of airborne radioactivity, above natural background, exceeds or is likely to exceed the derived air concentration (DAC) values listed in appendix A or appendix C of this part; or (2) An individual present in the area without respiratory protection could receive an intake exceeding 12 DAC-hours in a week [10 CFR 835]

Definitions

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.

Radiation: Ionizing radiation (alpha particles, beta particles, gamma rays, X-rays, neutrons, high-speed electrons, high-speed protons, and other particles) capable of producing ions.

Definitions

Accelerator Facility: The accelerator and associated roads within site boundaries, 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 workers, the public or the environment.

The term facilities 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, including all systems, components and activities that are addressed in the Safety Analysis.