DOE Accelerator Safety Workshop (ASW2010)
Tuesday, 8/17/10 Sesssion A (10:15 a.m. – 12:00 noon)
Facilitator: Jim Floyd
Key Discussion Topics:
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Equivalencies/Exemptions
Responsibilities
Definitions
USI
CRD structure and content
1. Non-complex needs clarification. Meaning was simple but don’t want to write it down
that way.
2. Room-sized accelerator: equivalent? Who approves & how to document? Answer:
under R2A2s (section 5, responsibilities).
3. What about portable machines that are not a facility, e.g., mobile units, are they
covered in exclusion? ANSWER: guide will have details. Disc. re: how it impacts people
offsite – more concern about mobile units.
4. 830/ASO Discussion: Purpose: language remains silent it becomes sticky because
“under 830” involves how to live under 2 sets of rules (e.g., LANL), 830 & 420.
Reworked the language to bring it under 835.
5. 830 vs. 835: 10CFRs (830, 835, 851) take precedent over 420.2C.
6. You are a reactor if you have a critical amount of material. Subcritical assemblies are
still a reactor. Criticality definition discussed.
7. The entire 830 order follows from the AE Act which deals only w/ special nuclear
material or source material & its fission products – have to have both to be included
in order.
8. Configuration: theoretical amount – adding this word because based on accel
facilities, we have an amount that is not capable of becoming critical. Talking about
exact configuration.
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9. Configuration is in the exclusion exemption. Want to define amount of material that
can sustain the reaction after the accelerator is off.
10.If you have enough material to be critical, you are a reactor depending on the
configuration (but you are still an accelerator).
11.Routine ops & accidents both have to be analyzed.
12.In 830 if you call it an accelerator, it’s exempt.
13.Two defs of accelerator in 830: one exempt; non-reactor exempts it – reactor doesn’t
exempt (“critical assembly” in your accelerator).
14.We continue to struggle w/ it. Language not clear enough. Need to clarify.
15. GC opinion on 830: conclusion states (reads from text) – not excluded from
requirements – part 830 cannot be applied.
16.Still required under 851 to provide safety to workers – have to analyze hazards.
17.Still have to follow order that calls for criticality safety.
18.Don’t fall under legal aspect of 830….we believe no PSO would approve a safety
analysis if you had that amount of rad matls if you hadn’t properly id’d it.
19.Our job here for ASO to allow that to happen but we can’t direct it.
20.Had a number of opinions in DOE for the last 7 years, but we believe the argument
raised by Ed is crucial to the continuation of accelerators. Match of reasonable
standards. Need that clause in place.
21.2B was considered a clarification that was a major stepping stone.
22.Any highpowered accel now falls into the def of a reactor…
23.Vital in 2003-04 re: SNS target facility. How to make that distinction but not cross the
boundary into reactor space. Some form of maintaining that distinction is vital to the
accelerator community.
24.If you leave it ambiguous (for site offices to decide) is not ideal.
25.“If you quality as a reactor…” – rather than “capability of criticality”….?
Consensus attempted: stand-alone statement rather than exemption: How to finish
statement in #4 (O 420.2C (3,C, 4) ) of presentation being reviewed/discussed.
26. Based on the config of material, the hazard analysis may (a note now).
27. Want to allow them to use the material.
28.Input from Malosh: if there is a potential criticality, it needs to fall under 830.
29.This order has to pass muster w/ Malosh.
30.If you’re going to use special nuclear material, have to keep amounts below that level
required for criticality.
31.Back to reason for using the word “configuration”…..
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32.“Potential” could be 10 to the minus 12.
33.Losing sight of what exemption is trying to accomplish: either you have 420.2C safety
basis or 830 Subpart B – you don’t have both.
34.Do you have enough to sustain a criticality – you’re still going to address those
hazards in your analysis – sort of an academic point.
35.Write your safety basis under one set of rules – not both.
36.How do we describe that to the community?
37.Talk to criticality expert as possible resource (Jerry McKamey?, DOE HQ involved in
crit safety); the technical piece.
38.We are trying to get to the words so it is clear & not confusing.
39.We are trying to craft words in an area for which few people in this room have the
necessary background.
40.…less than 10 to the minus 6…has been used & should be passed on for consideration
to those who know the subject.
41.Quantifiable definition of “potential” possible (less than 10 to the minus 9th, e.g.)
42.Criticality is not a public hazard; take credit for what you have documented.
43.If haz analysis id’s criticality as a hazard, you are in a different space.
44.CONCLUSION: Broadly agrees: the ASO is proper regulatory framework until you get
to some definition of “criticality” – working group has to get to language that will be
clear to DOE on how to move forward.
45. Exemptions and equivalencies: NEW TOPIC: generalizing – removing restrictions.
May be some redundancy – need to clear this up (ACTION) – some covered by 835.
46.Some discussion of useful redundancies re: ANSI standards, etc.
47.How you make your decision to put it under the equiv/exemption clause.
48.Benchtop vs. high energy – low voltage & don’t follow this standard, subject to
Order. Those 2 need to be connected somehow. Also need to pull references back
into standard.
49.Why not eliminate date since ANSI updates on a regular basis. Answer: WSS needs to
say more than “current version” – need something to reference so we can go back
thru the system, ask for an exemption if necessary, etc. OPTION: Given date OR the
current version. Discussion ensued. There may be guidance coming from DOE on how
to do this.
50.851: new standard comes out, but order is so tight, it’s hard to get room to get
approval; hope for quick reviews of equivalencies. Trying to simplify here.
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51.Clarify it’s up to approval authority that if exemption is not specifically cited & wants
to be used by the contractor, it has to go to the approval authority (site, HQ, etc.)
whether another equiv standard applies.
52.Clarification of concern (Varun G.) – do we want to lock ourselves into a date…or just
say “current”?
53.Individual unit may not exceed limits, but when assembled, it still needs to apply for
exemption if limit is exceeded.
54.RESPONSIBILITIES (next topical area): pushing them down to the field elements. At
Program Sectys office approving ASEs; all else is down @ field level.
55.Threshold has broad applicability – need to figure out approval auths, not figure out a
whole superstructure – just who does what….
56.Section 5A & 5B: 5B2a done by PSO; all else is run out by the field office.
57.Seeming overlap between approvals for equiv/exemptions – need to clean this up.
58.Equiv exemption belongs in field element section.
59.Restart after a DOE-mandated shutdown should be clarification, not simple “pauses”,
etc.
60.Discussion re: restart permissions – violated ASE (NNSA notified).
61.Old way keeps the responsibility of restart to those closest to the issue.
62.Depends on when you restart, what condition you are going to be in.
63.Even if you reword this, DOE can still come back & shut you down.
64.Implications on using Restart & Shutdown terms.
65.2B: req section, DOE talking to DOE: any activity violating ASE, activity must be
terminated.
66.Words we can use that clarify contractor’s shutdown based upon ASE violation? But
has to be high-level & capture intent of responsibility.
67.Distinction on who acts….chance to eliminate that confusion.
68.“Restart an accel facility after a DOE shutdown….” wording clarification may help.
69.“Contractor stops, contractor starts; DOE stops, DOE starts…”?
70. Responsibility wording matches CRD now.
71.Discussion honed in on Responsibilities (2) on section 5(a) PSOs.
72.“more than minor offsite conditions” is key; do you have a facility that requires offsite
emergency response actions – therefore DOE needs to be involved.
73.OAK: Reconsideration of ERPG Order Criterion by D. Freeman, ORNL: starting to get
into risk calculation where all we’re trying to do is get a threshold for who approves.
74.Discussion re: using ERPGs in ASO - DOE level of risk assessment.
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75.Location of accelerators is a key issue, e.g., downtown environment.
76.Does the PSO have to approve off-site planning need? Not necessarily.
77.Inconsistent because it’s an accelerator vs. any other facility – hazards identical.
78.Hold-over from old order re: haz classification. Question whether we even need to
have this @ the PSO level. Scott: yes, science programs want to know the haz level,
level of risk.
79.Consistent with your auth documents to have this in it – have to meet all auth basis
docs to get approval to operate. Who is DOE has to give this auth and what projects
fall into this?
80.Approval auth for accel ops is with field office if < 1 rem offsite.
81.If above ERPG, still need PSO approval….
82.Programs are telling Scott they still want some HQ approval.
83.No such thresholds on nuclear site for approvals. Inconsistency of approach. Bring
approvals down to where they need to be.
84.SAD is basis for developing your safety approach/approval.
85.SUMMARY: Value in retaining 1 rem offsite limit – linkage w/ NRC, etc. Drop off ERPG
2 – general consensus.
86.SAD – current language between Order & Guide: “determine acceptability of SAD”
but approval is with ASE. Determined it shouldn’t be mentioned in Order. Bottom
line is what Orders are about – what we are trying to accomplish, not how. Field
Office won’t approve an ASE unless SAD is acceptable.
87.Section 5B1 some language inconsistency pointed out (ACTION needed) –
“management & operating contractor” vs. “site/facility management contractors”
88.NEXT TOPIC: Definitions – generalized definitions of facility and created one for
operation. Criticality we took from 830 & modified it. Safety Envelope – wanted to
create 2 new components. Finally, USI – last year the workshop showed how much
variety of approach there was – need to recognize variability. Need concept that
there is a structured process behind the USI.
89.Summary of changes – giving better guidance.
90.“Roads” in “Accelerator Facility” was not comfortable to Scott & his resources.
General discussion. Put qualifier – “service”, “non-public”…? How far does this go –
has to be defined.
91.Transportation doc is done whether it’s a nuclear facility or not. If you are
transporting rad matl even on site (TSE). They are not public roads (Fermi) so would
like this word retained.
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92.Not the road but operation on the road…..
93.Trying to be clear/concise. “Associated roads within the site boundaries” may work.
94.“…regardless of where that apparatus may have been designed/operated/previously
used…” possible add. No discussion.
95.A couple of semi-colons in the Accelerator Ops section that need to be excluded
(ACTION)
96. Roger E.: don’t want to fill our documents with road hazards such as traffic accidents.
Response: clarification of intention – material being transported/different regulatory
scene. The road is part of your accelerator facility….
97.“bound by systems & controls” – slippery slope re: traffic accidents (Keith J.).
Clarification: accelerator-related hazards. ACTION: Put a qualifier on this word to
clarify intent.
98.New Topic: “readily verifiable” & “credited controls” – bounding limit called out by
CRD is helpful. Two words (“credited controls”), however, may help you get your ASE
approved. May want to leave details to the Guide, but you need the words there to
make the ASE streamlined and manageable. Discussion ensued.
99.If we can’t understand the risk, how are we going to improve it?
100. That issue should be addressed in the Guide….
101. If it’s not “readily verifiable” you may have exceeded it…
102. I have a process called configuration control – becomes accredited process.
Therefore don’t need “readily verifiable”. Omit “readily”? “Identifiable”? Something
that keeps you from putting in arbitrary boundaries (e.g. “I will follow all guidance.”)
103. Program element is how you are addressing Definition (Scott).
104. SUMMARY: Retain “credited controls” but figure out best adjective for “readily
verifiable” intent. Good clean linkage back to CRD needed - not redundant but no
gaps.
105. Suggest a set of definitive administrative controls…
106. New Topic: Criticality definition – add constraint at end – otherwise clean & simple.
107. New Topic: USI – Last sentence contradict earlier conversation (re: “ASE must not be
performed until restart is approved by DOE”). ACTION: Eliminate last sentence.
108. Accredited administrative control
109. After 1st sentence, it’s commentary that should be in Guide. (ACTION)
110. Add malfunction of EIS…
111. Accident condition? “accident or condition” or “new accident or condition”
(REVISION)
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112. New Topic: CRD – general: trying to clean things up & tighten it up.
113. Conduct of Ops may apply, when designated by DOE line management.
END OF MORNING SESSION
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