IA-87-809, Forwards Proposed Manual Chapter Re Insp of Large Irradiators Prior to Issuance of License.Comments Requested by 850515
| ML20244D314 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1985 |
| From: | Cobb L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Chapell D, Miller V, Nussbaumer D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20234D394 | List: |
| References | |
| FOIA-87-809 NUDOCS 8505010204 | |
| Download: ML20244D314 (6) | |
Text
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MEM3RANDUM FOR: Donald R. Chapell, Deputy Director Division of Fuel Cycle and Materials Safety, NMSS Vandy L. Miller, Chief '
Materials Licensing Branch, NMSS l -
Donald A. Nussbaumer, Assistant Director for 5 tate Agreements Programs, SP [+
James H. Joyner, Chief @
Nuclear Materials Safety and Safeguards Branch, RI 1
Kenneth P. Barr, Chief Nuclear Materials Safety and Safeguards Branch, RII William L. Axelson, Chief /
Nuclear Materials Safety and Safeguards Branch, RIII R. Jerry Everett, Acting Chief Nuclear Materials Safety and Safeguards Branch, RIV James L. Montgomery, Chief Nuclear Materials Safety and Safeguards Branch, RV FRDM: Leonard I. Cobb, Chief Safeguards and Materials Programs Branch, IE
SUBJECT:
INSPECTION OF LARGE IRRADIATORS PRIOR TO ISSUANCE OF A LICENS l * '
Currently there are three new large irradiator projects. They involve Co-60 I i
sources of fror 500,000 to 2,000,000 curies. We know about the Precision Materials Corporation irradiator in Region I, already constructed; the Isomedix facility j planned for Libertyville, Illinois; and an irradiator planned for the island of j Hilo, in the Hawaiian Islands. With the growing commercial interest in large irradiators, we can expect additional projects in the near future. In view of the potential hazard of the large gamma-emitting sources involved, it is essential that all components and systems carry out their designed safety functions as described in the NRC-approved application for an operating license. Therefore, we believe some type of formal relicensing inspection program is warranted and i
should be established. !
Although no construction permit is involved in these projects, there is the issue of having a factual basis upon which to decide whether the irradiation !
facility was constructed and tested in a way that demonstrates that it conforms j to the application. For example, interlocks and warning lights should be designed i and installed so that loss of electrical power, component failure, or other types of system failures, will result in an adequately shielded, safe condition l l for the source. i l (35V)5bwa% b )G% '
Contact:
J. Counts, IE ApR 2 6 1555 492-8457
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Multiple Addressees ]
It is obvious that the NRC needs to observe functional testing of the safety systems prior to installation and use of the irradiator source. My understanding is that we do this in the form of a relicensing visit. In addition to the functional tests, we should inspect the design and installation of these systems to determine whether, under all reasonably adverse conditions, they would work to shield the source and protect employees and the public.
We are proposing that NRC establish the inspection program described conceptually in this memo in keeping with one of the IE functions as stated in NRC 0127-021:
"When appropriate (IE) provides the responsible licensing officer information or assistance needed for approving or denying an authorization, permit or license."
That section also states that IE "... develops and administers policies and programs for regional inspection of ... applicants for an NRC license..." We view this as a joint NM55-1E-Regional effort because of the fact that the results of the inspection or inspections bear on the question of whether an applicant should be issued or denied a license for operating the irradiator or whether additional information is required before the NRC can determine that the facility can be operated safely.
1 Please recognize the pr'eliminary naturc of the procedure. We need some !
experience in order to ascertain how much relicensing inspection is necessary.
We need to establish the program fairly promptly, possibly in the form of a terporary instruction. It can be superseded by a permanent instruction af ter we gain some experience.
We would apprecia+. receivihgteny com ents you may have on the enclosed, proposed Manual Chapter b May 15,1985\
eonard I. Cobb, Chief Safeguards and Materials Programs Branch, IE
Enclosure:
As stated cc: J. Partio., IE
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DI l 1
CHAPTER 00XX l
CONSTRUCTION AND REOPERATION INSPECTIONS OF LARGE IRRADIATORS 00XX-01 PURPOSE The purpose of this Chapter is to ensure that large irradiators are designed and constructed so they can be operated in a manner that protects worker and public health and safety.
I OSXX-02 OBJECTIVES 02.01 To ensure, by conducting engineering and reoperation inspec-tions during construction, (a) that components and systems that ;
are important for protection of health'and safety at large irra-diators are built in accordance with the -license application, and (b) that tests demonstrate that all systems important .to health and safety function correctly an:! rePably.
02.02 To provide information to the materials licensing staff that )
will be used in support of a decision to' approve, deny, or l request changes in an application for an operating irradiator license.
1 i i
00XX-03 DEFINITIONS 03.01 Laroe Irradiators. Irradiators having areas where radiation levels in excess of 500 rems in one hour can exist at one meter from the source. Specific minimum safety requirements for such sources are stated in 10 CFR 20.203(c)(6). Large irradiators- i usually have stationary shields such as pools of water and con-crete or other structures.
03.02 Systems That Are Important To Safety. These include, but are i not limited to, engineered structural, mechanical, electrical, seismic, thermal, hydraulic and co puter systems that are designed, constructed, and operated to prevent or limit the exposure, or the potential for exposure, of workers and the pub-lic to radiation.
Issue Date:
1
. )
. . 1 CONSTRUCTION AND PF.EOPERATION
_ INSPECTIONS OF LARGE IRRADIATORS 00XX-04 00XX-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Director, Division of Inspection, (DI), IE Approves the inspection program.
04.02 Chief, safeauards and Materials Proarams Branch, (SMPB,), IE
- a. Develops, implements, and assesses the effectiveness of the !
inspection program in coordination with NM55.
- b. Develops new, and modifies existing inspection procedures, if and wher it is necessary to do 50.
- c. Coordinates with regional offices, the engineering te *iew 1 of license applications with new designs or significantly larger sources in order to ensure an adequate inspection j program.
- d. Provides regional of fices with engineering and technical j assistance as necessary to conduct the inspection program.
04.03 Recional Office Division Directors Responsible for Irradiator Construction and Reoperation Inspections Ensures that the affected regional office branch chiefs conduct i the inspection program. '
04.04 Affected Recional Office Branch Chiefs ;
- a. Provides SMPB with copies of license applications, draw- 1 ings, topical reports, and construction schedules in order to give SMPB the opportunity to review new designs or higher level sources.
- b. Evaluates the adequacy of the design, construction, and operability of engineered systems that are important to safety, with engineering and technical assistance from SMPB as necessary.
th nlops inspection plans in concert with the licensing e ef's review of the application.
- d. Develops a @ lements in! 1b
- i .
- e. In coordination with a state inspection agency accepts the results of building inspections to the extent that these contribute to the NRC objective in lieu of making certain inspections with NRC inspectors.
- f. Prepares formal inspection reports.
Issue Date: _ _ _ _ _ _ _
i CONSTRUCTION AND REOPERATION l 00XX-05 INSPECTIONS OF LARGE IRRADIATORS 00XX-05 BASIC REQUIREMENTS - .
05-01 Engineering Analysis. There are prer,ently no licensing accept- f ance criteria for engineered systems that are important to l safety at large irradiator facilities. Thus license applica-tions must be analyzed not only for inspectability but also for the adequacy of these systems. Potential inadequacies are to be reported, as soon as they are identified, to the license reviewer. If requested, the regional office engineering manage-ment will support the regional office license review management in communicating and explaining inadequacies to license. appli- !
cants. Inadequacies may include insufficient technical informa- '
tion in the license application.
. i i 05.02 Encineerino Construction Inspections Large irradiators are potential sources of lethal radiation j exposure. Thus all engineered systems that are important to i safety must be constructed so they can be operated reliably, !
i.e. , so that they function correctly not only during preopera-tion inspections, but also during the course of normal irradia- .
ter operations. Construction inspections should cover, but are I not limited to: foundations; shielding structures; hard wiring; hydraulic systems for water pools; mechanical handling mecha- i nisms; personnel safety interlock systems; remote control
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systems; radiation monitoring systems; emergency electric power supply systems; alarm systems; and computer systems. Inspec-l tions should be scheduled according to the regional Branch Chief's judgment of critical construction milestones.
The acceptance criterion is whether engineered systems that are l important to safety have been designed and constructed or !
installed in conformance with the details of the application, i meet construction codes and standards, and are capable of reliably carrying out the safety functions described in the ,
application. There may be cases where an applicant is proceed- l ing with construction befcre having received a license. In such cases, the acceptance criterion is whether construction and installation conforms with plans submitted with the license application. (The applicant is taking the risk that its plans may later be determined by NRC licensing management to be inade-quate.)
05-03 Enaineerina Reoperation Inspections.
At this stage, the applicant will have a license and anticipate receipt of the radiation sources it is licensed to possess and i
utilize.
l l Every engineered system that is important to safety, except the radiation shielding, can now be operationally inspected. The operational adequacy of the shielding will have to be inspected as soon as possible after the applicant has received the radia-tion source (s).
Issue Date:
a
. CONSTRUCTION AND REOPERATION.
INSPECTIONS OF LARGE IRRADIATORS 00XX-05-03 The licensee will have a NRC-approved set of operating. proce-dures. The inspection requirement is to observe the licensee conducting "6'y runs" through every NRC-approved operation pro-cedure. RSf'etfsn safety staff may be needed to inspect the functioning ti radiation instrumentation and- alarus by using check sources. The acceptance criteria is whether all engi-neered systems that are important to safety function properly and reliably (repeatedly). If inspectors identify problems that were not anticipated, the problems should be carefully l
inspected and documented. The inspection staff should follow up with the licensing staff or licensee, as appropriate, to correct the problems.
05-04 Inspe: tion Procedures (Construction and Reoperation).
The regional offices may utilize available applicable inspection procedures if they choose to do so. However, it is acceptable, and perhaps desirable to develop ad hoc engineering inspection plans utilizing the inspection staff's expertise and experience, and all applicable documents related to the license application.
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