Information Notice 2011-11, Heat and Smoke Detector Requirements for 10 CFR Part 36 Irradiators

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Heat and Smoke Detector Requirements for 10 CFR Part 36 Irradiators
ML103540028
Person / Time
Issue date: 04/27/2011
From: Reis T
NRC/FSME/DMSSA
To:
Herrera, Tomas: 415-7138
References
IN-11-011
Download: ML103540028 (6)


ML103540028 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF FEDERAL AND STATE MATERIALS

AND ENVIRONMENTAL MANAGEMENT PROGRAMS

WASHINGTON, D.C. 20555

April 27, 2011

NRC INFORMATION NOTICE 2011-11: REPORTING REQUIREMENT FOR HEAT AND

SMOKE DETECTOR FAILURES IN 10 CFR PART

36 IRRADIATORS

ADDRESSEES

All holders of irradiator licenses issued by the U.S. Nuclear Regulatory Commission (NRC)

under to Title 10 of the Code of Federal Regulations (10 CFR), Part 36, Licensees and

Radiation Safety Requirements for Irradiators; Agreement State Radiation Control Program

Directors and State Liaison Officers.

PURPOSE

The NRC is issuing this information notice (IN) to inform addressees that reporting may be

necessary when the smoke or heat detection systems in panoramic irradiators do not function

properly. This IN also reminds licensees that smoke and heat detectors required by 10 CFR 36, are independent systems and the inoperability of either is reportable when there is no redundant

equipment available to perform the required safety function. No specific action or written

response is required. The NRC is providing this IN to the Agreement States for their information

and for distribution to their panoramic irradiator licensees, as appropriate.

DESCRIPTION OF CIRCUMSTANCES

In September 2008, a State of Nebraska panoramic irradiator licensee reported that the smoke

detector used to detect smoke in the radiation room failed to operate during their quarterly

safety maintenance check. The smoke detector was not physically located in the radiation

room, but an inlet allows smoke to travel from the radiation room to the smoke detector. The

smoke detector failed to sense the smoke from a smoke stick. The licensee discovered that a

filter located between the smoke inlet and the smoke detector was clogged with debris and as a

result, the smoke detector was unable to detect the sample. The licensee tapped the filter with

a hammer, and blew compressed air through it to clear it out. The filter was re-installed and the

smoke detector retested successfully.

A State of Nebraska inspector was onsite during the licensees quarterly test. The licensee

informed the inspector that the smoke detector failed the test approximately once a year due to

a plugged filter. The licensee had not reported prior failures to the State regulator. From past

experiences, the licensee had not reported the prior failures because they thought that the heat

and smoke detectors required by the regulations made the two detectors redundant systems

since they both served to lower the source rack.

DISCUSSION

Both a heat and smoke detector were present, as required by the Agreement States regulatory

equivalent of 10 CFR 36.27; however, as already stated, the smoke detector failed its test.

Since this was the only smoke detector the failure required a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report in accordance with

the Agreement State equivalent of 10 CFR 30.50. 10 CFR 30.50(b)(2), which is applicable to

10 CFR Part 36 licensees under 10 CFR 36.1(a), and the equivalent Agreement State

regulatory requirements, require notification to the NRC or the Agreement State within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

after discovery of:

An event in which equipment is disabled or fails to function as designed when:

(i) The equipment is required by regulation or license condition to prevent releases

exceeding regulatory limits, to prevent exposures to radiation and radioactive materials

exceeding regulatory limits, or to mitigate the consequences of an accident

(ii) The equipment is required to be available and operable when it is disabled or fails

to function; and

(iii) No redundant equipment is available and operable to perform the required safety

function.

A similar situation was reported at an NRC regulated facility where a Radiation Safety Officer

was unaware that both smoke and heat detectors were required to function and were not

redundant systems. Other irradiator licensees may not be aware that smoke detectors and heat

detectors are independent requirements and both must be functional at all times. If either

system is not available and operable (e.g., disabled) or fails to function as designed, notice of

the inoperability or failure must be reported in accordance with 10 CFR 30.50(b)(2).

CONCLUSION

The Nebraska licensee resolved its problem by replacing the filters every quarter. NRC

licensees should check their detectors (and applicable filtration systems) at the interval

recommended by the manufacturer of their facility. NRC licensees should also consider

whether more frequent checks are necessary based on the cleanliness of their facility.

CONTACT

This IN requires no specific action or written response. If you have any questions about the

information in this notice, please contact the technical staff members listed below or the

appropriate regional office.

/RA/ by James G. Luehman for

Terrence Reis, Acting Director

Division of Materials Safety

and State Agreements

Office of Federal and State Materials

and Environmental Management Programs

Contacts: Tomas Herrera, FSME/MSSA

(301) 415-7138

Email: Tomas.Herrera@nrc.gov

Jack W. Foster, FSME/MSSA

(301) 415-6250

Email: Jack.Foster@nrc.gov

Enclosure:

List of Recently Issued FSME Generic

Communications

CONTACT

This IN requires no specific action or written response. If you have any questions about the

information in this notice, please contact the technical staff members listed below or the

appropriate regional office.

/RA/ by James G. Luehman for

Terrence Reis, Acting Director

Division of Materials Safety

and State Agreements

Office of Federal and State Materials

and Environmental Management Programs

Contacts: Tomas Herrera, FSME/MSSA

(301) 415-7138

Email: Tomas.Herrera@nrc.gov

Jack W. Foster, FSME/MSSA

(301) 415-6250

Email: Jack.Foster@nrc.gov

Enclosure:

List of Recently Issued FSME Generic

Communications

ML103540028 OFC

MSSA/LB

MSSA/LB

MSSA

OGC

MSSA

MSSA

NAME

THerrera

JFoster

AMcIntosh

BJones via

email

JLuehman

TReis

(JLuehman for)

DATE

12/21/11

1/4/11

1/20/11

4/5/11

3/8/11

4/18/11 OFFICIAL RECORD COPY List of Recently Issued Office of Federal and State Material

and Environmental Management Programs Generic Communications

Date

GC No.

Subject

Addressees

11/13/09 IN-2009-27

Revised International Nuclear and

Radiological Event Scale Users Manual

All holders of an operating license or construction

permit for a power reactor, test reactor or research

reactor issued under 10 CFR Part 50; holders of or

applicants for an early site permit, standard design

certification, standard design approval, manufacturing license, or combined license issued

under 10 CFR Part 52; holders of a materials license, certificate, approval, or registration issued under 10

CFR Parts 30, 31 through 36, 39, 40, 61, 70, 71, 72, and 76; Agreement State Radiation Control Program

Directors and State Liaison Officers.

11/19/2010

IN-2010-24 Notice of Possible Source Leakage During

Non-Routine Maintenance on a Gammacell

40 Irradiator

All academic Type A broad scope licensees; all

medical institutions; all self shielded irradiators

less than or equal to 10,000 cues licensees; all

Radiation Control Program Directors and State

Liaison Officers.

01/21/10

RIS-2010-02 The Global Threat Reduction Initiative (GTRI)

Federally Funded Voluntary Security

Enhancements for High-Risk Radiological

Material

All holders of operating licenses for nuclear power

reactors and research and test reactors

under the provisions of Title 10 of the Code of

Federal Regulations (10 CFR) Part 50, Domestic

Licensing of Production and Utilization Facilities, except those that have ceased operations and

have certified that fuel has been permanently

removed from the reactor vessel and have no

spent fuel stored on-site. All U.S. Nuclear Regulatory

Commission (NRC) fuel cycle facilities licensed under

10 CFR

Part 40, Domestic Licensing of Source Material or

10 CFR Part 70, Domestic Licensing of

Special Nuclear Material and gaseous diffusion

plants certified under 10 CFR Part 76, Certification of Gaseous Diffusion Plants.

All holders of site-specific licenses for independent

spent fuel storage installations (ISFSIs)

under the provisions of 10 CFR Part 72, Licensing

Requirements for the Independent Storage

of Spent Nuclear Fuel, High-level Radioactive Waste, and Reactor-related Greater than Class C

Waste, and all holders of 10 CFR Part 50 licenses

with ISFSIs under the general license

provisions of 10 CFR Part 72.

All NRC materials licensees authorized to possess

Category 1 or Category 2 quantities of

radioactive materials, under the provisions of 10 CFR

Parts 30, Rules of General Applicability

to Domestic Licensing of Byproduct Material, 40,

and 70. List of Recently Issued Office of Federal and State Material

and Environmental Management Programs Generic Communications

Date

GC No.

Subject

Addressees

05/25/10

RIS-2010-04

Monitoring the Status of Regulated Activities

During a Pandemic

All holders of operating licenses for nuclear power

reactors and research and test reactors under the

provisions of Title 10 of the Code of Federal

Regulations (10 CFR) Part 50, Domestic Licensing of

Production and Utilization Facilities, except those

that have ceased operations and have certified that

fuel has been permanently removed from the

reactor vessel and have no spent fuel stored on-site.

All U.S. Nuclear Regulatory Commission (NRC) fuel

cycle facilities licensed under 10 CFR Part 40,

Domestic Licensing of Source Material or 10 CFR

Part 70, Domestic Licensing of Special Nuclear

Material and gaseous diffusion plants certified

under 10 CFR Part 76, Certification of Gaseous

Diffusion Plants. All holders of site-specific licenses

for independent spent fuel storage installations

(ISFSIs) under the provisions of 10 CFR Part 72, Licensing Requirements for the Independent

Storage of Spent Nuclear Fuel, High-level Radioactive

Waste, and Reactor-related Greater than Class C

Waste, and all holders of 10 CFR Part 50 licenses

with ISFSIs under the general license provisions of 10

CFR Part 72. All NRC materials licensees authorized

to possess Category 1 or Category 2 quantities of

radioactive materials, under the provisions of 10 CFR

Parts 30, Rules of General Applicability to Domestic

Licensing of Byproduct Material, 40, and 70.

09/10/10

RIS-2010-09 Radiation Safety Officers For Medical-Use

Licenses Under 10 CFR Part 35 All U.S. Nuclear Regulatory Commission (NRC)

medical-use licensees, NRC master material

licensees, Agreement State Radiation Control

Program Directors, and State Liaison Officers.

01/25/11 RIS-2011-01 NRC Policy On Release Of Iodine-131 Therapy Patients Under 10 CFR 35.75 To

Locations Other Than Private

Residences

All U.S. Nuclear Regulatory Commission (NRC)

medical-use licensees, NRC master material

licensees, Agreement State Radiation Control

Program Directors, and State Liaison Officers.

Note: This list contains the six most recently issued generic communications, issued by the Office of Federal and State Materials and

Environmental Management Programs (FSME). A full listing of all generic communications may be viewed at the NRC public website at the

following address: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/index.html