ML20217N700

Responds to RAI Re Human Irradiation,Beam Room, Bridge Position Readout & Other Items Noted in Request

ML20217N700
Person / Time
Site:	Washington State University
Issue date:	02/20/1998
From:	Tripard G WASHINGTON STATE UNIV., PULLMAN, WA
To:	Mendonca M NRC
References
TAC-M79607, NUDOCS 9803090149
Download: ML20217N700 (16)

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] Washington StateUniversity Nuclear Radiaton Center P O Box 641300 Pullman, WA 991641300 509-335-8641 FAX 509 335 4433 Friday, February 20,1998 Marvin M. Mendonca Senior Project Manager U.S. Nuclear Regulatory Commission MS OWFN 11 B-20 Washington, D.C. 20555 Ref: Docket 50-27

Dear Mr. Mendonca:

' This letter is in response to a request for additional information (TAC NO M79607) dated January 9,1998. I will address each item in the crder in which they are listed in the request. The responses were reviewed and approved at the last Reactor Safeguards Committee meeting, February 17,1998.

1. We would prefer not to put any reference to human irradiation in these specifications. Even if we get to the place where we would like to explore such possibilities, it is our understanding that the US NRC has not given us permission to use human subjects by appmval of the technical specifications under current consideration. We do not think it makes any sense to explicitly mention human irradiation at this stage. No other reactor has such a technical specification. If we ever get to the point where we have developed an ideal BNC facility, I would not like anyone to think tha because we have a strange statement prohibiting human subjects in our technical s pecifications, the US NRC decided that WSU will NEVER be permitted to irradiate humans, even if we apply for permission later. We are not trying to do something sneaky or underhanded.

Everyone knows that deliberate human irradiation requires many explicit permits and licenses. I don't think the US NRC needs to worry that WSU will try to surreptitiously irradiate someone without explicit US NRC approval. If we ever get to the point where human subjects are considered, we will apply for the appmpriate change to our technical specifications to permit this activity.

2. Figure 1 shows the BNC beam room.

The beam room will be partitioned by an access gate into two separate areas. One area will be designated as the exclusion zone which includes the region where the targets are irradiated. The other area, on the other side of the access gate, will be referred to as the BNC display panel area.

It is in the BNC display panel area that the BNC facility experimenter will monitor the progress of any BNC experiment while a BNC targe.t is being irradiated.

The BNC remote display panel will have the following features: ,f l

. A bridge linear-position-read-out that digitally displays the position of the bridge.

. Two bridge location lights: yellow indicating bridge IN f)O jl l green indication bridge OUT (retracted)

L Two irradiation room access gate status lights:

- one light indicates access gate is closed and the exclusion f zone which includes the target region is secured Uduv1b 9803090149 990220 1Ell$1533 man e$jg mm I N,pHRIM

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- the other light indicates gate open and the exclusion zone which meludes the target region is unsecured

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• Analog Reactor Log Power dis > lay

• Analog Reactor Linear Power c isplay A Reactor SCRAM button The reactor can be scrammed fmm three locations within the beam room. If a person inside the exclusion zone wishes to scram the reactor, he can do so by pressing a SCRAM button inside the irradiation area near the neutron beam cr by opening the access gate. If a person is in the BNC

. display panel area, he can scram the reactor by >ressing the red SCRAM button on the BNC l dis > lay panel. The BNC display panel area SC (AM button, tl. irradiation area SCRAM button,

anc the access gate interlock switch will be added in mies to the existiag reactor SCRAM chain.

he access gate will be sufficiently mbust and large that the only way for a person to get to the other side would be to open the access gate. The access gate will require no shielding capability.-

' In fact it will be made in a way which permits one to see through it. The bulk of it will likely be made of enain-link material. There will be one normally-open (NO) micro-switch installed in the

. access gate such that a spring load will keep the switch open unless the access gate is closed. This NO-micro-switch will be part of the reactor SCRAM cham.-

There will be two additional normally-closed (NC) micm-switches on the access gate such that a

spring loading will keep each switch closed unless the access gate is closed. Oac of these NC-nucm-switches will move the bridge to the retracted position if the access gate is opened. The ot'ar NC-micro-switch will connect a vohage to the area monitor alarm if the access gate is .

opened. (See drawing entitled: BNCF Treatment Room Area Radiation MonitorInterlocks)

An altemate connection of a voltage to the area monitor alarm will be provided by a key bank. The key bank controls a NC-micro-switch which opens only if all of the keys in the key bank are i inserted and turned. This key bank will also contml an inhibit bladv withdrawal if any key is missing and the set of keys are not turned. Anyone who has one of the keys in his possession can be assured that the reactor can not be started up and that the area monitor alarm has been enabled even if the access gate is closed.

3. The i 19 % shoulu read i 10 i The number is somewhat arbitrary but reflects the current judgement that a monitor error of more than i 10 % may indicate a sufficiently serious malfunction of the monitor that the source of error should be investigated before proceeding with the irradiation. If the error is less than this specification, the decision to proceed should be left to the discretion of the experimenter.

4. There are no reactor or facility controls that pertain to these components, they are only mentioned here so that there will be no misunderstanding about whether or not such items are part of the definition of the BNC facility.

5. The bridge pcsition readout will not be used for anything other than a qualitative judgement about whether the bridge is stationary or moving. Rus, the primary purpose for the bridge  !

. position function can be fulfilled easily by a video camera and monitor. If the accuracy on the j position is within i 10 %, it will be good enough to tell whether the bridge is moving or not and in j which direction. All the camera has to do is cover the visual region of the current pointer and tape measure now mounted on the bridge and track. 1 i

De limit-switch light indicators will be the decisive indication as whether the bridge is in the retracted position or in its irradiation position.

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6. We agree that 10g is ambiguous and suggest that it be changed to read:

g) Bridge can be moved manually by Operational test someone standing on the reactor bridge

7. Specification 1. second sentence will be changed from:

"In the event that the medical facility scram is inoperable. ..."

to:

) "In the event that the BNC facility scram is inoperable. ..."

In the only other places in which the word " medical" was found, the word " medical" was deleted, namely; 3.(f)and 10.(n)

8. See the description of the access gate aal key bank under item number 2 and the drawing 1 entitled: BNCF Treatment Room Area Radiation MonitorInterlocks. I

9. The instructions to notify the reactor operator of an abnormality will be located in the BNC display panel area. The only neutron beam controls available to a person located anywhere in the beam room are the access gate and the two SCRAM buttons. Op ening the access gate or pressing either of the two SCRAM buttons will SCRAM the reactor ifit is operating and retract the bridge if itis in an unretracted position.

Sincerel , i

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&+k Gerald E. Tripard l Director i

enclosures: Draft-5 of the Proposed Technical Specification Changes to Accommodate a Boron Neutron Capture Facility at Washington State University, i Figure 1 Reactor Beam Room, Figure BNCF Treatment Room Area Radiation Monitor Interlocks '

cc: Howarti Miles,WSU Jim Venhuizen,INEL i D.W. Nigg INEL R.J. Wiersema, Neutron Therapies Incorporated R. Wesley Leid, WSU l P.R. Gavin, WSU i l

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. On this 'tfay personally appeared-before me . Senta 'E_ WJ, pean I to me known to be the individual described in and who executed the written instrument and acknowledge that HE/Me signed

' the same IIIShfER free and voluntary act and' deed for the uses and purposes herein mentioned.

"GIVEN UNDER MY HAND AND OFFICIAL SEAL, the 8" day of lma , /992 .

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i 3.15'. GENERATION OF BORON NEUTRON CAfrrURE FACILrrY BEAM Definitions:  !

1. For the purpose of this technical specification, the term 'BNC facility' shall refer to the boron neutron capture facility which includes the beam, bridge moving system, beam monitoring equipment, beam shielding room, access gate and experimental area viewing equipment. He experimental bench, positioning equipment, and other equipment used for the beam targets are not considered part of the BNC facility for purposes of this provision, except insofar as radiation safety (i.e., activation and/or contamination) is concerned.

2. He tenn 'BNC experiment' shall refer to a boron neutron capture experiment involving the neutron irradiation of biological cells enriched with boron.

3. De tenn ' calibration check' refers to the process of checking the beam intensity and quality via one or more of the following: foil activation; use of a fission chamber, use of an ion chamber; or an equivalent process. He purpose of a calibration check is to ensure that the beam has not changed in a significant way (e.g., energy spectrum or intensity) fmm the beam that was characterized.

4. The term ' functional check of the beam monitors' shall consist of verifying that system output is consistent (i 10%) with previously measured values upon normalization to a common reactor neutronic power level.

5. Tnc tenn ' characterization' refers to the process of obtaining the dose-versus-depth profile in phantoms. The dose-versus depth profile from the surface of the phantom to a depth at least equivalent to the total thickness of the target volume to be irradiated on a central axis is deemed adequate for a characterization. Fast neutron, thermal neutron, and gamma ray components are determined in a characterization and monitors are normalized by this characterization.

6. De tenn ' calibration'of the beam monitors' refers to the process whereby the beam monitors are calibrated against instruments that measure dose including a tissue equivalent 1

chamber and a graphite or magnesium wall ionization chamber ( or the equivalent to any of these three) that have in turn been calibrated by a secondary calibration laboratory.

7. The term ' design modification' as applied to the BNC facility beam refers (a) to a change

' that is shown to alter the dose-versus-depth profile of the fast neutrons, thermal neut ons, or gamma rays in the beam as sensed by the calibration check and (b) to a change that has the potential to increase significantly the amount of activation products in the BNC facility.

8. The term ' radiation fluence' means the total fluence of neutrons and gamma radiation that is emitted in the BNC facility beam. The determination of the ratios of gamma, fast acutron, and themial neutron fluences is part of the beam characterization. Knowledge of these ratios allows the total radiation fluence to be monitored by the on-line detectors, which are neutron sensitive. Compliance with the limits specified on radiation fluence by this specification is determined by reference to the fluence monitored by these detectors.

Aoolicability:

This specification applies solely to the generation of the BNC facility beam for BNC experiments. It does not apply to any other use of the BNC facility and/or its oeam. Surveillances

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listed in this specification are required only if BNC experiments are planned for the interval of the surveillance. However, in the event of a hiatus in the scheduled performance of any given surveillance, that st.tveillance shall be performed prior to the initiation of BNC experiments during the interval in question.

Obiective:

To acquire testing and operational experience in use of a facility developed specifically for Boron Neutron Capture Technology.

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Snecifications:

1. It shall be possible to initis x, reactor from a control panel located in the BNC facility area. In the evert eility scram is inoperable, it shall be acceptable to use one of the control .. sc.ams vm umunication with the reactor operator as a temporary means of satisfying this provision. Use of this temporary provision is limited to seven consecutive working days.

2. Access to the BNC facility shall be controlled by means of the access gate located at its entrance.

3. The following features and/or interlocks shall be operable:

(a) An interlock shall prevent moving the bridge from the retracted position unless the BNC facility's access gate is closed.

(b) The reactor shall scram and the bridge shall move to the retracted position automatically upon opening the treatment room's access gate.

(c) The bridge shall be designed to move to the retracted position automatically upon failure of facility electric power or low voltage on the backup batteries that power the bridge motor. l (d) Bridge movement that controls beam delivery shall be designed for manual movement to the retracted position. i (e) It shall be possible to move the bridge to the retracted position from within the BNC facility.

(f) A BNC facility lockdown near the access gate shall inhibit blade withdrawal when the key is not inserted and tumed to the locked position.

4. Bridge shall be equipped with a position readout that indicates the status of the bridge A g bridge position readout shall be visible at the BNC facility's local control panel. In the event of a bridge position readout malfunction. it shall be acceptable to use an alternate means of verifying position such as a video camera in the pool room providing a signal to a 3 i l

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l monitor at the BNC facility's local control panel. Use of this alternate means of bridge position verification is limited to seven consecutive working days. 1 1 1

5. The BNC facility shall be equipped whh a read out display of the reactor log-power and the linear power on the BNC facility control console just outside of the shielding.

6. The BNC facility shall be equipped with a monitor that provides a visual indication of the radiation level within the facility, that indicates both within the facility and at the local control panel, and that provides an audible alarm both within the facility and at the local contml panel.

(a) This radiation monitor shall be equipped with a backup power supply such as the reactor emergency power system or a battery.

(b) This radiation monitor shall be checked for proper operation by means of a check source on the calendar day of and prior to any BNC experimentation.

(c) This radiation monitor shall be calibrated quarterly.

(d) The audible alarm shall be set at or below 50 mR/hr. This monitor and/or its alarm l may be disabled once the BNC room has been searched and secured, such as is done immediately prior to initiation of BNC experimentation. If this is done, the monitor and/or its alarm shall be interlocked so that they become functional upon opening of the BNC facility access gate.

(e) In the event that this monitor is inoperable, personnel entering the BNC facility shall use either portable smvey instruments or audible alarm personal dosimeters as a temporary means of satisfying this provision. These instruments / dosimeters shall be in calibration as defined by the WSU Research Reactor's radiation protection program and shall be source-checked daily prior to use on any day that they are used to satisfy this provision. Use of these instruments / dosimeters as a temporary means of satisfying this provision is limited to seven consecutive working days.

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7. An intercom or other means of two-way communication shall be operable both between the BNC facility control panel and the reactor control room, and also between the BNC facility control panel and the interior of the BNC facility shielding.

8. It shall be possible for personnel monitoring a BNC experiment to open the BNC facility access gate manually.

9. It shall be possible to observe the BNC experiment by means of two independent closed-circuit TV cameras. Both cameras providing visualization shall be operable at the outset of any BNC experiment. Should either fail during the irradiation, the experiment may be continued at the discretion of the experimenter. Adequate lighting to permit such viewing shall be assured by the provision of emergency lighting and backup power for one TV camera and monitor.

10. The following interlocks or channels shall be tested at least monthly and prior to a BNC experiment if the interlock or channel has been repaired or deenergized:

Interlock or Channel Surveillance a) The reactor scrams and the bridge Scram test retracts upon BNC facility scram ,

i b) Bridge will not move from the retracted Operational test position unless access gate is closed c) Upon opening the BNC room's access Operational test gate the reactor scrams and the bridge moves to the retracted position d) Upon opening only the bridge retraction Operational test switch on the access gate of the bridge retracts e) The bridge moves toward the retracted Opemtional test position on loss of electrical power and low voltage on the bridge motor batteries 5 l

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f) Manual movement of bridge Operational test g) Bridge can be moved manually Opemtional test l

by someone standing on the reactor bridge h) Bridge position indicator and status Operational test lights i

i) Radiation monitor alarm Opemtional test l j Radiation monitor and/or alami Operational test enabled upon opening of shield door i I

k) Intercoms Opemtional test l l} BNC facility TV cameras, monitors and Operational test its power backup 3 m) BNC facility emergency lighting Operational test n) BNC facility lockdown blade inhibit Opemtional test In addition to the above, the BNC facility scram shall be tested prior to reactor startup if the reactor has been shut down for more than sixteen hours.

I1. Manual operation of the BNC facility's access gate in which the door is opened fully shall be verified semi-annually.

12. Use of the BNC facility beam shall be subject to the following:

a) A calibratica check of the beam and a functional check of the beam monitors shall be made weekly for any week that the beam will be used for BNC experiments.

These checks shall be made prior to any BNC experiment for a given week. In addition, a calibration check shall be perfomied prior to any BNC experiment in the event that any component of a given beam design has been replaced. Finally, a calibration and a functional check shall be performed prior to any BNC experiment in the event of a design madification.

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! b) A characterization of the beam shall be performed every six months for any six- l month interval that the beam will be used for BNC experiments. This six-month characterization shall be made prior to any BNC experiment for a given six-month

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interval. A characterization shall also be performed prior to any BNC experiment in the event of a design modification. As part of the characterization process, the proper response of the beam monitors shall be verified.

c) A calibration of the beam monitors shall be performed at least once every two years for any two-year interval that the beam will be used for UNC experimentation. The two-year calibration shall be made prior to any BNC experimentation during any given two-year interval.  !

d) A scram from full power initiated when the reactor is positioned against the BNC ,

facility filter shall be performed every six months or in the event of a design modification. The BNC room radiation monitor reading shall not exceed 50 mR/hr, 30 seconds after the initiation of the scram and bridge retraction.

13. Maintenance, repair, and modification of the BNC facility shall be performed under the supervision of a senior reactor operator who is licensed by the U.S. Nuclear Regulatory l

Commission to operate the WSU Research Reactor. All modifications will be reviewed pursuant to the requirements of 10 CFR 50.59.

14. Personnel who are not licensed to operate the WSU Research Reactor but who are responsible for either the BNC or the beam's design including construction and/or modification may operate the controls for the BNC facility beam provided that: ,

1 (a) Training has been provided and proficiency satisfactorily demonstrated on the design of the facility, its controls, and the use of those controls. Proficiency shall be demonstrated annually. j (b) Instructions an: posted at the BNC facility's local control panel that specify the procedure to be followed:

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l (i) to ensure that only the appropriate target is in the irradiation facility before l tuming the primary beam of radiation on to begin an irradiation; 1

(ii) if the operator is unable to tum the primary beam of radiation off with controls outside the BNC facility, or if any other abnormai condition occurs. A directive shall be included with these instructions to notify the reactor console operator in the event of any abnormality.

(c) In the event that bridge movement affects reactivity, personnel who are not licensed on the WSU Research Reactor but who have been trained under this provision may initiate bridge movement provided that verbal permission is requested and received from the reactor console operator immediately prior to such action. Emergency scrams causing a bridge retraction are an exception and may be made without first requesting permission.

Records of the training provided under subparagraph (a) above shall be retained in accordance with the WSU Research Reactor's training program or at least for three years.

A list of personnel so qualified shall be maintained in the reactor control room.

Basis The requirement that it be possible to initiate a scram from a control panel located in the BNC facility area assures the experimenter or die capability to terminate the irradiation immediately should the need arise. The provision that access to the BNC facility be limited to a single gate ensures that there will be no inadvertent entries. The various interlocks for the bridge movement system that controls beam delivery ensure that exposure levels in the BNC facility will be minimal prior to entry by personnel. The bridge position indicator and status lights serve to notify personnel of the beam's status. The provision for a radiation monitor ensures that personnel will

, have information available on radiation levels in the BNC facility prior to entry. The purpose of l

this monitor's audible alarm is to alen personnel to the presence of elevated radiation levels. This monitor and/or its alarm may be disabled once the BNC facility has been searched and secured so 8

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i that it will not distract attending personnel. The monitor and/or its alarm are interlocked with the access gate so that they are made functional upon opening that gate, and hence prior to any possible entry to the BNC facility. One intercom provides a means for the prompt exchange ofinformation between the experimenter (s) and the reactor operator (s).

The provision for manual operation of the BNC facility's access gate ensures access to the experimental area in the event of a loss of electrical power. The presence of the closed-circuit TV cameras provide the experimenter (s) with the opportunity to monitor the targe; area visually as well as through the use of various instruments. The emergency lighting and the backup power for a TV camera and monitor will permit visual surveillance of the target area in the event of a power failure.

The surveillance requirements for beam calibration checks and characterizations provide a mechanism for ensuring that the BNC facility and its beam will perform as originally designed.

Similarly, the surveillance requirements on the beam monitors ensure that these instruments are calibrated by a means traceable to the National Institute of Standards and Technology. The chambers specified (tissue-equivalent, and graphite or magnesium-wall) were chosen because they measure dose as opposed to fluence.

'Ihe specifications on maintenance and repair of the BNC facility ensures that all such activities are performed under the supervision of personnel cognizant of quality assurance and j l'

other requirements such as radiation safety. The provision on the training and proficiency of non-licensed personnel ensures that all such personnel will receive instruction equivalent to that given to licensed reactor operators as regards use of the BNC facility beam. (Note: Licensed reactor l operators may, of course, operate the BNC facility beam.) Also, this provision provides for the posting of instructions to be followed in the event of an abnomiality.

References 6.5-1 MITR Staff," Safety Analysis Report for the M!T Research Reactor (MITR-II)," Report No. MITNE-115,22 Oct.1970, Section .D.1.3.

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6.5 Choi, R.J.," Development and Characterization of an Epithermal Beam for Boron Neutron i Capture Therapy at the MITR-II Research Reactor," Ph.D. Thesis, Nuclear Engineering Department, Massachusetts Institute of Technology, April 1991.

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