ML23220A401
| ML23220A401 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 08/08/2023 |
| From: | US Dept of Commerce, National Institute of Standards & Technology (NIST) |
| To: | Document Control Desk, Division of Fuel Management |
| Shared Package | |
| ML23221A162 | List: |
| References | |
| TAC L32643 | |
| Download: ML23220A401 (1) | |
Text
SNM - 362 Encl. 2 License Renewal Application 2023 Page 1 of 5 ENCLOSURE - 2: Requested Exemptions under 10 CFR 36.17 and 70.17.
Exemption License Condition (LC)12:
10 CFR 36.23(b), Requirement (b) In addition, each entrance to a radiation room at a panoramic irradiator must have an independent backup access control to detect personnel entry while the sources are exposed.
Detection of entry while the sources are exposed must cause the sources to return to their fully shielded position and must also activate a visible and audible alarm to make the individual entering the room aware of the hazard. The alarm must also alert at least one other individual who is onsite of the entry. That individual shall be trained on how to respond to the alarm and prepared to promptly render or summon assistance.
Exemption Request The NIST is requesting exemption from:
The alarm must also alert at least one other individual who is onsite of the entry.
That individual shall be trained on how to respond to the alarm and prepared to promptly render or summon assistance.
Rationale The Gamma IR facility (see Figure & Table 2-1 below) consists of a control room, maze, and irradiator room. Access to the irradiator room is restricted by two independent doors separated by the maze.
There are multiple safety interlocks and independent access control systems in place. They are as follows:
- 1) Three factor authentication access to the control room is restricted to a small subset of authorized personnel. This access control system notifies security staff of any inappropriate entry to the control room which would cause security staff to respond to the facility.
- 2) If the Experiment door is open, the source cannot be exposed.
- 3) When the source is exposed, the Experiment door is held in a mechanically locked configuration. It cannot be unlocked until the source is returned to its fully shielded position.
- 4) When the source is exposed, breaching either the Control/Maze Door or the Experiment door causes audible and visual alarms.
- 5) When the source is exposed, breaching either the Control/Maze Door or the Experiment door causes the irradiator shutter to return to its fully shielded position. Following this interrupt, the irradiator cannot expose the source until the doors are closed and the last man out (LMO) button is pressed.
The above compensatory safety measures are intended to provide a level of health and safety equivalent to the regulation for which the exemption is being requested. The facility construction and subsequent installation of the irradiator were previously approved under Amendments 9 (ML17306A976) and 11 (ML21126A114) respectively. Therefore, we request continued exemption to part of the requirements of 10 CFR 36.23(b).
SNM - 362 Encl. 2 License Renewal Application 2023 Page 2 of 5 Exemption LC13:
10 CFR 36.23(c), Requirement (c) A radiation monitor must be provided to detect the presence of high radiation levels in the radiation room of a panoramic irradiator before personnel entry. The monitor must be integrated with personnel access door locks to prevent room access when radiation levels are high.
Attempted personnel entry while the monitor measures high radiation levels, must activate the alarm described in paragraph (b) of this section. The monitor may be located in the entrance (normally referred to as the maze) but not in the direct radiation beam.
Exemption Request The NIST is requesting exemption from:
. . . must activate the alarm described in paragraph (b) of this section.
Rationale NIST is requesting the continuation of partial exemption from 10 CFR 36.23(b), LC12, which describes an alarm that is also mentioned in 10 CFR 36.23(c).
The Gamma IR facility (see Figure & Table 2-2 below) consists of a control room, maze, and irradiator room. In addition to the access controls and interlocks mentioned above, there are multiple independent redundant radiation safety indicator systems that detect the presence of high radiation levels in the irradiator room. There are two area radiation monitors ((ARM) #1 and ARM #2) located in the irradiator room. ARM #1 provides visible and audible alarms in the maze and Control Room when there is radiation present. A second independent radiation monitor, ARM #2, also located in the irradiator room, indicates the presence of radiation levels with a visible and audible alarms in the irradiator room and visual in the maze.
ARM #1 is also interlocked with the Experiment door and Control/Maze door to produce a visible and audible alarm when either the Experiment door or Control/Maze door is opened when the ARM #1 detects elevated radiation levels. ARM #2 locks the Experiment door and keeps it locked to prevent room access upon detection of elevated radiation levels.
The above compensatory safety measures are intended to provide a level of health and safety equivalent to the regulation for which the exemption is being requested. Therefore, we request continued exemption to part of the requirements of 10 CFR 36.23(c).
Exemption 15:
10 CFR 36.27(a), Requirement (a) The radiation room at a panoramic irradiator must have heat and smoke detectors. The detectors must activate an audible alarm. The alarm must be capable of alerting a person who is prepared to summon assistance promptly. The sources must automatically become fully shielded if a fire is detected.
Exemption Request The NIST is no longer requesting exemption.
SNM - 362 Encl. 2 License Renewal Application 2023 Page 3 of 5 Rationale The NIST meets this requirement.
Exemption 16:
10 CFR 36.27(b), Requirement (b) The radiation room at a panoramic irradiator must be equipped with a fire extinguishing system capable of extinguishing a fire without the entry of personnel into the room. The system for the radiation room must have a shut-off valve to control flooding into unrestricted areas.
Exemption Request The NIST is no longer requesting exemption.
Rationale The NIST meets this requirement.
Exemption 17:
10 CFR 36.31(a), Requirement (a) The mechanism that moves the sources of a panoramic irradiator must require a key to actuate. Actuation of the mechanism must cause an audible signal to indicate that the sources are leaving the shielded position. Only one key may be in use at any time, and only operators or facility management may possess it. The key must be attached to a portable radiation survey meter by a chain or cable. The lock for source control must be designed so that the key may not be removed if the sources are in an unshielded position. The door to the radiation room must require the same key.
Exemption Request The NIST is requesting exemption from:
The key must be attached to a portable radiation survey meter by a chain or cable.
Rationale The facility is designed so that the key that controls the Experiment Door connecting the irradiator and maze area is the same key that is used to enable the control panel that operates the irradiator. This key design ensures that the irradiator can only be operated if the key used to unlock the Experiment Door is inserted into the irradiator control panel. As a result, the doors cannot be opened if the irradiator is being operated and it is in the unshielded position (radiation present in the irradiator area) since the key that operates the door is captured at the console (cannot be removed). If the key is removed from the console the irradiator will return to the safe condition.
The NIST system for protecting against entry into a room with an exposed source is more effective than the key attached to a survey meter system described in 10 CFR 36.31(a).
Therefore, we request continued exemption to part of the requirements of 10 CFR 36.31(a).
SNM - 362 Encl. 2 License Renewal Application 2023 Page 4 of 5 Exemption 21:
10 CFR 70.24, Requirement
§ 70.24 Criticality accident requirements.
(a) Each licensee authorized to possess special nuclear material in a quantity exceeding 700 grams of contained uranium-235, 520 grams of uranium-233, 450 grams of plutonium, 1,500 (2) An exemption from § 70.24 held by a licensee who thereafter elects to comply with requirements of paragraph (b) of 10 CFR 50.68 does not exempt that licensee from complying with any of the requirements in § 50.68 but shall be ineffective so long as the licensee elects to comply with § 50.68.
Exemption Request The NIST is requesting continued exemption from: 10 CFR 70.24.
Rationale Most discrete SNM sources are below the NMMSS reporting mass. Those that exceed the NMMSS reporting mass are segregated into three reporting areas in three separate buildings.
The source acquisition approval process includes verification to limit source inventories at each use location, to ensure no single location can aggregate a critical mass of SNM.
NIST commits to adequate practices to ensure that no combination of fissile uranium and plutonium exceeding 80 wt% of a critical mass threshold value as specified in 10 CFR 150.11 shall be used or stored at any single location (building). Based on the low mass and form of the discrete sources, laboratory segregation, and inventory control processes, NIST requests continued exemption from the 10 CFR 70.24 requirements [as specified in § 70.17(a)] and previously granted by NRC (ML13207A265). These practices provide adequate assurance that the requirements of 10 CFR 70.22(a)(8) are met.
SNM - 362 Encl. 2 License Renewal Application 2023 Page 5 of 5 Figure 2-1 : Location of Alarms, Radiation Monitors & Controls (redacted)
Table 2-1: Quick Reference for Labels Shown in Figure 2-1 LMO Audio and Visible ARM Area Radiation Monitor LMO-Audi/Vis Alarm alarm High Radiation Alarm Beacon Smoke Smoke Detector Rotating Beacon ESB Emergency Safety Button TL Tower light Tower light connected Heat Heat Detector TL-ARM to ARM Tower light connected LMO Last Man Out TL-Shutter to shutter LMO-Control for starting the LMO Control sequence Button