View source for IA-88-514, Forwards Summary of 870224 Meeting on Large Irradiators. Provides Guidance on Licensing of Large Irradiators & as Supplementary Ref Document to Std Review Plan for Applications for Licenses for Use of Different Irradiators

{{Adams
| number = ML20196E897
| issue date = 09/19/1988
| title = Forwards Summary of 870224 Meeting on Large Irradiators. Provides Guidance on Licensing of Large Irradiators & as Supplementary Ref Document to Std Review Plan for Applications for Licenses for Use of Different Irradiators
| author name = Lubenau J
| author affiliation = NRC OFFICE OF GOVERNMENTAL &amp; PUBLIC AFFAIRS (GPA)
| addressee name = 
| addressee affiliation = AFFILIATION NOT ASSIGNED
| docket = 
| license number = 
| contact person = 
| case reference number = FOIA-88-514
| document report number = NUDOCS 8812120128
| package number = ML20150E008
| document type = CORRESPONDENCE-LETTERS, NRC TO STATE/LOCAL GOVERNMENT, OUTGOING CORRESPONDENCE
| page count = 8
}}

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ALL AGREEMENT STATES                                                               .
GUIDANCE ON LARGE IRRADIATOR APPLICATIONS Enclosed for your infonnation is the summary of Meeting on large Irradiators held February 24, 1987.                This document provides infonnal general guidance on the 11ansing of large irradiators. You may find this useful as a supplementary reference document to the Standard Review Plan For Applications For Licenses For the Use of Panoramic Dry Source-Storage Irradiators, Self-Contained Wet Source-Storage Irradiators, and Panoramic Wet Source-Storage Irradiators.                                Please note that this is informal guidance and does not have NRC management approval.
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                                                                                                                          't s 1 0. Lubenau Acting Assistant Director for State Agreements Program State, local and Indian Tribe Programs

==Enclosure:==

As stated I
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ENCLOSURE
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==SUMMARY==
OF MEETING ON LARGE IRRADIATORS FEBRUARY 24, 1987 - HEADQUARTERS.
Attendees:        John Hickey, NMSS                Lloyd Bolling, SP Tom Clark, NMSS                  John Glenn, Region I John Roberts, NMSS               Earl Wright, Region II Kathy Black, AE00                Bill Axelson, Region III Bruce Carrico, NMSS              Jack Whitten, Region IV Al Roecklein, RES BACKGROUND During the January 1987 Executive Seminar in Region V, it was agreed to give high priority to review and improvement of our regulatory requirements for large irradiators. This has been a staff concern for several years. The February 24 meeting was scheduled to initiate concrete action. This document summarizes the consensus of the meeting attendees. NRC management has not yet necessarily concurred in the recommendations.

==GENERAL COMMENT==
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: 1. The meeting attendees agreed that license reviewers and inspectors should examine several safety aspects of irradiators more comprehensively, and that this comprehensive review should begin immediately. New procedures could be implemented by issuing interim guidance to license reviewers and inspectors. Licensees and potential applicants could be put on notice by an Information Notice and Federal Register notice.
: 2. Attendees agreed that a comprehensive regulation should be developed for large irradiators, similar to 10 CFR Part 34 for radiography.
: 3. NRC should discuss planned irradiators with applicants before construction begins. However, the regulations do not currently require this. Pending development of a new regulation, we should try to improve communications so that we can discuss planned irradiators with potential applicants whenever possible.
: 4. The attendees agreed that the planned revision to 10 CFR Part 20 should be at least as stringent as the current Part 20 with respect to safety requirements for irradiators.      However, the current regulation is somewhat difficult to interpret and implement, so revision and clarification is appropriate.                  .
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: 5. The regulatory requirements of 10 CFR Part 72 (spent fuel storage) were discussed as they might be adapted to large irradiators.
: 6. It was agreed that ANSI Standard N43.10 applicable to large irradiators, is a good reference for developing improved guidance on most areas of safety concern. ANSI /ANS 2.19, applicable to siting of spent fuel storage facilities, is also a good background document.
SPECIFIC ISSUES
: 7. Siting criteria - The meeting attendees did not id'entify the need for generic site prohibitions. However, the group agreed that irradiators should be designed to take into account the risk at a given s'ite of external hazards such as earthquakes, floods, and projectiles. It was recommended that the Uniform Building Code is a good reference addressing these issues.                                                                  ,
The following specific hazards were also discussed:
: a. Earthouakes - Seismic criteria for reactors and spent fuel facilities were discussed; these criteria are difficult to apply directly to irradiators. It was agreed that seismic risk should be evaluated for all irradiators. Irradiators east of the Rocky Mountains should normally be designed to withstand a seismic event in the range of 0.1-0.2 g. Irradiators west of the Rocky Mountains should be designed for a stronger seismic event if the site analysis so indicates. All irradiators should be designed to shut down automatically when a significant earthquake occurs, i
'               b. F_loods - The design basis flood for a given site should be determined, and the irradiator should be designed to withsta.4 such a flood,
: c. Tornados, projectiles - There was general agr'tement that special consideration need not be given to the risk of tornados or projectiles, provided that the irradiator is constructed of reinforced concrete i
and generally follows the Uniform Building Code. This is because the storage pools for irradiators would be at minimal risk.
Airports - There was a general feeling that locating an irradiator d.
near an airport would not increase risk significantly, but it was agreed that the issue should be studied further,
: e. Hazardous facilities - Consideration should be given to the proximity of known facilities or traffic which could cause an explosion or similar hazard. However, no specific criteria was discussed.
: 8. Desian C-iteria
: a. Foundation - The foundation soil should be analyzed, and the founda-tion appropriately designed to take into account soil stability.
The applicant should evaluate the consequences of a water leak and identify the nearest groundwater which is a public water supply.
: b.
* Pool liner - Irradiators should have a watertight, stainless steel pool liner. Systems to detect or divert and collect leaking water are desirable, but not mandatory.
: c. Shieldina - Shielding should be high density, reinforced concrete.
  . d. Water Control Water vol we should be monitored for high level, low levei, and excess makeup. A significant water problera should a'utomatically activate safety interlocks.
Water should be monitored for radioactive contamination by periodic grab samples (at least semi-annually and after pool cleaning), as well as monitoring filters for contamination buildup. The water processing systwm should automatically shut down if excess contamina-tion is present. Radiation shielding of filters should also be considered. Residue on bottom of pool should be checked annually and after any pool cleaning.
Corrosive agents such as chlorides in water should be minimized.
This can usually be achieved by controlling conductivity and/or pH.
Water temperature should be monitored and controlled. Air humidity should be controlled.
Liquid effluents to unrestricted areas should be monitored if they could contain contamination from a leaking source,
: e. Power Supply / Power Failure An external power failure should automatically shut down the irrarite-tor unless full emergency power is available for all s~&tety-relateu systems.
Emergency powcr should be installed as necessary for radiation monitors and other systems necessary to monitor the condition of the facility.
If an external power failure exceeds a specified period (for exemple, 24 hours), the facility should be shut down until NRC authorizes restart.
: f. Source Mechanism The applicant should evaluate the consequences of an emergency or accidental source rack drop (for example, power failure or broken cable).
The source rack should not require power to drop in the event of a power failure.
The rack should be designed so that sources will not be damaged during an emergency drop. Shock absorbers should be considered.
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: g. Cesium Sources The safety analysis of Department of Energy Waste Encapsulation Storage Facility (WESF) cesium capsules should be reviewed with respect to expected results in a fire or accidental source drop.
: h. Fire protection Irradiators should have a fire detection system, int:luding water and air temperature menitors. The presence of a fire h i dl autcmatically shut down the irradiator.
Irradiators should have a fine suppression system which is automatic or can be activated manually in accordance with a clear emergency procedure.
: i. Computers.
Computer systems should not have capability to override safety inter-locks. Interlocks should be "hard wired."
: j. Access Controls Access interlocks shod d comply with 10 CFR 20.203. The applicant should provice a logic diagram of his safety systems which specifies:
(1) what conditions have to exist before the source can be raised, (2) what conditions have to exist before a person can enter the irradiator room, (3) what events cause the source to drop automatica ally, (4) how the source position is monitored, and (5) which safety system failures will dictate that the irradiator remain shut down until repairs are completed.
Safety-related peripheral areas such as the electrical systems should be designed such that access can.be prevented or controlled.
: k. Resistance to high radiation Performance in high radiation of equipment inside the irradiation room should be considered. Lubricants are susceptible to high radiation damage.
: 1. Corrosion Susceptibility of equipment to corrosion (water, humidity, ozone) should be considered,
: s. Ventilation Ventilation should be upropriate to control temperature, humidity, ozone, and hazardous g ues. The exhaust vent should not be near the intake for another butiding.
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: n. Carrier Screen A physical barrier should protect the sourca rack from interference by passing products. Product carriers should be maintained to avoid jamming incidents.
  ,                   For irradiators which irradiate products in water, procedures should ensure that products will not be dropped on the source rack,
: o. Radiation Monitors Permanent radiation monitors should be installed in the personnel maze and the product carrier exit.
A requirement for a very high radiation monitor in the irradiation room itself needs to be reviewed.
The supplemental use of audible, portable instruments is desirable.
: p. Decommissioning - The irradiator design should anticipate eventual decommissioning,
: q. Visual Monitorina - There was general agreement that visual monitoring equipment is not necessary.
: 9.       Quality Control The applicant should have a quality control staff and comprehensive quality control program. The program should monitor construction of the facility, and include the concrete foundation and shielding, pool liner welds and leak testing, safety-related construction and equipment materials, and computer software.
!              Source rack cable should be "pre-stretched" and tested for strength.
: 10.      NRC Inspections I
Prior to licensing, NRC should, if possible, discuss a proposed irradiator with the applicant and perform construction inspections (see Manual Chapter 2815). The inspection and licensing staff should try to obtain 3 schedule from the applicant and discuss potential siting, design, and quality controi issues. Technical assistance should be requested from l              other NRC offices as appropriate.
Routine inspections should cover access control, radiation surveys, pool water quality, radiation monitors, fire protection systems, loss of power tests, and interlock tests (see draft Manual Chapter 2816, distributed for comment on February 12, 1987).
I'1. Operating and Maintenance Procedures Irradiators should have safety procedures covering the ivilowing:
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Periodic checks of all safety-relater equipment at specified frequencies.
Loading or removal of souhh.      (RSO should be physically present.)
Transportation requirements.
Exclusionofhighlyflammableandexplosivematerial'(flashpoint less than 140 F).
  ,                  Maintenance of water quality and water levels.
Calibration and operability of all radiation monitors.
Inspection of hoist mechanism, cables, and totes.
Operation of all radiation alarms and water le' vel controls and alarms.
Periodic prol cleaning.
Checks for corrosion and need for lubrication.                .
Checks for radiation damage in irradiation cell.
Maintenance of records "as built" drawings for reference.
Maintenance of records of safety and equipment checks.
The operating and maintenance procedures should specify action levels, what corrective action should be taken, and whether the irradiator must be shut down pending corrective action. Where redundant safety systems exist, it should be specified which items can fail and be repaired with-out the irradiator being shut down.
: 12. Authorized Users
              .ie applicant should identify the RSO and an alte.nate. The RSO.should have substantial health physics background. Authorized users should have 40 hours of formal training plus 90 days on-the-job training. Records should be saintained identifying authorized user.s and their training.
Concern was expressed about assuring adequate training of operators.          The fatal irradiator accident in Norway was discussed.
If the irradiator shuts down due to an emergency, the RSO should be present if the irradiation room is entered and when the irradiator is restarted.
All workers should wear personnel monitoring and have ajdible, portable monitors available.
It was suggested that NRC may want to make training materials available regarding potential hazards, as has been done for radiography.
: 13. Security Control of access to the facility should be established by administrative l          controls and alarms, t
: 14. Continaency Plans The t.pplicant should have contingency plans for the following events:
Radiation overexposure '
Stuck source rack 6

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Automatic shut down Fire Source in product carrier
     ,                      Leaking source (prior arrangements should be made for availability of shipping cask)
Water leak Interlock or radiation monitor failure Power failure The RSO should immediately report to the facility if an emergency occurs.
Prior arrangements should be made with hospitals for possible treatment of an exposed or contaminated victim.
* Prior arrangements should be made with fire and police officials, particu-larly with respect to staying out of the irradiator room.                      .
It was agreed that if a source leak occurs, the facility should be shut down and completely decontaminated before restart. Also, the groundwater should be monitored for contamination.
: 15. Administrative Potential applicants should be encouraged to notify early NRC and local governments of planned irradiators.      NRC should discuss a planned facility with the local government if the applicant does not.
: 16. Records                                                                                     j Licensees should maintain records of:
                            "As built" drawings of the facility. Authorized users and their training. Operating, maintenance, and emergency procedures.
: 17. Part 20 The new Part 20 should be at least as strict as the current Part 20.
However, it should be clarified as follows:
l Access controls should be physical barriers, not merely alarms or passive interlocks.
The requirements should apply to potential access points as well as normal personnel entrances.
An authorized user should be physically present whan the irradiator is operating, in order to respond to any' emergency.
The irradiator must be shut down if repairs are required for the safety systems, f
The time required for the source to drop needs to be considered.
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