ASO Revision Key Discussion Topics

1. ASO Revision Key Discussion Topics Session A and Session B Follow-up

2. Recap • 37 individual contributors yesterday • Good, constructive dialogue • Which demonstrates broad ownership • General consensus on the path • No show stoppers • Many direct improvements suggested to text • Good ideas for the remaining issues

3. Equivalencies/Exemptions • 835 • General acceptance of proposed expansion • Clean up coordination with NCRP/ANSI exclusions • Specific questions • i.e. portable; singly <10 MeV, but together above • Not trying to identify all cases; just provide better guidance • 830 • Common interpretation and understanding of exemption • Need to address: • Criticality

4. 420.2C Non-complex facilities with local work area impacts only and managed under 10 CFR 835, for example: Radiation generating devices A room-sized accelerator with a single external/extractable beam, an active safety system, and a single point of entry into the room X-ray or neutron generators that are bench top in size and that have a single external/extractable beam and a single operator such as those identified in ANS43.3 and NCRP 72. Unmodified commercially available units that are designed for industrial applications, including but not limited to, electron microscopes, ion implant devices, and x-ray generators. 835/ASONeed better coordination 420.2C • Nonmedical x-ray devices with the capability of accelerating electrons to energies not greater than 10 MeV, which are operated in accordance with American National Standards Institute (ANSI) N43.3-2008, General Radiation Safety Standard for Installations Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies Up to 10 MeV, or in accordance with another applicable consensus standard as directed by the cognizant DOE field manager. • Low-voltage neutron generators, which are operated in accordance with National Council on Radiation Protection and Measurements (NCRP) Report 72-1983, Radiation Protection and Measurements for Low-Voltage Neutron Generators, or in accordance with another applicable consensus standard as directed by the cognizant DOE/NNSA field manager.

5. 830 – ASO (I) • Accelerators are not non-reactor nuclear facilities • Excluded from 830 requirements via this route • However, may still be a reactor nuclear facility • This is what drives language on criticality • If there is a “potential for criticality,” then the facility is no longer an accelerator and it becomes a reactor • Other regulations must apply • How to properly define this threshold still needs work • Definition or Exclusion? (Ceiling vs. floor) • Configuration • Beam induced • Probability/Potential • Linkage to 830 definition

6. 830 – ASO (II) • Accelerators are not non-reactor nuclear facilities • Excluded from 830 requirements via this route • Cannot allow a gap between regulations/orders • How to make sure that proper analysis/controls are in place for accelerators with significant quantities of radiological material but below limit for nuclear material (less than criticality) • Assert that: • SAD/ASE framework allows for (in fact directs) this • Contractual flexibility allows for application of other ‘directives’ • Can be accomplished on a facility-by-facility basis • No need or value with specifying language in Order • Is language needed to ‘allow’ DOE to impose additional contractual requirements?

7. Responsibilities • Clarify: • Exemptions/equivalencies at Field Office level • Start-ups after DOE-imposed shut-downs • Linkage to requirements/definitions • Threshold • Eliminate chemical threshold

8. Oversee the safe operation of accelerator facilities…. (2) Approve items listed in 5.b.(2)(a) and (f) for accelerator facilities where site boundary consequences for credible postulated accident scenarios that potentially exceed 1 rem (0.01 Sv) and/or ERPG-2 (3) Grant equivalencies or exemptions from the requirements of this Order, unless otherwise specified in this DOE Directive Ensure the safe operation of accelerator facilities…. Except as provided in Section 5.a.(2), approves the following activities: ASE Start of commissioning activities after ensure that an appropriate ARR has been conducted Start of routine operations Restart of an accelerator facility after a DOE-ordered shutdown because of an unreviewed safety issue or ASE violation Decommissioning activities Equivalence/exemption requests Responsibilities Section 5 (a) PSOs Section 5 (b) Field elements

9. Definitions • Accelerator Facility • Roads; need to consider • ASE • Credited Control – OK • Need to define • Readily verifiable; need to consider • Identifiable, definitive, understood, etc.? • Guide or Order? • Criticality • Beam-induced to emphasize self-sustaining; emphasize configuration

10. USI • the determination that there is a significant increase in the probability of or consequences from of a previously analyzed postulated accident or of a new, previously un-analyzed postulated accident that could result in a significant adverse consequence. This determination is part of a structured process to identify and evaluate whether planned or as-found conditions, equipment, or processes may exceed the bounds of an accelerator’s ASE. Activities that exceed the bounds of the ASE must not be performed until restart is approved by DOE. • the determination that there is a significant increase in the probability of or consequences from 1) a previously analyzed postulated accident or condition or 2) a planned modification that creates a previously un-analyzed postulated accident or condition that could result in a significant adverse consequence.

11. Session B Summary - E. Lessard • Key Points • Accelerators include all systems, components and activities that are bounded by the safety analysis and controls in the SAD and credited controls in the ASE • Accelerators are not a reactor unless capable of criticality due to configuration of materials (not theoretically possible criticality)

12. Session B Summary • Terms defined in draft Order so that it can stand alone: • Accelerator • Accelerator Facility • Accelerator Operations • Accelerator Readiness Review • Accelerator Safety Envelope • Commissioning • Criticality • Hazard Analysis • Safety Assessment Document • Unreviewed Safety Issue

13. Session B Summary • Terms not defined in draft Order but found in DOE G 420.2-1, Accelerator Facility Safety Implementation Guide • ASE Limit • Authorized Alternative • Credited Control • Credited Administrative Control • Credited Engineering Control • Maximum Credible Incident • Standard Industrial Hazard • Safety Analysis

14. Summary Session B • Suggestions for Draft Order Definitions: • Commissioning should be defined clearly to indicate it is a two step process • Credited Control should be added to the draft Order • Hazard Analysis should be renamed Safety Analysis, which agrees with current Guide; need to rename it in definition of SAD too • Incorporate/add S. El-Safwany’s definition of Hazard Analysis • In USI definition, change “Activities that exceed the bounds…” to “Planned activities that exceed the bounds…

15. Summary Session B • Suggestions for future revised Guide: • Consider adding and defining a term: Special Administrative Control • Reword Credited Engineering Control to indicate “necessary” safety function rather than “particular” safety function • Consider adding “Minimum Operable Equipment” term as defined by LANL • Consider elaborating on “essential” in revised Guide for: Credited Controls means controls determined through hazard evaluation to be essential for safe operation directly related to the protection of personnel or the environment

16. The End • We like our terminology; its specific and aimed at unique accelerator hazards and controls • We find the Accelerator Safety Order to be effective and practical • Suggestions: • Document differences between accelerator and nuclear facilities in appendix to future Guide • Document “less than criticality” examples in future Guide