Evolution of Accelerator Regulation - PowerPoint Presentation

1. Evolution of Accelerator RegulationA Brief and Incomplete History of the Regulation of DOE Accelerators September 10, 2019Frank KornegayFat Boy Consulting, IncSNS Operations Manager, retired

2. Accelerator Safety Order History and Rationale (brief summary)Prior to 1982, DOE Accelerator facilities were generally regulated under portions of Nuclear Safety Orders.Tiger Team reviews in 1990 and 1991 of National Laboratories identified gaps and inconsistency in regulation of accelerators.In 1991, a DOE/Contractor workshop was held; at the Workshop, the SLAC accelerator guide, originally developed for SLAC operations, was used as a starting point for formulating an accelerator-specific order. In 1992, DOE Order 5480.25 Safety of Accelerator Facilities was formally issued. The Order focused on the principles and core functions of an effective accelerator safety program. The Order included only the requirements that contributed to accelerator safety, and only requirements that were not addressed in other DOE Orders.

3. Some Important Features of 5480.25Defined “accelerator facility” as components used to accelerate, store, and collide particle beam as well as tunnels and other structures, shielding, and any experimental areas or enclosures. An accelerator was broadly defined as a machine capable of creating a radiological area.The Order required processes to provide protection equal to those applicable to nuclear facilities. These include:ARRs (independent verification of physical and administrative controls)SADs (documenting the hazards, controls, and risks of the facility)USIs (documenting modifications, or an event that had not been evaluated)The USI was to be used to maintain the SAD “up-to-date” without rewrites for each modification.

4. Additional features of 5480.25Recommended the use of a graded approach.Research activities, such as “test stands” did not require approvals or exemptions.Excluded commercial accelerators with built-in protective features.DOE Headquarters and Field Managers were required to approve an Accelerator Safety Envelope that bounds the activities and provides reasonable assurance that the risk was acceptable.The responsible DOE official had the inherent right to impose more stringent approval levels than called for within the Order.

5. 5480.25 became 420.2 in 1998The new designation emerged in the directive reordering programThe transition was direct, except:Three additional exclusionsnon-medical X-ray devices,low-voltage neutron generators, and DOE facilities where 5480.23 was already appliedEliminated the requirement for hazard classification of accelerator facilities

6. Evolution of 420.2In 2001, 420.2 was cancelled, and 420.2A was issuedExtended the Order to NNSA-at-DOE, or NNSA-owned or -leased facilitiesOrder renewed in 2004, became 420.2B on 7-23-2004Applicability was clarified to “accelerator facilities (accelerators and their operations) or modules thereof, including injectors, targets, beam dumps, detectors, experiments, experimental halls, etc.”In September 2004 an SC Workshop was held at Fermilab to update the Guide to 420.2-1 that supported 420.2B. Participants included SC, seven SC accelerator facilities, plus INEEL and LANL. The updated Guide was issued in 2005, following review in the DOE RevCom system.SC undertook a review of 420.2B; it was determined that the accelerator-specific safety requirements in other Directives were not adequate for DOE accelerator operations. The team found that the DOE standards for particle accelerators were appropriate and effective in providing a safe workplace and operating environment.The team recommended that 420.2B be revised to clarify roles and responsibilities and focus the Order on specific requirements for accelerators. Retention of the Order was the greatest overall benefit to the SC accelerator safety program. Following development of a new Order by a team of DOE, NNSA, and Contractor personnel, 420.2C was issued, and the Guide was updated.

7. SNS ExperienceJanuary, 1999 a Lehman Review was conducted on the proposed Spallation Neutron Source at ORNLThe design proposed a 1.4MW proton accelerator, with a mercury target producing neutrons for User FacilityThe mercury target would contain activities in excess of STD-1027 thresholdsThree potential regulatory schemes were identified:The entire facility treated as an Accelerator facilityThe entire facility treated as a Nuclear facilityThe facility spit into an accelerator and a Candidate Nuclear Facility targetThe Federal Project Director directed the ES&H manager to proposed option 2The Lehman Team strongly rejected that proposed, and suggested option 3, with a goal to clarifying requirements and regulate SNS as an Accelerator

8. SNS Early YearsSNS developed a SAR for the Target, clearly defined as the volume between the proton beam window and the neutron beam guides, plus the Target service bay.A SAD was developed for the balance of the facility, including the Accelerator, plus the Experimental Hall and all detectors.Documentation evolved in parallel, including annual updates until 2005;The SNS Project Execution Plan was modified by SC to regulate the entire facility under 420.2B in 2005. No changes in the Target facility were made, but the SAR was merged into the SAD, and commissioning and operations were conducted under 420.2B.Following a series of ARRs, all conducted under 420.2B, the SNS was successfully commissioned and met Project criteria in June, 2006.

9. DevelopmentsAugust 2006 Memo:To Edwin Wilmot, Manager Los Alamos Site OfficeFrom Bruce Diamond, Assistant General Counsel for Environment“Thus, Part 830 cannot be applied to accelerators, including accelerator targets, even if they meet the criteria of DOE-STD-1027-92.”

10. ClarificationNovember, 2008 memo from David Jonas, NNSA General Counsel“…, the above response from the DOE General Counsel staff makes it clear that 10CFR Part 830 is applicable to any nuclear activity or operation at an accelerator facility or site (e.g., technical Area 53 at Los Alamos National laboratory) that is not related to the accelerator or its operation.”

11. SummaryDOE Regulation of Accelerator facilities has evolved for the last 40 yearsA unique arrangement has existed between SC and the accelerator community, involving experts in the development of regulatory requirements, and shared expertise between facilities.As accelerators have advanced, becoming more complex and powerful, the DOE regulatory requirements have accommodated the hazards.Continued involvement by all parts of the accelerator community is a requirement for effective and efficient operations as well as appropriate regulations and oversight.