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OAC 3701:1-66-17 3701:1-68-05 understanding and compliance statements
February 2012
(A) OUAL understands that the Department considers us to be in compliance if we feel that we meet all requirements.
1. Operators will be trained to their level of intended use and will operate within their level of training.
2. This is and has been evidenced by existing and continued licensing.
3. The OU RSO is the IRRP.
4. We consider this to be the TALC.
5. This has been amended to ensure compliance with this rule.
6. Certificate has been issued.
(B)
1. In high radiation conditions the Radiation Monitor System will shut down the accelerator upon initial motion of shielding door towards open direction. This feature exceeds the requirement because shutdown happens before there is an opening in shielding and before there can be any barrier penetration. The Dock and Mechanical Room are not considered high radiation areas unless future surveys prove them to be otherwise.
2. The safety instrumentation, readouts and controls are easily identifiable and discernible.
3. The EMO and Radiation Monitor System are independent. Other independent interlocks for equipment protection are not subject to this rule.
4. We have great confidence in the safety provided by the original Shut-down Module and the process in which operators confirm its functionality at start-up. In addition to the original Shut-down Module we have added the following additional interlocks to the accelerator operation. A redundant independent shut-down relay must be energized by the lack of an accumulated dose greater than 20 mR to allow accelerator operation. The redundant independent shut-down relay must also be energized by the lack of a maximum dose rate of 100 mR/H signal to allow accelerator operation. If this relay fails, the accelerator will shut-down. This arrangement gives backup shut-down mechanisms for both accumulated maximum dose shut-down and also maximum dose rate shut-down. An additional circuit to detect the maximum dose rate has also been implemented as a backup for the maximum dose rate detection electronics that will shut down the accelerator at a dose rate of 160 mR/H in the event the 100 mR/H detection system would fail. If the radiation monitor or the shut-down module do not have mains power applied the accelerator will shut-down. The accelerator will also shut-down if the interconnect cable between the radiation monitor and Shut-down module is removed.
5. We consider this requirement to be met by having to ensure that a door interlock is properly engaged after a shutdown by the Radiation Monitor System, or by having to reset the EMO button in that type of shutdown. We exceed this requirement by the fact that the ACPC in the Vault must be reset after any type of shutdown.
6. We developed a beam warning system that is initiated by LE cup action in order to meet this requirement. In high radiation conditions the cup action is delayed 15 seconds.
7. Yes
8. The existing flashing red light system meets this. The existing startup claxon exceeds this.
9. Our maximum possible condition is high radiation. Very high radiation and airborne radiation definitions do not apply. The LTR, STR, and Vault doors are posted with high rad signs that are only visible when the doors are closed.
10. At least one compliant EMO has been installed in each high rad area.
(C)
1. Grandfathered
2. Grandfathered
3. OU RSO has this authority
4. This is N/A in all nominal conditions
5. RSO has determined that we do not have enough material to trigger this requirement
(D)
1. The control room is part of a secured area which is only accessible by trained and qualified personnel.
2. Operators are trained for this requirement by the Interlock Rules in the Testing, Calibration, and Shutdown Book.
3. Policy governing this requirement is found in the Testing, Calibration, and Shutdown Book. Results of tests are found in the the same book. Failures are addressed by the Interlock Rules in the same policy.
4. The Shutdown/Interlock Handbook meets this
5. The Operating Procedures and Emergency Procedures books meet this
6. The Interlock Rules in the Testing, Calibration, and Shutdown Book contain this requirement. 7.
a. The Designated Operator will have a Direct Reading Dosimeter (DRD). Transfer of the DRD is part of the shift change procedure in the Ops book.
b. We consider that the film badges meet this
(E)
1. We have appropriate portable detectors for the facility. Personnel are trained in the use of these detectors as part of the radiation safety orientation. We consider the prior to use checkout process to meet the daily test requirement. Our calibration process meets this requirement and the results are located in the Testing, Calibration, and Shutdown book.
2. This will be done if any such changes ever arise
3. We do not create any airborne particulates
4. This is our Radiation Monitor System
5. The OU RSO conducts surveys in accordance with the Radiation Safety Handbook
6. These items will all be found in the Testing, Calibration, and Shutdown book
7. This process is addressed in the Radiation Safety Handbook and part of the Radiation Safety Orientation provided by the OU RSO.
(F)
1.
a. All sections of Appendix A are addressed in the Operator 1 training flow
b. Source material located in the Training Flow & Documentation Book, or in the electronic handbook (wiki) c. Source material located in Operating Procedures and Emergency Procedures books
2. Operator 1 certification will meet this requirement. OU RSO will have final approval of all Operator 1 certifications. Each required document will be available in any one of six control room books.
