NUREG-1601, Informs of Submittal of NUREG-1601,w/guidance on Chemical Process Safety at Fuel Cycle Facilities, Which Addresses Chemical Safety Issues Relevant to Fuel Cycle Facilities,As Pertaining to Performance of Integrated Safety Analysis
| ML20210U910 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1997 |
| From: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Gingrich N, Gore A, Murphy R GENERAL ACCOUNTING OFFICE, HOUSE OF REP., SPEAKER OF THE HOUSE, SENATE, PRESIDENT OF THE SENATE |
| References | |
| RTR-NUREG-1601 CCS, NUDOCS 9709220139 | |
| Download: ML20210U910 (4) | |
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.g - k UNITED STATES
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August 22, 1997 The Honorable Al Gore President of the United States Senate Washington, DC 20510
Dear Mr. President:
Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 1996 5 U.S.C. 801, the Nuclear Regulatory Commission is submitting NUREG 1601, with guidance on ' Chemical Process Safety at Fuel Cycle Facilities," which addresses chemical safety issues relevant to fuel cycle facilities, as they pertain to the performance of an integrated safety antlysis. NUREG-1601 is not a substitute for the regulations, and compliance is not a requirement. It describes a general philosophy of the role of chemical process safety regarding NRC-licensed material.
We have determined that this NUREG report is not a " major rule,' as defined in 5 U.S.C.
804(2). We have confirmed this determination with the Office of Management and Budget.
Enclosed is a copy of NUREG 1601, ' Chemical Process Safety at Fuel Cycle Facilities,' which is being transmitted to the Office of the Federal Register, for publication. It is intended to provide examples, which are net exhaustive, for addressing chemical process safety regarding the safe storage, handling, and processing of licensed nuclear material.
Sincerely,, g h AG LLL.
Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
NUREG 1601 1['O.}26 I 9709220139 970822 PDR NUREO PDR ILE EII,Ijll,Epill
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The Honorable Newt Gingrich Speaker of the United States House of Representatives i Washington, DC 20515
Dear Mr. Speaker:
Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 1996, 5 U.S.C 801, the Nuclear Regulatory Commission is submitting NUREG 1601, with guidance on ' Chemical Process Safety at Fuel Cycle Facilities,' which addresses chemical safety issues relevant to fuel cycle facilities, as they pertain to the performance of an integrated safety analysis. NUREG 1601 is not a substitute for the regulations, and compilance is not a requirement. It describes a general philosophy of the role of chemical process safety regarding NRC-licensed material.
We have detcrmined that this NUREG report is not a " major rule," as defined in 5 U.S.C.
804(2). We have confirmed this determination with the Office of Management and Budget.
Enclosed is a copy of NUREG 1601, ' Chemical Process Safety at Fuel Cycle Facilities," which is being transmitted to the Office of the Federal Register, for publication. It is intended to i provide examp!es, which are not exhaustive, for addressing chemical process safety regarding
- the safe storage, handling, and processing of licensed nuclear material.
Sincerely, G L-
,@$v Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
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August 22, 1997 Mr. Robert P. Murphy General Counsel General Accounting Office Room 7175 ,
441 G Street, NW Washington, DC 20548 Dear Mr. Murphy; Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 1996, 5 U.S.C. 801, the Nuclear Regulatory Commission is submitting NUREG 1601, with guidanca on ' Chemical Process Safety at Fuel Cycle Facilities," which addresses chemical safety issue
- Imevant to fuel cycle facilities, as they pertain to the performance of an integrated safety analysis. NUREG 1601 is not a substitute for the regulations, and compliance is not a requirement. It describes a general philosophy of the role of chemical process safety regarding NRC-licensed material.
We have determined that this NUREG report is not a " major rule,' as defined in 5 U.S.C.
804(2). We have confirmed this determination with the Office of Management and Budget.
Enclosed is a copy of NUREG 1601, " Chemical Process Safety at Fuel Cycle Facilities," which is being transmitted to the Office of the Federal Register, for publication, it is intended to provide examples, which are not exhaustive, for addressing chemical process safety regarding the safe storage, handling, and processing of licensed nuclear material.
Sincerely, gwc.t U4<--
W Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
CONGRESE10NAL CURRESPONDENCE SYSTEM DOCUMENT PREPARARON CilECRllST 1his check list is to.be submitted with each document (or gmy of Qs/As) sentforprocessing '
lato the CCS.
- 1. BR1EF DESGIPTION OF DOCUMENT (S) A< %
- 2. TYPE OF DOCUMENT X CORRESPONDENG HE4 RINGS (Qs/As)
- 3. DOCUMENT CONTROL _, SENSITIVE (NRC ONLY) X NON-SENSITIVE
- 4. CONGkESSIONAL COMMITIEE AND SUBCOMMITIEE ((f applicable)
Congressional Committee Subcommittee
- 5. SUBIECT CODES (A)
(B)
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(B) SC4N (C) ATTACHMENTS (D) OTHER
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- COMMENTS:
RELEASE TO PDR ,
- m. . . ,
NUREG-1601 Chemical Process Safety at Fuel Cycle Facilities 4
U.S. Nuclear Regulatory Commission Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 0001 David A. Ayres s
NUREG 1601 is being issued to provide broad guidance on chemical safety, it describes an approach acceptable to NRC staff, although the examples offered are not exhaustive.
NUREG-1601 is not a substitute for the regulations, and compliance is not a requirement.
This guidance document describes a general philosophy of the role of chemical process safety with respect to NRC licensed material.
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. ABSTRACT This NUREG provides broad guidance cn chemical safety issues relevant to fuel cycle facilities.
It describes an approach acceptable to the NRC staff, with examp'es that are not exhaustive, for addressing chemical prucess safety in the safe storage, handling, and processing of licensed nuclear material. It expounds to license holders and applicants a general philosophy of the role of chemical process safety with respect to NRC-licensed materials; sets forth the basic information needed to properly evaluate chemical process safety; and desenbes plausible methods of identifying and evaluating chemical hazards and assessing the adequacy of the chemical safety of the proposed equipment and facilities. Examples of equipmcnt and methods commonly used to prevent and/or mitigate the consequences of chemicalincidents are discussed in this document.
ii
t CONTENTS Page ABSTRACT ....... ..... .............................................il ACVNOWL.EDGMENTS .. ....... . ... ....... . .......... . . . . . . . . iv
- 1. I N TRO D U C T I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
- 2. D I S C U S S I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 Chernical Process information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ .3 2.1.2 Au xilia ry S yste m s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.1.3 Specialty Chemical Data .....................................5
- 2. 2 H az a rd Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ..... .5 2.2.1 S yste m R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.3 Identification of the Hazards ........................... .. .......... .6 2.3.1 Potentia! Accident Scenarios . . . . . . . . . . . ....... ....... .. ..... 6
- 2. 3.2. Instruments and Control Functions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.4 Design Basis . . . . . . . . . . . . . . . . . . . . . ....... ............. ....... 7 2.4.1 Physical Bamers ... .......... .............. .... ... .8 2.4.2 Mitigative Fe ature s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 2.5 Hazard Evaluation . . . . . . ..................................... . . .10 2.5.1 Methods ............................. .............. ... 10 2.5.2 Results ........................... . .................... 10 2.6 Continuing Assurance of Chemical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 2.6.1 Management Structure and Concepts . . . . ............... .......11 2.6.2 Procedures ....... ..................................11 2.6.3 Training . . . . ..... . . . ...... ...... .... . .... . 11 2.6.4 Maintenance . . . . . . . . . . . . . . . ............ . .... ... ..... 12 2.6.5 Configuration Management ............... ........ .... . 12 2.6.6 Emergency Planning . . . . . . . ... .................. .....,. 13
'2.6.7 incident Investigations ano Corrective Actions . . . . . . . . . .... . 13 2.6.8 Audits and Assessments . . ........................ ......... 13 2.6.9 Quality Assurance ..... . ... ............... ........ 14 2.6.10 Human Factors Program . . . . . . . . .. ...... .. .. .... .. . 15
- 3. REFERENCES. . ..... .... .. ........ ................ ............. 16 iii NUREG-1601
ACKNOWLEDGMENTS The author acknowledges and appreciates the contnbutions to this document from Dr. Lidia Roch6, Barry Mendelsohn, Robert Pierson, Donald Stout, Leslie Fields, William Troskoski, Garrett Smith, Dr. Richard Milstein, Dr. Tin Mo, Richard Cassano, Thomas Cox, and Michael Weber, all from the Office of Nuclear Material Safety and Safeguards at NRC Headquarters.
iv NUREG-1601
e 9
. 1. INTRODUCTION The issuance and continuance of specific licenses for activities involving source and special nuclear materials require that the applicant's proposed procedures, equipment, and facilities b) adequete to protect health and minimize danger to life or property in accordance with 10 CFR 40.32(c) and 70.23(a)(3) and (4),
To protect nsalth and minimize danger, the applicant should address all hazards of nuclear material, including chemical hazards posed Ly radioactive materials, _
chemicals, and pisnt conditions which may directly or indirectly Ef fect the licensed nuclear materialin an adverse manner.
According to the October 21.1988, Memorandum of Understanding (MOU) between NRC and the Occupational Scfety and Health Administration (OSHA), the regulation of these hazards is the responsibility of NRC. Also,10 CFR 76.87 requires gaseous diffusion enrichment plants to establish procedures and/or equipment to address chemical safety.
Performing an adequate analysis of chemical safety in processing licensed material at fuel cycle facilities decreases the potential for radiological and nonradiological exposures to workers and the public and minimizes releases to the environment.
This report highlights the importance of chemical process safety at facilities where licensees handle, process, and store nuclear materials. It provides broad guidance on chemical process safety issues at such facilities and discusses methods of preventing or mitigating the consequences of chemicalincidents.
- 2. DISCUSSION Most NRC fuel cycle licensees possess public and worker safety, but also with (neir materials that are chemiMy hazardous e*fect on safe operations, regardless of the and/or pose some sort of nonradiological total amount of the chemicals onsite. The nsk. Chemical and radiological risks have MOU between NRC and OSHA on chemical been known to compound one another, and safety issues makes provision for the NRC in rnany cases, radioactive materials are to assume responsibility for the control of also chemically hazardous. A chemical risks which may affect radioactive materials.
explosion in a fuel cycle facility could Faragraph 3 of the MOU states:
disperse radioactive material, just as the radiation environment could make it more There are four kinds of hazards difficult to respond to a hazardous chemical that may be associated with NRC-spill. Thus, chemical process safety plays a licensed nuclear facilities.
major role in the proper operation of nuclear fuel cycle facilities. Virtually all processes a. Radiation risk produced by of source and special nuclear materials use radioactive materials; chemicals which can be considered hazardous or potentially hazardous under b. Chemical risk produced by certain conditiens. radioactive material; For the purpose of this document, c. Plant conditions which affect hazbrdous chemicals are substances which the safety of radio 3ctive are toxic, explosive, flammable, corrosive, materia': and thus present an or reactive to the extent that they can cause increat ed radiation risk to significant damage to property or endanger workers. For example, these life if not adequately controlled. Some of might produce a fire or an the more common hazardous chemicals explosion, and thereby cause used in nuclear fuel cycle facilities are a release of radioactive uranium hexafluoride (UF.), strong acids, materials or an unsafe reactor ammonia, and hydrogen. Additionally, condition; and systems containing substances which are not normally considered hazardous under d. Plant conditions which result ambient conditions may, under extreme in an occupational nsk, but do conditions or in combination with other not affect the safety of chemicals, produce hazardous situations. licensed radioactive materials.
These substances include hot water, steam For example, there might be and cryogenic or compressed gases such exposure to toxic as air, nitrogen, and carbon dioxide, nonradioactive materials and other industrial hazards in the Many hazardous chemicals are also workplace.
regulated by other agencies, but mainly in the prevention of catastrophic events or Generally, NRC deals with the first three major releases to the environment. This hazards listed in paragraph 3 (a, b, and c),
regulation of hazardous chemicals is based and OSHA deals with the fourth hazard (d).
on threshold limits. The NRC's concern is not only with the effect of the chemicals on 2 NUREG 1601 l
The risks covered by NRC include those the equipment to be used, and destinations posed directly by radioactive chemicals, of outputs and effluents.
such as with UF., and any other condition which may directly or indirectly affect 2.1.1.2 Material Form radiation risk to workers or the environment.
Thus the NRC does not regulate chemicals The process description should include the per se, rather, the NRC venfies that the chemical and physical form (s) of the interactions of chemicals with NRC licensed licensed material at each process step. It nuclear materials and/or with equipment should include inputs, outputs, and any which processes, transports, or stores intermediary transformations occurring at these licensed materials have been each step.
considered in the design of the equipment and facilities and in the operating and 2.1.1.3 Process Chemicals maintenance procedures. Such interactions may cause degradation of equipment, loss The process description should include a of confinement, and misdirection of licensed list of all chemicals input to each process materials, resulting in potential danger to step, specifying which ones are to be in workers, the public, and the environment. contact with the licensed materials and which chemicals could potentially contact 2.1 Chemical Process information licensed materials in case of leaks or human error.
Safety of chemical processing of nuclear materials depends largely on the 2.1.1.4 Process Variables information available about the process and about the chemicals used in the process The process description should include the (including chemical intermediates, process approximate ranges of temperatures, parameter limits, etc.). The following p'essures, and mass flow rates for each of information should be documented and the process chemicals and the licansed made available to persons responsible for materials. These ranges should be verifying and maintaining chemical process included for inputs, outputs, and materials safety throughout the faci'ity, and chemicals in process.
2.1.1 Process Description 2.1.1.5 Process Control A description of the proposed chemical and The process description shoulci generally mechanical process steps for the licensed cover the process equipment and material aids the reviewer in understanding engineering design features used for the design basis. A complete description of process controlin each process step, the processes should contain the following including setpoint ranges for safety controls.
elements. Any special administrative or procedural controls should also be described.
2.1.1.1 Purpose 2.1.1.6 Materials of Construction The process description should state the purpose or objective of each process step, The process description should provide a including the operation (s) to be performed, list or description of the materials of construction used in the processing, 3 NUREG-1601
storage, and in-process transport of 2.1.2.1 Bulk Chemicals licensed material when that information is necessary for understanding the potential Attention should be given to systems which degradation, or the effect of radiation on the contain toxic and hazardous substances strength and properties, of the construction under NRC jurisdiction as defined by the material. MOU between OSHA and NRC. These include hazardous substances identified in 2.1.1.7 Safety Features 29 CFR Part 1910, Subparts H and Z.
regardless of quantdy.
The process description should include the structures, systems, equipment, 2.1.2.2 Utilities components, engineered design controls, and human actions and administrative A description of utilities near licensed-controls relied on for chemical process material processing should be part of or safety. Such features may include not only referenced by the process safety the engineered design controls and information. Steam, water, vacuum materials of construction mentioned above, systems, compressed gases, and electrical but also items such as chemical power supplies could, if interrupted or confinement, barriers, leak suppression uncontrolled, cause a hazardous condition equipment, emergency shutdown or to develop with the licensed materials.
response procedures, and passive engineered controls such as rupture disks. 2.1.2.3 Ventilation Where special nuclear material (SNM) might accumulate, as in dikes or bags to The operation of the ventilation system may contain leaks, criticality safe geometries be the single most important protection may need to be considered. against radiological exposure. Design information of the ventilation system 2.1.2 Auxiliary Systems ducting, scrubbers, filters, and controls should be included or referenced in the The process safety information should process safety information.
include a description of other systems (including safety features) in the licensed. 2.1.2.4 Chemical Traps and Filters material process areas, transport areas, or storage areas, such as plant utilities, bulk These systems may be considerd a subset chemical systems, and ventilation. These of the other process or auxiliary systems, systems are not necessanly part of the but are important enough to be mentioned licensed material processing system but, separately. The design of chemical traps under off normal' conditions, could affect and filters should be part of the process licensed material processing, safety information. Trap design, filter media, operating temperatures and pressures, cleanout or filter change procedures, and automated controls should be desenbed.
c 'Off normal conditions refers to cond.ttons that are in some respect outsee of the range for routine operations but have not resulted in an accdent 4 NUREG 1601
2.1.2.5 Emergency Systems system review should include the following elements.
Systems vvhich provide mitigative services (e.g., fire suopression equipment) or 2.2.1.1 Process Chemistry backup for main systems (e.g., emergency power supply) should be included or Observe the chemical components added refarenced in the process safety to each process step. Identify all chemical information. Descriptions of their locations, process hazards where chemical reactions operations, and testing methods may be cuuld prodisce hazardous materiale. which important with regard to chemical process were not previously present (e.g., the safety. evolution of hydrogen when metals are dissolved in acids).
2.1.3 Specialty Chemical Data
! 2.2.1.2 Effects of Variable Chemical lhe process safety information should Additions provide the general information included on the Material Safety Data Sheets' for any At each process step, analyze the effect mecialty chemical used in the that adding variable amounts of chemicals licensed-material process areas, transport has oi generating hazardous materials arid areas, or storage areas. on the chemical and physical forms of the licensed material. Evaluate the possibility 2.2 Hazard Audit and effect. . f adding the wrong chemicals t i
to a process step or adding them in the in order to minimize the probability of wrong sequence. Also evaluate the i accidents3 and their impact on the licensed potentially unwanted dissolution or ,
material, potential chemical process safety precipitation of the licensed material, ,
hazards should be identified through a especially if the licensed material could hazard audit. thereby be released into a waste stream.
2.2.1 System Roview 2.2.14 Energy Somces Evaluate the potential energy sources of the The first step is to thoroughly review the process components, such as source facility to identify potential chemical elevated temperatures and pressures, hazards
- of radioactive mat 3 rials and electrostatic forces, ex7 thermic reactions, radiation hazards caused by chemicals. The erosion caused by abrasive materials, and flammable and explosive materials. The potential effacts of these sources of energy 2
Pursuant to 29 CFR 191012003. osha requires on equipment and personnel should be Matenai safety oata sheets to be supphed by u s. chemical Considered as part of any hazard audit.
manufacturers and importers.
3
- An accident is an unpianned event or sequence of events that resuits b undesirable consequences; or an incent witn specac safety consequences or impacts. Determine whether the materials of
, construction and the process equipment enerracal charactens c$ hat $s tne pIteNNfor ca have been chosen in such a manner that a harm to humans or to the environment. Catastrophic failure resulting in a retease of 5 NUREG-1601
hazardous materials is unlikely. A 2.6) should be reviewed during each catastrophic failure could be causd by iteration of the hazard audit.
chemical incompatibility, thermal cycling, or excessive heat and pressure. 2.2.1.8 Human Factors 2.2.1.5 Process Control and Safety Potential human errors in the operation and Devices maintenance of the process should be guarded against. The review of chemical s
Determine whether adequate safety devices systems should consider ergonomics and or systems are in place to minimize worker fatigue as e potential cause of potential hazards from process cheWeals hazards. The design and location of the or chemical reactions; for example whether equipment, the layout of the process, and ventilation, pressure relief valves, the clarity and sequence of instructions in combustible gas detectors, double-wal'ed proceoures should all be reviewed with pipe, etc., are available to prevent, mitigate, human factors in mind.
or warn of a hazardous condition.
Determine whether process controls are 2.3 Identification of the Hazards adequate to prevent avoidable chemical hazards (e.g., controls for temperature, 2.3.1 Potential Accident Scenarios pressure, level, interface, pH, conductivity).
If the system review reveals, potential j 2.2.1.6 Other Chemical Systems in the chemical hazards of radioactive materials j Licensed Materlad Process Areas and radiation hazards caused by chemicals, the hazards should be identified, e Chemical systems which are not directly documented, and analyzed to determine q involved in the processing of lic3nsed their effects. Whenever possible, a -
materials but are in the same general area licensee's own experience should be used can interact with the licensed materials to supplement the identification of potential and/or associated equipment Therefore. chemical hazards. Chemical accidents that review the controls that are in place to have occurred in the past show the more prevent these systems from leaking into common hazards, but reliance on past and onto equipment containing licensed experiences alone may cause many material. A review of whether potential hazards to be overlooked. The lack of re; eases from other chem' al systems chemical accident occurrences in a could affect the access to or operability of particular area does not mean that chen,; cal equipment containing licensed materials hazards do not exist there.
sh>.ld also be considered.
Thero are many different methods of 2.2.1.7 Management Controls identifying potential chemical hazards.
Some of the more common methods The administrative controls placed on involve developing interaction matrices or chemical systems and the requirements using specific hazard evaluation techniques.
pis ed on workers can have an overriding However, any method which sufficiently effr. on the operation of the facility. The identifies potentialinteractions of the management control systems needed to process area chemicals with the licensed maintain chemical process safety (Section material and its associated confinement, process equipment, and workers would be 6 NUREG-1601
' acceptable. Regardless of the method licensed material and potentially have a chosen for identifying hazards, the human or environmentalimpact.
consequences to people and the environment must be considered in 2.3.2 lostruments and Cordrol
(
determining wl;ich conditions are hazards. Functions 2.3.1.1 Effects en Public and Workers Instrumentation and control systems, as identified by the integrated safety analysis5 The most commonly faced situation at fuel (ISA), should be provided to monitor cycle facilities is the exposure of workers to variables and operating systems important chemicals containing the licensed material. to safety during normal and off-normal Such situations could adversely affect the operations, accidents, and shutdown health of workers and/or members of the conditions. In addition, the overall general public and should be identified as confinement system, the confinement potentW chemical hazards. Chemicals barriers, and the other systems which affect
,cuch do not contain licensed materials plant safety should be monitored. Controls should also be identified as potential should maintain variables within prescribed chemical hazards because, even in the operating ranges under all normal absence of workers, release of such conditions, and control systems should be chemicals may affect the process by designed to fail to a safe state. Protection releasing the licensed material or may '
systems whose primary functions are to affect the confinement of the licensed prevent releases, facilitate process matcrialin a favorable geometry. shutdowns, or protect worker and public 2.3.1.2 Effects on the Environment
- a. initiate actions to ensure that design Chemicals which can cause a release of limits are not exceeded, licensed material to the environment above NRC prescribed !imits should be identified b. sense potentially hazardous cenditions, as potential chemical hazards. Such releases include onsite and offsite c. have reliability and testability, contamination of at., water, and soil.
- d. maintain function with loss of a single
, 2.3.1,3 5.ffects on ths Facility active component, The impact of chemicals on facility systems, e. maintain function with removal from structures, equipment, and componants service of any components,and (i.e., process equipment) is an integral part I
of any chemical hazard analysis. Chem; cal effects causing degradation of process 5 Integrated safety analysis means an unalysis to safety equipment (equipment for centify hazards and their potentiat for initiating event S t "" " ' " '
preventing, mitigating, and annunciating a g g,""*c,",*,P'n thb $ " Net res syst m process hazard), process contiol equ;pment. components, and activities of personnel. that are equipment, and confinement vessels snd rehed on for safety as stated in the Draft NuREG 1513.
structures should be identified as chemic.r: 5 e g use of acceptacle compensatory measures hazards if the degradation could affect the or backup equ'pment 'o assure availabihty and rehabihty of items rehed on for safety or remove hazard from system 7 NUREG-1601
4
. f. fail to a safe state in loss of power. iicensed material or its confinement. They
- are not normally recommended for SNM-Thus, the identification of hazards should bearing solutions unless adequate consider accident scenarios where provisions are made in the criticality control instrumentation and control systems can fail calculations, in the performance of one or more of these safety functions. 2.4.1.2 Liquid Confinement Dikes 2.4 Design Basis These barriers are widely used in bulk chemical storage areas for confinement of Assurance of chemical safety within a large spills. Dikes should also be used to facility begins with a good design basis, contain smaller amounts of spilled Adequately designed chemical systems, corrosives to prevent potential interaction including the controls used to prevent with licensed-material process equipment.
accidents, will have few safety probier.is Dikes used to contain SNM-bearing through most of their operating life. Properly solutions should not exceed criticality specified features such as materials of design constraints on volume, construction, equipment sizing, and system concentration, and enrichment.
fabrication techniques will prevent many chemical accidents from occurring. The 2.4.1.3 Glove Boxes system's engineered-design process control schemes enhance these features to provide in licensed-material handling areas where an even higher margin for safety. When the chemicals are present, glove boxes should risk involving the licensed material is high, be used to contain the licensed material and additional measures should be taken to protect it from undesired chemical ensure the chemical safety of the process, interactions. If other barriers are not in place, glove boxes should be constructed 2.4.1 Physical Barriers from materials that are resistant to the chemicals in the area.
The establishment of physical barriers is an effective method to prevent releases of 2.4.1.4 Splash Shields licensed materials to unwanted lecations.
Physical barriers can be used to prevent Splash shields can be used to direct spills auxiliary systems which do not contain Of hazardous liquids away from licensed licensed material from interacting with the rr aterial storage and process areas and licensed-material systems. Commonly used should also be used to protect worker: from physical barriers are described below. potential spills of solutions containing licensed material. Splash shields should be 2.4.1.1 Double-Walled Piping and Tanks transparent when possible so that a dripping solution can be identified and These physical barriers capture liquid leaks corrected quickly.
and (when properly installed) alert personnel to tha occurrence. They should 2.4.1.5 Fire Walls nr. mally be used on piping and storage :
vessels containing highly corrosive Fire walls can be used to protect licensed-materials (such as hydrogen fluoride) in material storage and process systems from areas where a leak could easily affect the potential fires and explosions. They should 8 NUREG-1601
be used as a barrier between licensed overflow vesselif all of the ascociated material and large quantities of flammable solutions are chemically compatible with or explosive chemicals which, when ignited, each other and with the overflow vessel could disrupt the integrity of confinement construction materials.
systems. Fire walls shoula also be used as a barrier for high-pressure systems located 2.4.1.9 Chemical Traps and Filters i near licensed materials.
These are typically used for collecting 2.4.1.6 Protective Cages vapors, aerosols, and particulates from air and gas streams. Chemical traps capture These barriers are used to protect chemical vapors and aerosols by absorption or and licensed-material systems from impacts adsorption onto a collection medium. An with moving objects. They are particularly example is the use of alumina to collect usefulin protecting polymer or glass small quantities of UF. vapors from an air components of chemical piping systems. stream. Filters are widely used to remove Protective cages should be utilized where radioacuve particulates from air flows, but such components are exposed to major can be used in other situations.
traffic areas.
2.4.2 Mitigative Features 2.4.1.7 Backflow Preventers and Siphon Breaks Mitigative features help reduce the impact of chemical accidents. Chemical systems These devices can be used in piping which tend to have an associated high risk systems to prevent chemicals or licensed level should include mitigative features in material solutions from f'owing into the equipment design. Multiple mitigative undesirable locations and creating features may need to be combined to truly hazardous conditions. They should only be minimize the hazard. Some of the more necessary where the process design common mitigative features in fuel cycle requires interconnection of two or more facilities are described below.
potentially incompatible systems. Good process design practices should be used to 2.4.2.1 Driving Force Controls minimize such connections.
These controls help stop the driving force of 2.4.1.8 Overflow Vessels the hazard. They are typically devices which cut power to heating elements or There should be an overflow strategy for other electrically driven equipment. They each process vessel containing licensed also include cutoffs for air-driven materials and/or hazardous chemicals equipment, pressure relief devices, and associated with it. In most instances, a emergency cooling systems. These separate vessel can be provided to controls should be in place on any system accommodate possible overflow of the which contains licensed materials or primary vessel, Such an overflow vessel , hazardous substances at elevated should contain an alarm system so that the ' temperatures or pressures.
overflow condition can be recognized.
Automatic cutoff systems on the process vessel feed lines can also be used. Multiple process vessels can be piped into the same 9 NUREG-1601
2.4.2.2 Solenoid and Control chemical release. These systems can be Valves run continuously or on demand when a release occurs. Since these systems These valves help stop the flow of typically have a limited capacity, they hazardous substances from their should be used in conjunction with other confinements in cases of pipe breakage or mitigative features. They are particularly downstream equipment failure. To be usefulin areas where spray systems are effectivo, they should be used in not feasible.
conjunction with inline pressure- or flow monitoring equipment. They should be 2.4.2.5 Alarm systems used on any system containing highly hazardous chemicals or explosive gases Alarm systems can be used as a mitigative which does not have a secondary feature by alerting workers to the situation confinement system (e.g , double-walled and enat,ung them to act quickly to reduce piping). For fuel cycle facilities, highly the effects of a chemical release. These hazardous chemicals7 would typically actions could include measures to stop the include ammonia and ammonia solutions release and/or evacuate the area. Alarm
(>44wt%), fluorine, hydrogen chloride and systems shcald be used in all high-risk concer.trated hydrochloric acid, hydrogen chemical process areas.
fluorice and concentrated hydrofluoric acid, hydrogen peroxide (>52wt%), concentrated 27 .azard Evaluation nitric acid (>94.5wt%), and uranium hexafluoride. The potential chemical hazards, once identified, should be evaluated for their 2.4.2.3 Spray Systems impact on humans and the environment.
The evaluation of chemical hazards should Spray systems can be used to lessen the be performed as part of an integrated effort, effects of a chemical accident by scrubbin9 along with other safety and safeguards chemicals from the air, diluting chemicals meetures, including fire protection, on the ground, or providing a quick coolin9 radiation safety, criticality safety, and mechanism. The most common spray physical security measures. Electrical and medium is water, but spray media can industrial safety concems may also be part include dilute solutions which react with the of the integrated safety analysis if their hazardous chemical and render it effects on workers can have a subsequent nonhazardous. Carbon dioxide is a typical effect on the confinement of the licensed cooling medium. Equipment containing material.
licensed material should use spray systems only after thorough consideration of their 2.5.1 Metheds effect on criticality control.
The rnethods used for performing the 2.4.2.4 Auxiliary Ventilation hazard evaluation can vary from a simple qualitative checklist to a complex Auxiliary ventitation systems can be located quantitative risk assessment. The in high-risk areas to reduce the effects of a: Integrated Safety Analysis Guidance Document (Draft NUREG-1513) and other 7 documents referenced therein describes Hghty hazardous enemices as listed in 29 CFR 1910.119, Appendix A. most of the techniques used by the 10 NUREG-1601 l
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chemical industry for hazards evaluation. associated with the input parameters for the The method chosen should be consistent hazard analysis can affect the accuracy of with the apparent risk associated with the the resuits. Therefore, the elements facility, the level of detail desired from the discussed below may affect chemical results, the amount of process safety processes at the facility and should be information available, and the current stage considered in the analysis. These elements of the process life cycle. should be reviewed iteratively with subsequent hazards analyses as new 2.5.2 Results knowledge is gained. This periodic review should reduce the uncertainties and provide The results of the hazard evaluation should assurance of chemical safety at the facility, undergo internal peer review for reasonableness by personnel not involved 2.6.1 Management Structure and in the original evaluation. The peer review Concepts team must be knowledgeable of the process facWy cperations. Management The management structt;re at a fuel cycle should then scrutinize the results and facility can vary widely according to the decide how to address each potential licensee's mission and capabilities. The chemical hazard. It is important to update important aspects of management structure and revalidate the evaluation periodically and functions have been assembled in and when a significant change to the NUREG/CR-6287, " Management Concepts process is made. Radiological and and Safety Applications for Nuclear Fuel chemical accidents which already have Facilities." It is recommended that each adequate preventive and mitigative controls licensee and license applicant designate and those invoiving very low risks (Iow one person to have overall responsibility probability and low consequence) may not and authority for chemical process safety in require any further action. Other chemical each facility, as is done for other disciplines hazards may need to be addressed by such as criticality and radiological safety.
establishing additional engineered-design controls; by installing protective barriers; 2.6.2 Procedures and by implementing administrative controls (e.g., revised procedures, a preventive Clear and comprehensive procedures are maintenance schedule, or an inspection- necessary to assure the safo operation of a and/or test based predictive mainter.ance fuel cycle facility. Without such procedures, system). A risk matrix can be used to measures taken to assure chemical safety provide guidelines for accepting or not would quickly lose their usefulness.
accepting the analyzed frequency and Chemical safety issues identified by the consequence of the potential chemical haard evaluation as having potentially hazard. significant impacts' on people or the environment should be addressed within the 2.6 Continuing Assurance of licensee's procedures. Procedures for fuel Chemical Safety cycle facilities are generally of two types, operating procedures and management Effective implementation of chemical safety: control procedures.
demands management involvement and control. The inherent uncertainties e irnpacts are consdered signrricant if tney could involve violations of Federal statutes 11 NUREG-1601 l
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1 2.6.2.1 Opera, ting Procedures 2.6.4 Maintenance Operating procedures directly control Effective maintenance and surveillance of process operations and should include facility equipment ensure that equipment instructions on handling chemical safety used to process, store, or handle hazardous concems during normal and off normal materials is constructed, installed, and conditions. These procedures should maintained to minimize the risk of provide specific direction reCarding accidental releases because of equipment administrative controls to ensure process failure. The mechanicalintegrity of all chemical safety. Procedures for process structures, systems, components, and operations which can affect chemical safety detection and monitoring equipment should include process operating limits and important for ensuring chemical safety controls and the required actions for normal should be included in the maintenance and off-normal conditions of operation. activities. These activities should include Off-normal conditions are conditions corrective maintenance, scheduled created by human failure or failure of any preventive maintenance, instrumentation system, structure, or component. calibration and testing, and scheduled surveillance and inspections for verifying 2.6.2.2 Management Control Procedures the integrity of the chemical safety of the facility, Maintenance and surveillance Management control procedures should be activities on chemical safety systems should used to manage activities such as include:
configuration management, maintenance, plant-wide safe work practices, training, a. pre-maintenance reviews of the work to audits, and incident investigations, There be performed; should be an overall chemical safety element describing the methods, activities, b. confirmed notification to pertinent and implementation of the overall safety operators and supervisors of the program. maintenance to be performed and its potential effects of maintenance on 2.6.3 Training ongoing operations, and notification of the completion of the planned Effective chemical safety training helps maintenance and the restoration of the employees understand the nature and affected equipment; causes of problems that could arise from process operacons and increases c. comprehensive procedures which awareness of the particular hazards of a address qualification of personnel process. The training programs described authorized to perform the maintenance in a licensee's safety program description or surveillance, controls on and should include provisions for chemical specification of any replacement safety training of all personnel who routinely components or materials to be used, access licensed material areas, including post-maintenance testing to verify contractor personnel, and visitors who are operability of the equipment, and allowed unescorted access to those areas. ; documentation of the results of the More intensive chemical safety training maintenance or surveillance activity.
should be provided to qualify personnel as chemical process operators.
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2.6.5 Configuration Management the design and licensing bases and the design requirements.
Configuration management (CM) ensures oversight and control of all design bases 2.6.5.3 Document Control and modifications (both temporary and permanent) to equipment, procedures, and The control of documents within the CM processing conditions important to chemical system should be established to include safety. Configuration management is one cataloging the document data base and of the measures that shouio be integrated maintaining and distributing the documents.
into a single safety program that Such documents should include items from incorporates chemical safety systems. A the process safety information (design Configuration Ma%gement system should requirements, chemical hazards analysis, include the following elements. as-built drawings, specifications, operating and non-operating procedures pertinent to 2.6.5. Implementation Plan chemical safety, etc.), emergency response plans, system modification documents, The implementation of a CM system should assessment reports, and any other determine the scope of the safety elements documents deemed necessary. Original or to be considered, a description of each CM master copies of documents should be activity and its objectives, and presenbe the stored under quakty assurance (QA) functional interfaces with quality assurance, requirements.
maintenance, and training. All chemical safety hazards identified as significant 2.6.5.4 Chaw Control should be considered. The CM system should also have formalized configuration The CM system should maintain strict management procedures and provide a consistency among the design method for initiating immediate corrective requirements, the physical configuration, actions to problems found with the CM and the facility documentation. Methods system. should be developed for identifying changes in the configurations relied on for chemical 2.6.5.2 Design Requirements safety, ensuring technical and managerial review of proposed changes, and tracking Design requirements and associated design and implementing those changes by placing bases should be establis',ed and documentation in a document control center maintained by an appropriate organizational and disseminating information to the unit. These design requirements should be training, engineering, operations, kept current and suitable hazard analysis maintenance, and QA functions.
methods should be used to evaluate chemical safety aspects of proposed 2.6.5.5 Assessments changes to the process. The design basis should be a set of facts about the chemical Assessments of the CM system should be safety elements covered by the CM system conducted to determine its effectiveness and should be reviewed and approved by and to correct deficiencies. Periodic i an appropriate authonty within the physical assessments (walkdowns) of the organization. A specific group should be che mical safety systems should be assigned the responsibility for maintaining performed to confirm the program's accuracy and adequacy.
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2.6.6 Emergency Planning for chemical safety controls, and the results a should be reviewed and acted upon by the The emergency plan, prescribes a licenf ee's management.
comprehensive response to chemical-related accidents and plant emergencies to 2.6.9 Quality Assurance protect the public, the workers, and the environment. The portion of the emergency Quality assurance (QA) provides 4 confidev^
plan relating to chemical process safety that the structures, systems, equipment, concerns should describe the significant components, and human actions relied on chemical hazards identified in the hazard for chemical safety are of acceptable i evaluation process and methods to be used quality, items relied on for chemical safety ,
to detect and mitigate the corresponding should be subject to the quality assurance g chemical accidents, criteria described below.
o 2.6.7 incidentInvestigations and 2.6.9.1 Design Control Corrective Actions Systems, structures, and components relied incident investigation activities identify the upon for chemical safety should be root causes of and responses to chemical designed with well-def i ned objectives and functions. The design should be controlled safety incidents that affect the licensed material and that have or could have to adhere to its defined function and should significant health and safety implications. be verified by knowledgeable personnel not Such investigations should identify directly involved in the original design.
corrective actions to be taken to minimize the incident or prevent it from recurring. A 2.6.9.2 Procurement Document Control system should be developed with an organizational structure and procedures for Applicable design bases and other establishing investigation teams, requirements necessary to ensce determining root causes, tracking and adequate quality should be included or referenced in documents for procurement of completing corrective actions, and items or services related to chemical safety.
documenting and applying the " lessons learned" to other operations, If possible, suppliers should have a QA program consistent with the quality level of the item to be procured.
2.6.8 Safety Program audits 2.6.9.3 Control of Purchased Material, Audits and assessments provide assurance Equipment, and Se vices that the safety program is functioning as intended and should be used to determine Purchasad material, equipment, and the effectiveness of chemical process services should be controlled to ensure safety controls. Audits and assessments conformance with specified requirements.
should be conducted according to written Materials should be inspected upon receipt procedures and checklists that ensure the for accuracy and quality, and critical documentation of findings, the distribution measurements should be verified.
of reports, and the assignment of follow up ;
Equipment should be tested for operational responsibilities. The audits and acceptance before being relied upon for assessments should be conducted by chemical safety. Purchased services which qualified personnel who are not responsible 14 NUREG-1601
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are relied upon for chemical safety should 2.6.10 Human Factors be monito:ed fr'equently for assurance of adequacy and completeness. Human factors are a potential cause of accidents involving hazardous chemicals 2.6.9A identification and Control of and should be evaluated when humans !
- Unacceptable Materials, Parts, interface with structures, systems, l and Components components, or functions that are l considered important to chemical safety. l Provisions should be made to identify and Such human actions should be supported i I
centrol those items which were to have by information such as data, alarms, been ralied on for chemical safety and are directions or management policies, training )
discovered to have incorrect or defective programs, and control displays so that they materials, parts, and components. can be peformed properly. A human Unacceptab!e items should be physically factors program should contribute to
% segregated from acceptable or untested reducing the probability of significant "N items when possible, and clearly marked or chemical-shfety related human errors,
, -- $ tagged as unacceptable so that they cannot provide for the detection and correction of 9 '41 be mistaken for acceptable items- the human errors that do occur, and i' '
integrate with other programs to provide 1 2.6.9.5 Measurement and Test Controls reasonable assurance that system performance will degrade in a safe manner, Provisions should be made to ensure that despite failures to prevent, detect, or correct tools, gauges, instruments, and other human errors. 4 measuring and testing devices used on items relied upon for chemical safety are ;
properly identified, controlled, calibrated,
. ;r and adjusted at specified intervals. Testing
' (~ i uirerlents for chemical safety systems 7
2
,.ktid oe specified in written procedures.
h h i.9.6 Corrective Actions, Record keeping, and Audits l
Provisians should be made to ensure that conditions adverse to the quality of chemical safety systems are promptly identified and corrected and measures taken to preclude repetition. Provisions should also be made for the identification, retention, retrieval, and maintenance of records that fumish evidence of the control s
of quality for activities important to chemical safety. Audits should be performed to verify jppliance with all aspects of the QA ~
~
A y
- gram and to determine its effectiveness.
L. ,
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3 REFERENCES American Institute of Chemical Engineers, Center for Chemical Process Safety, Guidelines for Hazard Evaluation Procedures, (2d edition with worked examples), Nev. /ork,1992.
American Society of Mechanical Engineers, "ASME Code for Chemical Plant and Petroleum
- Refinery Piping," ASME B31.3, New York,1993.
U.S. Code of Federa/ Regulations, " Domestic Licensing of Source Mate,ial," 10 CFR Part 40.
U.S. Code of Federal Regulations, " Domestic Licensing of Special Nuclear Mattdal,"
U.S. Code o/ Federa/ Regulations, " Occupational Safety and Health Standards,"
29 CFR Part 1910, Subpart H, " Hazardous Materials."
U.S. Code of Federal Regulations, " Occupational Safety and Health Standards,"
29 CFR Part 1910, Subpart Z, " Toxic and Hazardous Substances."
U.S. Nuclear Regulatory Commission, " Guidance on Management Controls / Quality Assurance, Requirements For Operation, Chemical Safety, and Fire Protection for Fuel Cycle Facilities,"
Federal Register, Vol. 54, No. 53, March 21,1989, pp.11590-11598.
U.S. Nuclear Regulmory Commission, " Integrated Safety Analysis Guidance Document," (Draft Report for Comment) NUREG-1513, February 1995.
J U.S. Nuclear Regulatory Commission, " Management Concepts and Safety Applications for Nuclear Fuel Facilities," NUREG/CR-6287, May 1995.
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