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On Friday 9/28/2012, while completing ISA … On Friday 9/28/2012, while completing ISA (Integrated Safety Analysis) meetings on a new process, several accident sequences were identified that had the potential for creating ocular exposures that could lead to intermediate consequences in accordance with 10CFR70. The sequences involved uranyl nitrate (UN) solutions. IROFS (Item Relied On For Safety) were identified for the new process.</br>As a follow-up to this activity, on 10/02/2012, plant safety personnel reviewed existing ISA accident sequences for other process systems where UN solution is present and at 0730 (PDT), reported to the EHS&L Manager that similar loss of containment accident sequences in other process systems were determined to be 10CFR70 low consequence events within the approved existing ISA.</br>This report is being made under 10CFR70 Appendix A, criterion (b)(1) which states, 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis, and which results in failure to meet the performance requirements of 10CFR70.61.'</br>10CFR70.61 (4)(e) states in part, '...Each engineered or administrative control or control system necessary to comply with paragraphs (b), (c), or (d) of this section shall be designated as an item relied on for safety.'</br>While this report is being made based on the treatment of UN sprays to the eye, this scenario can be applied to other hazardous chemicals falling under the scope of the ISA treatment.</br>Based on information obtained during the ISA activities for this new process, two other types of accident sequences documented in the existing facility ISA as 10CFR70 low consequence events need to be re-evaluated with respect to the 10CFR70 consequences of concern thresholds. These types of accident sequences are dermal contact and inhalation of liquid aerosols. These two types of accident sequences are being re-evaluated throughout the plant. The status of this re-evaluation effort will be reported in a 30-day follow-up report to this initial notification.</br>The personal protective equipment (PPE) that is used to provide protection to workers during work evolutions and the safety protocols for limiting exposures to UN are not categorized as IROFS for some of the existing processes. The PPE and safety protocols used by AREVA based on 40 years experience for these types of scenarios are considered to be adequate. AREVA's re-evaluation of these scenarios will be utilized to confirm their adequacy, or if applicable, to identify needed enhancements.</br>This discrepancy has potentially existed since 10/18/2004. This report does not involve potential criticality accident scenarios.</br>Corrective Actions in Progress:</br>1) verify that appropriate spray shields/deflectors are in place,</br>2) verify existing safety protocols that are in place are adequate, and </br>3) update the safety analysis and implementing documents to declare as IROFS the appropriate PPE and safety protocol.</br>The licensee will be notifying Region 2.ocol.
The licensee will be notifying Region 2.
14:30:00, 2 October 2012 +
48,366 +
20:56:00, 2 October 2012 +
14:30:00, 2 October 2012 +
On Friday 9/28/2012, while completing ISA … On Friday 9/28/2012, while completing ISA (Integrated Safety Analysis) meetings on a new process, several accident sequences were identified that had the potential for creating ocular exposures that could lead to intermediate consequences in accordance with 10CFR70. The sequences involved uranyl nitrate (UN) solutions. IROFS (Item Relied On For Safety) were identified for the new process.</br>As a follow-up to this activity, on 10/02/2012, plant safety personnel reviewed existing ISA accident sequences for other process systems where UN solution is present and at 0730 (PDT), reported to the EHS&L Manager that similar loss of containment accident sequences in other process systems were determined to be 10CFR70 low consequence events within the approved existing ISA.</br>This report is being made under 10CFR70 Appendix A, criterion (b)(1) which states, 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis, and which results in failure to meet the performance requirements of 10CFR70.61.'</br>10CFR70.61 (4)(e) states in part, '...Each engineered or administrative control or control system necessary to comply with paragraphs (b), (c), or (d) of this section shall be designated as an item relied on for safety.'</br>While this report is being made based on the treatment of UN sprays to the eye, this scenario can be applied to other hazardous chemicals falling under the scope of the ISA treatment.</br>Based on information obtained during the ISA activities for this new process, two other types of accident sequences documented in the existing facility ISA as 10CFR70 low consequence events need to be re-evaluated with respect to the 10CFR70 consequences of concern thresholds. These types of accident sequences are dermal contact and inhalation of liquid aerosols. These two types of accident sequences are being re-evaluated throughout the plant. The status of this re-evaluation effort will be reported in a 30-day follow-up report to this initial notification.</br>The personal protective equipment (PPE) that is used to provide protection to workers during work evolutions and the safety protocols for limiting exposures to UN are not categorized as IROFS for some of the existing processes. The PPE and safety protocols used by AREVA based on 40 years experience for these types of scenarios are considered to be adequate. AREVA's re-evaluation of these scenarios will be utilized to confirm their adequacy, or if applicable, to identify needed enhancements.</br>This discrepancy has potentially existed since 10/18/2004. This report does not involve potential criticality accident scenarios.</br>Corrective Actions in Progress:</br>1) verify that appropriate spray shields/deflectors are in place,</br>2) verify existing safety protocols that are in place are adequate, and </br>3) update the safety analysis and implementing documents to declare as IROFS the appropriate PPE and safety protocol.</br>The licensee will be notifying Region 2.ocol.
The licensee will be notifying Region 2.
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00:00:00, 2 October 2012 +
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20:56:00, 2 October 2012 +
0.268 d (6.43 hours, 0.0383 weeks, 0.00881 months) +
14:30:00, 2 October 2012 +
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