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{{#Wiki_filter:NEA International Workshop on Chemical Hazards in Fuel Cycle Facilities Nuclear ProcessingChemical Safety Requirements in the United States for Commercial Fuel Cycle FacilitiesMarilyn DiazU.S. Nuclear Regulatory CommissionApril 17, 2018 Topics 2*
{{#Wiki_filter:NEA International Workshop on Chemical Hazards in Fuel Cycle Facilities Nuclear Processing Chemical Safety Requirements in the United States for Commercial Fuel Cycle Facilities Marilyn Diaz U.S. Nuclear Regulatory Commission April 17, 2018
 
Topics
*  


==Background:==
==Background:==


-Overview of Fuel Cycle Facilities
  - Overview of Fuel Cycle Facilities
-Memorandum of Understanding between U.S. agencies-Regulatory Framework
  - Memorandum of Understanding between U.S.
*Chemical Safety Requirements
agencies
*Guidance*Conclusion Overview of Fuel Cycle Facilities Overview of Fuel Cycle Facilities 7
  - Regulatory Framework
* Chemical Safety Requirements
* Guidance
* Conclusion 2
 
Overview of Fuel Cycle Facilities Overview of Fuel Cycle Facilities 7
 
Chemical Hazards
Chemical Hazards
*Numerous chemicals used at fuel cycle facilities (FCF) for processing uranium and other heavy metals.*These are chemicals commonly used at FCF that may be considered hazardous:
* Numerous chemicals used at fuel cycle facilities (FCF) for processing uranium and other heavy metals.
-Uranium hexafluoride
* These are chemicals commonly used at FCF that may be considered hazardous:
,hydrogen fluoride , ammonia, hydroxylamine nitrate, nitrogen oxides, nitric acid, other acids and solvents.
  - Uranium hexafluoride, hydrogen fluoride, ammonia, hydroxylamine nitrate, nitrogen oxides, nitric acid, other acids and solvents.
8 Shared Responsibilities for Chemical Hazards*Memorandum of Understanding between U.S. Occupational Safety and Health Administration (OSHA) and U.S. Nuclear Regulatory Commission (NRC).*NRC is responsible for:
8
-Radiation risks of licensed materials
 
-Chemical risks of licensed materials, and
Shared Responsibilities for Chemical Hazards
-Plant conditions that affect or may affect the safety of licensed materials and thus , present an increased risk to workers.
* Memorandum of Understanding between U.S.
9 Regulatory Framework
Occupational Safety and Health Administration (OSHA) and U.S. Nuclear Regulatory Commission (NRC).
*10 CFR Part 70: Amended, in 2002, to incorporate Subpart H requirements which are risk informed, performance
* NRC is responsible for:
-based requirements.  
  - Radiation risks of licensed materials
*Performance Requirements (70.61)
  - Chemical risks of licensed materials, and
*Conduct and maintain an Integrated Safety Analysis (ISA) (70.62)
  - Plant conditions that affect or may affect the safety of licensed materials and thus , present an increased risk to workers.
*Identification of items relied on for safety (IROFS)
9
*ISA summary must include quantitative       standards (70.65) 10  
 
*10 CFR 70.61 presents risk performance requirements which include requirements for acute chemical exposure resulting in high and intermediate consequences (70.61(b)(4) and 70.61(c)(4)).
Regulatory Framework
-High consequence: initiated events that result in:
* 10 CFR Part 70: Amended, in 2002, to incorporate Subpart H requirements which are risk informed, performance-based requirements.
*Could endanger life of a worker, or
* Performance Requirements (70.61)
*Could lead to irreversible or other serious, long
* Conduct and maintain an Integrated Safety Analysis (ISA) (70.62)
-lasting health effects to any individual
* Identification of items relied on for safety (IROFS)
-Intermediate consequence: initiated events that result in:
* ISA summary must include quantitative standards (70.65) 10
*Could lead to irreversible or other serious, long
 
-lasting health effects to a worker,
Chemical Safety Requirements
*Could cause mild transient health effects to any individual 8Chemical Safety Requirements  
* 10 CFR 70.61 presents risk performance requirements which include requirements for acute chemical exposure resulting in high and intermediate consequences (70.61(b)(4) and 70.61(c)(4)).
*10 CFR 70.65 requires submittal of ISA Summary to support demonstration of compliance with performance requirements.  
  - High consequence: initiated events that result in:
-70.65(b)(7) requires a description of the proposed standards used to assess compliance with 70.61.
* Could endanger life of a worker, or
9Chemical Safety Requirements ISA Process 10Identify hazardsIdentify Accident SequencesIdentify Consequence and LikelihoodAssess the Consequence /likelihood for complianceIdentify IROFS ISA Process  
* Could lead to irreversible or other serious, long-lasting health effects to any individual
*10 CFR 70.61 Performance RequirementsCredible Event?Less than intermediate consequenceHigh consequenceIntermediate consequenceHighly UnlikelyUnlikelySTOP No Further Evaluation is Needed NoYesYes NRC Review of Chemical Safety
  - Intermediate consequence: initiated events that result in:
*Overview:Review of Chemical Hazards and Accident ConsequencesReview of Chemical Accident LikelihoodReview of Quantitative Standards for Acute Chemical Exposures 15  
* Could lead to irreversible or other serious, long-lasting health effects to a worker,
*Review of Chemical Hazards and Accident Consequences
* Could cause mild transient health effects to any individual 8
-Description and nature of chemical hazards*Concentration, release point, receptor location, processes involved.
 
*Vessel size, pressure, ventilation, building characteristics, meteorology, duration.
Chemical Safety Requirements
-Assessment of the consequences
* 10 CFR 70.65 requires submittal of ISA Summary to support demonstration of compliance with performance requirements.
-Credible scenarios identified in the ISA*Normal and abnormal conditions.
  - 70.65(b)(7) requires a description of the proposed standards used to assess compliance with 70.61.
13NRC Review of Chemical Safety  
9
*Review of Chemical Accident Likelihood
 
-High consequence events must be highly unlikely.
ISA Process Assess the Identify Identify Accident Identify Consequence Consequence        Identify hazards Sequences  and Likelihood
-Intermediate consequence events must be unlikely.*Quantitative Standards for chemical consequences
                                    /likelihood for compliance IROFS 10
-When is a standard necessary?
 
-Consideration of physical and chemical properties.
ISA Process
-No toxicity or animal testing needed.
* 10 CFR 70.61 Performance Requirements High consequence Highly Unlikely Yes                                                  STOP No Further Evaluation is Intermediate Credible Event?                                         Needed consequence        Unlikely Yes No                    Less than intermediate consequence
14NRC Review of Chemical Safety NRC Review of Quantitative Standards
 
*The quantitative standards serve to identify the event consequence categories for the ISA.
NRC Review of Chemical Safety
*When evaluating standards, NRC reviews the and expects a reasonable estimate of the consequences
* Overview:
*Publicly available, useful sources identified
Review of Chemical Hazards and Accident Consequences Review of Chemical Accident Likelihood Review of Quantitative Standards for Acute Chemical Exposures 15
-AEGLs, ERPGs, TEELs and others.
 
-Globally Harmonized System of Classification and Labelling of Chemicals (GHS): Hazard Statements.
NRC Review of Chemical Safety
-NIOSH Skin Notations for dermal exposures.
* Review of Chemical Hazards and Accident Consequences
15  
  - Description and nature of chemical hazards
* Concentration, release point, receptor location, processes involved.
* Vessel size, pressure, ventilation, building characteristics, meteorology, duration.
  - Assessment of the consequences
  - Credible scenarios identified in the ISA
* Normal and abnormal conditions.
13
 
NRC Review of Chemical Safety
* Review of Chemical Accident Likelihood
  - High consequence events must be highly unlikely.
  - Intermediate consequence events must be unlikely.
* Quantitative Standards for chemical consequences
  - When is a standard necessary?
  - Consideration of physical and chemical properties.
  - No toxicity or animal testing needed.
14
 
NRC Review of Quantitative Standards
* The quantitative standards serve to identify the event consequence categories for the ISA.
* When evaluating standards, NRC reviews the and expects a reasonable estimate of the consequences
* Publicly available, useful sources identified
  - AEGLs, ERPGs, TEELs and others.
  - Globally Harmonized System of Classification and Labelling of Chemicals (GHS): Hazard Statements.
  - NIOSH Skin Notations for dermal exposures.
15
 
ISG: Table 2 Conclusion
* The NRC regulations use risk informed performance standards. Assessment of compliance with the performance standards requires a thorough identification of credible hazards.
* New hazards may be introduced as the result of the introduction of new technology and/or new processes.
* The NRC recognizes that new technology and processes may introduce new hazards and it is important that regulators and operators maintain the safety mindset and conduct thorough analysis and review of the new hazards.
18
 
Marilyn Diaz U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Fuel Cycle Safety and Safeguards, and Environmental Review Marilyn.Diaz@nrc.gov 301-415-7110 Questions?
19
 
Key Terms
* CFR - Code of Federal Regulations
* ISA - integrated safety analysis
* IROFS - items relied on for safety
* UF6 - Uranium hexafluoride
* HF - Hydrogen Fluoride
* Subpart H - ISA requirements
* AEGL - Acute Exposure Guideline Levels
* ERPG - Emergency Response Planning Guidelines
* TEEL - Temporary Emergency Exposure Limits 20


ISG: Table 2 Conclusion 18*The NRC regulations use risk informed performance standards. Assessment of compliance with the performance standards requires a thorough identification of credible hazards. *New hazards may be introduced as the result of the introduction of new technology and/or new processes.
Key Terms
*The NRC recognizes that new technology and processes may introduce new hazards and it is important that regulators and operators maintain the safety mindset and conduct thorough analysis and review of the new hazards.
* NIOSH - The National Institute for Occupational Safety and Health
Questions?
* OSHA - Occupational Safety and Health Administration
19Marilyn DiazU.S. Nuclear Regulatory CommissionOffice of Nuclear Material Safety and SafeguardsDivision of Fuel Cycle Safety and Safeguards, and Environmental ReviewMarilyn.Diaz@nrc.gov 301-415-7110
* FCF - Fuel Cycle Facilities 21}}
*CFR -Code of Federal Regulations
*ISA -integrated safety analysis
*IROFS -items relied on for safety
*UF6 -Uranium hexafluoride
*HF -Hydrogen Fluoride
*Subpart H
-ISA requirements
*AEGL -Acute Exposure Guideline Levels
*ERPG -Emergency Response Planning Guidelines
*TEEL -Temporary Emergency Exposure LimitsKey Terms 20
*NIOSH -The National Institute for Occupational Safety and Health
*OSHA -Occupational Safety and Health Administration
*FCF -Fuel Cycle FacilitiesKey Terms 21}}

Revision as of 05:46, 21 October 2019

USNRC Presentation for Nea Workshop on Chemical Hazards in Fuel Cycle Facilities Nuclear Processing
ML18128A170
Person / Time
Issue date: 05/08/2018
From: Diaz-Maldonado M
Office of Nuclear Material Safety and Safeguards
To:
Diaz-Maldonado M
References
Download: ML18128A170 (21)
v • d • e


Text

NEA International Workshop on Chemical Hazards in Fuel Cycle Facilities Nuclear Processing Chemical Safety Requirements in the United States for Commercial Fuel Cycle Facilities Marilyn Diaz U.S. Nuclear Regulatory Commission April 17, 2018

Topics

Background:

- Overview of Fuel Cycle Facilities

- Memorandum of Understanding between U.S.

agencies

- Regulatory Framework

  • Chemical Safety Requirements
  • Guidance
  • Conclusion 2

Overview of Fuel Cycle Facilities Overview of Fuel Cycle Facilities 7

Chemical Hazards

  • Numerous chemicals used at fuel cycle facilities (FCF) for processing uranium and other heavy metals.
  • These are chemicals commonly used at FCF that may be considered hazardous:

- Uranium hexafluoride, hydrogen fluoride, ammonia, hydroxylamine nitrate, nitrogen oxides, nitric acid, other acids and solvents.

8

Shared Responsibilities for Chemical Hazards

  • Memorandum of Understanding between U.S.

Occupational Safety and Health Administration (OSHA) and U.S. Nuclear Regulatory Commission (NRC).

  • NRC is responsible for:

- Radiation risks of licensed materials

- Chemical risks of licensed materials, and

- Plant conditions that affect or may affect the safety of licensed materials and thus , present an increased risk to workers.

9

Regulatory Framework

  • 10 CFR Part 70: Amended, in 2002, to incorporate Subpart H requirements which are risk informed, performance-based requirements.
  • Performance Requirements (70.61)
  • Conduct and maintain an Integrated Safety Analysis (ISA) (70.62)
  • Identification of items relied on for safety (IROFS)
  • ISA summary must include quantitative standards (70.65) 10

Chemical Safety Requirements

  • 10 CFR 70.61 presents risk performance requirements which include requirements for acute chemical exposure resulting in high and intermediate consequences (70.61(b)(4) and 70.61(c)(4)).

- High consequence: initiated events that result in:

  • Could endanger life of a worker, or
  • Could lead to irreversible or other serious, long-lasting health effects to any individual

- Intermediate consequence: initiated events that result in:

  • Could lead to irreversible or other serious, long-lasting health effects to a worker,
  • Could cause mild transient health effects to any individual 8

Chemical Safety Requirements

  • 10 CFR 70.65 requires submittal of ISA Summary to support demonstration of compliance with performance requirements.

- 70.65(b)(7) requires a description of the proposed standards used to assess compliance with 70.61.

9

ISA Process Assess the Identify Identify Accident Identify Consequence Consequence Identify hazards Sequences and Likelihood

/likelihood for compliance IROFS 10

ISA Process

  • 10 CFR 70.61 Performance Requirements High consequence Highly Unlikely Yes STOP No Further Evaluation is Intermediate Credible Event? Needed consequence Unlikely Yes No Less than intermediate consequence

NRC Review of Chemical Safety

  • Overview:

Review of Chemical Hazards and Accident Consequences Review of Chemical Accident Likelihood Review of Quantitative Standards for Acute Chemical Exposures 15

NRC Review of Chemical Safety

  • Review of Chemical Hazards and Accident Consequences

- Description and nature of chemical hazards

  • Concentration, release point, receptor location, processes involved.
  • Vessel size, pressure, ventilation, building characteristics, meteorology, duration.

- Assessment of the consequences

- Credible scenarios identified in the ISA

  • Normal and abnormal conditions.

13

NRC Review of Chemical Safety

  • Review of Chemical Accident Likelihood

- High consequence events must be highly unlikely.

- Intermediate consequence events must be unlikely.

  • Quantitative Standards for chemical consequences

- When is a standard necessary?

- Consideration of physical and chemical properties.

- No toxicity or animal testing needed.

14

NRC Review of Quantitative Standards

  • The quantitative standards serve to identify the event consequence categories for the ISA.
  • When evaluating standards, NRC reviews the and expects a reasonable estimate of the consequences
  • Publicly available, useful sources identified

- AEGLs, ERPGs, TEELs and others.

- Globally Harmonized System of Classification and Labelling of Chemicals (GHS): Hazard Statements.

- NIOSH Skin Notations for dermal exposures.

15

ISG: Table 2 Conclusion

  • The NRC regulations use risk informed performance standards. Assessment of compliance with the performance standards requires a thorough identification of credible hazards.
  • New hazards may be introduced as the result of the introduction of new technology and/or new processes.
  • The NRC recognizes that new technology and processes may introduce new hazards and it is important that regulators and operators maintain the safety mindset and conduct thorough analysis and review of the new hazards.

18

Marilyn Diaz U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Fuel Cycle Safety and Safeguards, and Environmental Review Marilyn.Diaz@nrc.gov 301-415-7110 Questions?

19

Key Terms

  • CFR - Code of Federal Regulations
  • ISA - integrated safety analysis
  • IROFS - items relied on for safety
  • Subpart H - ISA requirements
  • AEGL - Acute Exposure Guideline Levels
  • ERPG - Emergency Response Planning Guidelines
  • TEEL - Temporary Emergency Exposure Limits 20

Key Terms

  • FCF - Fuel Cycle Facilities 21
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