ML18128A170
| 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) | |
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
- HF - Hydrogen Fluoride
- 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