Accelerating Nuclear Facility Mission Completion Through an Improved Chemical Hazard Control Strategy - 20460
Code of Federal Regulation (CFR) 10 CFR 830, Nuclear Safety Management [1], explicitly identifies hazardous materials in addition to radioactive materials when establishing the scope of materials that must be evaluated in Hazard Category (HC) 1, 2, and 3 nuclear facilities. This inclusion has led to a near decade-long progression of more and more rigorous application of chemical hazard controls in these facilities. The progressive addition of more rigorous chemical hazard controls has occurred across the Department of Energy (DOE) Complex, having been driven by contractors and regulators alike. However, chemical hazards in other DOE facilities have been, and continue to be, controlled using traditional industrial safety centered strategies. Thus, identical chemical hazards are controlled using dramatically different approaches based solely on the facility type. Not only are the controls different, the analysis and derivation rigor and requirements are also significantly different. In particular, chemical control derivation and application in non-nuclear facilities are much less onerous than the comprehensive hazard analysis process used in nuclear facilities, even in circumstances in which chemicals are not initiators to, or do not exacerbate a nuclear event. While the derivation and control approaches used in these two types of facilities are disparate, the safety results are similarly effective based on a review of reported chemical events from 2014 through 2018. While both approaches achieve comparable safety outcomes, the approach used in nuclear facilities results in significantly greater preparation costs and implementation costs. Furthermore, the problem with the differing approach is not relegated to the control preparation and implementation burden. The operational impact of potentially unnecessary controls slows mission completion without a corresponding increase in safety, not to mention the dilution of the importance of Technical Safety Requirements. The proposed solution must first include a critical and thorough examination of DOE Complex and top-tier chemical industry chemical hazard control practices, coupled with a similar examination of the driving facility regulatory requirements. Results from the examination can then be used to fuel a bold departure from current chemical control practices in Hazard Category 1, 2, and 3 nuclear facilities. Development of an improved and consistent chemical hazard control process would follow, one that continues to ensure safety while accelerating mission completion and significantly reducing the burden associated with chemical hazard control development and implementation. The improved process must establish a hierarchy where radiological hazards are addressed using safety class and safety significant controls and chemical hazards are addressed using overarching safety management programs (with limited unique exceptions). The improved Hazard Category 1,2, and 3 nuclear facility chemical hazard control strategy, while compliant with 10 CFR 830 [1], would be founded on the requirements in 10 CFR 851, Worker Safety and Health Program [2], and the complementary DOE O 151.1D, Comprehensive Emergency Management System [3]. In this way, the Hazard Category 1, 2, and 3 nuclear facility chemical hazard control strategy would, wherever appropriate, be the same process used at other DOE Complex facilities. Ultimately, the improved process will maintain safety and significantly reduce costs and life cycle risk through faster mission completion. (authors)