Perspectives on chemical hazard characterization and analysis process at DOE

Abstract

The United States (U.S.) Department of Energy (DOE) has a policy of Integrated Safety Management System (ISMS) that requires a hazard analysis and implementation of controls to protect the workers and public in an authorized hazard facility. The ISMS applies to all DOE facilities through DOE P 450.4, Safety Management System Policy , and DOE Acquisition Regulation (DEAR) clause 48 CFR 970.5223-1, Integration of Environment, Safety, and Health into Work Planning and Execution . However, no DOE-order or standard currently exists that provides specific guidance for the development of safety basis (SB) documentation for non-nuclear facilities. Various DOE sites over the years have adopted individual site-specific chemical SB processes and documentation resulting in wide variations across the DOE complex. The CSTC Phase 1 report, Current Chemical Hazard Characterization Practices in the DOE Complex summarizes the variations in the DOE complex (CSTC 2003-C). 1 In order to provide a common understanding of non-nuclear SB for chemical facilities, this report identifies various steps involved in developing a safety document that includes essential features of the five core steps of the ISMS. The SB development is an iterative process, but in general order of process completion, the listed steps for chemical, non-nuclear facility safety document are: • Facility and work description; • Hazard identification; • Facility hazard classification – industry Process Safety Management (PSM) based versus DOE traditional based high/moderate/low classification; • Hazard analysis – qualitative and/or semi quantitative; • Identification of controls; • Commitments to safety management programs (SMP); • Document and approval process. The non-nuclear SB process – (a) looks at different methodologies including hazard analysis from the chemical industry and DOE-STD-3009 nuclear facility-like approaches that can be used to implement each step, and (b) describes the advantages and disadvantages of various implementing methodologies that are either already in use or could be used by non-nuclear facilities. To note, this report is not a proposed standard or guidance for chemical, non-nuclear safety document. This report outlines various steps and methodologies together with advantages and disadvantages associated with them. Each DOE/NNSA facility or site can determine the appropriate course of action based on the merits and demerits of each approach. Adoption of any step of the safety document is voluntary. While intended for chemical, non-nuclear SB applications, the report may be useful in other related areas such as the emergency management program as required by DOE O 151.1C and explosive operations as required by 29 CFR 1910.109.