Hazard Identification and Analysis - hdbk11392002vol20044

DOE-HDBK-1139/2-2002

disposal of the chemical. WSRC uses both in-house technical expertise and subcontracted technical

support to perform these functions.

The diverse technical staff of CCMC includes procurement specialists and degreed professionals in

Industrial Hygiene, Environmental Engineering, Chemistry, and Chemical Engineering. The CCMC

administers the site Chemical Procurement Program, the SRS Hazard Communication Program, and the

Excess Chemical Program. The CCMC develops any procedures required for sitewide implementation of

the CMP. It also has oversight responsibility on chemicals and chemical safety in activities ranging from

acquisition, to storage and use in the operating divisions, and redistribution through the Excess Chemical

Program. Federal, state, and local regulations, DOE directives, and Industrial Best Practices are used to

formulate site-level and facility-specific procedures. Individual line organizations and support personnel

are responsible for the various activities involving chemicals in their facilities, including disposal.

The CCMC is responsible for the Chemical Lifecycle Management homepage on the SRS Intranet. The

homepage lists the CCMC staff, the CMC representatives, and the chemical coordinators. Employees

with a chemical safety concern can quickly identify and reach any of the listed personnel. Other elements

on the homepage include chemical ordering information, chemical compatibility, transportation, disposal,

and excess chemical information; a link to the SRS MSDS database; links to useful information; policies

and procedures; SRS chemical hazard ratings; and target organ effect information.

2.1 Hazard Identification and Analysis

The "WSRC Facility Safety Document Manual" governs the requirements for safety basis documentation

for nuclear and non-nuclear facilities, using a graded approach to classify the facility hazard categories.

Typical safety basis documentation includes Safety Analysis Reports for nuclear facilities and Auditable

Safety Analyses for non-nuclear, (i.e., radiological and chemical) facilities. To evaluate chemical

hazards, the facility hazard classification is based on a comparison of the chemical inventory with

regulated quantities. These include the Reportable Quantities (RQs) listed under CERCLA (40 CFR

302.4), Threshold Planning Quantities (TPQs) per SARA (40 CFR 355), and Threshold Quantities (TQs)

per OSHA-PSM, 29 CFR 1910.119 (PSM Plan), and EPA-RMP, 40 CFR 68 (Risk Management Plan). A

high-hazard chemical facility that has chemical inventories equal to or exceeding any of the TQs, requires

a "Process Hazards Analysis" (as described in the OSHA-PSM) to satisfy both PSM and RMP rules. For

low-hazard chemical facilities with chemical inventories at or above the CERCLA RQs, but below the

TQs and TPQs, an Auditable Safety Analysis with administrative limits will suffice as the safety basis

documentation.

For new facilities and upgrades of existing facilities, process hazards associated with chemicals are

identified through the Process Hazards Review (PHR) program, beginning with the Preliminary PHR

during the conceptual design phase, followed by the Design PHR during the design phase, and finally, the

Preoperational PHR during the installation phase.

In the case of existing facilities, any change in the process or process chemicals results in a Screening

PHR that qualitatively evaluates the change for potential impact on worker safety, property loss, or offsite

releases to the public. If the Screening PHR results in a finding that the change may have an adverse

impact (by exceeding specific accident criteria) on safety or worker protection, a full PHR is performed to

identify existing protection and any additional safety measures to be implemented. Existing facilities

perform periodic PHRs to ensure that no existing hazards have been overlooked and no new hazards have

been introduced into the process since the last PHR. Non-process hazards (i.e., standard industrial

hazards) are covered in site procedures, for example, in the WSRC Employee Safety Manual and are not

included in the PHR. Job hazard analyses (JHAs) are developed, as necessary, to identify and mitigate

hazards associated with a clearly defined scope of work activity.