Chemical/Nuclear Hazard Analysis

DOE-HDBK-1163-2003

EPA's Chemical Process Hazard Analysis (40 CFR 68, "Chemical Accident Prevention

Provisions," and 29 CFR 1910.119 [and 1926.64], "Process Safety Management"),

DOE's nuclear facility safety analysis (10 CFR 830, Subpart B, "Nuclear Safety

Management"),

Emergency Preparedness Hazard Assessment (DOE O 151.1, "Comprehensive Emergency

Management System", and

EPA's Environmental Impact Statements (40 CFR Parts 1500-1508, "Council on

Environmental Quality" and DOE's 10 CFR 1021, "National Environmental Policy Act

Implementing Procedures").

Chemical/Nuclear Hazard Analysis. Chemical process hazard analysis (PrHA) is required by

both OSHA (29 CFR 1910.119, and 29 CFR 1926.64) and EPA (40 CFR 68) for facilities

exceeding established hazardous chemical threshold quantities. These two chemical safety

regulations have essentially the same hazards analysis requirements (i.e., scope, techniques, and

required documentation), although there are slight variances in the threshold quantities for

various chemicals listed in each of these regulations. Both regulations also share similarity to 10

CFR 830, Subpart B that requires that a documented safety analysis (DSA) be prepared for

certain DOE nuclear facilities. The PrHA and the DSA serve as the primary analysis of facility-

level hazards, and both involve (1) identification of hazardous material or radionuclide

inventories; (2) implementation of formal hazard analysis techniques that are commensurate with

facility complexity; (3) identification of systems and equipment vital to safety; (4) formal

documentation of findings; and (5) periodic updates of hazard analysis information.

This overlap is recognized in DOE-STD-3009-94, Preparation Guide for U.S. Department of

Energy Nonreactor Nuclear Facility Safety Analysis Reports, which points out that many of the

requirements addressed in the OSHA PSM standard are directly parallel to DOE nuclear safety

analysis topics. Because of the apparent similarities, it is reasonable to conduct one

integrated hazard analysis at nuclear facilities at which all three regulations apply.

However, DOE goes beyond the PrHA requirements of OSHA/EPA by requiring DSAs to

evaluate potential consequences and estimation of the likelihood of accidents, both with and

without the aid of protective features (e.g., physical barriers, engineered controls, etc). Since a

DSA is more encompassing, it should be used as the primary vehicle for conveying the

results of an integrated chemical/nuclear hazard analysis at nuclear facilities.

Emergency Preparedness Hazard Assessment. The purpose of an Emergency Preparedness

Hazard Assessment (EPHA) is to help define a facility's emergency management plan and the

associated Emergency Planning Zone. The EPHA requires an evaluation of traditionally defined

"accidents" as well as those arising from external causes and malevolent acts. An analysis of

challenges to, and failures of, barriers protecting hazardous or radioactive materials is used to

determine the events and conditions that could result in the release of each hazardous material

and the magnitudes of those possible releases.

An EPHA is required by DOE O 151.1A, Comprehensive Emergency Management System, for

facilities exceeding certain chemical or radiological hazard thresholds. For hazardous chemicals,

this includes the lowest of Threshold Quantities (TQs) in 29 CFR 1910.119 (and 1926.64) or 40

CFR 68.130, or the Threshold Planning Quantities (TPQs) listed in 40 CFR 355. For chemicals

not listed, the Reportable Quantities (RQs) for hazardous substances listed in 40 CFR 302.4 may

be used. For radioactive materials, the limits are listed in 10 CFR 30.72, Schedule C.

Because of these thresholds, an EPHA is required for a broad set of facilities that encompass (1)

nuclear facilities subject to 10 CFR 830, Subpart B; (2) non-nuclear facilities subject to OSHA