Requirements from French
Nuclear Safety Authority on
Beryllium activities
Joelle Elbez-Uzan
Environmental Protection & Nuclear Safety Division
ITER Organization
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 1
Licensing roadmap for staged approach
Be is very
important
for the
staged
approach
licensing
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 2
French Nuclear Regulations/requirements
that are applicable for ITER Be activities
General ASN
regulations
Specific regulations
for ITER site
ITER DAC files
Answer to GP actions
 Decree No 2007-1557 of 2 November
2007
 INB order: Order dated 7 February 2012
 Decisions ASN 2013-DC-0360
 Other specific orders
 ITER decree
 Decision No. 2013-DC-0379




RPrS
Impact Study
Answer to GP actions
….
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 3
General ASN regulations
• Decree No 2007-1557 of 2 November 2007
– Any nuclear facility (INB) shall assess the impacts on the
“interests” mentioned in the article L593-1 of the Environment
code: health, security, public “salubrity”, nature and
environment protection.
– By this decree, ITER becomes an INB the day the preliminary
safety report is sent to the regulator, meaning in January 2008.
– Be impacts on the health and environment are subject to
this decree.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 4
General ASN regulations
• INB Order - Order dated 7 February 2012 relating to the
general technical regulations applicable to INB
– From the INB order article 1, it is clear that any activity related
to design, construction, operation, decommissioning,
surveillance and maintenance of activities related to protection
of the interests mentioned in the environmental code enters in
the scope of this INB order.
– Beryllium is concerned by these interests, since it can
affect the environment and health.
– From the title III in this order, the defence in depth principle
shall be implemented.
– The INB order establishes a list of internal and external
hazards to be considered in articles 3.5 and 3.6.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 5
General ASN regulations
• Decisions ASN 2013-DC-0360 of the French Nuclear
Safety Authority dated 16 July 2013
– The decision focuses on the control of pollution and the impact on
health and the environment of basic nuclear facilities
– The beryllium is an hazardous substance due to its impact on
health and environment, so the decision is applicable
– The title II related to water sampling, effluent discharges and transfer
in the air/water provides technical data. The process of Beryllium
during assembly and storage could lead to production of liquid and
gas effluents contaminated by beryllium mainly due to plates cleaning
process. These INB articles 3.5 and 3.6 provide requirements in
terms of collection, treatment, transfer and discharge of effluents
mainly articles from 2.3.5 until to 2.3.13 of ASN 2013-DC-0360.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 6
General ASN regulations
• Decisions ASN 2013-DC-0360 of the French Nuclear
Safety Authority dated 16 July 2013
– In particular, the article 2.3.13 requires having a stack design in order
to have a good atmospheric diffusion of releases airborne effluents in
order to avoid their re-use in neighbouring installations. The stack
height cannot be lower than the one resulting from the calculation in
appendix 1 of the decision.
– Additional monitoring of effluents under aerosol form as well as under
a potential liquid form is to be performed as per title III.
– It is specified in article 4.1.1 that the facilities shall be designed,
constructed, operated, decommissioned, dismantled, maintained and
monitored in such a way as to prevent or limit the direct or indirect
discharge of substances likely to cause pollution in the receiving
environment or sewage systems.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 7
Other specific orders
• Several other “decision” orders are applicable to ITER
facility (e.g. “waste” decision order) will need to be
further assessed.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 8
Specific regulations for ITER site
• ITER decree: Decree No. 2012-1248 dated 9 November 2012
authorising ITER Organization to build the licensed nuclear facility
called ITER in Saint-Paul-lez-Durance
– Article III-1:
The design, construction and operation of the facility shall control the
risk of spreading hazardous substances, such as radioactive substances
or beryllium, within the facility or its environment, during normal
operation and in incident or accident conditions.
Confinement of Be is a basic safety function
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 9
Specific regulations for ITER site
• ITER decree: Decree No. 2012-1248 dated 9 November 2012
authorising ITER Organization to build the licensed nuclear facility
called ITER in Saint-Paul-lez-Durance
– Article III-1:
The confinement of hazardous materials shall consist of two systems, based on
two confinement methods: static and dynamic:
1. A first system, located as close as possible to the materials, provided in
particular by the tokamak vacuum vessel and its extensions, the tritium
processes, the maintenance hot cells and the associated ventilation systems as
necessary.
2. A second system designed to limit releases into the environment, provided by
the walls of the rooms and buildings and the associated ventilation systems as
necessary.
In the parts of the facility where a risk of spread of dangerous materials
exists, ventilation system provisions ensure a negative pressure
cascade compared to atmospheric pressure.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 10
Specific regulations for ITER site
• ITER decree: Decree No. 2012-1248 dated 9 November 2012
authorising ITER Organization to build the licensed nuclear facility
called ITER in Saint-Paul-lez-Durance
– Article IV-1.7:
Concerning beryllium in particular, the operator shall set up:
1. Beryllium zoning upon receipt of this substance on site.
2. Dual confinement system mentioned in III.1 of this article, which is designed
to limit the spread of beryllium.
3.
Stationary and mobile means of atmospheric testing in work areas located in
“beryllium controlled areas”.
– Article V-5:
Before producing any waste, the waste disposal outlets will be identified during
the operation and dismantling phases for each waste type, particularly for waste
containing tritium, beryllium, tungsten and molybdenum-93.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 11
Specific regulations for ITER site
• Decision No. 2013-DC-0379 issued by the French
Nuclear Safety Authority on 12 November 2013
– I.6.3 Beryllium risks
I. The operator must provide all those who are potentially exposed to beryllium
with personal protective equipment as soon as the equipment or materials
containing this substance have been received.
II. The protective devices against beryllium are subject to suitable qualification, as
well as regular inspections to check their operation.
III. The operator must monitor the beryllium atmospheric concentration and
surface contamination, as well as making any necessary changes to the zoning
strategy.
IV. Prior to receiving this element onsite during the construction or assembly
phase, the operator must provide the relevant staff members with training on the
risks associated with beryllium.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 12
Reminder of regulator requests during the
initial safety licensing process
From GP safety option file report (2002)
• The operator will have to present (…), in particular for
Beryllium, the maximum quantities present in the facility,
where they are located, their physical and chemical forms,
their potential to be spread, and
bring all necessary
substantiations.
• Considering the toxicity risk associated with Beryllium, the
confinement concept is applicable to Beryllium.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 13
ITER RPrS
• Beryllium zoning will be applied during all phases, starting with
the construction phase and the safe transportation, delivery and
storage of beryllium on the ITER site.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 14
ITER RPrS
• Worker protection provisions will be the following for
beryllium-relevant zones:
– when the zone has been identified as a beryllium-controlled
zone:
• access is limited only to beryllium qualified personnel,
• specific medical monitoring will be associated with this berylliumqualified personnel,
– beryllium monitors will be implemented in the rooms with the
main risks,
– when the zone has been identified as a breathing protection
zone (above 0.2 μg/m3), then the same provisions are
considered as for beryllium-controlled zones, adding the
following requirements:
• air breathing masks will be required for personnel entering these
zones,
• the zones will have higher air renewal rates.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 15
ITER RPrS
• In addition, ITER will apply safety defence-in-depth principles in
order to optimize beryllium occupational exposure:
•
Prevention
Detection
Mitigation
•
•
limiting the operations in which workers can be exposed (e.g.
limiting beryllium machining preparations)
implementing beryllium zoning
implementing a confinement system in the rooms or zones in
which beryllium may be spread in order to avoid personnel
exposure, e.g. implementation of specific mobile or fixed
confinement systems such as ventilated airlocks
(depressurization and filtration)
• fixed or mobile detectors implementation in the rooms
liable to be exposed to beryllium spread
• regular air sampling or smear measurements
• specific air breathing systems in the air breathing zones
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 16
ITER RPrS
• Only atmospheric releases of beryllium are expected in
ITER (for liquid see slide 26).
• The potential release (stack height 58m) of airborne
beryllium is estimated at:
– during the construction and assembly phase: 6 g
– during the operation phases: 1.5 g
• The actual release should not exceed the values
estimated in the RPrS.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 17
Answer to GP action - Personal
Protective Equipment
• Provisions to avoid contamination rely on
– Collective measures
•
•
•
•
Beryllium containment (static, dynamic)
Beryllium zoning
Access control
Beryllium monitoring and detection
– Individual measures (adequate to the level of risk)
•
•
•
•
•
Protective clothing
Eye protection
Protecting gloves
Respirators
Etc.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 18
Reminder of Safety provisions required by
ASN regulations against Be risks
• To summarize, the following requirements for Beryllium
apply:
Confinement of
Beryllium
Beryllium zoning
Resistance to
internal and
external hazards
Protection of
workers;
training
Monitoring of
Beryllium
Beryllium waste
management
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 19
Reminder of Safety provisions required by
ASN regulations against Be risks
• Confinement of Beryllium
– The confinement of beryllium is a fundamental safety function,
that shall be ensured for the design, construction and
operation of ITER activities and for both inside the facility as
well as outside the facility, for normal incidental and accidental
situations. [ITER decree]
– This function shall be designed through the implementation of
a defense in depth principle. [INB order]
– The confinement of Beryllium shall be ensured by two
confinement systems, based on static and dynamic
confinement. [INB order]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 20
Reminder of Safety provisions required by
ASN regulations against Be risks
• Confinement of Beryllium
– In the parts of the facility where a risk of spread of dangerous
materials exist, ventilation system provisions ensure a
negative pressure cascade compared to atmospheric
pressure. [ITER decree]
– According to the appendix 1 of the “environment decision”, the
stack height shall be calculated with regards to the chemical
releases and considering an over-height imposed by the
distance to the surrounding buildings and their height. [ASN
decision]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 21
Reminder of Safety provisions required by
ASN regulations against Be risks
• Beryllium zoning
– A Beryllium zoning is implemented when Beryllium comes on
site, with fix or mobile atmospheric monitoring inside Beryllium
controlled zones. [ITER decree]
– Beryllium zoning will be applied during all phases, starting with
the construction phase and the safe transportation, delivery
and storage of beryllium on the ITER site. [ITER RPrS]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 22
Reminder of Safety provisions required by
ASN regulations against Be risks
• Resistance to internal hazards
projectile
emissions
pressure
equipment defects
collisions and load
drops
explosions
fires
emissions of
dangerous
substances
flooding
EMC
Malicious acts
Any other internal
hazard that the
regulator may ask
to consider
Combination of
these hazards
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 23
Reminder of Safety provisions required by
ASN regulations against Be risks
• Resistance to external hazards:
– risks induced by industrial activities and communication circuits, including
explosion, emissions of dangerous substances and aircraft dropping
– earthquakes
– lightening and associated EMC
– extreme meteorological or climatic conditions
– fires
– floods originating outside the INB perimeter, including their dynamic effect
– malicious acts
– any other external hazard that the regulator may ask to consider
– combination of these hazards [INB order]
All these hazards shall be considered. It does not mean that the design shall cope with
all these, but at least to assess its resistance level to each of these hazards and their
combinations.
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 24
Reminder of Safety provisions required by
ASN regulations against Be risks
• Resistance to internal and external hazards:
– These hazards shall be assessed based on the defense in
depth principle, to prevent and detect incidents, and to avoid
that these incidents become accidents, to recover the
situations up to normal situations or at least to maintain a safe
state, to control and mitigate accidents and to manage the
accident situations to limit consequences to persons and
members of the public. [INB order]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 25
Reminder of Safety provisions required by
ASN regulations against Be risks
• Worker protection, training
– The operator provides to potentially exposed persons individual
provisions
against
Beryllium,
since
the
reception
of
components/equipment including Beryllium [Decision n°2013-DC0379]
– Provisions against Beryllium shall be adequately qualified, as well as
submitted to periodic tests [Decision n°2013-DC-0379]
– Before reception of beryllium on site during construction/assembly
phase, the operator trains the persons likely to be exposed a training
on Beryllium risks [Decision n°2013-DC-0379]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 26
Reminder of Safety provisions required by
ASN regulations against Be risks
• Worker protection, training
– Individual measures (adequate to the level of risk)
Protective
clothing
Eye
protection
Others
Respirators
Protecting
gloves
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 27
Reminder of Safety provisions required by
ASN regulations against Be risks
• Beryllium monitoring
– A Beryllium zoning is implemented when Beryllium comes on
site, with fix or mobile atmospheric monitoring inside Beryllium
controlled zones. [ITER decree]
– The operator implements a monitoring of atmospheric and
surface contamination of Beryllium and modify if necessary the
Beryllium zoning [Decision n°2013-DC-0379]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 28
Reminder of Safety provisions required by
ASN regulations against Be risks
• Beryllium waste management
– The waste management requires that before any production of waste
to identify how to process these waste, in particular Beryllium waste,
and to limit as far as possible and using best techniques at
economically acceptable the waste volumes stored before evacuating
them. [ITER decree].
– Only atmospheric releases of beryllium are expected in ITER. Plasma
operations do not generate beryllium in liquid form. However, it is
perhaps possible that liquid beryllium will be created in the beryllium
laboratory in order to carry out beryllium measurements. Specific
procedures will be put in place in order that liquid beryllium samples
are not released in the industrial effluents (due to agreement with
CEA) and that they are captured and transferred for a specific waste
treatment. The same process of capture will be used for the first
rinsing water. Subsequent rinsing water may be released after
monitoring as an industrial effluent. [RPrS]
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 29
Thank you for your attention!
Workshop on Beryllium Applications and Health & Safety, ITER Organization
June 28-30, 2017
Page 30