Federal Regulation 10 CFR 851, which became effective February 2007, brought to light potential weaknesses regarding the Pressure Safety Program at the Pacific Northwest National Laboratory (PNNL). The definition of a pressure system in 10 CFR 851 does not contain a limit based upon pressure or any other criteria. Therefore, the need for a method to determine an appropriate risk-based hazard level for pressure safety was identified. The Laboratory has historically used a stored energy of 1000 lbf-ft to define a pressure hazard; however, an analytical basis for this value had not been documented. This document establishes the technical basis by evaluating the use of stored energy as an appropriate criterion to establish a pressure hazard, exploring a suitable risk threshold for pressure hazards, and reviewing the methods used to determine stored energy. The literature review and technical analysis concludes the use of stored energy as a method for determining a potential risk, the 1000 lbf-ft threshold, and the methods used by PNNL to calculate stored energy are all appropriate. Recommendations for further program improvements are also discussed
Revised: November 4, 2009 |
Published: August 25, 2009