1. Environmental Protection & Nuclear Safety Division
Requirements from French Nuclear Safety Authority on Beryllium activities
Joelle Elbez-Uzan
Environmental Protection & Nuclear Safety Division
ITER Organization

2. Licensing roadmap for staged approach
Be is very important for the staged approach licensing

3. 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 of 2 November 2007
INB order: Order dated 7 February 2012
Decisions ASN 2013-DC-0360
Other specific orders
ITER decree
Decision No DC-0379
RPrS
Impact Study
Answer to GP actions ….

4. General ASN regulations
Decree No 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.

5. 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.

6. 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 until to of ASN 2013-DC-0360.

7. General ASN regulations
Decisions ASN 2013-DC-0360 of the French Nuclear Safety Authority dated 16 July 2013
In particular, the article 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 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.

8. Other specific orders
Several other “decision” orders are applicable to ITER facility (e.g. “waste” decision order) will need to be further assessed.

9. Specific regulations for ITER site
ITER decree: Decree No 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

10. Specific regulations for ITER site
ITER decree: Decree No 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.

11. Specific regulations for ITER site
ITER decree: Decree No 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.
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.

12. Specific regulations for ITER site
Decision No 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.

13. 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.

14. 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.

15. 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 beryllium-qualified 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.

16. 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

17. 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.

18. 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.

19. 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

20. 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]

21. 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]

22. 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]

23. 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

24. 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.

25. 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]

26. 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-DC-0379]
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]

27. 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
Protecting gloves
Respirators
Others

28. 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]

29. 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]

30. Thank you for your attention!