ML20024A488

Forwards Response to Accident Evaluation Branch Draft SER, Per 830525 Meeting Request.Draft Page Changes Will Be Included in FSAR Rev Scheduled for Jul 1983

ML20024A488
Person / Time
Site:	Limerick
Issue date:	06/14/1983
From:	Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8306170369
Download: ML20024A488 (17)

Text

e PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101

/f EDW A R D G. B AU ER, J R.

a o oness a6coupesak EUG EN E J. BR ADLEY assoconta esnanas cousssat DON ALD BLANKEN CUDOLPH A. CHILLEMI (L C. KIRK H ALL T. H. M A H E R C#J RN ELL PAUL AUERB ACH assesTANY GmNanak Coupesab CDW ARD J. CULLEN, J R.

THOM AS H. MILLER, J R.

' " " " ' ^ " * * ' " " ^

June 14 1983 assesvan? counsso S

Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555

SUBJECT:

Limerick Generating Station Units 1&2 NRC Draft Safety Analysis Report (DSER)

Open Review Items from the Accident Evaluation Branch (AEB)

REFERENCE:

(I) Letter, A. Schwencer to E. G. Bauer, Jr., Dated March 11, 1983 (2) May 25, 1983 Meeting between AEB and Philadelphia Electric Co., Bethesda, Maryland FILE:

GOVT l-1 (USNRC)

Dear Mr. Schwencer:

The reference (1) letter transmitted, among others, four AEB open review items related to control room habitability, the resolution of which were discussed at the reference (2) meeting. This letter transmits the information requested by AEB at the reference (2) meeting to resolve these open review items, as follows:

AEB 1:

FSAR Table 15.10-3 is being changed (enclosure 1) to provide the clarification necessary to resolve this item.

AEB 2 & 3:

FSAR Section 2.2 is being changed (enclosure 2) to provide the information requested by AEB at the reference (2) meeting to resolve these items.

8306170369 830614 PDR ADOCK 05000352 g ll E

PDR

AEB 4 :

FSAR Section 6.4.4.2.3 is being changed (enclosure

3) to provide the information requested by AEB at the reference (2) meeting to resolve this item.

The information contained in these draft FSAR page changes will be incorporated into the FSAR, exactly as it appears in the enclosures, in the revision scheduled for July, 1983.

Very truly yours, Euge5e J.' Bra ey HDH/cw/30 Enclosures Copy to:

See Attached Service List l

l l

I

,4 cc: Judge lirarence Brenner (w/o enclosure)

Judge Richard F. Cole (w/o enclosure)

Judge Peter A. Morris (w/o enclosure)

Troy B. Conner, Jr., Esq.

(w/o enclosure)

Ann P. Hodgdon (w/o enclosure)

Mr. Frank R. Bcmano (w/o enclosure)

Mr. Robert L. Anthony (w/o enclosure)

Mr. Marvin I. Icvis (w/o enclosure)

Judith A. Dorsey, Esq.

(w/o enclosure)

Charles W. Elliott, Esq.

(w/o enclosure)

Jacqueline I. Ruttenberg (w/o enclosure)

'Ihcmas Y. Au, Esq.

(w/o enclosure)

Mr. 'Ihcmas Gerusky (w/o enclosure)

Director, Pennsylvania Emergency Managsaent Agency (w/o enclosure)

Mr. Steven P. Hershey (w/o enclosure)

James M. Neill, Esq.

(w/o enclosure)

Donald S. Bronstein, Esq.

(w/o enclosure)

Mr. Joseph H. White, III (w/o enclosure)

David Wersan, Esq.

(w/o enclosure)

Bobert J. Sugarman, Esq.

(w/o enclosure)

Martha W. Bush, Esq.

(w/o enclosure)

Atcmic Safety and Licensing Appeal Board (w/o enclosure)

Atcmic Safety and Licensing Board Panel (w/o enclosure)

Docket and Service Section (w/o enclosure) l l

l

Es/CLOSURd $, 9%. ll1 e

e.

IMS FSAR TABLE 15.10-3 BREATHING RATES M WSt% Dense Call'MEnOMG TIME PERIOD BREATHING RATE (hr)

(m3/sec) 0-S 3.47 x 10-*

8 - 24 1.75 x 10-*

24 - 720 2.32 x IO-*

x i

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hiY ASAllC 2., Re. llIl

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CHAPTER 2 TABLES (Cont'd)

Title Table c

2.2-4 Airways Within 10 mil'es of the Site

(

2.2-5 Onsite Chemical Storage i

Re Memhde Potentially Hazardous Chemicals,4'yny *--

_ f_____.

r _

2.2.6

___ n...... :...

n-Comparison of Annual Wind Direction Frequency 2.3.1-1 s

Distribution (%)

2.3.1-2 Mean' Monthly Temperature Comparison (*F) 2.3.1-3 Comparison of Mean Morning and Afternoon Relative Humidity 2.3.1-4 Distribution of Precipitation, Philadelphia International Airport Distri utio'n\\of Precipitation, Allentown Airport 2.3.1-5 2.3.1-6 MeanNumberlofThunderstormDaysperYear 2.3.1-7 Limerick Generating Station Design Basis Tornado Parameters 2.3.1-8 Limerick Generating Stadion; Vertical Profile of the 100 Year, Recurrence Interval, Fastest Mile of the Wind,

2.3.2-1 Limerick Generating. Station Percent Data Recovery for. Meteorological Sensors 2.3.2-2(*)

Weather Station No. 1, Annual Wind Distribution Brookhaven Turbulence Class, January 1972 to December 1976 2.3.2-3(*)

Weather Station No. 1, Monthly Wind Distribution Brookhaven Tur_bulence Class, January 1972 to December 1976 2.3.2-4(*)

Weather Station No. 1, Annual Wind Distribution NRC Lapse Rate Stability Class, 266-26 ft Height l-Interval, January 1972 to December 1976 These tables are provided separately from the FSAR.

l

(*)

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Rev.[,

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2-vi

6 N c kan M 6' 2.,

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.that the larger of the two lines (2'0") ruptures at the point J

'where the pipeline passes closest to the-Unit 2 reactor (approximately 3000 feet).

It is further. assumed to be a double-ended rupture (complete separation of the pipe at the point of rupture).

A portion of the cloud downwind within flammable limits is The radiant heat load at the cssumed to ignite and deflagrate.

Unit 2 reactor enclosure is calculated to be about 70 Btu per equare foot per hour (Ref. 2.2-5) for a short time.

This level i

would cause a slight warring of the outer layer of concrete.

i 2.2.3.1.3 Exposure to Hazardous Chemical Releases Exposure of control room personnel to hazardous chemical vapors could potentially result from an accident involving a chemical Such spills could occur on the rail line, one of several epill.

highways close by, nearby industrial faci'lities, or from onsite A chemical is considered a potential hazard if chemical storage.

that its it is stored or transported nearby in such quantities concentration at the control room air intake following a spill Acceptable 4g could. exceed the toxic incapacitation concentration.

if toxic incapacitation levels were based on compliance with the L

Regulatory Guide 1.78 requirement of 2 minutes for operator incapacitation models protective action, NUREG/CR-1741 OSHA exposure limits, and ACGIH concentrat (Ref. 2.2-8),

criteria.

Potential chemical hazards were identified by first compiling a list of toxic chemicals that could pose a vapor h'azard based on Regulatory Guide 1.78, NUREG-0570, and other sources.

Surveys

. were conducted to determine which of these are actually stored or

' shipped within 5 miles of the Limerick site, with what frequency, and in what quantities.

For the railroads, Conrail provided l

information on which of these are shipped.

Shipment frequency and quantity for those checirals determined to be a hazard to Per control room operators are indicated in Table 2.2-6.

chemicals shipped less than 30 times per Regulatory Guide 1.78, For the highways, no centralized year are disregarded.information source exists to determine what* chemicals ar A manufacturers and users survey was therefore shipped.

conducted to ascertain potential shippers and receivers of hazardous chemicals.

Various directories were used to identify such manufacturers in Pennsylvania and the surrounding states and Based on geographic location, competing users in the local area.

highways, and direct routes, those manufacturers and users who

,'I" n$q would reasonably use the three highways near the site were 2.2-7 Rev. 18, 03/83

E M cL o. star E 2, A 3[ tl

' LGS FSAR contacted regarding chemicals shipped or received, routes, and container sizes.

An analysis was then conducted to determine which of these chemicals, if spilled, could exceed toxic j

These are listed in incapacitation levels in the control room.

Table 2.2-6, along with centainer sizes.

The analysis assumed complete release of the contents of a single containe'r or tank.

In accordance with Regulatory Guide 1.78, it was assumed that after an initial puff of vapor, any remaining The methodology liquid spreads over the ground and evaporates.

of Regulatory Guide 1.78 and NUREG-0570 was used to model the initial puff and subsequent plume transport and dilution to the control roon air intake.y g

The consequences of an accidental release of phosgene gas, a combustion product of vinyl chloride, resulting from a fire in conjunction with an accident involving spillage of vinyl chloride The phosgene concentration in the control were also evaluated.

room was calculated using the models of NUREG-0570 and the heat rise models of J.A. Briggs (Ref.2.2-9).

Chemicals stored onsite include carbon dioxide, chlorine, nitrogen, and sulfuric acid, in quantities and at locations

(

listed on Table 2.2-5.

Analysis of accidents involving onsite chemicals resulted in identification of chlorine spillage as potentially hazardous to control room personnel.

As a result of the analyses, 6 potentially hazardous chemicals e

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were identified, as listed on Table 2.2-6.

The Limerick toxic chemical analysis complies with the intent of o

4 Regulatory Guide 1.78.

The analysis goes beyond the nethodologies outlined in this guide in the following areas:

In addition to the chemicals listed on Table C-1 of Regulatory Guide 1.78, other chemicals were investigated a.

to determine if potential hazards existed.

A total of 153 chemicals were evaluated, The models of NUREG-0570 were used to determine the b.

concentrations of hazardous chemicals in the control room.

The more stringent TLV levels were initially used instead of the Regulatory Guide 1.78 Table C-1 toxicity c.

limits to de: ermine which chemicals were potentially TELle C-2 of Regulatory Guide 1.78 was not hazardous.

used to determine which chemicals were hazardous.

, 43 2.2-8 Kev.g, /3

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The control room concentrations were determined using the following control room parameters:

a.

Control room envelope volume of 126,000 ft3, as defined in Section 6.4.2.1 b.

2100 cfn of incoming / outgoing air, based on the design outside air flow rate supplied by the normal control roon as described in Sections 6.4.3.1 ind 9.4.1.1.

HVAC systen,

air intake 36.5 neters above ground, as indicated c.

on Figures 1.2-27 and 6.4-2 d.

inleakage rate of 0.25 air changes per hour, during isolation, as discussed in Section 6.4.2.3 40 seconds time delay in the ductwork ye wap the yg e.

the control room intake 5hd the isolation the entry into the control [oom air space, detectors at r

valve at based on the air velocity in the duct during normal operation.

T-45/30(6/83)

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.I N M R T.2 P4. z. 2 - D As a result of the analyses, 6 potentially hazardous chemicals requiring nonitoring were identified, as listed on Table 2.2-6.

A brief description of each chemical and its effects on humanf/or laboratory animals are presented below:

Annonia, NH3 Annonia is a colorless gas with sharp, intensely irritating odor.

It has an odor threshold of 46.8 ppm for humans (Ref. 2.2-13).

Complaintf levelsof 20-25 ppm were first observed.

Human effects such as eye irri~tation sometimes with lacrimation, nose, throat and chest irritation (coughing, edema of lungs) were found at concentrations up to 700 ppm, depending on exposure time (Ref. 2.2-10, 2.2-11 & 2.2-12).

The chemical then becomes lethal starting at 2,000 ppm concentration even for exposures at very short duration (Ref. 2.2-10).

Chlorine, C12 It Chlorine in its gaseous form is greenish-yellow in color.

has a disagreeable, suffocating and irritating odor readily 3-5 ppm.

Its effects on hunans depend on the detectable at concentration.

Irritant effects to eyes, nose, throat and/or f ace were noted at low concentrations.

Effects on the upper and lower respiratory tracts and pulmonary edema were reported on exposures at high concentrations.

It becomes highly dan-gerous to be exposed for 30 minutes at 40-60 ppn, fatal at concentrations of 833 ppm if breathed for 30-60 minutes and r

rapidly fatal after a few breaths at 1,000 ppm (Ref. 2.2-10).

There were reports on effects of concentrations around 5 ppm c^"cri ng respiratory complaints, corrosion of teeth,

,__inflannation of mucous membranes of nose and increased tuber-E C$

culosis susceptability (Ref. 2.2-14).

CH0 Ethylene Oxide, 24 is a colorless gas, Ethylene Oxide, a suspected carcinogen, l

sickening and nauseating at moderate concentrations and irritating at high concentrations.

Humans exposed even to low concentrations showed delayed nausea and vomiting and at Inhala-continued exposure, numbing of the olfactory sense.

tion at high concentrations resulted in general anesthetic irritation of eyes effects as well as coughing, vomiting and and respiratory passages leading to emphysema, bronchitis and (Ref. 2.2-10).

The lowest toxic concentration pulnonary edema by inhalation on humans is 12,500 ppn for 10 ninutes with irritant effects observed only (Ref. 2.2-12).

Odor threshold is 50 ppm for this chemical (Ref. 2.2-13).

T-45/30(6/83)

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EHCLod 2.,

W.. Grlff Fornaldehyde, HCHO Fo rnaldehyde, a suspected carcinogen, is detectable by most people at levels below 1 ppm from References 2.2-11 and 2.2-14, 0.8 ppn f rom Ref erence 2.2-13.

Humans experienced irritant effects on the eyes, nose, throat and upper respiratory tract at concentration ranges of less than 1 ppm to 12 ppn.

At high concentrations, a severe respiratory tract irritation which lead to death was reported on humans (Ref. 2.2-14).

Inhala-tion study on rats and mice showed that formaldehyde has a carcinogenic effects on rats.

Rats developed nasal cavity squanous cell carcinonas after 12-24 months' exposure to 15 ppn and with deaths during this period.

Fatalities on rats were observed also at exposures to 81 ppn concentration (Ref. 2.2-14).

Vinyl Chloride, CH2 CHCl Vinyl chloride is a colorless, highly flannable gas at roon temperature and atmospheric pressure with a pleasant, sweet odor at high concentrations (Ref. 2.2-10).

It is toxic and evidence has shown it to be a carcinogen to persons exposed over extended periods of time (Ref. 2.2-10).

Exposure through inhalation at 200 ppn for 14 years showed occurrence of tumors on hunans, carcinogenic effects at 500 ppn for 5 years (Ref. 2.2-12).

At concentrations above 1,000 ppn, vinyl chloride was reported to slowly effect mild disturbance on hunans such as drowsiness, blurred vision, staggering gait, and tingling and nunbness in the hand and feet (Ref.

2.2-10).

The odor threshold for this chemical is 260 ppm (Ref. 2.2-13).

Phosgene, COCl2 Phosgene is a colorless, nonflannable, highly toxic gas at ordera<v temperature and pressure and with a musty hay like ' odor detectable at 0.5 to 2 ppm.

ft is a strong lung irritant and causes damage to the alvepli of the lungs.

Inhalation of phosgene produces catching of breath, choking, innediate coughing, tightness of the chest, o

lacrifation, difficulty and pain in breathing and cyan / sis (Ref. 2.2-10).

Humans experience throat irritation at 3 ppn, innediate eye irritation at 4 ppn and coughing at 4.8 ppn.

Brief exposure at 50 ppm may be rapidly fatal (Ref. 2.2-11).

T-45/36(6/83)

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To insure adequate protection of control room personnel, control room operators will be trained and periodically tested on their ability to put on breathing apparatus witWn2 ninutes after initiation of the toxic chenical alarm.

Subsequently, the operators will manually isolate the control room as described in Section

6. 4. 3. 2.3.

If chlorine is detected, automatic isolation of the control room occurs as described in Section 6.4.3.2.1.

T-45/36(6/83)

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d.

Potentially-hazardous chemicals were re-evaluated using the incapacitation models of NUREG/CR-1741 (Ref. 2.2-8) to determine if control room operations would be incapacitated.

This analysis is an amplification of Regulatory Position C.4 of Regulatory Guide 1.78.

2.2.3.1.4 Fires In addition to the flammable vapor clouds discussed earlier, fire hazards may also exist due to a burning tank car on the railroad, a fire subsequent to a ruptured pipeline, or a nearby forest / brush fire.

Potential adverse effects of such fires are radiant heat load on plant structures and smoke generation.

i To estimate the' effects of a railroad fire, an accident is hypothesized in which a railroad tank car derails, ruptures; and releases a cargo of 62 tons of liquified propane.

A 62-ton car is typically the largest size used for propane, and from a fire standpoint liquified propane represents one of the most severe-materials transported by rail.

The site of the hypothetical 9

derailment.is the closest point of approach to the Unit 1 reactor enclosure, about 600 feet.

The tank car propane is assumed to be released into the drainage ditch alongside the eastern side of 1

the right of way, where it pools and is subsequently ignited.

The vapor pressure of liquid propane is s~ufficiently high at ambient conditions that there will be an adequate supply of gaseous propane for ignition, after which the fire is self-propagating.

The fire duration is assumed to be 20 minutes, based on experience with this material.

Assuming 19,600 Btu per pound of propane and 62 tons being consumed in 20 minutes, the radiant heat load on the reactor enclosure may be calculated using the relationship (Ref 2.5-5):

1/2 D = (F0/12.57K)

(2.2-1) where:

D=

distance, feet F=

fraction of heat that is ra31 ant O=

heat release, Btu per hour E=

radiation load, Btu per square foot per hour The result of this calculation indicates a radiant heat load of approximately 500 Btu per square foot per hour for 20 minutes at

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2.2-9 Rev.

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_ _ _ _ _,.. _. _ _ _ _ _ -. _. _ _. _. ~. _ _ _ _.. ~.. _.

'stt6 2. M. 4/n WS TSAR

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i b.

Toxic Chemical Spill 1.

Control Room - detection and isolation capability I

is,provided for the 6 chemicals identified as constituting a hazard, as discussed in Section 6.4.

2.

Diesel Generators - The manufacturer of the emergency die'sel gener'ators h&s determined that the chemicals identified in Tables 2.2-5 and 2.2-6, when present in concentrations and for time spans calculated using the methodology described in Section 2.2.3.1.3, would have no adverse effects on diesel generator operation.

Propane tank car. fire - the radiant heat load from such c.

a fire is evaluated as having no adverse effect on safety-related structures.

The bulk of the heat load would be absorbed by the pre-cast panels on the face of the structures, which do not serve a safety function.

d.

ARCO pipeline fire - smoke detectors in the control room intake alarm, and the operator can manually isolate the control room ventilation system, as discussed in Section 9.4.1.

2.

2.4 REFERENCES

2.2-1 Department of the Army, Navy, and Air Force,

~

Structures to Resist the Effects of Accidental Explosions, TH5-1300, June 1969.

United States Nuclear Regulatory Commission, Safety 2.2-2 Evaluation Report, Hartsville Nuclear Plants, Dockets STN 50-518 through STN 50-521 (April, 1976).

2.2-3 N. 1. Sax, Dancerous Properties of Industrial Materials, 4th Ed., Van Nostrand Reinhold, New York (1975).

M.G. 2abetakis, Safetv with Cryocenic Fluids, 2.2-4 March 1967.

I Rev. 19, 04/93 2.2-12 s.

EsKlo.snet,C 3, 9%.10/ft LGS FSAR l.

2.2-5 American Petroleum Institute, Guide for Pressure Relief and Depressurina Systems, API RPS21, September, 1969.

2.2-6 American Conference of Governmental Industrial Hygienists, TLV's, Threshold Limit Values for Chemical Substances and Physical Acents in the Workroom Environment with Intended Chance for 1978..

2.2-7

. United States Environmental Protection Agency, Compilation of Emission Factors, AP 42, 3rd Ed.,

f (July, 1979).

2.2-8 NUREG/CR-1741, "Models for the Estimation of Incapacitation Times Following Exposures to Toxic Gases or Vapors", Gordon J. Smith, David E. Bennet, Sandia National Laboratories, Dec. 1980.

i 1

l l

2.2-9 D.H. Slade, Meteorolooy and Atomic Eneroy 1968, U.S.

l Atomic Energy Commission, July 1968.

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LGS FSAR

'IABLE 2.2-6 A6es45AENir A%dWF10A3W6 POTENTIALLY HAEARDCUS CHEMICALS _.,.,,.....____..A___..........-_.-..

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Rail 500-1000 54 tons / carload Chlorine 0*8 2D 73?

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Storage / Rail 500-1000 74 tons / carload Ethyls'ne Omide do 120

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Rail 500-1000 75 tons / carload 40 9.4

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500-1000 92 tons / carload Vinyl Chloride

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Phorgene 0,4 320 cas ca3 Rail shipments are average weights. No additional chemical hasards were identified when the maximum weight of 90 tons / carload was considere8.

<=3 Phosgene is a combustion product of vinyl chloride.

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If the concentration of any monitored gas should exceed the selected limits, alarms will be automatically triggered at the I

l analyzer and annunciated in the control room.

In addition to the concentration alarms, the system will indicate any malfunction related to electronics, optical system or loss of flow by local indication.

The equipment has built-in test features.

A part of the self-test program is automatically performed each. time the analyzer is zeroed.

The complete functional test can be requested by the operator.

Calibration of the detection system can be verified at any time by using a closed loop calibration system.

No special maintenance is required.

6.4.4.2.3 Respiratory Protection StTr$ M OAJr #0c/g f

( pre ~S5v R E D6'h94Mo Full-faced self-contained breathing apparatusj and protective j

clothing at'e available for control room operat. ors.

hspiatory uipm tdes/gnsadcapbili es ar cons antly imp ving.

or t s rea(on, s ecifi equi ment s no yet be n se cted f r Lir ick.

4 hen pecif'c equ pment s s'e

eted, I

e nsidera ion w' I be iven o the e imp ovemen. s. a well a to).

eliabi tv, d abili an serv' eabi ' tvI T1e number of l

respiratory devices shall, as a minimum, provide a six hour air supply for six individuals.

Consistent with the provisions of Regulatory Guide 1.95, one extra respiratory device will be l

provided for every three devices needed to meet the minimum capacity.

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A six hour onsite bottled air supply is provided by charged cylinders maintained for backup fire protection and health physics use.

Offsite replenishment is provided by compressors (fill capacity greater than 30 cylinders per hour) located at the Barbadoes and Peach Bottom Stations of PECo, located approximately 16 miles and 50 miles, respectively, from Limerick.

Rev.[.

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Control room operators are included in the provisions of th'e Respiratory Protection Program.

The Respiratory Protection Program includes training in the method of donning the equipment, proper use and care of the equipment, equipment limitations, and verification of individual capability to achieve and maintain a proper facial seal.

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cf +'- - rri--'-- -!*M a *m gr A program for periodic inspection of control. room operator respiratory equipment will be established.

The program will address inspection for defects, storage conditions, and, as found l

l to be necessary, cleaning, disinfecting, and repairing.

In addition, the equipment will be cleaned, disinfected, and inspected after each use.

Replacements and repairs will be done only by trained personnel using parts' designed for that l

equipment.

The equipment will be stored to protect against dust, I

sunlight, extreme heat or cold, excessive moisture, and damaging l

chemicals.

6.4.5 TESTING AND INSPECTION The control room HVAC emergency system filtration components are tested in a program consisting of the following classifications:

a.

Predelivery tests and factory component qualification tests to ensure the quality of the manufactured product b.

Preoperational tests in accordance with the requirements of Chapter 14 c.

Periodic tests in accordance with the requirements of Chapter 16 1

The frequency of tests and inspections is selected to ensure the l

continued integrity of the system.

Charcoal testing frequency is in accordance with Regulatory Guide 1.52 for the efficiency claimed and the bed depth specified.

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