DCL-14-123, Radiation Release Response to NRC Request for Additional Information- National Fire Protection Association Standard 805
| ML14365A377 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/31/2014 |
| From: | Allen B Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-14-123 | |
| Download: ML14365A377 (13) | |
Text
Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 December 31, 2014 Fax: 805.545.6445 PG&E Letter DCL-14-123 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Radiation Release Response to NRC Request for Additional Information- National Fire Protection Association Standard 805
References:
(1) PG&E Letter DCL-13-065, "License Amendment Request 13-03, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (200 1 Edition)," dated June 26, 2013 (2) NRC Letter, "Diablo Canyon Power Plant, Units 1 and 2 - Radiation Release (Rad Release) Request for Additional Information Re: License Amendment Request (LAR) 13-03 to Adopt National Fire Protection Association Standard 805 (TAC Nos. MF2333 and MF2334)," dated September 23, 2014
Dear Commissioners and Staff:
In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a license amendment request (LAR) to adopt National Fire Protection Association Standard 805.
In Reference 2, the NRC provided a request for additional information (RAI) regarding Reference 1. The RAI questions were discussed in draft form in a teleconference on September 22, 2014. Enclosed are PG&E's responses to the RAI questions.
PG&E is making a regulatory commitment (as defined by NEI 99-04) in this letter, which adds a LAR AttachmentS Table S-3 item.
If you have any questions or require additional information, please contact Mr. Philippe Soenen at 805-545-4720.
A member of the STARS- (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk PG&E Letter DCL-14-123 December 31, 2014 Page 2 I state under penalty of perjury that the foregoing is true and correct.
Executed on December 31, 2014.
Sincerely, s-!!:lenS ~
Site Vice President mjrm/4557/50037411-13 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Administrator Thomas R. Hipschman, NRC Senior Resident Inspector Siva P. Lingam, NRC Senior Project Manager Gonzalo L. Perez, California Department of Public Health A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- Wolf Creek
Enclosure PG&E Letter DCL-14-123 Radiation Release Response to NRC Request for Additional Information -
National Fire Protection Association Standard 805
References:
- 1. PG&E Letter DCL-13-065, "License Amendment Request 13-03, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition),"
dated June 26, 2013
- 2. NRC Letter, "Diablo Canyon Power Plant, Units 1 and 2 - Radiation Release (Rad Release) Request for Additional Information Re: License Amendment Request (LAR) 13-03 to Adopt National Fire Protection Association Standard 805 (TAC Nos. MF2333 and MF2334)," dated September 23, 2014 of this enclosure includes a list of acronyms used in this response for convenience.
On September 23, 2014, the NRC provided a RAI (Reference 2) regarding LAR 13-03 (Reference 1), herein referred to as "LAR" or "the LAR." PG&E's responses to the Radiation Release NRC questions are provided below.
Radiation Release RAI 01:
Please describe the radiological criteria that were used to screen fire areas out of the review. Also, please describe the qualifications of the personnel conducting the screening and whether the screening was conducted by an expert panel or a limited number of individuals.
PG&E Response:
Section 5.2 of "NFPA 805 Radioactive Release Review," (Calculation DCA 9000041465-000-00) describes how fire areas or fire zones were screened out of the review. The intent of the screening process was to include in the review all plant areas in which a potential radiological release could occur. Those areas which have no potential for radioactive release are considered screened out of the review.
The Radioactive Release Review screening process was performed by the following personnel:
- DCPP Radiation Protection Manager
- DCPP Radiation Protection Radwaste Engineer 1
Enclosure PG&E Letter DCL-14-123
- Industry Experts:
o NFPA 805 Fire Protection Engineer o DCPP NFPA 805 Technical Engineer The individuals in these positions were directly involved in the screening process.
Other professionals, including both PG&E personnel and consultants, were indirectly involved.
The qualifications of this group of individuals comprises of knowledge of the plant's radwaste processing and monitoring systems, RCA mapping, and the logistics for transporting radiologically contaminated material during all modes of operation.
These individuals are qualified in their respective disciplines and therefore represent a reasonable team to perform the screening process described in Section 5.2 of the Radioactive Release Review.
Radiation Release RAI 02:
Pacific Gas and Electric (PG&E) Calculation SAP No. 9000041465, Page 7, describes the radioactive material container of interest in the quantities release calculations as a sea-land container, fully loaded with dry active waste (DAW), and provides a rational why only considering a fire related release from one container as reasonable. However, Diablo Canyon Power Plant (DCPP) Calculations DCA 9000041373 (liquid releases) and DCA 9000041374 (gaseous releases) assume a bounding source term on a DAW box 10-B-001. If box 10-B-001 is not a sea-land container, please provide a basis for using a DAW box reading 200 mrem/hr on its surface, rather than a sea-land container (reading 200 milli rem per hour (mrem/hr))
for estimating the bounding source term to resolve this discrepancy.
PG&E Response:
Calculations DCA 9000041373, "Liquid Effluent Release to the Unrestricted Area Boundary Due to Fire," and DCA 9000041374, "Gaseous Effluent Release to the Unrestricted Area Boundary Due to Fire," focus on a specific "worst case" existing radioactive material storage container. The basis for the analysis was to examine the potentially combustible radioactive materials stored outdoors. At the site, there are two "sea-land" type containers of electrical power cable with trace radioactive contamination. Typically, there will also be two to three 20 foot "sea-land" type containers of bulk bagged contaminated DAW. In addition, there are one to two 20 foot "sea-land" type containers of bagged used contaminated protective clothing (Orex), and a "sea-land" type container of trash wood and cardboard debris. Of these combustible materials, the highest activity concentration is found in "sea-land" 2
Enclosure PG&E Letter DCL-14-123 type containers of bulk DAW that do not exceed 200 mR/hr contact dose rates in order to meet highway transport limits. Box 10-B-001, a 4 foot by 4 foot by 6 foot box of compacted DAW, with a dose rate of about 200 mR!hr was selected as a conservative source term for any outdoor "sea-land" type container or box of radioactive material because it has a representative spectra and contains much more activity than any "sea-land" type containers of bulk DAW.
Upon further consideration, PG&E has chosen an alternative approach to ensure that 10 CFR 20 limits are met at DCPP. PG&E has developed a new calculation, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007-CALC-01), that establishes the maximum level of curies that can be stored in a single fuel package (i.e., area, container or building) which, if completely consumed by fire, would not result in a radioactive release that would exceed 10 CFR 20 limits. PG&E Calculations DCA 9000041373 and DCA 9000041374 will be superseded by this new calculation, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007-CALC-01 ), once the new calculation is approved.
LAR AttachmentS Table S-3 will be revised to include a new implementation item.
PG&E's radioactive material storage procedure will also be updated to incorporate a monitoring program to ensure that materials which have the potential for radioactive release are not stored in a given area in excess of the value determined in the new vendor calculation 030007 -CALC-01 ). A regulatory commitment is discussed in the response to RAI 04.
Radiation Release RAI 03:
Table E-1 (Attachment E) of letter dated June 26, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13196A139) indicates that there are no engineered provisions to contain and monitor gaseous firefighting effluents and smoke in the following areas;
- a. Fire Zones 27 -A, 27 -B, and 27 -C in Building 117 A,
- b. Building 117 B,
- c. Area 10 Rotor Storage,
- d. Main Warehouse,
- e. Radioactive Storage Material storage in Building 117 C,
- f. Building 519, Warehouse A,
- g. Yard Areas,
- h. Fire Zone 34, Roof of the Auxiliary Building, and
- i. Fire Zones 3-BB and 3-CC, Containment Penetration areas.
Several of these buildings/areas appear to have the potential for containing substantially more radioactivity than the fully loaded DAW container used as the 3
Enclosure PG&E Letter DCL-14-123 source terms in DCPP Calculations DCA 9000041373 and DCA 9000041374.
Please describe the physical or administrative controls (e.g., limiting the amount of radioactivity stored in the area) provided to ensure that a fire in each of these areas will not involve more radioactivity than the bounding source term used in the calculations.
PG&E Response:
Each of the plant areas listed above in Radiation Release RAI 03 has limited or no engineering controls with respect to ventilation and drainage. PG&E utilizes a qualitative DID process to address the potential for radioactive release due to firefighting activities in these areas. Plant locations which have not been designed with engineering controls use a three level defense to maintain compliance:
- Administrative controls (including the use of appropriate storage containers to inhibit combustion of radioactive contents)
- Responders engaged and acting on the potential failure of the containment method
- Support from a radiation protection professional to support and monitor operations PG&E has developed two new calculations. The first new calculation developed, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007 -CALC-01 ), establishes the maximum level of curies that can be stored in a single fuel package (i.e., area, container or building) which, if completely consumed by fire, would not result in a radioactive release that would exceed 10 CFR 20 limits. PG&E Calculations DCA 9000041373 and DCA 9000041374 will be superseded by "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007 -CALC-01 ), once this new calculation is approved. The second new calculation developed, "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007 -CALC-02),
specifically addresses contaminated oil stored at DCPP, which, if consumed by fire, would not result in a radioactive release that would exceed 10 CFR 20 limits.
Responder actions such as smoke scrubbing, minimizing suppression water usage, diverting runoff, and using berms, temporary dikes, spill control kits and positive ventilation fans will be prompted. Fire brigade members will be trained to identify and act upon potential radiological release scenarios. Pre-Fire Plans are being modified to prompt consideration for monitoring and preventing radioactive release.
(See LAR AttachmentS, Table S-3 Item S-3.19).
Per PG&E Procedure CP M-6, radiation protection professionals are designated to 4
Enclosure PG&E Letter DCL-14-123 respond to all fire emergencies within the RCA.
Radiation Release RAI 04:
Table E-1 (referenced in RAI 03) indicates that Fire Zone 27-C is used for contaminated oil storage. Please provide a basis for concluding that the radioactive material release fractions used in DCPP Calculations DCA 9000041373 and DCA 9000041374, which are based on a fire in dry active waste, are conservative and bounding the fraction of radioactivity that would be released from burning oil, or any other waste form stored in the areas listed in Radiation Release RAI 03.
PG&E Response:
Calculations DCA 9000041373 and DCA 9000041374 can be disregarded with respect to an analysis of the contaminated oil storage in Fire Zone 27 -C. PG&E has chosen an alternative approach to analyze the radioactive release in a given area and developed a second new calculation, "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007-CALC-02), specifically to address contaminated oil stored at DCPP. This new calculation, "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007-CALC-02), establishes the maximum number of barrels of contaminated oil that can be stored at DCPP, which, if consumed by fire, would not result in a radioactive release that would exceed 10 CFR 20 limits.
PG&E is making the following regulatory commitment:
LAR Attachment S Table S-3 will be revised to include a new implementation item. DCPP's radioactive material storage procedure will be updated to incorporate a monitoring program to ensure that radioactive materials are not stored in a given area in excess of the value determined in the calculation.
Radiation Release RAI 05:
Assumption 3.3 on Page 5 of DCPP Calculation DCA 9000041373 states that the fraction of the radioactive material contained in the "bounding" DAW container released as liquid effluent is equal to the fraction assumed for gaseous releases in DCPP Calculation DCA 9000041374. This appears to be a very non-conservative assumption, since only 0.1% of the activity in the container is assumed to be released as an airborne effluent, leaving 99. 9°/o of the activity to potentially be washed away as a liquid effluent. Please provide a technical justification for this assumption.
5
Enclosure PG&E Letter DCL-14-123 PG&E Response:
The assumption noted in Radiation Release RAI 05 is no longer applicable. PG&E has chosen an approach to ensure that 10 CFR 20 limits are met at the site that differs from that discussed in Calculation DCA 9000041373. PG&E has developed a new calculation, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007-CALC-01), that establishes the maximum level of curies that can be stored in a single fuel package (i.e., area, container or building) which, if completely consumed by fire, would not result in a radioactive release that would exceed 10 CFR 20 limits. Both PG&E Calculations DCA 9000041373 and DCA 9000041374 will be superseded by this one new calculation, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007 -CALC-01 ), once this new calculation is approved. Calculation DCA 030007 -CALC-01 assumes the ARF is 6 percent. ARF values found in the references for DAW-Iike material range from 0.05 percent to 6 percent. The value of 6 percent was chosen for conservatism. The references used to support conservative assumptions are:
- Bryner and Mulholland, 1991, "Smoke Emissions and Burning Rates for Urban Structures," Atmospheric Environment Vol. 25a, No. 11, pp 2553-2562
- DOE-HDBK-301 0-94, "Airborne Release Fractions/Rates and Respirable Fractions For Nonreactor Nuclear Facilities Volume I -Analysis of Experimental Data," US DOE, December 1994, Washington, D.C.
- IAEA-TECDOC-1346, "Input Data For Quantifying Risks Associated With The Transport Of Radioactive Material," International Atomic Energy Agency March 2003, Vienna, Austria
- NUREG/CR-2658, "Characteristics of Combustion Products: 'A Review of the Literature'," US NRC, July 1983, Washington, D.C.
Relative to liquid effluent entrainment, Calculation DCA 030007-CALC-01 assumes 40 percent of the material becomes entrained in the water used to extinguish the fire. Though there is a paucity of information on the amount of material which remains as soot and ash, NUREG/CR-2658 indicates that 30 percent of the material will remain in the soot and ash (NUREG value is based on Douglas fir). Given that some of the material will become airborne and the fire brigade's efforts will reduce the amount burned, PG&E considers 40 percent to be a reasonable value.
Radiation Release RAI 06:
PG&E Calculation SAP No. 9000041465, "NFPA 805 Radiological Release Review,"
Page 14, has three recommendations resulting from the review. Please confirm 6
Enclosure PG&E Letter DCL-14-123 that these recommendations will be implemented as part of the transition to the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (NFPA 805), 2001 Edition.
PG&E Response:
Page 14 of 11 NFPA 805 Radioactive Release Review,~~ (Calculation DCA 9000041465-000-00) includes all of Section 7, "Recommendations." The three recommendations presented are as follows:
- 1. Create a pre-fire plan for "Yard" areas
- 2. Create a pre-fire plan for screened in RAM Storage Building 117 C
- 3. Maintain the results documenting conformance to NFPA 805 radioactive release criteria as part of DCPP's configuration control program In the Radioactive Release Review, the summaries for Recommendations 1 and 2 refer to LAR Attachment S, Table S-3, Item S-3.38 (LAR Revision 0, Item S-3.19),
which reads as follows:
"SAP Notification 50401036 has been issued to address revisions to pre-fire plans and training materials to address radioactive release requirements of NFPA 805."
The summary for Recommendation 3 refers to LAR AttachmentS, Table S-3, Item S-3.39 (LAR Revision 0, Item S-3.20), which reads as follows:
"SAP Notification 50541581 was issued to address incorporating the NFPA 805 Radioactive Release Review into DCPP's Configuration Control Program."
SAP Notification 50541581 was satisfied and the NFPA 805 Radioactive Release Review was incorporated into DCPP's Configuration Control Program utilizing the analysis from PG&E Calculations DCA 9000041373 and DCA 9000041374. PG&E has chosen an alternative approach to analyze the radioactive release resulting in the development of a new calculation, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007-CALC-01), which once approved, will supersede both of PG&E's Calculations DCA 9000041373 and DCA 9000041374. In compliance with Recommendation 3, LAR AttachmentS, Table S-3, Item S-3.39 (LAR Revision 0, Item S-3.20), a new SAP Notification 50679409 was opened on December 27, 2014, to track the incorporation of the new analysis from calculation 030007-CALC-01 into the NFPA 805 Radioactive Release Review 7
Enclosure PG&E Letter DCL-14-123 and DCPP's Configuration Control Program."
The SAP Notifications will be used by PG&E to track required items to completion.
In summary, the three listed recommendations will be implemented as part of LAR Table S-3, Items S-3.19 and S-3.20.
Radiation Release RAI 07:
For the areas listed in Attachment E, Table E-1 that take credit for the building they are located in' for containment and confinement of effluents, please state whether there are any building design features (roll-up doors, windows, etc.), similar to the louvered ventilation intake for the containment penetration areas (see Radiation Release RAI 03.i above), that can divert either liquid or airborne effluents from firefighting operations. If yes, please describe the controls provided to ensure the diverted effluents are not released offsite, or provide a quantitative assessment showing the radiological release criteria will be met by such a release.
PG&E Response:
For the areas listed in Attachment E, Table E-1 there are similar building design features that can divert either liquid or airborne effluents from firefighting operations.
Hardened structures have features for access and equipment movement that, with the loss of feature functionality, have the potential to create paths for radioactive release and the potential release of radioactive material. For this reason, PG&E applies a DID strategy.
These locations will use a three level defense to maintain compliance:
- Engineering controls
- Responders engaged and acting on the potential failure of the containment method
- Support from a radiation protection professional to support and monitor operations The engineering controls are design features and processes that contain liquid and gaseous effluent within a structure. The radwaste system and building ventilation systems are equipped to monitor potential radioactive releases.
In the event of the failure of an active and/or passive engineered feature, responder actions such as smoke scrubbing, minimizing suppression water usage, diverting runoff, and using berms, temporary dikes, spill control kits and positive ventilation fans will be prompted. Fire brigade members will be trained to identify and act upon 8
Enclosure PG&E Letter DCL-14-123 potential radiological release scenarios. Pre-Fire Plans are being modified to prompt consideration for monitoring and preventing radioactive release. (See LAR AttachmentS, Table S-3 Item S-3.19).
Per PG&E Procedure CP M-6, radiation protection professionals are designated to respond to all fire emergencies within the RCA.
Radiation Release RAI 08:
Please provide the NRC staff with the information contained in the following calculations referenced in letter dated June 26, 2013 Section 4.4.2:
PG&E Calculation SAP No. 9000041465, NFPA 805 Radioactive Release Review, Section 4.4.2 of the June 26, 2013, letter refers to information from the following sections of this calculation:
- Section 5.2 (screening process)
- Sections 5.3 and 6.1 (review of engineering controls and administrative controls)
- Sections 5.4 and 6.2 (review of Pre-Fire Plans)
- Sections 5.5 and 6.3 (review of Fire Brigade training materials)
As referenced in PG&E's response to Radiation Release RAI 06, PG&E Calculation SAP No. 9000041465, NFPA 805 Radioactive Release Review, Recommendation 3, LAR Attachment S, Table S-3, Item S-3.39 (LAR Revision 0, Item S-3.20), will incorporate new analysis from PG&E's development of two new calculations, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007-CALC-01}, and "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007-CALC-02}, which once approved, will reflect an alternative approach to analyzing radioactive release.
Calculation DCA 9000041373 is the Liquid Effluent Release to the Unrestricted Area Boundary Due to Fire calculation. Section 4.4.2 of the June 26, 2013 letter refers to information from sections 7.0 (Body of Calculation) and 8.0 (Results) of this 9
Enclosure PG&E Letter DCL-14-123 calculation.
Calculation DCA 9000041374 is the Gaseous Effluent Release to the Unrestricted Area Boundary Due to Fire calculation. Section 4.4.2 of the June 26, 2013, letter refers to information from sections 7.0 (Body of Calculation) and 8.0 (Results) of this calculation.
The first new calculation PG&E developed, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007 -CALC-01 ), once approved, will supersede both Calculations DCA 9000041373 and DCA 9000041374.
With respect to an analysis of the contaminated oil storage in specified fire zones, Calculations DCA 9000041373 and DCA 9000041374 can be disregarded. PG&E has developed a second new calculation, "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007-CALC-02), specifically to address contaminated oil stored at DCPP.
PG&E has posted the new calculations, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," (vendor calculation 030007 -CALC-01) and "Radioactive Release From Waste Oil Fire Suppression Calculation," (vendor calculation 030007-CALC-02), on the PG&E NRC portal for the NRC's review.
Upon issuance of the Safety Evaluation/License Amendment, PG&E will accept vendor calculations 030007 -CALC-01, "Radioactive Release From Dry Active Waste Fire Suppression Calculation," and 030007-CALC-02, "Radioactive Release From Waste Oil Fire Suppression Calculation," as PG&E Engineering Calculations. These accepted PG&E Engineering calculations will supersede DCA 9000041373 and DCA 9000041374.
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Enclosure Attachment 1 PG&E Letter DCL-14-123 Acronym List ARF Airborne Release Fraction DAW Dry Active Waste DCPP Diablo Canyon Power Plant DID Defense-in-Depth LAR License Amendment Request mR/hr millirem per hour NFPA National Fire Protection Association NRC Nuclear Regulatory Commission PG&E Pacific Gas and Electric Company RAI Request for Additional Information RCA Radioactive Control Area RCP Reactor Coolant Pump RCS Reactor Coolant System 1