ML18047A617
| ML18047A617 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/19/1982 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.078, RTR-REGGD-1.078, TASK-2.D.3, TASK-TM NUDOCS 8210220186 | |
| Download: ML18047A617 (9) | |
Text
consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 October 19, 1982 Dennis M Crutchfield, Chief Operating Reactors Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - NUREG-0737, ITEM III.D.3.4, CONTROL ROOM HABITABILITY -
ADDITIONAL INFORMATION NRC letter dated July 20, 1982 provided a review of the Consumers Power Company response to NUREG-0737 item III.D.3.4. "Control Room Habitability".
Two items in our December 19, 1980 response were identified as requiring additional information.
The first item is a request for Consumers Power Company to resubmit the toxic chemical analysis, in accordance with staff guidance as contained in NUREG-0737.
The reviewer of our original submittal suggests that we need to analyze for potential transportation accidents involving hazardous materials and determine potential impact on control room habitability.
Regulatory Guide 1.78 defines the assumptions for control room habitability evaluation for hazardous chemical releases in general whereas Regulatory Guide 1.95 deals only with chlorine release while Regulatory Guide 1.91 deals with the aspect of transportation explosions.
It is appropriate to deal with these three topics separately.
It can be shown that the topic of transportation accidents involving explo-sions is, of no relevance to the Palisades Plant.
Figure 1 of the Regulatory Guide shows that highways closer than 1,700 feet, or railroads closer than 2,400 feet to the control should be considered.
The Palisades control room is 3,600 feet from the nearest highway, and 11,600 feet from the nearest railroad.
Thus the risk from explosions is defined to be acceptably low.
Regulatory Guide 1.95 deals with protection of the control room from accidental chlorine release.
The Palisades Plant does not have any potential hazard for on-site chlorine release hazard because the plant uses sodium hypochlorite rather than chlorine to control cooling tower biological growth.
Standard Review Plan 6.4 defines that use of hypofhlorite biocide eliminates the on-site chlorine hazard.
9210220186 821019 PDR ADOCK 05000255 p
DMCrutchfield, Chief Palisad'es Plant NUREG-0737, Item III.D.3.4 October 19, 1982 An analysis of hypothetical transportation accident was done in order to determine the concentration of chlorine which would result in the control room as a result of the rupture and instantaneous release of the contents of a 137 pound chlorine cylinder in a highway accident at the nearest point to the plant.
The diffusion equation for instantaneous (puff) ground level release was used.
Forty seconds after the chlorine plume reaches the control room the resulting concentration would be only 0.052 mg of chlorine per cubic meter of air.
This is three orders of magnitude more dilute than the toxicity limits defined in Regulatory Guide 1.78.
Calculations are appended to this letter, as Appendix I.
The topic of the impact of release of toxic chemicals release on control room habitability is generally addressed in Regulatory Guide 1.78.
The original submittal from Palisades fell short of documenting the basis for the conclusion that highway transportation accidents involving hazardous materials are extremely unlikely.
An extensive review was conducted of the economic activities which take 2
place in western Michigan in order to define hazardous material transportation accident scenarios which have some likelihood of taking place.
The only major economic activity taking place within a five mile radius of the Palisades Plant is farming and extensive fruit growing activity.
There are no manufacturing activities which use or generate chemicals.
The agricultural activities do result in pesticide chemical transportation and use.
There has been so much attention focused on pesticides by EPA and various environmental groups that extensive regultions exist to protect the public from potential accidental release.
The more toxic insecticides are shipped in small shipping containers to minimize the impact of accidental release.
Mr. Robert Kirpatrick of Michigan Toxic Substances and Emergency Services, Plant Industry Division was asked to state his opinion of the most frequently used toxic pesticide in use in western Michigan.
He suggested that the insecticide, Parathion, was probably the best candidate for consideration.
A representative of Haviland Agricultural Chemical Company of Benton Harbor, MI was asked to identify the most toxic insecticide which they transport and market in Western Michigan.
He r3plied that they supply Parathion, which has an OSHA limit of only 0.1 mg/m, to the farming industry.
He went on to say that the shipping containers are kept small for safety reasons and are only 5 gallons in size.
It should also be pointed out that the vapor pressure of parathion at 68°F is only 0.0004 mm of mercury.
Thus accidental rupture of a container of parathion in a highway accident would not be expected to result in measurable concentrations of the chemical at a distance of one kilometer.
DMCrutchfield, Chief Palisades Plant NUREG-0737, Item III.D.3.4 October 19, 1982 The physical properties of parathion are similar to most insecticides and herbicides used in the fruit industry.
In general, this class of products has very low vapor pressure, and very low solubility in water.
Consequently, these products, if involved in a transportation accident would be expected to remain in place, near the site of the accident, and not be a threat at any distance.
Efforts were taken to call the majority of chemical manufacturers and users in the Grand Rapids and Muskegon areas in order to determine the existence of any chemical shipments made in frequency of greater than 10 per year which are routed past the Palisades Plant.
Contacts made are given in Table I.
TABLE I
- 1.
Spartan Chemical Co., Grand Rapids, MI
- 2.
EI DuPont De Nemours & Co., Montague, MI
- 3.
Gold Shield Division of Dextrex, Grand Rapids MI
- 4.
Bofors Lakeway Corp., Muskegon, MI
- 5.
Cordova Chemical Co., Muskegon, MI
- 6.
Webb Chemical Services Corp., Muskegon Heights, MI
- 7.
Burdick and Jackson Co., Muskegon, MI
- 8.
Park-Davis Corp., Holland, MI
- 9.
Hexcell Corp., Zealand, MI
- 10.
Sun Chemical, Muskegon, MI
- 11.
Thomas Solvent Co., Muskegon, MI
- 12.
Guardsmen Chemical Co., Muskegon, MI
- 13.
East Shore Chemical Co., Muskegon, MI
- 14.
Muskegon Chemical Co., Muskegon, MI
- 15.
.Amway Corp., Grand Rapids, MI As a result of contacts with the chemical manufacturing industry in western Michigan, we can expect the following chemicals to be transported in quanti-ties greater than ten truck loads per year past the Palisades Plant.
TABLE II Acetone Methyl Ethyl Ketone Isopropyl Alcohol Ethyl Acetate Methylene Chloride Trichloroethylene Perchloroethylene 32% Muriatic Acid Oryzalin Herbicide Polyethylene Amines Poly-Functional-Aziridines Benzene*
Ethyl Ether Formaldehyde*
Hydrogen Cyanide*
3
DMCrutchfield,_ Chief Palisades Plant NUREG-0737, Item III.D.3.4 October 19, 1982 Methanol*
Sulfuric Acid Xylene*
Hexane Acetic Acid 50% Caustic Soda Toluene
- The asterisk indicates chemicals which are listed in Table C-1 of Regulatory Guide 1.78.
Most of the chemicals listed in Table II are of relatively low toxicity at the concentration levels which would be expected to result at the Palisades control t'oom-;. - Many of the chemical-s listed are industrial _solvents_ which -are_ -
ultimately used in the formulation of paints.
The probable impact from these to human health would be expected to be no worse that the threat of being in a freshly painted room.
The only chemicals listed in Table II which really have any potential to deliver a toxic plume to the control room are Formaldehyde, Benzene, chlorinated hydrocarbon solvents, and hydrogen cyanide.
Of these, hydrogen cyanide gas is by far the most toxic chemical, and offers toxic effects which can take place over a very short time period (ie respiratory paralysis). It was decided to calculate control room hydrogen cyanide concen-tration levels resulting from a worst case transportation accident scenario.
Using Regulatory Guide 1.78, Table C-2, the Palisades control room should be classified as a Type C control room.
The Palisades control room has an air exchange rate of approximately 1.7 per hour.
It should also be pointed out that according to wind rose data, that the wind at the plant only flows from the eastern quadrant 18% of the time, and from due east less than 4% of the time.
The mean wind velocity when the wind blows from th_e east is 3.5 meters/second.
The accident scenario assumes an accident taking place on Highway 196, 1000 meters due east of the Palisades Plant.
The wind velocity is 3.5 meters per second from the east.
The vertical rise from the road to the control room is 15 meters.
The travel time for the plume from the accident to reach the co~trol room is 286 seconds.
It is assumed that a gas cylinder containing 64.2 pounds of hydrogen cyanide catastrophically fails.
The calculation is given in Appendix II and is based on equation 5.21 from Turners Workbook.
Atmospheric stability class F is assumed.
No credit is taken for any reduc-tion on control room chemical concentration resulting because of physical barriers or filtration.
The results of the calculation indicate that the maximum HCN concentration in the control room is reached the instant that the plume reaches the control room, but the concentration rapidly falls off.
The maximum calculation is calculated to be 227 mg of HCN per cu~ic meter.
Forty seconds later, concentration will fall to 0.025 mg/m
- 4
DMCrutchfield, Chief PalisadeS' Plant NUREG-0737, Item III.D.3.4 October 19, 1982 The Matheson Gas Data Book provides the following table:
Concentration ppm 2.5 10 20-40 100-140 200-480 3000 Concent~ation mg/m 2.2-5.5 11 22-44 100-154 220-528 3300 Effect Odor detectable TLV Slight symptoms after several hours Dangerous within one hour Fatal within 30 minutes Rapidly fatal It is clear that the concentration resulting from the accident scenario would not be dangerous.
Consideration was also made of the question of transportation accidents involving rail shipment of chemicals and determined that this in not a factor insofar as control room habitability.
The Chesapeake and Ohio Railroad track is 2.2 miles from the Palisades Plant at its nearest approach.
Communication with the C&O freight agent in St. Joseph, Michigan, indicated that to the best of his knowledge, no shipment of hazardous chemicals has ever taken place over the section of track in question.
Shipments of bulk chemicals between Chicago and Grand Rapids or Muskegon take place over track which is further to the east.
REFERENCES
- 1.
Industrial Ventilation, A Manual of Recommended Practice, 11 Edition, American Conference of Governmental Industrial Hygienists.
- 2.
Occupational Health Guidelines for Chemical Hazards, NIOSH Publication 81-123.
- 3.
Workbook of Atmospheric Dispersion Estimates, D Bruce Turner, Environ-mental Protection Agency.
- 4.
SRI Directory of Chemical Producers, SRI, International, Menlo Park, CA.
- 5.
Matheson Gas Data Book, Fifth Edition, Matheson Gas Products, Milwaukee, Wisconsin.
5
DMCrutc-hfielu, Chief Palisades Plant NUREG-0737, Item III.D.3.4 October 19, 1982 6
The second item of additional information involved the number of Self-Contained Breathing Apparatus (SCBA) provided within the control room.
Consumers Power has ordered an additional SCBA to bring the total in the control room to 8.
Present plans indicate the installation of these additional units in the control room by January 1983.
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment -
3 Pages
APPENDIX I - Calculation of chlorine concentration expected to result in control room from hypothetical transportation accident.
1 Scenario - at road 1 Km (1000 meters) from plant, a cylinder containing 137 pounds (62,143 grams) of chlorine catastrophically fails in an accident.
Elevation difference between road and control room is 15 meters.
Atmospheric Stability Class F is assumed.
From Figures 1, and 2, Appendix B, Regulatory Guide 1. 78, for distance of 1000 meters, U = U
= 33 and U
= 15.
x y
z Wind speed is 3.5 meters per second and time for plume to reach control room is 286 seconds.
Equation 5. 21 for instantaneous sources is-taken from Turriers--Workbook:
Calculation is done for the instant that the plume reaches control room.
t(xcCt )2]
=
exp
- 15. 15 a x exp [- ~ (~J]
[
l
(
2 l exp
~\\Gy J J Stability Category F Assume Where:
Qt = grams of chemical spilled M
= wind velocity, m/seconds t
= seconds after release
~
= horizontal downwind standard deviation of plume
= horizontal lateral standard deviation er~ = vertical standard deviation H
elevation above ground level of release x = 1000 meters = distance between control room and release point.
The maximum concentration at the control room will occur at the instant the plume first arrives.
The travel time for the plume to arrive is 286 seconds at a wind velocity of 3.5 meters/sec.
x =
2( 62,143) 15.75(33)(33)(15)
Since H = 0 with ground level discharge, and Y = 0 with wind blowing directly from spill to control room, the last two exponental terms are equal to 1.
X = 0.483 exp (-030004591)
X = 0.483 gr~ms/m x= 483 mg/m Note that the concentration of 483 mg/m3 of chlorine which is calculated is the theoretical maximum concentration.
It is instructive to do the same calculation for only forty seconds later at a time of 326 seconds after
. ~-
release.
In this case, the exponential term becomes:
The concentration in the control room becomes
)(= (0.483)(.ogo109) = 0.00052 gra~s/m 3
X= 0.052 mg/m Obviously, the concentration would not peak nearly as high as 483 mg/m3 in reality, but would be much lower.
-~- -
2 It should also be pointed out that the -equatio-n u-sed -for-- tllese-cakulatiohs - -
is much more conservative in favor of safety then is the equation given in Appendix B of Regulatory Guide 1.78.
The Appendix B equation gives concentrations which are far too small because the first term in the ex-ponential is apparently in error.
For the case where X = 1000 meters and a = 33 x
then exp [- ~~)] =
x e -459 =
This is such a small number that the overall equation yields a very small number.
t APPENDIX II For the Hydrogen Cyanide Accident Scenario:
Density of HCN at 20°c = 0.6871 g/ml Volume of HCN Cylinder = 1.5 ft3 = 4.245 x 104ml.
Wt HCN = 64.2 pounds = 29,167 grams H = 0 ax
.= 33 meters
~ =
15 meters Travel time of plume to control room is 286 seconds at wind speed of 3.5 m/s.
X = 1000 meters, distance between spill and control room X=
2Qt exp re; JJ
- 15. 15 a ay a; x
exp t~~~J exp
[~~ayrJ The second and third exponential terms drop out because H = 0 and Y = 0.
X= 2(29,161) exp
_r~(iooo - 3.5 c286t2l 15.75(33)(33)(15) l \\
33
- J X = 0.227 exp [-0.0004591]
X= 227 mg/m3 3
0.227 grams/m Note that if t is increased by forty seconds to 326 seconds after release, the concentration in the control room would become 227 (.000109) = 0.025 mg/m3 Thus in the course of forty seconds, the concentration drops to a value far below the level of concern. 3 The level of concern is defined in Regulatory Guide 1.78 as being 22 mg/m 3