ML19290F187

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Forwards IE Circular 80-03, Protection from Toxic Gas Hazards. No Written Response Required
ML19290F187
Person / Time
Site: Oyster Creek
Issue date: 03/06/1980
From: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
References
NUDOCS 8003180278
Download: ML19290F187 (1)


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.-4 REGION 1 0,, Y[g%,id[o 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA 19406 March 6, 1980 Docket No. 50-219 Jersey Central Power and Light Company ATTN:

Mr. Ivan R. Finfrock, Jr.

Vice President Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Gentlemen:

The enclosed IE Circular No. 80-03, " Protection from Toxic Gas Hazards", is forwarded to you for information.

No written response is required.

If yce desire additional information regarding this matter, please contact this office.

Sincerely, fff f L

Boyce H. Grier Director

Enclosures:

1.

IE Circular No. 80-03 with Attachments 2.

List of Recently Issued IE Circulars CONTACT:

R. J. Bores (215-337-5260) cc w/encis:

J. T. Carroll, Station Superintendent 8003180a%

ENCLOSURE 1 SSINS:

6830 Accession No.:

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NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT gd)

WASHINGTON, D.C.

20555 IE Circular No. 80-03 Date:

March 6, 1980 Page 1 of 2 PROTECTION FROM T0XIC GAS HAZARDS Chlorine gas releases have been reported at two different reactor facilities in the past two years.

At Millstone, in March 1978, a leak of about 100 :tandard cubic feet of chlorine (about a gallon of liquid) occurred over a ten minute period, resulting in the hospitalization of 15 people.

The ventilation system carried the chlorine into the plant buildings, where personnel distress was noted.

No injuries occurred in the buildings due to the small size of the release.

At Browns Ferry, in June 1979, a small leak from a diaphragm on a chlorine reducing valve resulted in the hospitalization of five people, including a control room operator.

Chlorine is highly toxic, producing symptoms after several hours exposure in concentrations of only one ppm.

Concentrations of 50 ppm are dangerous for even short exposures and 1000 ppm is fatal for brief exposures.

Chlorine, used at some power stations to control organisms in the circulating water, is normally supplied in one ton containers or in tank cars of up to 90 tons capacity.

Other potential sources of toxic gas that have been identified at nuclear power plants include:

Nearby industrial facilities.

At Waterford, in July 1979, construction forces had to be evacuated for two and a half hours due to a chlorine gas release from a nearby chemical plant.

Chlorine transportation on adjacent highways, railway' and rivers.

Large tanks of aqueous ammonia stored near plant buildings.

Both acid and caustic storage tanks located in a common building near the control room.

At the Dresden site, in Augrst 1977, accidental mixing of acid and caustic solutions resulted in toxic fumes that entered the control room via the ventilation system.

IE Circular No. 80-03 Date:

March 6, 1980 Page 2 of 2 Cr'terion 19 of Appendix A to 10 CFR 50 requires a control room from which action can be taken to maintain the reactor in a safe condition under accident conditions.

The control room designs in current license applications are reviewed for operator protection from toxic gases (as well as radiation), in accordance with Standard Review Plan (SRP) 6.4 (NUREG 75/087 d.ted 11/24/75).

Related information on the identification of potential hazards and the evalua-tion of potential accidents can be found in SRP sections 2.2.1-2.2.2 and 2.2.3 respectively.

The SRP references Regulatory Guide 1.78 (dated June 1974) on control room habitability during chemical releases.

It also references Regula-tory Guide 1.95 on requirements for protection against chlorine releases specifically.

The majority of the plants currently operating, however, were t"ilt and licensed prior to the development and implementation of this guidance.

A review of some older plants, with respect to toxic gas hazards indicates that they do not have the degree of protection that would be required for present day plants.

Evaluation of the protection of control rooms from toxic gas releases is part of the systematic evaluation program currently being carried out on certain older plants.

Also, as older facilities submit requests for significant license amendments, their design features and controls for protection of control rooms are reviewed and, if appropriate, are required to be changed.

However, the recent history of frequent toxic gas release incidents appears to warrant a more rapid implementation of the newer toxic gas protection policies.

For the above reasons, it is strongly recommended that:

You evaluate your plant (s) against section 6.4 and applicable parts of sections 2.2.1-2.2.2 and 2.2.3 of the SRP with respect to toxic gas hazards.

Wher the degree of protection against toxic gas hazards is found to be significantly less than that specified in the SRP, provide the controls or propose the design changes necessary to achieve an equivalent level of protection.

No written response to this circular is required.

If you desire additional information regarding this matter, contact the Director of the appropriate NRC Regional Office.

Attachments:

Sections 2.2.1-2.2.2; 2.2.3 and 6.4 of NUREG 75/087

Attachment to IE Circular No. 80-03 NUREG 75/067 foarc o

o y M3 g ',g U.S. NUCLEAR REGULATORY COMMISSION STANDARD REVIEW PLAN i'%..../.! OFFICE OF NUCLEAR REACTOR REGULATION SECTIONS 2.2.1 - 2.2.2 ICENTIFICATION OF POTENTIAL HAZARDS IN SITE VICINITY l

REVIEW RESPONSIBILITIES Primary - Ac:ident Analysis Branch ( AAS)

Secondary - None I

AREAS OF REV!EW

. Locations and separation distances from the site of industrial, military, and transportation facilities and routes in the vicinity of the site. Such facilities and routes include air, ground, and water traffic, picelines, and fixed manufacturing, processing, and storage facilities. Potential external hazards or ha:ardous materials that are present or wnich may reasonably be expected to be present during the projected life time of tne proposed plar.t. The purpose of this review is to establish the infomation concerning the presence of potential external hazards wnich is to be used in further review in Secticns 2.2.3, 3.5.1.5, and 3.5.1.5.

II. ACCEPTANCE CRITERIA 1.

Data in the SAR adequately describes the lccations and distances of i.1c.ustrial, l

military, and transportation facilities in the vicinity of the plant, and is in agreement with data obtained from other sources, when available.

2.

Descriptions of the nature and extent of activities conducted at nearby facilities, including the products and materials likely to be processed, stored, used, or trans-ported, are adequate to permit evaluations of possible ha:ards in Part 3 review sections dealing, witn scecific hazards -

3.

Where potentially hazardous materials may be processed, stored, used, or transported in the vicinity of the plant, sufficient statistical data on such materials are l

provided to establish a basis fcr evaluating the potential hazard to the plant.

III. REVIEW PRCCEDURES Selection ano empnasis of varicus aspects of the treas covered by this review plan will ne made by the reviewer on each case. The judgment of the areas tu be giv/n attention curing the review is to be based on an inspection of the material preser ud, the similarity cf the 4-se-ial to that recently reviewed on other plants, and wnether ite:'s of special safety significance are involved. The following procecures are followed:

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STANDARD REVIEW PLAN

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OFFICE OF NUCLEAR REACTOR REGULATION SECTICN 2.2.3 EVALUATION OF POTENTIAL ACCIDENTS REVIEW RESPCNSIBILITIES Primary - Accident Analysis Branch (AAS)

Secondary - Applied Statistics Branch (ASB/MPA)

AREAS OF REVIEW The applicant's identification of potential accident situations in the vicinity of the plant is reviewed to determine the comoleteness of and the bases upcn whicn these potential accidents were or were not acecm edated in the design. (See Standard Review Plans 2.2.1 and 2.2.2.)

The applicant's probability analyses of ;ctential accidents invclving ha:ardous materials or activities in tne vicinity of the plant, if such analyses have been cerfor-'ed, are also reviewed by ASS /MPA on request by AAB to determine that approcriate data and analytical models have beer utili:ed.

The analyses of the consequences of accidents involving nearby industrial, military, and transportation facilities which have been identified as design basis events are reviewed.

II. ACCEPTANCE CRITERIA The identification of design basis events resulting from the cresence of hazardous materials or activities in the vicinity of the plant is acceptable if the design aasis events include each postulated type of accident for which the expected rate of occurrence of potential excosures in excess of the 10 CFR Part 100 guidelines is estimated to exceed the NRC staff objective of approximately 10' per year. Ee:ause of the difficulty of assigning accurate num rical values to the ex;ected rate of unprecedented potential hazards generally con-sidered in this review plan, judg ent must be used as to the acceptability of the overall risx presented.

The probability of Oc:urrence of the initiating events leadi.g to potential consecuences in excess of 10 ;FR Part 100 exposure guidelines should be estimated using assumptions that are as representative of the specific site as is practicable. In addition, because of the low procabilities of the events under c:nsidaration, data are often not available to permit accurate calculation of probabilities. Accordingly, the expected rate of ec:ur-rence of potential exposures in excess of the 10 CFR Part 1C0 guidelines of approximately 10 per year is acceptable if, when cor:bined with reasonable cualitative arguments, the realistic probability can be shewn to be icwer.

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Attachment to IE Circular No. 80-03 The effects of design basis events have been adecuately considered if analyses of the l

effects of those accidents on the safety-relateo f3tures cf the plant have been perfonned N

and measvaes (e.g., hardening, fire protection', to m tigate the consequences of such events have been taken.

III. REVIEW PROCEDURES g

In some cases it may be necessary to consult with or obtain specific data from other branches, such as the Structural Engineering Branch (SES) or Auxiliary Systems Branch l

(ASB), regarding possible effects of external events on plant structures or components.

The applicant's probability calculations are reviewed, and an independent probability analysis is performed by the staff if the potential hazard is considered significant enougn to affect the licensability of the site or is important to the identification of design ba",is events.

All stocMstic variables that affect the occurrence or !? verity of the postulated event are icentified. z judged to be either independent or conditioned by other variables.

Probabilistic models should be tested, where possible, against all available information.

If the model or any portien of it, by simple extension, can be used to predict an observ-able accident rate, this test should be performed.

The design parameters (e.g., overpressure) and physical pnenomena (e.g., gas concentration) selected by the applicant for each design basis event are reviewed to ascertain that t.w values are comparable to the values used in previous analyses and found to be acceptable by the staff.

Each design basis event is reviewed to determine that the effects of the event on the safety features of the plant have been adequately accorrnodated in the design.

If accidents involving release of smoke, flammable or nonflammaale gases, or chemical bearing clouds are considered to be design basis events, an evaluation of the effects of these accidents on centrol room habitability should be made in SAR Section 6.t and on the cperation of diesels and.:ner safety-related equipment in SAR Chapter 9.

Special attention should be given to the review of standardized designs which propose criteria involving individual numerical probability criteria for individual classes of external man-made hazards. In such instances the reviewer should establish that the envelope also includes an overall criterion that limits the aggregate probability of exceed-i n,9 design criteria associated witn all of the identified external man-made hazards.

Simiicaly, special attention should be given to the review of a site where several man-made hacards are identified, but none of which, individually, has a probability exceeding the acceptance cr,iteria stated herein. The objective of this special review should be to assure that the aggregate probability of an outcome that may lead to unacceptable plant damage meets the acceptance criteria of Part II of tnis SRP Section. (A hypothetical examole is a situatien where the probability of sr.ock wave overpressure greater than design Rev. 1 2.2.3-2

Attachment to IE Circular No. 80-03 overpressure is about 10' per reacter year from accicents at a nearby industrial facility,

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and approximately equal probabilities of exceeding design pressure from railway accidents, highaay accidents and from shipping accidents. Individually each may be judged acc.eptably low; the aggregate probability may be judged sufficiently great that additional features of design are warranted.)

IV. EVALUATION FINDIN35 If the reviewer verifies that sufficient information has been provided and that his evaluation is sufficiently complete and. adequate to meet the acceptance criteria in Section II of this SRP, conclusions of the following type may be prepared for the staff's, safety evaluation report:

"The applicant has identified potential accidents which could occur in the vicinity of the plant, and from these has selected those which should be considered as design l

basis events and has provided analyses of the effects of these accidents on the Jafety-related features of the plant. The applicant has demonstrated that the plant is adequately protected and can be operated with an acceptable degree of safety w th regard to potential accidents which may occur as the result of activities at nearcy industrial, military, and transportation facilities."

V.

REFERENCES Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," Revision 2.

I Affidavit of Jacoues B. J. Read before the Atomic Safety and Licensing Board in the matter of Skagit Nuclear Power Project, Units 1 6..d 2. July 15,1976. Docket Nos. STN 50-522, 523.

Atomic Safety and Licensing Board, Supplemental Initial Decision in the Matter of Hope Creek Generating Station, Units 1 and 2. March 28,1977. Docket Nos. 50-354, 355.

Sect'-

2, Supplement 2 to the Flcating Nuclear Plant Safety Evaluation Repert, Docket No.

. 50-437, September 1976.

Rev. I 2.2.3-3

Attachment to IE Circular '. 80-03 NUREG 75/087 om nooq'o

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OFFICE OF NUCLEAR REACTOR REGULATION SECTION 6.4 HABITABILITY SYSTEMS REVIEW Resp 0NSIBILITIES Primary - Accident Analysis Branch (AAS)

Secondary - Hydrology-Meteorology Branch (HMB)

Auxiliary Systems Branch (ASS)

Effluent Treatment Systems Branch (ETSS)

I.

AREAS OF REVIEW The control roca ventilation system and control building layout and structures, as cescribed in the applicant's safety analysis recort (SAR), are reviewed with the 00jective of assuring that plant operators are acequately protected against the effects of accidental releases of toxic cr radioactive gases. A further objective is to assure that the control rocm cari be maintained as the center frem which emergency teams can safely operate in the case of a design basis radioicgical release. To assure that these cojectives are accom-plished the fo11cwing items are reviewed:

1.

The zone serviced by the c:ntrol room emergency ventilation system is examined to ascertain that all critical areas requiring access in the event of an accident are included within the :ene (control rocm, kitchen, sanitary facilities, etc.) and to f

assure that those areas not requiring access are generally excluded from the zone.

2.

The capacity of the control rocm in terms of the n*2ber of people it can acccmmodate for an extended period of time is reviewed to confirm the acequacy of emergency food and medical supplies and self-contained breathing apparatus and to determine the length of time the cuntrol room can be isolated before CO levels become excessive.

2 3

The control rocm ventilation system laycut and functional design is reviewed to determine flow rates and filter efficiencies for inout into the AAS analyses of the builduo of racicactive or toxic gases inside the centrol room, assuming a design basis release. Basic deficiencies that might impair the effectiveness of the system are examined. In addition, the system coeration and procedures are reviewed. The ASB has primary responsibility ir.., system review area under Standard Review Plan (SRP) 9.4.1.

The ASB is censulted when reviewing barcware and cperating procedi res.

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