ML19340E405

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Forwards Addl Info Required by NUREG-0737 Re TMI Action Plan Items Addressed:Shift Technical Advisor,Noble Gas Effluent Monitor,Sampling & Analysis of Plant Effluents & Control Room Habitability
ML19340E405
Person / Time
Site: Yankee Rowe
Issue date: 01/01/1981
From: Kay J
YANKEE ATOMIC ELECTRIC CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-2.F.1, TASK-2.F.2, TASK-2.K.3.17, TASK-3.D.3.3, TASK-3.D.3.4, TASK-TM FYR-81-6, NUDOCS 8101140361
Download: ML19340E405 (33)
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{{#Wiki_filter:, YANKEE ATOMIC ELECTRIC COMPANY 4 B.3.2.1 _g1 1671 Worcester Road, Framingham, Mossochusetts 01701 YANKEE FYR 81-6 m _/ January 1, 1981 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention : Mr. Darre.'l G. Eisenhut, Director Division of Licensing

Reference:

(a) License No. DPR-3 (Docket No. 50-29) (b) USNRC Letter, D. G. Eisenhut to All Licensees of Operating Plants, dated October 31.1980 (NUREG-0737) (c) YAEC letter to USNBC, dated December 15, 1980 (WYR 80-136) Subject : Information Required by NUREG-0737

Dear Sir:

This letter transmits additional information required by NUREG-0737. The information is contained in the Enclosure and discusses the following TMI Action Plan items: I.A.l.1 Shift Technical Advisor II.F.1 Noble Gas Effluent Monitor II.F.1 Sampling and Analysis of Plant Effluents II.F.2 Instrumentation for Inadequate Core Cooling II.K.3 17 Report on Outages of ECCS III.D.3 4 Control Room Habitability We trust this information is satisfactory; however, if you have any questions please contact us. Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY SENb - J. A. Kay b[ Q i,/ El NJ C3 ~ JAK/kab gggy} }[ n sure !8103;

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u ENCLOSURE YANKEE ATOMIC ELECTRIC COMPANY ITEM: I.A.l.1 TITLE: Shif t Technical Advisor (STA) The following describes our Shif t Technical Advisor (STA) training program and our plans for requalification training. The description includes the level of training attained as of January 1, 1981 and demonstrates conformance with the qualification and training requirements in the USNRC letter dated October 30, 1979. EXISTING TRAINING PROGRAM Selection Criteria Although the October 30, 1979 letter recommends that each STA have college level courses in science and engineering, we have determined that requiring a Bachelor of Science degree in engineering or a science will enhance the STA function by providing a broad, technical base upon which to develop. Recognizing the experimental and accelerated nature of the training for January 1, 1981, the first qualified group was selected primarily from the existing plant staff to use their level of experience, and all hold Bachelor of Science degrees in engineering or a science. Training and Qualification Program The requirements for training and qualification in the October 30, 1979 letter are those contained in Paragraphs A.1, 2 and 3 of Enclosure 2 of the USNRC letter dated September 13, 1979. To show conformance, our training and qualification program is compared with that of the September 13, 1979 letter. Our qualification and training program exceeds the requirements of that letter. A.1 General Technical Education l l General technical education is provided in three parts: a) As stated previously, each of the STA's qualified as of January 1, 1981, has a Bachelor of Science degree in engineering or science. This guarantees a sound technical foundation which allows the individual to acquire knowledge in those disciplines required for objective accident assessment. b) At a college level, and tailored to Yankee Rowe specifically, the training program included a two-week session which covered the following areas: _1_

4 Thermodynamics Heat Transfer Fluid Mechanics Reactor Physics Specific Accident / Transient Analysis for Yankee Rowe These topics were taught by instructors from the Transient / Accident Analysis and Reactor Physics groups of Yankee Nuclear Services Division, each topic being taught by an expert in that particular field. c) A continuing education concept will be employed such that, as time allows, individuals will take advantage of short courses and seminars which are available to supplement their knowledge in particalar technical areas. For example, in July 1980, members of the STA group who had ao college credits in the effects of radiation on materials attended an intensive week long seminar at Dartmouth College entitled, "The Behavior of Structural Materials in Nuclear Power Systems". A.2 Reactor Operations Training Since the STA's who were qualified as of January 1, 1981 were not operators, it was necessary to devise a special course to train them in the details of the design, function, arrangement and operation of plant systems. This was accomplished through an intensive eight (8) week systems course, given on a Reactor Operator / Senior Reactor Operator level. Effectiveness of this training was monitored by weekly exams and plant administered mid-term and final exams. Final qualification was verified via a third party independent audit which was performed by a consultant. A.3 Transient and Accident Response Training Beyond the training given in anticipated transients / accident and emergency procedures during the Reactor Operations phase of the training program, the program covered this area in two additional phases. These two phases were: a) A 15-day simulator training program. This training (4 hours classroom, 4 hours simulator per day) was specifically designed to train STA's to deal with a wide range of accident scenarios. This training program a' the simulator covered all areas and scenarios required by Section 6.8 of Revision 0 of the INPO document, " Nuclear Power Plant Shift Technical Advisor". b) Yankee Rowe specific transient / accident response training was given by Ysnkee Nu. lear Services Division. This two week course, also mentioned above under " General Technical Education", encompassed an in-depth study of the accident analysis and bases _

( i for a wide range of postulated accidents. Effectiveness of this training was also verified through the same third party independent audit, mentioned in the Reactor Operations Section, I by our consultant. Requalification Training Requalification for the STA's qualified as of' January 1, 1981 is i to consist of a simulator training program of the same scope as initial simulator training. The requirements of Section 6.8, Revision 0, of the INPO docume:nt, " Nuclear Power Plant Shift Technical Advisor", will be met. i- 'T ? I i I e P l t ~_.--.,-

j e 1 1 Long-Term Program The following describes our long-term Shif t Technical Advisor (STA) program. The qualification and training plans of our program are compared with those of Sections 5 and 6 of Revision 0 of the INPO document, " Nuclear Power Plant Shift Technical Advisor". Selection criteria and cur position on the eventual phaseout of the STA program are also addressed. A. Selection Criteria Individuals who enter our STA training program shall have a Bachelor of Science degree in engineering or science. This requirement guarantees a broad technical foundation upon which our training program can build. It also certifies the ability of the candidate to learn at a level commensurate with the training provided. Exceptions to the Bachelor of Science degree requirement may be made for special cases. These shall be evaluated on a case-by-case basis. B. Qualification and Training Program Our program is described in the format of Sections 5 and 6 of the INPO document. The required comparisons are included in each section. 5. General Education and Experience 5.1 Education and Training INPO Section 5.1 calls for compliance with Section 6. The requirements of Section 6 have been used as a guide in the development of our program. I 5.2 Experience Each qualified STA shall have at least 12 months of experience at Yankee Rowe. INPO Section 5.2 is a complex set of requirements and exceptions. It requires 18 months of experience, then provides various credits to reduce that. The heart of this section is 12 months on station. Given the situation at Yankee Rowe and the characteristics of this training program, a simple experience requirement of 12 months on site meets the objective of the INPO standard. 5.3 Absences From STA Duties Prior to operation following a refueling or extended outage, each STA will receive training in facility / procedure changes which have occurred. Training requirements following an individual STA's absence of greater than 30 days will be dealt with on a case-by-case _-_,..._.~. _ _ _ _..._ _ _. _

9 4 basis and will ensure cognizance of facility / procedure changes which have occurred and which effect his function as an STA. It is not expected that a qualified STA will be absent for periods of greater than 6 months. Should this occur, the need for annual requalification training prior to assuming duty will be evaluated on a case-by-case basis. Each qualified STA will receive annual requalification training. 6. Education and Training Requirements 6.1 Education 6.1.1 Prerequisites Beyond High School Diploma Our normal selection criteria guarantees that the requirements of this section will be met. Documentation of course completion will not be maintained for this section, for those inlividuals selected by our normal selective criteria. Exceptions to the Bachelor of Science degree requirement entering into the STA function would be evaluated on a case-by-case basis. Documentation of course completion beyond the high school diploma would be maintained for this section. 6.1.2 College Level Fundamental Education Shif t Technical Advisor positions will, for the most part, require a Bachelor of Science degree in engineering or in a science. Exceptions to this requirement may be allowed baseri upon a management evaluation that an individuals background and experience will allow for satisfactory performance of STA duties. While each STA will have completed the majority of the courses contained in this section, it is quite likely that no STA will have completed all of them. With this in mind, the content and scope of our training program is such that each technical area of this section is covered in sufficient depth to assure that required knowledge is obtained. This overlaps the " Plant Specific-Applied Fundamentals" Section 6.2 of the INP0 standard. Based on the above, it is not required that each STA have college credit and/or a coarse in each subject in this section, and it is not felt that INPO certification for training within our program on a specific topic need be obtained. Basically, our program calls for a rigorous approach to selection of qualified personnel coupled with a rigorous approach to applied fundamentals to fulfill the overall requirements for education. We recognize this section of the INPO standard as an ideal, and plan to use a continuing education concept such that, as time allows, individuals will take advantage of short courses and aeminars which are available to supplement their knowledge in particular technical areas indicated by this section of the INPO standard. 6.2 Applied Fundamentals - Plant Specific Intensive training sessions will cover the following topics: The rmodynamic s Heat Transfer Fluid Mechanics Reactor Physics Specific Accident / Transient Analysis for Yankee Rowe Plant Chemistry and Corrosion Control, and Reactor Instrumentation and Control will be covered during the Reactor Operations phase of the training program with equivalent depth of study. As noted previously, our program calls for integration of the goals of INPO Sections 6.1 and 6.2. Consequently, the contact hours for this section far exceed the INPO standard. 6.3 Management / Supervisor Skills Training which covers all topics of this section will be administered as part of the training program. The requirement of this section for 40 contact hours will be met. 6.4 Plant Systems 6.5 Administrative Controls 6.6 General Operating Procedures The Reactor Operations phase of der training program covers all topics in each of these three sections wifS the exception of topics not applicable to Yankee Rowe (e.g., ite.o }"rts monitoring, seismic monitoring, unit interface controlsy. The number of contact hours requir-d by each section is exceeded in our training program. 6.7 Transient Accident Analysis and Emergency Procedures . l

t Intensive training in the topics required by this section will be given. The number of contact hours required by 5.nf t section will be exceeded in our training program. 6.8 Simulator Training A simulator training program will be given at a qualified training center. This program will involve approximately 100 contact hours (50% classroom, 50% claulator). The trainee / instructor ratio should not excese isi. All PWR Simulator Exercises listed in this section will be covered in the program. 6.9 Annual Requalification Training Annual requalification training will be a simulator training program of the same scope and content as that described in Section 663e This 100 contact hour program exceeds the 80 contact hour requirement of this section. C. Phaseout of the STA Program It is planned at this time that the STA program shall be an on going function over the next three to five years. A gradual phaseout of the STA program would be initiated in conjunction with required college credits obtained by the Shif t Supervisor. 3 _. _-

...n. ITEM: II.F.1 TITLE: Noble Gas Effluent Monitor 1. A single high-range monitor w?ll be placed in the vent stack sampling-system, in addition to the norcal range monitors already in place. i 2. A single monitor to cover the ranges of interest will be placed on each of the steam lines. ihe design is such that multiple monitors are not necessary. 3. Display will be in units of dose rate with conversion to release rate accomplished by procedure. N i i e M ITEM: II.F.1 TITLE: Sampling and Analysis of Plant Effluents Although this item is deferred to the SEP program, Yankee takes exception with the design basis shielding envelope used fog the stack sampling media to contain the sample exposed to 10 uCi/cm (I-131) for 30 minutes for the following reasons. a) Calculations based on the above assumptions and the stack sample flow rate yield the following collected activity on the stack sample; 255 Ci of I-131 for Yankee Rowe. This activity only reflects the I-131 component and when other noble gases are included, the activity is significantly increased. Plant personnel would not be allowed to handle a sample of such high activity. b) This concentration of I-131 can only be produced at the stack by purging a containment fuel-melt LOCA source term directly to the stack at an unfiltered high flow rate. This sequence of events is not poscible at Yankee Rowe. A*1 other sources ofI-131releasetothesgackwou}dproduceI-131 concentrations that are decades below 10 uCi/cm c) In the event of a high-level halogen release from the plant, there exists more reliable and reasonable methods for a quantitative assessment of the release. This can be accomplished through a direct measurement of the source or of f-site sampling for I-131. d) As indicated by a Commission Meeting on IODINE RELEASE FROM ACCIDENTS and ESTIHATES OF CONSEQUENCES OF NUCLEAR ACCIDENTS on Tuesday, November 18, 1990, the halogen component available for release from a LOCA is much less than that assumed (25% of core inventory) due to a much higher degree of plateout and other effects. Therefore, even under the condition where a l LOCA containment is vented directly to the stack, the realistic halogen component would be very low. l I i l l f l l.

ITEM: II.F.2 TITLE: Instrumentation for Detection of Inadequate Core Cooling Discussions detailing the planned instrumentation for monit.oring of inadequate core cooling are ontained in the following referenets: a) YAEC Letter to USNRC dated April 26, 1979 (WYR 79-53) b) YAEC Letter to USNRC dated May 24, 1979 (WYR 79-63) c) YAEC Letter to USNRC dated November 19, 1979 (WYR 79-141) d) YAEC Letter to USNRC dated December 31, 1979 (WYR 79-163) e) YAEC Letter to USNRC dated January 21, 1979 (WYR 80-8) f) YAEC Letter to USKRC dated January 24, 1979 (WYR 80-11) g) YAEC Letter to USNRC dated April 9, 1980 (WYR 80-43) h) YAEC Letter to USNRC dated June 4, 1980 (WYR 80-60) i) YAEC Letter to USNRC dated December 15, 1980 (WYR 80-136) The information contained in these references provides descriptions of existing instrumentation systems (e.g., subcooling meter and incore thermocouples), as well as the guidelines and analyses used to develop current emergency procedures for inader ate core cooling. Yankee Rowe has proposed a change to Technical Specifications in our letter dated September 16, 1980 (WYR 80-108), in response to your letter dated July 2, 1980. i' Our position on additional instrumentation to provide indication of inadequate core cooling (e.g., water level) is discussed in Reference (g). Until such time that a new reactor vessel water level system or any l of the presently proposed systems prove to be acceptable for Yankee Rowe, we reserve commitment on any implementation schedule for new equipment. l 1 l l i. -. _., _

ITEM: II.K.3.17 TITLE: Report on Outages of Emergency Core-Cooling Systems Licensee Report The following table summarizes the outages of Emergency Core Cooling System components for the past five years. The report contains the date, length (where applicable), component, reason, corrective action, licensee event report number and plant status at the time of the occurrence. No proposed Technical Specifications are deemed necessary at this time. 1 i I

OUTAGE HISTORY OF EMERGENCY CORE COOLING SYSTEM COMPONENTS FOR Tile LAST FIVE YEARS l Cont'd Time to Plant Date Repair Component Reason Corrective Action Duration

  • Status 3/12/79 2 Hrs.

TDC-2 Relay Sticky Relay Replaced Relay in Unknown Mode 1 25 Min. (SI Accumulator (Relay was Functional Kind (27 Days) Actuation Circuit, But Out of Tolerance) One of Four) Tolerance 11/9/79 3 Hrs. TDC-4 Relay Design Deficiency Modified All Units Unknown Mode 1 (SI Accumulator (Relay was Functional (32 Days) Actuation Circuit, But Out of Tolerance) One 1/26/80 39.5 Hrs. SI-SV-609 Fo.iled Internals Valve was Cleaned Unknown Mode 5 (Safety Valve, One (4 Mos.) J, of Three) 1/28/80 16 Hrs. SI-SOV-56 Fouled Internals Replaced in Kind Unknown Mode 5 (Solenoid Operated (4.5 Mos.) Valve, One of Four) 2/1/80 TDC 1,2,3 & 4 Probable Reversed Polarity Rewired Unknown ** Mode 5 (SI Accumulator (Probable Incorrect Wiring) Actuation Circuit) '1 3/7/80 Adjusted TDC-2 Relay Set Point Drift Adjusted Within Unknown Mode 5 in place (SI Accumulator (Relay was Functional Tolerance (34 Days) Actuation Circuit, But Out of One of Four) Tolerance)

    • It was determined that the wiring connection could not be verified with 100% certainty since the event was discovered af ter a wiring change. If the polarity of the signal leads were reversed, the duration of the event would have been 113 days.

= OUTAGE HISTORY OF EMERGENCY CORE COOLING SYSTEM COMPONENTS FOR THE LAST FIVE YEARS (Item II.K.3.17) Time to Plant Date Repair Component Reason Corrective Action Duration

  • Status 3/8/76 6 Days SI Accumulator Improper Operation Replaced Coil Unknown Mode 1 Safety Valve Solenoid (119 Days) 5/13/76 2 Hr.
  1. 1 LPSI Pump Excessive Leakage Added Packing 2 Hr.

Mode 1 12/16/76 4 Hr.

  1. 1 HPSI Pump Seal Failure Installed New Casket 4 Hr.

Mode 1 40 Min. (One of Three) 40 Min. 1/7/77 2 Hr..

  1. 1 LPSI Pump Worn Packing Repacked Pump 2 Hr.

Mode 1 40 Min. (One of.Three) 40 Min. t 8- [ 3/1/77 3 Hr.

  1. 1 Emerg. Diesel Starter Motor Failure Replaced Starter Motor 3 Hr.

Mode 1 (One of Three) 5/24/77 4 Hr. SI Accumulator Instrument Drift Calibrated Instrument Unknown Mode 1 Low Level Raised Level of (20 Mos.) (Level Instrument) Accumulator 8/2/77 ~ 5 Days

  1. 1 Emerg. Diesel Overheated Due to Cleaned Radiator Unknown Mode 6 (One of Three)

Radiator Fouling (18 Mos.) 8/2/77 11 Days

  1. 3 Emergency Diesel Overheated Due to Cleaned Radiator Unknown Mode 6 (One of Three)

Radiator Fouling (18 Mos.) 1/26/78 5 Hr. SI-TV-604 Valve Leaked by Seat Repaired (Replaced 5 Hr. Mode 2 5 Min. (To Repair Had to Shut Seal Ring) 5 Min. SI-V-53 & 69 Making-PR-59 Inoperable)-

    • Duration is the maximum possible out of tolerance duration. In most cases, the actual duration is unknown; the duration shown in parenthesis is the time between surveillance testing.

Item: III.D.3.4

Title:

Control Room Habitability In response to Item IIID.3.4, control room habitability has been evaluated for Yankee Nuclear Power Station. Both radiological and chemical releases were considered. The following Regulatory Guides and sections of the Standard Review Plan were utilized in performing the evaluation: 1. USNRC, Standard Review Plan, Section 2.2.1-2.2.2, " Identification of Potential Hazards in Site Vicinity". 2. USNRC, Standard Review Plan, Section 2.2.3, " Evaluation of Potential Accidents". 3. USNRC, Standard Review Plan, Section 6.4, " Habitability Systems". 4. USNRC, Standard Review Plan, Section 15.4.9, " Radiological Consequences of Control Rod Drop Accident (BWR)". 5. USNRC, Regulatory Guide 1.78, " Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release". 6. USNRC, Regulatory Guide 1.95, " Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release". 7. USNRC, NUREG-0570, " Toxic Vapor Concentration in the Control Room Following a Postulated Accidental Release". 8. USNRC, NUREC/CR-009, " Technological Bases for Models of Spray Washout of Airborne Contaminants in Containment Vessels". Where exceptions have been taken to the above mentioned documents, explanations are provided in Attachment A. l I. RADIOLOGICAL RELEASE, Discussion used to analyze the control room dose from The following assumptions ver s a Design Basis LOCA. i 1. Instantaneous release of 100% of the noble gases and 50% of the halogens to the containnent atmosphere. 2. 50% of the airborne halogens plateout leaving a total of 25% of the halogens airborne and available for release. l _. ~.

3. Containment leak rate is 0.2% per day for the first 24 hours and 0.1% per day thereaf ter. 4. The infiltration rate into the control room is assumed to be 34 cfm for the duration of the accident. 5. X/Q 's were calculated based on a release from the containment to the turbine building. The released activity is assumed to infiltrate into the control room from the turbine building. Results Results of this evaluation indicate that a control room emergency filtration system will be needed to maintain doses within acceptable limits under the assumptions for halogen release stated above. We intend to complete this mooffication by January 1, 1983. This will permit us sufficient time to engineer and procure the necessary equipment as well as determine the impact of the SEP on this modification. II. CHEMICAL RELEASE Discussion The evaluation of control room habitability from potential hazardous chemicals was done according to criteria in Regulatory Guide 1.78 and methodology in NUREG-0570. The chemical releases considered were the following: 1. All potentially hazardous chemicals stored on-site. See Attachment A Response 1.3. 2. Off site manufacturing, storage or transportation facilities of hazardous chemicals within a five-mile radius. See Attachment A Response I.4. A detailed discussion of the assumptions used in the analysis is provided in Attachment A, Section III. Results l 1. No potential hazard was defined for control room personnel from toxic chemical materials stored on-site. 2. No potential hazard was defin:d for contcel roan personnel from off-site manufacturing, storage or transportation of hazardous materials. 1 l

ATTACHMENT A I. Information Required for Control Room Habitability Evaluation 1. Control Room Mode of Operation: The normal mode of control room ventilation operation is 100% recirculation with fresh air makeup provided on a as-needed basis. 2. Control Room Characteristics a. Air Volume of Control Room The air vo2ume of the control room is 33,660 cu. ft. b. The Control Room Emergency Zone All instrumentation and controls necessary for safe plant shutdown are located in the control room. A controlled set of all drawings and procedures necessary to operate the plant are also kept in the control room. The operations office, TSC, the operator's wash room, Reactor Engineering Office, and kitchen are located in the Control room.

c.. Control Room Ventilation System Schematic N/A see 1 d.

Infiltration Leakage Rate The infiltration leakage rate assumed in the analysis is 34 cfm. e. HEPA Filter and Charcoal Adsorber Efficiencies There are no filters in the Yankee control room ventilation system. l f. Closest distance between containment stack and control room air intake X/Q 's were calculated based on a distance of 35 meters from the containment to the turbine building (see assumption 5 under l Radiological Releases). g. Control Room Layout and Chemical Storage Refer to Figure III.D.3.4.1. h. Control Room Shielding The Yankee control room is protected from radiation sources by four feet of concrete shiciding on the roof and south wall, and i l l

hree feet of concrete shielding on the east and west walls. The north wall of the control room is presently being modified by the addition of twelve inches of concrete shielding along the entire length.
i. Automatic Isolation Capacity Yankee does not have control room automatic isolation capability.

J. Chlorine or Toxic Gas Detectors Yankee does not have any control room toxic gas detectors. k. Self-Contained Breathing Apparatus The Yankee control room is s'.ocked with three sets of Scott air packs. 1. Bottled Air Supply The Yankee control room contains a 4.5 man-hour supply of bottled air. Emergency Food and Water Supply m. The Yankee control room will contain emergency food supplies. The potable water supply is a deep well. Bottled water is also supplied. n. Control Room Personnel Capacity Under normal conditions the control room personnel capacity is five. Under accident conditions the personnel capacity is three. o. Potassium Iodide Drug Supply The Yankee control room is equipped with a potassium iodide drug supply. No credit has been taken for the use of thyroid blocking agents ot self-contained breathing apparatus in the dose calculations performed. 3. On-Site Storage of Chlorine and Other Hazardous Chemicals - Total Amount Location and Size of Container 98% h a. 2SO4 - 1500 gallons e ted i the Thewatertreatmentroomks$ocateSattUatertre$bmenktSom. e east s eo e turbine building at elevation 1022' 8". The room has three vents, two closed louvered openings in the external wall and one roof louver. There is no forced ventilation in the room. Concentrated sulfuric acid is non-volatile and presents no hazard as a toxic fume. A reaction between concentrated sulfuric acid and water could release sufficient heat to vaporize the acid as an aerosol. This accident, - - ~ -. --

t is not considered feasible since there are no sprinklers above the tanks and the top tank entrances are kept in place. b. 50% NaOH - 1500 gallons located in the water treatment room. Sodium Hydroxide is non-volatile and presents no hazard as a toxic fume. If NaOH and sulfuric acid are intermixed, a neutralization reaction occurs, resulting in release of heat, sodium sulfate and mists of entrained acid and caustic. 1 The accident is feasible, if either chemical was pumped in large quantities, into the wrong tank. This is not considered a possible pathway since the outside loading connections are dissimiliar and very clearly labeled. There are no common plumbing to between the two tanks that would allow intermixing. I If a spill were to occur in the water treatment room, there are floor drains that lead to a large neutralization tank. c. Halon fire protection system - Halon is a gas containing bromotrifluromethane and is classified as a simple asphyxiant. Yankee has six compressed gas bottles, each containing 240 pounds, stored in the switchgear room, and one bottle containing 45 pounds, stored in battery room one and two. The switchgear room and battery rooms are located under the control room at elevation 1037' 8". 1 - Upon the initiation of the iire system there is a sounding of a l local alarm and an alarm in the control room. The rooms are l subsequently automatically isolated with the closure of fire dampers and supply fans. Thirty seconds later the halon gas is released. The gas is purged from the switchgear and battery rooms via the existing room ventilation (three 10,000 cfm dampers) to the turbine hall, which has two large ventilators (each 145,000 cfm) located on the building roof. The results of the analysis indicate that the control room concentration is less than 1% by volume and is thus not considered a hazard to control room personnel habitability. d. Chloroethane - 55 gallon drums located in the lube oil room. Chloroethane is a liquid cleaner consisting of 1,1,1-trichloroethane which has a toxicity limit in air of 350 ppm (2084 mg/m3). The lube oil room is a small enclosed room located on the east side of the ground floor (elevation 1022' 8") of the turbine building. The exhaust system consists of a centrifugal fan unit (2500 cfm) located above the oil storage room ceiling with' suction duct work exhausting from high and low room levels and a discharge duct exhausting to outdoors. Air is drawn into the oil room from the condenser room through fire dampers. Analysis indicates chloroethane is not a hazard to contro_*. room habitability. l ..m.. ,,.. _. ~ _, - _.._._-,,--,,---,.,_,,,m-,-..,_--.- _, ~, _., -,

e. Unisol - 55 gallon drums located in the lube oil room. Unisol is a solvent degreaser consisting of methylene chloride 15% (toxicity 250 ppm - 948 mg/m3), perchloroethylene 35% (toxicity 100 ppm - 740 mg/m3) and 1,1,1-trichloroethane 50%. Analysis indicates unisol is not a hazard to control room habitability. f. Hydrazine - 55 gallon drums, 35% aqueous solution, located in the water treatment room. Hydrazine has a toxicity limit in air of 1 ppm (1.4 mg/m3) and is not considered a flammable hazard in concentration of 35%. Analysis indicates hydrazine is not a hazard to control room habitability. g. Penetone Formula 2101 - 55 gallon drums located in the lube oil room. Penetone 2101 contains methylene chloride. Analysis indicates Penetone 2101 is not a hazard to control room habitability. h. Penetone Inhibisol - 55 gallon drums, located in the lube oil room. Penetone inhibisol contains 1,1,1-trichloroethane. Analysis indicates Penetone inhibisol is not a hazard to control room habitability. 1. CO2 - 300ft3 gas bottles located in the turbine hall stairwell below the control room, elevation 1022' 8". CO2 is considered an asphyxiant with a toxicity limit of 1% volume. Analysis indicates that the rupture of a CO2 gas cylinder is not a hazard to control room habitability. 4. Off-Site Manufacturing, Storage or Transportation Facilities of Hazardous Chemicals a. The only manufacturing or storage facility within five miles of Yankee is the Deerfield Paper Company. They were contacted and indicated they do not store or use any hazardous chemicals that may result in toxic fumes upon release into the atmosphere. b. N/A see 4.1 c. N/A see 4.1 d. The following chemicals are transported by the Boston and Maine Railroad on a rail line which is located at its closest point, 4 miles from the site. The Manager of Safety could not supply average weights per tank car but estimated the quantities to be 10,000 - 30,000 gallons. The frequency of shipment is based on commodities carried during the year 1979. l Frequency Hazardous Material (cars per year) Acrylonitrile (Flammable Liquid) 18 Alcohol, Denatured (Flammable Liquid) 37 Amylenes Pentene (Flammable Liquid) 10 Carbon Bisulfide (Flammable Liquid) 3 Compound, Polishing Liquid (Flammable Liquid) 3 Epichlorohydrin (Flammable Liquid) 8 l Ethyl Acetate (Flammable Liquid) 1 Ethyl Acrylate (Flammable Liquid) 4 Ethyl Alcohol, Cologne Spray (Flammable Liquid) 2 Ethylene Oxide (Flammable Liquid) 5 Hexane (Flammable Liquid) 5 Jet Fuels (Flammable Liquid) 11 Methanol (Flammable Liquid) 17 Methyl Methacrylate Monomer Inhibited (Flammable Liquid) 317 Propyl Alcohol (Flammable Liquid) 3 Propylene Oxide (Flammable Liquid) 6 Spirits, Alcohol (Flammable Liquid) 3 Styrene, Liquid (Flammable Liquid) 4 Tetrahydrofuran (Flammable Liquid) 2 Toluene (Flammable Liquid) 3 Vinyl Acetate (Flammable Liquid) 55 Vinylidene Chloride, Inhibited (Flammable Liquid) 3 Xylene (Flammable Liquid) 1 Alcohol, N.O.S. (Flammable or abustible Liquid) 304 Anti-Freeze Preparation (Flammaole or Combustible Liquid) 2 Asphalt Tile (Flammable or Combustible Liquid) 2 Brandy, Alcoholic (Flammable or Combustible Liquid) 9 Coal Tar (Flammable or Combuctible Liquid) 11 Compounds, Waterproofing (Flasmable or Combustible Liquid) 1 Defoaming Compound (Flammable or Combustible Liquid) 4 Fuel Oil Distillate (Flammable or Combustible Liquid) 10 Ink Materials (Flammable or Combustible Liquid) 1 Naphtha (Flammable or Combustible Liquid) 28 Pipeline Coating (Flammable or Combustible Liquid) 1 Plasticizers, Paint, Lacquer or Varnish (Flammable or Combustible Liquid) 117 Pulp Mill Liquid (Flammable or Combustitle Liquid) 5 Rosin Solution (Flammable or Combustible Liquid) 6 Rubber Preservative (Flammable or Combustible Liquid) 5 Turpentine (Flammable or Corbustible Liquid) 5 Wines, Not elsewhere classified (Flammable or Combustible Liquid) 787 .Wood Turpentine (Flammable or Combustible _iquid) 1 Alcohol, Furfury (Combustible Liquid) 7 Alcohol Hexyl (Combustible Liquid) 21 Decyl Alcohol (Combustible Liquid) 6 i Diisobutyl Ketone (Combustible Liquid) 3 Glycol Ethers (Combustible Liquid) 1 _- _ _ _. _ _ _ -. -.. _.. _ _ - _ _ _ _ _. _ - ~ _,

Frequency Hazardous Material (cars per year) Octyl Alcohol (Combustible Liquid) 3 Pine Oil (Combustible Liquid) 8 Refined Oil, Burning / Illuminating (Combustible Liquid) 75 Anhydrous Ammonia (Non-Flammable Gas) 156 Carbon Dioxide (Non-Flammable Gas) 189 Chlorine (Non-Flammable Gas) 380 Fert. Ammoniating Solution (Non-Flammable Gas) 137 Sulfur Dioxide (Non-Flammable Cas) 6 Butadiene (Flammable Gas) 4 Dimethylamine (Flammable Cas) 9 Dimethyl Ether (Flammable Gas) 1 Hydrogen Sulfide (Flammable Gas) 2 Isobutane (Flammable Gas) 7 Liquefied Petroleum Gas (Flammable Gas) 1301 Mineral Spirits (Flammable Gas) 1 Vinyl Chloride (Flammable Gas) 7 Anti-Knock Compound (Poison B) 4 Arsenic Acid (Poison B) 4 Arsenic, Crude (Poison B) 43 Calcium Arsenate (Poison B) 1 Carbolic Acid (Poison B) 30 Insecticides (Poison B) 20 Toluene Diisocyanate (Poison B) 11 Hydrocyanic Acid (Poison A) 513 Cartridges, Small Arms (Explosives C) 2 Ammonium Nitrate Fertilizer (Oxidizer) 6 Calcium Nitrate (Oxidizer) 8 Fertilizing Compounds (Oxidizer) 69 Hydrogen Peroxide (Oxidizer) 3 Lead Peroxide (Oxidizer) 2 Potassium Perchlorate (Oxidizer) 4 i Sodium Chlorate (Oxidizer) 27 Sodium Nitrate (Oxidizer) 11 l Sodium Nitrite (Oxidizer) 6 Acid, N.E.C. Dry (Corrosive Material) 37 l Acid, Propionic (Corrosive Material) 5 Acid Sludge (Corrosive Material) 13 Butyl Phenol (Corrosive Material) 74 l Chloral (Corrosive Material) 1 Diethanolamine (Corrosive Material) 4 Ethylenediamine (Corrosive Material 1 l .Hydrofluosilicic Acid (Corrosive Material) 211 Hydrochloric (Muriatic) Acid (Corrosive Material) 201 l Phosphatic Fert. Solution (Corrosive Material) 64 l Phosphoric Acid (Corrosive Material) 29 Phosphorus Trichloride (Corrosive Material) 76 Potassium Hydroxide (Corrosive Material) 19 Sodium Hypochlorite (Corrosive Material) 1 l l,-

Frequency Hazardous Material (cars per year) Sodium Hydrosulphide (Corrosive Material) 5 Sodium Hydroxide (Corrosive Material) 1323 Sulphide Waste (Corrosive Material) 3 Sulphuric Acid (Corrosive Material) 47 Water Treatment Compounds (Corrosive Material) 25 Calcium Carbide (Flammable Solid -W-) 37 Metallic Sodium (Flammable Solid -W-) 58 Aluminum Alloy, Powdered (Flammable Solid) 1 Burnt Cotton (Flammable Solid) 134 Carbon, Activated (Charcoal) (Flammable Solid) 5 Charcoal Briquets (Flammable Solid) 74 Fibers (Flammable Solid) 4 Fish Meal (Flammable Solid) 24 Matches (Flammable Solid) 7 Phosphorus, N.E.C. (Flammable Solid) 59 229 Rags (Flammable Solid) Scrap Rubber (Flammable Solid) 50 Sodium Hydrosulphite (Flammable Solid) 23 49 Tankage (Flammable Solid) 20 Waste Paper (Flammable Solid) 8 Wool Waste (Flammable Solid) The closest major highway is U.S. Route 2, an east-west road which carries a small amount of truck traffic. An analysis was done assuming a six-ton chlorine tank truck rupture. 5. Technical Specifications Yankee has no technical specifications regarding control room habitability. t

II. CHDfICAL RELEASE ANALYSIS ASSUMPTIONS Discussion The chemical releases considered were the following: 1. All potentially hazardous chemicals stored on-site. See response to I.3. 2. Off-site manufacturing, storage or transportation facilities of hazardous chemicals within a five-mile radius. See response to I.4. The evaluation of control room habitability from potential hazardous chemicals was done according to criteria in Regulatory Guide 1.78 and methodology in NUREG-0570. The following assumptions were used in the analysis: 1. The volatility of a substance was determined by its vapor pressure. For compressed and liquified gases and liquids whose normal boiling points are far below the ambient temperature, (21 C), instantaneous flashing (rapid formation of a puff), and continual vaporization by drawing heat from the surroundings was taken into account. The values used for determining the vaporization rates were: d. Atmospheric and Solar Radiation 2 qr = 212 cal /m ,,c b. Earth Conduction .5 c,37,2 qd = 197 (21 -T ) t see B TB = n rmal boiling of the liquid c. Forced Air Convection 2 qc = 1.6 (21 -T ) cal /m sec B 2. Chemicals with normal boiling points above the ambient temperature will evaporate or vaporize into the atmosphere. For chemicals stored outside of plant buildings, the rate of evaporation was determined by forced convection. For chemicals stored in areas Hof confined buildings, the rate of release was determined by gaseous diffusion in still air. i I l 3. The meterological parameters used were: wind speed = 1m/sec blowing from the release point to the control room fresh air intake, stability class = F X/Q = According to the Gaussian plume model, the basic equation for atmospheric diffusion for the continuous release of a plume from a source at ground level is: 1 2 X/Q = exp (~Y 2) exp (~Z2) (Eq. 1) 2 'TTU6 6 26 (2 6 ) 7 2 and represents the relative concentration (sec/m ) at distance R(m) 3 from the source in the direction of the wind at an elevation Z(m) and a lateral displacement Y(m) from the plume centerline. The horizontal and vertical diffusion coefficients for that distance are 6 and 6, 7 3 respectively. The wind speed in m/sec, is designated as U Yankee is located at the bottom of a deep river valley approximately 1150 feet above sea level. Due to the unusually high mixing rate that prevails within the valley, cross-valley plume concentrations depart from the above Gaussian dictribution and become essentially uniform. For this reason, the diffusion estimate was based on the integral of Equation 1 in the z direction from 0 to00and in the y direction from -oo to +00 divided by the valley cross-sectional area between the valley floor and a height H. The continuous diffusion equation for such a uniform concentration is: 1 6, 42 Tr 6 X/Q = TU6 6 W 2H 7z 1 i UWH (Eq. 2) W(m) is the mean width of the valley at a height H/2. The mixing height H was chosen to correspond to the vertical distance where the Gaussian plume concentration drops to 10 % of its value on the plume axis (obtained from, D.H. Slade, Ed., " Meteorology and Atomic Energy" - 1968, USAEC); H = (21n 100/10).56, = 2.14 6. 2 Topographical maps of the region where Yankee is situated, indicate that the mean width of the valley at the 1150 foot level is approximately 350 meters. In addition, the slopes of the valley average about 20 degrees. Accordingly, the valley mean width at a height H/2 is; W = 350 + H cot (20). The diffusion equation used for an instantaneous puff release was based on the assumption of a Gaussian distribution along the wind direction; 1 X/Q = exp [.5(x/6x)2]. (Eq. 3) WH (2 5 ).5 6x According to methodology in NUREG-0570, the above parameters are calculated as follows: 62=6[+6, 2 6[=0.05(X)0.61, o 6,= [Mvo/2 7 3/2gyjl/3, 1/2 6 = 0.02 (X )0.89 and x o X = X -Ut, o where: 6 = initial standard deviation of the puff (M), o Mvo = mass of the instantaneously released puff (gram), (v = density of the puff (g/m ) 3 X = ground distance between the source of spell and receptor (m), o and t = time after release (sec). 4. Yankee has no forced ventilation into the control room. Infiltration into the control room was assumed to be 0.06 volume changes per hour i and was calculated to be 34 cfm. This is the recommended value from K.G. Murphy and K.M. Campe, " Nuclear Power Plant Control Room Ventilation System Design for Meeting General Criterion 19", 13th AEC l Air Cleaning Conference, August, 1974. l S. The rate of mass transfer (vaporization or evaporation) was assumed i to be directly proportional to the surface area of the spill. For spills occurring inside buildings, the maximum area was fixed by the room dimension. For spills occurring outside confined areas, the maximum area of the spill was estimated from the initial volume assuming l a spill thickness of I cm. 6. Toxicity limits not given in Regulatory Guide 1.78 were obtained from the following references: Dangerous Properties of Industrial Materials, N. Irving Sax 4th a. { i

Ed., Van Nostrand Reinhold Co., New York, 1975. b. The Condensed Chemical Dictionary, Gessner G. Hawley, 9th Ed., Van Nostrand Reinhold Co., New York. 7. The following general equation was used to determine the chemical concentration buildup in the control room; .d,A. pg (xfq) _ F,A dt V where: F = fresh air infiltration rate into the control room, M_.3, S M = source strength, g or release rate, g sec-1 E = dispersion for puff release, m-3 or vaporization release, sec Q -3 m A = amount of chemical in the control room, grams V = control room volume, m3 Solution: [T 3 [ CT= = A exp(i) + exp(i) FMX exp(_F ) dt (Eq. 4) o t V V V Q V o J where: A = initial amount of chemical in the control room - assumed to o be zero CT=concentragionasafunctionoftimepost-accidentinthecontrol room, g/m The concentration buildup inside the control room as a function of time after the postulated chemical cpill was calculated. If the concentration did not exceed the toxicity limit as defined in Regulatory Guide 1.78, it was concluded that the chemical could not result in the control room becoming uninhabitable. A: On-Site Chemicals The following assumptions were used in the analysis of control room habitability from on-site storage of potentially hazardous chemicals: s 1. Release of the total contents of the largest container of each hazardous chemical stored on-site in excess of 100 pounds, unless the containers were interconnected in such a manner that a single failure could result in release from several containers. 2. The vapor pathway to the control room from chemicals stored in plant buildings was through the storage location ventilation exhaust system and then into the control room via the fresh air intake. 3. Accident scenarios were considered for nonvolatile chemicals that could release hazardous vapors or mists upon interaction with the environment or as a result of a plant fire. 4 The following general equation was used to determine the chemical concentration buildup in the control room from chemicals which vaporize inside plant buildings: a. Release rate out of the storage room dm FM R =R,- dt VR where: R' = chemical vaporization rate, gram sec-1 3 -1 FR = ventilation exhaust, m eec 3 Vg = room volume, m M= mass airborne in the room, gram solution: T r M' = % exp (_ h T) FR R'eXP( t') dt' (Eq. 5) V V R R J o b. Concentration in the control room (substitution of Equation 5 into Equation 4) T t f f R exp(_ R T) exp( b t) exp(F_ t) R'exp( t') dt' dt CT, VQ ' V V V V V R R R Ao do -27.

Results As a result of the evaluation, no potential hazard was defined for control room personnel from toxic chemical materials stored on-site. B. Off-Site Chemicals The following assumptions were used in the analysis of control room habitability from off-site manufacturing, storage or transportation facilities of hazardous materials: 1. Hazardous chemicals have been identified as being shipped on the main east-west rail line of the Boston and Maine Railroad, located at its closest point approximately four miles from the south side of the site. An analysis was done for all shipments defined by Regulatory Guide 1.78 as being frequent, i.e., 30 per year for rail traffic. 2. The analysis was based on the maximum concentration accident, in which the quantity of the hazardous chemical considered was the instantaneous release of the total contents of the largest tank car. This is the case compared with partial ruptures where the contents leak out worst in a steady flow. This was confirmed with a chlorine tank car having an assumed leak rate of 1 kg/sec as suggested in "The Accidental Episode Manual" prepared for the Environmental Protection Agency, January 1972. 3. The concentration buildup in the control room was the sum of the concentration due to the instantaneous puff and the concentration due to the continual vaporization of the remaining mass. 4. The only major highway by Yankee is Route 2, an east-west road located at its closest point six miles from the station. An accident analysis was done assuming a six ton chlorine tank truck rupture. I Results As a result of the rail line and truck transportation analysis, no potential l hazard was defined for control room personnel. l l l l i,

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