RA10-035, 2010 Triennial Chlorine Survey Report

2010 Triennial Chlorine Survey Report

ML101310212
Person / Time
Site:	LaSalle
Issue date:	05/07/2010
From:	Wozniak D Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA10-035
Download: ML101310212 (10)

Text

Exelon Generation Company, LLC www.exeloncorp.com LaSalle County Station Nuclear 2601 North 21" Road Marseilles, IL 61341-9757 10 CFR 50.4 RA10-035 May 7, 2010 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374

Subject:

2010 Triennial Chlorine Survey Report Enclosed is the Exelon Generation Company, LLC, LaSalle County Station (LSCS) 2010 Triennial Chlorine Survey Report. The survey is submitted in accordance with the provisions of the April 11, 1986, letter transmitting Amendments 38 and 20 to the LSCS Facility Operating Licenses for Units 1 and 2, respectively.

Should you have any questions concerning this letter, please contact Mr. Terrence Simpkin, Regulatory Assurance Manager, at (815) 415-2800.

Respectfully, David B. Wozniak Site Vice President LaSalle County Station Attachment cc: Regional Administrator - NRC Region III NRC Senior Resident Inspector - LaSalle County Station

CHLORINE SURVEY IN THE VICINITY OF LASALLE COUNTY GENERATING STATION

1. Executive Summary A triennial survey of potential sources of chlorine was conducted by LaSalle station to ensure compliance with General Design Criteria (GDC) 19 of Appendix A of 10CFR 50.

The 3 year survey re-evaluates use of chlorine within 5 miles of the plant's Control room and ensures that a chlorine hazard does not exist. The survey also ensures compliance with Regulatory Guides (RG) 1.78 revision 0, "Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release" and RG 1.95 revision 0, "Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release".

A database of potential chlorine sources was built based on facilities identified in previous surveys and updated with information from the Grundy and LaSalle County Emergency Services and Disaster Agencies (ESDA). The database was limited to facilities located between the Marseilles and Dresden Island Locks and included facilities within and outside the five-mile radius of LaSalle Station. A total of seventeen facilities in Grundy and LaSalle Counties fit the criteria and were included in this survey.

Data from seven controlling authorities and seventeen facilities was reviewed and follow-up contacts were made to confirm the information gathered. The 2010 survey identified nine facilities that used and stored chlorine onsite. Three of the nine chlorine sites identified are located within the five-mile radius of LaSalle Station. All nine facilities reported their chlorine was stored in 150 lb. cylinders. Per Regulatory Guide 1.95 revision 0, storage of single containers of chlorine exceeding 150 lbs would require installation of chlorine detectors and automatic protective features located at the fresh air inlet of control room ventilation.

The results of this survey indicate chlorine is used and stored in cylinders that are not larger than 150 lbs. at facilities in the vicinity of LaSalle Station. Also no chlorine is transported on the Illinois River.

2. Introduction Licensing of LaSalle County Generating Station required a survey of industries and transportation routes in the site vicinity that may use, store, and/or transport hazardous chemicals. The original survey, conducted in 1975, revealed anhydrous ammonia and probably chlorine were transported by barge on the Illinois River. The information gathered was not complete enough to conclude that chlorine was not shipped in large quantities by barge on the Illinois River.

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A new survey was conducted in January-February 1986 to supplement the information obtained from the 1975 chlorine survey. The information collected by the 1986 survey concluded no special chlorine protection provisions were required at LaSalle Station. In the safety evaluation supporting Amendment No. 38 to Facility Operating License No.

NPF-1 1 and Amendment No. 20 to Facility Operating License No. NPF-1 8, the U.S.

Nuclear Regulatory Commission (NRC) agreed with this conclusion, but recommended a three-year update for the Illinois River chlorine survey. Exelon Corporation committed to the survey update in a letter to the NRC dated March 5, 1986. Surveys have been conducted on a 3 year frequency supporting the conclusion that chlorine is not shipped on the Illinois River in sufficient quantities to present a hazard to the LaSalle Station Control Room. In accordance with this commitment, a new survey has been conducted in 2010.

The following sections describe regulatory guides that form the basis of the control room habitability evaluation, results of previous surveys, the methods and results of current survey, and the conclusion regarding chlorine as a hazard. The results of the current survey and previous surveys fully support the 1986 conclusion that no special chlorine protection measures are required at LaSalle Station.

3. Regulatory Guides Regulatory Guide 1.78 revision 0, "Assumption for Evaluating the Habitability of a Nuclear Power Plant Control Room during a Postulated Hazardous Chemical Release" identifies chlorine as a hazardous chemical that requires a control room habitability analysis in the event of an accidental chlorine release from stationary or mobile sources near the station. Regulatory Guide 1.95 revision 0, specifically addresses onsite accidental chlorine release. However, it can also be used in analyzing effects of an offsite chlorine release.

Regulatory Position 1 of Regulatory Guide 1.78, states chlorine stored or situated at greater distances than five miles from the control room need not be considered in evaluating habitability of the nuclear power plant control room during a postulated chlorine release. Regulatory Guide 1.78 also specifies frequency, distance, and quantity of chemicals transported or stored with respect to the control room that require a control room habitability analysis. The Regulatory Guide specifies three modes of transportation that must be considered for chlorine manufactured, stored or used by industries in the vicinity of the control room: railroads, highways, and waterways.

4. Earlier Surveys Of Chlorine Shipment The LaSalle County Final Safety Analysis Report (FSAR) Section 2.1.1 describes the location of the plant and transportation routes near the plant. FSAR Section 2.2.2 describes nearby industrial, transportation, and military facilities. All industrial facilities are located outside of a five-mile radius of the plant, therefore, chlorine used or stored at these facilities need not be considered in evaluating control room habitability. A survey of these industries was conducted in 1975 to determine the shipment of chlorine by three modes of transportation, U.S. Highway 6 and State Highway 47, the nearest highways to the station used by these industries and the Chicago Rock Island and Pacific, the nearest railroad, are all located farther than five miles from the station. Therefore, transportation of chlorine by these two modes of transportation need not be considered in the control room habitability analysis.

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FSAR Section 2.2.2.4 describes river traffic on the Illinois River passing the site. Section 2.2.3.1.c concluded the only transportation route potentially carrying chlorine within five miles of the station was the Illinois River, which is located approximately 4.7 miles north of the station. However, the available data on commodities transported on the Illinois River (FSAR Table 2.204) did not differentiate barge shipments of chlorine from other chemicals. The survey found a small quantity of chlorine was used by the Illinois Nitrogen Corporation, located at river mile 248.7, approximately five miles north of the station, however, there was not sufficient information available if it was receiving chlorine supply by barge. In order to expedite the licensing process, chlorine detectors were provided in the control room HVAC system intake air ducts.

To supplement the 1975 survey and to obtain additional specific information on chlorine shipments, a survey was conducted during January-February 1986 to determine whether chlorine was, in fact, transported in barges on the Illinois River.

Information was collected from the U.S. Army Corps of Engineers, the U.S. Coast Guard, and Lockmasters for Starved Rock and Dresden Dams. None of the sources had information suggesting chlorine is transported on the Illinois River. Because none of the barge operators, barge terminals, or chemical companies reported chlorine shipments on the Illinois River and neither of the lockmasters was aware of any chlorine passing through their locks, it was concluded that chlorine was not shipped on the river in significant quantities.

5. Year 2010 Survey of Chlorine Shipments The criteria used for the 2010 survey limited sites of interest to those located between Marseilles and Dresden Island Locks and included facilities within and outside of the five-mile radius of LaSalle Station. Previous surveys were reviewed and updated from reports from Grundy and LaSalle County ESDA's.

Table 1 shows results of the seventeen barge terminals, chemical companies, water treatment plants, and potential chlorine users contacted. None of the barge terminals located between the closest upstream and downstream dams handle chlorine. None of the chemical companies, water treatment plants or other potential chlorine users sends or receives chlorine on the Illinois River. Nine facilities were identified using small quantities of chlorine. Three of these sites are located within five miles of LaSalle Station. All nine facilities stated their chlorine is transported and stored in 150 lb.

cylinders. CSX operates the closest regularly traveled railroad to LaSalle Station. The railroad is located outside the five-mile radius of LaSalle Station Table 2 shows the results of seven government agencies, public officials, and trade organizations contacted for the 2010 survey. The Chlorine Institute reported no chlorine is transported on the Illinois River, and has no knowledge of any chlorine producer or distributor located on the river. United States Coast guard stated that any company transporting chlorine on a barge is required to notify them and that they have not received such notification for the Illinois River. The Corps of Engineers provided information that, according to their records, no chlorine was moved on the Illinois River i,) he years 2007 and 2008.

LaSalle Station HAZMAT Coordinator reported no chlorine used or stored on-site.

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Although four facilities were identified using small amounts of chlorine, there was no indication chlorine is transported on the Illinois River.

6. Conclusion of Findings The 2010 survey concludes chlorine is not transported in any significant quantities on the Illinois River and within a five-mile radius of LaSalle Station. Small quantities of chlorine are used and stored in 150 lb. cylinders at nine sites. Three of the nine sites identified are within the five-mile radius of LaSalle Station. Regulatory Guide 1.95 C.3 states that only single container quantities exceeding 150 lb. need to be considered for control room ventilation requiring automatic chlorine protection features. Therefore, the 2010 survey concludes that chlorine detectors are not required for the LaSalle County Station.

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Table 1. Barge Terminals Chemical Companies, Water Treatment Plants, and Other Potential Chlorine Users in Towns on the Illinois River in the Vicinity of LaSalle Station Company County Address Phone Distance to Chlorine LaSalle Station Identified?

Cargill Inc. LaSalle S. Main Street (815) 357-8760 <5 miles None Seneca POC: Tom Cromwell Agrium US inc. (formerly LaSalle 2100 E. Broadway (815) 795-4151 >5 miles None Royster-Clark) Marseilles POC: Joe Moyer Morris Sewage Treatment Grundy N. River Road (815) 942-0643 >5 miles Yes Plant Morris 20 - 150 lb POC: Junior King cylinders PCS Phosphates LaSalle P.O. Box 88 (815) 795-5111 >5 miles None Marseilles POC: Bob Startzer Forbo Chemicals, Inc. Grundy Dupont Road (815) 357-6726 >5 miles None (formerly Reichhold Seneca Chemicals, Inc.) POC: Dick Oberholtzer Shipyard Terminal and LaSalle P.O. Box 380 (815) 357-6721 <5 miles None Industrial Park Seneca POC: George Lamb Marseilles Wastewater LaSalle #2 Spicer Lane (815) 795-2150 >5 miles Yes, 150 lb Cyl.

Treatment Facility Marseilles and 2 stored inside POC: Don Christiansen < 5 miles 7 stored outside 5 mile radius Village of Seneca Wastewater LaSalle 301 W. Union (815) 357-8406 <5 miles Yes Treatment Facility Seneca 9 - 150 lb POC: Paul Rivett cylinders 5

Table 1 (continued). Barge Terminals Chemical Companies, Water Treatment Plants, and Other Potential Chlorine Users in Towns on the Illinois River in the Vicinity of LaSalle Station Ay County Address Phone Distance to Chlorine LaSalle Station Identified?

ADM/Growmark LaSalle Towpath Road (815) 433-3635 >5 miles None Ottawa POC: Gary Boyd CF Industries, Inc Grundy 737 E. DuPont Road (815) 357-8811 >5 miles None Seneca POC: Ron Witalka Explosive Energies, Inc (This Grundy 7700 DuPont Road (815) 942-5802 >5 miles None facility was closed in 2006) Morris POC: Becky Younker Sabic Innovative Plastics LaSalle 2148 N 2753rd Rd (815) 434-7000 > 5 miles Yes (formerly GE Plastics) Ottawa, IL ext 7621 8 - 150 lb POC: Dave Parrot cylinders Air Products and Grundy 8805 Tabler Rd. (815) 941-0433 > 5 miles Yes Manufacturing Morris, IL 4- 150 lb POC: Mike Brown cylinders Marseilles Well House #4 LaSalle 350 10th St. (815) 795-4000 > 5 miles Yes Marseilles, IL 5 - 150 lb POC: Gary Flemming cylinders Marseilles Well House #5 LaSalle 930 Best St. (815) 795-4000 > 5 miles Yes Marseilles, IL 5 - 150 lb POC: Gary Flemming cylinders Marseilles Well House #6 LaSalle 2651 N. 2553rd Rd. (815) 795-4000 < 5 miles Yes Marseilles, IL 5 - 150 lb POC: Gary Flemming cylinders Pacific Street Well House LaSalle 215 Pacific St. (815) 795-4000 > 5 miles Yes Marseilles, IL 5 - 150 lb POC: Gary Flemming cylinders 6

Table 2. Government Agencies, Public Officials and Trade Organizations Organization Information that Chlorine is Transported on the Illinois River Chlorine Institute, Rosslyn VA None Illinois Department of Transportation, Hazardous Materials Division, None Springfield, IL Lockmaster, Marseilles, Illinois None Emergency Services and Disaster Agency of LaSalle County, Ottawa IL None Emergency Services and Disaster Agency of Grundy County, Morris IL None U.S. Army Corps of Engineers, Planning Division, Rock Island, IL None U.S. Coast Guard, Chicago IL. None 7

7. References Chlorine Institute, Rosslyn, VA, Mr Frank Reiner, Personal Conservation with Exelon Corporation on 03/15/10, (1'03)741-5762 Illinois Department of Transportation, Hazardous Materials Division, Springfield, Illinois, (217) 785-3064, Mr. Tom Wise, Personal Conversation with Exelon Corporation on 03/15/10.

Asst. Lockmaster, Marseilles Lock and Dam, Marseilles, Illinois, (815) 795-2593, Mr. Larry Rodriquez, Personal Conversation with Exelon Corporation on 03/15/10.

U.S. Army Corps of Engineers, Planning Division, Rock Island, Illinois, (309) 794-5366, Mr. Jack Karr, Personal Conversation with Exelon Corporation on 03/15/10.

Grundy County Emergency Services and Disaster Agency, (815) 941-3212, Mr. Jim Lute, Personal conversation with Exelon Corporation on 03/15/10 and e-mail received on 03/15/10.

LaSalle County Emergency Services and Disaster Agency, (815) 433-5622, Mr. Mike Jobst, Person Conversation with Exelon Corporation on 03/15/10.

Cargill Inc., Seneca, Illinois, (815) 357-8760, Mr. Tom Cromwell, Personal Conversation with Exelon Corporation on 02/18/10.

Agrium US Inc, Marseilles, Illinois, (815) 795-4151, Mr. Joe Moyer, Personal Conversation with Exelon Corporation on 02/19/10.

Morris Sewage Treatment Plant, Morris, Illinois, (815) 942-0643, Mr. Junior King, Personal Conversation with Exelon Corporation on 02/19/10.

PCS Phosphates, Marseilles, Illinois, (815) 795-5111, Mr. Bob Startzer, Personal Conversation with Exelon Corporation on 02/18/10.

Forbo Chemicals Inc., Seneca, Illinois, (815) 357-6726, Mr. John Raney, Personal Conversation with Exelon Corporation on 02/18/10.

Lamb Seneca Terminal (formerly Shipyard Terminal and Industrial Park), Seneca, Illinois, (815) 357-6721, Mr. George Lamb, Personal Conversation with Exelon Corporation on 02/19/10.

Wastewater Treatment Facility, Marseilles, Illinois, (815) 795-2150, Mr. Don Christiansen, Personal Conversation with Exelon Corporation on 02/18/10.

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Village of Seneca Wastewater Treatment Facility, Seneca, Illinois, (815) 357-8406, Mr. Paul Rivett, Personal Conversation with Exelon Corporation on 02/23/10.

ADM/Growmark, Ottawa, Illinois, (815) 433-3635, Mr. Gary Boyd, Personal Conversation with Exelon Corporation on

2/18/10.

CF Industries, Inc., Seneca, Illinois, (815) 357-8811, Mr. Ron Witalka, Personal Conversation with Exelon Corporation on 02/18/10.

Dyno Nobel (formerly Explosive Energies, Inc.), Morris, Illinois, (815) 795-4151, Mr. Mike Fritschtnitch, Personal Conversation with Exelon Corporation on 02/19/10.

US Coast Guard, Chicago, Illinois, (630) 986-2155, Response Desk, Marine Safety Unit - Chicago, Personal Conversation with Exelon Corporation on 03/15/10.

Sabic Innovative Plastics (formerly GE Plastics), Ottawa, Illinois, (815) 434-7000 ext. 7621, Mr. Dave Parrot, Personal Conversation with Exelon Corporation on 02/24/10.

Air Products and Manufacturing Corp, Morris, Illinois, (815) 223-2924, Mr. Gary Ghighi, Personal Conversation with Exelon Corporation on 3/23/10.

Marseilles Streets Department, Marseilles, Illinois (815) 795-4000, Mr. Gary Fleming, Personal Conversation with Exelon Corporation on 3/25/10.

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