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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl 05000382/LER-1999-005, Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits1999-06-24024 June 1999 Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits ML20196G5731999-06-24024 June 1999 Forwards Operator Licensing Exam Outlines Associated with Exam Scheduled for Wk of 991004.Exam Development Is Being Performed in Accordance with NUREG-1021,Rev 8 ML20212J4121999-06-23023 June 1999 Responds to NRC Re Reconsideration of EA 98-022. Details Provided on Actions Util Has Taken or Plans to Take to Address NRC Concerns with Ability to Demonstrate Adequate Flow Availability to Meet Design Requirements ML20196E9371999-06-22022 June 1999 Forwards Revs Made to EP Training Procedures.Procedures NTC-217 & NTC-217 Have Been Deleted.Procedure NTP-203 Was Revised to Combine Requirement Previously Included in Procedures NRC-216 & NTC-217 ML20196A1021999-06-17017 June 1999 Provides Supplemental Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Per 990513 Request of NRC Project Manager ML20195F3671999-06-0909 June 1999 Forwards Rev 21,Change 0 to EP-001-010, Unusual Event. Rev Reviewed in Accordance with 10CFR50.54(q) Requirements & Determined Not to Decrease Effectiveness of Emergency Plan ML20195C7801999-06-0303 June 1999 Submits Response to Violations Noted in Insp Rept 50-382/99-08.Corrective Actions:All Licensee Access Authorization Personnel Were Retrained Prior to Completion of Insp ML20195C2951999-05-28028 May 1999 Forwards Annual Evaluation of Changes & Errors Identified in Abb CE ECCS Performance Evaluation Models Used for LOCA Analyses.Results of Annual Evaluation for CY98 Detailed in Attached Rept,Based Upon Suppl 10 to Abb CE Rept ML20195C0241999-05-28028 May 1999 Notifies NRC of Operator Medical Condition for Waterford 3 Opertaor Sp Wolfe,License SOP-43723.Attached NRC Form & Memo Contain Info Concerning Condition.Without Encls ML20196L3281999-05-24024 May 1999 Informs That Entergy Is Withdrawing TS Change Request NPF-38-205 Re TS 3.3.3.7.1, Chlorine Detection Sys & TS 3.3.3.7.3, Broad Range Gas Detection Submitted on 980629 ML20206S4691999-05-17017 May 1999 Requests Waiver of Exam for SRO Licenses for an Vest & Hj Lewis,Iaw 10CFR55.47.Both Individuals Have Held Licenses at Plant within Past Two Year Period,But Licenses Expired Upon Leaving Util Employment.Encl Withheld 05000382/LER-1999-004, Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.31999-05-14014 May 1999 Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.3 ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 ML20206J1471999-05-0606 May 1999 Requests That Implementation Date for TS Change Request NPF-38-211 Be within 90 Days of Approval to Allow for Installation of New Monitoring Sys for Broad Range Gas Detection Sys ML20206J1721999-05-0606 May 1999 Notifies That Proposed Schedule for Plant 1999 Annual Exercise Is Wk of 991013.Exercise Objective Meeting Scheduled for 990513 at St John Baptist Parish Emergency Operations Ctr ML20206G8021999-05-0404 May 1999 Provides Revised Response to NRC Re Violations Noted in Insp Rept 50-382/99-01.Licensee Denies Violation as Stated.Change Made Is Denoted by Rev Bar & Does Not Materially Impact Original Ltr ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested ML20205T2531999-04-22022 April 1999 Forwards LER 99-S02-00,describing Occurrence of Contract Employee Inappropriately Being Granted Unescorted Access to Plant Protected Area ML20205R2611999-04-20020 April 1999 Forwards Rev 19 to Physical Security Plan,Submitted in Accordance with 10CFR50.54(p).Plan Rev Was Approved & Implemented on 990407.Rev Withheld,Per 10CFR73.21 ML20205Q3241999-04-16016 April 1999 Submits Addl Info Re TS Change Request NPF-38-215 for Administrative Controls TS Changes.Appropriate Pages from New Entergy Common QA Program Manual Provided as Attachment to Ltr 1999-09-07
[Table view] Category:UTILITY TO NRC
MONTHYEARW3P90-1505, Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-071990-09-17017 September 1990 Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-07 W3P90-1163, Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR501990-09-0606 September 1990 Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR50 W3P90-1191, Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal1990-08-31031 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal W3P90-1194, Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 19901990-08-29029 August 1990 Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 1990 W3P90-1184, Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay1990-08-20020 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay W3P90-1187, Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public1990-08-17017 August 1990 Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public W3P90-1189, Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator1990-08-17017 August 1990 Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator W3P90-1162, Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-19951990-08-16016 August 1990 Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-1995 W3P90-1174, Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization1990-08-0707 August 1990 Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization W3P90-1177, Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 9010241990-08-0303 August 1990 Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 901024 W3P90-1164, Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 19901990-08-0303 August 1990 Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 1990 W3P90-1167, Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div1990-07-19019 July 1990 Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div W3P90-1148, Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves1990-07-17017 July 1990 Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves W3P90-1143, Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation1990-07-0606 July 1990 Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation W3P90-1379, Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 9006061990-07-0202 July 1990 Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 900606 ML20044A5541990-06-26026 June 1990 Forwards Response to Generic Ltr 90-04 Requesting Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions ML20044A5551990-06-22022 June 1990 Describes Changes Required to Emergency Plan as Result of Transfer of Operations to Entergy Operations,Inc. Administrative Changes to Plan Necessary to Distinguish Support Functions to Be Retained by Louisiana Power & Light W3P90-1365, Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util1990-06-19019 June 1990 Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util ML20043G3431990-06-14014 June 1990 Requests That All NRC Correspondence Re Plant Be Addressed to RP Barkhurst at Address Indicated in 900523 Ltr ML20043F5121990-06-0808 June 1990 Forwards List of Directors & Officers of Entergy Operations, Inc.Operation of All Plants Transferred to Entergy on 900606 ML20043F2621990-06-0606 June 1990 Requests Withdrawal of 900504 Request to Extend Implementation Date of Amend 60 Re Transfer of Operations to Entergy,Inc.All Necessary Regulatory Approvals Obtained & License Conditions Implemented ML20043C1861990-05-29029 May 1990 Submits Response to 900426 Comments Re Investigation Case 4-88-020.Util Issued P.O. Rev Downgrading Order of Circuit Breakers & Eliminating Nuclear Requirements ML20043E5441990-05-24024 May 1990 Forwards Public Version of Change 1 to Rev 2 to EPIP EP-002-015, Emergency Responder Activation. Release Memo Encl ML20043B3501990-05-23023 May 1990 Forwards Response to Concerns Noted in Insp Rept 50-382/90-02.Response Withheld ML20043B3781990-05-23023 May 1990 Requests Change in NRC Correspondence Distribution List, Deleting Rt Lally & Adding DC Hintz,Gw Muench & RB Mcgehee. All Ref to Util Changed to Entergy Operations,Inc.Proposed NRC Correspondence Distribution List Encl W3P90-1314, Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed1990-05-21021 May 1990 Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed ML20043B3271990-05-21021 May 1990 Forwards Justification for Continued Operation Re Taped Splice for Use in Instrument Circuits,Per 900517 Request ML20042F5251990-05-0404 May 1990 Requests Extension of 90 Days to Implement Amend 60 to License NPF-38 in Order to Provide Securities & Exchange Commission Time to Review Transfer of Licensed Activities to Entergy Operations,Inc ML20042E5501990-04-17017 April 1990 Responds to Request for Addl Info Re Feedwater Isolation Valve Bases Change Request Dtd 891006 ML20012F4551990-04-10010 April 1990 Forwards Rev 10,Change 4 to Physical Security Plan.Encl Withheld ML20012F5491990-04-0606 April 1990 Advises That Util Installed Two Addl Benchmarks for Use as Part of Basemat Surveillance Program to Increase Efficiency of Survey Readings.New Benchmarks Will Be Shown on FSAR Figure 1.2.1 as Part of Next FSAR Rev ML20012F3181990-04-0606 April 1990 Forwards Util,New Orleans Public Svc,Inc & Entergy Corp 1989 Annual Repts ML20012E8971990-03-30030 March 1990 Submits Results of Evaluation of Util 900414 Response to Station Blackout Rule (10CFR50.63).Station Mod May Be Required to Change Starting Air Sys to Accomodate Compressed Bottled Air ML20012E2551990-03-27027 March 1990 Responds to Violation Noted in Insp Rept 50-382/90-01. Corrective Actions:Qa Review of Licensed Operator Medical Exam Records Conducted & Sys Implemented to Track Types & Due Dates of Medical Exams Required for Operators ML20012E0511990-03-27027 March 1990 Forwards Rev 10,Change 3 to Physical Security Plan.Rev Withheld ML20012D5461990-03-22022 March 1990 Forwards Documentation from Nuclear Mutual Ltd,Nelia & Nuclear Electric Insurance Ltd Certifying Present Onsite Property Damage Insurance ML20012D4911990-03-21021 March 1990 Responds to NRC 900208 Ltr Re Violations Noted in Investigation Rept 4-89-002.Corrective Action:Proper Sequence of Insp Hold Point Placed in Procedure Under Change Implemented on 880425 ML20012C0691990-03-14014 March 1990 Advises That Util Intends to Address Steam Generator Overfill Concerns (USI A-47) Utilizing Individual Plant Exam Process,Per Generic Ltr 89-14 ML20012C0421990-03-12012 March 1990 Forwards Questionnaire in Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. Results Not Reflective of Particular Calendar Yr ML20012B6731990-03-0707 March 1990 Responds to NRC Bulletin 88-011,Action 1.a Re Insp of Surge Line to Determine Discernible Distress or Structural Damage & Advises That Neither Surge Line Nor Affiliated Hardware Suffered Any Discernible Distress or Structural Damage ML20006F5321990-02-22022 February 1990 Forwards Payment for Order Imposing Civil Monetary Penalty in Response to Enforcement Action EA-89-069 ML20011F1401990-02-21021 February 1990 Responds to Violations Noted in Insp Rept 50-382/89-41. Corrective Action:Review of Independent Verification Requirements Re Maint Activities Performed ML20006F1731990-02-19019 February 1990 Forwards Corrected Pages 9.2-21 & 9.2-22 of Rev 3 to FSAR, Per 891214 Ltr ML20006E5781990-02-13013 February 1990 Forwards Third Refueling Inservice Insp Summary Rept for Waterford Steam Electric Station Unit 3. ML20006D0571990-02-0202 February 1990 Responds to SALP Rept for Aug 1988 - Oct 1989.Contrary to Info Contained in SALP Rept,Civil Penalty Not Assessed by State of Nv for Radioactive Matl Transport Violations.Issue Resolved W/State of Nv W/O Issuance of Civil Penalty ML20006C1631990-01-30030 January 1990 Requests Extension of Commitment Dates in Response to Violations Noted in Insp Repts 50-382/89-17 & 50-382/89-22 to 900222 & 19,respectively.Violations Covered Use of Duplex Strainers & Missing Seismic Support for Cabinet ML20006C1581990-01-29029 January 1990 Forwards Response to Generic Ltr 89-13 Re safety-related Open Svc Water Sys.Instruments in Place on Component Cooling Water Sys/Auxiliary Component Cooling Water Sys HXs Which Connect to Plant Monitor Computer ML20006C1611990-01-29029 January 1990 Responds to NRC Bulletin 89-003 Re Potential Loss of Required Shutdown Margin During Refueling Operations. Instructions for Determining Acceptable Refueling Boron Concentration Provided in Procedure RF-005-001 ML20006B4121990-01-26026 January 1990 Informs That Photographic Surveys Discontinued,Per Basemat Monitoring Program.Monitoring Program Implementing Procedure Will Be Revised to Reflect Change ML20006A7091990-01-22022 January 1990 Forwards List of Individuals That No Longer Require Reactor Operator Licenses at Plant 1990-09-06
[Table view] |
Text
.
Lo uisI AN A / 442 oe-o~o raser POWER & LIGHT / NEW oALEANE LoUSANA
. ao oox.oo.
70174400. G (504)388-2345 USE0kS SYS W3P84-2152 3-A1.01.04 August 9, 1984 Q-3-A29.02 Director of Nuclear Reactor Regulation Attention: Mr. G. W. Knighton, Director Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Waterford 3 SES Docket No. 50-382 Toxic Chemicals
Reference:
LP&L Letter W3P84-1094 dated 4/30/84
Dear Sir:
The above reference submitted to you the results of the LP&L-conducted toxic chemical survey of the industries surrounding Waterford 3. The purpose of this letter is to give you an update on the same subject. The data collected in the survey were evaluated and our evaluation indicates that the protective features described in the FSAR will provide adequate protection for the control room operators. ,
The attachment to this letter is a complete report on the analysis performed and the model and assumptions used. The results of the analysis are summarized in Table 1 of the attachment.
In comparison with Regulatory Guide 1.70 and Standard Review Plan Subsection 2.2.3, the probability of Immediatgly Dangerous to Life or Health (IDLH) levels being exceeded is smaller than 10 per year if credit is taken for odor detection and will be reduced even further by the toxic gas detectors. Also, considering the conservatisms of the analysis, the results indicate that the level of protection is marginally adequate even without reliance on odor detection or the broad range toxic gas detectors.
If you have any questions, please advise.
Very truly yours, K. W. Cook Nuclear Support & Licensing Manager KWC/PC/ch cc: E.L. Blake, W.M. Stevenson, J.T. Collins, D.M. Crutchfield, J. Wilson, G.L. Constable, K. Campo 8408230179 040809 OO(
PDR ADOCK 05000382 A PDR
',I
Pign 1 of 10 ATTACHMENT RESULTS OF THE 1983-1984 SURVEY OF T0XIC CHEMICALS STORED OR TRANSPORTED IN THE VICINITY OF WATERFORD SES UNIT 3
- BACKGROUND AND
SUMMARY
In.its letter"of February - 24, 1983, the NRC requested that the FSAR be updated to include all significant quantities of hazardous chemicals near the Waterford 3 site. It further requested that any additions to the listing be evaluated to ensure that the consequences of any accident involving these hazardous chemicals are within the design basis envelope for Waterford 3.
In response to this request we have updated the survey of major industries within 5 miles of.Waterford 3 to determine the types and quantities of hacardous materials which are stored or transported in the vicinity of the site. Our evaluation of the materials indicates that the protective features described in the FSAR will provide adequate protection for the control room operators.
INDUSTRIAL SURVEY To determine the types and quantities of hazardous materials which are stored or transported in the vicinity of Waterford 3 we had sent detailed .
. written questionnaires to the major industrial facilities located within 5 miles of Waterford 3. Questionnaires were sent to, and replies received from, the following facilities:
- Beker Industries Occidental Agricultural Products EI Dupont de Nemours & Co. Shell Chemical, Taft Plant GATX Terminals Corp. Shell Oil, Norco GHR Energy. Inc. Shell Western E&P, Crawfish Plant Hooker Chemical Union Carbide Linde Division LP&L Little Gypsy SES Union Carbide, Star Plant LP&L Waterford SES 182 Union Carbide,-Ethylene Oxide /
ye ant, Taft Occidental Chemical, Taft Witco Chemical Co.
m
p Pzga 2 of 10 In addition, we obtained from the Missouri Pacific Railroad Co. data on the types,-quantities and shipment frequency of hazardous materials through Taft, LA in 1983. When necessary, written information provided by the
. industrial facilities and Missouri Pacific was supplemented by telephone inquiries.
ANALYSIS OF DATA AND RESULTS The survey revealed that many of the toxic chemical sources listed in the FSAR, such as ammonia and chlorine, are still present. In addition, a number of new chemicals were identified. Using the methodology described in Section 2.2.3.3 of the FSAR, all of the toxic chemical sources were examined to identify those chemicals which, on the basis of their proximity to the plant, volatility and toxicity, could pose a threat to the control room operators in esse of an accidental release.
The locations and quantities of chlorine and ammonia were found to be the same as in the FSAR. As demonstrated there, for these chemicals, the redundant, dedicated detectors will assure control room habitability. In fact, we reanalyzed the ammonia sources and found that the 5 ppm setpoint and 2 second response time of the ammonia detectors which were assumed in the FSAR can both be relaxed. The analysis showed that a detector set to isolate the control room at 50 ppm of ammonia and having a 20 second response time would provide adequate protection.
Chemicals other than ammonia and chlorine were analyzed to assess the severity and likelihood of the threat to control room operators. We also evaluated the feasibility of protective action based on odor detection or notification by offsite authorities. Since the broad range toxic gas detectors are not yet operational, no automatic control room isolation or alarm was assumed.
The results of this analysis are presented in Table 1. This table lists all the chemical sources which were found to be capable of producing IDLH*
- Immediately Dangerous to Life or Health. (Ref. 1)
I L
Page 3 of 10 concentrations in the control room within 30 minutes of the plume's arrival on site under a spectrum of meteorological conditions, including 5 percentile conditions. Though the 30 minute period is somewhat arbitrary, we considered it reasonable to assume that within this period the control room operators would be notified that an accident has occurred by either the St. Charles Parish Industrial Hotline, or other means. We expect it would take the parish between 2 and 5 minutes to notify LP&L of an emergency condition at a nearby industrial facility, after the parish were notified.
The name of each chemical is shown in Column 1. Columas 2 and 3 list, respectively, the IDLH value and-the odor threshold for each chemical.
Except as noted in the notes to the table, the IDLH values were taken from
-Reference 1 and the odor thresholds from Reference 2. Whenever both
. detection and recognition levels were listed in Reference 2, the latter value was used.
Columns 4, 5 and 6 show, respectively, the location of the source from which the release is postulated to occur, the annual shipment frequency for mobile sources and the amount of material which is assumed to be released.
These data were provided by the survey respondents. The amount released, listed in Column 6, is the quantity contained in the largest single storage tank. For the Missouri-Pacific data, it is the average lading for each chemical.
Column 7 shows the minimum time from when the release occurs to when the IDLH concentration is calculated to be reached in the control room for the spectrum of meteorological conditions considered. Neglecting the possibility of notification prior to release, the values indicate the time available for notification by offsite authorities. Column 8 shows the minimum time from odor detection to when the IDLH concentration is reached.
This indicates the minimum available response time by the operators based on odor detection. Column 9 shows the maximum concentration in the control room at two minutes following odor detection - time within which the control room operators would be expected to don breathing apparatus ( .
p lL Paga 4 of 10 h
.It should be noted that the values in columns 7, 8 and 9 may not correspond to the same meteorological conditions. Generally, IDLH is reached most rapidly'at relatively high wind speeds whereas the maximum concentration at 2 minutes following odor detection occurs at lower wind speeds and very
~
- stable conditions. As such, the values presented in columns 7, 8 and 9 present the envelope of " worst" consequences.
The likelihood of transportation' accidents which can result in the consequences presented in columns 7, 8 and 9 are indicated in columns 10 and 11. These columns list the annual probabilities for IDLH levels being exceeded within'30 minutes of plume arrival on site or within 2 minutes of odor detection, respectively. These probabilities were calculated as follows: The length of railroad track, highway or shoreline within a
- five-mile radius of the plant was divided into a number of segments. An accident was postulated at the center of each segment resulting in a total
- - release of lading. -Using'the median windspeed for each meteorological
-stability class and the joint frequency data in FSAR Tables 2.3-126 through 2.3-132, the probability that the accident at a given location would result in control room concentration in excess of IDLH levels was
~
calculated. The resultant values of probability were multiplied by the lengths of the segments and summed to obtain the probability-weighted hazard length. This length was then multiplied by the annual shipment
!~
frequency in Column 5 and, finally, by the appropriate probability per vehicle mile of an accident involving a carrier of hazardous material which results in a loss of lading ( }.
Column 12 lists the ionization potentials (in electron volts) of the listed chemicals (5) . All chemicals with ionization potentials less than 11.7 eV would be detectable by the Broad Range Toxic Gas Detectors. The ionization potential of sulfur monochloride was not found in the literature; however, j as_' indicated in the notes to the table, we expect this chemical to also be l detectable, i
The results in Table I show that only three stationary sources can produce l IDLH levels in the control room within 30 minutes of the plumes' arrival on t
-site. Of these, thionyl chloride gives an adequate warning through odor L'
+' c z
+.~
Pagn 5 of 10-detection, and can also be detected by photoionization. Hydrogen chloride and sulfur dioxide do not provide a 2-minute odor detection warning, nor can .they be detected by photoionization. However, we were informed by Union Carbide that they plan to terminate'the process using hydrogen chloride in November, 1984, in which case this hazard will no longer exist.- In the case of sulfur dioxide, the IDLH concentration is not a reached until 23 m he'saftertheaccident. This should allow sufficient time for notifi:ati6n by the St. Charles Parish Industrial Hotline.
s Furthermore, the actual concentration is likely to be much lower. Sulfur
.s s dioxide has over twice the density of air and will tend to concentrate near the ground. Also' while above tihe IDLH ' level, the calculated concentration of 280 ppm 2 minutes aftier odor detection is not likely to be immediately incapacitating. Patty (5) and Fairhall (6) give 400-500 ppm as the
. con' centration that is dangerous for short exposures.
The total' probability for a transportation accident causing an IDLH concentration in the control room within~30 minutes of the plume's arrival
-6 on' site is 2.9x10 per year. The probability of exceeding IDLH before the operators can don breathing apparatus (2 minutes after odor detection) is
~
9.4x10 per year. This latter value includes those chemicals which cannot be ' detected by odor. If~only chemicals which cannot be detected by the Broad Range Toxic Cas Detectors are considered, the probabilities are
~7 ~
reduced'{d6.1x10 without odor detection and 4.4x10 with it (assuming adequate detector sensitivities and response times).
The above probability estimates may be compared to the guidance in Section 2.2.3 of Regulatory Guide 1.70 ( }. Also, Section 2.2.3 of the Standard j Review Plan } indicates: -
"...the identification of design basis events resulting from the presence of hazardous materials or activities in the vicinity of the plant is acceptable if the design basis events include each postulated type of accident for which the expected rate of occurrence of potential i
exposures in excess of the 10 CFR Part 100 guidelines is estimated to exceed the NRC staff objective of
~
approximately 10 per year."
l
$i ,
Pzgs 6 of 10 Furthermore,
"...the expected rate of' occurrence of potential exposures in excess of the 10 CFR Part 100 guidelines of approximately 10 ~0 per year is acceptable if, when combined with reasonable qualitative arguments, the realistic probability.can be shown~to be-lower."
As indicated before.c the model used to evaluate the consequences of postulated chemical releases is very conservative. Among the conservatisms'are the following:
- 1. Initial dilution due to entrainment of_ air in flashing liquids is neglected.
- 2. Material spilled on the ground-is assumed to evaporate from a pool which has a depth of I cm. While this conservative assumption eliminates the
'need for a detailed characterization of the spill terrain, it results in unrealistically large evaporation rates.
3.-Both source and receptor are assumed to be at ground level. In reality, the effects of gravity on dense vapors from pressurized liquids would tend to reduce the concentration at the 17 meter height of the control room outside air intake.
'4. Except for atmospheric turbulence, processes which would tend to reduce the concentration of airborne chemicals-are neglected. These processes would include condensation and dissolution in atmospheric water vapor by cr>1d gases such as hydrogen chloride and' sulfur dioxide as well as deposition on the ground.-
l5. IDLH values are appropriate for an exposure period of approximately 30 minutes. Significantly higher concentrations can be tolerated for the short time in which the operators would take protective action.
- 6. The possibility of notification prior to plume arrival on site is not.
considered.
y Pagn 7 of 10 Considering the additional fact that incapacitation of the operators need not result in exposures in excess of the 10 CFR Part 100 guidelines, the.
results of our analysis indicate that the' level of protection is marginally adequate even without. reliance on odor' detection or the Broad Range Toxic 6
Cas Detectors.' The probability is below the 10 per year criterion if credit is taken for odor detection and will be reduced even further by the toxic gas; detectors. Thus, the results indicate that the protective
. features described in the FSAR provide adequate. protection for the control room operators.
L c
. -. , - - . . , n , n. , n - -.,---,e- m-. ,c y
y Pcg3 8 of 10 References.
t
~
fl. . NIOSH/ OSHA. Pocket Guide to' Chemical Hazards. DHEW (NIOSH)
Publication No.78-210, (1978).
2.- Fazzalari,.F.A. ned.L. Compilation'of Odor and Taste Threshold Value Data. American Society for Testing and Materials (1978).
- 3. U.S. Nuclear Regulatory. Commission. Regulatory Guide 1.78.
Assumptione :for Evaluating the Habitability of a Nuclear power Plant
. Control Room-During'a' Postulated' Hazardous Chemical Release (June 1974).-
-4. -
Arthur D. Little, Inc. A Modal Economic and Safety Analysis of the Transportation of Hazardous Substance in Bulk.' COM-74-11271. National Technical Information Service.(1974).
- 5. Weast, R.C., ed. . Handbook of Chemistry and Physics, 64th Ed., CRC Press.-Inc. (1983).
-f
.6. Patty, F.A.,led. Industrial Hygiene and Toxicology, Second Ed., Vol.
II. 'Interscience Publishers-(1967).
> 7. 'Fairha11 .L'.T., Industrial Toxicology. Hefner Publishing Co. (1969).
- 8. U.S. Nuclear Regulatory Commission. Regulatory Guide 1.70. Standard Format and Content of Safety Analysis Reports for Nuclear power Plants, 1 - LWR Edition. Rev.'.3,.(November 1978).
L 9. _ U.S. Nuclear Regulatory Commission. Standard Review Plan for the Review of Safety. Analysis Reports for Nuclear Power Plants,. LWR Edition, NUREG-0800 (July 1981).
- 10. Sax,[N.I. Dangerous Properties of Industrial Materials, 3rd Edition.
- Van Nostrand Reinhold Co. (1968).
-w - . , w ..--a-- , -w ,n ---m=-w=n-y ,-yt+ - ryv,-wry-ww--v e g
- t-w- ~*5* -ev=-'-tr -r-*-e e f- +a > -- W-' 'm
d..
- - ' TABLE'I Page 9 cf 10l
- Chemicals in Vicinity of WSES-3 Posing' Potential Hazards to Control Room Personnel ~
- 1 -- 2 3, 4 'S 6 7. ;8" 9- 10 211 12' l Chemical IDLH- ' Odor- Source ** Shipment ' Amount Time of IDLH From: Conc.'at P(IDT.H) '(yr ) Ion..
- (ppm) l. thr. .'(kg.) Release. Odor. . th r. Odor +2 min dE30 min 40 dor +2 min Pot.
.(ppm)~ Frg). .
.(yr .(ppa) -(eV)
. 21 :7.1x10 -7~
Acrolein' 5 MPRR 164 2.4' min. 42 sec 36 .2.0x10 4.5x10 10.1 0 -9
-Acrylo- 4000 21 MISS 4 l'.9x10 25 min 18 min- 240 1.5x10 0 -10.9 nitrile 6 -8 Benzene 2000 4.7 MISS 70 1.8x10 25 min 19 min 110 2.4x10 0 9.2-I' Ethylene' 800 500 MPRR, 814 7.3x10 40 min 30 min 54 3.3x10
-9' O 10.6 oxide 4 -8 Formalde- 100 1 MPRR 33 7.6x10 12 min 8.6 min 24 2.4x10 0 .10.9-
., ehyde (37%)~
! Hydrogen 100 10 UC-T --
6.6x10 6.8 min 30 see 1100 -- --
12.7
-7 chloride MPRR 166 ~6.2x10 1.5 min 10 sec 4400 4.3x10- 3.5x10 4 -
Hydrogen 50 1 MPRR 1 4.7x10 4.8 min 2.2 min 47 3.5x10 0 13.8
. cyanide 4 -8 Hydrogen 20 --
MPRR 10 6.6x10 l'.4 min -- --
7.5x10 --
15.8
' fluoride 4 -0 Phosphorus 50 --
MPRR 67 8.1x10 12 min -- --
4.5x10 -
9.9 trichloride 4
Sulfur 100 .47 OCC --
7.8x10 23 min 1.3 min 280 -- --
-8 12.3 dioxide MPRR 61 7.6x10' 4 min 50 sec 950 1.0x10- 1.9x10 b 4 -9 Sulfur 10 S MPRR 130 8.6x10 ' 30 min .14 min 6 2.0x10 0 /_11. 7
Thionyl 2 .47' OCC --
1.9x10 14 min 7 min- 2 --
-7 II*I chloride 3127 77 1.8x10 20 min 8 min 2 2.0x10 0 i
,
P gs 10 of 10 NOTES TO TABLE I
- a. Location Code:
MISS - Mississippi River MPRR - Missouri-Pacific Railroad OCC - Occidental Chemical Co.
UC-T - Union Carbide Corp., Ethylene Oxide / Glycol Plant (Taft) 3127 - Louisiana Route 3127
- b. Odor detection threshold not listed in Reference 2. However, since each molecule of S C1 w uld yield two molecules of hcl upon contact 2 2 with water (such as in the moist mucous membrane), and since the odor threshold for hcl is 10 ppm, 5 ppm seemed to be a reasonable value,
- c. Value not listed in references, but was inferred as follows: Sulfur monochloride (S C1 ) is structurally analogous to thionyl chloride 2 2 (SOC 21 ). Oxygen and sulfur have the same electronic configuration in the outermost shells, but the sulfur valence electrons are less tightly bound. Comparison of analogous 0 and S compounds shows that the sulfur compound always has the lower ionization potential. Therefore, we are reasonably certain that the ionization potential of S C1 is less than 2 2 that of SOCl and, thus, less than 11.7 eV.
2
- d. Value not in references. Sax ( cites 17.5 ppm as fatal to cate in 20 minutes. Action is comparable to phosgene, in that both compounds react with water to liberate hydrogen chloride. 2 ppm, which is the same as the IDLH for phosgene, is a conservative value.
- e. Not listed in Reference 2. Sax (10) describes the odor as similar to sulfur dioxide, so the odor threshold of the latter was used.
- f. Value quoted by HNU Systems, Inc.
-