ML18096A454

LER 91-038-00:on 911219,calculations Indicated That Regguide 1.78 Toxic Limit for Ammonia Would Be Exceeded.Caused by Inadequate Design Review.Temp Indicator added.W/920116 Ltr

ML18096A454
Person / Time
Site:	Salem
Issue date:	01/16/1992
From:	Pollack M, Vondra C Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.078, RTR-REGGD-1.078 LER-91-038, LER-91-38, NUDOCS 9201280186
Download: ML18096A454 (7)

Text

e OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Salem Generating Station January 16, 1992 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 LICENSEE EVENT REPORT 91-038-00 This Licensee Event Report is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR 50.73(a) (2) (ii). This report is required to be issued within thirty (30) days of event discovery.

Sine ely yours, C. A Vondra General Manager -

Salem Operations MJP:pc Distribution The Energy People_

9201280186 920116 PDR ADOCK 05000272 95-2189 (10M) 12-89 S PDR

NRC FORM366 U.S. NUCLEAR REGULATORY COMMISSION (6.S9l :APPROVEO OMB NO. J150_-0104 EXPIRES: 4/30/92 , ,

• ESTIMATED BURDEN i>*ER RESPONSE .TD COMP.LY WTH. THls INFORMATION 'COLLECTION REQUEST: 50.0 -HRS. FORWARD LICENSEE EVENT REPORT (LERI COMMENTS REGARDING BURDEN ESTIMATE TO*THE RECORDS .

AND REPORTS MANAGEMENT BRANCH (P-630l;U.S. NUCLEAR

'* REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO

'THE PAPERWORK *REDUCTION PROJECT (3150-01041, OFFICE OF MANAGEMENT AND BUDG_ET, WASHINGTON; DC 20503.

FACILITY NAME (11 * !DOCKET NUMBER .(21

• I .PAGE (31 Salem Generating Station_- Unit 1 . 0 I 5 'i 0 I 0 I 0 12 17 12 I 1 OF 0 5 TITLE (41 Control Habitabjlity Concern From Postulated Ammonium Hydroxide Release EVENT DATE _(61 LER NUMBER 161 " REPORT DATE 171 OTHER FACILITIES INVOLVED ,Ill MONTH DAY YEAR YEAR tl SE~~~~~~AL tl ~~~~~~ MONTH . DAY YEAR FACILITY NAMES DOCKET

. NUMBERISI Salem Unit *2 .* o I 51 O .I O j O t3 I 11 1 O 1S10-10101 I I THIS REPORT IS SUBMITTED PURSUANT TD THE R~QUIREMENTS OF 10 CFR §: (Ch<<k ono or mor0 of tho_ foilowin11J (111 OPERATING MODE (Ill l

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1101 I *" 20.4051*11111111 60.381cll21 60.731all21Mil OTHER (Spocify in Abrtroct IHlow *nd In T*xt. NRC Form 20.40lll*ll1 lliill 60.731*1121111 60.73(allZIMllllAI 366AJ 20.406i*ll1 lllvl 20.4061*1111 M -x 60.73(*112lliil 60.731*112lliiil LICENSEE CONTACT FOR THIS LER 1121 60.731oll21Cvllll IBI

&0.731*112lhil NAME TELEPHONE NUMBER M. J~ Pollack -*LER Coordinator 6 I 01 9 3 I 31 9 I- I 2 I 0 I 21 2 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 1131 COMPONENT MANUFAC* MANUFAC*

CAUSE SYSTEM COMPONENT TUR ER TUR ER I I I I *I* I I I I I I I I I I I I I I I I I I . 1* I I SUPPLEMENTAL REPORT EXPECTED 1141 MONTH _DAY YEA EXPECTED

~NO SUBMISSION rl YES (If yor, comploto EXPECTED SUBMISSION DATE/

DATE 1151 I I I ABSTRACT (Limit ta 1400 ipact11. I.*.* *pproitim*r.ly fiftHn 1inglt1-1pace ty1Mwrit~n limn} 118)

On 12/19/91, an interim calculation concluded tha*t a Control Room habitability concern was possible, du~ to postulated failure of a 300Q gallon capacity Turbine Building ammonium hydroxide storage tank. In accordance with Regulatory Guide 1.78, the maximum*concentration release was postulated from a catastrophic failure of the largest storage tank of ammonium hydroxide (27.5 wt%). The liquid ammonium hydroxide would vaporize to ammonia upon release, exhaust to the environment (from the Turbine Building Ventilation System), and disperse to the Control Room air supply intakes. Calculations indicate that the Regulatory Guide 1.78 toxic limit for ammonia (100 ppm) would be exceeded. The root cause of this event is attributed to inadequate design review during the preparation of the Final Safety Analysis Report (FSAR). Compensatory actions have been taken to ensure control room habitability under postulated accident conditions including the addition of a temperature indicator with chart recorder by the storage vessel and administrative controls for ammonium hydroxide tanker

., receipt. A survey for additional hazardous chemical on-site storage concerns was conducted. An Engineering Evaluation, including a 10CFR50.59 Safety Evaluation, will be completed to address the ammonium hydroxide and any other applicable hazardous chemical issues. The UFSAR will be updated as applicable. Evaluations will be completed of the chemical control program and procedures.

NRC Form 366 16-891

• • ~ ,.. ,- .

LICENSEE EVENT REPORT* (LER) TEXT CONTINUATION ,, . z**- . ......-

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Salem Generating Station DOCKET NuMBER *LER NUMBER *.PAGE

• Unit 1 ._ _ _ _ _5_0__00~72 ---~__,~1~03_8-Q_Q_ _ _ -~2~<?.t-".L**~- '

PLANT AND SYSTEM IDENTIFICATION: .. *~

Westinghous~ ~ Pressurized Wate~ Rea~tbr .. *,, .-* - . "*-:*, .... , ..

Energy Industry Identification- System_. (EilS) codes are -identified in the teXt as. ( xX I .;.

...-~ _.,...:. ..... . . '. - _. . ' .-

IDENTIFICATION OF.OCCURRENCE:

--~ -

Control Room habitability :concjern from .postulated .a:mm~nium ,.t*iydroxide release Discovery Date: *12/19/9i

- ~ . --: ..- , : '-*

Report Date: 1/16/92 This report was initiated by Incident *Repor~ No.* . 91~920. *

• CONDITIONS PRIOR TO OCC~R~]lCE:

Unit 1: Mode 1 Reactor Power.100% - Unit* Load 1158 Mwe*

Unit 2: Defueled - 6th Refueling in progress On December 19, 1991, an interim calculation concluded that a Control Room.habitability concern was possible due, to postulated failure of a 3000 gallon capacity ammonium hydroxide storage tank (1CrE24),

located on 120' El. Unit 1 Turbine Building. The analysis was prepared by Stone & Webster Engineering Corporation (SWEC) using the "VAPOR" computer program. Ammonium hydroxide is used to maintain_

secondary plant pH control (i.e., Chemical Feed System [KDJ).

In accordance with Regulatory Guide 1.78, the maximum concentration release was postulated from a catastrophic failure of the largest storage tank of ammonium hydroxide (27.5 wt%). The liquid ammonium hydroxide would vaporize to ammonia upon release, exhaust to the environment (from the Turbine Building Ventilation System), and disperse to the Control Room air supply intakes. The VAPOR calculation indicated that the Regulatory Guide 1.78 toxic limit for ammonia (100 ppm) would be exceeded. On December 19, 1991, at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, the Nuclear Regulatory Commission (NRC) was notified in accordance with Code of Federal Regulations 10CFR50.72(b) (1) (ii).

An ammonium hydroxide habitability concern was first identified by an NRC inspector on September 9, 1991 (reference NRC Inspection Report 50-272/91-25, dated September 26, 1991). A preliminary assessment was conducted using the "CHARM" computer program, developed by Radian Corporation. From the preliminary assessment, PSE&G concluded that no significant safety concern would exist; however, to support this conclusion, a more detailed computer program (VAPOR) was used. VAPOR identified a safety concern as discussed above. Additional discussion is contained in the Analysis of Occurrence section.

, LICENS.EE EVENT REPORT (LER) _TEXT CONTINUATION* __

-- Salem Generating Station DOCKET NUMBER LE;R NUMBER.

• PAGE Unit 1 ~_Q_QJ>~72________91-Q_~]_-q_o_**-----=3~of 6__

APPARENT CAUSE-OF OCC'(}RRENCE The root c_ause _ofc this event. is :attributed to _inadE!quate- dej;ign _

review.

The original design identified-the current storage t~nk used for secondary water chemistry control as containing morpholine. Prior*to issuance of an operating iicense, secondary water treatment was changed*and the tank designated to store ammonium-hydroxide. Review of licensing basis documents indicate that FSAR Section io.2.1.6, Chemical Feed_ System discusses -morpholine for pH *con_trol. FSAR Figure 10. 2-9, Feedwater Chemical Treatmen_t Sys'tem identifies the storage tank for morpholin~. H6wever, a side note states the system is designed for use of either.Ammonia or Morpholine.< FSAR Section 10.2.1.6 and Figure 10.-2-9 were revised by Amendment -37 dated April 5, 1976. No discussion of control room habitability for ammonium hydroxide was* included in the FSAR. Discussions involve other hazardous chemicals, airborne radiation, smoke and fir_e. -Further research identified the tank's vendor drawing which-shows it was revised from morpholine to ammonium hydroxide in April 1971.

Morpholine is less_ toxic than ammonia and has a higher boiling point.

Morpholine and ammonium hydroxide are not specifically listed in Regulatory Guide 1.78. -

Additionally, the original FSAR was developed *in-accordance -with the June 30, 1966 AEC Guide for the Organization and Contents of Safety Analysis Reports and AEC General Design Criteria dated July 10, 1967. These documents did not require review and-evaluation of site hazards to the degree required after Salem was licensed. The FSAR made no commitment to Regulatory Guide 1.78 dated June 1974, but did evaluate the effects from accidents involving potential hazardous materials stored on-site a*s a result of FSAR Review Question 2.11.

During the licensing of Unit 2 the response to FSAR Review Question 9.60 and NUREG-0737 TMI Action Item III.D.3.4 stated that plant and site were evaluated for compliance with Regulatory Guid~ 1.78 and Standard Review Plan Sections 2.2 and 6.4.

An internal engineering memorandum (Engineering memo dated September 14, 1977) addresses a preliminary judgement for compliance with Regulatory Guide 1.78. It specifically addresses ammonium hydroxide being stored in sufficient quantities to be a potential concern; however, the memo states, "there should be little problem in maintaining a habitable environment in the Salem Unit 2 Control Room following a postulated hazardous chemical release". This conclusion was based on, "our ability to meet the intent of Control Room ventilation design with respect to 10CFR50 Apnendix A Design Criteria 19". Documentation has not been found which identifies the specific characteristics of ammonium hydroxide and its as-built storage conditions in relation to the Engineering memo's conclusions.

The preliminary assessment, conducted in September 1991, supported the conclusion that the Control Room habitability would not be impacted upon failure of the ammonium hydroxide storage tank.

However, this assessment was considered preliminary and a more

LICENSEE EVENT .REPORT (LER) TEXT CONTINUATION .

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Salem Generating Station DOCKET NUMBER - LER NUMBER *PAGE Unit 1 5Q_Q_Q 21 ~---*-*-*-~J.~o_:rn_-o_q_*-~-4:._<?Lf?_.__ _

APPARENT CAUSE OF OCCURRENCE: ----~~~~~

(cont'd) detailed analysis. would be required. As -*a result of the-. December -

'199]_ subsequent analysis it was conclude~ that toxic :limits' could be exceeded *

. ANALYSIS .OF-OCCURRENCE

-In July 1980, a review and evaluation of the plant and site was

-conducted per NUREG-0737 Action Item .III.D. 3. 4. The -Action Item required identification and.evaluati~n of potential hazardo~s material and a_ determination that the-control room was *adequately protected., The review ~oncluded-that the control room was.adequately protected sinc*e* *11 no cheniical . hazards: exist-" -based on previous*.

• responses to NRC inquiries.

T~e Updated Final *safety Analysis Report. (UFSAR) do~~ not include

~amnioniuin hydroxide. on the s'tored -*hazardous chemical .,list~ (UFSAR Section 2 ._2) . . UFSAR Section 6. 4, :does not address. ammonium :hydroxide impact on.control room habitability. The AEC 'standard format (dated 1966) did- not contain a section requiring discussfons of.*coritrol room habitability *. During the Unit 2 FSAR .. review. (to support._Unit 2 licensing) r "NRc Question. 9. 60. did ask .how Salem Is . design complied with Regul,.a~or*y Guide 1. 78; bu:t it *was -asked relat:'J. ve to offsite r1ver. accidents *..- - - _;-. - . . <**': . --.-; -~ . ' . . - ,_.

When the a~onium hydro~l.de concern was first ide~tified .in September

• 1991 an assessment of control room habitability was initiated. This assessment involved the use of the :"CHARM" computer program.

• Results i_ndi.cated that the toxic limit for ammonia gas, listed in Regulatory guide 1.78, woutd not be exceeded. The CHARM computer program methodology is based on an Envirorimental*Prot~ction Agency (EPA) accepted model. The program model takes into accourit varying dispersive phenomena, release scenarios and the chemical's physical characteristics.

• A second assessment was contracted in which the VAPOR computer program was used. VAPOR is based on the methodology presented in NUREG-0570 dated June 1979 which utilizes ve_ry conservative assumptions. The VAPOR program determined that the two (2) minute toxic limit of Regulatory Guide 1.78 could be exceeded and render the control room uninhabitable.

UFSAR and licensing correspondence contain no commitment nor any analysis performed by PSE&G for ammonium hydroxide release using NUREG-0570 methodology. Also, the NRC did not review the acceptability of Salem's design using the methodology of NUREG-0570.

The Safety Evaluation Reports and their supplements do not reference this document.

Comparison of the VAPOR and CHARM models identified differences in approaches to heat transfer, mass transfer, and atmospheric modeling. The VAPOR program is being reviewed and will be verified.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION*

Salem Generating_Station DOCKET NUMBER *LER NUMBER PAGE Unit 1 5b00272

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ANALYSIS OF OCCURRENCE: (cont'd)

Hope Creek. Generating Stat.ion, locatt3d. on *the. same sit.e as Salem Generating Station, was notified .*bf the -Salem Contro1-:0 :Room habitability concern for potential impact at Hope Creek Geperating *.

Station.

CORRECTIVE ACTION ..*_:

The following compensatory actions were* taken t:o ensur~ .controi room habitability under postulated accident. conditions

~ . :*. ,

(per VAPOR) :

1. A temperature indicator with chart.recor~~~'was placed. in the proximity of the storage vessel to -mC:>nitor temperature in the tank area. Aiitmonia i;-elease is. te:mperature depe.ndent (i~e., 27.5 wt% ammonium hydroxide solution.has a boiling point of 82° F) ...

2. The maximlim allowable storage volumes for 27.5 wt% ammonium hydroxide were determined for-temperatures up to 75°F and transmitted to the Salem Operations and Chemistry.. -

departments.

3. Precautionary administrative controls, for ta_nker. truck delivery, have been initiated. They will be *detailed in a revision to Chemistry procedure* SC.CH-AD~ZZ-0474, *;'Receipt of Ammonium Hydroxide Tank Trucks".

A survey for additional hazardous chem1cal on-site* storage concerns was conducted. Results identified two (2) additional.chemicals with the potential to impact Control Room habitability~ They are 35 wt%

hydrazine (stored in a 300 gallon vessel on 120'- El. Unit 1 Turbine Building) and 50 wt% sodium hydroxide whose largest' single container is one of the two (2) 4000 gallon tanks located on 88' El. Unit 1 Turbine Building. Preliminary assessment indicates an impact on Control Room habitability is not expected upon release of these two (2) chemicals. This assessment will be finalized using the VAPOR program.

An Engineering Evaluation, including a 10CFR50.59 Safety Evaluation, will be completed to address the following ammonium hydroxide issues.

1. The final VAPOR program calculation review;

2. A determination of whether 15 wt% ammonium hydroxide can be used, instead of 27.5 wt%; and

3. An evaluation for design modifications to correct Control Room habitability concerns.

The UFSAR will be updated to include ammonium hydroxide as a potential accident hazard along with any other chemicals identified.

Evaluations will be completed of the chemical control program and

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION A

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Salem Generating Station DOCKET NUMBER LER NUMBER PAGE Unit 1 - - - - - - - - - - -5000272

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CORRECTIVE ACTION (co~t~l procedures to identify programmatic/procedure revisions or development of new procedures to ensure evaluation of chemicals for their impact on control room habitability.

General Manager -

Salem Operations MJP:pc SORC Mtg.92-007