ML091040207

Calculation No. OSC-9293, Rev. 0, NFPA 805 Transition Radioactive Release G-1 Table.

ML091040207
Person / Time
Site:	Oconee
Issue date:	05/23/2008
From:	Lechner J Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Shared Package
ML091040234	List: ML091040205 ML091040206 ML091040207 ML091040208 ML091040214
References
OSC-9293, Rev 0
Download: ML091040207 (14)

Text

Form 1.01.1 (R08-04)

CERTIFICATION OF ENGINEERING CALCULATION Station And Unit Number Oconee Units 1, 2 & 3 Title Of Calculation NFPA 805 Transition Radioactive Release G-1 Table Calculation Number OSC-9293 Total Original Pages i thru iv and 1 Through 5 Total Supporting Documentation Attachments 1 (3 pages) -Total Microfiche Attachments 0 Total Volumes 1 Active Calculation /Analysis Yes x No .'

Microfiche Attachment List ;iýYes x No IfActive is this a Type I Calculation/Analysis Yeys/No (See Form 101.4)

These engineering Calculations cover QA Condition 2 Items. In accordance with established procedures, the quality has been assured and I certify that the above Calculation has been Originated, Checked, or Approved as noted-below* _____-__:__

Originated By J. E. Lchner. - Date 5-23-08 Checked By ( ,4 £ * -y1it Date /

Z.*/2 Verification Method: Method I Method 2 Li Method 3 Li Other [E Approved By . 6_.

z' e*1-*e-( -* Date S/-.3 /10*

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Received By Document Management ZI 4 ate..Fj )

Complete The Spaces Below For Documentation Of Multiple Originators Or Checkers Pages Through Originated By Date Checked By _ Date Verification Method: Method 1 I Method 2 Li Method 3 F1 Other F]

Pages Through Originated By Date Checked By Date Verification Method: Method 1 [-I Method 2 Li Method 3 Li Other F]

Pages Through Originated By Date "

Checked By "_Date Verification Method: Method 1 E] Method 2 Fl. Method' 3 Li Other Li

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Form 101.2 (R3-03) Calculation Number OSC-9293 REVISION DOCUMENTATION SHEET Revision Revision Description Number 0 Initial issue 4-

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'. FORM 101.3 (R08.04)

CERTIFICATION OF ENGINEERING CALCULATION - REVISION LOG Station And Unit Number Oconee Units 1, 2 & 3 Title Of Calculation NFPA 805 Transition Radioactive Release G-1 Table Calculation Number OSC-929-3 Active Calculation / Analysis Yes x No[

Calculation Pages (Vol) Supporting Volumes "'"' C } Verif. Issue R~ev.

No. Revised Deleted I Documentation (Vol)

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Date C

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Note 1: When approving a Calculation reVision with multiple Originators or Checkers, the Approver need sign only one block.

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Engineering Manual 4.9 CALCULATION IMPACT ASSESSMENT (CIA)

Station / Unit Oconee 123/ Calculation No. OSC-9293 Rev. 0 Page iv PIP No. (if applicable) O008-02009 By J. E. Lechner Date 5/23/2008 Prob. No. (stress & s/r use only) n/a Checked By CA &iL6-11.

z Date 5'2 for NEDL reviewed to identify calculations? YES ,; Note: A NEDL search is NOT required calculation originations (i.e. Rev. O's)

(formally SAROS)

Identify in the blocks below, the groups consulted for an Impact Assessment of this calculation origination/revision.

Indiv. Contacted/Date Indiv. Contacted/Date 0 RES El NGO (Power, I&C, ERRT, (QA Tech. Services (ISl),

Reactor). Severe Accident Analysis,Elect.

Sys. & Equip., Design & Reactor Supp., Civil Structural, Core El MCE Mech. & T/H Analysis, Mech.

(Primary Systems, Balance of Sys. & Equip., Nuclear Design Plant, Rotating Equipment, Valves & Heat Exchangers, and Safety Analysis, Matls/Metallurgy/Pipinng Civil)

El MOD (Mechanical Engr., Electrical 21Training Scott Boggs 1-28-08

-.- Eng.-i-,ii-Engr-) -ike:-Adaffs-3--.-260 El Operations- El Local IT OPS Support El Regulatory Compliance El Maintenance -

Tech. Support El Chemistry El Work Control -

Program. Supp.

0l Radiation Protection El Other Group El No Group requitred to be consulted Listed below are the identified documents (ex: TECHNICAL SPECIFICATION SECTIONS, UFSAR.SECTIONS, DESIGN BASIS DOCUMENTS, STATION PROCEDURES-, DRAWINGS, OTHER CALCULATIONS, ETC.) that may require revision as a result of the calculatlon origination or revision, the document owner/group and the change required (including any necesssary PIP Corrective Actions),

• Note: Any design changes, which require changes to Station Procedures, must be transmitted as Design Deliverable Documents.

DOCUMENT GROUP CHANGE REQUIRED New Lesson Plan Emergency Planning New Fire Brigade Lesson Plan per PIP 0-08-02009 Page 1 of 1

Calculation No.: OSC-9293 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 1 of 5 1.0. Problem Statement The transition for Oconee to a new NFPA-805 fire protection licensing. basis under 10 CFR 50.48 (c) requires that the potential of radioactive release due to fire suppression activities be evaluated under the licensing basis transition to NFPA-805. This calculation documents the results of that review for incorporati .intoothe. Duke Document Control system as a QA condition 2 design input.

2.0. Methodology The guidance for performing this review is contained in Nuclear Energy Institute (NEI) 04-02, Guidance for Implementing a Risk-Informed, Performance-BasedProgram Under 10 CFR 50.48(c), Revision 1 (Sections 4.3 and Appendix B), as endorsed by Regulatory Guide 1.205, Risk-Informed, Performance-BasedFire Protectionfor Existing Light-Water Nuclear PowerPlants, Revision 0. Sections 4.3.4 and Appendix G of NEI 04-0.T, -Revision1 provided the background and basis for the Radioactive Release Transition Reviews.

The treatment of radioactive release to any unrestricted area due to fire is focused on potential radioactive release due to potential fuel damage and fire fighting activities.

The Nuclear Safety Goal, Objectives and Performance Criteria require the prevention of fuel cladding damage. As such, radioactive release due to-fuel damage does not require a separate examination since no such damage is assumed to occur without violating the basic requirements of NFPA-805. This effectively limits the source of radiation (release source term). Therefore, containment integrity does not require specific examination either. Not all containment isolation valves are included within the scope of the fire protection safety analyses. The potential for radioactive release' is addressed by examination of the direction for and conduct of fire fighting activities. The primary objective in conducting the examinations of fire fighting activities is to address the potential for loss of boundary control for contaminated spaces.

The pre-fire plans were reviewed to ensure that locations which have the potential for contamination contain specific steps for confinement/containment and monitoring of potentially contaminated fire suppression water and contaminated smoke. Those pre-plans for zones that did not have the potential to contain radioactive materials were screened from further review. Updating of pre-fire plans and other fire brigade procedures and instructions were recommended where applicable.

Fire Brigade Training lesson plans and related materials were reviewed to ensure that they specified how to deal with the containment and monitoring of potentially contaminated fire suppression water and contaminated smoke.

Calculation No.: OSC-9293 Revision No.: 0 Applicable Units: Oconee Unit 1,2, & 3 Page 2 of 5 3.0. Design Bases and References 3.1 Title 10 Code of Federal Regulations, Section 50.48 (c) 3.2 National Fire Protection Association 805, Performance-BasedStandardfor Fire Protection for Light Water Reactor Electric GeneratingPlants, 2001 Edition.

.3.3 Nuclear Energy Institute (NEI) 04-02, Revision 1, Guidance for Implementing a Risk-Informed, Performance-BasedProgram Under 10 CFR 50.48(c), September 2005 3.4 Regulatory Guide 1.205, Risk-informed, Performance-BasedFire Protectionfor Existing Light-Water Nuclear Power Plants, May 2006 3.5 10 CFR 50, Appendix R, Fire ProtectionProgramfor NuclearPower Facilities OperatingPriorto January 1, 1979 3.6 NGD-FP-01, Rev. 3, FIRE BRIGADE ORIENTATION 3.7 NGD-FP-02, Rev. 2, FIRE BEHAVIOR AND METHODS OF EXTINGUISHMENT 3,8 SAF-FP-03, Rev. 3, PORTABLE FIRE EXTINGUISHERS 3.9 NGD-FB-04, Rev. 4, FIRE FIGHTING PERSONAL PROTECTIVE EQUIPMENT (PPE) 3.10 NGD-FP-05, Rev. 4, FIRE HOSE, NOZZLES, APPLIANCES, AND STREAMS 3.11t NGD-FP-06, Rev. 4, FIRE SUPPRESSIONAND DETECTION SYSTEMS 3.12 NGD-FP-07, Rev. 1, SELF CONTAINED BREATHING APPARATUS (SCBA) 3.13 NGD-FP-08, Rev. 4, INCIDENT COMMAND SYSTEM AND FIRE FIGHTER SAFETY 3.14 NGD-FP-09, Rev. 3, FIRE AREA SEARCH AND RESCUE 3.15 NGD-FP-1 0, Rev. 4, VENTILATION AND DAMAGE CONTROL 3.16 NGD-FP-1 1, Rev. 2, INTRODUCTION TO HAZARDOUS MATERIALS 3.17 ONS-FBL, Rev. 0, FIRE BRIGADE LEADER TRAINING 3.18 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 1, General Response Guidelines, dated 2-27-97.

3.19 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 2, Staffing Guidelines, dated 10-25-05.

Calculation No.: OSC-9293 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 3 of 5 3.20 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 3, Electrical Fires, dated 2-27-97.

3.21 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 4, Fire Brigade Leadership Guidelines, dated 2-27-97.

3.22 Oconee NuclearStation, Fire Brigade Operations, Standard Operating Guideline Number 5, Fires Involving Main Transformers, dated 2-27-97.

3.23 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 6, Restoring Equipment, dated 2-27-97.

3.24 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 7, Wheeled Fire Extinguisher Locations, dated 2-13-07.

3.25 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline N-m--er 8 a8dH---s-M-te-fi-alý-Response, dte-d-2-27-ST-.

3.26 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 9, Hose Selection and Use, dated 11-16-98.

3.27 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 10, Fire Brigade Equipment Locations, dated 4-23-03.

3.28 Oconee Nuclear Station, Fire-Brigade Operations, Standard Operating Guideline Number 11, Hydrogen Bulk Storage, dated 10-2-07.

3.29 -Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 12, Purging Electrical Generator, dated 12-20-01.

3.30 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 13, Sprinkler Cross Reference, dated 9-19-07.

3.31 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 14, Fire Fighting Foam Carts, dated 9-18-07.

3.32 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 15, Fire Response to C02 Dump, dated 10-2-07.

3.33 Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 16, Fire Within a RCA/RCZ, dated 1-23-08.

3.34 Oconee Nuclear Station Fire Brigade Pre-Fire Plans (all fire zones) 3.35 FAQ 06-0025, Minimum Pre-plan Scope, dated 7-19-07, ML072080246.

3.36 NSD-112, Rev. 8, Fire Brigade Organization, Training and Responsibilities.

Calculation No.: OSC-9293 Revision No.: 0, Applicable Units: Oconee Unit 1. 2, & 3 Page 4 of 5 3.37 ERTG-001, Rev. 17, Emergency Response Organization and Emergency Services Training Program.

3.38 PIP 0-08-02009, Need for New Fire Brigade Lesson Plan.

3.39 SLC 16.11.1, Radioactive Liquid Effluents, dated 07/12/01.

3.40 SLC 16.11.2, Radioactive Gaseous Effluents, dated 01/31/00.

4.0. Summary Information This i Type I c Ilation b use it mu e review or each n 'neering nge thai s pleme and up when qui d. T Att hm t 1, 1 tab ca asonab b'expe ed t outi ly i olve in *g icant ch es due to E gineerin anges .. ce it is ba ally a rev of fire bri de pre-fir ans and le on plans.

... si n c/ng s wo dec a \ -- J.

The fire brigade pre-plans were reviewed to determine if any fire zones had the potential for radioactive materials or if they were within the Radiologically Controlled Area (RCA).

The review also assessed the consideration of radioactive release paths. Revisions to Standard Operating Guidelines for the Fire Brigade (SOG's) were recommended to address the additional needs identified. SOG-16 was written to address the additional strategies necessary for fighting fires within a RCA/RCZ to control and monitor potential radioactive releases.

Fire Brigade Training lesson plans and related materials were reviewed to assess how fire brigade members were being taught to control and monitor potential radioactive releases. Of the lesson plans reviewed only the one on Hazardous Materials discussed potential radioactive releases and ALARA principles. The development of the new SOG-16 also requires additional training of fire brigade members. Given the fleet-wide nature of fire brigade training lesson plans, an open item was generated to create a new lesson plan for initial fire brigade training to address radioactive release control and monitoring measures. This Open Item is documented and being tracked in PIP 0 02009.

The results of this review have determined that the fire brigade pre-fire plans and lesson plans. needed minor updates on managing fire-s in areas containing radioactive materials. The results were summarized and entered into a database utilized to capture the NFPA-805 transition information and provide the NEI 04-02 Table G Radioactive Release Transition Report.

Calculation No.: OSC-9293 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 5 of 5 5.0. Assumptions 5.1. The methodology is based upon NEI 04-02, Revision 1 and FAQ 06-0025. The FAQ states that plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present. The assumption is madeoof there being eventual endorsement of this FAQ on pre-fire plan scope by the NRC via revision to NEI 04-02 and R.G. 1.205. Adjustments to the calculation may be necessary based upon changes to those documents.

6.0 Technical Presentation Attachment 1 - Table G Radioactive Release Transition Report

Calculation No.: OSC-9293 Revision No.: 0 Applicable Units: Oconee Unit 1, 2. & 3 Attachment I Attachment I Table G Radioactive Release Transition Report 3 total pages

Table G Radioactive Release Transition Report NFPA 805 Section 1.5.2 Radioactive Release Performance Criteria Radiation release to any unrestricted area due to the direct effects of fire suppression activities (but not involving fuel damage) shall be as low as reasonably achievable and shall not exceed applicable 10 CFR, Part 20, Limits.

Implementingi Guidance, Appendix G Step 1 Review pre-fire plans.

Ensure for locations that have the potential for contamination that specific steps are included for containment and monitoring of potentially contaminated fire suppression water. Update pre-fire plans as necessary.

Review A comprehensive review of the ONS fire pre-plans, including applicable outbuildings was conducted. Areas known to contain a RCA/RCZ are identified in the "Special Hazards* Section of the specific fire plan zone. The Pre fire plans also address smoke management inthe "Ventilation Equipment section of each prefire plan. This section discusses I informs the fire brigade leader and or control room of existing or possible supply air pathways as well as exhaust air pathways and ventilation pathways via HVAC units as well as fire dampers. These units can be shut down for smoke management during a contaminated fire event. Also identified are ingress and egress pointsfor smoke mitigation. General building ventilation is monitoredby RIA's. Fire Brigade Standard Operating Guideline 16 "Fires within a RCA/RCZ" was developed to address radiological release concerns.

Floor drains in radiological areas are muted to contaminated hold-up tanks, then processed prior to release. Yard drains and other drains are routed to Chemical Treatment Pond #3 and monitored for radioactive liquid releases before the water leaves site. ONS has unrestricted areas [denoted in Figure 2.1-4(a) of the ONS UFSAR]that shell be limited to 10 times the effluent concentrations specified in 10 CFR20.

Standard Operating Guideline for "Fires within a RCNARCZ" has been created to address smoke management as well as potentially contaminated run off when fires involve potentially contaminated areas that may not be identified in the fire plan. These areas may include other RCZ 's that may be established for short term periods such as maintenance.

Unit Applicability 1,2, and 3 Comments Pre-fire plans for zones 1-47 were screened from review due to being outside the RCA. Pre-fire plans for outbuildings which may be Used for storage of radioactive materials and which may house a RCA were included in the review. Outbuildings included were 8027, 8055, 8087, 8089. 8091, 8093, and 8096.

Reference Document Document-Detail SLC 16.11.1, Radiological Effluents Control, 7/12/2001 SOG 8, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 8, Hazardous Materials Response, 2/27/1997 SOG 9, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 9. Hose Selection and Use, 11/16/1998 SOG 10, Oconee Nuclear Station, Fire Brigade Operations, Standard OperatingGuideline Number.lO, Fire Brigade Equipment Locations, 4124/2003

,SOG 11, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 11, Hydrogeni Bu~lk Storage, 10/2/2007 SOG 12, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 12, Purging Electric Generator, 12/20/2001 SOG 13, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating. Guideline Number 13, Sprinkler Cross Reference, 9019/2007 SOG 14, Ocornee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 14, Firefighting Foam Carts, 9/18/2007 SOG 15, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 15, Fire Response to C02 Dump, 10/2/2007

- Oconee Page 1 of 3 5/2212008

- ONS - LAR No 2008-0.1 rev B.mdb Transition Tool Version 1.0.5

Table G Radioactive Release Transition Report NFPA 805 Section 1.5.2 Radioactive Release Performance Criteria SOG 16, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 16, Fires Within a RCAIRCZ, 112312008 SOG 6, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 6, Restoring Equipment, 2/27/1997 SOG 5., Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 5., Fires Involving Main Transformers, 2/27/1997 SOG 4, Oconee Nuclear Station. Fire Brigade Operations, Standard Operating Guideline Number 4, Fire Brigade Leadership Guidelines, 2/27/1997 SOG 3, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 3, Electrical Fires, 2(27/1997 SOG 2, Oconee Nuclear Station, Fire Brigade Operations, Standard Operating Guideline Number 2, Staffing Guidelines, 10/25/2005

_ SO-GA._OQne.eudýe~arLtat oi,_FceBngad-Qp;eatton,-

Standard Operating Guideline Number 1, General Response Guidelines, 2/27/1997 SLC 16.11.2, Radiological Effluents Control, 1/31/2000 FAQ 06-0025, Define Minimum Acceptable Pre-Plan Scope, 7119/2007 Oconee Nuclear Site Fire Plan Oconee Page 2 of 3 5/22/2008 ONS - LAR No 2008-01 rev B.mdb Transition Tool Version 1.0.5

Table G RadioactiveRelease Transition Report NFPA 805 Section 1.5.2 Radioactive Release Performance Criteria Radiation release to any unrestricted area due to the direct effects of fire suppression activities (but not involving fuel damage) shall be as low as reasonably achievable and shall not exceed applicable 10 CFR. Part 20, Limits.

Implementing Guidance Appendix G Step 2 Review fire brigade training materials.

Ensure that training materials deal specifically with the containment and monitoring of potentially contaminated fire suppression water.

Update training materials as necessary.

Review Training on radiological release potential is provided in one lesson plan. The Hazardous Materials lesson plan discusses radioactive materials and need for containment of run Off and use of ALARA principles. Other topical lesson plans do not address radiological release boundary control or monitoring. Creation of SOG-16 for fires within a RCA.RCZ requires inclusion into this training.

Unit Applicability 1, 2, and 3 Comments Control and monitoring of potential radiological releases consistent with SOG-16 needs to be incorporated into the initial fire brigade training and continuing curriculum.

Reference Document Document Detail

.. ........-SOG -A 6TOeonee-Nu~ lrJea Station7:FireBrig-ade-Operatidrn, ........ ... .. . ........................... ...... .... ... .. : ....

Standard Operating Guideline Number 16, Fires Within a RCA/RCZ, 1/23/2008 FAQ 06-0025, Define Minimum Acceptable Pre-Plan Scope, 7/19/2007 NGD-FP-01, FIRE BRIGADE ORIENTATION, Rev. 3 NGD-FP-02, FIRE BEHAVIOR AND METHODS OF EXTINGUISHMENT, Rev. 2 NGD-FP-05, FIRE HOSE, NOZZLES, APPLIANCES, AND STREAMS, Rev. 4 SAF-FPr03, PORTABLE FIRE EXTINGUISHERS. Rev. 3 NGD-FB-04, FIRE FIGHTING PERSONAL PROTECTIVE EQUIPMENT (PPE), Rev. 4 NGD-FP-06, FIRE SUPPRESSION AND DETECTION SYSTEMS, Rev. 4 NGD-FP-07, SELF CONTAINED BREATHING APPARATUS (SCBA), Rev. 1 NGD-FP208, INCIDENT COMMAND SYSTEM AND FIRE FIGHTER SAFETY, Rev. 4 NGD-FP-09, FIRE AREA SEARCH AND RESCUE, Rev. 3 NGD-FP-10. VENTILATION ANDDAMAGE CONTROL, Rev.

4 NGD-FP-1 1, INTRODUCTION TO HAZARDOUS MATERIALS, Rev. 2 ONS-FBL, FIRE BRIGADE LEADER TRAINING, Rev. 0 Oconee Page 3 of 3 5/22120018 ONS - LAIR No 2008-01 rev B.mdb Transition Toot Version 1.0,5

CERTIFICATION OF ENGINEERING CALCULATION - REVISION LOG Station And Unit Number Oconee Units. 1, 2 &3 Title Of Calculation NFPA 805 Transition B-1 Table/Report Calculation Number O.C-9295 Active Calculation / Analysis Yes x No EJ Srup ot 1 1" - , , -

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Note 1: When approving a Calculation revision with multiple Originators or Checkers, the Approver need sign only one block.