ML20040F876
| ML20040F876 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/22/1982 |
| From: | Gustafson P ILLINOIS, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0848, RTR-NUREG-848 NUDOCS 8202100414 | |
| Download: ML20040F876 (2) | |
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Illinois Department of %uclear Safety Q. *
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1035 Outer Park Drive t-
'ngfield, Illinois 62704 (217)546-8100 Philip F. Gustafson s
e3 Jane A. Bolin w Din <tm g.-.y g FEB 91982P_
tv a r::m an m=u Ti N 7" g January 22, 1982 Q
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Director, Division of Licensing Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission Washington, D.C.
20555 RE: Draft Environmental Statement Related to the Operation of, Byron Station, Units 1 & 2 (NUREG-0848), Operating License Stage.
(Docket No.s STN 50-454 and STN 50-455)
Dear Sir:
After review of the subject document, the following comments and questions are directed to your attention:
A.
Circulating Water and Non-Essential Service Water Systems -
Section 4 - 2.3.4.1 This section indicates that sponge rubber Es11s will be used to wipe the condenser tubes clean of biological growths as an aid to biofouling control. What analysis has been performed examining the affects of the introduction of these sponge rubber balls into both the Rock River via normal blowdown and into the pumping and internal system of the natural draft cooling tower? How does this system compare to that system already in use at the Zion Nuclear Power Station?
B.
Radioactive-Waste Management System -
Section 4.2.5 Item 3 in this section indicates a change in the design of the ventila-tion system filtration path for the main condenser air ejector and auxiliary fuel and waste buildings' discharge exhausts. This design change, since the construction stage permit, utilizes only a HEPA filter.
The nov design does allow the discharge paths to be diverted, presumably by operator action, to a path containing a HEPA filter, charcoal adsorber and another HEPA filter, all in series, if a high radiation signal is present.
In Section 5.9.4.4, " Mitigation of Accident Consequences", it appears that credit is taken for the use of the former design ventilation pathway of a direct filter-adsorber-filter series. What controls, commit-ments, equipment qualification or technical specification requirements 9202100414 820122 gdd DR ADOCK 05000 g
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Pag; 2 will be imposed to assure that the rediverting actions are taken for mitigation of accident consequences?
C.
Radiological - Section 5.9 (1) Section 5.9.1 discusses the Regulatory requirements used in the assessments for protection against indiation. The present version of 10CFR20 is cited, but what consideration or assessments have been made for this evaluation in light of the proposed revision of 10CFR207 (2) This section discusses the radiological aspects of normal operation and accident conditions, risks, impacts and probabilistic assessments.
Commonwealth Edison Company operates Zion Nuclear Power Station, another very similar PWR, as well as other nucicar plants. How have the operating experiences, including accidental radioactive releases, safety systems out of service, licensee event reparts and abnormal occurrences been included in the development of the assessments made in this section?
What emphasis has been placed on this more realistic information versus other older theoretical references utilized within the section?
(3)
In some of the cases analyzed in Section 5.9.4.5, " Accident Risk and Impact Assessment", the staff judges that some of the calculated results are over estimates of the consequences related to nuclear accidents, rather than under estimates. The staff also indicates that the uncertainties and error bounds may be as large as the probabilities themselves. Clarification of these combined positions is needed if realistic values for the impacts given are to be considered acceptable.
(4)
Sections 5.9.4.4, " Mitigation of Accident Consequences", and 5.9.4.5., " Accident Risk and Impact Assessment" indicate that this report does not take credit for the TMI-2 related requirements specified in NUREG-0737 and NUREG 0660, which apply to the Byron Station.
Please provide a brief synopsis of the applicable requirements and a schedule for completion.
(5) Section 5.9.4.5, " Accident Risk and Impact Assessment", indicates I
that sequences initiated by natural phenomena, such as a seismic event, l
are not included in the event sequences being evaluated. The staff also indicates this, as well as other natural phenomena effects, would not contribute sigificantly to risk. The Safe Shutdown Earthquake is normally considered to be a design basis event, for which a great deal of design analysis, qualification, and other special concerns at lease equivalent to l
the pipe break analyses, has been performed. Further discussion should be included in this seerion to support the judgement of the staff for at least i
the seismic events.
Thank you for the opportunity to review the Byron Station Draft Environmental Statement - Operating License Stage. Your consideration of the above comments is appr:ciated.
l Sincerely, j-WJ t
Philip F. Gustafson, Director Illinois Dept. of Nuclear Safety PFG:RWD:jt
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