ML20054E760
| ML20054E760 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/07/1982 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20054E730 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8206140165 | |
| Download: ML20054E760 (8) | |
Text
1 t
UNITED STATFS OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of
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)
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COMMONWEALTII EDISON COMPANY
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Docket Nos. 50-454 OL
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50-455 OL
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(Byron Nuclear Power Station, )
Units 1 & 2)
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AFFIDAVIT OF TOM TRMiM The attached questions and answers constitute my testimony in the above-captioned proceeding.
The testimony is true and accurate to the best of my knowledge, information and belief.
["
Tom Tramm Subscribed and sy r to befor,p me this day.
of U;' t ett_, 1982.
',Q h ' t u t c c.i/- A cr<u Notary Pdblic
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J 9206140165 820607 PDR ADOCK 05000454 Q
b TESTIMONY OF TOM-TRAMM
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ON DAARE/ SAFE CONTENTION 7 Q.
Please state your name, present occupation and present position.
A.
My name is Tom Tramm, I am a Nuclear Licensing Admini-strator for Commonwealth Edison.
Q.
Briefly state your educational and professional back-ground.
A.
I received a Bachelors degree in Engineering Science from Purdue University in 1968 and a Masters degree in
. Nuclear Engineering from Northwestern University in 1973.
Since 1968 I have been employed by Common-wealth Edison in various capacities relating to the design and operation of its generating stations.
From 1968 to 1972 I performed reactor physics calculations and economic analyses required for re-loading of the Dresden 1 core.
From 1972 to 1973 I was a staff assistant to the President of Commonwealth Edison and was involved in the activities of obtaining and maintaining permits and licenses for the Company's nuclear generating stations.
From 1973 to 1975 I worked at Zion Station as an engineer responsible for trouble-shooting, special test supervision, and modifi-cation of the primary coolant systems and the associated safety equipment.
From 1975 to 1976 I was assigned O
N to the Fuel Department where I coordinated the purchase l
of uranium, conversion services, separative work, and fabrication of fuel for Commonwealth Edison's reactors.
In 1976 I was assigned to the Station Nuclear Engineer-ing Department to work on modifications and engineering studies for Zion Station.
From 1977 to 1980 I was the head of the group of engineers responsible for that work.
In 1980 I became the Nuclear Licensing Admini-strator for Commonwealth Edison's pressurized water reactors.
Q.
Describe your duties and responsibilities in connection-with the Byron /Braidwood project.
A.
I am responsible for coordinating communications between the Company and the NRC regarding the licensing of Byron and Braidwood Stations.
I provide guidance to Company personnel regarding the implementation of NRC requirements.
I respond on behalf of the Company to all NRC requests regarding these plants.
When new rules are issued by the NRC I assure that they are reviewed by the appropriate Company departments and that all necessary steps are taken to assure compliance.
Q.
To which contention is.this testimony addressed?
A.
DAARE/ SAFE Contention 7.
The text of the contention is as follows:
The Intervenor contends that the FSAR and Applicant offer insufficient safeguards against hydrogen explosions, such as are alleged to have occurred at Three Mile Island Reactor 2.
There
ai
.. is no evidence that the recombiners for taking up pJ hydrogen would be adequate if circumstances similar to those at.TMI 2 should occur at Byron.
s-Q.
Please describe the Byron Station containments.
A.
There are two Westinghouse pressurized water reactors-at Byron.
Each reactor is located in a separate con-tainment structure.
These structures are designed to contain the bulk of the fission products which would be released if the fuel cladding and the primary coolant system were both breached.
These are characterized as large dry containments because they do not rely on water or ice to immediately absorb energy released in a LOCA or secondary side pipe break.
Q.
Are you aware that the NRC has proposed new rules on hydrogen control which would apply to Byron?
A.
Yes.
On December. 23, 1981 the NRC published a proposed interim rule which would require analysis of reactors such as Byron to demonstrate that.they could " withstand an accident with the concomitant generation of large amounts of hydrogen such as the type which occurred.at
... TMI-2."
Q.
Will Edison comply with new regulatory requirements per-taining to hydrogen control / generation matters applicable to the Byron Station.
A.
Yes, that is Edison's present intent.
O
e DAARE/ SAFE CONTENTIONS 8 AND 9 (e)
CONTENTION 8 Intervenors contend that Applicant does not meet the requirements of 10 C.F.R. Part 51.21 and 51.20(a),
(1 and 2); (b), (c) because no consideration is given the environmental impact of primary coolant system chemical decontamination and steam generator chemical cleaning which the Department of Energy has determined will occur twice during the lifetime of a nuclear power plant.
Recent data raise the possibility of serious adverse consequences of the decontamination process.
Chelating agents, intended for the removal of highly radioactive corrosion products adherent to the coolant system surfaces, sharply increase the rate of migration of these same radioactive products through the envir-onment and into the food chain.
No analysis or dis-cussion is given possible biological consequences to the accidental spillage during decontamination, waste storage, transportation or disposal (on or off-site).-
CONTENTION 9 (e)
Intervenors contend that there are many unresolved safety problems with clear health and safety implica-tions and which are demonstrably applicable to the Byron Station design, but are not dealt with adequately in the FSAR.
These issues include but are not limited to:
The process of chemical decontamination may ex-e.
acerbate safety problems through a degradation of the integrity of the primary coolant system boundary.
Such degradation may occur during the process of decontamination or during subsequent operation of the reactor.
Also, chemical solution decontamination may add to the deposition of radioactive corrcsive products, according to an NRC official.
Decontamination is not discussed in Applicant's FSAR or EROL.
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MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD 1.
No particular method of decontamination has been proposed for the Byron Station.
(Blomgren Affidavit, p. 5.)
2.
No significant liquid or gaseous radioactive effluents are expected to be released to the environment in the event of chemical decontamination of the Byron Station.
(Blomgren Affidavit, p.
4-5.)
3.
The amount of solid low level radioactive wastes gen-erated during chemical decontamination would be small compared to the amount of solid waste generated during routine operation of the Byron Station. (Blomgren Affidavit, p. 10.)
4.
Reported instances of chelating agents increasing the rate at which radioactive' wastes have migrated from waste disposal sites involved radioactive wastes containing chelants disposed of as a liquid.
(Blomgren Affidavit,
- p. 6.)
5.
Radioactive wastes containing chelants can be solid-ified in steel drums with polymers and buried at an arid site to eliminate the potential problem of rapid migration through ground water.
(Blomgren Affidavit, p.
7-8.)
6.
Chelating agents themselves pose no threat to the environment.
(Blomgren Affidavit, p. 9.)
7.
The presence of chelants in low level wastes pose no special problem during chemical cleaning or the pro-()
cessing and shipping of wastes for disposal.
(Blomgren 8-2 l _
J
Affidavit, p. 9-ll.).
()'
8.
The total impacts associated with chemical decontam-ination would be a very small fraction of radiological impact of routine operation of the Byron Station.
(Blomgren Affidavit, p. 5.)
9.
There are currently available methods of chemical decontamination which would effectively clean the Byron system without adversely affecting the integrity of the system.
(Blomgren Affidavit, p. 13.)
10.
Prior to any chemical decontamination of the Byron primary coolant system, testing would be performed to verify that the method selected would be effective to clean the system and would not be detrimental to the integrity of the system.
(Blomgren Affidavit, p. 13.)
11.
The act of decontamination would not increase the depo-sition of radioactive corrosion products in the Byron Station primary coola.t system.
(Blomgren Affidavit, p.
14-15.)
DISCUSSION In Contentions 8 and 9(e) DAARE and SAFE purport to raise issues regarding the environmental effects of chemical decontamination of the Byron Station primary coolant system, and Applicant's ability to perform such chemical decontamin-ation without degrading the integrity of the system.
These Contentions are related and the material facts necessary to their disposition overlap.
Consequently, we address both Contentions in this discussion.
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The Byron primary coolant system may not even require chemical cleaning.
If decontamination is required, tech-O niques currently exist for which the total environmental impact of chemical decontamination would be a small fraction of the radiological environmental impact of routine operation of the Byron Station.
According to the NRC Staff, the radiological impact of routine operation of the Byron Station itself is so small that it does not warrant detailed inves-tigation or consideration of mitigative actions.
(SER Table 6.1 and footnote 3 thereto.)
DAARE and SAFE have indicated they do not intend to sponsor an expert witness on Conten-tion 8 and therefore the insignificant environmental impacts of chemical decontamination, in the event it is ever needed at Byron, can be weighed by the Board based on the infor-mation available in the attached affidavit without any need for evidentiary hearings.
The affidavit of Mr. Blomgren also establishes that ex-isting technology could be utilized to chemically clean the Byron primary coolant system effectively and without adversely affecting the integrity of the system.
These uncontroverted facts provide reasonable assurance that if chemical cleaning is required for the Byron Station, it can be performed with-out adversely affecting the health and safety of the public.
The above-listed and adequately supported facts are not dis-puted and demonstrate that Applicant is entitled as a matter of law to a favorable decision on these Contentions.
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