ML20066B853
| ML20066B853 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 11/03/1982 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 5369N, NUDOCS 8211090216 | |
| Download: ML20066B853 (3) | |
Text
'
N Commonwealth Edison
) one First Nationil PLua, Chicago, Ilknois Address R: ply to: Post Office Box 767 v
Chicago. Illinois 60690 Novembe r 3, 1982 Mr. Harold R.
Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Units 1 and 2 Braidwood Station thits 1 and 2 Volume Reduction System N RC Docke t No s. 50-454, 50-455, 50-456, and 50-457 Re ference (a):
October 4, 1982, letter from
- 8. J. Youngblood to L. O. DelGeo rge.
Dea r Mr. Denton :
This is to provide an advance copy of the response to a Byron /Braidwood FSAR question regarding the volume reduction system.
At tachment A to this letter contains the response to question 321.53.
This response will be incorporated into the FSAR at the earliest opportunity.
One signed original and fifteen copies of this letter and the attachment are provided for your use.
Please eddress further questions to this of fice.
Very i.ruly yours, h
T. R. Tramm RJclear Licensing Administrator 1m AttachmeMt 1
Y Q
5369N i' 8211090216 821103
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l PDR ADOCK 05000454
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ATTACHMENT A Question 321.53 "Your response to Questions 321.43 states that you are unaware of any federal, state, or local agency approvals or permits that are necessary to construct or operate the volume reduction system.
It is our understanding that all incinerators, require a permit from the Illinois Environmental Protection Agency and that under Rule 203. (e). (4) all new incinerator-r are limited to 0.1 grains per SCFM corrected to 12% C0. opacity limits as 7
stated in Rule 202, and to CD emissions of 500 ppm when cor-rected to 50% excess air.
Please address your conclusion that additional permits or approvals are not required and address the capability o f the gasecus e ffluents to meet the above limitations for stationary sp m 6es."
Response
-sihli ation will be made to the Illinois Environmental Protec-tion Agency for incinerator operating permits for the Byron and Braidwood volume reduction systems (VRS).
Ho weve r, it is our position that the VRS with its evaporators, scrubbers and two high ef ficiency and one charcoal filter is not a conventional incinerator and does not need a permit.
Comparison of emissions from the VRS system to the emission limits contained in current State o f Illinois Air Pollution Control Regulations, are shown on Table 351.53.. The emission limts in the regulations are for exhaust into the atmosphere which, in this case, is the Unit 2 ventilation exhaust stack with a discharge of 229,440 CFM.
The VRS has an exhaust of 466 SCFM.
The comparison shows that particulate emissions due to the VRS are over 8 orders of magnitude less than the limit and the carbon monoxide emissions are over 3 orders o f magnitude less than the limit.
It is assumed that the opacity " Rules 202(a) and 202(b) shall not apply if it is shown that the emission source was, at the time of such emission, in compliance with the mass emission limitation o f Rule 203. "
Since the mass flow is over 8 orders of magnitude less than the limits of Rule 203, one can predict with confidence compliance with the opacity rule.
The response to Question 321.43 will be revised to conform to this response.
5369N
r Table 321.53 Comparison of Volume Reduction System Air Emissions to Emission Limitation for Incinerators Emission (i)
At VRS At Building Criteria Limit Exhaust Exhaust Particulate Emissions -
Grains per Standard Cubic 0.1 gr 0.107x10-kr 2.17x10-kr Feet p% CO Rule 203(e)(4) er Minute corrected to 12 2
Opacity limits -
30%
0(2)
O(2)
Rule 202(b)
Emissions of carbon 500 ppm 129 ppm 0.262 ppm monoxide into the atmosphere (corrected to 50% excess air)
Rule 206(b)
(i Emission limits are for exhaust to the atmosphere.
(2) Rule 202(c)(3) states " Rules 202(a) and 202(b) shall not apply if it is shown that the emission source was, at the time of such emiss. ion, in compliance with the = ass emission limitation of Rule 203.
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